ML20246M588
| ML20246M588 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/03/1989 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20246M585 | List: |
| References | |
| 0106T, 106T, NUDOCS 8905190194 | |
| Download: ML20246M588 (3) | |
Text
.
Comm:nwrith Edison l
72 West Adams Street Chicago !!hnois l, -
- Address RepIy 10: Fo'5IDfdB37767 Chcago, Illinois 60690 0707 May 3, 198 9 h
l %
4 Mr. A.
Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subjects LaSalle County Station Units 1 and 2 Request for Discretionary Enforcement MRC Docket Nom. 50-373 and 50-374 Reference (a): May 2, 1989, Conference Call with W.
- Forney, E. McKenna, et. al.
Dear Mr. Davls:
Per discussions in Reference (a), Commonwealth Edison requested and was granted discretionary' enforcement for the continued operation of LaSalle Units 1 and 2 for the purpose of surveillance testing of LaSalle Stations five d1esel generators, in accordance with Technical Specifications 4.8.1.1.2.a.4 and 5 and 4.8.1.1.2.d.7 and 13, to prove operability-.
Enclosed is the Commonwealth Edison Company's formal request and justification for discretionary enforcement with respect to the surveillance requirements of LaSalle County Technical Specifications 4.8.1.1.2.a.4 and 5 and 4.8.1.1.2.d.7 and 13.
Rollef was requested to avoid the shutdown of LaSalle County Station Unita 1 and 2 when all five station diesel generators were declared inoperable due to the noncompliance with the above mentioned Technical Specifications.
If you have any further questione regarding this matter, please direct them to this office.
Very truly yours, M AL.
J W. E. Morgan Nuclear Licensing Administrator Im cct NRC Resident Inspector - LSCS P.C. Shemanski - Project Manager, NRR 8905190194 890509 0106T/
PDR ADOCK 05000373 p
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a ATIACI91RCf EVEEDSE This document is being submitted to document discussions held between NRC regional personnel and Commonwealth Edison personnel regarding discretion-ary enforcement for Technical Specifications 4.8.1.1.2.a 4 and 5 and 4.6.1.1.2.d.7 and 13 with regards to the five diesel generators at LaSalle County Station. This document provides the written basis for the discretionary enforcement granted verbally to prevent the unnecessary shutdown of both LaSalle County Units while testing could be accomplished for these five diesels.
BACKGEQURD The present LaSalle County Station Technical Specifications 3/4.8.1.1 require that each diesel generator be verified to be able to start and accelerate to 900 rpm within 13 seconds and be able to be loaded to 2600 kw within 60 seconds of synchronization to the associated bus (Surveillance requirement 4. 8.1.1. 2.a 4 and 5).
This surveillance requirement is modified with a footnote (a) which requires this be performed at least once per 184 days. The footnote further states that all other engine starts for the purpose of this surveillance testing shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that mechanical stress and west on the diesel engine is minimised.
< LaSalle procedures for performance of the 184 day test which timed the die (el start and load provided for a prelube period prior to the fast start and load which was t. accomplished by starting the diesel, holding the
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diesel speed at 400 to 500 rpm for 3 minutes and then either bringing the j
diesel to full speed prior to shutdown or shutting the diesel down from the reduced speed.
After this prelube. the 184 day surveillance was performed.
During the course of discussion with NRC personnel who were on-site on May 2, 1989, CECO was informed that this practice constitutes a warmup procedure which is not consistent with the requirement that the tests be done from " ambient condition."
In addition, LaSalle procedures for verifying that the proper diesel trips are bypassed during ECCS conditions did not test the actual bypass contact but lifted a lead to simulate this function.
This testing is required by Technical Specifications 4.8.1.1.2.d.7 and 13.
tirtp rOR EMEDRcEMENT DISCRET10tl Due t.o this, the previous practice constituted not performing an 3dequate Technical Specification required surveillance test.
This affected all five diesel generators 0, 1A, 2 A, ID and 2B, if these diesel generators were declared inoperable, a shutdown of both units per specification 3.0.3 would be required.
Since the performance of the slow start prior to the 184
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. ' ',. day surveillance test was not expected to" impact on the ability of any diesel to satisf actorily meet the Technical Specification requirements without this slow start, and the relay contacts were not expected to fall because the relay coll and other contacts were veriflod to operato properly.
Discretionary enforcement was requested such that both units would not be placed in n chutdown transient during the period when the diesel surveillance could be performed to verity continued operability.
JUSTIflCA710N The ability of all the diesels to start and load within the required time f rames has been verified every 184 days as specified in the Technical Specification with the exception that a slow start of the diesel for prelubrication purposes was done prior to the timing verification.
The prestart of the diesels would not affect the ability of the diesel to load (ie, it should not improve the loading ability by any pre-warming).
Any effect would be expected to be seen in the starting time.
LaSa11e's diesels do not have any history of not meeting the 13 second responce time to start and come up to running speed.
During the 18 month diesel surveillance this time la measured without any prestarts.
A review of diesel failures since January 1, 1986 showed that no s'
tallure.d occurred which were in any way related to the ambient start conditions, or that would have been detectable only during an ambient start.
Failures were related to not starting at all or failure to properly load.
During diesel testing performed on May 2 and May 3, 1989, all diesels met the response times required of the Technical Specifications.
The relays in question were verified to energize and de-energize when required during the surveillance testing.
At least one contact on each relay was also verified to operate properly. The failure of a contact on these relays is considered unlikely in this case.
These relays were all verified to operate correctly during testing performed on May 3, 1989.
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