ML20211A874

Informs That Repetition of 69/n Emergency Diesel Generator Start Tests Unnecessary Nor Productive,Based on Listed Findings.Response to Region III in Preparation.Request for Formal Technical Evaluation Rept Canceled

ML20211A874
Person / Time
Site:	Perry
Issue date:	01/23/1986
From:	Stefano J Office of Nuclear Reactor Regulation
To:	Giardina R, Tomlinson E NRC
References
NUDOCS 8606110396
Download: ML20211A874 (3)

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%,.....,/ JAN 2 31986 NOTE T0: E. Tomlinson, P-904 R. Giardina, P-904 FROM: J. Stefano, Sr. Project Manager BWR Project Directorate No. 4

SUBJECT:

REGION III ASSISTANCE REQUEST (1/3/86) RE TDI EMERGENCY DIESEL GENERATOR (EDG) START TESTS In consideration of the views expressed by you and C. Berlinger (TDI/EDG Task Force Lead Engineer) during our meeting of January 10, 1986 to discuss the subject regional staff assistance request, and subsequent discussions held with the Perry Applicant (CEI), it has been concluded that it would not be necessary or proouctive to have CEI repeat any cf the 69/n EDG start tests in accordance with Regulatory Position C.2.a(9) in Regulatory Guide (RG) 1.100. This conclusion is based on the following findings and determinations:

1. For the Perry TDI/EDGs and possibly other EDGs with lube oil preheat systems, the only significant offset which would be determined from a repeat of the 69/n start tests would be a confirmation of the quality anc reliability of the engine control systems. The abil.ity of the Perry EDGs to start on demand would be unaffected by variations in engine lube oil / jacket water /

component metal tenperatures, as long as the engine temperature is ebove 50 F. If the engines are start-tested at any temperature within the standby temperature range recommended for the Perry EDGs by the manufacturer (140 F to 180 F), there would not be any discernible ditference in engine starting reliability, altering the results of the tests already performed by CEI. The test results attached to the Region 111 assistance request neno show that the 69/n start tests were all performed within the manufacturer's recommended standby temperature range.

2. The variation in lube oil, jacket water and engine component metal ten.peratures observed during the Perry 1 EDG tests are believed to be insignificant for the reasons stated above, even though (as you main-tained at the January 10th meeting) that the engines would experience less resistance during startup at temperatures higher than the 150 F lube oil tenperature which you censider to be the more accurate standby teroperature at which the engines shculd have been allowed to cori dcwn between each consecutive start.

Contact:

J.Stefano X28358 8606110396 860123 PDR ADOCK 05000440 P PDR

, E. Tomlinson/R.Giardina 3. Finally' we cannot find any regulatory basis, definition, or requirement for " standby" temperature in RG 1.108 or the Perry SER, other than that RG 1.108 stipulates that the 69/n tests be performed within the temp-erature range recommended by the EDG manufacturer. In the case of Perry, the 69/n start tests would total 23 tests per EDG. (i.e., since the Perry plant utilizes four identically designed TDI/EDGs, the minimum number of tests required for each EDG is 23). From the test data furnished by the regional staff, CEI appears to have performed more than the required number of start tests per EDG, having conducted 35 start tests with each Perry 1 EDG. Therefore, we fino that CEI has adequately met its FSAR comitments to RG 1.108.

l We are preparing a response to Region III which will relate the above findings.

and determinations. Should you desire to comment further on this matter please

' let me know. Otherwise, my January 7,1986 request to you for a formal technical evaluation report is hereby cancelled. I do, however, wish to express my appre-ciation for your technical assistance on this matter, q

, /

Joh l . Stef no, r. Project Manager BW iroject ir- orate No. 4 cc: R. Bernero R. Houston .

W. Butler J. Hulman M. Srinivasan C. Berlinger C. Woodhead, (ELD)

I l

F .

E. Tomlinson/R.Giardina 3. Finally, we cannot find any regulatory basis, definition, or requirement for " standby" temperature in RG 1.108 or the Perry SER, other than that RG 1.108 stipulates that the 69/n tests be performed within the temp-erature range recomended by the EDG manufacturer. In the case of Perry, the 69/n start tests would total 23 tests per EDG. (i.e., since ,

the Perry plant utilizes four identically designed TDI/EDGs, the minimum number of tests required for each EDG is 23). Frcm the test data furnished by the regional staff,_CEI appears to have performed more than the required number of start tests per EDG, having conducted 35 start tests with each Perry 1 EDG. Therefore, we find that CEI has adequately met its FSAR comitments to RG 1.108.

We are preparing a response to Region III which will relate the above findings, and determinations. Should you desire to comment further on this matter please let me know. Otherwise, my January 7, 1986 request to you for a formal technical evaluation report is hereby cancelled. I do, however, wish to express my appre-ciation for your technical assistance on this matter.

Original St-~1 by John J. Stefano, Sr. Project Manager BWR Project Directorate No. 4 cc: R. Bernero R. Houston W. Butler 1 J. Hulman l M. Srinivasan C. Berlinger C.Woodhead,(ELD)

]ISRIBUTION: .. . _

%cket or Central: File' NRC PDR Local PDR PDe4 Reading File JStefano itRushbrook M

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! i 01/3/86