ML20078S067

Forwards Excerpt from Minutes of Plant Operations Review Committee Meeting 538,per 831012 IE Enforcement Conference Commitments.Operability Test Criteria Per Operations Order 83-19 Acceptable.Commitments Satisfied

ML20078S067
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/26/1983
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-83349, NUDOCS 8311150381
Download: ML20078S067 (7)

Text

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g1 public Service Company @ OdcMe 16805 WCR 19 1/2, Platteville, Colorado 80651 October 26, 1983 Fort St. Vrain Unit #1 P-83349 b Mr. John T. Collins '

Regional Administrator '

nbV ti FG i,. Reg?on IV a Nuclaar Regulatory Commission ._ d 611 f.yan Plaza Dr., Suite 1000 m..

- Arlington, TX 76011

SUBJECT:

Enforcement Conference

, Commitments

REFERENCE:

NRC Letter Dated October 13, 1983

, JTC to ORL (G-83362)

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Dear Mr. Collins:

fn an Enforcement Conference on October 12, 1983, in Arlington,

,', Texas, Public Service Company of Colorado committed to provide the NRC, Region IV, with the results of the Fort St. Vrain Plant Operations Review Committee's (PORC) determination regarding the length of time that an emergency diesel generator should be operated to prove operability] Attached is an excerpt from the minutes of PORC meeting number 538 wherein PORC reviewed Operations' Order Number 83-19 (attached) which fulfills, all three commitments contained in G-83362. PORC reviewed the " Operability Test" provision contained in Operations' Order 83-19 and concurred with the operability test criteria as written in the Operations' Order.

Subsequent to the PORC review, Operations' Order 83-19 was issued effective October 14, 1983. Operations' Order 83-19 will remain in effect until the revisions to electrical portions of the Technical Specifications are revised which will occur during the upcoming refueling outage. Items one through three of G-83362 are included in the Operations' Order thereby closing out the commitments made at the Enforcement Conference on October 12, 1983.

Ohho$oo8lj7 g PM i 9,

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e If you have any questions regarding this letter or the attachments hereto please contact Mr. L. M. McBride at (303) 785-2223.

Very truly yours,

~ /Y Wwun8 Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DW/dje Attachmants

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. 1 Reconvened, Thursday, October 13, 1983 The meeting was reconvened at 2:30 p.m. by Chairman M. McBride with members C. Fuller, F. Novachek, B. Burchfield and J. Van Dyke present. Mr. G. L. Plumlee, III, NRC Senior Resident Inspector, Mr.

Mike Niehoff, NED Site Manager and Mr. Richard Craun, NED Site Engineering Supervisor were in attendance as Observers. At 3:15 p.m.

T. Borst replaced C. Fuller as a member.

The matter under consideration was a proposed Operations Order 83-19 (attached) which will be issued effective 10-14-83 to define actions to be taken by the Operations staff in the event that an Emergency Diesel Generator set is determined to be inoperable.

The Operations Order 83-19 is the result of commitments made to the NRC, Region IV, at an Enforcement Conference meeting on October 12, 1983, as stated in the attached letter (G-83362).

The Committee reviewed Operations Order 83-19 and adde 1 clarification phrases where necessary to aid the Operations staff implementing the Operations Order. The Plant Operations Re.' Committee concurred with the Operations Order as revised by tt ; Committee members and further determined that the length of time for a diesel generator to be operated in order to prove operability was the length

.of time required for the diesel generator to start, and accelerate to normal operating speed which is comparable to t M criteria specified in the Westinghouse Standard Technical Specifications. Mr. Rick Craun, NED Site Engineering Supervisor, had consulted with the diesel manufacturer prior to the meeting and stated that the manufacturer had concurred with the operability test as so specified.

The Committee discussed at some length the consequences of placing the mode switch in " parallel" mode fo- the diesel generator set to be

-tested for operability given that tne remaining diesel generator set has been declared inoperable. One of the members did not feel that such a test was necessary to prove operability of the second diesel because the set had been proven operable by the previous surveillance test and, within the one week surveillance interval, a diesel generator set is considered operable by the Technical Specifications.

Also of concern was the fact that, for the interval that the second diesel set is in the " parallel" mode, a loss of outside power and turbine trip would result in a total loss of power until tha diesel generator set could be manually loaded because the diesel will not perform its automatic start, automatic load shed and automatic load p ogramming functions unless the switch is in the " independent" mode, w

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Such a condition could result, in the worst case, in a loss of forced circulation until the diesel generator set could be manually loaded.

The definition of an operable diesel under the conditions set forth in LCO 4.6.1, Section d, Part 3 are not met during the operability test. However, for reporting purposes, Section 7.5.2, Part b, Article 2 and its accompanying note allows such a system configuration for the purposes of routine surveillance testing, instrument calibration or preventive maintenance which could be construed to be the case for the purposes of the operability test.

Finally, the time interval involved to prove operability of the second diesel generator set is minimal because operability is proven without applying load to the generator, hence proof of operability could be accomplished in approximately thirty minutes.

The Committee concurred with the issuance of the Operations Order, but found it to be Safety Significant in that the Operations Order represents a change in the interpretation of the applicable Technical Specifications regarding the requirement to test the second emergency diesel. In the literal sense, an interpretation does not represent a change to the Technical Specifications but the Committee felt that the NFSC 'should be made aware of the change in interpretation and therefore declared the Operations Order to be Safety Significant to provide a vehicle for ensuring NFSC review. Operations Order 83-19 is not an unreviewed safety question.

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Page 1 NUM.BER #83-19 ISSUE 2 g3 OATE poac 53B SYSTEM Administrative OPERATIONS ORDER ATTENTION:

lXXXXXXl lXXXXXXl [XXXXXXl l l l l l l l l l I SS R0 EO AT Note:

Initial when order is read f

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As a result of the PSC-NRC meeting concerning diesel generator operability testing requirements, the following actions are to be implemented immediately:

CASE 1 - Known, future inoperability_

When it is known beforehand that a diesel generator is going to be made inoperable (for example, for lobe oil changeout or other preventive mainter.ance), then p ri g.r, to making that diesel generator set inoperable, the other diesel generator set must be demonstrated to be operable. This demonstration shall be cer the below cited operability test or SR 5.6.la-W and must be corrpleted within _orie_(1)_ hour of declaring the first diesel generator set inoperable.

Pago 2 NUMBER #83-19 ISSUE 2 DATE 1 0983 FORC SYSTEM Administrative S

This criteria is consistent with our past understanding of LCO 4.6.1, with the additional guidance that "immediately prior" has been defined to mean "no more than one hour."

CASE 2 - Diesel generator set "found" inoperable This case applies to the situation where, for some reason, it is dGermined that one diesel generator set is inoperable. For example, this case applies to conditions such as: observed overheating or vibration of a diesel generator set during routine surveillance testing, failure of a diesel generator to start on demand, automatic tripping of a diesel genera tor set while running, etc. The following scenarios apply:

a) One diesel generator set is "found" inoperable, and operability of the other diesel generator set has been confirmed within the previous eight (8) hours of declaring the first set inoperable.

Action Required - None. Since the operability of the second set had very recently been confirmed, it can be assumed to be operable.

I l i b) One diesel generator set is "found" inoperable, and l operability of the other diesel generator set has not been l confirmed within the previous eight (8) hours of declaring l the first set inoperable.

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Action Required - The operability of the second diesel generator set must be confirmed by the successful completion of the operability test cited below or SR 5.6.la-W. The second diesel generator set must be started within one (1) hour after declaring the first set inoperable.

CASE 3 - Two diesel __. generator sets inop_erable simultaneously If, at any time, both diesel generator sets are determined to be inoperable simultaneously, the reactor shall be in a shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

CASE 4 - Routine oil _ clean-up of diesel generator set _

It is permissible to defeat the automatic starting feature of one diesel oenerato_r_ set at a time (for the purposes of diesel l generator oil cleanup only) by going to the " parallel" mode, without demonstrating the prior operability of the second diesel generator set provided that:

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Page 3 NUMBER #83-19 a -

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ISSUE 2 DATE Poac 5 3 3 g l'31983 SYSTEM Administrative

1) A clearance tag issued to the Shift Supervisor may be placed on the independent mode switch for the purpose of  !

,ccomplishing oil cleanup. '

2) The Station Log has a log entry of the time when the switch l

l. was placed into the " parallel" mode.

3) The Station Log has a log entry of the time when the switch l was returned to the " independent" mode.

4) The time interval used is entered in the Shift Supervisors diesel generator log and is countec' against the seven days per month inoperability allowed by LCO 4.6.1.

In the event that the Shift Supervisor chooses to tag-out the diesel generator set using a more complex clearance in order to accomplish the oil clean-up, then the diesel generator set is, by definition, going 'o be made inoperable.

. Therefore, the operability test or SR 5.6.la-W for the other diesel generator set must be completed during the one (1) hour prior to making the first diesel generator set inoperable. Again, the times of inoperability must be entered in the log, and must be counted against the seven days per month of inoperability allowed by LCO

4.6.1.

Operability Test Verify the diesel generator starts and accelerates to normal operating speed. The generator voltage and frequency shall be 480 plus or minus 48 volts and 60 plus or minus 1.2 Hz. After this verification the diesel generator set shall be shut down, and its controis returned to the automatic mode.

SR 5.6.la-W, or the operability test sited above, rtay be used to demonstrate diesel generator operability but in no say supercedes the routine operating capability testing required by SR 5.6.1.

The- Shift Supervisors are instructed to direct any question concerning these testing requirements to the Superintendent of Operations or the Station Manager.

Wh fl?lC L h Superintendent, Operations (or) Station Manager u