ML20117A605

Proposed Tech Specs Re Diesel Generator 18-month Surveillance Mode Restrictions

ML20117A605
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/16/1992
From:	DUKE POWER CO.
To:
Shared Package
ML20117A601	List: ML20117A600 ML20117A605
References
NUDOCS 9211300218
Download: ML20117A605 (14)

Text

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4 ATTACHMENT 1 DUKE POWER COMPANY MCGUIRE NLCLEAR S'"ATION PROPOSED TECHNICAL SPECIFACATION CHANGES t

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' ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b)

A kinematic vicosity at 40 C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes (alternatively, Saybolt viscosity, SUS at 100 F of greater than or equal to 32.6, but less than or equal to 40.1), if gravity was not determined by comparison with the supplier's certification.

c)

A flash point equal to or greater than 125 F, and d)

A clear and bright appearance with proper color"when tested in accordance with ASTM 04176-82.

2)

By verifying within 31 days of obtaining the sample that the other properties specified in Table 1 of ASTM 0975-81 are met when tested in accordance with ASTM 0975-81 except that the analysis for sulfur may be performed in accordance with ASTM 01552-79 or ASTM 02622-82.

d.

At : aast once e very 31 days by obtaining a sample of fuel oil from the stotege tanks in accordance with ASTM 02276-78, and verifying that total particulate contamination is less than 10 mg/ liter when checked in accordance with ASTM D2276-78, Method A.

e.

At least once per 18 montns, f_ ' % i t h m, by: j((

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1)

Subjecting the diesel to an inspection in accordance with' procedures prepared in conjunction witb its manufacturer's recommendations for this class of standby service; N-dwra NQo s

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A)

Verifying 7the generator capability to reject a load of greater j

than or equal to 576 kW while maintaining voltage' at 41601 g

?20 volts and frequency =t 60 t 1.2 Hz;

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3)

Verifying $the generator capability to reject a load of 4000 kW

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without tripping.

The generator voltage shall not exceed x\\

4784 volts during and following the load rejection; 4)

Simulating a loss-of-offsite power by itself)and:

a)

Verifying deenergization of th. amergency busses and load shedding from the emergency busses, and b)

Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 11 seconds, energizes the auto-connected blackout loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the blackout loads.

After energization, the steady-state voltage and frequency of the emergency busses shsil be maintained at 4160 t 420 volts and 60 1.2 Hz

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during this test.

McGUIRE - UNITS 1 and 2 3/4 8-4 Amendment No. I(Unit 1) kaendment I:o.

(Unit 2)

E*ECTRICAL POWER SYSTEMS SURVEILLANCE _ REQUIREMENTS (Continued) 5)

Verifying that on an ESF actuation 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.

The genu ator voltage and frequency shall be at least 4160 volts and 57 Hz within 11 seconds after the auto-start signal; the steady state generator vcltage und frequency shall be maintained within 4160 1 420 volts and 60 1 1.2 Hz during this test; 6)

Simulating a loss-of offsite power in conjunction with an ESF actuation test signal, and b

a)

Verifyingfdeenergizationcftheemargencybussesandload shedding from the emergency busses; huririq %U 4

)

Verifyinghhedieselstartsonth'eauto-startsignal, energizes the emergency busses with permanent;y connected loads within 11 seconds, energizes the auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads.

After

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energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 1

~~~ ~ ~ _ _ _ M 420 volts and 60 t 1.2 Hz during this test; and durm3 D M 0'"% /)

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__#c Verifying /that all automatic diesel generator trips, except engine overspeed, lube oil pressure, generator time over-current and generator differential are autom.atically bypassed upon loss of-voltage or, the emergency bus concur-rent with

• Safety Injection Actuation signal.

GDehted 3 L e St T$ t J

Operatir,g.cr cae hcur at d000 g m a W eo 7) u +e5'eraterc et M '-

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Within ; ininutc, restart and gciivim Suivaillencc-Rarlo brant d. S. '.1. 2e. 0)b-).

8)

Verifying ehe fdsel gener%sfor operates for at least 24 hcurs.

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( ped 'E^ 7 m 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 gpnerator

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SCO S*/ s hal l be l oaded'^ - + - '"- - - - - ' N 4400 kv 3nd during

%a 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 d.esel generator shall be loadedf ;;r::ter th= _ e q=' t: 4000 kW." The ge+erator

- betwe,n p,oc g g valtage an'd frequency shall be at least 4160: volts and 57 Hz and

~~~~~ y within 11 seconds after the start signal.

The steady-state generator voltage ano freriency shall be maintained within 4160 i.420 volts and 60 2 2 Hz during this test. uJihn 3

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lI s ecomh, *b McGUIRE ' UNITS 1 and 2 3/4 8-5 Amendment No.

(Unit 1)

Amendment No.

(Unit 2) c.

RECTRICAL POWER SYSTEMS

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SURVEILLANCE REQUIREMENTS (Continued) 9)

Vorifying that the auto onnected loads to each diesel generator do not exceed the 2-hour rating of 4400 kW;

10) Verifying)the diesel generator's capsbility to:

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Synchronize with the offsite power source while the q

generator is loaded with its emergency loads upon a sirrulated restoration of of fsite power, b)

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

Be restored to its standby status.

11) 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) automatically energizing the emergency loads with offsite power;

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12) 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; k-

13) Verifying that the automatic load sequence timer is OPERABLE with the interval between each load block are within the

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tolerances shown in Table 4.8-2; due;q %ddow, 7 -14) Verifying that the following diesel generator lockout features g

prevent diesel generator starting only when required:

a)

Turring gear engaged, and b)

Emergency stop.

15) Verifying that with all diesel generator air start receivers

~' s pressurized to less than or equal to 220 psig and the compres-

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sors secured, the diesel generator starts at least 2 times from 7

ambient conditions and accelerates to at least 488 rpm in less than or equal to 11 seconds.

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o At least once per 10 years or af ter any modifications which could affect diesel generator inteidependence by starting both diesel generators siravitaneously, during shutdown, and verifying _ that bot i diesel gentrators accelerate to at least 488 rpm in less than or equal to 11 seconds; and g.

At least once per 10 years by:

l McGUIRE - UNITS 1 and 2 3/4 8-6 Amendment No.

' (U11 t 2)

Amendment No.

(Unit 1)

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'3/1.8 ELECTRICAL F0WE2 SYSTEMS i

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' BASES 3/4.8.1, 3/4.8.2 AND 3/4.8.3 A.C. SOURCES, D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and 0.C power sources and associated distribution systems during operation ensures that sufficient power.will be available to supply the safety-related equipmen'. required for:

(1) the safe shutdown of the facility, and (2) the mitigation and control of accident condi-tions within the facility.

The minimum specified independent and redundant A.C. and 0.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix A to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation.

The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of on.ite A.C. and D.C.

power sources and associated distribution systems OPERABLE during accident conditions coincioent with an assumed loss-of-offsite power and single failure of the ether onsite A.C. source.

The A.C. and D.C. source ellowable out-of service times are based on Regulatory Guide 1,93, " Availability of Electrical Power Sources", December 1974. When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERAF E diesel generator as a source of emergency power, are also-OPERABLE, and that the steam-driven auxiliary feedwater pump is 09ERABLE.

This require-ment is intended to provide assurance that a loss of-offsite power event will not result in a complete loss of safety function of critical systems during the period one of the diesel generators is inoperable.

The term verify as used in this context means to administratively check by examining logs or other in-formation to determine if certain components aYe out of-service for maintenance or other reasons.

It does not mean to perform the Surveillance Requirements needed to demonstrate the OPERABILITY of the component.

The ACTION requirements-for diesel generator testing in the event of the inoperability of other electric power sources also reflect the potential for degradation of the diesel._ genera-tor due to excessive testing.

This concern has developed,. concurrently with increased industry experience with diesel gene ator% and ha: been acknowledged by the NRC staff in Generic Letter 84-15.

The OPERABILITY of the minimum specif<ed A.C. and D.C. power sources and associated distribution systems during snt.tdown and refueling ensures that:

l (1) the facility can be maintained in the shutdown or refueling condition for ex+. ended time periods, aM (2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9, " Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10, 1971, 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Neclear Power Plants." Revisior 1, August 1977, and L 137, "Ft.el-Oil Systems for Standby Diesel Generators,"

Revision 1, October'1979: also, Generic Letter 84-15, which modified the test-ing frequencies specified in Reguletory Guide 1.108.

McGUIRE - UNITS 1 and 2 B 3/4 8-1 Amendment No. 71 (Unit 1)

Amendment-No. 52 (Unit 2)

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ELECTRICT.L POWER SYSTEMS BASES Some of the Surveillance Raquirements for demonstrating the I

operability of the diesel generators are modified by a footnote.

The Specificatioris state the Surveillance Requirements are to be performed during shutdown, with the unit in mode 3 or higher.

The f ootnote allows the particular surv '.llance to be perforned during a preplanned Preventative Maj ntener.co (PM) ectivities that would result in the-diesel generator being inoperable.

The surveil.'.ance can be performed at that time as long as it does not increase the time the diesel generator is inoperable for the FM activity that is being performed, The footnote is onli applicable at that time.

The provision of the footnote shall not be utilized for operational-convenience.

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24cGUIRE - UNITS 1 and 2 B 3/4 8-la

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ELECTRfC POWER SYSTEM 5

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s BASES A.C. SOURCES, D.C. COURCES AND ONSITE POWER "'fTR19UTION SYSTEMS (Continued)

The Surveillance equirement for demanstrating the OPERABILITY of the station batteries are based on the recommendations of Regultiory Guide 1.129,

" Maintenance Testing and Replacement of Larga Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "1EEE Recommended Practice for fiaintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal

'tage onfloat charge, connection resistance values and the performance of oattery service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates and compares the battery capacity at that time with the rated capacity.

Table 4.8-3 specifies the normal limits for each designated pilot cell

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and each connected cell for electrolyte level, float voltage and specific gravity.

The limits for the designated pilot cells float voltage and specific gravity, greater than 2.13 volts and 0.015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adeouate capacity. The normal g

limits for each connected cell for float voltage and specific gravity, greater

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than 2.13 volts and not more than 0.020 below the manufacturer's full charge specific gravity with an averase specific gravity of all the connected cells not more than 0.010 below the manufacturer's full charge specific gravity, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-3 is permitted for up to 7 days. During this 7-day period:

(1) the allowable values for electrolyte level ensures no physical damage to the plates w,th an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than 0.020 below the manufacturer's recommended full charge specific gravity, ensures that the decrease in rating will 'ce less than the safety,aargin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than 0.040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an ir ividual cell's float voltage, greater than 2.07 volts, ensures the bacte.g's capability to perform its design function.

l McGUIRE - UNITS 1 and 2 8 3/

c2 Amendment No. 71 (Unit 1)

Amendment do. 52 (Unit 2)

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. ATTACllMENT 2-DUI.E POWER COMPANY MCGUIRE NUCLEAR STATION DISCUSSION OF CHANGES AND JUSTIFICATION O

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INTRODUC" ION By-a February 10, 1989 letter, Duke Power Company submitted a proposed license amendment to racility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2

- respectively, pursuant to 10 CFR CO.90.

The proposed _amendmont would allow certain 18 month diesel generator (D/G) Technical Specification (TS) surveillance tests currently required to he performed during unit shutdown only, to be able to conduct thene surveillance tests during unit operation as well (i.e. not restricted to a specific mode).

These changes were requested to provided additionul flexibility in scheduling surve111arces.

Specifically, the requested changes involved TS 4.8.1.1.2.e,-

which lists 15 surveillances to be performed on an 18-month basis, during shutdown to demonstrate the operability of each D/G.

The proposed changes would have deleted the "During Shutdown" provision from the opening general requirements and add tnem only to the specific individual surveillance that either actually technically require the test to be performed during-a shutdown or is desired to be performad dr. ring a shutdown.

This would have allowed certain individual surveillances for which the words 'During Shutdown" were not added, to be performed regardless of the unit's mode of operation, including power operation.

Subsequent to the February 10, 1989 submittal, conference calls were held on August 15 and 20, 1991 between representatives of Duke Power Company and the HRC staff.

The NRC staff discussed the concerns that they had regarding the performance of certain

' 3ased on-these surveillance requirements while at power.

discuselons, the TS amendment request submitted February 10, 1989 was supplemented by a letter dated April-3 0, -- 1 9 9 2.

Subsequent to the April 30, 1992 supplemental letter, a meeting between NRC staff personnel and representetives from Duke Power was held at McGuire Nuclear Station onLJuly'28, 1992.

A summary-of the meeting is documented within an NRC letter dated September 1,

1992.

Briefly, as a result of the July 20, 1992 meeting, an additional supplement to the proposed TS amendment request was warranted.

To assure clarity.and to simplify NRC's review, the revisiens provided by this submittal (Attachment 1) supersede'in

-its entirety all previously provided TS amendment requests on this subject matter.

The following paragraphs discuss.the-L changes made and the actior.s taken as a result of the-July 28, 1992 meeting and the September'1, 1992 NRC letter documenting the j

meeting.

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DISCUSSION OF CHANGES TS 4.8.1.1.2e.6)

Proposed Change: reinstated the phrase "During Shatdown" for TS 4.8.1.1.20.6)c), thua this Surveillance Requirement (SR) will continue to be performed during a shutdown.

A footnote was also added that will enable this portion of the surveillance to be performed in conjunction with the regularly scheduled Diesel Generator (DG) Preventative Maintenance (PM) activities.

Justification: Currently, this TS specifies that this test be performed during a shutdown.

The change provided by this supplement reinstates this requirement, thus there is no changr.

A fcotnote was added that will enable the performance of thir surveillance requirement to be dono during the regularly scheduled PM activities for that particular DG, The basic antent of the DG PM program is to ensure the continued reliabill',y Of the DG.

The implementation of some of the elements of ota PM program does require that the DG be removed from service on a periodic basis.

The footnote will allow for the performance of this SR to be done during the times in which the DG will be out of service for PM related activities.

The footnote also'has a restriction so that the time tha DG is out of service for performing PM related activities can not be extended in order to complete this surveillance requirament.

The intent is that thu provision of the footnote can not be implemented for operetional convenience.

Althcugh the Unit is still at power, because of PM related activities, the DG is rendered inoperable.

The performance of these PM activities does enhance the overall reliability of the DG beyond the impact associated with the temporary unavailability of the DG.

The performance of the SR associated with TS 4.8.1.1.2e.6)c), during the time the.DG is inoperable, as specified by the footnote, will not adversely impact-plant operation and can be done safely in conjunction with the regularly scheduled FM activities.

This should result in an overall increase in the reliability of the DG, thereby enhancing plant safety.

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TS 4;8.1.1.2e.7) and 8)

Proposed Change: The SR'specified by TS 4.8.1.1.20.7) has been relocated to the end of TS 4.8.1.1.2e.8).

A footnote was also

,j added so that a re-run of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test prior to the hot-restart = test would not have to be performed if there was a failure during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test, provided that the DG had been operated for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before perfoc: ming the hot restart test.

In addftlon, the 5 minute restart-criterion was-reinstated in conjunction with the hot restart test, finally, the requirement to perfort testing in accordance with the requirements specified q

by TS 4.8.1.1.20.6)b) waa replaced by the phrase "... verify that toe generator voltage and f requency reaches at least 4160 volts

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and 57 llz within 11 seconds."

Justification: The relocation of the Tb requirement to another section of the TSs is an administrative change..The requirement to perform the hot restart test is still required.

The hot restart test is now coupled with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing requirements specified by TS 4.8.1.1.20.8).

The operation of the DG for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will ensure that temperature stability of the DG is achieved and that the DG is sufficiently hot prior to performing the hot restart ost.

By coupling the hot restart test to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test, results in an increased restriction and is more.

conservative then what is currently allowed.

'ihe TS now only requires that the DG be operated for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before the hot restart test is performed.

The change to reinstate the 5 minuts criterion, re-establishes the same restriction that currently exists in the TS now.

Thus, the previous TS change is withdrawn.

A footnote was added to address the situation when there is a failure during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test.

For this situatica, the hot restart test could be performed, prior to completing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test, provided that the DG has operated for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

This will ensure that temperature stability of--the DG has been.

achieved and that the DG is hot.

The-completion of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test is nM an essential prerequisite for the performance of the hot restart test.

What is important is that the temperature of the DG be stable and-that the DG be sufficiently hot The primary purpose-of this surveillance is to demonstrate that the DG can be rcstarted from a hot condition, such as subanquent to ahutdown from normal surveillance.

This would demonstrate that the DG is capable of responding toLa signal to start while hot.

The change provided by this supplement continues to accomplish this fundamental intent of the SR.

In addition, this change in consistent with the language used in NUREG-1431 for this particular TS.

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TS 4.8.1.'1.2e.9)

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Proposed Change: The change provided by this supplement deletes the requirement to perform this SR during a plant shutdown.

Justification: Actual testing, startup or operation of the DG is not necessary in ordor to comply with this SR.

An engineering calculation is all that is required to verify that'the auto-connect loads do not exceed the 2-hour ratin g of 4400 FW.

This calculation can be performed during any operatioral mode withou.

impacting tne nit or plant safety.

The proposed change e?.iminates an unnecessary restriction and thus reduces the associated regulatory burden without impacting the health and safety of the public.

TS 4.8.1.1.2e.14)

Proposed change: The change provided by this supplement reinstates the shutdown requirement, thus this SR will continue to be pt -formed during a shutdown.

A footnote was clso added i

lut will enable this portion of the surveillance to be performed in conjunction with the reg"larly scheduled DG PM activities.

Justification: Currently, this TS specifies that this test be performed during a shutdown.

The change prr71ded by this supplement reinstates this requirement, thus there is no change.

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A footnote was added that will enable

.tv performance of tb.is SR to be done during the regularly schedui.4d PM activities for that particular DG.

The basic intent of the DG PM-program is to i

ensuru the continued reliability of the DG.

The implementat on of some of the elements of our PM program does require that the DG be removed from service on a periodic batts.

The footnote will allow for the performance of-this surveillance requirement to be done during the times in which the_DG-will-be out of service-for PM related activities.

The footnote also has a restriction so that theftime the DG is out of_ service for performing PM related activities can.not be extended in order to complete this surveillance requirement.

The intent is that_the

-pivvision of the footnote.can not be-implemented for operational convenience.

Although the Unit is still at power, because of PM related activities, the DG is rendered inoperable.

The performance ofz these PM activities does enhance the overall re11 ability of the DG beyond the impact associated with the. temporary unavailability i

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^of-Ehe DG, The performance of the SR associated with TS 14.8.1.1.2e.14), during.the. time the DG is inoperable,_as specified by the footnoto, will not adversely impact plant operation and can be done safely in conjunction with the regularly sc.ieduled PM activities.

This should result in an overall increase in the reliability of the DG, thereby enhancing plant safety.

TS 4.8.1.1.2e.15)

Proposed change: The change provided by this supplement, reinstates the nhutdown requirement, thus this curveillance requirement will continue to be performed during a shutdown, Tustification: Currently, this TS specifies that this test be tperformed during a shutdown.

The change provided by this supplement reinstates this requirement, thus there is no change.

BRSES Proposed Change: The bases was updated to add a discussion about the gplicability and interpretation of the footnote which allows for testing to be por'ormed in conjunction with the regularly scheduled DG PM activities.

Justification: Tne footnote that was added will allow for the s

performance of the surveillance requirement to be dono during the regularly scheduled PM activities for that particular DG.

The fasic intent of the DG PM program is to ensure the continued reliability of the DG.

Although-the Unit is stilliat power, the DG.is rendered inoperable because of PM;related activities.

The performance of these PM activities-does enhance the overall reliability of the DG beyond the-impact associated withithe temporary unavailability of the DG.

The performance of the surveillanco requirements associated with the footnote during the time the DG is inoperable due to PM activities, will not advorsely impact plant operation and can-be done safely in conjunct!.on with the regularly scheduled-PM activities.. This should result in an overall increare in the reliability of tha DG, thereby enhancing plant safety.

The changes to_the bases only_provides additional information in regard to the-correct application and' interpretation of the footnote.

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