View source for AECM-86-0394, Forwards Application for Amend to License NPF-29,revising Tech Specs for Diesel Generator Testing,Allowed out-of-svc Time & Surveillance Requirements for Offsite & Onsite Ac Electrical Sources.Fee Paid

{{Adams
| number = ML20215C515
| issue date = 12/09/1986
| title = Forwards Application for Amend to License NPF-29,revising Tech Specs for Diesel Generator Testing,Allowed out-of-svc Time & Surveillance Requirements for Offsite & Onsite Ac Electrical Sources.Fee Paid
| author name = Kingsley O
| author affiliation = MISSISSIPPI POWER &amp; LIGHT CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000416
| license number = 
| contact person = 
| document report number = AECM-86-0394, AECM-86-394, TAC-55863, TAC-61970, NUDOCS 8612150204
| package number = ML20149C259
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 2
| project = TAC:55863, TAC:61970
| stage = Request
}}

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MISSISSIPPI POWER & LIGHT COMPANY
                            ]
EdMdMdiddB Helping Build Mississippi P. O. B O X 164 0, J A C K S O N, MIS SIS SIP PI 39215-1640 December 9, 1986 O. D. KINGSLEY JR.
VeCE PRESIDENT NUCLE AR OPERATIONS U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.               20555 Attention: Mr. Harold R. Denton, Director

==Dear Mr. Denton:==

==SUBJECT:==
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 File: 0260/0840/L-860.0 Proposed Amendment to the Operating License (PCOL-86/10 Resubmittal)
AECM-86/0394 Mississippi Power & Light (MP&L) Company requested by {{letter dated|date=May 22, 1986|text=letter dated May 22, 1986}}, an amendment to the Grand Gulf Technical Specifications concerning A. C.
Electrical Power Sources. These changes were reviewed by the NRC staff and the results of this review were documented in a Safety Evaluation dated October 23, 1986. The changes to the Technical Specifications proposed in this submittal reflect the parts of the original submittal that were found acceptable by the staff and modifications to parts of the original submittal to make them acceptable.
In accordance with the provisions of 10 CFR 50.30, three (3) signed originals and forty (40) copies of the requested amendment are enclosed. The attachment provides the complete technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee (PSRC) and was reviewed and accepted by the Safety Review Committee (SRC) at the time of the original submittal.
Based on the guidelines presented in 10 CFR 50.92, it is the opinion of MP&L that this proposed amendment involves no significant hazards considerations.
In accordance with the requirements of 10 CFR 170.21, we have determined that the application fee is $150. A remittance of $150 is attached to this letter.
Your    uly, 8612150204 DR 861209 ADOCK 05000416 PDR                            ,                0}0 e
ODK:rg gi  o Attachments: GGNS PC0L-86/10 Resubmittal                                     I cc:      (See Next Page)                                                         ,            gg Member Middle south utilities system J12AECM86120501 - 1

e-AECM-86/0394 Page.2 cc: Mr. ' T. H. Cloninger (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. R. C. Butcher (w/a)
Mr. James M. Taylor, Director (w/a)
Office of Inspection & Enforcement U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Dr. J. Nelson Grace, Regional Administrator (w/a)
U. S. Nuclear Regulatory Comission Region II 101 Marietta St., N. W.,   Suite 2900                          ,
Atlanta, Georgia 30323 Dr. Alton B. Cobb (w/a)
State Health Officer State Board of Health Box 1700 Jackson, Mississippi 39205 J12AECM86120501 - 2

AECM-86/0394 Paga 4 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and                                        '
MIDDLE SOUTH ENERGY, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, stated that.I am Vice President, Nuclear Operations of Mississippi Power & Light Company; that on behalf of Mississippi Power & Light Company, Middle South Energy, Inc., and South Mississippi Electric Power Association I am authorized by Mississippi Power & Light Company to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of Mississippi Power & Light Company; and that the statements made and the matters set forth therein are true and correct to th best of my knowledge, information and belief.
                                                                                            ~
STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 befpre me, a Nofpry Public, in and for the County and State above named, this 60 day of A/pudt)                                ,   1986.
(SEAL) 50b      6       g fj,3 p           ,
Notary Public My commission expires:
My Commission Ex$ce: Sq. 21, 1937 J12AECM86120501 - 4 W         M  --

NLS-85/17     Diesel Generator Technical Specification Relaxations (Resubmittal)

==SUBJECT:==
Technical Specification-3.8.1.1 Action Statements a through f, Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5, Table 4.8.1.1.2-1, Bases 3/4.8.1; pages 3/4 8-1, 8-2, 8-3, 8-8, and B 3/4 8-la.
DISCUSSION:   The changes proposed in this submittal are made in response to the NRC's Safety Evaluation dated October 23, 1986 concerning revised technical specification for diesel generator testing.
The onsite and offsite electric power systems for Grand Gulf are described in FSAR Chapter 8.0. The station is supplied AC. power by two 500 KV lines from the system grid to the 500KV switchyard. Two service transformers supplied from the 500KV switchyard provide two sources of power to the Class 1E and B0P electric systems. A third source of power to the Class 1E electrical system is provided from a separate 115KV line. The onsite Class 1E AC power system is divided into three independent divisions to provide AC power to the three divisions of ESF loads. An alternate source of AC power for each ESF division is an associated diesel generator which will automatically supply power to its ESF bus in case of a loss of preferred power source. A simplified one line diagram is attached to show the Grand Gulf AC electrical power arrangement.
The proposed changes affect the allowed out of service time requirement and surveillance requirements for both the offsite and onsite A.C. electrical sources. Some of the changes are in response to the NRC's Generic Letter 84-15, " Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability",
dated July 2, 1984; while other changes are proposed to clarify existing requirements while meeting the intent of Generic Letter 84-15. Specific changes are proposed as follows:
Present Action a has been divided into Action a, for a required offsite circuit inoperable, and Action b, for a required diesel generator 11 or 12 inoperable.
Action a:
: 1) Extend the time requirement and reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within 24 hours.
: 2) The restoration statement is clarified by requiring the offsite circuit to be returned to operable status within 72 hours from time of initial loss.
J16ATTC86010701 - 1

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Action b:
: 1) Extend the time requirement and reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within 24 hours.
: 2) The restoration statement is clarified by requiring the inoperable diesel generator 11 or 12 to be returned to operable status within 72 hours from time of initial loss.
Present Action b has been changed to Action c.
Action c:
: 1) Extend the time requirement and reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within 8 hours for one of the required offsite circuits and diesel generator 11 or 12 inoperable.
: 2) Delete the sentence requiring restoration of at least two of the required offsite circuits and diesel generators 11 and 12 to operable status within 72 hours from time of initial loss.
Present Action c has been changed to Action-d.
Action d:
: 1) Reference to Action a or b is changed to Action b or c.
Present Action d has been changed to Action e.
Action e:
: 1) Extend the time and reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within 8 hours for two of the l
required offsite circuits inoperable.
: 2) Delete the sentence requiring restoration of at least i                                two offsite circuits to operable status within 72 hours from time of initial loss.
Present Action e has been changed to Action f.
l I
t l
l J16ATTC86010701 - 2

                        -Action f:
: 1) Reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within the next 2 hours after restoring at least or,e of the inoperable diesel generators 11 or 12 within 2 hours,               j
: 2) Delete the sentence requiring restoration of both diesel generators 11 and 12 to operable status within 72 hours from time of initial loss.
Present Action f has been changed to Action g.
Action g:
: 1) Reduce the periodicity for performing Surveillance Requirement 4.8.1.1.2.a.4 from within two hours and at least once per 8 hours thereafter, to once within 2 hours when diesel generator 13 is inoperable.
Surveillance Requirement 4.8.1.1.2.a.4:
: 1) Add a "*" footnote to relax the present fast start requirements. All diesel generator starts may be preceded by an engine prelube period. The diesel generator start (10 sec) from standby conditions shall be performed at least once per 184 days in these surveillance tests. All other engine starts for the purpose of this surveillance testing may be preceded by warmup procedures as recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized. This change requires demonstration of the 10 second start criteria only once per 184 days.
: 2) Change " ambient" to " standby".
Surveillance Requirement 4.8.1.1.2.a.5:
: 1) Add a "#" footnote to relax the present diesel generator loading requirements. The diesel generator loading (60 sec) shall be performed at least once per 184 days in these surveillance tests. All other diesel engine runs for the purpose of this f                                          surveillance testing may include gradual loading i
as recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized. This change requires demonstration of the 60 second loading criteria only once per 184 days.
J16ATTC86010701 - 3

9 Table 4.8.1.1.2-1:
: 1) Remove test frequency of 3 days.
: 2) Change the criteria for determining fatsures to a per diesel generator basis instead of the present per nuclear unit basis.
: 3) Add a reference to exceptions to Regulatory Guide 1.108 as noted in the FSAR.
: 4) Add the methodology for transvaluing the number of
(                               diesel generator failures to zero.
: 5) Delete the statement " Entry into this test schedule shall be made at the 31 day test frequency".
Bases 3/4.8.1:
: 1) Add exceptions taken with respect to Regulatory Guide 1.108 requirements.
Attached to this proposed change are marked up technical specification pages reflecting the proposed changes.
JUSTIFICATION: The various changes discussed above are justified as follows:
Action a:
Present Action a contains requirements with either one offsite source or diesel generator 11 or 12 inoperable. The proposed change will split present Action a into Action a for one offsite source inoperable and Action b for diesel generator 11 or 12 inoperable. The remaining action statements have been renumbered to accommodate the split of present Action a.
Present test requirements for diesel generators 11, 12 and 13 with one of the required offsite sources inoperable are to perform 4.8.1.1.2.a.4 for one diesel generator at a time, within 2 hours and at least once per 8 hours thereafter. The proposed change will allow diesel generator testing to be                                                                                                             l performed once                                 ' thin 24 hours. The proposed change follows                                                                           I the guidance ps.,vided in Generic Letter 84-15 to reduce excessive diesel generator testing and thereby enhance the reliability of the diesel generators. Diesel generator testing within the first 24 hours will provide assurance that no starting problems exist with the diesels and will provide additional time for inspection prior to the test.
J16ATTC86010701 - 4

h The restoration requirements for one of the required offsite A.C. sources being inoperable have been clarified by adding the phrase "from time of initial loss" after the 72 hour restoration statement. This phrase is being added to proposed Actions a and b and is being deleted from present Actions b, d, and e. Present Actions b, d, and e specify requirements when two A.C. electrical power sources are inoperable. When one of the inoperable A.C. electrical power sources is returned to operable status, present Action b, d, or e, as applicable, is exited and present Action a is entered for one of the required A. C. electrical power sources inoperable. Therefore, the restoration requirement in present Actions b, d, and e for restoration of two of the required A. C. electrical power sources within 72 hours from time of initial loss is never entered or used. This requirement is adhered to, however, by entering present Action a where present plant interpretations require restoration of both required A. C. electrical power sources within 72 hours from time of initial loss. This change does not alter present interpretations or plant actions but rather clarifies the requirements by placing them in the appropriate action statements. This proposed change follows the guidance provided in Generic Letter 84-15 to reduce excessive diesel generator testing and thereby enhance the reliability of the diesel generators.
Action b:
Proposed Action b contains the action requirements if either diesel generator 11 or 12 is inoperable. The proposed changes will reduce excessive diesel generator starts by extending the present time requirements for testing the operable diesel generator 11 or 12 from within 2 hours and at least once per 8 hours thereafter, to once within 24 hours. This proposed change follows the guidance provided in Generic Letter 84-15 to reduce excessive diesel generator testing and thereby enhance the reliability of the diesel generators.
As described for Action a above, the restoration requirements for diesel generator 11 or 12 inoperable has been clarified by adding the phrase "from time of initial loss". This requirement in proposed Action b is justified as described l
above for Action a, is provided for clarification only, and l                    does not change present plant interpretations of action requirements.
i                    Action c:
I l                    The time requirement for testing the remaining two operable diesel generators is presently within 2 hours and once per 8 hours thereafter. The proposed change will require testing of the operable diesel generators pursuant to Specification 4.8.1.1.2.a.4 only once within 8 hours. This change is consistent with the recommendations of Generic Letter 84-15
:                    and is intended to reduce unnecessary diesel generator l                    testing, thus increasing availability and reliability.
J16ATTC86010701 - 5

r The last sentence of present Action b has been deleted with the proposed Action c changes. The deletion of the restoration statement for two offsite circuits and diesel generators 11 and 12 within 72 hours is purely administrative and is proposed only for clarification. Present interpretations of action requirements by plant staff would require exiting proposed Action c when one offsite circuit or when either diesel generator 11 or 12 is returned to operable status and entering proposed Action a or b for one remaining inoperable offsite circuit or diesel generator 11 or 12.
Action d:
The only change to Action d is editorial in nature due to the proposed renumbering of the action statements. Reference to Action a or b is changed to Action b or c.
Action e:
Present test requirements for diesel generators 11, 12 and 13 with two of the required offsite circuits inoperable are to perform 4.8.1.1.2.a.4 for one diesel generator at a time, within two hours and at least once per 8 hours thereaf ter.
The proposed change will allow diesel generator testing to be performed once within 8 hours. The proposed change follows the guidance provided in Generic Letter 84-15 to reduce excessive diesel generator testing and thereby enhance the reliability of the diesel generators. Diesel generator testing within the first 8 hours will provide assurance that, with two of the required offsite A.C. sources inoperable, the diesel generators will perform their design function.
The restoration requirement of 72 hours for both of the inoperable offsite circuits is deleted from present Action d and not included in proposed Action e. As discussed in the justification for proposed Action c changes above, this change is purely administrative in nature since the 72 hour requirement from time of initial loss is now included in proposed Action a.
Action f:
With both diesel generators 11 and 12 inoperable, diesel generator 13 is presently required to be tested within 2 hours and at least once per 8 hours thereafter. The proposed change will require that diesel generator 13 be tested only once and then only after restoration of either diesel generator 11 or
: 12. If diesel generator 11 or 12 cannot be restored within 2 hours, then diesel generator 13 testing is not required while the plant is being taken to cold shutdown. Excessive testing of the remaining diesel generator 13 while taking the plant to cold shutdown may reduce the reliability of the one operable onsite A.C. source and should, therefore, not be required.
This change will reduce unnecessary testing on diesel generator 13 while providing assurance that the diesel can start d perform its intended design function. Other provisions of J16ATTC86010701 - 6

Action f require either diesel generator 11 or 12 to be returned to service within 2 hours or be in hot shutdown within the next 12 hours and in cold shutdown within the following 24 hours.
The 72 hour restoration statement for both diesel generators 11 and 12 being inoperable is deleted from proposed Action f.
This change is similar to that discussed in Action c above and is purely administrative in nature. The 72 hour restoration statement is included in proposed Action b for either diesel generator 11 or 12 inoperable. - Action b would be entered when one of the inoperable diesel generators 11 or 12 is returned to operable status, thus retaining the requirement to restore both diesel generators 11 and 12 to operable within 72 hours of initial loss.
Action g:
Present Action f for diesel generator 13 inoperable requires testing of diesel generators 11 and 12 within 2 hours and at least once per 8 hours thereafter. The proposed change will require testing of diesel generators 11 and 12 once within 2 hours. This proposed change will reduce unnecessary testing requirements for diesel generators 11 and 12 and help to increase their reliability and availability.
Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5:
A footnote is proposed to be added to each of these surveillance requirements to specify relaxations in the present cold start and loading requirements. With the proposed changes all diesel generator starts for the purpose of these surveillance requirements may be preceded by an engine prelube period. The footr.otes propose that diesel generator starts (10 sec) and loading (60 sec) from standby only be performed once per 184 days. All other starts for the purpose of satisfying Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 may be preceded by warmup procedures and may also include gradual loading as recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized (i.e., the 10 second start criteria and the 60 second load criteria do not have to be demonstrated for these other tests.) The proposed changes follow the guidance provided in Generic Letter 84-15 to reduce cold fast starts. As stated in Generic Letter 84-15, it is the NRC staff's technical judgement J16ATTC86010701 - 7

that an overall improvement in diesel engine reliability and availability can be gained by performing diesel generator starts for surveillance testing using engine prelube and other manufacturer recommended procedures to reduce engine stress and wear. The proposed change incorporates these recom-mendations by allowing a prelube period before diesel starts, by requiring fast start criteria (10 sec) and fast load criteria (60 sec) to be imposed only once per 184 days, and by allowing warmup and gradu~al loading for tests other than those performed once per 184 days.
Table 4.8.1.1.2-1:
The proposed deletion of the 3 day test frequency follows the intent of Generic Letter 84-15 to reduce unnecessary testing of diesel generators. The 7 day minimum test interval provides adequate assurance of diesel generator operability and follows the guidance in Generic Letter 84-15.
The criteria for determining number of failures and number of valid tests is currently based on a per nuclear unit basis.
The proposed change is to a per diesel generator '..: sis following the guidance in Generic Letter 84-15. Presently, with one diesel generator experiencing failures, the test frequency for all three diesel generators is increased. This increased testing on diesel generators which have not experienced valid failures decreases their reliability and increases the potential for wear related problems.
The exceptions MP&L has taken with respect to Regulatory Guide requirements are specified in the FSAR. A clarification is added to the "*" footnote to specify that exceptions taken with respect to Regulatory Guide 1.108, Revision 1, August 1977 requirements are noted in the FSAR.
The "*" footnote is also modified by adding provisions to reduce the test failure count to zero if a major diesel overhaul is completed. This major diesel overhaul will be followed by post-maintenance operation and testing approved by the manufacturer and will require NRC acceptance of diesel generator reliability. These provisions specify methods that can be used to reduce the test failure count while maintaining controls to ensure appropriate reliability is maintained.
The present statement that entry into this test schedule shall be made at the 31 day test frequency has been deleted. The number of valid failures determines the frequency of testing thus negating the need for this statement.
J16ATTC86010701 - 8

Bases 3/4.8.1:
The propo yd change to Bases 3/4.8.1 provides exceptions taken with respict.te Regulatory Guide 1.108 requirements. These
               \      exceptions are in regard to Technical Specification Table
               ,      4.8.1.1.2-1 requirements regarding test frequency and determination of valid failures. The proposed exceptions comoly with provisions contained in Generic Letter 24-15 and are intended to provide adequate assurance of diesel generator J     availability without causing degradation due to excessive i    engine starts.
SIGNIFICANT HAZARDS CONSIDERATIONS:
MP&L has evaluated the proposed changes and considers them not to involve a significant hazards consideration for the following reasons.
(1) The proposed changes will not significantly increase the probability or consequences of an accident previously evaluated, because the changes will eliminate a practice of unnecessary and abusive diesel generator testing contained in the technical specifications. Such testing contributes to accelerated diesel generator wear, which consequently degrades their reliability and availability.
Increasing the reliability and availability of the diesel generators helps to further assure the ability to perform their design functions when required in accident situations. Therefore, previous accident analyses are not adversely impacted. Additional clarifications are provided in the action statements to provide restoration requirements consistent with present plant interpretations. These interpretations are' consistent with the present intent of the technical specification and therefore do not increase the probability or consequences of an accident previously evaluated.
(2) The proposed changes will not create the possibility of l
a new or different accident from any accident previously evaluated, because no physical modifications are required to be made to the plant in co june' ion with these proposed changes. The changes are intended to increase diesel generator reliability; therefore, availability of the onsite emergency power system as described in the FSAR will be enhanced. No new failure modes are introduced by the proposed changes; therefore, these changes will not create the possibility of a new or different accident from any previously evaluated.
J16ATTC86010701 - 9

Y -
(3) The proposed changes will not involve a significant reduction in a margin of safety, because demonstration of diesel generator operability will be maintained at necessary to ensure operability and availability, and will be conducted on a more optimum test schedule that will improve the overall performance of the onsite emergency power system, t
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