ML20211H635

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Proposed Tech Specs,Modifying Section 3/4.8.1.1 Re Diesel Generator Testing
ML20211H635
Person / Time
Site: Callaway Ameren icon.png
Issue date: 02/18/1987
From:
UNION ELECTRIC CO.
To:
Shared Package
ML20211H606 List:
References
NUDOCS 8702260229
Download: ML20211H635 (13)
v • d • e


Text

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g 3/4.8 ELECTRICAL POWER SYSTEMS Attachment 1 3/4.8.l'A.C. SOURCES ULNRC-1448 OPERATING LIMITING CONDITION FOR OPERATION f

3.8.1.1 As a minimum, the f'ollowing A.C. electrical power sources shall be OPERABLE:

, a. Twopbhsi$allyindependentcircuitsbetweentheoffsite transmission network and the Onsite Class IE Distribution System, and

b. Two separate and independent diesel generators, each with:

V :{i - 1) A separate day tank containing a minimum volumeS.ofA l 390 gallons of fuel, I

( 2) A separate Fuel Oil Storage System containing a minimum volume of 85,300 gallons of fuel, and

3) A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION

a. One Offsite Circuit Inoperable:

With an offsite circuit of the above required A.C.

electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. source by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either diesel generator of the above required A.C. electrical power

! sources has not been s5cddssfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate OPERABILITY by perfornting Specification 4.8.1.1.2a.4)## for that diesel generator ,

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restore at~least two offsite circuits and two diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in 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 />.

b. One Diesel Generator Inoperable:

With one diesel generator of the above required A.C.

electrical power sources inoperable, demonstrate the

    1. The automatic start and sequence loading of a diesel generator satisfies the testing requirements of Specification 4.8.1.1.2a.4) for this Action Statement.

@702260229 B70218 5 PDR ADOCK 050004B3 3/4 8-1 P -PDR

OPERABILITY of the offsite A.C. sources by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Specification 4.8.1.1.2a.4) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in 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 />. In addition, perform ACTION d.

c. One Offsite Circuit and One Diesel Generator Inoperable:

With one offsite circuit and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining of fsite A.C. source by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and Specification 4.8.1.1.2a.4)## within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

  • for the remaining diesel generator.~~ Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT STANDBY within 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 />. Restore the remaining inoperable A.C. electrical power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the Specification 3.8.1.1 ACTION a.

or ACTION b., as applicable, with the time requirement for the ACTION based on the time of the initial loss of the remaining inoperable A.C. electrical power source.

A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4)## under this ACTION for an OPERABLE diesel generator satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a. or ACTION b. for an OPERABLE diesel generator. In addition, perform ACTION d.

d. With one diesel generator inoperable in addition to ACTION b. or c. above, verify that:
1. All required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and
  • This test is required to be completed regardless of when the inoperable diesel generator is restored to OPERABLE status unless the diesel was declared inoperable to do preplanned preventive maintenance, testing, or maintenance to correct a condition which, if left uncorrected, would not affect the OPERABILITY of the diesel generator.
    1. The automatic start and sequence loading of a diesel generator satisfies the testing requirements of Specification 4.8.1.1.2a.4) for this Action Statement.

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2. When in MODE 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.

If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in 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 />.

e. Two Offsite Circuits Inoperable:

With two of the above required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by sequentially performing Specification 4.8.1.1.2a.4) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the diesel generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in a least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Following restoration of one offsite A.C.

electrical power source, follow ACTION a. above with the time requirement of ACTION a. based on the time of the initial loss of the remaining inoperable offsite A.C.

electrical power source. A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4)## under this ACTION for the diesel generators satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a.

f. Two Diesel Generators Inoperable:

With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in 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 />. Following restoration of one diesel generator, follow ACTION b. with the time requirement of the ACTION based on the time of initial loss of the remaining inoperable diesel generator. A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4) under this ACTION for the OPERABLE diesel generators, satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION b.

SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the Onsite Class lE Distribution System shall be determined OPERABLE at least once

    1. The automatic start and sequence loading of a diesel generator satisfies the testing requirements of Specification 4.8.1.1.2a.4) for this Action Statement.

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per 7 days by verifying correct breaker alignments, indicating power availability 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

a. In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:
1) Verifying the fuel level in the day tank,
2) Verifying the fuel level in the fuel storage tank,
3) Verifying the fuel transfer pump starts and transfers fuel from the storage system to the day tank,
4) Verifying the diesel starts and accelerates to at least 514 rpm in less than or equal to 12 seconds.** The generator voltage and frequency shall be 4000 + 320 volts and 60 + 1.2 Hz within 12 seconds ** after the start signal.~ The diesel generator shall be started for this test by using one of the following signals, a) Manual, or b) Simulated loss-of-offsite power by itself, or c) Safety Injection test signal.
5) Verifying the generator is synchronized, gradually loaded to an indicated 6000 to 6201 kW*** for at least 60 minutes, and
6) Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.
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 day tanks;
c. At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks;
    • This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
      • This band is meant as guidance to avoid routine overloading -

of the engine. Loads in excess of this band for special testing under direct monitoring or momentary variations due to changing bus loads shall not invalidate this test.

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d. By sampling new fuel oil in accordance with ASTM-D4057 prior to addition to storage tanks and:
1) By verifying in accordance with the tests specified in ASTM-D975-81 prior to addition to the storage tanks that the sample has: ,

a) An API Gravity of within 0.3 degrees at 600F, or a gpecific gravity of within 0.0016 at when compared to the supplier's 60/60 F, certificate, or an absolute specific gravity at 60/600F of greater than or equal to 0.83 but less than or equal to 0.89, or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees; b) A kinematic viscosity at 400C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes, if gravity was not determined by comparison with the supplier's certification; c) A flash point equal to or greater than 125 0 F; and d) A clear and bright appearance with proper color when tested in accordance with ASTM-D4176-82.

2) By verifying within 30 days of obtaining the sample that the other properties specified in Table 1 of ASTM-D975-81 are met when tested in accordance with ASTM-D975-81 except that the analysis for sulfur may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
e. At least once every 31 days by obtaining a sample of fuel oil in accordance wtih ASTM-D2276-78, and verifying that total particulate contamination is less than 10 mg/ liter when checked in accordance with ASTM-D2276-78, Method A; f.# 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 recommendations for this class of standby service;
  1. The specified 18 month frequency nay be waived for Cycle I provided the surveillance is performed prior to restart following the first refueling outage or June 1, 1986, whichever occurs first. The provisions of Specification 4.0.2. are reset from performance of this surveillance.

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2) Verifying the diesel generator capability to reject a load of greater than or equal'to 1352 kW (ESW pump) while maintaining voltage at 4000 + 320 volts and frequency at 60 + 5.4 Hz;
3) Verifying the diesel generator capability to reject a load of 6201 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection;
4) Simulating a loss-of-off-site power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency

' busses, and b) Verifying the diesel starts ** on the. auto-start signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the shutdown sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the

- emergency busses shall be maintained at 4000 +-'

320 volts and 60 + 1.2 Hz during this test.

1

5) Verifying that on a Safety Injection test signal without loss-of-offsite power, the diesel generator starts ** on the auto-start signal and operates on standby for greater than or equal to 5 minutes; and the offsite power source energizes the auto-connected emergency (accident) load through the LOCA sequencer. The generator voltage and frequency shall be 4000 + 320 volts and 60 + 1.2 Hz

! within 12 seconds after the auto-start signal; the generator steady-state generator voltage and frequency shall be maintained within these limits 1

during this test;

6) Simulating a loss-of-offsite power in conjunction with a Safety Injection test signal, and a) Verifying deenergization of the emergency busses and load shedding from the emergency busses; b) Verifying the diesel starts ** on the auto-start signal, energizes the emergency busses with permanently connected loads within 12 a

1

    • This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized./

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seconds, energizes the auto-connected emergency (accident) loads through the LOCA sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with emergency loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 + 320 volts and 60 + 1.2 Hz during this test; and c) Verifying that all automatic diesel generator trips, except high jacket coolant temperature, engine overspeed, low lube oil pressure, high crankcase pressure, start failure relay and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal.

7) Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to an-~

indicated 6600 to 6821 kW*** and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to an indicated 6000 to 6201 kW.*** The generator voltage and frequency shall be 4000 + 320 volts and 60 + 1.2,-3 Hz within 12 seconds after the start signal; the steady-state generator voltage and frequency shall be maintained within 4000 + 320 volts and 60 + 1.2 Hz during this test. Withis 5 minutes after completing this 24-hour test, perform Specification 4.8.1.1.2f.6)b)*;

8) Verifying that the auto-connected loads to each diesel generator do not exceed 6201 kW;
9) 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,

  • If Specification 4.8.1.1.2f.6)b) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead the diesel generator may be operated at 6201 kW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until operating temperature has stabilized.
      • This band is meant as guidance to avoid routine overloading of the engine. Loads in exceas of this band for special testing under direct monitoring or momentary variations due to changing bus loads shall not invalidate this test.

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

10) Verifying that with the diesel generator operating in a test mode, connected to its bus, a simulated Safety Injection signal overrides the test mode by:

(1) returning the diesel generator to standby operation, and (2) automatically energizing the emergency loads with offsite power;

11) Verifying that the fuel transfers pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines; and
12) Verifying that the automatic LOCA and shutdown sequence timer is OPERABLE with the interval between each load block within + 10% of its design interval.
g. At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting ** both diesel generators simultaneously, during shutdown, and verifying that both diesel generators accelerate to at least 514 rpm in less than or equal to 12 seconds; and
h. At least once per 10 years by:
1) Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or equivalent, and
2) Performing a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure.

i l

    • This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.

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i. At least once per 184 days the diesel generators shall be started ** from ambient conditions (using the keep warm system) using one of the signals specified in 4.8.1.1.2a.4) and accelerated to at least 514 rpm in less than or equal to 12 seconds. The generator voltage and frequency shall be 4000 + 320 volts and 60 + 1.2 Hz within 12 seconds after the start signal. . Subsequently verify _the generator is loaded to an indicated 6000 to 6201 kW*** in less than or equal to 60 seconds and operates at an indicated load of 6000 to 6201 kW*** for

~

at least 60 minutes.

4.8.1.1.3 Reports - All diesel generator failures, valid or nonvalid, shall be reported in a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days. Reports of diesel generator failures shall include the information

< recommended in Regulatory Position C.3.b. of Regulatory Guide

' l.108, Revision 1, August 1977. If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1, August 1977.

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    • This test shall be preceded by an engine prelube period so that the mechanical stress and wear on the diesel engine is minimized.
      • This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band for special testing-under direct monitoring or momentary variations due to changing bus loads shall not invalidate this test.

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TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE #

1 NUMBER OF FAILURES IN NUMBER OF FAILURES IN LAST 20 VALID TESTS

  • or LAST 100 VALID TESTS
  • TEST FREQUENCY

<1 -

<4 At least once per 31 days

> 2** -

> 5 At least once per 7 days

  1. - The most limiting test frequency should be applied from the two columns of this table.
  • Criteria for determining number of failures and number of j valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, but determined on a per diesel generator basis.

For the purposes of determining the required test frequency, the previous test failure count may be reduced to zero if a complete diesel overhaul to_like-new conditions is completed, provided that the overhaul, including appropriate post-maintenance operation and testing, is specifically approved by the manufacturer, and if acceptable reliability has been demonstrated. The reliability criterion shall be the successful completion of 14 consecutive tests in a single series. Ten of these tests shall be in accordance with Specification 4.8.1.1.2a.4) and 4.8.1.1.2a.5); four tests in accordance with Specification 4.8.1.1.2i. If this criterion is not satisfied during the first series of tests, any alternate criterion to be used to transvalue the failure count to zero requires NRC approval.

    • The associated test frequency shall be maintained until seven consecutive failure free tests have been performed and the

! number of failures in the last 20 valid tests has been reduced to one.

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Attachment 2 ULNRC 1448 SUPPLEMENTAL EVALUATION

References:

1) ULNRC-1376 dated 9/29/86
2) Amendment No. 48 to Facility Operating License NPF-7 for the North Anna Power Station, Unit No. 2, dated 4/25/85 This Supplemental Evaluation addresses the changes to diesel generator (D/G) testing requirements identified in Attachment 1 to this letter from those changes proposed in the amendment request transmitted by Reference 1. These changes are considered minor in nature and are consistent with findings of the Safety Evaluation and Significant Hazard Evaluation transmitted by Reference 1.
1. Action Statements 3.8.1.1.a, 3.8.1.1.c, and 3.8.1.1.e A ## footnote has been added to clarify that for the purpose of these action statements, an automatic start and sequence loading of the D/G satisfies the testing requirements of 4.8.1.1.2a,4). Surveillance 4.8.1.1.2a.4) verifies that the diesel starts and accelerates to rated speed and voltage within 12 seconds.
2. Action Statements 3.8.1.1.b and 3.8.1.1.c The
  • footnote has been revised to clarify that the testing of the OPERABLE D/G is not required when a diesel is declared inoperable to do preplanned preventive maintenance, testing, or maintenance to correct a condition which, if left uncorrected, would not affect the operability of the D/G.

This is to allow work to be performed to correct conditions which would clearly not have implications of a common mode failure and which could have affected the operability of both D/Gs. This footnote has also been udded to Action Statement 3.8.1.1.c.

3. Action Statement 3.8.1.1.e This action statement is applicable when two offsite circuits are inoperable. The statement has been changed to clarify that the demonstration of D/G operability under 4.8.1.1.2.a.4) is to be performed sequentially for the two diesels.
4. Surveillance Requirements 4.8.1.1.2a.5), 4.8.1.1.2f.7), and
      • footnote These surveillance requirements have been changed to require the D/G be tested to a range near the rated load rather than to 60% of rated load as proposed in Reference 1.

(Union Electric and the D/G engine manufacturer believe the test to 60% of rated load is sufficient to demonstrate D/G operability and that operating the D/G at 100% rated load will lead to additional wear on the unit. It is also true that the diesel is designed to operate at the rated load for extended lengths of time and that the differential between the two during surveillance testing will not have a noticeable effect on the diesel life. Given the other improvements included in the referenced amendment request, the overall benefit in diesel reliability is maintained.)

The *** footnote addresses testing of the D/G at a range near 100% rated load to prevent routine overloading of the D/G. This is similar to the changes previously approved by NRC in Reference 2.

5. Surveillance Requirement 4.8.1.1.2f This change addressed performing certain 18 month surveillances during operation. Union Electric has decided not to pursue this change but to maintain the presently approved specification which requires that they be performed during shutdown. This is based on the guidance provided in NRC I&E Information Notice 84-69 and its Supplement 1. The flexibility gained through this change is not considered essential and would most likely not be utilized.
6. Surveillance Requirement 4.8.1.1.2f.7) and *** footnote This change is similar to the change previously discussed in Item 4 concerning testing at a range to prevent routine overloading. This change provides a range for the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> test of the diesel at 6821 kW. This is similar to the changes previously approved in Reference 2.
7. Surveillance Requirement 4.8.1.1.21, ** footnote, and ***

footnote This surveillance requirement and ** footnote have been revised to clarify that the test will be performed from ambient conditions using one of the signals specified in 4.8.1.1.2a.4). Ambient conditions are clearly identified as using the keep warm system, and the ** footnote requires the test be preceded by an engine prelube period.

This surveillance requirement has been revised and the ***

footnote added to address testing at a range near 100% rated load to prevent routine overloading. This is similar to Items 4 and 6 above and to the changes previously approved in Reference 2.

8. Table 4.8-1,
  • footnote This footnote addressed the requirements to reduce the previous test failure count to zero. The post-maintenance operation and testing is to be specifically approved by the manufacturer. T:.is has been previously approved by NRC in Reference 2.

The 14 consecutive test series include ten tests in accordance with Specifications 4.8.1.1.2a.4) and 4.8.1.1.2a.5). These include starting the diesel, gradually loading to 100% rated load and operating it for one hour.

Four of the fourteen tests are to be in accordance with 4.8.1.1.2i, which in addition, loads the D/G within 60 seconds. This is a more stringent test than that originally proposed in Reference 1.

An additional sentence has been added to the

  • footnote to clarify that if the first series of tests is not satisfied, NRC approval is required of any alternate criterion to reduce the failure count to zero. This has been previously approved by NRC in Reference 2.

Conclusion The changes discussed in this Supplemental Evaluation are minor in nature and are consistent with the evaluations previously transmitted by Reference 1.

_ __

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