ML20129G920
| ML20129G920 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/03/1985 |
| From: | Parker M ILLINOIS, STATE OF |
| To: | Butler W Office of Nuclear Reactor Regulation |
| References | |
| DOE-85-084, DOE-85-84, NUDOCS 8506070410 | |
| Download: ML20129G920 (2) | |
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STATE OF ILLINOIS DEPARTMENT OF NUCLEAR SAFETY 1035 OUTER PARK DRIVE SPRINGFIELD 62704 (217) 546-8100 TERRY R. ' LASH DAN L. WILLIAMS DEPUTY DIRECTOR D**"
June 3,1985 Director of Nuclear Reactor Regulation Attention:
Mr. W. R. Butler, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
REFERENCE:
Docket No.50-46I; lilinois Power Compcny, F. A. Spongenberg letter U 60016, dated May 24,1985 to NRC, W. R. Butler, " Periodic Testing of Diesel Generator Units" In Reply Please Refer To: DOE-85-084
Dear Mr. Butler:
The lilinois Department of Nuclear Safety has reviewed the referenced letter and provides its comments herein.
Section C.2.o. of Regulatory Guide 1.108, Revision I, was written to ensure that the design of emergency diesel generators includes provisions to allow the unit to be tested on site, simulating the pcrameters of operation that would be expected if actual demand were to be placed on the system. The order of testing, as described in C.2.o.(5),
-provides for a hot restart and design-loading of ter the 24-hour test. " Illinois Power Company proposes to meet the intent of C.2.a.(5) by running either the 24-hour test as described in C.2.o.(3) or by running the diesel at 100% power (nominal) for o sufficient period of time to ensure that the units have reached a stabilized temperature prior to running the tests described in C.2.a.(l) and C.2.o.(2)."
Regulatory Guide 1.108, Revision I clearly points out the reason for the sequence of testing required in C.2.o. Illinois Power Company has not indicated their reason for requesting deviation from the Regulatory Guide.
If the 2-hour rating of the generator were used in the last 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the 24-hour test, prior to running C.2.o.(l) and C.2.o.(2), then it is possible that the ternperature of the diesel generator cooling system would be hotter than the value that Illinois Power Company would assign to " stabilized temperature".
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-Mr. W. R. Butfor
..Page 2 June 3, 1985 It is also not clear from the request whether a deviation is being requested from paragraph C.2.a.(3). "Another test, which meets the requirements of paragraph C.2.a.(3) will be performed as part of a 24-hour load test." C.2.a.(3) is the 24-hour load test.
l.)
lilinois Power Company should clearly indicate if they are requesting o deviation from performing the 24-hour test.
2.)
If the " stabilized temperature" were the highest temperature attained during the 24-hour test prior to performing paragraphs C.2.a.(l) and C.2.a.(2), then the intent of Regulatory Guide 1.108, Revision I would be met, in our interpretation.
3.)
We believe the combination of testing required by paragraphs C.2.a.(l) and C.2.o(2), into a single test, is acceptable.
Sincere 4 + Chief ic e C.
- rker, Division of gineering MCP:bkw cc:
G. N. Wright, IDNS B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident insp. etor Regional Administrator, Region 111, U.S. NRC F. A. Spangenberg, IPC
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