Text

Application for Amend to License NPF-30,revising TS 3/4.8.1 & Associated Bases to Achieve Overall Improvement in EDG Reliability & Availability Based Upon,In Part,Guidance of GLs 94-01,93-05 & Reg Guide 1.9,Rev 3
	ML20086R963
Person / Time
Site:	Callaway
Issue date:	07/25/1995
From:	Schnell D; UNION ELECTRIC CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086R967	List: ML20086R975; ULNRC-03244, Application for Amend to License NPF-30,revising TS 3/4.8.1 & Associated Bases to Achieve Overall Improvement in EDG Reliability & Availability Based Upon,In Part,Guidance of GLs 94-01,93-05 & Reg Guide 1.9,Rev 3;
References
	RTR-REGGD-01.009, RTR-REGGD-1.009 GL-93-05, GL-93-5, GL-94-01, GL-94-1, ULNRC-03244, ULNRC-3244, NUDOCS 9508010050
	Download: ML20086R963 (47)
	v • d • e

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.. 1901 Chouteau Avenue

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Po:t O!!ce Bu 149 St tours.IAssouri63166 314-554-2650 DonaldF. Schnen UNION su1y 2s, 1995 senio, vice e,es,sent Etecruic rw .,

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'3 U.S. Nuclear Regulatory Commission Attn: Document Control Desk a

M'il Station F1-137 Washington, D.C. 20555 ULNRC-03244 Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.8.1 A.C. SOURCES

Reference:

ULNRC-3072, dated September 9, 1994 Union Electric Company herewith transmits an application for amendment to Facility Operating License i No. NPF-30 for Callaway Plant.

This amendment application supersedes the referenced letter and proposes revising Technical Specification 3/4.8.1 and its associated Bases to achieve an overall improvement in emergency diesel i generator reliability and availability. Specifically, )

it is being proposed that the guidance of Regulatory ;

Guide 1.9, Revision 3, Generic Letter 93-05, and Generic. Letter 94-01 be adopted. Also, several surveillance requirements would be revised or eliminated and the emergency diesel generator fuel oil l surveillance requirements would be addressed as an administrative program. Descriptions of the Diesel Puel Oil Testing Program and the Emergency Diesel Generator Reliability Program would be added to Section ,

6 of the technical specifications to ensure that )

administrative controls are in place to maintain emergency diesel generator reliability and availability. These proposed changes are consistent, in part, with recent NRC guidance concerning emergency diesel generator surveillance requirements.

Attachments 1, 2, 3, and 4 contain the Safety Evaluation, the Significant Hazards Evaluation, the Environmental Consideration, and the Proposed Technical Specification Changes in cupport of this amendment request. This change request has been approved by the Callaway Onsite Review Committee and the Nuclear Safety Review Board.

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h If you have any questions'concerning this; !

matter, please contact me. ;

t Very truly yours, Donald F. Schnell r

i JMC/sid j Attachments: 1) Safety Evaluation f

2) Significant Hazards Evaluation l

3) Environmental Considerations l

4) Proposed Technical Specification I Changes l t

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STATE OF MISSOURI ) !

) SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn I upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content _thereof; that he has ;

executed the same for and on' behalf of said company with full f power and authority to do so; and that the facts therein !

stated are true and correct to the best of his knowledge, information and belief. f By ~

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Donald F. Schnell l Senior Vice President +

Nuclear SUBSCRIBED and sworn to before me this NI day of Mf - , 1995.

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BARBARk J. PfkE l f NOTARY PUBUC-STATE OF MISSOUM MY COMMISSION EXPIRES APRIL 22,199Z SI. LOUIS COUNTX 1

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cc: T. A. Baxter,.Esq..

. Shaw, Pittman, Potts & Trowbridge

.2300 N. Street, N.W.

Washington,-D.C. 20037 M. H. Fletcher R Professional Nuclear Consulting, Inc. '

19041 Raines Dr E2rwood, MD 20855-2432 j M. J. Farber Chief, Reactor ProjectsSection III A !

U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road i Lisle, IL 60532-4351 Bruce Bartlett ,

Callaway Resident Office U.S. Regulatory Commission RR#1 i Steedman, MO 65077 L. R. Wharton (2) ;

office of Nuclear Reactor Regulation ,

U.S. Nuclear Regulatory Commission 1 White-Flint, North, Mail Stop 13E21 11555 Rockville Pike i Rockville, MD' 20852-2738 [

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Manager, Electric Department -

Missouri Public Service Commission P.O.-Box 360 :

Jefferson City, MO .65102 -

. Ron Kucera f Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 :

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bcc: D. Shafer/A160.761

/QA Record (CA-758)

E210.01-DFS/ Chrono D. F. Schnell J. E. Birk J. V. Laux R. D. Affolter G. L. Randolph R. J. Irwin P. M. Barrett C. D. Naslund J. D. Blosser A. C. Passwater D. E. Shafer W. E. Kahl S. Wideman (WCNOC)

F. C. Wilks, PE (Bechtel)

H. D. Bono NSRB (P. L. Reynolds)

J. M. Chapman R. L. Hux A140.0001.002(1170) i i

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s7 ,v Att: chm:nt i Page 1 of 30 ULNRC-3244 SAFETY EVALUATION packaround The proposed changes to Technical Specification 3/4.8.1 described in this license amendment request are based upon, in part, the guidance of Generic Letter 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators From Plant Technical Specifications," Generic Letter 93-05, "Line-Item Technical Specifications improvements to Reduce Surveillance Requirements for Testing During Power Operation," Regulatory Gui de 1.9, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electrical Power Systems at Nuclear Power Plants," Revision 3, and NUREG-1431, " Standard Technical Specifications - Westinghouse Plants." Also, the guidance of NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors," Revision 1, and Regulatory Guide 1.160 has been adopted to formulate a comprehensive Emergency Diesel Generator Reliability Program. The proposed technical specification changes are an integral part of this reliability program.

A short description for each of the aforementioned guidance documents is provided below.

Generic Letter 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators From Plant Technical Specifications," was issued on May 31, 1994, to advise licensees that they may request a license amendment to remove accelerated testing and special reporting requirements for emergency diesel generators from plant technical specifications. This generic letter stated that in order to implement the )

recommendations of the generic letter licensees must commit to implement within 90 days a l maintenance program for monitoring and maintaining diesel generator performance consistent l with the provisions of 10 CFR 50.65, " Requirements for Monitc, ring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance of Regulatory Guide 1.160,

" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

Generic Letter 93-05, "Line-Item Technical Specifications improvements to Reduce Surveillance Requirements for Testing During Power Operation," was issued on September 27, 1993, to provide guidance to licensees in preparing a license amendment request to implement line-item technical specifications improvements concerning the reduction in the amount of testing that the technical specifications require during power operation. These line-item technical specifications are based upon the recommendations of a study that included a comprehensive examination of surveillance requirements and is reported in NUREG-1366,

" Improvements to Technical Specifications Surveillance Requirements."

Regulatory Guide 1.9, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants,"

Revision 3, was issued as part of the resolution of Generic Safety issue B-56, "EDG Reliability." This regulatory guide integrates the guidance previously contained in Regulatory Guide 1.9, Revision 2, Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," and Generic Letter 84-15,

" Proposed Staff Actions to improve and Maintain Diesel Generator Reliability."

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,r Att@chment i Page 2 of 30 ULNRC-3244 NUREG-1431, " Standard Technical Specifications - Westinghouse Plants," contains improved Standard Technical Specifications for Westinghouse plants and documents the positions of the Nuclear Regulatory Commission based on the Westinghouse Owners Group's proposed Standard Technical Specifications. The improved Standard Technical Specifications were developed based on the criteria in the interim Commission Policy Statement on Technical Specification improvements for Nuclear Power Reactors, dated February 6,1987.

NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors," Revision 1, presents all generic guidance developed for rneeting the requirements of the station blackout rule,10 CFR 50.63, it includes appendices that provide guidance relative to emergency diesel generator reliability programs and equipment operability, in particular, Appendix D provides a methodology for effective monitoring and maintaining emergency diesel generator reliability.

Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," was developed to provide guidance for complying with the provisions of 10 CFR 50.65.

1 Evaluation 1

This section of the license amendment request describes each of the proposed changes to the j technical specifications and the justification for each proposed change. Revised technical I specification numbers are provided in parentheses next to the current technical specification I numbers, where applicable. Also, a table has been included that provides a cross reference of the current technical specification numbers to the revised technical specification numbers with a brief description of the proposed change.

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Attachm:nt i '

Page 3 cf 30 .M ULNRC-3244 Current - Revised

' Technical Technical Specification Proposed Technical Specification Changes Specification Number Number Index Page XI Deletes reference to Table 4.8-1 3.8.1.1, Action Implements the guidance of Generic Letter 93-05 and NUREG-1366 a

3.8.1.1, Action implements the guidance of Generic Letter 93-05 and NUREG-1366 b

3.8.1.1, Action implements the guidance of Generic Letter 93-05 and NUREG-1366 c

3.8.1.1, Action Implements the guidance of Generic Letter 93-05 and NUREG-1366 e

implements the guidance of NUREG-1431 3.8.1.1, Action g

implements the guidance of NUREG-1431 3.8.1.1, Action h

4.8.1.1.2a implements the guidance of Generic Letter 94 01 -

4.8.1.1.2a.4 Implements the guidance of Regulatory Guide 1.9, Revision 3 and NUREG-1431 A.8.1.1.2a.5 Implements the guidance of Regulatory Guide 1.9, Revision 3 and NUREG-1431 4.8.1.1.2b implements the guidance of NUREG-1431 ,

4.8.1.1.2c No Change 4.8.1.1.2d implements the guidance of NUREG-1431 4.8.1.1.2e implements the guidance of NUREG-1431 4.8.1.1.2i implements the guidance of Regulatory Guide 1.9, Revision 3 and NUREG-1431 4.8.1.1.2f~

4.8.1.1.2f No Change 4.8.1.1.2g -

4.8.1.1.2f.1 Deleted per Regulatory Guide 1.9, Revision 3 4.8.1.1.2f.2 Deleted 4.8.1.1.2f.3 Combines Full-Load and Single-Load Rejection Test Acceptance Criteria 4.8.1.1.2g.1 4.8.1.1.2f.4 Reformatted to be consistent with NUREG-1431 4.8.1.1.2g.2 4.8.1.1.2f.5 Reformatted to be consistent with NUREG-1431 4.8.1.1.2g.3 4.8.1.1.2f.6 Reformatted to be consistent with NUREG-1431/ Portions relocated to 4.8.1.1.2g.5 ' 4.8.1.1.2g.4 Contains portions relocated from 4.8.1.1.2f.6 4.8.1.1.2g.5 4.8.1.1.2f.7 Implements guidance of Regulatory Guide 1.9, Revision 3/ Deletes Overload Test 4.8.1.1.2g.6 4.8.1.1.2f.8 Deleted per Regulatory Guide 1.9, Revision 3 and NUREG-1431 4.8.1.1.2f.9 Reformatted to be consistent with NUREG-1431 4.8.1.1.2g.7

- 4.8.1.1.2f.10 No Change 4.8.1.1.2g.8

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Attachment I c Page 4 Cf 30 -

ULNRC-3244 -

Current Revised Technical Technical Specification Proposed Technical Specification Changes (Continued) Specification Number Number 4.8.1.1.2f.1 1 No Change 4.8.1.1.2g.9 4.8.1.1.2f.12 No Change 4.8.1.1.2g.10 4.8.1.1.2f.13 No Change 4.8.1.1.2g.11 4.8.1.1.2g Reformatted to be consistent with NUREG-1431 4.8.1.1. 2h 4.8.1.1.2h Reformatted to be consistent with NUREG-1431 4.8.1.1.2i 4.8.1.1.3 Deleted per guidance of Generic Letter 94-01 Table 4.8-1 Deleted per guidance of Generic Letter 94-01 4.8.1.2 Deletes reference to Technical Specification 4.8.1.1.3 Bases 3/4.8 Expands descriptions of Surveillance Requirements and Action Statements Adds requirement for ORC review of Diesel Fuel Oil Testing Program 6.5.1.6, item q Adds requirement for audits of the Diesel Fuel Oil Testing Program 6.5.2.8, item I Adds requirements for the establishment of procedures for the Diesel Fuel Oil Testing 6.8.1, item j Program Adds description of Diesel Fuel Oil Testing Program 6.8.4, item h Adds description of Emergency Diesel Generator Reliability Program 6.8.4, item i

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Att: chm:nt i Page 5 of 30 UL.NRC-3244 I. Index Page XI A. Descriotion of Prooosed Chanae This proposed change would delete the reference to Table 4.8-1. Table 4.8-1 specifies the frequency of testing based on the number of failures during the last 20 or 100 valid tests of each emergency diesel generator.

B. Justification Reference Technical Specification 4.8.1.1.2a.

II. Technical Specification 3.8.1.1, Action a A. Descriotion of Prqp_gsed Chance This action statement currently provides the actions to be taken with one offsite circuit of the required A.C. electrical power sources inoperable. Specifically, this action statement requires, in part, that if either emergency diesel generator of the required A.C. electrical power sources has not been successfully tested within the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , Technical Specification 4.8.1.1.2a.4 must be performed separately for that emergency diesel generator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to demonstrate its operability.

Note "##" for this action statement states that the automatic start and sequence loading of an emergency diesel generator satisfies the testing requirements of Technical Specification 4.8.1.1.2a.4 for this action statement. It is proposed that this portion of Action a and its associated note be deleted.

B. Justification This proposed change is consistent with the guidance of Generic Letter 93-05 and NUREG-1366 which allow the deletion of requirements for alternate testing that requires testing of emergency diesel generators and other unrelated systems not associated with an inoperable train or subsystem (other than an inoperable emergency diesel generator). Note "##" can be deleted since an emergency diesel generator is no longer required to be tested as part of this action statement. These {

proposed changes are also consistent with Technical Specification 3.8.1, Action A, j from NUREG-1431 and are compatible with plant operating experience. j lil. Technical Specification 3.8.1.1, Action b A. Descriotion of Prooosed Chance This action statement currently provides the actions to be taken with one emerger:cy diesel generator of the required A.C. electrical power sources inoperable. Specifically, this action statement requires, in part, the demonstration l of the operability of the rernaining operable emergency diesel generator by performing Technical Specification 4.8.1.1.2a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Note "*" for this action statement states that this test is required to be completed regardless of when the inoperable emergency diesel generator is restored to operable status

1 y f- Q,r' Attachm:nt i Page 6 of 30 ULNRC-3244 unless the emergency diesel generator was declared inoperable for preplanned ;

preventative maintenance, testing, or maintenance to correct a condition which, if I left uncorrected, would not affect the operability of the emergency diesel generator.

It is being proposed that the requirement to test the remaining operable emergency diesel generator.when one emergency diesel generator is inoperable be limited to those situations where the cause for inoperability could not be conclusively demonstrated. This will preclude the potential for common mode failures. Also, in '

addition to the current exceptions stated in Note "*", the test would not be required to be accomplished if the emergency diesel generator was declared inoperable due to an inoperable support system or an independently testable component. When a test is required, it would be required to be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of having i determined that the emergency diesel generator is inoperable.

B. Justification This proposed change is consistent, in part, with the guidance of Generic Letter 93-05 and NUREG-1366 which recommend that when an emergency diesel generator is inoperable (not including a support system or independently testable component), .

the other emergency diesel generator should be tested only once, unless it can be demonstrated that there is no potential common mode failure for the remaining-diesel generator. This proposed change is also consistent with Technical l Specification 3.8.1, Action B, from NUREG-1431 which states that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time frame to confirm that the operable emergency diesel generator is not affected by the same problem as the inoperable emergency diesel generator.

Also, this change is compatible with plant operating experience.

IV. Technical Specification 3.8.1.1, Action c

A. Descriotion of Pronosed Chanae This action statement currently provides the actions to be taken with one offsite circuit and one emergency diesel generator of the required A.C. electrical power sources inoporable. Specifically, this action statement requires, in part, the demonstration of the operability of the remaining operable emergency diesel generator by performing Technical Specification 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Note

"*" for this action statement states that this test is required to be completed <

regardless of when the inoperable emergency diesel generator is restored to 4 operable status unless the emergency diesel generator was declared inoperable for preplanned preventative maintenance, testing, or maintenance to correct a condition which, if left uncorrected, would not affect the operability of the emergency diesel generator, it is proposed. that the requirement to test the remaining operable emergency diesel generator when one offsite circuit and one emergency diesel generator is inoperable be limited to those situations where the cause for inoperability could not be conclusively demonstrated. This will preclude the potential for common mode failures. Also, in addition to the current exceptions stated in Note "*", the test would not be required to be accomplished if the emergency diesel generator was declared inoperable due to an inoperable support system or an independently testable component.

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Page 7 of 30 ULNRC-3244 This action statement also states that a successful test of emergency diesel generator operability performed in accordance with Technical Specification , 4.8.1.1.2a.4 under this action for an operable emergency diesel generator or an l emergency diesel generator that was restored to operable status, satisfies the l subsequent testing requirements of Technical Specification 3.8.1.1, Action a or Action b for an operable emergency diesel generator. It is proposed that the i reference to Technical Specification 3.8.1.1, Action a be deleted since Action a no longer requires the testing of an emergency diesel generator.

I B. Justification This proposed change is consistent with the guidance of Generic Letter 93-05 and NUREG-1366 which recommend that when an emergency diesel generator is inoperable (not including a support system or independently testable component),

the other emergency diesel generator should be tested only once and within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless the absence of any potential common mode failure can be demonstrated.

These proposed changes are also compatible with plant operating experience.

V. Technical Specification 3.8.1.1, Action e A. Descriotion of Prooosed Chanae This action statement currently provides the actions to be taken with two offsite circuits of the required A.C. electrical power sources inoperable. Specifically, this i action statement requires, in part, the demonstration of the operability of two >

emergency diesel generators by performing Technical Specification 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless the emergency diesel generators are already operating. Also, this action statement states that a successful test of emergency diesel generator operability performed in accordance with Technical Specification 4.8.1.1.2a.4 under this action for the operable emergency diesel generators, satisfies the subsequent testing requirement of Technical Specification 3.8.1.1, Action a. Note

"##" for this action statement states the automatic start and sequence loading of an emergency diesel generator satisfies the testing requirements of Technical Specification 4.8.1.1.2a.4 for this action statement. It is proposed that Gm ,

portions of Action e and its associated note be eliminated. l B. Justification These proposed changes are consistent with the guidance of Generic Letter 93-05 and NUREG-1366 which allow the deletion of requirements for alternate testing that requires testing of emergency diesel generators and other unrelated systems not associated with an inoperable train or subsystem (other than an inoperable emergency diesel generator). Note "##" can be deleted since an emergency diesel generator is no longer required to be tested as part of this action statement. Also, the reference to Technical Specification 3.8.1.1, Action a can be deleted since !

Action a no longer requires the testing of an emergency diesel generator. These proposed changes are consistent with Technical Specification 3.8.1, Action C, from i NUREG-1431 and are compatible with plant operating experience. l l

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Att: chm:nt i Page 8 of 30 ULNRC-3244 -

VI. : New Technical Specification 3.8.1.1, Action g A. Descriotion of Prooosed Chanoe it is proposed that Action g be added to Technical Specification 3.8.1.1' to require i that with one or more diesel generators with new fuel oil properties outside the. l required Diesel Fuel Oil Testing Program limits, following addition of new fuel' oil to j

. the Diesel Fuel Oil Storage Tanks, the stored fuel oil properties must be restored to j within the required limits within 30 days. Also, a note would be added to require. .l that the properties of API Gravity, specific gravity or'an absolute specific gravity; -l kinematic viscosity; water and sediment content; and flash point be confinned to be . ;

within the limits of the Diesel Fuel Oil Testing Program, prior to the addition of the .

new fuel oil to the Diesel Fuel Oil Storage Tanks. !

l A. Justification i Action g, and its associated note, would address the required action to be taken in i the event the new fuel oil properties do not meet the Diesel Fuel Oil . Testing i Program limits. A failure to meet the American Petroleum Institute (API) gravity,- i kinematic viscosity, flash point or water and sediment limits is cause for rejecting j the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not represent a failure to meet the Limiting Condition for Operation.of Technical- ,

Specification 3.8.1.1, since the new fuel oil will not have been added to the storage '

tanks. Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage tanks, 30 days is provided in the Diesel Fuel Oil +

Testing Program to complete the analyses of the other new fuel oil properties. In :

the event the other new fuel oil properties are not met, this action statement provides an additional 30 days to meet the Diesel Fuel Oil Testing Program' limits.

This period provides sufficient time to test the stored fuel oil to determine that- the new fuel oil, when mixed with the previously store fuel oil, remains acceptable, or .

to restore the stored fuel oil properties. This additional 30 day period is acceptable i because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on emergency diesel generator operation. The diesel i fuel oil surveillance conducted in accordance with the Diesel Fuel Oil Testing' +

Program will ensure the availability of high quality fuel oil for the emergency diesel generators. The proposed addition of this action statement is consistent with the intent of Technical Specification 3.8.3 of NUREG-1431. l i

it itproposed that a description of the Diesel Fuel Oil Testing Program be added to Section 6 ~of the technical specifications. It is also proposed that Section 6 be

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revised to require that the. Diesel Fuel Oil Testing Program be reviewed by the !

Onsite Review Committee, audited by the Nuclear Safety Review Board, and ,

written - procedures . established, implemented

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, and maintained ' for the '

implementation' of the program. These proposed revisions are discussed in more detail later in this evaluation under items XXIX thru XXXill. :

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Page 9 of 30 ULNRC-3244 Vll. New Technical Specification 3.8.1.1, Action h A. Descriotion of Proposed Chance it is proposed that Action h be added to Technical Specification 3.8.1.1 to require that with one or more diesel generators with stored fuel oil total particulates outside the required Diesel Fuel Oil Testing Program limits, the stored fuel oil properties must be restored to within the required limits within 7 days.

B. Justification Action h would address the required action in the event the stored fuel oil total particulates do not meet the Diesel Fuel Oil Testing Program limits. At least once every 31 days, a sample of fuel oil is obtained from the storage tanks and the particulate contamination is verified to be less than 10 mg/ liter. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. Fuel oil degradation during long term storage is identified by an increase in total particulates, due mostly to oxidation. An increase in particulates does not mean the fuel oil will not burn properly in a diesel engine. The increase in particulates can cause fouling of filters and fuel oil injection equipment which can cause engine failure. The frequency for performing surveillances on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances. The proposed addition of this action statement is consistent with the intent of Technical Specification 3.8.3 of NUREG-1431. As discussed previously, it is proposed that a description of the Diesel Fuel Oil Testing Program be added to Section 6 of the technical specifications, it is also proposed that Section 6 be revised to require that the Diesel Fuel Oil Testing Program be reviewed by the Onsite Review Committee, audited by the Nuclear Safety Review Board, and written procedures established, implemented, and maintained for implementation of the program. These proposed revisions are discussed in more detail later in this evaluation under items XXIX thru XXXill.

Vill. Technical Specification 4.8.1.1.2a A. Descriotion of Prooosed Chanae This surveillance requirement currently requires that each emergency diesel generator be demonstrated operable in accordance with the frequency specified in Table 4.8-1 on a staggered test basis. Table 4.8-1 specifies the frequency of testing based on the number of failures during the last 20 or 100 valid tests of each emergency diesel generator. It is proposed that Table 4.8-1 be deleted. The frequency of testing for the emergency diesel generators would be changed to at

. least once per 31 days on a staggered test basis.

., e s,a Attichm:nt i Page 10'of 30 ULNRC-3244 ,

B. Justification This proposed change is consistent with the guidance presented in Generic Letter 94-01. This generic letter was developed based upon Option 4 in SECY-93-044, i

" Resolution of Generic Safety issue B-56, ' Diesel Generator Reliability'." Option 4 recommends that licensees adopt the accelerated testing provisions of the improved ,

Standard Technical Specifications with an option to relocate accelerated testing and special reporting requirements for the ernergency diesel generators from the -

technical specifications to the maintenance program when the maintenance rule goes into effect in 1996. However, after further consideration by the NRC it was concluded that it was not necessary to await the effective date of the maintenance L rule. The generic letter states that licensees may request the removal of the technical specification provisions for accelerated testing and special reporting requirements for emergency diesel generators at this time. However, licensees :

must commit to implement within 90 days a maintenance program for monitoring and maintaining diesel generator performance consistent with the provisions of 10 t CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance of Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." !

Callaway Plant has currently implemented this maintenance program under the cognizance of the Emergency Diesel Generator Reliability Program (EDGRP). The ,

EDGRP governs all activities associated with emergency diesel generator reliability i and is based upon Appendix D of NUMARC 87-00, Revision 1. This program -

captures the provisions of the maintenance rule as it applies to emergency diesel generators and is consistent with the provisions of 10 CFR 50.65 and the guidence of Regulatory Guide 1.160. Also, as part of this license amendment request, it is proposed that a description of the EDGRP be added to Section 6 of the technical '

specifications. This addition is discussed later in this evaluation under item XXXIV. i IX. Technical Specification 4.8.1.1.2a.4 A. Descriotion of Prooosed Chance f This surveillance requirement currently requires that each emergency dics.,I generator starts and accelerates to 514 revolutions per minute (RPM) in less than or '

equal to 12 seconds. This surveillance also requires that each emergency diesel ;

generator obtain a voltage of 4000 i 320 volts and a frequency of 60 f_1.2 Hertz within 12 seconds after the start signal. The emergency diesel generator shall be ,

started by manual control, a simulated loss-of-offsite power signal, or a safety injection test signal. It is proposed that this surveillance requirement be revised to eliminate the 12 second requirement for obtaining the prescribed speed, voltage, and frequency. The requirement to obtain 514 RPM would be deleted since it is redundant to the frequency requirement. A statement would also be added that allows the emergency diesel generator to be slow started and allowed to reach rated speed at a rate that is selected to minimize stress and wear. In order to

, Attachm:nt l l Page 11 of 30 ULNRC-3244 accomplish a slow start, the emergency diesel generator must be placed in manual control; therefore, the requirement to start the emergency diesel generator by a simulated loss-of-offsite power signal or a safety injection test signal would be deleted.

B. Justification This surveillance requirement is considered to be a " Start Test" as described in Regulatory Guide 1.9, Revision 3. A " Start Test" is performed to demonstrate proper startup from standby conditions and to verify that the required design voltage and frequency is attained. For these tests, Regulatory Guide 1.9, Revision 3, recommends that the emergency diesel generators be slow started and allowed to reach rated speed on a prescribed schedule that is selected to minimize stress and wear. Therefore, the removal of the 12 second time requirement is justified in order to reduce undue stress and wear on the emergency diesel generators. The requirement to demonstrate a 12 second start capability would continue to be satisfied by renumbered Technical Specification 4.8.1.1.2f on a 184 day frequency.

Also, this proposed change is consistent, in part, with Technical Specification 3.8.1.2 from NUREG-1431.

The proposal to delete the requirement to obtain 514 RPM is consistent with Regulatory Guide 1.9, Revision 3, and Technical Specification 3.8.1.2 from NUREG-1431. As stated above, the 514 RPM verification is redundant to the frequency verification since the frequency of the generator can be converted directly into engine RPM (RPM = 120(frequency)/# Poles). Therefore, the verification that the -

emergency diesel generator reaches rated volta 0e and frequency is a satisfactory means of demonstrating operability in lieu of the RPM verification.

X. Technical Specification 4.8.1.1.2a.5 A. Descriotion of Prooosed Chanae This surveillance requirement currently requires that the emergency diesel generator be synchronized and gradually loaded to an indicated 6000 to 6201 kilowatts for at !

least 60 minutes. It is proposed that the load band of 6000 to 6201 kilowatts be revised to correspond with 90 to 100 percent of the continuous rating of the emergency diesel generators (5580 - 6201 kilowatts). Also, it is proposed that a statement be added to this surveillance requirement that requires the emergency diesel generator to be operated until temperature equilibrium is attained in addition to the 60 minute operating requirement. A statement would also be added that allows the loading of the emergency diesel generator to be gradual in order to l minimize stress and wear on the emergency diesel generator.

B. Justification Regulatory Guide 1.9, Revision 3, considers this surveillance requirement to be a

Load-Run Test." A " Load-Run Test" demonstrates 90 to 100 percent of the ;

continuous rating of the emergency diesel generator for an interval of not less than l 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and until temperature equilibrium has been attained. This test may be

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, ' ULNRC-3244 u

accomplished by synchronizing the generator with offsite power and the loading and unloading of an emergency diesel generator during this test should be gradual and -

based on a prescribed schedule that is selected to minimize stress and wear on the emergency diesel generator. The proposed changes to this surveillance requirement .

are consistent with the guidance of Regulatory Guide 1.9, Revision 3, and Technical Specification 3.8.1.3 from NUREG-1431.

XI. Technical Specifications 4.8.1.1.2b A. Descriotion of Proposed Chanae r-This surveillance requirement currently requires the checking for and the removal of accumulated water in the diesel generator day tanks at least once per 31 days and after each operation of the emergency diesel ~ generator where the period of operation was greater than or equal to one hour. it is proposed that this surveillance requirement be revised to eliminate the requirement to check for and remove accumulated water from the diesel generator day tanks after each operation of the emergency diesel generator where the period of operation was greater _ than or equal to one hour.

B. Justification This proposed change would make this surveillance requirement. consistent with-Technical Specification 3.8.1.5 from NUREG-1431. NUREG-1431 states that the removal of water from the day tanks eliminates the necessary environment for bacterial survival and is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during emergency diesel generator operation. Also, NUREG-1431 considers the performance of this surveillance requirement as preventative maintenance and that the presence of water does not necessarily represent failure of this surveillance requirement, provided the accumulated water is removed during the of performance of this surveillance.

Xll. Technical Specifications 4.8.1.1.2d and 4.8.1.1.2e A. Descriotion of Prooosed Chanoe These surveillance requirements currently require, in part, the sampling of new and stored fuel oil in accordance with prescriptive requirements specified in each surveillance requirement. It is proposed that these prescriptive surveillance requirements be revised to require that the new and stored fuel oil properties be tested and maintained within the limits of the Diesel Fuel Oil Testing Program.

B. Justification The Diesel Fuel Oil Testing Program includes the sampling and testing requirements and acceptance criteria which are based upon the applicable ASTM Standards.

This program ensures that the quality of new fuel oil and stored fuel oil is. verified and maintained in order to sustain the reliability and operability of the emergency

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ULNRC-3244 diesel generators. The surveillance Requirements' periodicity, ASTM testing standards, and acceptance criteria would be specified in the Bases Section for this ;

technical specification, as well as in the _ plant procedures utilized to test the i emergency diesel generator fuel oil on initial receipt and periodically, as currently- !

required. The relocation of the diesel fuel oil surveillance requirements is !

1 consistent, in part, with the intent of NUREG-1431. As previously discussed in this evaluation, it is proposed that a description of the Diesel Fuel Oil Testing Program :

be added to Section 6 of the technical specifications. Also, Section 6 of the j technical specifications would be revised to required that the program be reviewed - i by the Onsite Review Committee, audited by the Nuclear Safety Review Board, and ;

written procedures established, implemented, and maintained for the implementation of the Diesel Fuel Oil Testing Program. These proposed revisions !

are discussed in more detail later in this evaluation under items XXIX thru XXXill.

Xill. Technical Specification 4.8.1.1.2f.1 A. Descriotion of Prooosed Chanae This surveillance requirement currently requires the inspection of an emergency diesel generator in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service at least once per 18 months during shutdown. It is proposed that this requirement be relocated to the EDGRP.

B. Justification it is proposed that this technical specification surveillance requirement be relocated :

to the EDGRP based on the guidance of Regulatory Guide 1.9, Revision 3, and NUREG-1431 which no longer require an -inspection of an emergency diesel ,

generator on an 18 month frequency. The EDGRP would still require the inspection l in conjunction with the manufacturer's recommendations and the incorporation of specific plant experience; however, the inspection would no longer be a technical-specification requirement. Changes to the inspection performed with procedures ;

in conjunction with the manufacturer's recommendations would be accomplished pursuant to 10 CFR 50.59, ' Changes, tests, and experiments." Title 10 CFR 50.59 permits a licensee, among other things, (1) to make changes to the facility as :

described in the safety analysis report, or (ii) to make changes in the procedures as described in the safety analysis report, without prior NRC approval, unless the proposed change involves a change in the technical specifications or an unreviewed safety question. It is also proposed that a description of the EDGRP be added to .;

Section 6 of the technical specifications. This proposed addition is discussed in j more detail later in this evaluation under item XXXIV. i i

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a 3e Att; chm:nt I j Page 14 of 30 i ULNRC-3244 XIV. Technical Specification 4.8.1.1.2f.2 A. Descriotion of Prooosed Chance l l

This surveillance requirement currently requires the verification of the ability of an emergency diesel generator to reject the Essential Service Water Pump motor load (the largest single emergency load) while maintaining voltage at 4000 i 320 volts and the frequency at 60 .i. 5.4 Hertz. It is proposed that this requirement be eliminated.

B. Justification it is proposed that this surveillance requirement, which is considered to be the

" Single-Load Rejection Test" by Regulatory Guide 1.9, Revision 3, be eliminated based on its redundancy with the " Full-Load Rejection Test" which is required to be accomplished by surveillance requirement 4.8.1.1.2f.3. The ' Single-Load Rejection Test"is an insignificant transient compared to the other transient tests performed and is a duplication of the testing of the generator and engine capabilities to handle a transient. The starting sequence tests duplicate the transient load swings that occur when conducting the ' Single-Load Rejection Test," and if the emergency diesel generator satisfies the requirement for the load sequencing, it will pass the

' Single-Load Rejection Test."

Regulatory Guide 1.9, Revision 3, position C.2.2.7, " Single Load Rejection Test,"

requires the demonstration that the emergency diesel generator is capable of rejecting a loss of the largest single load while operating at a power factor between O.8 and 0.9 with voltage and frequency requirements being met. The emergency diesel generator shall not trip on overspeed. Position C.2.2.8, " Full-Load Rejection Test," requires the demonstration that the emergency diesel generator is capable of rejecting a load equal to 90 to 100 percent of its continuous rating while operating at a power factor between 0.8 and 0.9 with the voltage requirements being met.

The emergency diesel generator chall not trip on overspeed. Regulatory Guide 1.9, Revision 3, allows a maximum frequency of 65.4 Hertz (560 RPM) for the " Single-Load Rejection Test" and the " Full-Load Rejection Test". This is based on a nominal speed of 514 RPM plus 75 percent of the difference between the nominal speed and the overspeed trip setpoint of 575 RPM.

Analysis of previous surveillance tests conducted at Callaway Plant has shown that the frequency and voltage transient from the " Single-Load Rejection Test" is far less severe of a test on the emergency diesel generators than that from the " Full-Load Rejection Test." Previous surveillance tests results have shown that the frequency has never exceeded 61 Hertz (523 RPM) for the " Single-Load Rejection Test" nor the " Full-Load Rejection Test." This is well within the band allowed by Regulatory Guide 1.9, Revision 3 and does not approach the overspeed trip setpoint of 575 RPM. Similar analysis has shown that the voltage transient from the " Single-Load Rejection Test" is insignificant compared to that of the " Full-Load Rejection Test."

Typical maximum transient values are 4300 volts for the " Single-Load Rejection

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Page 15'of 30 ULNRC-3244

?- L Test" with the' maximum allowable value being 4320 volts and 4600 volts for the.

l1 " Full-Load Rejection Test" with the maximum allowable value being 4784 volts.

~

The performance data for the previous largest single load rejection tests is shown in Table' 1. This' data shows that the maximum transient values are well within the 4000 +/-320 Volt and 60 +/-5.4 hertz acceptance criteria and is within the steady state criteria of 4000 +/-320 Volt and 60 +/-1.2 hertz stated for the LOCA/ SIS test. The. previous performance testing has shown that the rejection of.the !!

Essential Service. Water pump is a minor transient for which the ' voltage and a frequency stay entirely within steady state performance criteria. !

At a minimum, the addition of a tighter frequency criteria for the full load rejection ;

test (< 65.4 hz) and the requirement that the emergency diesel generator ;

performance tests provide steady state operation within 4000 +/-320 Volt and 60 j

+/-1.2 hertz will adequately assure the continued required performance of the ,;

emergency diesel generators in lieu of performing the largest single load rejection. !

For over-frequency conditions, the 65.4 Hertz limit being applied to the full load !

rejection test will provide for adequate performance'for limiting motor overspeed I well within NEMA MG 1-20.44 specifications and is equivalent to the previous limit given for the single largest load rejection test. Operation within the steady state criteria provides adequate voltages and frequencies for the continuous operation of the connected loads, specifically induction motors, and conforms to NEMA Std. MG i 1-20.45 for variations from rated voltage and rated frequency.

Institute of Electrical and Electronics Engineers (IEEE) Std 387-1977, "lEEE

Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations," only specifies' the performance of a load rejection test that demonstrates the capability of the emergency diesel generator to reject the maximum rated load without exceeding speeds or voltages which will cause tripping, mechanical damage, or harmful overstresses. It does not specify.

the performance of a " Single-Load Rejection Test."

The magnitude of the load changes seen by the emergency diesel generator during load sequencing is greater than 2 times that of the ' Single-Load Rejection Test."

l' The sequencing of the largest load occurs late in the load sequencing, and is l- approximately equivalent to the ' Single-Load Rejection Test." ; An example of the kilovolts-amps-reactive (KVAR) and kilowatts rejections can be seen in Figure A2 of IEEE Std 387-1984.

The actual test load torque for the ' Single-Load Rejection Test"(Essential Service Water Pump) is approximately 8453 lb-ft. The maximum design load torque'is 9491 lb-ft for rejection of,the Essential Service Water pump. The starting and ~

breakdown torques are 10385 lb-ft and 20770 lb-ft, respectively, at the Essential Service Water pump nameplate voltage of 4000 Volts A.C. Therefore, the load torque upon loss of the Essential Service Watei ,nump is approximately one-half'of the torque change seen during starting of the Essential Service Water pump.

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Attachment I Page 16 of 30 f ULNRC-3244 * : :-

TABLE 1' EDG SINGLE LARGEST LOAD REJECT HISTORY I

Equipment Work Date Steady Volt Max. Volt Min. Steady State Hertz Hertz Max.

Number Document Performed State- After Trip After Trip Prior to trip After Trip KKJ01 A SO12978 3/8/86 4130 4183 4130 60 60.4-KKJ01A S408592 9/14/87 4148 4200 4148 60.4 60.8 KKJ01 A S426314 4/2/89 4130 4183 4130 60.1 60.9 ..j KKJ01 A S453922 9/23/90 4148 4209 4148 60.1 60.5 R KKJ01A S485359 3/24/92 4113 4176 4113- 60.3 60.6 KKJ01 A S516249 10/5/93 4155 4234 4155 60.2 60.6' KKJ01 A S540910 3/27/95 4078 4137 4078 60.2 60.4 KKJ01B STO7203 3/10/86 4130 4200 4130 59.7 60 l KKJ01 B - S408595 9/16/87 4113 4183 4113 59.7 60 KKJ01B- S426315 4/4/89 4130 4200 4130 59.6 60.2 KKJ018- S453920- 9/25/90 4095 4148 4095 59.7' 60 KKJ01B S485361 3/25/92 4130 4193 4130 59.8 60.2 KKJ01B S513510 10/3/93 3990 4060 3990 59.8 60.1 :

KKJ01B S541051 3/27/95 4095 4158 4095 59.7 59.9 i .

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, Att:chmint I : l Page 17'of 30 :j ULNRC-3244 !

The' load rejection of the Essential Service Water pump on an isochronous operating'

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' diesel generator. will result in an acceleration of the shaft and the corresponding ;

increase in frequency. However, the system inertia will act to resist the increase in frequency. The acceleration torque will remain until the engine electricalmechanical j

governor com'pensates to shut the fuel rack and bring the shaft speed back to 514 ' -i 4

. rpm. This load rejection can take place before or after- the engine governor or *

- generator voltage regulator have corrected for the load additions depending on the -

time constants of the governor and voltage regulator. Due to _the large system inertia which is mostly the emergency diesel and generator, the speed change-is small and will be less than that seen during the load sequencing. The governor correction during rejection of the Essential Service Water pump is minimal and more i during starting. The starting of the Essential Service Water pump has a greater i affect on the emergency diesel generator because the torque being added to the !

system is a load and accelerating torque for the Essential Service Water pump and l motor. Therefore, based on the above discussion, the " Single-Load Rejection Test" is redundant to the " Full-Load Rejection Test" and can be eliminated. 't XV. Technical Specification 4.8.1.1.2f.3 (4.8.1.1.2g.1)

A. Descriotion of Proposed Chanae ;

This . surveil lance requirement currently requires the verification that each !

emergency diesel generator is capable of rejecting a load of 6201 kilowatts without -

tripping and that the ~ emergency diesel generator voltage does not exceed 4784

~

volts during and following the load rejection. It is proposed that this surveillance i requirement be revised to require the' verification that each emergency diesel :

generator operating at a power factor between 0.8 and 0.9 does not trip on overspeed and that the voltage does not exceed 4784 volts and that the frequency j does not exceed 65.4 Hertz following a load rejection of 5580 to 6201 kilowatts. '!

The frequency criteria from - the " Single-Load Rejection Test" in surveillance ;

requirement 4.8.1.1.2f.2 would be relocated to this surveillance requirement. Also, l' a note would be added which states that this surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requirement. :

B. Justification i As discussed previously, this surveillance requirement is classified as the " Full-Load i Rejection Test" by Regulatory Guide 1.9, Revision 3. Specifically, Regulatory Guide j 1.9, Revision 3, describes this test as a demonstration of the emergency diesel. 1 generator's capability to reject a load equal to 90 to 100 percent of its continuous rating (5580-6201 kilowatts) while operating at a power factor between 0.8 and :

0.9 and verifying that the voltage requirements are met and that the emergency .

diesel generator will not trip on overspeed. The proposed changes to this !

surveillance requirement will encompass, in part, the guidance of Regulatory Guide 2 1.9, Revision 3. Also, the proposed addition of the note that will not allow the surveillance requirement to be performed in Modes 1 or 2 is based on the improved Standard Technical Specifications (NUREG-1431) which recognizes that the ,

performance of this surveillance requirement during operation with the reactor .i i

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Atttchm:nt i Page 18 of 30 ULNRC-3244 critical could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

The proposed deletion of surveillance requirement 4.8.1.1.21.2 and the revision of surveillance requirement 4.8.1.1.2f.3 has combined, in part, the requirements of the " Single-Load Rejection Test" and the " Full-Load Rejection Test."

XVI. Technical Specification 4.8.1.1.2f.4 (4.8.1.1.2g.2)

A. Descriotion of Prooosed Chanae This surveillance requirement currently requires the demonstration, by simulating a loss-of-offsite power, that the emergency buses are deenergized and the loads are shed from the emergency buses, and the emergency diesel generator starts on the autostart signal. Also, the emergency busses must be energized with the permanently connected loads with 12 seconds and the auto-connected shutdown loads must be energized through the shutdown sequencer with the emergency diesel generator operating for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steaay state voltage and frequency of the emergency busses shall be maintained within specified limits. It is proposed that this surveillance requirement be retained in its entirety; however, it would be reformatted to be consistent with surveillance requirement 3.8.1.11 from NUREG-1431. Also, a note would be added which states that this surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requirement.

B. Justification 6 This surveillance requirement can be classified as the " Loss-of-Offsite-Power Test" in accordance with Regulatory Guide 1.9, Revision 3. As stated above this sorveillance requirement would be retained in its entirety; however, it would be reformatted to be consistent with the improved Standard Technical Specifications.

Also, the justification for tne addition of the note is discussed above under Technical Specification 4.8.1.1.2f.3.

XVil. Technical Specification 4.8.1.1.2f.5 (4.8.1.1.29 .3)

A. Descriotion of Procosed Chanae This surveillance requirement currently requires that on a safety injection actuation signal (SIAS) without loss-of-offsite power, the emergency diesel generator starts on.the autostart signal'and operates on standby for greater than or equal to 5 minutes. Also, the offsite power source must energize the auto-connected emergency (accident) load through the LOCA sequencer and the generator voltage and frequency shall be within specified limits within 12 seconds after the autostart signal. It is proposed that this surveillance requirement be retained in its entirety; however, it would be reformatted to be consistent, in part, with surveillance requirement 3.8.1.12 from NUREG-1431. Also, a note would be added which states that this surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requircment.

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3e .4e' Attzchm:nt i Page 19 of 30 1 ULNRC-3244 l I

B.' Justification- )

q This surveillance requirement can be classified as the "SIAS Test" in accordanceu 'j with Regulatory Guide 1.9, Revision 3. As ' stated above this surveillance -l

' requirement would be retained in its entirety: however, it would be reformatted to l

be consistent, in part,iwith the improved Standard Technical Specifications. - The 1 portion of surveillance requirement 3.8.1.12 from NUREG-1431 which requires the . j verification that permanently connected loads remain energized from the offsite ' 1 power system would not be added to Technical _ Specification 4.8.1.1.2f.5-(4.8.1.1.2g.3) since it is not discussed in Regulatory Guide 1.9, Revision 3 and is not currently in Technical Specification 4.8.1.1'.2f.5. Also, the justification for the j addition of the note is discussed above under Technical Specification 4.8.1.1.2f.3. l i

XVill. Technical Specification 4.8.1.1.2f.6 (4.8.1.1.2g.4) l i~ A. Descriotion of Proposed Chance ;

I This - surveillance requirement currently requires the demonstration that the j emergency diesel generator can satisfactorily respond to a loss-of-offsite power 1 (LOOP) in conjunction with a SIAS in whatever sequence they might occur. A .

simultaneous LOOP /LOCA event is demonstrated by simulating a LOOP and SlAS .]

and verifying that the emergency buses are deenergized and loads are shed from j the emergency buses and the. emergency diesel generator starts on the autostart j signal. Also,- the emergency diesel generator must attain the required voltage and -

frequency, energize the permanently connected loads within acceptable limits and ;

time, energize the autoconnected loads through the load sequencer, and operate for greater than or equal to 5 minutes. Also, all automatic diesel generator trips,.

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_j except high jacket coolant temperature, engine overspeed, low lube oil pressure, ').

high crankcase pressure, start failure relay, and generator differential, must be verified to be automatically bypassed upon loss of voltage on the emergency bus concurrent with a SIAS. it is proposed that this surveillance requirement be .

retained in its entirety, except that the requirement to verify that a portion of the-automatic diesel generator trips are automatically bypassed would be relocated to renumbered Technical Specification 4.8.1.1.2g.5. In addition, 'the surveillance requirement would be reformatted to be consistent with' surveillance requirement 3.8.1.19 from NUREG-1431. Also, a note would be added which states that this surveillance shall not be performed in Modes 1 or 2 and credit may be taken for j unplanned events that satisfy this requirement. j W'

B. Justification

This surveillance requirement can be classified as the " Combined SIAS and LOOP Tests" in accordance with Regulatory Guide 1.9, Revision 3. As stated above, this surveillance re'quirement would be retained in its entirety except that a portion of ,

the surveillance test would be relocated to renumbered Technical Specification !

4.8.1.1.2g.5. Also, it would be reformatted to be consistent with the Improved Standard Technical Specifications. The justification for the addition of the note is

. discussed above under Technical Specification 4.8.1.1.2f.3.

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Att: chm:nt i Page 20 of 30 ULNRC-3244 XIX. (Renumbered Technical Specification 4.8.1.1.2g.5)

A. Descriotion of Prooosed Chance Currently, Technical Specification 4.8.1.1.2f.6 requires, in part, 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, be verified to be automatically bypassed upon loss of voltage on the emergency bus concurrent with a SIAS. It is proposed that this portion of Technical Specification 4.8.1.1.2f.6 be relocated to renumbered Technical Specification 4.8.1.1.2g.5. Also, a note would be added which states that this surveillance shall not be performed in Modes 1 or 2 and credit may be taken for unplanned events that satisfy this requirement.

B. Justification The portion of Technical Specification 4.8.1.1.2f.6 that is proposed to be relocated to renumbered Technical Specification 4.8.1.1.2g.5 is considered to be the

" Protective Trip Bypass Test," as described in Regulatory Guide 1.9, Revision 3.

This surveillance would be reformatted to be consistent with surveillance requirement 3.8.1.13 from NUREG-1431. Also, the justification for the addition of the note is discussed above under Technical Specification 4.8.1.1.2f.3.

XX. Technical Specification 4.8.1.1.2f.7 (4.8.1.1.29.6)

A. Descriotion of Prooosed Chance Currently, surveillance requirement 4.8.1.1.2f.7 requires the verification that each emergency diesel generator operate for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the emergency diesel generator shall be loaded to an indicated 6600 to 6821 kilowetts and during the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the emergency diesel generator shall be loaded to an indicated 6000 to 6201 kilowatts. The generator voltage and frequency shall be 40001320 volts and 60 + 1.2 Hertz,- 3 Hertz within 12 seconds after the start signal and the steady state generator voltage and frequency shall be maintained within 4000 i 320 volts and 6011.2 Hertz during the test. It is proposed that this surveillance requirement be revised to require that the full-load capability of each emergency diesel generator be demonstrated at a power factor between 0.8 and 0.9 for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at 5580 to 6201 kilowatts. The generator voltage and frequency shall be maintained within 4000 i 320 volts and 60 i 1.2 Hertz during this test.

This proposed change would eliminate the requirement to load the emergency diesel generator to an indicated 6600 to 6821 kilowatts for the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the test.

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Attachm:nt i Page 21 of 30 ULNRC-3244 i

l B. Astification These changes are consistent, in part, with the definition of the " Endurance and Margin Test" as described in Regulatory Guide 1.9, Revision 3. However, the requirement to operate each emergency diesel generator for two hours at 105 to 110 percent of the continuous rated load has been eliminated. It appears that this requirement originates from the fact that many older nuclear power plants were built with emergency diesel generator capacity below emergency bus loading. At the start of an accident, the bus loading during the first two hours, at these older plants, may well be above the continuous rating of the emergency diesel generator.

Bus loading calculations for Callaway Plant indicate that under the worst scenario, emergency bus loading would be 6039 kilowatts, which is only approximately 97 percent of the rated continuous load for each emergency diesel generator.

The emergency diesel generators at Callaway Plant utilize Colt-Pielstick PC 2.5V 14 '

cylinder engines. The generator ratings are 6201 kilowatts continuous, 6635 kilowatts for 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months , 6821 kilowatts for 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months (110 percent of rated continuous), and 7441 kilowatts for 30 minutes. All ratings are at a power factor of 0.8. The worst case accidant bus loading occurs during a station blackout, cold shutdown conditions with r,ngineered safety features and non-engineered safety features loads connected The bus loading under these conditions is 6039 kilowatts. Without non-en{lineered safety features loads connected, the bus load is 4556 kilowatts. Under LOCA conditions, recirculation phase, the maximum load (engineered safety features plus non-engineered safety features) is 5440 kilowatts.

With LOCA recirculation conditions and only engineered safety features loads connected, the total bus load is 5258 kilowatts. At the continuous rated load of the emergency diesel generator (6201 kilowatts with power factor at 0.8), the normal fuel rack position is 47 to 49 millimeters. At the 110 percent power level (6821 kilowatts with power factor at 0.8), the fuel rack position is 51 to 52 millimeters. A total of 75 millimeters of fuel rack movement is available; however, a mechanical stop prevents movement above 55 millimeters. The ability of the governor actuator and fuel rack mechanism to move rapidly to the maximum fuel position is demonstrated each time a successful fast start of the emergency diesel generator is conducted and the fuel rack position will be verified and trended during these fast start surveillances to assure it is not approaching the mechanical stop, thus assuring the emergency diesel generator's capacity remains above the emergency bus loading. Therefore, as described above ample margin exists in the capacity of the emergency diesel generators to preclude overloading during the accident conditions.

The EDGRP will contain the minimum requirements for emergency diesel generator performance monitoring that are commensurable with the goals of the program.

The purpose of performance monitoring is to monitor certain parameters on an ongoing basis in order to obtain information about the physical state of the emergency diesel generators that may potentially impact the operability and which could be used for trending purposes. These trends may signal degradation and would allow the evaluation of the condition to enable the prediction of the onset of failures and allow corrective actions to be taken prior to a failure occurring. The EDGRP will establish a thorough performance monitoring system that will specify,

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Att chm:nt l l Page 22 of 30 I ULNRC-3244 I

trend, and analyze the necessary emergency ciesel generator parameters. Tracking and trending of operational parameters will ensure high reliability and availability of the emergency diesel generators.

In addition, operating at 110 percent of rated load is detrimental to long-term emergency diesel generator reliability. The relationship between high loads and wear is well known for typical piston engine applications and engine manufactures have indicated that aging and wear significantly increase after 95 percent of the continuous load rating is achieved. Therefore, based on the Callaway Plant emergency bus loading, the diesel generator rated capacity, and the increase in aging and wear, the requirement to perform the two hour margin test is considered unnecessary and detrimental to the long-term reliability of the emergency diesel generators.

XXI. Technical Specification 4.8.1.1.2f.8 A. Descriotion of Proposed Chanae Currently, Technical Specification 4.8.1.1.2f.8 requires the verification that the auto-connected loads to each emergency diesel generator do not exceed 6201 kilowatts. It is proposed that this surveillance requirement be eliminated.

B. Justification This surveillance requirement can be eliminated based on the fact that bus loading calculations for Callaway Plant indicate that under the worst scenario emergency bus loading would be 6039 kilowatts which is only approximately 97 percent of the rated continuous load for each emergency diesel generator. Also, this requirement is not contained in NUREG-1431 or Regulatory Guide 1.9, Revision 3. The auto-connected bus loadings are monitored and trended by the Emergency Diesel Generator Reliability Program with the electrical bus load growth being controlled by an Electrical Load Growth Program.

XXil. Technical Specification 4.8.1.1.2f.9 (4.8.1.1.2g.7)

A. Descriotion of Proposed Chanae it is proposed that a note be added to this surveillance requirement which stipulates that the surveillance shall not be performed in Modes 1, 2, 3, or 4 and that credit may be taken for unplanned events that satisfy this requirement.

B. Justification The addition of this note would make this surveillance requirement consistent with surveillance requirement 3.6.1.16 from NUREG-1431. The requirement for not performing this surveillance requirement in Modes 1, 2, 3, or 4 is due to the fact that a required offsite circuit is removed from service, the electrical distribution system is perturbed, and safety systems are challenged.

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l XXill. Technical Specification 4.8.1.1.2g (4.8.1.1.2h) !

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A. Descriotion of Proposed Chanae This surveillance requirement currently requires that at least once per 10 years or after any modifications which could affect emergency diesel generator interdependence, both emergency diesel generators be started simultaneously, during shutdown, and verify that both emergency diesel generators accelerate to at least 514 RPM in less than or equal to 12 seconds. It is proposed that this surveillance requirement be revised to eliminate the requirement to perform the test after any modifications which could affect emergency diesel generator interdependence and replace the requirement to obtain 514 RPM with voltage and frequency requirements.

B. Justification This surveillance requirement can considered to be the " Redundant Unit Test" in accordance with Regulatory Guide 1.9, Revision 3. This test demonstrates that, by starting and running both redundant units simultaneously, potential common failure modes that may be undetected in single emergency diesel generator unit tests do not occur. The proposed change to this surveillance requirement will make it consistent with surveillance requirement 3.8.1.20 from NUREG-1431. The replacement of the requirement to accelerate the emergency diesel generator to at least 514 RPM in less than or equal to 12 seconds with voltage and frequency requirements is justified since the RPM requirement is redundant to the frequency and voltage requirements (Reference Justification for Technical Specification 4.8.1.1.2a.4).

XXIV. Technical Specification 4.8.1.1.2h (4.8.1.1.2i) )

A. Descriotion of Prooosed Chanae l This surveillance requirement currently requires that every 10 years each fuel oil i storage tank be drained, accumulated sediment removed and cleaned using a l sodium hypochlorite solution or equivalent. It is proposed that this surveillance l requirement be revised to eliminate the requirement to clean the tank using a ;

sodium hypochlorite solution or equivalent. j l

B. Justification The proposed change to this surveillance requirement will make it consistent with surveillance requirement 3.8.3.6 from NUREG-1431. The proposed removal of the requirement to clean the tank using a sodium hypochlorite solution or equivalent will allow greater flexibility for cleaning the tanks. Sodium hypochlorite is no longer a >

viable cleaning medium since it has been classified as a hazardous waste. More effective cleaning techniques are now available such as high-pressure water cleaning. The EDGRP will ensure that the method of cleaning the fuel oil tanks will not introduce surfactants in the fuel oil system that could potentially affect the operability and reliability of the emergency diesel generators.

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, XXV. - Technical Specification 4.8.1.1.2i (4.8.1.1.2f) j A. Descriotion of Proposed Chanae i

This surveillance requirement currently requires that each emergency diesel !

generator be started from ambient conditions (using the keep warm system) by l manual control, a simulated loss-of-offsite power signal, or a safety injection test !

signal. Each emergency diesel generator must be accelerated to at least 514 rpm in . I less than or equal to 12 seconds and generator voltage and frequency shall be .

4000 i 320 volts and 60.i.'1.2 Hertz within 12 seconds after the start' signal. l Also, the emergency diesel generator must be loaded to an indicated 6000 to 6201. ,

kilowatts in less than or equal to 60 seconds and be operated at a load of 6000 to 6201 kilowatts for at least 60 minutes. Note "* * *" states that the 6000 to 6201 kilowatt band is meant as guidance to avoid routine overloading.of the engine and j

that loads in excess of this band for special testing under direct monitoring or 3 momentary variations due to changing bus loads shall not invalidate this test. Itis ;

proposed. that the requirement to load the emergency diesel generator to an ;

indicated 6000 to 6201 kilowatts in less than or equal to 60 seconds, to operate !

the emergency diesel generator at a load of 6000 to 6201 kilowatts for at least-~ .

60 minutes, and its associated note be eliminated. Also, it is proposed that the 'l requirement to accelerate the emergency diesel generator to at least 514 rpm in i less than or equal to 12 seconds be deleted. !

,l B. Justification l

Regulatory Guide 1.9, Revision 3, considers this surveillance to be a " Fast-Start '

Test." A " Fast-Start Test" demonstrates that each emergency diesel generator i starts from standby conditions. If a plant normally has in operation keep warm [

systems designed to maintain lube oil and Jacket water cooling at certain !

temperatures or prelubrication systems or both, this would constitute- normal !

standby conditions for that plant. Verification that the emergency diesel generator 1 reaches required voltage and frequency within acceptable limits and time is also i required. Therefore, based on this guidance, the requirement to operate the '

emergency diesel generator for at least 60 minutes at 6000 to 6201 kilowatts can be deleted. This portion of the surveillance requirement would be satisfied by the .;

performance of Technical Specification 4.8.1.1.2a.5. once per 31 days on a - '

staggered test basis. The requirement to accelerate the emergency diesel generator ;

to at least 514 rpm in less than or equal to 12 seconds can be deleted since it is- .;

redundant to the requirement to obtain the specified frequency and voltage in less 'r than or equal to 12 seconds (Reference Justification for Technical Specification - 4.8.1.1.2a.4). Also, the requirement to load the emergency _ diesel generator to an'- ,

indicated 6000 to 6201 kilowatts in less than or equal to 60 seconds can be deleted since Regulatory Guide 1.9, Revision 3, no longer requires the emergency 1 diesel generator to be fast loaded, due to the adverse affect on the reliability of the i emergency diesel generator. The proposed changes to this surveillance requirement are consistent with the guidance of Regulatory Guide 1.9, Revision 3, and j surveillance requirement 3.8.1.7 from NUREG-1431. '

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XXVI. Technical Specification 4.8.1.1.3 A. Descriotion of Prooosed Chance l

This surveillance requirement currently requires the reporting of all emergency diesel generator failures, valid or nonvalid, in a Special Report to the Commission. Itis proposed that this surveillance requirement be eliminated.

B. Justification The elimination of this surveillance requirement is consistent with the guidance provided in Generic Letter 94-01 and is discussed under Technical Specification 4.8.1.1.2a. 10 CFR 50.72 and 50.73 still provide criteria that may require the notification of the Commission of significant emergency diesel generator failures.

Also, guidance will be provided in the EDGRP on reporting failures of the emergency diesel generators.

XXVil. Table 4.8-1 A. Descriotion of Proposed Chanae Reference Technical Specification 4.8.1.1.2a.

XXVill. Technical Specification 4.8.1.2 A. Descriotion of Proposed Chance This surveillance requirement currently requires the demonstration of the operability of one circuit between the offsite transmission network and the onsite Class 1E Distribution System and one emergency diesel generator during Modes 5 and 6 by the performance of each of the requirements of Technical Specifications 4.8.1.1.1, 4.8.1.1.2 (except for Technical Specification 4.8.1.1.2a.5), and 4.8.1.1.2f.5), 6),

10) and 12) for the LOCA sequencer portion of LSELS only), and 4.8.1.1.3. Itis proposed that the reference to Technical Specification 4.8.1.1.3 be deleted.

B. Justification The proposed deletion of the reference to Technical Specification 4.8.1.1.3 (Reports) is necessary since it is being proposed to eliminate Technical Specification 4.8.1.1.3 based on the guidance provided in the Generic Letter 94-01.

L XXIX. Technical Specification Bases Section 3/4.8 A. Description of Proposed Chanae j lt is proposed that Technical Specification Bases Section 3/4.8 be revised to I

describe, in part, the changes proposed by this license amendment request and I provide greater detail concerning certain surveillance requirements and actions l

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ULNRC-3244 I

statements. Also, the Diesel Fuel Oil Testing Program would be described and the f specific surveillance requirements from Technical. Specifications 4.8.1.1'.2d and'

_ f 4.8.1.1.2e would be relocated to this Bases Section. These relocated surveillance i requirements. could then be changed without . prior NRC approval, provided an j unreviewed safety question did not exist. !

It is. being proposed that relocated Technical Specifications '4.8.1.1.2d and !

4.8.1.1.2e be revised to provide greater flexibility for the testing of the diesel fuel l oil. These changes include the addition of an ASTM standard (ASTM D4294-90) !

for the analysis for sulfur. This ASTM standard provides a more current method for l the analysis for sulfur then those already specified in the surveillance requirements. l In addition to the ASTM standard, it is being proposed that the phrase 'in ,

accordance with" be replaced with ' based on" in the relocated surveillance i requirements. This change will allow minor variances from a. specific ASTM :

standard while still meeting the intent of the standard. These minor variances are i

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sometimes necessary due to the impracticality of a test or due -to an ASTM standard not being specifically meant for diesel fuel oil. Also,- the current I requirement to test new fuel oil for a clear and bright appearance with proper color f when tested in accordance with ASTM D4176-82 would be replaced' with the - .

requirement to test new fuel oil for a water and sediment content of less than or i equal to 0.05 percent when tested in accordance with ASTM D1796-83. This !

proposed change is discussed in more detail later in this evaluation. The proposed !

changes described above will not affect the ability to verify the quality of diesel fuel i oil.

XXX. Technical Specification 6.5.1.6, item q A. Descriotion of Proposed Chanae It is proposed that item.q be added to Technical Specification 6.5.1.6 to require '

that the Onsite Review Committee be responsible for the review of the Diesel Fuel l Oil Testing Program. This proposed change is consistent with Technical

! Specification 5.5.1.2 from NUREG-1431. ]

~XXXI. Technical Specification 6.5.2.9, item 1 - i A. Descriotion of Pronosed Chanae it is proposed that item I be added to Technical Specification 6.5.2.9 to require j audits of the Diesel Fuel Oil Testing Program be performed under the cognizance of !

the Nuclear Safety Review Board. This proposed change is consistent with - l Technical Specification 5.5.2.3 from NUREG-1431. !

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'XXXil. ~ Technical Specification 6.8.1, item j A. Descriotion of Pronosed Chanas I It is proposed that item j be added to Technical Specification 6.8.1 to require that '

written procedures be established, implemented, and maintained for the- '

implementation of the Diesel Fuel. Oil Testing Program. This proposed change is consistent with Technical Specification 5.7.1.1 from NUREG-1431. ;

XXXill. Technical Specification 6.8.4h .

J A. Descriotion of Pronosed Chanae it is proposed that this technical specification be added to the " Administrative ;

Controls" section- of the technical specifications in order to briefly- describe the Diesel Fuel Oil Testing Program. The Diesel Fuel Oil. Testing Program includes sampling and testing ;equirements, and acceptance criteria for both new and stored ;

fuel oil to ensure the proper quality of the fuel oil utilizing recommended fuel oil ;

practices. The program provides means of determining whether new fuel oil is of i the appropriato grade and has not been contaminated with substances that would l have an immediate, detrimental impact on emergency diesel generator operability. .

Also, the program provides sufficient testing of stored fuel oil to ensure that fuel oil degradation is identified prior to potentially affecting emergency diesel generator operability or reliatjlity.

Contrary to NUREG-1431, exception is taken to the requirement for new fuel oil to. ,

have a clear and bright appearance with proper color. 40 CFR 80.29, " Fuels and Fuel Additives," was amended in 1992 to conform with the Clean Air Act

-l Amendments of 1990. The Clean Air Act authorizes the EPA to require the use of a dye in high sulfur non-highway diesel fuel to differentiate it from low sulfur highway diesel fuel. As an alternate test method for the requirement in NUREG-1431 to test for clear and bright appearance with proper color, it is proposed that j new fuel oil be tested for water and sediment based on the applicable ASTM 'j Standards. Specifically, Technical Specification Bases Section 3/4.8 will require j that new fuel oil be tested for a water and sediment content of less than or equal to ,

0.05 percent when tested in accordance with ASTM D1796-83. This proposed j change will still ensure that the properties of new fuel oil are adequate to maintain i the reliability and operability of the emergency diesel generators.

An exception is also taken to ASTM D2276-78 as to the nominal filter size used in . l the laboratory particulate test analysis. The proposed change allows the use of a - l 3.0 micron nominal laboratory filter in lieu of the 0.8 micron nominal filter-as j specified in ASTM D2276-78, Method A. ASTM D2276 was written based on .i aviation turbine fuel requirements. Diesel generator engines require less restrictive I fuel particulate contamination requirements than that of aviation turbines and I therefore less restrictive fuel oil specifications. Callaway Plant's emergency diesel generators are designed to operate with fuel delivered through a 5 micron nominal filter. Therefore, based on this, a laboratory testing method utilizing a filter more i representative of the ones used on the emergency diesel generators would provide )

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ULNRC-3244 a test method more representative 1 for. diesel . engine fuel ' oil particulate contamination. The particulate contamination will still be maintained less than 10 mg/ liter when verified based upon ASTM D2276-78, Method . A.- . The only difference is that a 3.0 micron nominal test filter will be used instead of the 0.8 micron nominal filter, and since the engine filters are 5.0 micron nominal size the

. 3.0 micron nominal test filters provide sufficient conservatism that the emergency' diesel generators will still perform their intended safety function.

Changes to the Diesel Fuel Oil Testing Program would be accomplished pursuant to.

10 CFR 50.59, " Changes, tests, and experiments." . Title 10 CFR 50.59 permits a licensee, among other things, (i) to make changes to the facility as described in the :

safety analysis report, or (ii) to make changes in the procedures as described in the safety analysis report, without prior NRC approval, unless the proposed ~ change involves a change in the technical specifications or an unreviewed safety' question.

By deleting the specific reference in the technical specifications 'of the testing standards used to meet technical specifications testing requirements, .an ASTM :

standard, or standard edition, could be . changed without prior NRC approval, provided an unreviewed safety question did not exist.

An unreviewed safety question exists (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to . safety previously evaluated in the safety an'alysis report' may be_ increasedi or- (ii) if a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report may be increased;' or (iii) if the margin of.

safety as defined in the basis for any technical specification is reduced. 10 CFR 50.59(b)(1) requires that records be maintained of any. changes made pursuant to 10 CFR 50.59 and that these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. Additionally, a report is required to be submitted to the NRC periodically containing a brief description of any changes made pursuant to -

10 CFR 50.59, as well as a summary of the safety evaluation of each change. As a result, the NRC will periodically be informed of changes that are made to the Diesel Fuel Oil Testing Program.

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All of the proposed changes to the fuel oil technical specifications have. been previously approved by the NRC for Florida Power and Light Company's Turkey Point Nuclear Plant.

XXXIV. Technical Specification 6.8.4i A. Descriotion of Proposed Chanae It is proposed that this technical specification be added to the " Administrative Controls" section of the technical specifications in order to briefly describe the Emergency Diesel Generator Reliability Program. The EDGRP establishes the requirements and guidelines for emergency diesel generator reliability, availability, and monitoring. The EDGRP is~ based upon NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors," Revision 1, Appendix D. Also, incorporated in the EDGRP are provisions

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Attachm:nt i Page 29 of 30 ULNRC-3244 for meeting the requirements of the Maintenance Rule,10 CFR 50.65. The EDGRP requires implementation of activities to ensure that: emergency diesel generator performance is maintained at an acceptable level and target reliability is achieved; emergency diesel generators whose performance deviates significantly from acceptable levels are subject to additional efforts to restore emergency diesel generator performance; and a graded response to declining emergency diesel generator reliability is implemented via action levels and remedial efforts developed from statistical analyses and programmatic experience.

Compliance with the requirements of the maintenance rule, as it applies to the emergency diesel generators, is accomplished by: using an emergency diesel generator target reliability as the overall performance goal: using an emergency diesel generator target reliability and system availability goal as the overall performance criteria: using methods of the NUMARC program to monitor emergency diesel generator failures and govern the remedial actions taken when a failure occurs: screening emergency diesel generator failures for maintenance preventable function failures; and prescribing system parameters important to system performance a.nd reliability that are to be monitored and trended.

This license amendment request proposes to revise the existing Callaway Plant Technical Specification requirements concerning emergency diesel generator testing. These changes are in accordance with the intent of guidance provided by the Commission in Generic Letter 94-01, Generic Letter 93-05, Regulatory Guide 1.9, NUREG-1431, and manufacturer's recommendations. The proposed changes will serve to increase the overall emergency diesel generator reliability and iongevity, and do not involve an unreviewed safety question because operation of Callaway Plant with these changes would not::

a. Increase the p:obability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.

These proposed changes do not involve a cha 10 in the operational limits or physical design of the emergency power system. Emergency diesel generator operability and reliability will continue to be assured through implementation of the EDGRP, while minimizing the number of required emergency diesel generator starts. Also, emergency diesel generator reliability will be enhanced by minimizing service test conditions which can lead to premature failures.

b. Create the possibility for an accident or malfunction of equipment of a different type than any previously evaluated in the Safety Analysis Report.

These proposed changes do not involve a change in the operational limits or physical design of the emergency power system. The performance capability of the emergency diesel generator will not be affected. Emergency diesel generator reliability and availability will be improved by the implementation of the proposed changes. There is no actual impact on any accident analysis.

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c. Reduce the margin of safety as defined in the basis for any technical

!. specification.

p These proposed changes do not involve a change in the operational limits or physical design of the emergency power system. The performance capability of the emergency diesel generator will not be affected. Emergency diesel-generator reliability and availability will be improved by the implementation of K the proposed changes. No margin of safety is reduced.

Given the above discussions as well as those presented in the Significant Hazards Evaluation,.

the proposed changes do not adversely' affect or endanger the health or safety of the general public or involve a significant safety hazard. The proposal corrects an inconsistency in the plant technical specifications that causes a compliance problem.

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1% .1 Attachmnnt il Page 1 of 1 ULNRC-3244 SIGNIFICANT HAZARDS EVALUATIN This license amendment request proposes revising Technical Specification 3/4.8.1 and its associated Bases to achieve an overall improvement in emergency diesel generator reliability and availability. Specifically, it is proposed that the guidance of Regulatory Guide 1.9, Revision 3, Generic Letter 93-05 and Generic Letter 94-01 be adopted. Also, several surveillance requirements that are redundant or inappropriate would be revised or eliminated and emergency diesel generator fuel oil surveillance requirements would be addressed as an administrative program. Descriptions of the Diesel Fuel Oil Testing Program and the Emergency Diesel Generator Reliability Program would be added to Section 6 of the Technical Specifications to ensure that administrative controls are in place to maintain emergency diesel generator reliability and availability. These proposed changes are consistent, in part, with recent NRC guidance concerning emergency diesel generator surveillance requirements.

The proposed changes do not involve a significant hazards consideration because operation of Callaway Plant with these changes would not:

1. Involve a Significant increase in the Probability or Consequences of an Accident Previously Evaluated.

These proposed changes do not involve a change in the operational limits or physical design of the emergency power system. Emergency diesel generator operability and reliability will continued to be assured while minimizing the number of required emergency diesel generator starts. Also, emergency diesel generator reliability will be enhanced by minimizing severe test conditions which can lead to prcmature failures.

2. Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.

These proposed changes do not involve a change in the operationallimits or physical design of the emergency power system. The performance capability of the emergency diesel generator ;

will not be affected. Emergency diesel generator reliability and availability will be improved by l the implementation of the proposed changes. There is no actual impact on any accident analysis.

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3. Involve a Significant Reduction in the Margin of Safety.

These proposed changes do not involve a change in the operational limits or physical design of the emergency power system. The performance capability of the emergency diesel generator will not be affected. Emergency diesel generator reliability and availability will be improved by the implementation of the proposed changes. No margin of safety is reduced.

Based on the above discussions, it has been determined that the requested technical specification revision does 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 an new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety. The requested license amendment does not involve a significant hazards consideration.

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Attrchm:nt til 1 Page 1 of 1 ULNRC-3244 ENVIRONMENTAL CONSIDERATION This amendment application revises the requirements of Technical Specification 3/4.8.1 and its associated Bases to achieve an overall improvement in emergency diesel generator ,

reliability and availability. These proposed changes are based on the guidance of Generic ;

Letters 94-01 and 93-05, Regulatory Guide 1.9, Revision 3, and NUREG-1431. !

The proposed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10 CFR 20 and revises surveillance l i

requirements. Union Electric has determined that the proposed amendment does not involve:

1) A significant hazards consideration, as discussed in Attachment ll of this amendment application;

2) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite;

3) A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

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t PROPOSED TECHNICAL SPECIFICATION CHANGES SPECIFICATIONS: INDEX MARKUP 3/4.8.1 MARKUP 3/4.8.2 MARKUP B3/4.8 MARKUP 6.5.1.6 MARKUP 6.5.2.9 MARKUP 6.8.1 MARKUP 6.8.4 MARKUP '

r SPECIFICATIONS: INDEX RETYPED [

3/4.8.1 RETYPED 3/4.8.2 RETYPED B3/4.8 RETYPED' !

6.5.1.6 RETYPED 6.5.2.9 RETYPED 6.8.1 RETYPED 6.8.4 RETYPED t I

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ULNRC-03244, Application for Amend to License NPF-30,revising TS 3/4.8.1 & Associated Bases to Achieve Overall Improvement in EDG Reliability & Availability Based Upon,In Part,Guidance of GLs 94-01,93-05 & Reg Guide 1.9,Rev 3

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Reference:

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