W3P87-0950, Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-59,revising Action Statements & Surveillance Requirements of Tech Spec 3.8.1.1, Electrical Power Sys,Ac Sources - Operating. Fee Paid

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Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-59,revising Action Statements & Surveillance Requirements of Tech Spec 3.8.1.1, Electrical Power Sys,Ac Sources - Operating. Fee Paid
ML20205J825
Person / Time
Site: Waterford Entergy icon.png
Issue date: 03/26/1987
From: Dewease J
LOUISIANA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205J830 List:
References
W3P87-0950, W3P87-950, NUDOCS 8704010431
Download: ML20205J825 (10)
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LOUISIANA 317 BARONNE STREET . P. O. BOX 60340 POWER & L1GHT/ NEW ORLEANS, LOUISIANA 70160 . (504) 595-2781 us: N hrSSEM March 26, 1987 J. G. DEWE ASE SENCt VXE PRE 5 DENT-NUGEAR OMRATONS W3P87-0950 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Waterford SES Unit 3 Docket No. 50-382 Technical Specification Change Request NPF-38-59

Dear Sir:

Louisiana Power & Light hereby files an application for an amendment to the Waterford 3 Technical Specifications regarding the emergency diesel generators.

The enclosed amendment request does not involve an unreviewed safety question nor a significant hazards consideration. Should you have any questions or require additional information concerning the proposed change, please contact Mike Meisner at (504) 595-2832.

Yours very truly, ewease

&C

.J4G.

S'enior Vice President Nuclear Operations JGD/DPS/plm

Enclosures:

NPF-38-59 Filing Fee - LP&L Check No. 03-0750 cc: E.L. Blake, W.M. Stevenson, G.W. Knighton, J.H. Wilson, R.D. Martin, NRC Resident Inspector's Office (W3), Administrator Nuclear Energy Division (State of Louisiana), American Nuclear Ins.. rats 8704010431 870326 PDR ADOCK 05000362 ,

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s 4gf "AN EQUAL OPPORTUNITY EMPLOYER" I

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Louisiana Power & Light Company ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT J.G. Dewcase, being duly sworn, hereby deposes and says that he is Senior Vice President, Nuclear Operations of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request; that he is familiar with the content thereof; and that the matters set forth herein are true and correct to the best of his knowledge, information and belief.

Y D -

id. Dewease enior Vice President-Nuclear Operations STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

Subscribed and sworn to beforeg,e, p Notary Pub g in and for the p rish qE-47M day of yg' ,y f ///_ Ajf2 and State above named this ' ~~

1987.

[ Notary Public 7

My Commission expires ( -

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NPF-38-59 4

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-59 This is a request to revise the action statements and surveillance requirements of Technical Specification 3.8.1.1, " Electrical Power Systems, A.C. Sources -

Operating".

Existing Specification See Attachment A Proposed Specification See Attachment B Description The proposed change will revise the action statements and surveillance requirements of Technical Specification 3.8.1.1, " Electrical Power Systems, A.C.

Sources - Operating". The reason for this change is to implement a more performance based Technical Specification that will improve the overall reliability and availability of Waterford 3's emergency diesel generators.

The proposed change consists of the following:

1) ACTION statement "a' currently specifies the action to be taken if either an offsite A.C. power source or an emergency diesel generator (EDG) becomes inoperable. The proposed change would place the offsite circuit and the diesel generator into separate action statements; that is, the proposed ACTION statement "a" would specify only those actions that are required when one offsite A.C. circuit becomes inoperable while the proposed ACTION statement "b" would specify only those actions that are required when one EDG becomes inoperable. This will provide the operators with specific instructions for each case thereby reducing the potential for operator error. This change is strictly administrative and does not affect the manner in which the plant is operated.
2) When one required offsite A.C. circuit is inoperable, ACTION statement "a" currently requires all remaining A.C. power sources (including both EDGs) to be demonstrated operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

The proposed change would not affect the reguirement to verify the operability of the remaining offsite A.C. circuit but would change the requirement for testing the diesel generators. The diesel generator testing requirements would be changed from "within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" to "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (unless it is already operating)". This change would reduce the number of diesel generator starts and is consistent with NRC Generic Letter 84-15, Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability, and other EDG Technical Specification changes previously approved on other plants.

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3) When one required diesel generator is inoperable, ACTION statement "a" currently requires all remaining A.C. power sources to be demonstrated operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. The proposed change would not affect the requirement to verify the operability of the offsite A.C. circuits but would reletter this action statement as ACTION statement "b" and modify the diesel generator testing requirements. The new ACTION statement "b" would require testing of the remaining operable EDG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (same as (2) above) but only "if the diesel generator became inoperable due to any cause other than preplanned preventive maintenance or testing". This reduced testing requirement is consistent with other EDG technical specification changes previously approved on other plants.
4) With one offsite A.C. circuit and one diesel generator inoperable, ACTION statement "b" currently requires the remaining A.C. power sources to be demonstrated operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

The proposed change would retain the same requirements for verifying the operability of the remaining offsite A.C. circuit, but would not require operability tests on the remaining operable EDG if it was already running or if the inoperable EDG became inoperable due to preplanned preventive maintenance or testing. The requirement to restore at least one of the inoperable power sources to operable status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is also retained; however, the requirement to restore both offsite A.C. circuits and both EDGs to operable status has been reworded to clarify what credit may be taken and what time requirements are involved when one of the inoperable A.C. power sources has been returned to operable status. These changes are consistent with NRC Generic Letter 84-15 and should assist the operators in properly interpreting the action statements. Note that this action statement has been relettered as ACTION statement "c".

5) When one diesel generator is inoperable, ACTION statement "c" currently requires action to be taken which is in addition to ACTION statement "a or b". The proposed change would reletter this action statement (to ACTION statement "d") and change the reference from ACTION statement "a or b" to ACTION statement "b or c". This is strictly an administrative change to maintain consistency throughout the Technical Specifications.
6) When both of the required offsite A.C. circuits are inoperable, ACTION statement "d" currently requires both diesel generators to be demonstrated operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter (unless they are already operating). The proposed change deletes the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> requirement and specifies that both EDGs must be demonstrated operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The requirement to restore at least 1 offsite A.C. circuit to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been retained; however, the requirement to restore both offsite A.C. circuits to operable status has been reworded to clarify what credit may be taken and what time requirements are involved when one of the inoperable offsite A.C. circuits has been returned to operable status. These changes are consistent with NRC Generic Letter 84-15 and should assist the operator in properly interpreting the action statements.

Note that this action statement has been relettered as ACTION statement "e".

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7) When both of the required diesel generators are inoperable, ACTION statement "e" currently requires both offsite A.C. circuits to be demonstrated operable within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. In addition it requires that one EDG be restored to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the reactor must be shutdown. There is no change to these requirements. The proposed change to this action statement is to reword the requirement to restore both EDGs to operable status in order to clarify the time requirements that are involved when an inoperable EDG is returned to operable status. This is strictly an administrative change to assist the operators in interpreting the action statements. Note that this action statement has been relettered as ACTION statement "f".
8) Surveillance Requirement 4.8.1.1.2a.5 currently requires that, on a staggered test basis, each diesel generator be synchronized and loaded to greater than or equal to 4400 kw in less than or equal to 176 seconds and operate at this load for at least an additional 60 minutes. The proposed change would replace " greater than or equal to 4400 kw" with "between 4000 and 4400 kw". The reason for this change is to allow routine monthly testing below the continuous diesel generator rating of 4400 kw. The NRC staff has previously stated, in a safety evaluation of similar changes for another plant, that the intent of monthly testing is not to show that the EDG can exceed its continuous duty rating on a frequent basis but, rather, to exercise the EDG, confirm its operability and detect any performance degradation prior to a failure. The ability of the EDG to meet the design basis accident loads (4619 kw) and the maximum continuous design load (4383 kw) is verified every 18 months by performing surveillance requirement 4.8.1.1.2d.6. Therefore, since the exact value of generator load is not critical and it has been shown that frequent overloading is a potential cause of EDG failures, the reduction in EDG loading for routine tests should result in an overall increase in the reliability and availability of the diesel generators.
9) Surveillance requirement 4.8.1.1.2c.2 currently requires that, in order to maintain an operable EDG, the diesel generator fuel oil supply must have an impurity level of less than 2 mg of insolubles per 100 ml. The proposed change would add a statement that would allow the EDG to retain operable status even if this parameter was outside of the prescribed limits as long as corrective action is initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to return the fuel oil supply to within acceptable limits. The reason for not requiring the EDG

. to be declared inoperable is because this is a non-critical fuel oil parameter that could result in long term degradation of the EDG but would not have an impact on starting or short term operation. This change is consistent with the inoperability requirements of Regulatory Guide 1.137 (Position 2a).

10) Surveillance requirement 4.8.1.1.2c.3 currently requires that, in order to maintain an operable EDG, the diesel generator fuel oil supply must be maintained with properties consistent with Table 1 of ASTM-D975-1977 and Regulatory Guide 1.137 (Position 2a). The proposed change to this I surveillance requirement is the same as that described in (9) above in that l a statement will be added to allow the EDG to remain operable when non-critical fuel oil parameters are outside of the acceptable limits. It l NS20601

should be noted that the two parameters called out in Regulatory Guide 1.137 (Position 2a) as being critical to EDG operability (i.e., viscosity and water / sediment) are specifically covered in surveillance requirements 4.8.1.1.2c.1 and 4.8.1.1.2c.2. These parameters must be within acceptable limits or the EDG is declared inoperable.

11) Surveillance requirement 4.8.1.1.2d.6 currently requires, in part, that every 18 months each EDG be run continuously for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a load greater than or equal to 4840 kw and the last 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at a load greater than or equal to 4400 kw. The basis for this requirement is to ensure that each EDG can maintain the peak accident design load (4619 kw) if required and the maximum continuous design load (4383 kw) if required. The proposed change would revise the maximum EDG loading for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from " greater than or equal to 4840 kw" to "between 4620 and 4840 kw". This will verify that the EDG is capable of maintaining the peak accident design load without overloading it. The requirement for maintaining greater than or equal to 4400 kw for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> is unchanged. The proposed change also corrects a typographical error in the last line of this surveillance requirement. This line should read, "Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2d.3b" (vice 4.8.1.1.2d.4b).
12) Table 4.8-1, which specifies the diesel generator test schedule, is based on Regulatory Guide 1.108 and currently requires a test frequency varying from once every three days to once every 31 days depending on the number of failures in the last 100 valid tests. The proposed change would add a 20 test criterion for determining test frequency, change the 100 test criterion to reflect a reduced testing frequency, and change the test criteria from a "per nuclear unit" basis to a "per diesel generator" basis. In addition, a note will be added to this table which provides a direct incentive for major corrective action when a diesel generator has been experiencing repeated failures. That is, once the EDG has been completely overhauled to "like-new" conditions and demonstrated its reliability, the diesel generator failure count would be reduced to zero and the EDG would re-enter the test schedule at the monthly test frequency. In order to demonstrate EDG reliability, the diesel generator would be successfully started 14 consecutive times. These changes are consistent with NRC Generic Letter 84-15 and other EDG Technical Specification changes previously approved on other plants.

Safety Analysis The proposed changes described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No NS20601

Emergency onsite power sources (i.e., diesel generators) are credited in all FSAR Chapter 15 accident analyses that assume a loss of offsite power.

The analyses include virtually every type of accident; from reactivity initiated accidents (e.g., CEA Drop and CEA Ejection) to primary and secondary systen pipe breaks (e.g., Steam Line Break and Loss of Coolant Accident). When evaluating these accidents it is typical to assume that one emergency diesel generator (EDG) fails to start and/or load, hence each EDG must be capable of powering the Engineered Safety Features (ESF) that are necessary to mitigate the consequences of the accident.

In the case of Waterford 3, it has been calculated that the initial peak accident load (i.e., the power that must be available for the first two hours of the design basis accident) is approximately 4619 kw while the long-term accident loads (i.e., the power that must be available for several weeks post-accident) is approximately 4383 kw. The Waterford 3 EDGs therefore, have design ratings of 4840 and 4400 kw for the peak and long-term accident loads, respectively. In order to ensure that these EDGs can indeed perform as they were designed, it is important that they be tested on a routine basis; however, when the testing becomes excessive (as much as 3 times a day for some ACTION statements) the tests themselves can lead to EDG degradation and subsequently, reduce their reliability and availability.

The proposed change to this Technical Specification provides for an overall reduction in diesel generator testing that is consistent with the guidelines provided by NRC Generic Letter 84-15 and other EDG Technical Specification changes that have been previously approved by the NRC. Since the proposed change will improve the overall reliability and availability of the diesel generators and each EDG (by itself) can satisfy the power requirements for the peak and long-term accident loads, the proposed change will not signi-ficantly increase the probability or consequences of any accident previously evaluated.

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The emergency diesel generators provide backup electrical power to vital plant systems in the event that primary offsite power is lost. They provide no direct support for plant systems during normal plant operation.

The proposed change, which will implement reduced testing requirements, is intended to increase the overall reliability of the EDGs thereby increasing their availability. Since the diesel generators will still be capable of ,

performing their design function (with potentially increased availability) l the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No NS20601

The intent of this Specification is to ensure there is sufficient power available to supply the safety-related equipment required for safe shutdown of the plant and mitigation and control of accident conditions. The redundancy of the power sources required (2 onsite sources and 2 offsite sources) ensure that, even during an accident with a coincident loss of ,

offsite power and a single failure of one onsite power source, there is l still sufficient power to supply all required safety systems. Since the proposed change has no effect on the Limiting Condition for Operation (LCO), these requirements are unaffected. The action statements to the LC0 restrict operation of the plant in a manner commensurate with the level of degradation. For example, when one emergency diesel generator is inoperable, the action statements require verification that all other A.C.

power sources are operable and that all required systems, subsystems, trains and components that depend on the remaining EDG are also operable.

This provides assurance that a loss of offsite power will not result in a complete loss of safety function of critical systems during the time one EDG is inoperable. The proposed changes to the action statements are either administrative (such as dividing the current ACTION statement "a" into separate ACTION statements "a" and "b") or they implement the reduced testing requirements recommended by NRC Generic Letter 84-15. These changes should result in increased reliability and availability of the EDGs. The surveillance requirements are intended to demonstrate the operability of the A.C. sources. There have been no changes to the surveillance requirements affecting the operability of the offsite A.C.

sources while changes to the EDG surveillance requirements have been fairly minor. The proposed changes are mainly to reduce the frequency and potential for overloading the EDGs in order to reduce the overall wear on the engine. This should result in an increased reliability of the EDGs.

Therefore, due to the increased reliability and availability of the EDGs, the proposed change does not involve a significant reduction in the margin of safety.

Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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