ML20206L448

Proposed Tech Specs,Allowing Use of Fifth Standby Diesel Generator

ML20206L448
Person / Time
Site:	Sequoyah
Issue date:	08/08/1986
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20206L431	List: ML20206L429 ML20206L448
References
NUDOCS 8608200185
Download: ML20206L448 (25)

Text

ENCLOSURE 1 Proposed Technical Specification Change SEQUOYAH NUCLEAR PLANT Docket Nos. 50-327, 50-328 (TVA SQN TS 57)

Proposed Change to Surveillance Requirements For Diesel Generators List of Affected Pages

' Unit 1 3/4 8-3 3/4 8-5 3/4 8-6 i

3/4 8-7 3/4 8-7b 6-22 6-22a Unit 2 3/4 8-3 3/4 8-7 3/4 8-8 3/4 8-8b 6-27 6-27a P

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tLECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) -

4. Verifying the diesel starts from ambient condition and-accelerates to at least 900 rpm in less than or equal to 10 seconds. The generator voltage and frequency shall be 6900 690 volts and 60 1.2 Hz within 10* seconds after the [ .

start signal. The diesel generator shall be started for this test by using one of the following signals with startup on each signal verified at least once per 124 days:

a) Manual.

b) Simulated loss of offsite power by itself.

) Sicc~ lated len of effsite pc m ,, ce,,ju,c $ n ith r EEF cctuati

n t:;t ;i;;nci c/) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized, loaded to greater than or equal to 4000 kw in less than or equal to 60 secondsf and l operates for greater than or equal to 60 minutes, and

6. Verifying the diesel generator is aligned to provide standby power to the associated shutdown boards. I

b. At least once per 31 days and af ter each operation of the diesel where the period of operation was greater than or equal to I hour by checking for and removing accumulated water from the engine-mounted fuel tanks.

c. At least once per 92 days and from new fuel oil prior to addition to the 7-day tanks by verifying that a sample obtained in accordarice with ASTM-D270-1975 has a water and sediment content of less than or equal to .05 volume percent and a kinematic viscc.sity @ 100 F of greater than or equal to 1.8 but less than or equal to 5,8 centi-stokes when tested in accordance with ASTM-D975-77, and an impurity l level of less than 2 mg. of insolubles per 100 ml. when tested in l accordance with ASTM-D2274-70.

d. At least once per 18 months during shutdown by:

1. Subjecting the diesel to an inspection in accordance with j procedures prepared in conjunction with its manufacturer's l recommendations for this class of standby service,

2. Verifying the generator capability to reject a load of greWic l than or equal to 600 kw while maintaining voltage at 6960 1 n%"

volts and frequency at 60 + 1.2 Hz.

l 3. Verifying the generator capability to reject a load of 4000 kw l without tripping. The generator voltage shall not exceed 7866 volts during and following the load rejection. '

SEQUOYAH - UNIT 1 3/4 8-3 l

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Footnote The diesel generator start (10 see) and load (60 sec) from standby conditions shall be performed at least once per 184 days in these surveillance tests. All other diesel generator engine starts and loading for the purpose of titis surveillance testing may be preceded by an engine idle start, followed by gradus 1 acceleration to synchronous speed (900 rpm), synchronization, and gradual loading.

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ELECTRICAL POWER SYSTEMS SURVEILLANCE

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REQUIREMENTS (Continued)

Within 5 minutes after cogpieting this 24 hcur test, perform Specification 4.8.1.1.2.-e 4. The generator voltage and fre-quency shall be 6900 1 690 volts and 60 1 1.2 Hz within 10 seconds after the start signal; the steady state generator voltage and frequency shall be maintained within these limits dgring this test.

9.

Verifying that the auto-cennected loads to each diesel generator ,

do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 4000 kw.

10.

Verifying the diesel generator's capability to:

a)

Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and c) Be restored to its snutdown status.

11.

Verifying that the automatic load sequence timers are OPERABLE with the setpoint its design for each sequence timer within + 5 percent of setpoint.

12.

Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:

a) Engine overspeed b) 86 GA lockout relay l e.

At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 900 rpm in less than or equal to 10 seconds.

l f.

At least odce per 10 years

• by:

l 1.

! Draining each fuel oil storage tank, removing the accumulated sedimentand solution, and cleaning the tank using a sodium hypoclorite 2.

l Performing a pressure test of those portions of the diesel fuel oil system design to Section III, subsection ND of the ASME Code at a test pressure equal to 110 percent of the system design pressure.

• lhese requirements are waived for the initial surveillance.

SEQUOYAH - UNIT 1 3/4 8-5 esp. *

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.3 The 125-volt D.C. distribution panel,125-volt D.C. battery bank and associated charger for each diesel generator shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying:

1. That the parameters in Table 4.8-la meet the Category A limits.

2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge.

b. At least once per 92 days by:

1. Verifying that the parameters in Table 4.8-la meet the Category B limits,

2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to terminal connection resistance of these items is less than 150 x 10 8 ohms, and

3. Verifying that the average electrolyte temperature of 6 connecte cells is above 60 F.

c. At least once per 18 months by verifying that:

1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.

i l 2. The battery to battery and terminal connections are clean,

! tight and coated with anti-corrosion material.

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3. The resistance of each cell to terminal connection is less than or equal to~ 150 x 10 8 ohms.

1 r 4.8.1.1.4 Reports - All diesel generator failures, valid or non-valid, shall l be reported to the Commission pursuant to Specificction 4 ,4.4, ": pert: O f 6.917-.

I dic 1 gencr:ter failure: th2!' include +he 4-fermatic" ece- :nded 4" Regu!a-l tery Position C.3.h of Regulatory Cuide 1.100, Revi;ier.1, August 1077. If the number of f;ilure: i- the la:t 100 talid tect: (en a per nuclear unit ba;ia) i: gr;;tcr than or cqual t: 7, the rcport : hall bc uppica:ntcd to

.uclude th; cdditicr.cl 'nformatier r::::::nded 4" 90gulatery occitic" C.2.5 ef

":gulatory Cuidc 1.100, Revisica 1, August 1077.

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SEQUOYAH - UNIT 1 3/4 8-6 r me v e,- r .* w ~

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ELECTRICAL POWER SYSTEMS TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE Numbe of Failures in Last 1 Valid Tests

• Test Frequency

<1

_ At least once per 31 day 2 At least once per 14 ys 3 At least once per days

>4 1

_ At least once p r 3 days

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^ Criteria for determining numbe of failures d number of valid tests shall be in accordance with Regulato 00sition C .e of Regulatory Guide 1.108, Revision 1, August 1977, where th last 1 tests are determined on a per nuclear unit basis. For the purpos of this test schedule, only valid tests conducted after the Operating Licens 'ssuance date shall be included in the computation of the "last 100 valid t ". Entry into this test schedule shall be made at the 31 day test fr quen .

i REPLAcc teirW THE .

ATTACH ED REstl$ Eb TABtg 4, g _( ynd A NAek w+d ,

1 SEQUOYAH - UNIT 1 3/4 8-7 Amendment No. 1 -

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@ TABLE 4.8-1 *

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r. Diesel Generator Reliability No. of Failures in , No. of Failures in ,

last 20 valid tests last 100 valid tests Reliability Actions I1 -

Test at least once per 31 days

-2 -

Test at 1 cast once per 7 days 3 6 Within 30 days prepare a report for NRC audit, in accordance with ti Section 6.9.2.2 s~

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5 11 Declare the diesel generator inoperable and perform a re-qualification test for the affected diesel generator pursuant to the attachment to this table

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• Criteria for determining number of failures and number of valid tests shall be in accordance with

Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the number of tests and failures are determined on a per diesel generator unit basis. For the purposes of this J test schedule, only valid tests conducted after the Operating License issuance date shall be j included in the computation of the "last 20 valid tests". Entry into this test schedule shall be made at the 31 day test frequency.

q This test frequency shall be maintained until seven consecutive failure free demands have been j performed and the number of failures in the last 20 valid demands has been reduced to one or less.

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Ja ATTACHMENT TO TABLE 4.8- 1 /

DIESEL GENERATOR REQUALIFICATION PROGRAM s

(1) Perform seven consecutive successful d2mands without a failure vj thin 30 days of diesel generator being restored to operable status anc fourteen consecutive successful denands withoat a failure within 75 days of diesel, generator of being restored to operable status. ,

(2) If a failure occurs during the fir,st seven tests in the- requalification tesc program, perform seven successful demands without 'ai additional; failure within 30 days of diesel generator of being restorec to operable status and fourteen consecutive successful demands without a failure within 75 days of being restored to operable.=tatus. ,

(3) If a failure occurs during the second seven tests (tests 8 through 14) of (1) above, perform fourteen consecutive successful demands without an additional failure within 75 days of the failure which occurred during the requalification testing.

s (4) Following the second failure during the requalification test program, be in at least HOT STANDBY witnin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within

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the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(5) During requalification testing the diesel genciator should not be tested l more frequently than at 24-hour intervals.,

After a diesel generator has been successfully requslified, subsequent repeated requalification tests will not be required for that diesel generater under the following conditions:

1 (a) The number of failures in the last 20 valid demands is less'than 5.

l (b) The number of failures in the last 100 valid demands is less than 11.

(c) In the event that following successful requalification of a diesel generator, the number of failures is still in excess of the renedial action criteria (a and/or b above) the following exception sill be allowed until the diesel generator is no longer in violation of the remedial action ~ criteria

(a and/or b above).

1 Requalification testing will not be required provided that after each valid demand the number of failures in the last 20 and/cr 100 valid demands has not i increased. Once the diesel generator is no longer in violation of the remedial action criteria above the provisions of those criteria alone will prevail.

O SEQUOYAH - UNIT 1 7 3/4 8-7b

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l ADMINISTRATIVE CONTROLS RADIAL PEAKING FACTOR LIMIT REPORT 6.9.1.14 The W(z) function for normal operation shall be provided to the Direc-tor, Nuclear Reactor Regulation, Attention, Chief of the Core Performance Branch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 at least 60 days I prior to cycle initial criticality. In the event that these values would be '

submitted at some other time during core life, it will be submitted 60 days prior by thetoCommission.

the date the values would become effective unless otherwise exempted Any information needed to suport W(z) will be by request from the NRC and need not be included in this report.

SPECIAL REPORTS 6.9.2.1 Special reports shall be submitted to the Director of the Office of Inspection and Enforcement Regional Office within the time period specified for each report.

6.9.2.2 Diesel Generator Reliability Imorovement Program As a minimum the Reliability Improvement Program report for NRC audit ,

required by LCO 3.8.1.1, Table 4.8 '1, shall include:

(a) a summary of all tests (valid and invalid) that occurred within_the time period over which the last 20/100 valid tests were performed (b) analysis of failures and determination of root causes of failures (c) evaluation of each of the recommendations of NUREG/CR-0660, "Enchancement of Onsite Emergency Diesel Generator Reliability i in Operating Reactors, " with respect to their application to the Plant (d) identification of all actions taken or to be taken to 1) correct the root causes of failures defined in b) above and 2) achieve a general improvement of diesel generator reliability (e) the schedule for implementation of each action from d) above (f) an assessment of the existing reliability of electric power to engineered-safety-feature equipment

! A supplemental report shall be pre-pared within 30 dsys after cach subsequent the affected diesel generator unit continues to violate failure duringthe a valid demand for so long as criteria l (3/20 or 6/100) for the reliability improvement program remedial action.

l The supplemental report need only update the failure /demcnd history for SEQUOYAH - UNIT 1 6-22 ~

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued) the affected diesel generator unit since the last report for that diesel generator.! The supplemental report shall also present an analysis of the failure (s) with a root cause determination, if possible, and shall delineate;any further procedural, hardware or operational changes to be incorporated into the site diesel generator improvement program and the schedule for implementation of those changes.

,In addition to the above, submit a yearly data report on the diesel generator reliability.

6.10 RECORD RETENTION In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

6.10.1 The following records shall be retained for at least five years:

a. Records and logs of unit operation covering time interval at each power level,

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c. All REPORTABLE EVENTS submitted to the Commission,

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e. Records of changes made to the procedures required by Specification 6.8.1 and 6.8.4.

f. Records of radioactive snipments.

g.

h.

Records of sealed source and fission detector leak tests and results.

Records of annual physical inventory of all sealed source material of record.

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+ ELECTRICAL POWER SYSTEMS b SURVEILLANCE REQUIREMENTS (Continued)

4. Verifying the diesel starts from amMsnt condition and accelerates to at least 900 rpm in less than or equal to 10 seconds. The generator voltage and fre 6900 690 volts and 60 t 1.2 Hz within 10guency shall seconds afterbethe start signal. The diesel generator shall be started for this l test by using one of the following signals with startup on each signal verified at least once per 124 days:

a) Manual.

b) Simulated loss of offsite power by itself.

u) 'M.~;o;.md 1 ., ef eff;it; p; m i., c..,j actica itt, ;r, Ecr

tucti r t::t ci;;n:1.

c.jl) An ESF actuation test signal by itself.

5.

Verifying the generator is synchronized, loaded to greatgr than or equal to 4000 kw in less than or equal to 60 seconds, and  !

operates for greater than or equal to 60 minutes, and

6. Verifying the diesel generator is aligned to provide standby power to the associated shutdown boards.

b. At least once per 31~ days and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the engine-mounted fuel tanks.

c. At least once per 92 days and from new fuel oil prior to addition to the 7-day tanks by verifying that a sample obtained in accordance with ASTM-0270-1975 has a water and sediment content of less than or l

equal to .05 volume percent and a kinematic viscosity @ 100 F of greater than or equal to 1.8 but less than or equal to 5.8 centi-stokes when tested in accordance with ASTM-0975-77, and an impurity l level of less than 2 mg. of insolubles per 100 ml. when tested in accordance with ASTM-02274-70.

d. At least once per 18 months, during shutdown,- by:

1. Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's t

recommendations for this class of standby service,

2. Verifying the generator capability to reject a load of greater l than or equal to 600 kw while maintaining voltage at 6900 1 690 l

volts and frequency at 60 1 1.2 Hz.

3. Veritying the generator capability to reject a load of 4000 kw without tripping. The generator voltage shall not exceed

) 7866 volts during and following the load rejection.

,J SEQUOYAH - UNIT 2 3/4 8-3 AR allAd L%le

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Footnote The diesel generator start (10 see) and load (60 see) from standby conditions shell be performed at least once per 184 days in these surveillance tests. All other diesel generator engine starts and loading for the purpose of this survoillance testing may be preceded by an engine idle start, followed by gradual acceleration to synchronous speed (900 rpm), synchronization, and gradual loading.

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l ELECTRICAL POWER SYSTEMS i SURVEILLANCE REQUIREMENTS (Continued) ,

1 4.8.1.1.4 Renorts - All diesel generator failures, valid or non-valid, shalln.

be re . . ,.

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SEQUOYAH - UNIT 2 3/.4 8-7

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ELECTRICAL POWER SYSTEMS TABLE 4.8-1  !

DIESEL GENERATOR TEST SCHEDULE Number f Failures in Last 100 _alid Tests

• Test Frequency

<1 At least once per days 2 At least once p 14 days 3 At least once per 7 days

>4 At least o e per 3 days

• Criteria for cetermining number of ilur s and number of valid tests shall be in accordance with Regulatory Posi

• C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the las 00 tests are determined on a per nuclear unit basis. For the purpose of , is test schedule, only valid tests conducted after the Operating Licen e issua e date shall be included in the T computation of the "last 100 vali tests". E ry into this test schedule -j shall be made at the 31 day test requency.

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SEQUOYAH - UNIT 2 3/48-8 m ..c m

"a IE ELECTRICAL POWER SYSTEMS El y; TABLE 4.8-1 g: -

p Diesel Generator Reliability n

No. of Failures in , No. of Failures in ,

last 20 valid tests last 100 valid tests Reliability Actions I1 -

Test at least once per 31 days

-2 -

Test at least once per 7 days 3 6 Within 30 days prepare a report for NRC audit, in accordance with Section 6.9.2.2

$h 5 11 Declare the diesel generator a, inoperable and perform a re-f, qualification test for the affected diesel generator pursuant to the attachment to this table Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the number of tests and failures are determined on a per diesel generator unit basis. For the purposes of this test schedule, only valid tests conducted after the Operating License issuance date shall be included in the computation of the "last 20 valid tests". Entry into this test schedule shall be made at the 31 day test frequency, tw This test frequency shall be maintained until seven consecutive failure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one or less.

ATTACHMENT TO TABLE 4.8-1 DIESEL GENERATOR REQUALIFICATION PROGRAM (1) Perform seven consecutive successful demands without a failure within 30 days of diesel generator being restored to operable status and fourteen consecutive successful demands without a failure within 75 days of diesel generator of being restored to operable status.

(2) If a failure occurs during the first seven tests in the requalification test program, perform seven successful demands without an additional failure within 30 days of diesel generator of being restored to operable status and fourteen consecutive successful demands without a failure within 75 days of being restored to operable status.

(3) If a failure occurs during the second seven tests (tests 8 through 14) of (1) above, perform fourteen consecutiv successful demands without an additional failure within 75 days of the failure which occurred during the requalification testing.

(4) Following the second failure during the requalification test program, be in at least HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(5) During requalification testing the diesel generator should not be tested more frequently than at 24-hour intervals.

After a diesel generator has been successfully requalified, subsequent rapeated requalification tests will not be required for that diesel generator under the following conditions:

(a) The number of failures in the last 20 valid demands is less than 5.

(b) The number of failures in the last 100 valid demands is less than 11.

(c) In the event that following successful requalification of a diesel generator, the number of failures is still in excess of the remedial action criteria (a and/or b above) the following exception will be allowed until the diesel generator is no longer in violation of the remedial action criteria (a and/or b above).

Requalification testing will not be required provided that after each valid demand the number of failures in the last 20 and/or 100 valid demands has not increased. Once the diesel generator is no longer in violation of the remedial action criteria above the provisions of those criteria alone will prevail.

SEQUOYAH - UNIT 2 3/4 8-8b m i:

ADMINISTRATIVE CONTROLS RADIAL PEAKING FACTOR LIMIT REPORT 6.9.1.14 ThesW(z) function for normal operation shall be provided to the Director, Nuclear Reactor Regulation, Attention, Chief of the Core Performa'nce Branch, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555 at least 60 days prior to cycle initial criticality. In the event these values would be submitted at some other time during core life, it will be submitted 60 days prior to the date the values would become effective unless otherwise exempted by the Commission. '

Any information needed to support W(z) will be by request from the NRC and need not be included in this report. -

SPECIAL REPORTS

'6.9.2.l' Special reports shall be submitted to the Director of the Office of Inspection and Enforcement Regional Office within the time period specified for each report.

6.9.2.2 . Diesel Generator Reliability Imorovement Program As a minimum the Reliability Improvement Program report for NRC audit ,

required by LCO 3.8.1.1, Table 4.8-1, shall include:

(a) a summary of all tests (valid and invalid) that occurred within the time period over which the last 20/100 valid tests were performed (b) analysis of failures and determination of root causes of failures (c) evaluation of each of the recommendations of NUREG/CR-0660,

' "Enchancement of Onsite Emergency Diesel Generator Reliability in Operating Reactors, " with respect to their application to the Plant (d) identification of all actions taken or to be taken to 1) correct the root causes of failures defined in b) above and 2) achieve a general improvement of diesel generator reliability i

(

(e) the schedule for implementation of each action from d) above (f) an assessment of the existing reliability of electric power to engineered-safety-feature equipment pared Within 30 days after each subsequent A supplemental report shall be pre-i the affected diesel generator unit continues to violate the criteriafailure during a valid demand for l

(3/20 or 6/100) for the reliability improvement program remedial action.

The supplemental report need only update the failure / demand history for SEQUOYAll-UNIT 2 6-27 rus tsi

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued) the affected diesel generator unit since the last report for that diesel generator. The supplemental report shall also present an analysis of the failure (s) with a root cause determination, if possible, and shall delineate any further procedural, hardware or operational changes to be incorporated into the site diesel generator improvement program and the schedule for implementation of those changes.

In addition to the above, submit a yearly data report on the diesel generator reliability.

6.10 RECORD RETENTION In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

6.10.1 The following records shall be retained for at least five years:

a. Records and logs of unit operation covering time interval at each power level,

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c. All REPORTABLE EVENTS submitted to the Commission,

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e. Records of changes made to the procedures required by Specification 6.8.1 and 6.8.4.

f. Records of r,adioactive shipments.

g.

Records of sealed source and fission detector leak tests and results.

h. Records of annual physical inventory of all sealed source material of record.

SEQUOYAH - UNIT 2 6-27 a l

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ENCLOSURE 2 Proposed Technical Specification Change SEQUOYAH NUCLEAR PLANT Docket Nos. 50-327, 50-328 (TVA SQN TS 57)

Description and Justification for Proposed Changes to Surveillance Requirements for Diesel Generators es

. _ , , . - _ _ . . _ . , . _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - ' - - - - - ** ~

Description of Change This technical specification change will delete Surveillance Requirement (SR) 4.8.1.1.2.a.4.c. It will also add a footnote to SR 4.8.1.1.2.a.4. and 5 and SR 4.8.1.1.2.d.5 to allcw a reduction in fast start / fast load surveillance testing of Rmergency Diesel Generators. A change is made to SE 4.8.1.1.2.d.8 in Unit 1 technical specification to correct an editorial mistake.

The reporting requirements of 4.8.1.1.4 are changed to reference Administrative Control Section 6.9.2.2. This section is being added to describe the reporting required by the proposed Reliability Improvement Program.

Table 4.8-1 is being revised to reflect changes to the Diesel Generator reliability program and an attachment to this table is added to describe the L

Diesel Gener& tor Requalification Program.

Reason for Change l

The current testing program for emergeracy diesel generators has been determined to result in premature degradation due to excessive wear from cold starting. These changes are intended to reduce these cold starts and rapid accelerations.

SR 4.8.1.1.2.a.4.c requires verification of diesel generator start on a coincident test signal from Emergency Safety Feature Actuation System and a l

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simulated loss of offsite power. This surveillance test is not applicable to Sequoyah's system as designed and as such is extremely difficult if not impossible to perform.

The change to Unit 1 SR 4.8.1.1.2.d.8 is to correct an editorial mistake.

This SR refers to a surveillance requirement which does not exist.

The changes to Table 4.8-1, section 4.8.1.1.4 and 6.9.2.2 are intended to improve the reliability basis for diesel generator performance as recommended by Generic Letter 84-15 " Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability". (reference 1)

Justification for Change The change which deletes SR 4.8.1.1.2.a.4.c which requires verification of diesel generator start by injection of an Engineered Safety Feature (ESP) signal coincident with a simulated loss of offsite power signal. The emergency start logic of the diesel generator due to these signals is shown by reference 3. This drawing shows schematically, that contacts K609, 27DIAX and 27DIAY (which change positions in order to operate the ESIAY relay) are arranged in series. The K609 relay is associated with the actuation of the ESF signal. Relays 27DIAX and 27DIAY sense voltage from the 6900V shutdown boards and actuate on degradation of that voltage indicative of a loss of offsite power (reference 4). Operation of the ESIAY relay causes the correct alignment of its associated contacts in the remote auto-start circuitry for starting the Diesel Generator. (reference 5).

Since the K609, 27DIAX and 27DIAY contacts are arranged in series it would take simultaneous operation of these contacts to accomplish the surveillance requirements as currently present in technical specifications. Due to the electronics of the circuit it would be extremely difficult (if not impossible) to facilitate simultaneous operation of these contacts. Even if this were possible, due to the arrangement of the circuitry, this test would add no assurance to the verification of the operability of the diesel generators since the ESIAY relay operation is assured by the individual tests called for by SR 4.8.1.1.2.a.4.b and 4.8.1.1.2.a.4.d.

The change to SR 4.8.1.1.2.d.8 in Unit 1 technical specification is strictly editorial. As currently present in technical specifications this SR refers to I

l a non-existent SR 4.8.1.1.2.c.4. This should correctly be SR 4.8.1.1.2.d.4.

I The remainder of the changes proposed by this amendment request are intended to improve the reliability of the diesel generators. These changes are consistent with those proposed by Generic Letter 84-15 (reference 1). As currently present in technical specifications a cold, fast acceleration and loading of the diesel generators is required at least once per 31 days. It has been noted that this frequent starting and rapid acceleration from these conditions could add to wear of the diesel generators such that reliability could actually decrease.

The changes to Table 4.8-1 SR 4.8.1.1.4 and section 6.9.2.2 are intended to meet the guidelines for the Reliability Improvement Program as presented by Generic Letter 84-15 (reference 1).

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- References

1. Nuclear Regulatory Commission to All Licensees of Operating Reactors.

Applicants for an Operating License, and Holders of Construction Permits.

" Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability (Generic Letter 84-15)" dated July 2, 1984

2. L. M. Mills to H. R. Denton dated October 1, 1984 (L44 841001 807) (TVA response to Generic Letter 84-15)

3. TVA Drawing 45N767-5 " Wiring Diagram 6900V Diesel Generators Schematic Diagram SH-5" Revision 15 dated March 18, 1985

4. TVA Drawing 45N765-1 " Wiring Diagram 6900V Shutdown Auxiliary Power Schematic Diagram SH-1" Revision 14 dated April 16, 1986.

5. TVA Drawing 45N767-2 " Wiring Diagram 6900V Diesel Generators Schematic Diagram SH-2" Revision 13 dated October 4, 1983 FCM:GC 0001h

o ENCLOSURE 3 Proposed Technical Specification Change SEQUOYAH NUCLEAR PLANT Docket Nos. 50-327 and 50-328 (TVA SQN TS 57)

Proposed Evaluation of No Significant Hazards for Changes to Surveillance Requirements For Diesel Generators e

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SIGNIFICANT HAZARDS CONSIDERATIGiG

1. Is the probability of an occurrence or the consequences of an accident previously evaluated in the safety analysis report significantly increased?

No. The Diesel Generators and their associated circuitry are provided to assure a reliable source of power to essential plant equipment in case of a loss of offsite power. These changes are intended to improve the reliability of this emergency power supply. First, by decreasing a potential source of damage from excessive fast starts and loading.

Secondly, by instituting a reliability improvement program (which was proposed by Generic Letter 84-15). The deletion of SR 4.8.1.1.2.a.4.c does not affect D/G reliability since this test does not provide a different start signal than the individual tests required by 4.8.1.1.2.a.4.b and d. The change to Unit 1 SR 4.8.1.1.2.d.8 is an editorial correction and does not affect any analysis previously performed.

2. Is the possibility for an accident of a new or different type than evaluated previously in the safety analysis report created?

No. The changes do not represent a change in plant configuration or testing methods. The reduction in frequency of fast starts and the reliability basis testing is intended and has been evaluated to increase rather than decrease the reliability of the system.

The change to SR 4.8.1.1.2.d.8 for Unit 1 Technical Specification is editorial only and does not affect or create the possibility of a new or different type of accident l

l 3. Is the margin of safety significantly reduced?

No. The margin of safety provided by the Emergency Power Supply System (i.e. Diesel Generators) is that an available, reliable supply of power is available for emergency equipment in case of a loss of offsite power. The changes to the frequency of testing proposed by this amendment are evaluated to increase the reliability of the emergency power supply.

Deletion of SR 4.8.1.1.2.a.4.c does not affect the margin of safety since due to the physical arrangement of the circuitry this test prosides no additional assurance of diesel generators start than the performance of l individual starts required by SR's 4.8.1.1.2.a.4.b and 4.8.1.1.2.a.4.d.

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