ML20141H422

Safety Evaluation Supporting Amends 111 & 94 to Licenses DPR-53 & DPR-69,respectively

ML20141H422
Person / Time
Site:	Calvert Cliffs
Issue date:	12/31/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20141H420	List: ML20141H414 ML20141H422
References
NUDOCS 8601130622
Download: ML20141H422 (5)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.111 AND 94 TO FACILITY OPERATING LICENSE N05. DPR-53 AND DPR-69 BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318 Introduction By application for license amendments dated October 12, 1984, Baltimore Gas and Electric Company (BGAE) requested changes to the Technical Specifications (TS) for Calvert Cliffs Units 1 and 2.

The proposed tmendments would change the Unit 1 and Unit 2 TS 3/4.8.1, "A.C. Sources" as follows:

(1) separate remedial actions to be taken for inoperability of on-site A.C. power sources from those actions to be taken for inoperability of off-site A.C. power sources; (2) provide clarification regarding testing of automatic start bypass functions for the diesel generators; (3) delete a footnote in TS 3.8.1.1.b.2 that is no longer applicable; (4) reduce the frequency of diesel generator " cold, fast starts"; (5) change the remedial action requirements for the inoperability of the off-site A.C. power sources; and (6) update the standard for analysis of diesel fuel from ASTM D975-68 to ASTM D975-81.

Discussion and Evaluation At the present time TS 3.8.1.1 Action a provides remedial action to be taken in the event that one offsite power circuit or diesel generator becomes inoperable. The licensee has proposed that Action a be divided into two remedial actions, the first t,eing applicable in the event that one offsite power circuit is inoperable. The second action statement, to be designated Action b, would be applicable in the event that a diesel generator becomes inoperable. Subsequent action statements would be redesignated to accommodate the new Action b.

Aside from providing clarification by segregating remedial action requirements for off-site power sources from those for a diesel generator, the staff finds this proposed change has no effect on TS 3.8.1.1, is administrative in nature and is acceptable.

The licensee has proposed a change to TS 4.8.1.1.2.c.3.c concerning the testing of diesel generator trip) signals which are bypassed on a safety injectionactuationsignal(SIAS. Section 8.4.1.2 of the Calvet Cliffs FSAR contains a list (items a through 1) of all protective functions which will trip a diesel generator. A list (items a through e) is also presented which

.etc,es those protective functions which will still trip a diesel generator 8601130622 851231 DR ADOCK O y7

. in the event that a SIAS is actuated. A comparison of the two lists provides a third collection of protective functions which are bypassed on SIAS (even though these trip signals may be generated, they are not permitted to trip the diesel generator when SIAS is actuated.) This list consists of "high jacket coolant temperature" and " low jacket coolant pressure."

It should be noted that there are other protective functions, bypassed on SIAS, which are not i

important under potential accident conditions. These protective functions are " start failure relay" which terminates a diesel start attempt rather than tripping the diesel generator during operation and " loss of field" which is important only when a diesel generator is synchronized to an energized bus during normal operation..

The purpose of TS 4.8.1.1.2.c.3.c is to periodically test all those protective functions which are bypassed on SIAS. The list of protective functions in the TS however, represents those trips which are not bypassed under SIAS conditions, preceded by the wording " Verifying that all diesel generator trips, except...."

The proposed wording would be, " Verifying that the high jacket coolant temperature and low Jacket coolant pressure trips are automatically bypassed on a Safety Injection Actuation Signal." The proposed char.ge to the wording of TS 4.8.1.1.2.c.3.c provides a considerable improvement in clarity in that the list of protective functions to be tested is provided in the TS rather than the list of protective functions not requiring testing. There is no change, however, to the requirements of the TS and thus the staff finds the change is acceptable.

The licensee has proposed deletion of a footnote to TS 3.8.1.1.b.2 which is no longer applicable. The footnote pertains to a special operability requirement for the fuel oil storage system which permitted the storage tanks to be removed from service for inspection, during the Unit 2, April 1982, refueling outage. This footnote is no longer applicable and its deletion has no effect on TS 3.8.1.1.b.2, and thus the staff finds this change acceptable.

The licensee has proposed changes to TS 3.8.1.1 to reduce the frequency of diesel generator starts without prior lubrication (" col:1 fast start") and to elminate unnecessary testing of the diesel generators when on-site or off-site power sources are inoperable.

The NRC staff has long recognized that the diesel generator reliability is a key factor in mitigation of design basis accidents involving loss of off-site power. More recently, the NRC staff has been concerned that excessive testing of diesel generators may actually be decreasing the reliability of this equipment at nuclear power facilities. On July 2, 1984, the NRC issued Generic Letter 84-15 (GL 84-15) wnich calls for licensees to reduce the frequency of diesel generator " cold fast starts" at nuclear power facilities.

As part of GL 84-15, the NRC provided model TS containing the recommended frequency for " cold fast starts" and other types of diesel generator testing.

In a pa* tial response to GL 84-15, the licensee concluded that the diesel generators at Calvert Cliffs were being tested at frequencies exceeding those recomended by GL 84-15 and has requested changes to the TS.

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. At the present time, TS 4.8.1.1.2.a.4 requires the diesel to be started on a monthly basis and accelerate to 900 rpm in less than or equal to 10 seconds.

This TS represents the " cold fast start" requirement. The licensee has requested a change to TS 4.8.1.1.2.a.4 to delete the 10-second start requirement and add the following footnote:

"All engine starts for the purpose of this surveillance requirement may be preceded by an engine prelube period and/or other warm-up procedure recomended by the manufacturer so that mechanical wear and stress on the diesel engine is minimized."

In addition, the words "...with generator voltage and frequency at 4160 420 volts and 60 i 1.2 Hz, respectively," would be added to the TS requirements.

A new proposed " cold fast start" requirement would be incorporated in new TS 4.8.1.1.2.c and would require the diesel to be started from ambient conditions every 184 days and accelerated to at least 900 rpm in less than or equal to 10 seconds. Subsequent TS would be renumbered to accommodate this new TS. The modified TS 4.8.1.1.2.a and new TS 4.8.1.1.2.c are consistent with the model TS in GL 84-15 and are acceptable.

The' licensee has also proposed a change to TS 3.8.1.1 concerning the testing of the diesel generator (s) when other diesel generator (s) and/or off-site power sources are inoperable. At the present time, diesel generator (s) must be started within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and restarted at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> under the following conditions:

o Inoperability of one off-site power source (Action a) o Inoperability of one diesel generator (Action b) o Inoperability of one off-site power source and one diesel generator (Action c) o Two off-site power sources (Action d)

The licensee has requested that Actions a, b, e and d be changed to reflect the following diesel generator start times:

Action a - Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Action b - Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Action c - Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Action d - Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> The above would only have to be performed if the diesel generator (s) were not already running for Actions a, c and d.

The licensee's proposed TS would result in a longer time before the first diesel generator start and eliminate repetitive starts consistent with the model TS in GL 84-15.

By eliminating unnecessary diesel generator testing, especially those requiring " cold fast starts," it is expected that the overall reliability of the diesel generators will be improved. The staff finds that the proposed TS changes are consistent with the guidance in GL 84-15 and are acceptable.

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i 4-i The licensee has requested a change to the Action Statements of TS 3.8.1.1 which address the remedial measures to be taken when off-site power sources are inoperable. At the present time, the Limiting Condition for Operation

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(LCO) references three off-site' power sources: two'500 Ky circuits and one

6SKv circuit. The Action statements, however, are based on two 500 Ky circuits. 'The. licensee has proposed that reference to "500 Kv" in the. Action statements be deleted so that the, Action statements would be applicable to either 500 Ky or 69 Ky off-site power sources.

In addition, the Action statements would be changed as follows:'

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. Action a,' applicable to the inoperability of one off-site power source would be changed to be applicable to two-offsite power sources.

o Action c, applicable to the inoperability of one-off-site power source and one diesel generator would,be: changed to be applicable 4

to two off-site power sources and. one diesel generator.

o Action d, applicable to the inoperability of two off-site power sources

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would be changed to be applicable to three off-site power sources.

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A comparison of Calvert Cliffs TS 3.8.1.1. with the model TS of GL 84-15 indicates that3alvert Cliffs is credited'with more off-site power sources in-l the LCO than are reflected 'in the Actfdn statement. The licensee's proposed changes to the Action statements would be consistent with the LCO, would provide consistency within the TS, and would not otherwise effect the rer,uirements.of TS 3.8.1.1; thus the staff finds they are acceptable.

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s Finally, BG&E ha b requested a' change to TS 4.8.1.1.2.b which requires that diesel fuel oil be tested,in accordance with ASTM D975-68. The licensee has requested that a revised t,tindard, ASTM D975-81, be referenced in TS 4.8.1.1.2.b.

A comparison of ASTM D975-68 and ASTM D975-81 indicates that no change to diesel generator' operation would result from use of the revised standard in TS 4.8.1.1.2.b.

Si.nce diesel generator reliability would not be decreased, the staff finds:that the proposed change to TS 4.8.1.2.b is acceptable.

Environmental Consideration These amendments involve, a, change in the 'insta11atien or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requiremants. The staff has determined that the amendments involve 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 Comission has previously published a proposed finding that these amendments involve no significant hazards consideration and there has been no public coment on such fihding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 551.22(c)(9).

assessment need be prepare (b), no environmental impact statement or environme Pursuant to 10 CFR 551.22 a in connection with the issuance of these amendments.

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5-Conclusion We have 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, and (2) such activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Date:

December 31, 1985 g

Principal Contributors:

O. Chopra D. Jaffe 0

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