ML20209H104

Proposed Tech Spec Change to Table 4.8.1.1.2-1 Re Diesel Generator Test Schedule

ML20209H104
Person / Time
Site:	Grand Gulf
Issue date:	01/29/1987
From:	SYSTEM ENERGY RESOURCES, INC.
To:
Shared Package
ML20209G695	List: AECM-87-0024, Amended Application for Amend to License NPF-29,originally Submitted on 860522 & 1209.Wording of Footnote to Tech Spec Table 4.8.1.1.2-1 Changed to Reflect Discussion W/Nrc ML20209H104
References
TAC-55863, NUDOCS 8702050528
Download: ML20209H104 (4)

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AECM-87/0024 Page 4 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0. NPF-29 DOCKET N0. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of System Energy Resources, Inc.; and that the statements made and the matters set for therein are true and correct to the best of my knowledge, information an ief.

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STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 before me, a Notary Public, in and for the County and State above named, this f94(day of %nge r t; , 1987.

J (SEAL)

NotgyPublic' My commission expires:

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./9' 8702050528 870129 PDR ADOCK 05000416 P PDR J19AECM87012601 - 4

NLS 85/17 Diesel Generator Technical Specification Relaxations (Supplement)

SUBJECT:

Technical Specification Table 4.8.1.1.2-1; Page 3/4 8-8 DISCUSSION: Proposed changes to Technical Specifications regarding A.C.

Electrical Power Sources were submitted to the NRC by letter (AECM-86/0157) dated May 22, 1986 and subsequently resubmitted by letter (AECM-86/0394) dated December 9, 1986. Discussions with NRR staff have resulted in this amended submittal which

-addresses the staff's comments regarding the wording of the footnote to Table 4.8.1.1.2-1.

The proposed changes to Technical Specification 3.8.1.1, 4.8.1.1.2.a.4, 4.8.1.1.2.a.5 and Bases 3/4.8.1 are as described in the submittal dated December 9, 1986.

JUSTIFICATION: The proposed deletion of the 3 day test frequency follows the intent of Generic Letter 84-15 to reduce unnecessary testing of diesel generators. The 7 day minimum test interval provides adequate assurance of diesel generator operability and follows the guidance in Generic Letter 84-15.

The criteria for determining number of failures and number of valid tests is currently based on a per nuclear unit basis.

The proposed change is to a per diesel generator basis follow-ing the guidance in Generic Letter 84-15. Presently, with one diesel generator experiencing failures, the test frequency for all three diesel generators is increased. This increased testing on diesel generators which have not experienced valid failures decreases their reliability and increases the potential for wear related problems.

The OL issuance date of June 16, 1982 has been included so as to clearly define the start date from which valid tests are to be computed.

The present statement that entry into this test schedule shall be made at the 31 day test frequency has been deleted. The number of valid failures determines the frequency of testing thus negating the need for this statement.

SIGNIFICANT HAZARDS CONSIDERATIONS:

SERI has evaluated the proposed changes and considers them not to involve a significant hazards consideration for the j following reasons:

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(1) The proposed changes will not significantly increase the probability or consequences of an accident previously evaluated, because the' changes will eliminate a practice of unnecessary and potentially detrimental diesel generator testing contained in the technical specifica-tions. Such testing contributes to accelerated diesel generator wear, which consequently degrades their reliability and availability. Increasing the reliability and availability of the diesel generators helps to further assure their ability to perform their design functions when required in accident situations. Therefore, previous accident analyses are not adversely impacted and the probability or consequences of an accident previously evaluated has not been increased.

(2) The proposed changes will not create the possibility of a new or different accident from any accident previously evaluated, because no physical modifications are required to be made to the plant in conjunction with these proposed changes. The changes are intended to increase diesel generator reliability; therefore, availability of the onsite emergency power system as described in the FSAR will be enhanced. No new failure modes are introduced by the proposed changes; therefore, these changes will not create the possibility of a new or different accident from any previously evaluated.

(3) The proposed changes will not involve a significant reduction in a margin of safety, because demonstration of diesel generator operability will be maintained as necessary to ensure operability and availability, and will be conducted on a more optimum test schedule that will improve the overall performance of the onsite emergency power system.

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J12ATTCH87012601 - 2 L

TABLE 4.8.1.1.2-1 DIESEL GENERATOR TEST SCHEDULE Number of Failures in Last 100 Valid Tests

• Test Frequency 11 At least once per 31 days 2 At least once per 14 days 33 At least once per 7 days i4 ^t ! = t en:

. pt- ? ty:

• Criteria for determining number of f ailures and number of valid test shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the last 100 tests are determined on a perarc'c: e 't basis. For the l dinej geneawpurposes of this test schedule, ohly valid tests conducted af ter the OL issuance date 4 shall be included in the computation of the

,, m y ,,,,,[.ed;eth;=e:,t=1.=;=:3 last 100 valid tests." Entry 'it: thh t;;t ;;h;d le ; hall 6 I

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