Text

Proposed Tech Specs Re Method of Verifying DG Hot Restart Capability
	ML20101F135
Person / Time
Site:	Seabrook
Issue date:	06/19/1992
From:	; PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	;
Shared Package
ML20101F107	List: ML20101F104; ML20101F123; ML20101F135;
References
	NUDOCS 9206240294
	Download: ML20101F135 (18)
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Aturkup vf Proposed Gunnes See attached snarkup of proposed changes to Technical Specificallons.

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L L tt l R H AL r'UWL K b T h i t N)

_AiC.'SOURG11 EfMUM SURVElllANCE RE0VIR[MENTS l

4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class lE Distribution System shall be:

a.

Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability, and b.

Demonstrated OPERABLE at least once per 18 months during shutdown by transferring (manually and automatically) unit power supply from the normal circuit to the alternate circuit.

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.2 Each diesel generator shall be demonstrated OPERABLE:

n.

In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:

1)

Verifying the fuel level in the day fuel tank; 2)

Verifying the fuel level in the fuel storage tank; 3)

Verifying the fuel transfer pump starts and transfers fuel from the storage system to the day tank; 4)

Verifying the lubricating oil inventory in storage; s%a%

5)

Verifying the diesel starts from Mnditionband accelerages to at least 514 rpm in less than or equal to 10 seconds. The generator voltage and frequency shall be e

4160 1 420 volts and 60 1 1.2 Hz within 10 seconds -after the start signal. The diesel generator shsil be started for this test by using one of the following signals:

a)

Manual, or b)

Simulated loss-of-offsite power by itself, or

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oAll die 1 gene ator starts for t/e purpose [f this su veillance test may be preced by_a ngine p elube peytod.

Furt er, all s rveillanc tests' hd all o er eng' e start for thejpurpose of this sury illance t ting, th the

-exce ion of once per 184 days may also e preced by warmu proced (e.., grad' al acctl ration

d/or grad al loadinp/e n 60 se'y es greater t conds)as mmendef by the,anufactu er so tha the mech,anical stre s and wear on the re di sel engine is. nimized p

SEABROOK UNIT 1 3/483 1 All plaud sfaris he n. ppm of Mese rw v e,Wa<r ny 6e p r u <.k/

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fLECTRICAL PQWER SYS_TEMS, C SOURCE 1

.0L'ERATING

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SURVEILLANCE REOUIREMENTS 4,8.1.1.2 (Continued) c)

Sinulated loss-of-offsite power in t.onjunction with an SI Actuation test sign 41, or i

d)

An 51 Actuation test signal by itstlf.

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Verif/ingtne9,enerator}ssynchronized-Joadedt,ogrpater N

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4 thap'or equal'40 6083 kV in lest than cyequal it) 12.0 seionds*, and operate /with af oad g7 ter than or% qual to l

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~d083 Qf,o{at least'60 minutep:_and

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Verifyic,9 the diesel generator is aligned to provide standby power to the associated emergency bu:,ses.

b.

At least once per 31 days and after each operation of the diesel where the period 'of operation was greater than or equal to I hour by checking for and removing accumulated water from the day fuel i

tank; o

c.

At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks; d,

By sampling new fuel oil in accordance with ASTM-04057-81 prior to addition to storage tanki and:

1) dy verifyinc in accordance with the tests specified in ASTM-0975-81 prior u addition to the storage tanks that the sample has:

a)

An API Gravity of within 0.3 degree at 60'F, or a specific gravity of within 0,0016 at 60/60'F, when compared to the supplier 's certificate,-or an absolute specific gravity at 60/60'E of greater than or equal to 0,81 but less than or equal to 0.89, or an API gravity of greater than or equal to 28 degrees but less than or equal to 42 degrees; g)d 1% cct ?

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,,. Mall diespl generator sta s for ho purppse of this surveil]ance test may be x

preceded by an engtarts/for thc/purpo,sy'further, di surveil)lange tests an ir,e pr lube p riod i

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all ot)fer engine s of this furveillan4e tpsting, with the i

exception of ong,e per }BS days; may al,so be prqceded by w/r than 60 seco 4rmup procedures (e.g., gradual /

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rect)mmended by/ acceler'ation af /or gy dual loa, ding greatthe ma'nufacturer to

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SEABROOVs - UNIT 1 3/4 8-4

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Insert'1.

n iifying the generator-is synchronized, loaded to greater'than or equal

.a 560D kW and Jess than or equal to 6100-kW**, and operates with -a load greater than or equal _to 5600 kW and less than or equal to 6100 kV for at least 60 minutest and Insert-2.

- Diesel generator loading may be in accordance with manufacturers recotomendations, including a warmup period.

The load range is provided to preclude routine overloading of the diesel generator. Momentary transients outside the load range, due to changing bus conditions, do not invalidate the test i,

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AK.-C,DSOURCESS-l0ffRAYING SURVEILLANCE RE001REMENTS

4. 8.1.'l. 2 (Continued) a)

Verifying deenergization of the emergency busses and load shedding from the emergency busses, and,

6 5 64 =osdhns, b)

Verifying the diesel startsVon the loss of offsite power signal, crergizes the emergency busses with permane,tly connected loads within 12 seconds,

- energizes the autoconnected shutdown loads through the 4

emergency power sequencer and operates'for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 1 420 volts and 60_i 1.2 Hz during this test.

c,e n sh.Ap eendsk s, Verifying that on.an Si actuation test signal,k%s on the 5) hout loss-of-offsite power, the diesel generator start auto-start signal and operates on standby for greater than or equal to 5 minutes,. The generator voltage and frequency shall be 41G0 i 420 volts and 6011.2 Hz within 10 seconds after the auto-start signal; the steady-state' generator voltage and frequency shall be maintained within these limit during this test;

'6)

Simulating a loss-of-offsite power in conjunction with an Si actuation test signal; and e

a):

Verifying deenergization of the emergency busses and lead shedding from the emergency busses;

.fm s kdH ce sdshch s, b)

Verifying the diesel starts on the auto-start signal, v

energin s the emergency busses with permanently connected loads within 10 seconds, energizes the o

L auto-contactrd emergency (accident) loads through the k

eaargency pm sequencer and operates for greater than L

or equal-_to 6 minutes while its generator is loaded L-with t!A emergency leadL After energization, the L

steedysstato Vtap and frequency of the emergency

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bustes shall b~e maintained at 4160 1 420 volts and

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60_'i.l.2 Hz during this test; and c)

Verifying that, all wtomatic diesel generator trips,

except engine tv9rspeed, low lube oil pressure, 4160-volt hus fault, and generator differential, are automatically bypssed upon loss of voltage on the emergency bus concurrent with a Safety Injection actuation signal.

SEABROOK - JNIT I 3/48-6 r

ELECTRICAL-POWER SYSTEMS-A1,_ SOURCES

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-SURVEILLANCE RE0VIREMENTS 7'J 4.8.1.1.2- (Continued)

'N Verifying /the.diese) generator opefi ates for at lepst 24 7)

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hours, ring the/first 2. Aours o this test, the diesel f and dur ng the re'maining 22 ho_ur9 of thi[s test / the dies 6 generato shall be loaded Ao greaper tha or eq(al to 6697 kW L<d 3 b

_generattor shall/ e loaded to greater try'an or (qual to 6083

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kW. The generator voltdge and freque ey sha)1 be 416Cy'i 420 volts /and60t'l.2HzAlthin}0seco s after the start signal; the steady-s hte generator v ltage/and freq/u4ncyithin the shal/l be mai tained Within 5 mi utes af, er completing /(his 2(-hour test, perform j

Specificat n 4.8.4.1,2 f. 6)b) ; *

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8).

Verifying that the auto-connected loads to each diesel generator do not exceed the short time rating of 6697 kW; 9)-

Verifying the diesel generator's capability to:

a)

Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b)

Transfer its loads to the offsite power source, and

c)

-Be restored to its standby status.

10) ~

Verifying that with the diesel generator operating in a test mode, connected to_ its bus, a_ simulated Safety Injection signal cierrides the _ test mode by: (1) returning the diesel

_ generator to standby operation,_and (2) automatically-energizing the emergency _ loads with offsite power; Verifying that the fuel transfer pump transfers fuel from 11)

~each fuel storage tank to the day tank of each diesel via the installed cross-connection lines; 12)

Verifying that the emergency power sequence timer is OPERABLE with the interval between each load block within t 10% of its design interval;

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'[*necejrsary tq' repeat /the pIf Sppti ficat40n 4.8 'l. l. 2 6)b) is not sa isfactof

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f ceding 4-hour test. Jnstead he digsel.g'enerator may/beope/atedat/6083) for 1, our o until operating emperature/has stabilized.

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,SEABROOK - UNIT 1 3/4 8-7

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7)

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Durirg the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the diesel generator shall be 6?00.rW.** greater than or equal to 6300 kW and less than or equal to loaded to During the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel c.anerator shall be loaded to greater ttan or equal to 5600 kW and Iess than or equal to 6100 kW. The generator voltage and frequency-thall te 4160 2 420 volts and 60 t 1,2 Hz within 10 seconds after the start signal; the steady-state generator voltage and frequency

hall bwmaintained within these limits during this test. Within 5 rinutes after completing this 24-hour test, verify that the diesel generato? starts on a manual or auto start signal, attains cenerator valtage and frequency of 4160 1 420 volts and 6011.2 Hz wTthin 10 seconds, and operates for longer than 5 minutes.***

Insert 4.

- Diesel generator loading may be in accordance with manufacturers recommendations, in(luding c warmup period. The load range is provided to preclude routine overloading'of tha diesel generator. Momentary transients outside the load range, due to changing bus conditions, do not invalidate the test

- - If'the diesel generator f ails to start during this test, then it is not necessary to repeat the preceding 24. hour test.

Instead, the diesel generator may be operated at greater than or equal to 5600 kW and less than or equal to 6100 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperature has stabilized.

The load' range is provided to preclude routine overloadinc of the diesel generator. Momentary transients outside the load range, iue to changing bus

-conditions, do not irvalidate the test d

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.a III.

Itetine of Proposed Chances See attached retype of proposed changes to Technical Specifications. The attached retype reflects the currently issued version of Technical Specifications.

Pending Technical. Specification changes or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with-Technical Specifications prior to issuance.

Revision bars are provided in the-right hand margin to indicate a revision to text.

No revision bars are utilized when the page is changed solely to accommodate the shifting of text due to additions or deletions.

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ELECTRICAL POWER SYSTEMS LA.C; SOURCES OPERATING

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SVRVEILLANCE RE0VIREMENTS 1

4.8.1.1.11 Each of the above required independent circuits between the offsite transmission network and the onsite Class lE Distribution System shall be:

a.

Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability, and b.

Demonstrated 0PERABLE at least once per 18 months during shutdown by-transferring (manually and automatically) unit power supply from the normal circuit to the alternate circuit.

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE *:

a.

In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:

1)

Verifying the fuel level in the day fuel tank; 2)

Verifying the fuel level in the fuel storage tank; 4

3)

. Verifying the fuel transfer pump starts and transfers fuel from the_stwage system to the day tank; 4)

Verifying the lubricating oil inventory in storage; t

5)

Verifying the diesel starts from standby conditions and accelerates to at least 514 rpm in less than or equal to 10 seconds.

The generator voltage and frequency shall be 4160 1 420 volts and 60 i 1,2-Hz within 10' seconds after the start signal. The diesel generator shall be started for this test by using one of the following signals:

a)

Manual, or 1

b)

Simulated loss-of-offsite power by itself, or

All planned starts for the purpose of these surveillances may be preceded by an engine prelube period.

SEABROOK UNIT 11 3/4 8-3 Amendment No.

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-fLECTRICAL POWER' SYSTEMS

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'A.C.-SOURCES OPERATING-SVRVElllANCE RE0VIREMENTS 4.8;1.1.2- (Continued) c)

Simulated loss-of-offsite power in conjunction with an SI Actuation test signal, or d)

An-Si Actuation test signal by itself.

6)

Verifying. the generator is synchronized, loaded to greater than or equal to-5600 kW and less than or equal to 6100 kW**,

and operates with a load greater than or equal to 5600 kW and less than or equal to 6100 kW for at least 60 minutes; and 7)

Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

b.

At least once.per:31 days and after each operation of the diesel where the period of operation was greater than or equal to I hour 4

by checking for and removing accumulated water from the day fuel tank; c.

-At-least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks; d.

By sampling new fuel oil in accordance with ASTM-04057-81 prior to addition _to storage tanks and:

1)-

By verifying in accordance with the te.sts specified in ASTM-D975-81 prior to addition to the storage tanks _that the sample has:

a)

An API Gravity of within 0.3 degree at 60*F, or-a specific gravity of within 0.0016 at 60/60*F, when compared to the-supplier's certificate, or an absolute specific gravity at 60/60*F of greater than or equal to 0.81-but less than or equal-to 0.89, or an API gravity of greater than or equal to 28 degrees but less_ than or equal to 42 degrees;

- Diesel generator loading may be in accordance with manufacturers recommendations, including a__ warmup period.

The load range is provided to preclude routine overloading of the diesel generator. Momentary transients outside the. load range, due to char.ging bus conditions, do not invalidate the L

test.

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SEABROOK - UNIT 1 3/4 8-4 Amendment No.

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- ELECTRICAL POWER SYSTEMS -

A.C' SOURCES OPERATING p

SURVEILLANCE RE@lR. EMENTS L

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-4.8.1.1.2 (Continued)

I a)

Verifying deenergization of the emergency busses and i

load shedding from the emergency busses, and l

b)

Verifying the diesel starts from standoy i.onditions, on l

the loss of offsite power signal, energizes the eme rgency busses with permanently connected loads 1

within ~.2 seconds, energizes the autoconnected shutdown loads through the emergency power sequencer and _

u operates for greater than or equal to 5 minutes while L

'its generator is loaded with the shutdown loads. After l '.

energization, the steady-state. voltage and frequency of l.

the emergency busses shall be maintained at 4160 t 420 volts anj 50 1 1.2 Hz during this test.

l.

5)

Verifying that on an SI actuation test signal, without loss-of-offsite power, the diesel generator starts from l

standby ccnditions, on the auto -start signal and operates on standby for greater than or equal._to 5 minutes, The generator voltage andtfrequency shall be 4160 t 420 volts and

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60 -! 1,2 Hz within 10 seconds af ter the auto. start signal, the steady-stata generator voltage and frequency shall be maintained within these limits during this test;

_6)

Simdatimj a -loss-of-offsite power in ccnjunction with an SI actuation test signal; and

- a)

'Varifying deonerg11ation of the emergency busses and load shmtding from the emergency busses; p-b)

Verifying the diee.el ' starts-from standby conditions, on the auto start signal., energizes the emergency busses l ~,

with permanently connected loads within 10 seconds, energizeithe auto-connected emergency (accident) loads through.the emergency power sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After L

energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 2.420 y

volts and 60--t 1.2 Hz during.this_ test; and-

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c)

Verify'ing_ that all ' automatic diesel generator trips, except engine overspeed,- low lube oil pressure, 4160 volt bus fault, and generator diff 3rential, are automatica'ily bypassed upon loss of voltage on the emergency. bus concurrent with a Saf ety injection l

actuation signal, SEABROOKt< UNIT:1 3/4 8-6 Amendment Ho, m

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ELECTRICAL POWER SYSTEMS A.C. SOURCES OPERATING SURVElllANCE REQUIREMENTS 4.8.1.1.2 (Continued) 7)

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the diesel generator shall be loaded to greater than or equal to 6300 kW and less than or equal to 6700 kW.**

During the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel generator shall be loaded to greater than or equal to 5600 kW and less than or equal to 6100 kW. The generator voltage and frequency shall be 4160 420 volts and 60 i 1.2 Hz within 10 seconds after the start signal; the steady-state generator voltage and frequency shall be maintained within these limits during this test.

Within 5 minutes af ter completing this 24-hour test. verify that the diesel generator starts on a manual or auto start signal, attains generator voltage and frequency of 4160 1 420 volts and 60 i 1.2 Hz within 10 seconds, and operates for longer than 5 minutes.***

8)

Verifying that the auto-connected loads to each diesel generator do not exceed the short time rating of 6697 kW; 9)

Verifying the diesel generator's capability to:

a)

Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b)

Transfer its loads to the offsite power source, and c)

Be restored to its standby status.

10)

Verifying that with the diesel generator operating in a test mode, connected to its bus, a simulated Safety Injection signal overrides the test mode by: (1) returning the diesel generator to standby operation, and (2) a'itomatically energizing the emergency loads with offsite power; 11)

Verifying that the fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines; 12)

Verifying that the emergency power sequence timer is OPERABLE with the interval between each load block within 10% of its design interval;

- DieseT generator loading may be in accordance with manufacturers recommendations, including a prelude period.

The load range is provided to preclude routine overloading of the diesel generator.

Momentary transients outside the load range, due to changing bus conditions, do not invalidate the test.

- - If tha diesel generator fails to start during this test, then it is not necessary to repeat the preceding 24-hour test.

Instead, the diesel generator may be operated at greater than or equai to 5600 kW and less than or equal to 6100 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperature has stabilized.

The load range is provided to preclude routine overloading of the diesel generator.

Momentary transients outside the load range, due to changing bus conditions, do not invalidate the test.

S(.ABR00K - UNIT 1 3/4 8-7 Amendment No.

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Safety Ihaluation of Ileense Amendment Reauest 91 10 Supplement i Proposed Channes As presently written Technical Specification 4.8.1.1.2f.7 requires dicsci generator hot restart capability to be demonstrated by initiating a LOP /SI test within 5 minutes of completing _ the; 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months diesel generator run. This requirement is derived from Regulatory Guide 1.108 Periodic Testing._of I)lesel Generator Units Used as Onsite Electric Power S3 stems at Nuclear Power Plants. The cuirent Technical Specification requirement creates significant scheduling demands during an outage by reducing schedule flexibility and imposing unnecessary operational burdens. The requirement to sequence on the LOP /SI loads does not contribute to verifying the ability of the diesel generator to start from normal operating temperature. New llampshire Yankee (NHY) belieses that the proposed Technical Specification change satisfies the intent of Regulatory Guide 1.10S as discussed below.

Regulatory Guide 1.108 Position C.2.a(5), which is the basis for the requirement to

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perform the LOP /SI test immediately aftec the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months test states that the purpose of the requirement is to: ' demonstrate functional capability at full load temperature conditions". Functional capability, i.e. the ability of the diesel generator to stait from norraal operating temperature, _ can be adequately demonstrated by either manually or automatically starting the diesel generator from normal operating temperature. As stated earlier, sequencing on the LOP /SI loads does not contribute to verifyirig that the diesel gencrutor will start from normal operating temperature.

Demonstrat.ing diesci generator hot restart capability without loading the engine with LOP /51 loads does not invalidate or reduce the effectiveness of either test, provided normal operating temperature conditions are achieved prior to demonstraling hot restart capability.

Normal operating tcmperature conditions will be assured by performing the test within 5 minutes of completing the 24 hc.ur diesel generator run.

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If for. some reason the surveillance cannot be conducted within the 5 minute time period, the. engine may be brought to operating temperature conditions by operating at a load of greater than or equal to 5600 kW and less than or equal to 6100 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperature has stabilized.

The proposed changes to footnotes. clarify the existing footnotes by separating the information items contained in one footnote into individual items and applying the separate information items to the applicable Surveillance Requirement. - Additional information regarding the performance of SURVEILLANCE REQUIREMENTS h baing added.

This information v.ill enhance Technical Specifications by improving the clarity of the requirements.

Replacing the term " ambient conditian" with " standby conditions" and inserting the term " standby condition" will impiove the clasity of Technical Specifications. The latter term mote accurately describes the conditions which the diesels are maintained as it recognizes the lact that the diesels are maintained prelubed and warm by the l

co.oling water and tube oil systems.

A load range is being provided where applicable to preclude routine overload of the diesel generator.

As presently written, during surveillance testing which requires loading of the diesel generator, the operator must maintain load greater than the i

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continuous diesel generator load rating of 6083 kW. This is to prevent grid induced transients, specifically changes in VARS, from lowering the output of the diesel generator to less than the surveillance required load of 6083 kW. Thus, providing a load range of greater than or equal to 5600 kW and less than or equal to 6100 kW will preclude routine esceedences of the diesel generator continuous load rating.

Similarly, the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months rating of the diesel generator is tested by operating at a load of greatcr than or equal to 6697 kW. This requirement is revised to incorporate a range of greater than or equal to 6300 kW and less than or equal to 6700 kW.

l.oading the diesel generators to the specified ranges will continue to verify that the diesel generators are t apable of supporting operation of the emergency busses but will significantly reduce the times that the load ratings of the diesel generator are

exceeded, Surveillance Requirement 4.8.1.L2a,6) specifies in part that at least once per IS4 days that the diesel generator be rapidly loaded to greater than or equal to 6083 kW in equal to 120 seconds. Rapid loading of the diesel generator in this less than or manner introduces mechaaical stresses and :ngine wear. The purpose of this test is to demonstrate that the diesel generator is capable of accepting load by simulating the loading rate of the emergency power sequencer. This test does not validate any operational requirement which is not demonstrated by performance of Surseillance Requirements 4,8.1.1.2f.4) and 6).

These tests are the Loss of Offsite Power and Loss of Olfsite Power / Safety injection tests. Performance of these tests demonstrate that the die.,el generators are capable of accepting load as it is sequenced by the emergency power sequencer Therefore, :liminating the requirement to rapidly load the diesel generator at least once per lis4 days will reduce the mechanical stress and wear to which the diesel generator is subjected. The diesel generator will still be verified to be OPERABLE, specifically, the ability of the dical generator to accept load from the emergency power sequencer will continue to be demonstrated.

In conclusion, since the proposed revision to the diesel generator Surveillance Requirements will continue to verify that the diesel generators are OPERABLE and since these revisions continue to meet the intent of Regulitory Guide 1.108, there is no increase in the safety consequences associated with the requested amendment.

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- V, Determination of Slenifica n t llurards' for iIrense Amendment Request 91.t0 Supplement 1 Proposed Channes The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed revisions to the diesel generator Surveillance Requirements do not change the function or operation of any plant equipment or affect the response of that equipment if :t is called upon to operate..The diesel generators will be tested with a LOP /SI start from standby conditions and be rapidly loaded by the emergency power sequencer, Diesel Generator hot restart capability will continue to be verified a will be the ability of the diesel generators to carry load. The tests being performed are not new or unique and the hot restart test is similar-to the monthly surveillances. The response of the diesel generators and the electrical system as described in UFSAR Section 15.2.6, loss of Nonemereency AC Power to The Plant Auxiliaries (Loss of Offsite Power) will remain unchanged. Therefore, since the emergency diesel generators are designed to respond to the loss of voltage on the emergency busses they will function as designed with no adverse affect from the changes and there will be no increase in the probability of an accident presiously evaluated in the U FS AR.

The proposed revision of the diesel generator Surveillance Requirements will not increase the probability of an accident and it will not change the response of the diesel generators to a loss of power on the emeigency busses.

The revision of the diesel generator Surveillance Requirements does not alter the operation of the diesel generators or the associated response circuitry, but it does verify that the dicsci generator will respond to a loss of power and will supply-the emergency busses. Therefore, the accident analysis of

- Chapter 15 is unchanged 'and in particular the statement in the UFSAR Section 15.2.6.1.d remains true and in.an accident scenario "[t]he emergency diesel generators, started on loss

of voltage on the piant emergency busses, begin to supply plara vital loads". Since the plant response to an accident--will not change there is no change in the potential for an increase in the release of radiation to the public from the revision of the diesel generator Surveillance Requirements, Therefore, it follows that the consequences of an accident, as measured in

. terms of _ dose,-will not increase dt.e to the revision of the dicsci generator Surveillance Requirements.

2.

The proposed changes do not create the-possibility of a new or different kind of accident from any accident previously evaluated, The proposed revision of the diesel generator Surveillance Requirements does not affect the-operation or response of any plant equipment or introduce any new failure mechanisms. The revisions do not affect the test results and the diese: generators will still be verified to be OPERABLE and their response to a LOP will be unchanged. The plant equipment will

-respond per the -design and analyses and there will not be a malfunction of a new or any type introduced by the revision to the diesel generator Surveillance Requirements. Therefore, i.

l the previous accident analyses are unchanged and bound all expected plant transients and

~ here are no new of different accident scenarios introduced.

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mar gin n in the nt reductio the that significa ms, state nsure that in a n t result Syste e

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ensure e that hpe cificationsof safety.

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RequirellLE a sur ordance diesel genot affected a of in 13ases duction cc nce Surveilla OPERAOPERA DLE in a significant re the are in of arc ns rs 1 Specificatio tions r ato n

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3.

The proposed changes do not result in a significant reduction in the margin of safety.

l The-bases of the Technical Specification-3/4.8, Electrical Power Systems,- state that the operability of the AC and DC power systems and associated distribution systems ensure that sufficient power will be available to supply the safety-related equipment required for safe shut -down and mitigation and control of accide,t conditions. The bases also state that the surveillance requirements for determining the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guide 1.108, Revision 1. The revision of Surveillance Requirements establishes tests that will continue to verify that the diesel generators are OPERABLE and the testing will still meet the intent of Regulatcty Guide

- 1.108, Revision 1.

OPERABLE diesel generators ensure that the assumptions in the bases of the Technical Specifications are not affected and ensure that the margin of safety is not reduced.

Therefore,- the assumptions in the Bases of Technical Specifications are not affected and this change does not result in a significant reduction in the margin of safety.

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- Pronnsed Schedule for 't,1 cense - Amendment Issuance and I:ffectiveness -

New Hampshire Yankee requests NRC review of Supplement I to License Amendment Request 9140 and issuance' of a-license amendment having immediate effectiveness by. August 15, 1992.

The Technical Specification changes proposed herein will enhat.cc the safe operation of the plant' an'd remove unnecessary operational burdens during the upc6 ming refueling outage which-is scheduled to begin or. September 7.1992.

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I'nstron' mental impact 4 scssment New llampshire Yankee (NilY) has reviewed the proposed license amendment against the-criteria' of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts Lof effluent that may be released offsite, nor significantly increase individual or

' cumulative occupational radiation exposures. Ilased on the foregoing, NilY concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical.cxclusion from the requirements for an Environmental Impact Statement.

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ML20101F135

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