ML20213G651

Application for Amend to License NPF-42,revising Tech Spec 3/4.8.1 to Achieve Overall Improvement in Diesel Generator Reliability & Availability.Safety Evaluation & Significant Hazards Consideration Also Encl.Fee Paid

ML20213G651
Person / Time
Site:	Wolf Creek
Issue date:	11/14/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20213G654	List: ML20213G651 ML20213G655
References
KMLNRC-86-212, TAC-63951, NUDOCS 8611180248
Download: ML20213G651 (19)

Text

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KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY GLENN L KOESTER vice patt+ DENT NvCLE Am November 14, 1986 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 KMLNRC 86-212 Re: Docket No. STN 50-482 Subj: Revision to Technical Specification 3/4.8.1-Electrical Power Systems-A.C. Sources

Dear Mr. Denton:

The purpose of this letter is to transmit three original and 40 conformed copies of an amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station, Unit No. 1. Submittal of this amendment request supports, Licensing NPF-42.in part, resolution of License Condition 2.c (11) of Operating The application 1,

for amendment revises Wolf Creek Generating Station, Unit No.

Technical Specification 3/4.8.1 and its associated Bases modifying the Emergency Diesel Ger.c.7 tor (D/G) Technical Specification to achieve an overall improvement in D/G reliability and availability. The proposed changes to the Technical Specifications are provided in Attachments III and IV.

A complete Safety Evaluation and Significant Hazards Consideration are provided in Attachment I and II respectively.

In accordance with 10 CFR 50.91, a copy of the application, with attachments is being provided to the designated Kansas State Official. Enclosed is a check for the $150.00 application fee required by 10 CFR 170.21.

The proposed modification of the Wolf Creek Generating Station Technical Specifications will be fully impleme.1ted within 30 days of formal Nuclear Regulatory Commission approval.

bbbhey PDR fg g N Rec 'l w/c*cd'o "o 201 N. Market -Wictuta, Kansas -Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

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Mr. H. R. Denton November 14, 1986 KMLNRC 86-212 Page 2 If you haie any questions concerning this matter, please contact me or Mr.

O. L. Maynard of my staff.

Very truly yours, kA 1

Glenn L. Koester

, GLK:see Vice President - Nuclear Enclosure 1

Attachments: I Safety Evaluation II Significant Hazards Consideration III Proposed Technical Specification Changes (marked up)

IV Proposed Technical Specification Changes (typed) cc: P0'Connor (2)

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I, John A. Bailey, of lawful age, being first duly sworn upon oath, do depose, state and affirm that I am Director Engineering and Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, that I have i cigned the foregoing letter of transmittal for Glenn L. Koester, Vice President -

Nuclear of Kansas Gas and Electric Company, know the content thereof; and that all statements contained therein are true.

By John A. Bailey Director Engiheering Technical Services SUBSCRIBED and sworn to before me this / day of' Of2 , 1986. ,'.$.! ..!.., ',

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I Mr. H. R. Denton November 14, 1986 Attrchmsnt I to KMLNRC 86-212 Paga 1 SAFETY EVALUATION I. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action a A. Description of Change This action statement provides the actions to be taken with one offsite circuit of the required A.C. electrical power sources inoperable. The actioni required when one diesel generator (D/G) is inoperable are being separated from this action _ statement and incorporated into an individual action statement (proposed Technical Specification 3.8.1.1. Action b.).

Specification 4.8.1.1.2a.4), demonstration of D/G operability, will be performed once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for each D/G unless a D/G has been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The existing Specification requires demonstration of D/G operability pursuant to 4.8.1.1.2a.4) ,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 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter regardless of when the last D/G test was performed.

B. Justification Performing D/G operability tests following the loss of one offsite circuit is to verify the availability of a backup power source. The D/G's are designed and are intended to be standby power sources.

The present Technical Specifications require that both D/G's be tested initially within the first hcur and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, regardless of how recently a test has been successfully completed.

In a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period, an inital test within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and a followup test every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter results in a total of nine D/G tests.

This contradicts manufacturer recommendations that the D/G's be tested with a maximum frequency of 7 days and introduces accelerated D/G wear. However, it is understood that when an offsite power source is lost D/G availability becomes more essential and the D/G's should be tested if they have not been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If a D/G has been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an additional test provides little further assurance of D/G availability than what was provided in the previous successful test. D/G testing within the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will, in addition to providing assurance of starting capability, also provide additional time for inspection and prelube and other warmup procedures recommended by the manufacturer to minimize the mechanical stress and wear on the D/G's. Furthermore, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permits sequential testing of the D/G's rather than the simultaneous testing of both.

Repetitive testing increases the likelihood of a D/G failure rather than providing continued assurance of starting capability especially since loss of an offsite source does not directly imply a failure of the D/G's. Based on the above, the tests required for one inoperable D/G are being separated from this action statement.

Mr. H. R. Denton November 14, 1986 Attrchm:nt I to KMLNRC 86-212 Page 2 The present' D/G testing requirements have been identified as a contributing factor to inducing premature diesel engine wear.

Consistent with Generic Letter 84-15, one operability test per D/G provides assurance of D/G availability in the event of a loss of an offsite power source.

II. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1. Action b.

A. Description of Change This action statement provides the actions required when declaring one D/G inoperable. Making this a separate action statement is an administrative change.

Specification 4.8.1.1.2a.4), demonstration of D/G operability, will be performed once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of declaring a D/G inoperable unless the D/G became inoperable due to preplanned preventive maintenance or testing. This test will be required to be completed regardless of when the inoperable D/G is restored to an operable status. The present requirement is to perform a D/G operability test 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 the inoperable D/G is not returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the action will require the unit to be in hot standby within 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 />.

B. Justification Performing a D/G cperability test following the loss of the remaining D/G is to verify the availability of the remaining D/G.

Specifically, an operability test of the remaining D/G provides assurance that the remaining D/G is not subject to a common mode failure. Testing the operable D/G by verifying D/G starting capability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is in accordance with manufacturer recommendations. The discussions in the justification for Specification 3.8.1.1 Action a. are applicable to this action also.

III. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action c.

A. Discussion This action statement provides the required actions to be taken when declaring one offsite A.C. source and one D/G inoperable.

This is Action b. of the existing Technical Specifications.

Specification 4.8.1.1.2a.4) will be performed once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of declaring both A.C. electrical power sources inoperable. The present requirement is to demonstrate D/G operability within 1

r" Mr. H. R. Denton November 14, 1966L

{f Attachesnt I to KMLNRC 86-212 Page 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 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. Clarification is also provided regarding required actions to subsequently entered action statements. When a D/G or an offsite A.C. circuit is returned to service, either the proposed Action a. or Action b.

is entered.

B. , Justification Performing .a D/G operability test within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of declaring an offsite source and a D/G inoperable provides adequate assurance of the availability of the remaining D/G while eliminating.

unnecessary D/G starts. Since the allowable outage period for this action is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, followup D/G starts are not applicable.

A successful D/G operability test performed pursuant to this action also satisfies the subsequent requirement to verify D/G operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under Action a. or Action b. This transfer statement prevents having to retest a D/G just because a new Action is entered when the D/G has previously been tested as part of .this Action. This will aid in eliminating unnecessary D/G starts. These changes are consistent with Generic Letter 84-15.

IV. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action d.

This action provides the required response when a D/G is inoperable.in addition to the requirements of Action b. or Action c.. In the existing Specifications this is Action c. and refers to Actions a. or b.. There are no substantive changes to this Action only a relabeling of Action statements.

V. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1. Action e.

A. Description of Change This action provides the required response in the event of a loss of both offsite A.C. circuits. Specification 4.8.1.1.2a.4) will be performed once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the D/G's are already operating. The existing Specification requires the D/G's to be tested within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the loss of both offsite A.C. electrical power sources and at lease once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

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B. Justification l'

i The proposed change is consistent with these made for Actions a, b and c above. As previously noted, loss of an offsite A.C.

electrical power source does not suggest that the D/G's have become less reliable than noted by a previous surveillance test.

Given the significance of losing both offsite A.C. electrical 4

power sources, one operability test per D/G within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

provides adequate assurance of D/G availability. This proposed

! change is consistent with Generic Letter 84-15.

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Mr. H. R. Denton Novembar 14, 1986 Attechmant I to KMLNRC 86-212 Page 4 VI. PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action f.

A. Description of Change This action provides the required response when both D/G's are inoperable. This is Action e. of the existing Specifications.

Following the restoration of a D/G, Action b. would be entered and will require restoring the remaining D/G within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of the initial loss or be in 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 with the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. There are no substantive changes proposed, only clarification of the required Action as D/G's are returned operable.

B. Justification See description above.

VII. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2a.5)

A. Description of Change The present surveillance requirement demonstrates D/G operability by verifying the D/G is synchronized and loaded to greater than or equal to 6201 kW (continuous rating) in less than or equal to 60 seconds and operated with a load greater than or equal to 6201 kW for at least 60 minutes. The proposed changes modify the test requirement to permit gradual loading of the D/G's during routine surveillance and Action statement operability testing.

The proposed change also reduces the loading requirement of 6201 kW to greater than or equal to 3721 kW (60% of continuous rating) any time the D/G is routinely operated.

B. Justification To reduce wear and minimize the severity of thermal transients on the D/G's, the manufacturer has recommended gradual loading of the D/G's to greater than or equal to 60% of continuous rating load (3721 kW) any time a D/G is routinely tested. The manufacturer has recommended gradual loading of the D/G's during routine surveillance / maintenance situations as a means of engine preconditioning and to avoid subjecting the D/G to the severe thermal transients which result from fast loading. Reaching the continuous rating load within 60 seconds is based on FSAR analysis assumptions for a design base LOCA concurrent with a LOOP. Requiring the D/G to be routinely tested to design base conditions is excessive, unwarranted and against manufacturer recommendations. A design basis accident test performed every 184 days is sufficient to ensure the D/G's can withstand design basis accident loads (proposed Specification 4.8.1.1.2f. Routine surveillance tests should be used as a means of implementing

Mr. H. R. Denton Novembsr 14, 1986 Attcchmsnt I to KMLNRC 86-212 Pega 5 manufacturer's testing recommendations and verifying load handling capability not accident simulation testing.

Accordingly, the proposed changes have eliminated the 60 second requirement from this surveillance and included it into the 184 day surveillance testing pursuant to the proposed Specification 4.8.1.1.2f. These changes are in accordance with Generic Letter 84-15.

VIII. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2f A. Description of Change This Specification is proposed to encompass the 184 day test requirements as discussed earlier in the proposed changes to Specifications 4.8.1.1.2a.4) and 4.8.1.1.2a.5). This surveillance demonstrates D/G operability by verifying the D/G's can be started and loaded under design base accident conditions.

The D/G's will be verified to start and accelerate to at least 514 rpm in less than or equal to 12 seconds. The generator voltage and frequency will also be verified to attain 4160 + 160

- 420 volts and 60 1 1.2 Hz respectively within 12 seconds after

, the start signal. In addition, the generator is verified to be loaded to greater than or equal to 6201 kW (continuous rating) 4 within 60 seconds after the start signal for at least 60 minutes.

B. Justification This surveillance encompasses the same requirements of the existing Specifications 4.8.1.1.2a.4) and 4.8.1.1.2a.5) with the exception of reducing the surveillance interval.

IX. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2g.4. 5 and 6 A. Description of Change Notes have been added to ensure that an engine prelube is done prior to starting the diesel.

B. Justification Only once every 184 days does the diesel have to be started from ambient conditions, these notes merely ensure that a prelube is performed.

X. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2g A. Description of Change This change is being submitted concurrent with the other proposed changes in order to reduce Technical Specification change submittals. This change is not related to Generic Letter 84-15 or manufacturer recommendations. This change deletes the requirement to perform 18 month surveillances only during shutdown.

Mr. H. R. Denton November 14, 1986 l Att: chm:nt I to KMLNRC 86-212 Page 6 B. Justification The "during shutdown" requirement of Specification 4.8.1.1.2g pertains to all items under that section (1 through 12). While j it is necessary to perform some of these tests with the plant I shutdown , there are tests that could be performed with the plant "on-line" thereby reducing the number of surveillances required during an outage and prevent requiring a plant shutdown for a surveillance that could be performed "on-line" thereby reducing the number of surveillances required during an outage and prevent requiring a plant shutdown for a surveillance that could be performed "on-line" (i.e. Sections 2, 3, 11, etc.). For those surveillances requiring shutdown, the surveillance procedures identify the appropriate mode of operation for performance as initial conditions.

XI. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2g.4)

This surveillance requirement verifies the D/G starts on the auto-start signal in the event of LOOP. No substantive changes are made, only a footnote stating that D/G starts pursuant to this Specification shall be conducted in accordance with manufacturers recommendations regarding engine prelube and warmup procedures. This is consistent with Generic Letter 84-15.

XII. PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2h/.21 These Specifications are 4.8.1.1.2g/2h respectively of the existing Specifications. No substantive changes are proposed only a relabeling of the Specifications due to the addition of Specification 4.8.1.1.3f.

XIII. PROPOSED TECHNICAL SPECIFICATION TABLE 4.8.-1 A. Description of Change This table provides the required D/G surveillance test frequency for Specification 4.8.1.1.2a.4). The existing test frequency is based on the number of valid failures experienced in the last 100 valid tests per nuclear unit in accordance with Regulatory Guide 1.108, Revision 1, August 1977. The proposed test frequency is based on a matrix of the number of valid failures in the last 20 and 100 valid tests on a per D/G basis. In addition, the proposed changes provide a restart in counting failuras provided successful corrective actions have been implemented.

Mr. H. R. Denton Novembsr 14, 1986 l

• Att chmsnt I to KMLNRC 86-212 Pega 7 B. Justification The existing Specifications require accelerated surveillance testing of the D/G's based on the number of valid failures in the last 100 valid tests in accordance with Regulatory Guide 1.108.

The test schedule is based on a nuclear unit basis rather than a D/G basis. The current test frequency proceeds from testing the D/G's at least once per 31 days, 14 days, 7 days or 3 days when the number of valid D/G failures is less than or equal to 1 failure, 2 failures, 3 failures, or greater than or equal to 4 failures respectively.

The proposed changes provide a different test schedule adapting the general criteria of Regulatory Guide 1.108 and Generic Letter 84-15 with the exception that a reset in the number of valid failures to zero is permitted following a complete diesel overhaul and successful post-maintenance, operability verification and subsequent surveillance testing per vendor manual. Post-maintenance testing will be established on a case specific basis dependent on the extensiveness of the overhaul (i.e. it is anticipated if replacement of major parts is needed that a more extensive test program including a break-in run of the diesel and power run to re-baseline trending parameters would be required). Operability testing will remain per common practice (Specification 4.8.1.1.2a.4).

The concept of resetting the number of valid failures to zero is included to encourage corrective actions which enhance reliability rather than maintain a punitive testing schedule following corrective action that is counterproductive to diesel reliability. The 100 valid test criteria has also been revised to reflect the Generic Letter 84-15 concept of reliability goals. In addition, the proposed change provides accelerated testing based on the number of valid failures in the last 20 valid tests. Two valid D/G failures in the last 20 valid starts may be indicative of a failure rate of 0.1 (90% reliability).

Accelerated testing at this point in time would provide better sensitivity to the possibility of abrupt D/G degradation and initiate prompt corrective actions. Increasing the test frequency would provide a faster accumulation of test data upon which to judge D/G reliability. This additional data can be used to distinguish between failures which occur in a short period of time simply due to coincidence and failures that are indicative of an abrupt decline in actual reliability. The 7 day test frequency would be continued until 7 consecutive failure free tests have been performed and the number of failures in the last 20 valid tests have been reduced to one.

Seven successful tests indicate a reliability of at least 0.90/ demand but only at the 50% confidence level. Continued accelerated testing until the number of failures is 1 out of 20 provides further assurance that the D/G has not degraded below the 0.90/ demand level. This is consistent with the recommendations of Generic Letter 84-15.

Mr. H. R. Denton November 14, 1986 Att!chmsnt I to KMLNRC 86-212 Page 8 This Amendment request revises the existing Wolf Creek Generating Station Technic.a1 Specification requirements concerning emergency diesel generator testing. These changes are in accordance with the intent of guidance provided by the Commission in Generic Letter 84-15 and manufacturer's recommendations. The proposed changes should serve to increase overall emergency diesel generator reliability and . longevity. Based on the aforementioned discussion, KG&E has concluded that the proposed revision's to Technical Specification 3/4.8.1 and its associated Bases do not adversely affect or endanger the health or safety of the general public or involve an unreviewed safety question.

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Mr. H. R. Denton November 14, 1956 Attrohmint II to KMLNRC 86-212 Pags 1 SIGNIFICANT HAZARDS CONSIDERATION The proposed modification to action statement testing requirements does not involve a significant hazards consideration.

1) This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The change does not involve a change in the operational limits cr physical design of the emergency power system. In -accordance with the recommendations of Generic Letter 84-15, the proposed testing requirements adequately assure continued emergency diesel generator operability and reliability while minimizing the number of required i emergency diesel generator (D/G) starts. This also allows adequate time for the completion of all manufacturer recommended D/G prelubrication and warmup procedures.

2) This change does not create the possibility of a new or different kind of accident- from any accident previously evaluated. The change does not involve a change in the operational limits or physical design of the emergency power system. This change does not affect emergency diesel generator performance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability.

3) This change does not involve a significant reduction in a margin of safety. The change does not involve a change in the operational limits or physical design of the emergency power system. This change does not affect emergency diesel generator performance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability. No margin of safety is reduced.

The proposed modification to routine (frequency other than 184 days or 18 months) load testing requirements does not involve a significant hazards consideration.

1) This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

This change does not involve a change in the operational limits or physical design of the emergency power system. The emergency diesel generator manufacturer has recommended gradual loading of the D/G's to greater than or equal to 60% of continuous rating load for all routine loading tests. This has been recommended to avoid subjecting the D/G to the severe thermal transients which result from fast loading. D/G operation in accordance with this manufacturer recommendation will reduce unnecessary engine stress and wear, while potentially improving overall D/G reliability and availability.

, _Mr. H. R. Denten Novembar 14, 1986 Attachmsnt II to KMLNRC 86-212 Page 2

2) This change does. not create the possibility of a new or different kind of accident from any accident previously evaluated. The change 1

does not involve a change in the operational . limits or physical design of the emergency power system. This change does not affect emergency diesel generator performance. It merely revises D/G

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testing requirements to achieve an overall gain in D/G reliability and availability.

3) This change does not involve a significant reduction in a margin of safety. The change does not involve a change in the operational limits or physical design of the emergency power -system. This change does not affect emergency diesel generator performance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability. No margin of safety is reduced.

The proposed modification adding 184 day testing requirements does not 2 -

involve a significant hazards consideration.

1) This change does not involve a significant increase in the '

probability or consequences of an accident previously evaluated.

This change does not involve a change in the operational limits or physical design of the emergency power system. In accordance with the recommendations of Generic Letter 84-15, this testing

' requirement has been added to encompass the fast loading to the continuous duty rating requirement being deleted from routine testing. This reduced frequency for fast start, full load (6201 kW) ,

testing avoids subjecting the .D/G to severe thermal transients, which result from fast loading, on a routine basis. D/G operation in accordance with this manufacturer recommendation will reduce unnecessary engine stress and wear, while potentially improving overall D/G reliability and availabilty.

2) This change does not create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not involve a change in the operational limits or physical design of the emergency power system. This change does nott affect emergency diesel generator per formance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability.

3) This change does not involve a significant reduction in a margin of safety.. The change does not involve a change in the ' operational limits or physical design of the emergency power system. This change does not affect emergency diesel generator performance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability. No margin of safety is reduced.

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Mr. H. R. Danton November 14, 1986 Attichmsnt II to KMLNRC 86-212 Page 3 The proposed modification to the diesel generator testing schedule requirements does not involve a significant hazards consideration.

1) This ' change does not involve a significant increase in the i

, probability or consequences of an accident previously evaluated, The change does not involve a change in the operational limits or physical design of the emergency power system. This change will minimize unnecessary emergency diesel generator testing, while 3

maintaining the reliability levels recommends in Generic Letter 84-15. The proposed testing schedule adequately assures continued

D/G reliability without maintaining a punitive testing schedule following effective corrective action. This change will serve to reduce engine stress and wear, while potentially improving overall D/G reliability and availability.

2) This change does not create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not involve a change in the operational limits or physical 4 design of the emergency power system. This change does not affect emergency diesel generator performance. It merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability.

3) This change does not involve a significant reduction in a margin of safety. The change does not involve a change in the operational limits or physical design of the emergency power system. This change does not n fect emergency diesel generator performance. It

merely revises D/G testing requirements to achieve an overall gain in D/G reliability and availability. No margin of safety is reduced.

Based on the above discussions and those preseiited in Attachment I, it has been determined that the requested Technical Specification revisions do not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety. Therefore the requested license amendment does not involve a significant hazards consideration, i

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ATTACHMENT III Proposed Technical Specification Changes (marked up)

Mr..H. R, DInton Novembsr 14, 1986 Attrchmsnt III1to KMLNRC 86-212 Page 1 INSERT "A" "If both diesel generators of the above required A.C. electrical power sources have not been successfully 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 performing Specification 4.8.1.1.2a.4) separately for each diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

INSERT "B" "b. With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the 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 /> *; restore the inoperable diesel generator 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 />."

INSERT "C"

"...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 /> on the redundant diesel generator..."

INSERT "D"

"...the remaining a.c. electrical power source (offsite circuit or diesel generator) to OPERABLE in accordance with 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 ger.erator or a diesel generator that was restored to OPERABLE, satisfies the subsequent testing require- ment of Specification 3.8.1.1 ACTION a. or ACTION b. for an OPERABLE diesel generator."

Mr. H. R. Denton Novcmbar 14, 1986 Attechm:r.t III to KMLNRC 86-212 Paga 2 INSERT "E" "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 OPERABLE diesel generators, satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a.."

INSERT "F" "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."

INSERT "G" At least once per 184 days the diesel generators shall be started ** and accelerated to at least 514 rpm in less than or equal to 12 seconds.

The generator voltage and frequency shall be 4160 + 160-420 volts and 60 + 1.2 Hz within 12 seconds after the start signal. Subsequently verify the generator is loaded to greater than or equal to 6201 kW in less than or equal to 60 seconds and operates with a load greater than or equal to 6201 kW for at least 60 minutes."

INSERT "H" If the diesel generator became inoperable due to any cause other than preplanned preventative maintenance or testing, this test is required to be completed regardless of when the incperable diesel generator is restored to OPERABLE.

INSERT "I" Diesel generator starts from ambient conditions shall be performed only once per 184 days in these surveillance tests and all other engine starts for the purpose of this surveillance testing shall be preceeded 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.