ML20140F851

Proposed Tech Spec Sections 2 & 3 Incorporating Surveillance Requirements for Solid Radwaste.Discussion,Justification & Significant Hazards Consideration Encl

ML20140F851
Person / Time
Site:	Fort Calhoun
Issue date:	03/21/1986
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20140F820	List: ML20140F816 ML20140F839 ML20140F851
References
TAC-55860, NUDOCS 8604010194
Download: ML20140F851 (9)

Text

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'. 2.0 - LIMITING CONDITIONS FOR OPERATION 2.4 Containment Cooling (Continued)

During power aperation one of the components listed above (in addition to one raw water pump) may be inoperable. If the inoper-able component is not restored to operability within seven days, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If the inoperable component is not restored to operability within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(2) Modification of Minimum Requirements During power operation, the mir.imum requirements may be modi-fied to allow a total of two of the components listed in a. and

b. to be inoperable at any one time (in addition to one raw water pump). Only two raw water pumps may be out of service. l If the operability of both components is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the operability of both components is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Any valves, interlocks and piping directly associated with one of the above components and required'to function during acci-dent conditions shall be deemed to be part of that component and shall meet the same requirements as for that component.

Any valve, interlock or piping associated with the containment cooling system which is not included in the above paragraph and which is required to function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If operation is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Basis The requirements of Section 2.3, Emergency Core Cooling System, apply to the specifications above with respect to the operability of the 2-25 ATTACHMENT A Amendment No. 49 40go g [5000205 P n

___- p--- . s

TABLE 3-2 (continued) ~

F MINIMUM FREOUENCIES FOR CHECKS, CALIBRATIONS AFD TESTING OF

@ ENGINEERED SAFETY FEATURES, INSTRUMENTATION AND CONTROLS 3 &

9 Surveillance

" Channel Description Function Freauency Surveillance Method

5

6. (continued) b. Calibrate R b.. Exposure to known external l E radiation source.

1

c. Test M c. Remote operated integral i

radiation check source used to verify instrumentation, one channel at a time, and isolation 1

lockout relay functional check.

7. Manual Safety Injection a. Test R a. Manual initiation.

Initiation F

• 8. Manual Containment a. Test R a. Manual Initiation.

Isolation Initiation

9. Manual Initiation Con- a. Test R a. Manual switch opera-tainment Spray tion; pumps and valves tested i

separately.

10. Automatic Load a. Test Q a. Proper operation will be veri-l Sequencers fled during safety feature

' acutation test of Item 3(a) above.

1-q 11. Diesel Start See Tech Spec 3.7 for these tests.

1

TABLE 3-2 (continued)' -

MINIMUM FREQUENCIES FOR CHECKS. CALIBRATIONS AND' TESTING OF ENGINEERED SAFETY FEATURES. INSTRUMENTATION AND CONTROLS Surveillance Channel Description Function Frecuency ' Surveillance Method I

12. Diesel Fuel Transfer a. Test M a. Pump run to refill day tank.-

Pump

13. SIRW Tank Low Level a. Check S a. . Verify level indication between Signal independent channels.

b. Test / M b. A test pressure simulating the tank level is applied to each w tank bubbler, one at a time.

.L C'

c. Calibration R c. Known level signal applied to sensors and STLS logic verified.

14. Safety Injection Tank a. Check S a. Verify that level and pressure indications are between indepen-dent high and low alarms for level and pressure.

E

3.0- SURVEILLANCE REQUIREMENTS 3.7 Emergency Power System Periodic Tests Applicability Applies to periodic testing and surveillance requirements of the emergency power system.

Objective To vertfy that the emergency power system will respond promptly and properly when required.

Specifications The following tests and surveillance shall be performed subject to the following:

A. A maximum allowable extension not to exceed 25% of the surveillance interval unless otherwise specified, and B. A total maximum combined interval time for any 3 consecutive surveillance functions not to exceed 3.25 times the specified interval.

(1) Diesel Generators

a. Each diesel engine shall be started at least once per 31 days on a staggered basis. The test .shall verify that:

1. The diesel starts from ambient condition and accel-erates to rated speed and voltage in less than or equal to I 10 seconds.* The signal initiated to start this test shall be varied from one test to another to verify manual and auto start circuits.

ii. With the diesel running'at rated speed and voltage, the generator shall be synchronized with the 4.16 KV bus and the diesel breaker manually closed from the electrical control board. The generator shall be loaded to nominal nameplate rating and run for a minimum of 15 minutes.

After this 15 minutes, a continuation of the run shall be accomplished for a total run of at least 60 minutes before being off-loaded and the diesel breaker tripped.

b. The diesel auto start initiating circuits shall be tested prior to each start up if not done during the previous week.

'The diesel generator start (10 seconds) from ambient conditions shall be performed at least once per 184 days in these surveillance tests. All other engine starts for the purpose of this surveillance testing may be preceded by an engine prelube period and/or other warmup procedures recom-mended by the manufacturer so that mechanical stress and wear on the diesel engine is minimized.

Amendment No. 41 3-58 el

. 3.0 SURVEILLANCE REQUIREMENTS 3.7 Emergency Power System Periodic Tests (continued)

(1) Diesel Generators (continued)

c. Tests shall be conducted during each refueling outage to demonstrated the satisfactory overall automatic operation of each diesel system. This test shall be initiated by the simulated simultaneous loss of 4.16 KV supplies to bus lA3 (IA4) and a simulated auto start signal. Proper operation will be verified by observation of (1) de-energization of bus 1A3 (IA4) and load shedding from bus (both 4160 V and 480 V), (2) diesel automatic start, energization of bus lA3 (IA4), automatic sequence start of emergency load and opera-tion for > 5 minutes while its generator is loaded with the emergency loads. Manual control of diesel generators and breakers shall also be verified during refueling shutdowns.

d. Each diesel generator shall be given a thorough inspection at least annually following the manufacturer's recommenda-tions for this class of standby service. The above tests will be considered satisfactory if all applicable equipment operates as designed. This will include calibration of mon-itoring instrumentation.

e. The fuel. oil transfer pumps shall be verified to be '

operable each month.

(2) Station Batteries

a. Every month the voltage of each cell (to the nearest 0.01 volt), the specific gravity, and temperature of a pj' pt )

cell .in each battery shall be measured and recordedW(2 I

b. Every three months the specific gravity of each cell, the temperature reading of every fifth cell, and the amount of water added shall be measured and recorded. During the first refueling outage and every third refueling outage thereafter the batteries shall be subjected to a rated load discharge test.

c. At monthly intervals the third battery charger, which is capable of being connected to either of the two D.C. distri-bution buses, shall be paralleled in turn to each D.C. bus.

In-each case, load shall be transferred to this reserve battery charger by switching out the normal charger. The reserve charger shall be run on load for 30 minutes on each bus and the system shall finally be returned to normal.

d. During refueling shutdowns the correct function of all D.C.

emergency transfer switches shall be demonstrated by manual transfer of normal D.C. supply breakers at the 125 volt D.C. distribution panels.

Amendment No. 24 3-59 ti

-3.0 SURVEILLANCE REQUIREMENTS 3.7 Emergency Power System Pariodic Tests (Continued)

(3) Energency Lighting The correct functioning of the emergency lighting system shall be verified at least once each year.

~

(4) 13.8 Kv Transmission Line The 13.8 Kv transmission line will be energized and loaded to minimum shutdown requirements at each refueling outage following installation.

Basis The emergency power system provides power requirements for the engineered safety features in the event of a DBA. Each of the two diesel generators is capable of supplying minimum required safety feature equipment from independent buses. This redundancy is a factor in establishing testing intervals. The monthly tests speci-fied will demonstrate operability and load capacity of each diesel generator. These tests are conducted to meet the objectives of NRC Generic Letter 84-15 regarding the issue of reductions in cold fast starts. For this reason, the test verifying a 10 second start will be conducted from ambient conditions once per 184 days for each diesel. Other monthly tests will allow for manufacturer recommended warmup to reduce the mechanical stress and wear on the diesel engines. The fuel supply and various controls are contin-uously monitored and alarmed for off-normal conditions. At approximately yearly intervals (during refueling shutdowns) automa-tic starting on loss of off-site power and automatic load shedding, diesel connection, and loading will be ver_ified. At the same inter-vals, capability will be verified for manual emergency control of I these functions from the diesel and switch-gear rooms.

Considering system redundancy, the specified testing intervals for the station batteries should be adequate to detect and correct any malfunction before it can result in system malfunction. Batteries will deteriorate with time, but precipitous failure is extremely unlikely. The surveillance specified is that which has been demon-strated over the years to provide an indication of a cell becoming unserviceable long before it fails.

References (1) USAR, Section 8.3.4 (2) USAR, Section 8.4.2 Amendment No. 24 3-60 ti

'. - DISCUSSION, JUSTIFICATION, AND SIGNIFICANT HAZARDS CONSIDERATIONS The NRC's Generic Letter 84-15, dated July 2, 1984, provided staff ob-jectives with respect to the emergency diesel generators at nuclear power facilities. The first. attachment to this letter addressed a staff objec-tive of reducing the number of cold fast start surveillance tests for diesel generators which were deemed as resulting in premature diesel en-gine degradation. The Generic Letter requested a description of the current surveillance testing program, and a description of intended actions to reduce cold fast starts.

OPPD's response directly applicable to this i. tem of the Generic Letter was provided in our letter LIC-84-413, dated December 28, 1984. In this l_et-ter, we described our cold fast start surveillance testing program, and stated that we would conduct a review of the Technical Specifications and surveillance testing in order to determine if any unnecessary testing could be eliminated. In a letter to the NRC (LIC-85-362) dated October 25, 1985, OPPD stated that our review indicated that certain changes to the Technical Specifications would be in order. We further noted that we expected to submit those changes in the form of an Application for Amend-ment approximately 30 days after full power operation following the 1985 refueling and maintenance outage. Accordingly, the proposed changes to

-the Technical Specifications are intended to meet that objective.

The proposed changes to the Technical Specifications are as follows:

Technical Specification 2.4, Limiting Condition for Operation of the Containment Cooling System, part (2), Modification of Minimum Require-ments. The existing Technical Specification allows during power operation, The minimum requirements to be modified to allow a total of two of the components listed in a. and b. to be inoperable at any one time (in addi- '

tion to one raw water pump) provided that the emergency diesel generator connected to the other engineered safeguards 4.16 KV bus (IA4 or IA3) is started to demonstrate operability. The proposed Technical Specification removes the requirement that the emergency diesel be started. This partic-ular requirement imposes the stresses associated with cold fast starts on the diesel engines. Further, the requirement is not consistent with the Standard Technical specifications. Therefore, this start requirement has been removed from Technical Specification 2.4(2).

Technical Specification 3.1, Instrumentation and Control, applies to the checks, calibration, and testing of the RPS, ESF, and miscellaneous plant instrumentation and controls. Item 11 of Table 3-2, of the Specification addresses test requirements for the diesel generators. These requirements i are spelled out in far greater detail in Specification 3.7. Therefore, l the Item 11 of Table 3-2 has been modified to refei ence Technical Specifi-cation 3.7. This will climinate redundant roouirements and clarify the j specifics of the diesel tests actually requirid.

l The requirement for a manual start found in item lla is essentially l

redundant to that found in Technical Specification 3.7(1)a.

i ATTACHMENT B tt

, ATTACHMENT B (Continued)

The requirement to start the diesel in Table 3-2, Item 11b, has been removed. The text required by Table 3-2, Item 3b will verify that the proper start signals are received. Thus the intent ~of this Technical Specification can be met by verifying a start signal is present without actually starting the diesel. The change will reduce the number of diesel starts required by the Technical Specifications.

The existing requirement of Table 3-2, Item 11c to test the diesel during the refueling shutdowns is redundant to the test noted in 3.7(1)c and is therefore deleted.

The requirements of Table 3-2, Item Ild to test the diesel auto start initiating circuits prior to startup if not done during the previous week have been moved to Section 3.7(1)b. ~Thus provides for the~ diesel generator testing requirements to be located within one specification.

Technical Specification 3.7(1) has been modified to allow for the dicsel '

start (10 seconds) from ambient conditions to be performed at least once per 184 days. The other engine starts in this specification will be allowed to be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that mechanical stress and wear on the engine is minimized.

Technical Specification 3.7(1)(e) has been removed from the Technical Spec-ifications. This specification refers to design consideration and not a surveillance requirements. The design basis considerations are found in USAR Section 8.4.1.2.

A note has been added to the Basis section of 3.7 to specify that Generic Letter 84-15 recommendations to reduce cold fast starts have been incorpor-ated into these Technical Specifications. I Justification This change to the Technical Specifications is proposed in response to the NRC recommendations of Generic Letter 84-15. This change will reduce the number of unnecessary cold fast starts of the emergency diesel generators.

These changes will bring applicable portions of the Fort Calhoun Station Technical Specifications into conformance with the recommended changes noted in the Attachment to Enclosure 1 of Generic Letter 84-15.

Significant Hazards Considerations The proposed changes to the Technical Specifications have been reviewed relative to the provisions of 10 CFR 50.90. This review resulted in the ,

following conclusions:

The proposed changes will not involve a significant increase in the probability or consequences of an accident or malfunction of equipment previously evaluated in the Safety Analysis Report. These changes are intended to reduce degradation of the emergency diesel generators caused by cold fast starts. Thus, the probability of malfunction of equipment can be considered to have been lessened, d

. ATTACHMENT B (Continued)

The changes will not create the possibility of a new or different kind of accident from any previously evaluated. The proposed changes do not change the normal operating mode of any existing system, but only alter the testing mode. i The proposed changes will not involve a significant reduction'in a margin of safety. The changes are intended to provide a less severe method of testing of the diesel generators, thus decreasing the likelihood of de-gradation and wear. Thus, the proposed changes could be viewed as increasing a margin of safety.

en