ML20113A598

Safety Evaluation Supporting Amend 112 to License NPF-30

ML20113A598
Person / Time
Site:	Callaway
Issue date:	06/17/1996
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20113A596	List: ML20113A592 ML20113A598
References
NUDOCS 9606240360
Download: ML20113A598 (16)

Text

_

f UGQ

[

}t UNITED STATES g

,j NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 20066-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.112 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC CONPANY CALLAWAY PLANT. UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By letter dated September 9,1994, as superseded by letter dated July 25, 1995, and subsequently supplemented by letters dated February 28, 1996, and April 9,1996, Union Electric Company (UE), requested changes to the Technical Specifications (Appendix A to Facility Operating License No. NPF-30) for the Callaway Plant, Unit 1.

The proposed amendment would revise TS 3/4.8.1 and its associated Bases to improve overall emergency diesel generator reliability and availability. Specifically, the proposed changes would incorporate recommendations and suggestions from Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation;" NUREG-1431, " Standard Technical Specifications - Westinghouse Plants;" Regulatory Guide (RG) 1.9, Revision 3,

" Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class IE Onsite Electric Power Systems at Nuclear Power Plants;"

and GL 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators from Plant Technical Specifications."

The February 28, 1996, and April 9,1996, supplemental letters provided additional clarifying information and did not change the original no significant hazards consideration determination published in the Federal Reaister on August 30, 1995 (60 FR 45188).

2.0 EVALUATION 2.1 TS Section 3.8.1.1 Action Statement a:

The licensee proposes to delete the following sentence from the action statement:

"If either diesel generator of the above required A.C. electrical power sources has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate OPERABILITY by performing Specification 4.8.1.1.2.a.4)

1. 1. for that diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." The licensee also proposes to delete the following footnote:

"## The automatic start and sequence loading of a diesel generator satisfies the testing requirements of Specification j

4.8.1.1.2.a.4) for this Action Statement."

In addition, the licensee proposes 1

to delete "and two diesel generators" from this action statement. These proposed changes are in accordance with the recommendations provided in Generic Letter (GL) 93-05 and Action A of TS 3.8.1 from NUREG-1431. The 9606240360 960617 PDR ADOCK 05000483 P

PDR

, recommendations contained in these documents allow the deletion of requirements for alternate testing of emergency diesel generators (EDGs) when one offsite power source is inoperable. Therefore, these changes are acceptable.

Action Statement b: The proposed Action Statement b deMas the following footnote:

• • This test is required to be completed regar %ss of when the inoperable diesel generator is restored to OPERABLE sta a unless the diesel was declared inoperable to do preplanned preventative n9denance, testing, or maintenance to correct a condition which, if left uncoracted, would not affect the operability of the diesel generator." The proposed action statement also adds tha following footnote: "*Unless the following conditions are met:

1) It can be demonstrated that there is no potential common mode failure for the remaining diesel generator, and 2) The diesel generator was declared inoperable due to: a) an inoperable support system,- or b) an independently testable component, or c) preplanned preventative maintenance, testing or maintenance to correct a condition which, if left uncorrected, would not affect the OPERABILITY of the diesel generator."

The proposed changes are consistent with the recommendations contained in GL 93-05 and Action B of TS 3.8.1 of NUREG-1431.

The GL suggests that when an EDG is inoperable (unless it is inoperable because of a support system or an independently testable component), the other EDG should be tested only once, unless the absence of potential common-mode failure mechanisms can be demonstrated. NUREG-1431 indicates that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time to confirm that the operable EDG is not affected by the same problem as the inoperable EDG. Therefore, the proposed changes are acceptable.

Action Statement c:

Proposed Action Statement c deletes the same "*" footnote deleted above for Action Statement b.

The proposed action statement also adds the following footnote:

"*Unless the following conditions are met:

1) It can be demonstrated that there is no potential common mode failure for the remaining diesel generator, and 2) The diesel generator was declared inoperable due to:

a) an inoperable support system, or b) an independently testable component, or c) preplanned preventative maintenance, testing or maintenance to correct a condition which, if left uncorrected, would not affect the OPERABILITY of the diesel generator."

In addition, the licensee proposes to delete reference to Action Statement a.

The proposed changes are in accordance with the recommendation in GL 93-05 that if ar. EDG it inoperable for reasons other than inoperability of a support system or an independently testable component, the other EDG should be tested only once and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the absence of potential common-mode failure mechanism can be demonstrated. The deletion of the reference to Action Statement a is appropriate since the proposed Action Statement a no longer requires testing of an EDG. Therefore, these changes are acceptable.

Action Statement e: The licensee proposes to delete the phrase " demonstrate the OPERA 8ILITY of two diesel generators by sequentially performing Specification 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the diesel generators are already operating;" from the current action statement. The licensee also

i 1

4 j

i 1

j ;

I proposes to delete the following sentence:

"A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4)## under this ACTION for the diesel generators satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a."

In j

addition, the proposed action statement deletes the same "##" footnote that is provided above for Action Statement a.

I Deletion of the phrase and sentence is consistent with the recommendations in GL 93-05.

These recommendations allow the deletion of requirements for alternate testing of EDGs when offsite power sources are inoperable. These 4

two deletions are also consistent with Action C of TS 3.8.1 from NUREG-1431.

j.

Deletion.of the."##" footnote is appropriate since an EDG is no longer to be 1

tested as part of this action statement. Therefore, these proposed changes l

are acceptable.

u i

Action Statement a: The licensee proposes to add to the TS an action i

statement that will require restoring within 30 days to the prescribed limits the properties of stored diesel fuel oil which, due to addition of new fuel oil, could get outside of these limits. This new requirement would ensure 4

high quality fuel oil for emergency diesel generators. The 30-day time limit i

for restoring stored fuel oil properties is acceptable because the fuel oil properties at issue do not have an immediate impact on diesel generator j

operation.

This time. limit is specified in Standard Technical Specification (STS) 3.8.3.D of NUREG-1431. The proposed amendment conforms to this I

specification and is, therefore, acceptable.

i

}

Action Statement h: The licensee proposes to add to the TS an action j

statement that will require restoring within 7 days to the prescribed limit i

(10 mg/ liter) particulate concentration in the stored diesel fuel oil, i

whenever this concentration exceeds this limit.. This requirement would prevent fouling of filters and fuel injection equipment, which could cause engine failure.

The 7-day time limit is acceptable because 10 mg/ liter is a conservative value and is unlikely to cause diesel generator failure. The risk associated with this time limit is less than that associated with a 1

shutdown transient.

This request is consistent with TS 3.8.3.C of NUREG-1431 1

j and is, therefore, acceptable.

i j

2.2 TS Section 4.8.1.1.2 1

i TS 4.8.1.1.2.a:

The licensee proposes to delete the words "In accordance with the frequency specified in Table 4.8.1" and add the words "At least once per i

j 31 days."

Table 4.8.1 specifies the frequency of testing based on the number of failures i

during the last 20 or 100 valid tests of each EDG. The proposed changes for TS 4.8.1.1.2.a. are consistent with suggestions in GL 94-01.

i The NRC issued GL 94-01 which states that licensees may request the removal of the TS provisions for accelerated testing and special reporting requirements j

for EDGs. However, in revising the TS accordingly, licensees must commit to j

implement within 90 days a maintenance program for monitoring and maintaining 4

~-

, EDG performance consistent with the provisions of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance of RG 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The licensee has documented that the Callaway Plant has currently implemented this maintenance program under the Emergency Diesel Generator Reliability Program (EDGRP).

In addition, the licensee has documented that the EDGRP governs all activities associated with EDG reliability. Further, the EDGRP captures the provisions of the maintenance rule as it applies to EDGs and is consistent with the provisions of 10 CFR 50.65 and the guidance of RG 1.160.

On the basis of the above, the proposed changes for TS 4.8.1.1.2.a are acceptable.

TS 4.8.1.1.2.a.4:

The licensee proposes to delete the current TS 4.8.1.1.2.a.4) in its entirety:

" Verifying the diesel starts and accelerates to at least 514 rps in less than or equal to 12 seconds.** The generator voltage and frequency shall be 4000 320 volts and 60 i 1.2 Hz within 12 seconds ** after the start signal. The diesel generator shall be started for this test by using one of the following signals: a) Manual, or b) Simulated loss of offsite power by itself, or c) Safety Injection test signal." This would be replaced by " Verifying the diesel starts ** and obtains a voltage of 4000 i 320 volts, and a frequency of 60 1.2 Hz. The diesel generator can be slow started and allowed to reach rated speed at a rate that is selected to minimize stress and wear."

The proposed changes make this surveillance requirement consistent with the

" Start Test" as described in RG 1.9, Revision 3.

The start test is performed to demonstrate proper startup from standby conditions and to verify that the required design voltage and frequency are attained.

For these tests, RG 1.9, Revision 3, recommends that the EDGs be slow started and allowed to reach rated speed on a prescribed schedule that is selected to minimize stress and Thus, the removal of the 12-second time requirement is appropriate in wear.

order to reduce undue stress and wear on the EDGs.

The proposal to delete the requirement to obtain 514 RPM is consistent with the recommendations of RG 1.9, Revision 3, and TS 3.8.1.2 from NUREG-1431. The 514 RPM verification is redundant to the frequency verification since the frequency of the generator can be converted directly into engine RPM. Therefore, the proposed changes are acceptable.

TS 4.8.1.1.2.a.5:

The licensee proposes to replace the current "6000" with i

'5580."

The licensee also proposes to add "yntil temperature equilibrium is attained. The rate of loading and unload should be gradual, based upon minimizing t af the generator during this test

% cs and wear on the diesel I

generator, and."

The proposed changes make this surveillance requirement consistent with the

" Load-Run Test" as described in RG 1.9, Revision 3.

This test is to demonstrate 90 to 100 percent of the continuous rating of the EDG for an

] interval of not less than I hour and until' temperature equilibrium has been attained. As indicated in RG 1.9, Revision 3, the test may be accomplished by synchronizing the generator with offsite power, and the loading and unloading of an EDG should k gradual and based on a prescribed schedule that is selected to minir.ize stress and wear on the EDG. The proposed changes are also in accordance with TS 3.8.1.3 from NUREG-1431. Based on this information, these changes are acceptable.

TS 4.8.1.1.2.b:

The current specification requires checking and removing accumulated water in the day tanks at least once every 31 days and after every operation of the diesel engine for longer than one hour duration. The licensee proposes to eliminate the portion of the requirement dealing with the need for checking for accumulated water after diesel operation for longer than one hour. Control of accumulated water-in the day tanks is needed to prevent microbiological growth which could produce filter fouling. The presence of water in the fuel oil could also affect performance of the diesel engine.

However, present experience has indicated that removal of the accumulated water once every 31 days provides sufficient protection for the diesel engine.

This is reflected in TS 3.8.1.5 of NUREG-1431.which requires testing for accumulated water once every 31 days, but does not require testing after diesel operation. The proposed amendment conforms to this TS specification 1

and is acceptable.

TS 4.8.1.1.2.d:

The current specification describes the tests to be performed on new diesel fuel oil prior to its addition to the storage tanks. The lii mee proposes to relocate this requirement to the Administrative Controls So.jun of ae TS and to include in TS 4.8.1.1.2.d only a statement that the properties of new oil should be verified and maintained in accordance with the Diesel Fuel Oil Testing Program. The surveillance requirements, ASTM testing standards and acceptance criteria for this program will be included in the Bases Section of the TS as well as in the plant procedures. Since the relocation of the diesel fuel oil surveillance requirements to the Administrative Controls Section of TS is consistent with. the format of the improved TS of NUREG-1431, the modification proposed by the licensee is acceptable.

TS 4.8.1.1.2.e:

The current specification describes the requirements for testing of the stored diesel fuel oil. As in TS 4.8.1.1.2.d, the licensee

' proposes to relocate the testing requirements to the Administrative Controls Section of the TS and have the Diesel Fuel 011 Testing Program included in the Bases Section of the TS and in plant procedures. This proposed modification is acceptable because it meets the intent of the improved TS of NUREG-1431.

TS 4.8.1.1.2.f.1:

The licensee proposes to delete from the current TS the following surveillance requirement:

" Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service." The licensee also proposes to relocate this surveillance requirement to the EDGRP.

In addition, the licensee proposes to delete the "#" footnote that is applicable to all parts of the current TS 4.8.1.1.2.f.

This footnote is as follows:

"#The specified 18 month frequency may be waived for Cycle I provided the

i i

j l1 !

l l

surveillance is performed prior to restart following the first refueling outage or June 1, 1986, whichever occurs first. The provisions of Specification 4.0.2 are reset from performance of this surveillance."

l The 18 month manufacturer recommended inspection will continue to be performed j

by the licensee. This requirement is not being eliminated but rather is being relocated to the EDGRP which is subject to the 10 CFR 50.59 review process.

i j

Deletion of the "#" footnote is appropriate since it is no longer applicable.

i Based on this information, the proposed changes are acceptable.

1 4

'l j

TS 4.8.1.1.2.f.2:

The licensee proposes to delete " Verifying the diesel i

j generator capability to reject the ESW pump motor load (the largest single I

1 emergency load) while maintaining voltage at 4000 320 volts and frequency at t

60 + 5.4 Hz."

(

i The staff expressed concern regarding this deletion since eliminating the EDG t

single load rejection test is not in accordance with recommendations of j

RG 1.9, Revision 3, and NUREG-1431.

In response to this concern, the licensee provided documentation indicating that analysis of previous surveillance tests i

conducted at the Callaway Plant has shown that the frequency and voltage transient from the single-load rejection test is far less severe a test of the

{

EDGs than the transient from the full-load rejection test.

Previous single i

i load rejection surveillance test results have shown that the maximum transient i

i values are well within the 4000 320 volts and 60 5.4 hertz acceptance I

criterion and are within the steady-state criterion of 4000 i 320 volts and 60 j

1.2 hertz provided for the LOCA/ SIS test.

j The proposed addition of a tighter frequency criterion of <65.4 hertz for the i

full-load rejection test (4.8.1.1.2.g.1) and the requirement that the EDG performance tests provide steady-state operation within 4000 320 volts and 60 1.2 hertz is to assure that the EDGs continue to perform as required when the single-load rejection test is no longer performed. For overfrequency conditions, the 65.4 hertz limit being applied to the full-load rejection test

^

is to provide adequate performance for limiting motor overspeed and is equivalent to the previous limit for the single-load rejection test.

t l

Operation within the steady-state criterion provides assurance of adequate voltages and frequencies for the continuous operation of the connected loads and specifically of the induction motors.

In addition, the licensee provided documentation indicating that the magnitude of the' load changes seen by an EDG during load sequencing are twice as great

^

as durin the single-load rejection test.

Further, the sequencing of the largestfondoccurslateintheloadsequencingandisapproximately equivalent to the single-load rejection test. The load rejection of the i

essential service water pump motor on an isochronous operating diesel 1

generator results in an acceleration of the shaft and a corresponding increase i

in frequency. However, the system inertia acts to resist the increase in j

frequency. Due to the large system inertia which is mostly the emergency diesel and generator, the speed change is small and is less than during the 1

i load sequencing.

The starting of the essential service water pump motor has a j

greater effect on the EDG because the torque being added to the system is a 1

1

, load and accelerating torque. The licensee also provided EDG single-load rejection test history results as shown in attached Table 1.

Table 1 indicates that for EDG single largest load rejection testing, the voltage and frequency changes were well within the acceptance criteria and that there were no significant differences in EDG voltage and frequency changes for any of the 14 tests performed.

To supplement the above information, the licensee provided three strip chart recordings that were obtained during past testing. These recordings indicate EDG voltage and frequency transient responses during a full-load rejection test, during a single-load rejection test, and during loading of an essential service water pump motor. The recordings clearly indicate that the voltage and frequency swings (transient responses) that occur during loading of the essential service water pump motor (single largest load) are much greater than the swings during the rejection tests and indicate that the conected loads can handle the transient resulting from the single-load rejection test.

In addition, the recordings clearly indicate that these voltage and frequency swings for a single-load rejection test are within the steady-state acceptance criteria values at all times during the transient.

The licensee has also revised the Bases section of the TS to include the following information. Through a plant procedure, the essential service water pump motor starting transient during the LOCA sequencing test (TS 4.8.1.1.2.g.4.d) will be demonstrated to be within a minimum voltage of 3120 Vac and to recover to 3680 Vac within 3 seconds and to be within a maximum voltage of 4784 Vac and recover to 4320 Vac within 2 seconds. This acceptance criteria is based on RG 1.9, Revision 3, Section 1.4 and past trending of essential service water pump motor starting. transient performance.

Since, in part, the single-load rejection test is to verify satisfactory response of the EDG voltage regulator and governor when removing EDG electrical loading, this added commitment provides further assurance that this response is maintained.

Based on the above, the staff concludes that the proposed TS change is acceptable.

TS 4.8.1.1.2.f.3 (Renumbered TS 4.8.1.1.2.a.11:

The licensee proposes to delete the current TS:

" Verifying the diesel generator capability to reject a load of 6201 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection." This would be replaced with the following:

" Verifying each diesel generator operating at a power factor between 0.8 and 0.9 does not trip on overspeed and voltage does not exceed 4784 volts and frequency does not exceed 65.4 Hz following a load rejection of 5580 to 6201 kW,**."

The following footnote would also be added:

"** This surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requirement."

The proposed changes make this TS consistent with recocuendations in RG 1.9, Revision 3, for the " Full-Load Rejection Test." As described in this RG, this test demonstrates an EDG's capability to reject a load equal to 90 to 100

, percent of its continuous rating (5580-6201 kilowatts) while operating at a power factor between 0.8 and 0.9 and verifies that the voltage requirements are met and that the EDG will not trip on overspeed. The proposed addition of the footnote forbidding the surveillance requirement to be performed in Modes 1 or 2 is based'on NUREG-1431, which recognizes that the performance of this.

surveillance requirement during operation with the reactor critical could cause perturbations in the electrical distribution systems that could challenge continued steady-state operation, possibly comprising safety systems. On the bases of this information, the proposed changes are acceptable.

TS 4.8.1.1.2.f.4 (Renu =Aered TS 4.8.1.1.2.a.2):

The following would be deleted:

" Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency s

busses, and b) Verifying the diesel starts ** on the auto-start signal, energizes the emergency busses wit:i permanently connected loads within 12 seconds, energizes the auto-connected shutdown. loads through the shutdown 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 4000 320 volts and 60 1.2 Hz during this test." The following would be added:

" Verifying on an actual or simulated loss-of-offsite power signal *: a)

De-energization of emergency busses; b) Load shedding of emergency busses; c)

The diesel generator auto-starts from standby conditions ** and:

1) energizes permanently connected loads within 12 seconds, 2) energizes the auto-connected shutdown loads through the shutdown sequencer, 3) maintains steady state voltage at 4000 320 volts, 4) maintains steady state frequency at 60 1.2 Hz, and 5) operates for greater than or equal to 5 minutes while generator is loaded with the shutdown loads." The licensee would also add the same "*"

footnote as for Renumbered TS 4.8.1.1.2.g.1) (see above).

The proposed changes maintain the current surveillance requirement in its entirety. However, the wording would be revised to be consistent with that for Surveillance Requirement 3.8.1.11 from NUREG-1431. These changes are also in accordance with recommendations for the " Loss-of-Offsite-Power Test" as described in RG 1.9, Revision 3.

Thus, they are acceptable.

TS 4.8.1.1.2.f.5 (Renumbered TS 4.8.1.1.2.o.3):

The licensee proposes to delete the current TS:

" Verify that on a Safety Injection test signal without loss-of-offsite-power, the diesel generator starts ** on the auto-start signal and operates on standby for greater than or equal to 5 minutes; and the offsite power source energizes the auto-connected emergency (accident) load through the LOCA sequencer. The generator voltage and frequency shall be 4000 i 320 volts and 60 i 1.2 Hz within 12 seconds after the auto-start signal; the generator steady-state generator voltage and frequency shall be maintained within these limits during this test." This would be replaced with the following:

" Verifying on an actual or simulated Safety Injection Signal (SIS)* without loss-of-offsite power that each diesel generator auto-starts from the standby condition ** and: a) achieves a voltage of 4000 320 volts in less than or equal to 12 seconds after the auto-start signal; b) achieves a frequency of 60 1.2 Hz in less than or equal to 12 seconds after the auto-

x.

-g-i start signal; c) operates on standby for greater than or equal to 5 minutes;

{

d) the offsite power source energizes the auto-connected (accident) loads through the LOCA sequencer." The same "*" footnote provided for renumbered TS 1

4.8.1.1.2.g.1) would be added to the replacement TS.

The proposed changes retain the current surveillance requirement in its entirety. The wording for the added surveillance requirement is consistent with that in NUREG-1431. The changes also result in a surveillance requirement that is in accordance with the recommendations provided in RG 1.9, Revision 3, for the "SIAS Test." The justification for adding the "*"

footnote is the same as given above for renumbered TS 4.8.1.1.2.g.1). 'On this basis, the proposed changes are acceptable.

TS 4.8.1.1.2.f.6 (Renumbered TS 4.8.1.1.2.a.4):

The licensee proposes to delete the current TS:

" Simulating a loss-of-offsite power in conjunction with a Safety Injection test signal, and a) Verifying deenergization of the emergency busses and load shedding from the emergency busses; b diesel starts ** on the auto-start signal, energizes the emergenc)y busses withVerifying permanently connected loads within 12 seconds, energizes the auto-connected emergency (accident) loads through the LOCA sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with emergency loads.

After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 320 volts and 60 i 1.2 Hz during this test; and c) Verifying that all automatic diesel generator trips,.except high jacket coolant temperature, engine overspeed, low lube oil pressure, high crankcase pressure, start failure relay, and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal." This would be replaced by the following:

" Verifying on a simulated loss of cffsite power-in conjunction with a simulated SIS

• that each diesel generater auto-starts from the standby condition ** and: a) achieves a voltage of 4000 i 320 in less than or equal to 12 seconds after the auto-start signal; b) achieves a frequency of 60 i 1.2 Hz in less than or equal to 12 seconds after the auto-start signal; c) de-energization of the emergency busses and load shedding from the emergency busses; d) energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected emergency (accident) loads through the LOCA sequencer; e) operates for greater than or equal to 5 minutes while its generator is loaded with emergency loads." The licensee also proposes to add in the replacement TS the same "*" footnote as provided above for renumbered TS 4.8.1.1.2.g.1).

The proposed changes make this surveillance requirement consistent with recommendations for the " Combined SIAS and LOOP Tests" as described in RG 1.9, Revision 3.- The resulting surveillance requirement retains the current TS in its entirety, excluding verifying that all automatic diesel generator trips (except the identified ones) are automatically bypassed upon loss of voltage on the emergency bus concurrent with a SIAS. The exclusion is relocated to renumbered TS 4.8.1.1.2.g.5) and is addressed below. The justification for the addition of the "*" footnote is the same as provided above for Renumbered TS 4.8.1.1.2.g.1).

On this basis, the proposed changes are acceptable.

a a

_jt_

Renu =ihered TS 4.8.1.1.2.a.5:

The licensee proposes to add the following as the renumbered TS.

" Verifying each diesel generator's automatic trips are bypassed upon the simulated SIS and loss-of-offsite power combined test

• except: a) Hi oil pressure;gh jacket coolant temperature; b) Engine overspeed; c) Low lube d) High crankcase pressure; e) Start failure relay; f) Generator differential current." The licensee also proposes to add the same **"

footnote as provided above for Renumbered TS 4.8.1.1.2.g.1).

As proposed, this surveillance requirement is in accordance with the recommendations for the " Protective Trip Bypass Test" as described in RG 1.9, Revision 3.

The wording for the proposed surveillance requirement is consistent with that for SR 3.8.1.13 from NUREG-1431. The justification for adding the "*" is as above. Thus, the proposed TS is acceptable.

TS 4.8.1.1.2.f.7 (Renumbered TS 4.8.1.1.2.a.6):

The licensee proposes to delete the current TS:

" Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to an indicated 6600 to 6821 kW*** and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to an indicated 6000 to 6201 kW.***

The generator voltage and frequency shall be 4000 320 volts and 60 + 1.2 Hz, -3 within 12 seconds after the start signal; the steady state generator voltage and frequency shall be maintained within 4000 320 volts and 60 1.2 Hz during this test." This would be replaced by the following:

" Verifying full-load carrying capability of the diesel generator ** at a power factor between 0.8 and 0.9 for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 5580 to 6201 kW (indicated). The generator voltage and frequency shall be maintained within 4000 i 320 and 60 i 1.2 Hz during this test." The added TS would have the following footnote:

"**This surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requirement."

The proposed changes result in a surveillance requirement that is in part consistent with the suggestions for the " Endurance and Margin Test" as described in RG 1.9, Revision 3.

However, the requirement to operate each EDG for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 105 to 110 percent of the continuous rated load as suggested 4

in RG 1.9, Revision 3, and currently required, is not being proposed. The staff expressed concern regarding this exception.

In response to this concern, the licensee stated that the EDGs at the Callaway Plant utilize Colt-Pielstick PC 2.5V 14 cylinder engines. The generator ratings are 6201 kilowatts continuous, 6635 kilowatts for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, 6821 kilowatts for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />, and 7441 kilowatts for 30 minutes. All of these ratings are at a power factor of 0.8.

In addition, the licensee stated that the worst-case accident i

bus loading occurs during a station blackout, in cold shutdown conditions, with engineered and non-engineered safety features loads connected.

The bus loading under these conditions is 6039 kilowatts; without non-engineered l

1 safety features loads connected, the bus loading is 4556 kilowatts. Under l

LOCA conditions, during the recirculation phase, the maximum load is 5440 kilowatts; with only engineered safety features loads connected, the total bus load is 5258 kilowatts.

Further, the licensee documents that at the continuous rated load of an EDG, the normal fuel rack position is 47 to 49 millimeters. At the 110 percent power level, the fuel rack position is 51 to I

l

,a 52 millimeters. A total of 75 millimeters of fuel rack movement is available; however, a mechanical stop prevents movement in excess of 55 millimeters. The ability of the governor actuator and fuel rack mechanism to move rapidly to the maximum fuel position is demonstrated each time a successful fast start of the EDG is prformed. This indicates that the engine is capable of producing the higher torsepower necessary for the 110 percent power level.

In addition, the relationship between high loads and wear is established for typical piston engine applications, and engine manufacturers have indicated that aging and wear significantly increase after 95 percent of the continuous load rating is achieved. The staff asked the licensee to address the affects of loading changes.

In response, the licensee proposed to add the following to the proposed TS: " Verify the diesel generator operates for 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded to an indicated 6600 to 6821 kW if auto connected loads increase above 6201 kW."

Further, the following footnote was also added to the proposed TS:

"****This band is meant as guidance to avoid routine overloading of the engine.

Loads in excess of this band for special testing under direct monitoring or momentary variations due to changing bus loads shall not invalidate this test." The staff finds this exception to RG 1.9, Revision 3, to be acceptable on the bases of the Callaway Plant emergency bus loading (worst case) is below the continuous rating of the EDGs, the potential for increased EDG aging and wearing, and the added TS requirement of verifying the diesel generator operates for 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded to an indicated 105 to 110 percent of continuous rated load if auto connected loads increase above 6201 kW.

Justification for adding the "*" footnote is the same as provided above for Renumbered TS 4.8.1.1.2.g.1).

The "****" footnote is added to provide guidance to avoid routine overloading of the engine.

On the bases of this information, the proposed changes are acceptable.

Renumbered TS 4.8.1.1.2.f.8:

The licensee proposes to delete " Verifying that the auto-connected loads to each diesel generator do not exceed 6201 kW."

The licensee documents that this surveillance will be relocated to Chapter 16 of the Updated Safety Analysis Report and controlled by the 10 CFR 50.59 process.

In addition, the bus loading calculations for the Callaway Plant indicate that the worst-scenario emergency bus loading would be 6039 kilowatts, which is approximately 97 percent of the rated continuous load for each EDG.

Furthermore, the auto-connected bus loadings are to be monitored and trended by the EDGRP with the electrical bus load growth being controlled by an Electrical Load Growth Program.

Based on the above, the proposed change is acceptable.

TS 4.8.1.1.2.f.9 (Renumbered TS 4.8.1.1.2.a.7):

The licensee proposes to add the following "**" footnote to this TS:

"**This surveillance shall not be performed in Modes 1, 2, 3, or 4 and credit may be taken for unplanned events that satisfy this requirement."

The addition of this note makes this surveillance requirement consistent with Surveillance Requirement 3.6.1.16 from NUREG-1431. This Surveillance

n

• 1 Requirement is not performed in Modes 1, 2, 3, or 4 because it would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Thus, this proposed addition is acceptable.

TS 4.8.1.1.2.a (Ren -hered TS 4.8.1.1.'d ).: The licensee proposes to delete the current TS:

"At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting ** both diesel generators simultaneously, during shutdown, and verifying that both diesel generators accelerate to at least 514 rps in less than or equal to 12 seconds; and..."

This would be replaced with the following:

"At least once per 10 l

years verify that when started simultaneously from standby conditions,** each diesel generator achieves in less than or equal to 12 seconds, a voltage of 4000 320 volts and a frequency of 60 1.2 Hz."

The changes proposed make this surveillance requirement consistent with Surveillance Requirement 3.8.1.20 from NUREG-1431. The replacement of the requirement to accelerate the EDG to at least 514 RPM in less than or equal to 12 seconds with voMage and frequency requirements is justified since the RPM requirement is redundant to the frequency requirement. On this basis, the proposed changes for this TS are acceptable.

TS 4.8.1.1.2.h (Renumbered TS 4.8.1.1.2.1):

The surveillance requirement in the current TS specifies that at least once every 10 years the diesel fuel oil storage tank should be drained to remove accumulated sediments and cleaned using a sodium hypochlorite solution or equivalent.

The licensee proposes to revise this surveillance requirement by eliminating the requirement to clean the tank using a sodium hypochlorite or equivalent. The reason for this change is that there currently exists better cleaning methods and the surveillance specification should allaw their use.

In addition, sodium hypochlorite is no longer a viable cleaning agent since it has been classified as a hazardous waste. The propcsed change is consistent with the surveillance requirement in TS 3.8.3.6 of NUREG-14El, which does not specifically require the use of sodium hypochlorite solution.

It is discussed in the Bases as a possible option. The proposed change is, therefore, acceptable. However, the licensee should refrain from using soap or surfactants as cleaning agents.

TS 4.8.1.1.2.1 (Renumbered TS 4.8.1.1.2.fi: The licensee proposes to delete the current TS 4.8.1.1.2.1:

"At least once per 184 days the diesel generators shall be started ** from ambient conditions (using the keep warm system) using one of the signals specified in 4.8.1.1.2.a.4) and accelerated to at least 514 rps in less than or equal to 12 seconds.

The generator voltage and frequency shall be 4000 1 320 volts and 60 i 1.2 Hz within 12 seconds after the start signal. Subsequently verify the generator is loaded to an indicated 6000 to 6201 kW*** in less than or equal to 60 seconds and operates at an indicated load of 6000 to 6201 kW*** for at least 60 minutes." The "***" footnote would also be deleted:. "*** This band is meant as guidance to avoid routine overloading of the engine.

Loads in excess of this band for special testing under direct monitoring or momentary variations due to changing bus loads shall not invalidate this test." The licensee proposes to add the following new TS 4.8.1.1.2.f:

"At least once per 184 days verify each diesel generator

he

, starts from standby conditions ** and achieves in less than or equal to 12 seconds, a voltage of 4000 1 320 volts, and a frequency of 60 1.2 Hz using one of the following signals: 1) Manual, or 2) Simulated loss-of-offsite power by itself, or 3) Safety injection test signal." The following "**" footnote would also be added:

"** This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacture so that the mechanical stress and wear on the diesel engine is minimized."

The added TS 4.8.1.1.2.f surveillance requirement is consistent with RG 1.9, Revision 3.

The requirement to operate the EDG for at least 60 minutes at 6000 to 6201 kilowatts can be deleted since this portion of the current surveillance requirement would be satisfied by performing TS 4.8.1.1.2.a.5 once per 31 days on a staggered test basis.

The requirement to accelerate the EDG to at least 514 rps in less than or equal to 12 seconds can be deleted since it is redundant to the requirement to attain the specified frequency in less than or equal to 12 seconds (discussed above for TS 4.8.1.1.2.a.4).

In addition, the requirement to load the EDG to an indicated 6000 to 6201 kilowatts in less than or equal to 60 seconds is deleted since RG 1.9, Revisicn 3, no longer suggests that the EDG be fast loaded (fast loading adversely affects EDG reliability). Deleting the current TS and adding TS 4.8.1.1.2.f makes this surveillance requirement consistent with Surveillance Requirement 3.8.1.7 from NUREG-1431.

Based on the above, the proposed change is acceptable.

TS 4.8.1.1.3:

The licensee proposes to delete the following:

" Reports - All diesel generator failures, valid or nonvalid, shall be reported in a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days.

Reports of diesel generator failures shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1. August 1977.

If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1, August 1977."

The elimination of this TS requirement is in accordance with the recommendations in GL 94-01 discussed above for TS 4.8.1.1.2.a).

In addition, 10 CFR 50.72 and 50.73 provide criteria for notifying the Commission of significant EDG failures. Therefore, the deletion of this TS requirement is l

acceptable.

TS Table 4.8.1: Table 4.8.1 would be deleted. This deletion is consistent with proposed changes discussed above for TS 4.8.1.1.2.a and as such is acceptable.

TS 4.8.1.2:

For this TS, the licensee proposes to replace 4.8.1.1.2.f.5), 6),

l 10), and 12) with 4.8.1.1.2.g.3), 4), 8), and 10), respectively.

The phrase "and 4.8.1.1.3" would also be deleted.

I

Ae l

l

} !

The proposed deletion of the reference to TS 4.8.1.1.3 (Reports) follows from the proposal to delete TS 4.8.1.1.3.

The replacements are edi.torial changes making the TS references consistent with other proposed changes. Therefore, these proposed changes are acceptable.

l 4

TS 3/4.8 - Bases: The licensee proposes to introduce in the current Bases a section describing in greater detail certain surveillance requirements which were previously included in Surveillance Requirements sections 4.8.1.1.2.d and j

4.8.1.1.2.e and now are relocated to the Administrative Controls Section and to the plant procedures. The Bases will also include a description of the Diesel Fuel Testing Program. The requirements of the program included in the Bases deviates in the following instances from the specifications in 4

Callaway's current TS and in the improved TS of NUREG-1431:

Instead of using " Clear and Bright Pass / Fail Procedures" (ASTM D4176-82) for determining free water and particulate contamination in diesel fuel oil, a centrifuge method is specified (ASTM D1796-83) with the requirement that water and sediment contents should be less than 0.05 percent. The reason for this change is that currently diesel fuel oil may contain a dye which makes the Clear and Bright Test impractical.

In addition to the tests required by the current TS and described in ASTM D1552-79 and D2622-82, analysis for sulfur in diesel fuel oil can be performed by a test based on non-dispersive X-ray fluorescence spectrometry (ASTM D4294-83). This is a more up-to-date method and would be helpful in monitoring sulfur content in diesel fuel oil.

The niethod could yield results of a comparable accuracy to the other two methods.

l In Method A of the ASTM 2276-78 standard for determining total particulate concentration in the stored diesel fuel oil, the licensee proposes to use a filter size of 3.0 microns nominal for collecting particles instead of 0.8 microns, specified in the standard. The 0.8 micron size was intended for fuel oils used for other applications than diesel. For diesel fuel meeting the criterion of particle concentration of 10 mg/ liter or less, use of a 3.0 micron filter is adequate.

All of the surveillance requirements and the Diesel Fuel Testing Program described in the Bases, including the specific deviations discussed above, are acceptable because they either meet the intent of the improved TS of NUREG-1431, or provide an adequate level of safety.

i TS 6.8.4.a:

The licensee proposes to include in the Administrative Controls Section of the TS a brief description of the Diesel Fuel Test Program, which in the current TS is specified in TS 4.8.1.1.2.d and TS 4.8.1.1.2.e.

The program described in the Administrative Controls Section will require both new and stored fuel oil to meet the acceptance criteria when sampled and tested in accordance with the applicable ASTM Standards. The particulate concentration of the stored fuel oil will be required to be below 10 mg/ liter when tested i

--u

,.,-n y

,Ao every 31 days based on ASTM Standard 2276. The details of the program will be described in Bases Section 3/4.8 of the amended TS and in plant procedures.

This would allow for the licensee in the future to amend the program under 10 CFR 50.59, provided no unreviewed safety questions are involved. This change is acceptable because it is consistent with the requirement of Section 5.5.13 relative to materials and chemical engineering of the improved TS of NUREG-1431, and meets the requirements of General Design Criterion 18 as it applies to inspection and testing of electric power systems including operability and functional performance of the components of the systems.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (60 FR 45188). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Attachment:

Table Principal Contributors:

F. Ashe S. Mitra K. Parczewski Date:

June 17,1996

t TABLE 1 EDG SINGLE LARGEST LOAD REJECT HISTORY 1

Equipment Work Date Steady Volt Max.

Volt Min.

Steady State Hertz Hertz Max.

Number Document PerIormed State Af ter Trip AfIer Trip Prior to trip After Trip KKJ01 A SO12978 3/8/86 4130 4183 4130 60 60.4 KKJ01A S408592 9/14/87 4148 4200 4148 60.4 60.8 KKJ01A S426314 4/2/89 4130 4183 4130 60.1 60.9 KKJOIA S453922 9/23/90 4148 4209 4148 60.1 60.5 KKJ01A S485359 3/24/92 4113 4176 4113 60.3 60.6 KKJ01A S516249 10/5/03 4155 4234 4155 60.2 60.6 KKJ01A S540910 3/27/95 4078 4137 4078 60.2 60.4 KKJ01B STO7203 3/10/86 4130 4200 4130 59.7 60 l

KKJ01B S408595 9/16/87 4113 4183 4113 59.7 60 KKJ01B S426315 4/4/89 4130 4200 4130 59.6 60.2 KKJ01B S453920 9/25/90 4095 4148 4095 59.7 60 KKJ01B S485361 3/25/92 4130 4193 4130 59.8 60.2 KKJ01B SS13510 10/3/93 3990 4060 3990 59.8 60.1 KKJ01B S541051 3/27/95 4095 4158 4095 59.7 59.9

- ~ -

u