ML20133F763

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Provides Followup to Request for Discretionary Enforcement from SR 3.0.3 Requirements to Delay Implementation of SR 3.8.1.14 & 3.8.1.15 of TS 3.8.1, Electrical Power Sys Until NRC Approves Rev of SR 3.8.1.14 & 3.8.1.15
ML20133F763
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 01/13/1997
From: Krieger R
SOUTHERN CALIFORNIA EDISON CO.
To: Bateman W
NRC (Affiliation Not Assigned)
Shared Package
ML20133F767 List:
References
NUDOCS 9701140347
Download: ML20133F763 (7)
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Text

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h' $O01hlRN CALIFORNIA R. W. Krieger id

{ QQ JV Vice President Nuclear Generation An LDISON JATIJtM TION 41 Company January 13, 1997 I

I Mr. William H. Bateman i Director, Directorate IV- II l U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Docket No. 50-362 Request for Enforcement Discretion Emergency Diesel Generator Surveillance Testing San Onofre Nuclear Generating Station, Unit 3

Dear Mr. Bateman:

The purpose of this letter is to provide written followup to a request for discretionary enforcement from the requirements of Surveillance Requirement ]

(SR) 3.0.3, for the purpose of delaying implementation of SR 3.8.1.14 and 3.8.1.15 of Technical Specification 3.8.1, " Electrical Power Systems." This enforcement discretion is requested until the NRC approves on an exigent basis a license amendment which will revise SR 3.8.1.14 and 3.8.1.15 until the next refueling outage on Unit 3. This request was discussed with the NRC in a telephone call on the morning of January 12 and verbally granted during that call at 9:20 a.m. PST.

The need for this request results from an administrative error in implementation of the Technical Specification Improvement Program (TSIP) approved by the NRC and implemented by Edison on August 5,1996. During the 1 SIP project, Edison personnel recognized that the new TS 3.8.1 surveillances contain less rigorous kW loading limitations than were present in the g correspondingpre-TSIPTS3/4.8.1,"A.C. Sources,"surveillancesand incorrectly believed that the new TS surveillances were therefore satisfied.

Consequently, the EDGs were tested to a more rigorous set of performance standards than allowed by the new TSIP SR's. At the time of NRC review and approval of our TSIP application, Edison should have requested delayed g)k implementation of these TSIP refueling interval surveillances until the next scheduled refueling outage.

9701140347 PDR 970113 P

ADOCK 05000362 PDR P.O.th 128 1 s.g h ) 9 b San Cleinente, CA 42674 716308+255 I'as 714 368+183

Document Control Desk On January 11, 1997, Edison noted that the existing Unit 3 pre-TSIP surveillances of record did not fully satisfy the new SRs 3.8.1.14 and 3.8.1.15. However, both Unit 3 emergency diesel generators (EDGs) are fully functional and capable of performing their intended safety functions, as demonstrated by satisfactory surveillances performed under the more rigorous but different pre-TSIP surveillance kW loading requirements. In addition, both Unit 3 EDGs have successfully undergone full load rejection tests per the new, and less rigorous, loading limitations specified in the new SR 3.8.1.10.

This enforcement discretion would avoid an undesirable transient associated with an unnecessary plant shutdown and thus minimize potential safety consequences and operational risks associated with such action.

A. Requirements For Which The Notice of Enforcement Discretion was Requested:

The following TSIP surveillance requirements apply:

SR 3.0.3 (in part)

If it is discovered that a Surveillance was not performed within its specified Frequency, then Compliance with the requirement to declare the LC0 not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

SR 3.8.1.14

NOTES-------------------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.
2. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG, when operating with the maximum kVAR loading permitted during testing, operates for 1 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

a. For 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded E 4935 kW and 5 5170 kW; and
b. For the remaining hours of the test loaded E 4450 kW and 5 4700 kW.

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, l Document Control Desk SR 3.8.1.15

NOTES--------------------------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded E 4450 kW and-5 4700 kW.

Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.  !

Verify each DG starts and achieves, in s 10 seconds, voltage 1 3924 Y and 5 4796 V, and frequency 1 58.8 Hz and 5 61.2 Hz; and operates t 5 minutes.

TS surveillances 3.8.1.14 and 3.8.1.15 correspond to the pre-TSIP surveillances 4.8.1.1.2.d.8 and 4.8.1.1.2.d.4.b, which stated:

4.8.1.1.2.d.8 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 greater than or equal to 5170 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 greater than or equal to 4700 kw. The generator voltage and frequency shall be 4360

  • 426 volts and 60 i 1.2 Hz after the start
  • signal; the steady state l l

generator voltage and frequency shall be maintained at 4360

  • 436 volts and60+1.2/-0.3 Hz for 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 and 4360
  • 436 volts and 60 1 1.2 Hz 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.

Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2.d.4.b.

  • The engine start for the purpose of this surveillance test may be precededbyanengineprelubeperiodand/orotherwarmupprocedures recommended by the manufacturer so that mechanical stress and wear on j the engine is minimized.

4.8.1.1.2.d.4.b Simulating a loss of offsite power by itself, and b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds and operates for greater than or equal to 5 minutes while its generator is

Document Control Desk loaded with the permanently connected loads. After energization, the steady state voltage and frequency of the emergency busses shall be maintained at 4360 1 436 volts and 60 1 1.2 Hz during this test.

The TSIP surveillances restrict the kW loading for the first two hours ,

to 1 4935 kW and 5 5170 kW, and for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> the loading '

is restricted to 1 4450 kW and 5 4700 kW. However, the pre-TSIP surveillance was performed under a more rigorous loading of 15170 kw i for the first two hours and 1 4700 kW for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />. The l pre-TSIP Surveillance Operating Instruction S023-3-3.23.1, 1

" Diesel Generator Refueling Interval Tests," actually required the operator to set the loading between 5170 to 5200 kW for the first two hours, and then reduce load to at least 4700 kW but less than 4850 kW j for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />. Similarly Note 1 of SR 3.8.1.15 specifies that this surveillance is to be performed after the DG has operated 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> loaded t 4450 kW and 5 4700 kW.

For Unit 3, the last pre-TSIP surveillance values recorded were:

Diesel Generator 2-Hour kW & KVAR Load 22-Hour kW & KVAR Load 3G002 5180 3000 4750 - 4800 2000 - 3000 )

l 3G003 5190 500 4780 - 4830 3000 l l

Therefore, although the test with the larger load is a more demanding test of the EDGs, both the 2-hour and 22-hour loading values exceeded the maximum permitted by the TSIP surveillances of 5170 kW and 4700 kW, respectively. Also, since the 24 run was not conducted within the limits of Note 1 to SR 3.8.1.15, this SR was also not satisfied.

B. Circumstances Surrounding the Situation:

Unit 2 is currently in a refueling outage, and Unit 3 is operating at full power. In response to a recent unrelated, but similar problem with SR 3.8.1.9, Edison was in the process of reviewing other EDG j surveillances to ensure full compliance with the new TSs. During this review, and as noted above, on January 11, 1997, Edison recognized that the existing Unit 3 pre-TSIP surveillances of record did not fully satisfy the new SR 3.8.1.14 and 3.8.1.15 loading requirements.

This is considered to have been caused by personnel error. During the pre-TSIP reviews to verify TSIP compliance, the associated reviewers recognized that pre-TSIP testing was more rigorous than the TSIP l

4 Document Control Desk testing. Therefore, the previous surveillances were believed to be l bounding, and full TSIP compliance would not require any additional refueling interval EDG testing until the next scheduled outage.

Because the EDG performance data collected during pre-TSIP surveillance testing exceeds the requirements of the new TSIP surveillances, Edison concludes the tests of record did not fully comply with the new  ;

surveillance requirements. As such, Edison declared a missed surveillance on both Unit 3 EDGs, and entered the provisions of SR 3.0.3 at 5:10 pm PST on January 11, 1997.

C. Compensatory Measures:

Because the Unit 3 EDGs had passed their previously required, and more rigorous, pre-TSIP surveillances and the most recent TSIP full load rejection test, both EDGs are fully capable of performing their intended safety functions. Consequently, Edison does not consider any compensatory actions, beyond this request for enforcement discretion and an exigent change to the TS, are warranted. A copy of the proposed change to the TS that will be submitted on an exigent basis Is enclosed.

D. Safety Basis For This Request:  ;

Because the Unit 3 EDGs had passed their previously required, and more rigorous, pre-TSIP surveillances, both EDGs are fully capable of performing their safety functions. Therefore, there would be no safety benefit in performing the post-TSIP SR, and further, there are no consequences associated with not performing these SRs. This would also result in an unnecessary shutdown transient to confirm the ability of the EDGs to adequately pass less rigorous surveillances than those 4 already performed.

This conclusion is corroborated by probabilistic risk assessment insights which indicate that deferral of the tests until the Unit 3 refueling outage would expose the plant to no increase in risk over that of normal plant operations and would avoid the risks associated with shutting the unit down to perform the tests.

E. Justification for the Duration of the Enforcement Discretion:

Enforcement discretion is requested until the NRC approves on an exigent basis a license amendment which will revise SR 3.8.1.14 and 3.8.1.15 until the next refueling outage on Unit 3. This request will preclude

1 . .

i . .

Document Control Desk  !

the need to shut down Unit 3 before the refueling outage for the sole l purpose of performing this SR.

F. Basis for No Significant Hazards

Conclusion:

10 CFR 50.92 defines that no significant hazards will occur if operation of the facility, in accordance with the enforcement discretion, does not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or
2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
3. Involve a significant reduction in a margin of safety.

More stringent surveillance tests than those in SR 3.8.1.14 and 3.8.1.15 have been completed in accordance with the previous TS. Based on that testing, Edison concludes the EDGs have demonstrated their capability to i perform their specified safety function. Consequently, Edison does not consider this enforcement discretion to involve a potential detriment to the public health and safety, and that neither an unreviewed safety question nor a significant hazard is involved.

G. Basis for No Irreversible Environmental Consequences:  ;

As this activity is confined to site boundaries, this request for an NRC notice of enforcement discretion involves no increase in the amounts, and no change in the types of any effluent that may be released offsite.

There is also no increase in individual or cumulative occupational radiation exposure involved with this enforcement discretion.

Accordingly, this temporary enforcement discretion meets the eligibility criteria for categorical exclusion set forth in 10 CFR Section 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 granting of the notice of enforcement discretion.

Document Control Desk The San Onofre Nuclear Generating Station Onsite Review Committee reviewed and approved this request for an NRC notice of enforcement discretion.

If you have any questions or comments, or if you would like additional information, please let me know.

Sincerely, 1

<l s

Enclosure:

] ,M cc: L.J. Callan, Regional Administrator, NRC Region IV K.E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J.A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M.B. Fields, NRC Project Manager, San Onofre Units 2 and 3 l

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