ML20149N021

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Forwards Addl Info Supporting 870120 Application for Amend to Licenses DPR-44 & DPR-56,revising Tech Spec 1.0 Definitions to Defer Surveillance Test of Emergency Diesel Generators,Per 880228 Commitment
ML20149N021
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/26/1988
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Butler W
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
NUDOCS 8802290404
Download: ML20149N021 (3)


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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P/0. BOX 8699 PHILADELPHI A, PA 10101 tain saisoot JoscPj4 w o,ALLaowcm February 26, 1988 avn..........

Docket Nos. 50-277 50-278 Mr. W. R. Butler, Director Project Directorate I-2 Division of Reactor Projectt. I/II U.S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555

Subject:

Diesel Generator Testing

References:

(1)

January 20, 1987 Application for Amendment of Facility Operating Licenses DPR-44 and DPR-56 (2)

Letter, R. E. Martin, NRC, to E. G. Bauer, Jr., PECo, dated September 8, 1987 (3)

Letter, J. W. Gallagher, PECo, to W. R. Butler, NRC, dated October 23, 1987 Dear Mr. Butler In Reference 1, Philadelphia Electric Company requested an Amendment to Technical Specification Section 1.0-Definitions.

The proposed change requested deferral of a surveillance test of the emergency diesel generators, if they had been similarly tested for the other unit in accordance with the Specifications.

The intent of the request was to prevent a plant shutdown for the exclusive purpose of testing the same diesel generators which had been tested for the other unit.

The NRC staff requested additional information concerning the impact of taking credit on one unit for an emergency diesel generator test performed on the other unit (Reference 2).

In Reference 3, Philadelphia Electric committed to respond to the additional requests by Februsry 28, 1988.

Our responses are presented below.

l 8002090404 0D0226 PDR ADOCK 05000277 P

PDR

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s Mr. W. R. Butler February 26, 1988 Page 2 Question 1:

Assess the applicability of taking credit on one unit for a tent performed on the other unit.

Consider any equipment which is required by Technical Specifications to be tested, and which is dedicated to one unit, such as dedicated diesel generator follower instrumentation and equipment for each plant which controls the opening of circuit breakers to shed loads and the closing of circuit breakers to sequence on loads.

Response

The Emergency Diesel Generator Simulated Auto Acceptance Test (ST 11.6-2 and 11.6-3) which is performed to satisfy Technical Specification Survoillance Requirement 4.9.A.1.b, was reviewed to verify that all dedicated diesel genere'or follower instrumentation and equipment for each plant are tested in other Surveillance Tests.

This unit-specif!7 equipment controls the opening of circuit breakers to shed loads and the closing of breakers to sequence on loads.

With the exception of two relays in each loop of the core spray system logic, this unit-specific equipment is already tested in other surveillance tests which have equal or more frequent testing requirements than ST 11.6-2 and 11.6-3, and which are already required by Technical Specifications.

The Core Spray Logic System Punctional Tests (ST 1.4 and 1.5) which are performed every 6 months will be revised to include testing of the relays.

This revision will be mrde by June 30, 1988.

Question 2:

Determine whether the time interval for testing this complete loop of dedicated emergency diesel generato equipment and instrumentation for each plant will meet the testing requirements of current Technical Specifications.

Response

If the Emergency Diesel Generator Simulated Auto Acceptance Test is deferred for one unit, operability of the diesel generators will have been demonstrated by the test performed on the other unit, and operability of the follower instrumentation and equipment will have been demonstrated by the system surveillance tests (including the core spray relays when ST 1.4 and 1.5 have been revised).

Even under the provisions of the proposed amendment, the complete loop of emergency diesel generator equipment and instrumentation

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' tg Mr. D. R. ButlCr February 26, 1988 Page 3 for each plant will meet the testing frequency requirements of the current Technical Specifications.

If you have any further questions regarding the proposed i

amendment or the responses provided herein, please do r.ot hesitate to contact us.

Very truly yours, yrt.3G cc:

Addressee W. T. Russell, Adminstrator, Region I, USNRC T. P. Johnson, USNRC Senior Resident Inspector i

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