ML20216D027

Update to 860321 Application for Amend to License DPR-40, Incorporating Discussion,Justification & Significant Hazards Considerations Re Deletion of Requirement to Start Diesel Engine

ML20216D027
Person / Time
Site:	Fort Calhoun
Issue date:	06/22/1987
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20216D032	List: ML20216D027 ML20216D057
References
GL-84-15, TAC-55860, NUDOCS 8706300430
Download: ML20216D027 (7)

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I Omaha Public Power District 1623 Hamey Omaha, Nebraska 68102 2247 1 402/536 4000 June 22, 1987 -

LIC-87-426 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

References:

1. Docket No. 50-285 l

2. Application dated March 21, 1986

3. Letter from 0 PPD (R. L. Andrews) to NRC (W. A. Paulson) dated March 31, 1987 (LIC-87-126)

Gentlemen:

SUBJECT:

Diesel Generator Technical Specifications On June 9, 1987, members of my staff and the NRC's staff conducted a telephone conversation regarding the subject Technical Specifications. Per an agreement made in that call, OPPD has consolidated information pertaining to this Application for Amendment, submitted by References 2 and 3, into Attachments A, B, and C to this letter. Attachment A summarizes where the changes were docketed. Attachment B provides discussion and justification on "Significant Hazards Considerations Analyses" which includes and consolidates information provided in earlier submittals. Attachment B has been revised to include additional discussion of an item of concern to the NRC reviewer. Attachment C includes all pages of the Technical Specifications relative to the diesel generator application for amendment. We believe this will serve to resolve this issue.

OPPD respectfully requests 30 days from date of issuance in order to implement the revised specifications.

Sincerely, R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1 R. D. Martin, NRC Regional Administrator Anthony Bournia, NRC Project Manager 0 8[(

P. H. Harrell, NRC Senior Resident Inspector

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. ATTACHMENT A.'

tu Summary of Changes 6- P_itga Docketed-25- - Application of March 21,-1986

~2 From.LIC-87.-126 dated March 31, 1987 1

3-9 From LIC-87-126 dated March 31,'1987 3110 From LIC-87-126. dated March' 31, 1987

, 3-58 - From LIC-87-126 dated March 31,.'1987-t .'.

3 Fr om LIC-87-126. dated March 31,>1987 60J From LIC-87-126 dated March 31, 1987

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r-p DISCUSSION, JUSTIFICATION. AND I

.SIGNIFICANT HAZARDS CONSIDERATIONS

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The NRC's Generic \ Letter 84-15,' dated July 2,1984, provided staff objectives )

, with respect to the, emergency' diesel generators at nuclear power facilities. i The first attachment"'to_thi's letter addressed a staff objective of reducing I the number of cold fast start surveillance tests for diesel generators which  !

were deemed as resulting in premature diesel engine degradation. The Generic 1 Letter requested a description of the current surveillance testing program, i and a description of intended actions to reduce cold fast starts. '

OPPD's response directly applicable to this item of the Generic Letter was provided in our letter LIC-84-413, dated December 28, 1984. In this letter, '

we described our cold fast start surveillance testing program, and stated that we would conduct a review of the Technical Specifications and surveil-lance testing in order to determine if any unnecessary testing could be eliminated. In a letter to the NRC (LIC-85-362) dated October 25, 1985, OPPD stated that our review indicated that certain changes to the Technical Speci-fications would be in order. We further noted that we expected to submit those changes in the form of an Application for Amendment approximately 30 days after full power operation following the 1985 refueling and maintenance outage. Accordingly, OPPD submitted an Application for Amendment in March, 1986, which proposed changes to the Technical Specifications to meet that objective.

Subsequent to our initial Application for Amendment of Operating License, several discussions concerning that Application have been held with the NRC reviewer.

Several comments were raised which have been discussed with the plant staff and the reviewer. As was noted to the reviewer, the changes requested must be concurred with by both the Fort Calhoun Station Plant Review Committee, and the Omaha Public Power District offsite Safety Audit and Review Commit-tee. The following discussion presents our revised changes to the Technical Specifications and amplified discussion of the justification for those changes.

Technical Soecification 2.4. Limitino Condition for Operation of the Containment Coolina System. (2). Modification of Minimum Reauirements.

Technical Specification 2.4 currently allows modification of the minimum requirements of the specification for the Containment Cooling System during power operation to allow a total of two of the components listed in Technical Specification 2.4 a. and b. to be inoperable at any one time (in addition to one raw water pump) provided that the emergency diesel generator connected to the other engineered safeguards 4.16 KV bus (1A4 or 1A3) is started to demonstrate operability.

The proposed Technical Specification removes the requirement for the emergency diesel to be started in order to modify the minimum requirements.

This partic"'ar requirement imposes the stresses associated with cold fast starts on the diesel engines. Additionally, the requirement in the existing Technical Specification: is inconsistent with the Standard Technical Specifi-cations, in that no such diesel start is imposed by the Standard Technical ATTACHMENT B

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Attachment B (continued)

Specifications in order to comply with the provisions of the Liiriting Conditions for Operation for the Containment Cooling System. Therefore, OPPD believes that there exists adequate justification for deletion of the requirement to start the diesel engine, and has therefore proposed that the ,

Limiting Condition for Operation be revised to remove that requirement.

(This item remains as it was initially submitted-in our March 21, 1986, submittal.) Additionally, the BASIS to Technical Specification 2.4 has been '

revised in order.to provide consistency between specification and basis.

(This item was overlooked in our initial application.) {

l Technical Specification 3.1, Instrumentation and Control.

This Technical Specification refers to the requirements for the surveillance testing in terms of checks, calibration, and testing of the Reactor Protective System (RPS) found in Table 3-1, Engineered Safety Features (ESF) found i in Table 3-2, and other miscellaneous plant instrumentation and controls  !

found in Table.3-3. .l Table 3-2, Item 11 currently addresses several surveillance requirements associated with the diesel generators. Additionally, other testing require- j ments are specified in Technical Specification 3.7. The reasons for removing. j Item 11 from the Table wem discussed with the reviewer. He believed it was  ;

appropriate to only maintain items in Table 3-2 which directly relate to diesel circuitry, but not the engine. The reviewer requested that the check of.the diesel start circuit be retained in Table, while diesel starts be moved to Technical Specification 3.7. However, all tests presented in Table 3-2 Item 11, result in a diesel start, and, as such will be placed in i Technical Specification 3.7. This information was verbally agreed to by the l reviewer. This is consistent with Standard Technical Specifications. The following explains the rationale for each of the changes made to Table 3-2. l Item lla of the existing Specifications contains requirements to perform monthly testing of the diesel by manual initiation of a starting signal.

This requirement relates to more than the diesel circuitry, and has been 1 moved to Specification 3.7. Additionally, the monthly testing of the diesel l is specified in greater detail, including the necessary starting signals, j and acceptance criteria, in Specification 3.7. Therefore, Item lla has been j moved to Specification 3.7 to avoid duplication.

Item 11b as it exists in Table 3-2 has been factored into Technical Specifi-cation-3.7(1)c, as was discussed with the reviewer. The start of the diesel engine upon a Safety Injection Signal will be reserved for the refueling i test specified in Technical Specification 3.7(1)c and discussed below. This >

proposed change will reduce the potential for error auring the conduct of surveillance by keeping the amount of activity associated with the Safety Injection Actuation Signal test to a minimum. Therefore, the requirements of ,

item lib have been revised and moved to 3.7(1)c. i

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.. l Attachment B (continued) l I

The requirement of Table 3-2, Item 11c (to perform a test of the diesel during refueling shutdowns) is redundant to the tests which are specified in the '

proposed revision to 3.7(1)c. Therefore, the requirement of 11c has been ,

removed from the table. The test is specified in greater detail, including '

initiating parameters and acceptance criteria, in Specification 3.7, and is better placed there. The requirement remains the same as is detailed below.

The requirements of Table 3-2, Item 11d (to test the diesel auto start initiating circuits prior to startup if not done during the previous week) have ,

been moved to Specification 3.7(1)b. The test;results in a diesel engine start '

and should be located with the other diesel tests in Specification 3.7.

Technical Soecification 3.1. Emeraency Power System Periodic Tests. 1 Technical Specification 3.7(1)a has been modified to allow for the diesel start 1 (10 teconds) from ambient conditions to be performed at least once per 184 days. The other engine starts, conducted at least once per 31 days, in this Specification will be allowed to be preceded by an engine pre-lube period $

and/or other warmup procedures recommended by the manufacturer so that i mechanical stress and wear.on the engine is minimized.- This is consistent with the changes recommended in Generic Letter 84-15. The format 'is slightly different. (That is, the 184 day Specification is not contained in a footnote; j it has been included in the text of the Specification.)

As noted above' Table 3-2, Item Ild, has been moved to Item 3.7(1)b.

I Specification 3.7(1)c has been reworded in order to increase its clarity. No I major functional changes between testing currently conducted will result from  !

this change. Technical Specification 3.7(1)e has been altered in wording  !

somewhat and incorporated into Specification 3.7(1)c as a criteria of acceptance of the refueling frequency testing. The initial 0 PPD Application for Amendment of Operating License had proposed removing this particular Specification from the Technical Specifications. OPPD has modified 3.7(1)c to include a verification-that the auto-connected loads do not exceel 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the engine, consistent with Standard Technical Specifications. The loads which'are auto-connected are currently monitored as a part of.the refueling test, so it will not result in any additional requirements. The statement has been reworded to denote an action associated with surveillance rather than the current wording which connotates a design requirement. The design-basis considerations of this requirement are found in USAR Section 8.4.1.2 and are footnoted as such.

The portion of current Technical Specification 3.7(1)c dealing with manual control of the diesel generators and breakers has been separated from the automatic operation portion. It has been designated as 3.7(1)d. Current Specification 3.7(1)d has been redesignated as 3.7(1)e. The frequency was

' changed from annual to Refueling. It is the intention of this change to no  !

longer conduct the manufacturer's recommended overahaul (which requires re- f moving the diesel from service) during power operation. This arrangement was i recommended by the Region IV office.

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I Attachment B (continued)

Additional discussion of a deletion from the current Specification 3.7(d) was requested in a telephone conversation on June 9, 1987. The phrase deleted was:

"The above tests will be considered satisfactory if all applicable equipment operates as designed. This will include calibration of monitoring instrumen-tation." Essentially, the phrase was deleted as it is superfluous to the specification, and could be replaced with "The equipment must be operable".

Additionally, the definition of Operability in the Fort Calhoun Technical Specifications includes the associated instrumentation for a piece of equip-ment. Thus, operability of the equipment includes operability of the associated monitoring instrumentation.

If as an alternative, the NRC wishes to not exclude the calibration statement, leaving it intact is also acceptable. We do prefer to delete the "satisfac-tory" statement as it is redundant to the definition of operability and its inclusion is unnecessary.

A note has been added to the Basis section 3.7 to specify that Generic Letter 84-15 recommendations to reduce cold fast starts have been incorporated into these Technical Specifications.

Justifications This change to the Technical Specifications is proposed in response to the NRC recommendations of Generic Letter 84-15 and has been modified per conversations with the NRC technical reviewer. This change will reduce the number of unneces-sary cold fast starts of the emergency diesel generators. These changes will bring applicable portions of the Fort Calhoun Station Technical Specifications into conformance with the recommended changes noted in the Attachment to Enclosure 1 of Generic Letter 84-15.

Sionificant Hazards Considerations The proposed changes to the Technical Specifications have been assessed against the provisions of 10 CFR 50.92. This review resulted in the following conclusions:

The proposed changes will not involve a significant increase in the probability or consequences of an accident or malfunction of equipment previously evaluated in the Safety Analysis Report. These changes are intended to reduce degrad-ation of the emergency diesel generators caused by cold fast starts. Thus, the probability of malfunction of equipment can be considered to have been lessened. Additionally, by not conducting the annual overhaul during power operation, the possibility of an occurrence at power with one engine tagged out for maintenance is virtually eliminated.

The changes will not involve a significant reduction in a margin of safety.

The changes are intended to provide a less severe method of testing of the diesel generators, thus decreasing the likelihood of degradation and wear. By restricting the overhaul to refueling outages, the periods of time with one diesel tagged out for maintenance during normal operation will be limited to necessary maintenance concerns, instead of preventive maintenance which can be accomplished during refueling shutdowns.

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Attachment 8 (continued)-

1 The NRC has.provided guidance concerning the' application of standards for y determining whether a significant hazards consideration exists by providing l certain: examples.of amendments that are not likely to involve significant- i hazards considerations (51 FR 7751). This application is deemed,to be similar I to example (i) in.that it wi11' achieve consistency throughout the Technical '

Specifications by placing all diesel generator surveillance requirements in one location. This an.endment is'also somewhat sii'nilar to example-(iv) whore the I relief based upon. " acceptable operation" is in part based on NRC reassessment- l of the testing requirements imposed upon diesel-generators. Based upon conclu- 1 sions drawn from Generic Letter 84-15, the proposed changes are in keeping with j the concept of increasing safety by precluding unnecessary wear on the emer- 1 gency diesel engines. For these reasons, OPPD believes that these changes _do not constitute 'a significant hazards consideration.  ;

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