ML20064F515

Application for Amend to Licenses NPF-2 & NPF-8 Consisting of Proposed Changes to Tech Specs Reducing Diesel Generator Load Testing & Deleting River Water Sys.Safety Evaluations Encl

ML20064F515
Person / Time
Site:	Farley
Issue date:	12/30/1982
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20064F518	List: ML20064F515 ML20064F522
References
NUDOCS 8301060394
Download: ML20064F515 (18)

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Mamng Address Alabama Power Company

. 600 North 18th Street Post Offic9 Box 2641 Birmingham, Alabama 35291 Telephone 205 780-6081 F. L Clayton, Jr.

C 4' C ff,*"' AlabamaPower the southem electnc system December 30, 1982 Docket Nos. 50-348 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Request for Change to Diesel Generator Technical Specification and Deletion of River Water System Technical Specification Gentlemen:

In a letter dated August 3, 1982, Alabama Power Company requested a permanent change to the Diesel Generator Technical Specification Surveillance Requirement (Section 4.8.1.1.2.c.5) involving a 24-hour overload test. That proposal would have changed the loading requirement for the 24-hour test and would have clarified that the diesel generators may be manually unloaded / DO[

before they are tripped and hot restart demonstrated. ffj Subsequently, Alabama Power Company requested in letter dated ,/F6 August 20, 1982 asimilarone-timechangetothedieselgenerator\*!CIGdh*,

technical specification that was granted by the NRC in Amendment Nos. 27 and 16 to the Farley license for Units 1 and 2 respectively. This one-time change was partly justified to the NRC/I VVoo.ob based on a commitment made by Alabama Power Company in the August 20, 1982 letter to request deletion of the river water system from the technical specifications at a later date.

Pursuant to this commitment, Alabama Power Company hereby requests a permanent technical specification change to reduce diesel generator load testing and to delete the river water j system technical specifications. These changes to technical specifications provide assurance of diesel generator operability without unnecessarily exposing the diesel to excessive testing that could degrade long-term reliability. In addition, an adequate heat sink providing sufficient cooling water for safety related equipment during normal and emergency conditions is ensured.

8301060394 821230 PDR ADOCK 05000348 P PDR

Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission It should be noted that the proposed diesel generator surveillance testing technical specification change and the proposed deletion of the river water system from the plant technical specifications are related. The deletion of the river water system from the plant technical specifications will result in reduced loading requirements for the diesel generators that power the river water pumps. The reduced loading requirements provide additional justification for this diesel generator surveillance technical specification change requested herein. The combined changes in the technical specifications will preclude potential degradation to the diesel generators from surveillance testing and, as stated in the August 3.1982 letter, the reduced load testi.ng on the diesel generators concurs with the recommendations of the diesel generator manufacturer to prevent long-term diesel degradation.

The basis for the change request for diesel generator technical specification is: 1) the deletion of the river water system from the technical specifications eliminates the need to automatically sequence the loads in excess of the diesel generator continuous rating; 2) the previous overload testing of the Farley diesel generators has established a high degree of confidence in overload capability; 3) to preclude exposing the diesel generators to excessive testing that could degrade long-term reliability; and

4) to comply with the recommendations of the diesel generator manufacturer.

The basis for the request to delete the river water system technical specification, which additionally justifies the above change request to the diesel generator technical specification, is as follows: 1) the Farley dam is seismically qualified; 2) the storage pond, dam and dike at Farley were designed and constructed in accordance with NRC reauirements as documented in the FNP-Final Safety Analysis Report; 3) the river water system is primarily a make-up system to the pond and dam; 4) the removal of the river water system from the technical specification is in accordance with current NRC licensing practice; and 5) the pond and dam are tested and monitored to ensure continued compliance with original design criteria.

River Water System Technical Specification Deletion During normal operation, the river water system provides make-up to the emergency storage pond (pond and dam). The service water system supplies water from the pond and dam to the plant safety related equipment for ultimate discharge to the river.

Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 3 U. S. Nuclear Regulatory Commission In emergency conditions, the service water system recirculates water from the pond to the plant safety related equipment and back to the pond. The service water system does not discharge water to the river in this recirculation mode. Such recirculation during

. emergency conditions provides a 30-day supply of cooling water for the plant safety related equipment which is sufficient to bring

-both Units 1 and 2 to a safe shutdown condition. No make-up or other use of the river water system is necessary to provide this 30-day supply.

A detailed discussion with justification for deleting the river water system technical specification is presented in Attachment 1. An outline of the rationale is as follows:

1. The emergency cooling pond is the safety-grade ultimate heat sink for all postulated accident conditions. The river water system is not needed to meet any NRC design criteria as an ultimate heat sink.

2. The emergency cooling pond dam was designed and constructed in accordance with all applicable seismic Category I standards to assure seismic integrity.

3. The pond and dam are tested and monitored to ensure continued compliance with the original design criteria.

4. The NRC has licensed other nuclear power plants with similar emergency cooling ponds without requiring a safety-grade backup system for the ultimate heat sink.

5. The Farley Nuclear Plant site is in a low seismic activity region. Therefore, in the judgement of Alabama Power Company, a backup to the emergency cooling pond is no more important at Farley than at other licensed nuclear power plant sites that do not have a backup system.

6. The river water system will be maintained at a high level of availability in order to ensure reliable make-up of the pond (i.e., support normal plant operation).

7. Although the river water pumps are proposed to be deleted from-the technical specifications, if an emergency condition should arise requiring operation of the river water pumps, they will be capable of being manually loaded onto the diesel generators in accordance with operating procedures.

Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 4 U. S. Nuclear- Regulatory Commission

8. Dam failure; assessment was performed for failure due to external-and random events. It was determined that external events are negligible in comparison to the random f requency of dam failure. The random failure frequency was evaluated and determined to meet or exceed failure-criteria for other safety related plant equipment.

Based on the above and as further discussed in Attachment 1, the pond-and dam serves as the ultimate heat sink, and the river water system is not an essential component of the ultimate heat sink to achieve a safe shutdown under any accident or normal condition. Consequently, the deletion of the river water system technical specification does not challenge the safe shutdown capability of the Farley Nuclear Plant and represents an improvement in operation by minimizing the potential occurrences of Limiting Conditions for Operation. The detailed technical and safety evaluation of the proposed change is presented.in Attachment 1 and the proposed Technical Specification change is provided in Attachment 3.

Diesel Generator Technical Specification Change During the NRC review process of the proposed changes to the J. M. Farley Nuclear Plant Diesel Generator Technical Specifica-tions Section 3/4.8.1.1 submitted by Alabama Power Company letter dated October 28, 1981, the NRC Staff changed paragraph 4.8.1.1.2.c.5 to. require the diesel generator 24-hour load tests to be conducted at the 2000-hour rating vice the continuous rating.

The NRC Staff required this change because the estimated load on diesel generators 1-2A and 1C approaches the 2000-hour rating for FSAR Table 8.3-2 events 1, 2, 3 and 4 during two-unit operation.

The NRC Staff surveillance requirements were reviewed with the diesel generator manufacturer who agreed with the need for a 24-hour load test but recommended that the test be conducted at 60-90% of the continuous load rating. The manufacturer emphasized that the diesel generator will operate for at least 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> at the 2000-hour rating but reiterated that load tests at loads greater than the 60-90% load range do not contribute to either the dependability or longevity of the diesel generators. .Therefore, the 24-hour load test at the 2000-hour load rating exposes the diesel generators to an unnecessarily high loading without concomitant benefits.

The deletion of the river water system from the technical specifications will eliminate automatically sequencing accident loads on the diesel generators that exceed their continuous rating, which is the reason for the existing 24-hour' testing requirement involving operation at overload levels (i.e. , the 2000-hour

Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 5 U. S. Nuclear Regulatory Commission rating). This will also allow the operator to manually load the diesels with significant non-automatic loads and still operate near or below the continuous rating of the diesel generators.

Therefore, this proposed Technical Specification change negates the reason for the existing diesel generator 24-hour surveillance requirement at overload values.

The diesel generators at Farley Nuclear Plant have all received extensive reliability testing including overload testing.

It is the opinion of Alabama Power Company that this extensive reliability testing provides adequate confidence in diesel generator reliability.

Attachment 4 presents a summary of previous overload tests on all five diesel generators including factory performance testing, field pre-operational testing and inservice testing. As a minimum, all diesel generators have passed both factory overload testing and field overload testing at or above the 300-hour rating. All but diesel generator 1B have been exposed to at least one 24-hour endurance test. It should be noted that the four failures of auxiliary equipment af fecting diesel generator testing identified in Attachment 4 would have been detected by testing at any load rating and are not indicative of the load carrying capability of the diesel generators. Additional informaticn on continuous load testing has been included in Attachment 4 since such testing demonstrates overall load carrying capability of the diesel generators. As stated in August 3,1982 letter, the diesel manufacturer recommends load testing at the continuous rating to provide assurance of load carrying capability including overload testing. It should be noted that the diesel generators are currently tested at least bi-weekly for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the continous ra ti n g . Therefore, the previous bi-weekly tests at the continuous load rating provide added assurance of diesel generator operability such that the proposed technical specification change does not degrade confidence in diesel generator operability under any postulated emergency conditions.

A more representative test requirement, than is provided in the current Technical Specification, has been developed to satisfy issues about accident load conditions and long-term diesel generator reliability. The proposed technical specification change contains the following test requirements:

1. Represent the initial accident loading conditions by operating the diesel generators at their maximum calculated accident load conditions or the continuous load rating, whichever is greater, for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the 24-hour test and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at the continuous rating.

I Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 6 U. S. Nuclear Regulatory Commission

2. Following the 24-hour test, reduce load, trip the diesel generator and demonstrate hot restart capability within ten minutes.

The above proposed test procedure represents actual estimated load conditions and satisfies the manufacturer's recommendations for preventing excessive testing. The detailed technical and safety evaluation of the proposed test procedure is presented in Attachment 2 and the proposed Technical Specification change is provided in Attachment 3.

Conclusion In order to ensure reliable diesel generators in compliance with the recommendations of the manufacturer and as it is proposed to reduce the postulated maximum automatically sequenced loads to approximately the continuous rating, Alabama Power Company provides this proposed change to the Diesel Generator Technical Specification 4.8.1.1.2.c.5. This proposed change will assure diesel generator operability without excessive testing that could degrade long-term reliability. The proposed deletion of the River Water System Technical Specifications 3/4.7.5 and 3/4.7.6 precludes unnecessary Limiting Conditions for Operation and assures an ultimate heat sink to provide safe shutdown capability during any normal or accident condition.

In conclusion, the proposed changes to Technical Specifications 4.8.1.1.2.c.5., 3/4.7.5 and 3/4.7.6 have been made to provide the appropriate testing and surveillance requirements at Joseph M. Farley Nuclear Plant such that the highest assurance of safety is achieved. Alabama Power Company's Plant Operations Review Committee has reviewed these proposed changes to the Technical Specifications and has determined that the changes do not involve an unreviewed safety question as shown in the attached safety evaluation. The Nuclear Operations Review board is scheduled to review these changes at a future meeting.

Alabama Power Company requests approval of these proposed technical specification changes by July 1, 1983 to improve diesel generator reliability and longevity and to support the planning and scheduling of the diesel generator and river water system surveillance testing.

This proposed amendment is designated as Class III for Unit 1 and Class I for Unit 2 in accordance with 10CFR170.22 requirements. Enclosed is a check for $4,400.00 to cover the total amount of' fees required.

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Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 7 U. S. Nuclear Regulatory Commission In accordance with 10CFR50.30(c)(1)(i), three signed originals and forty-(40) additional copies of the proposed changes are enclosed.

Yours very truly, F. L. Clayton J r.

FLCJ r/BDM:mjh-D35 Attachments cc: Mr. R. A. Thomas SWORN TO AND SUBSCRIBED BEFORE ME Mr. G. F. Trowbridge THIS % 8 DAY OF D e- L 1982 Mr. J. P. O'Reilly Mr. E. A. Reeves /

Mr. W. H. Bradford M//IfIk Not'ary Public

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ATTACHMENT 1 SAFETY EVALUATION FARLEY NUCLEAR PLANT - UNITS 1 AND 2 RIVER WATER SYSTEM TECHNICAL SPECIFICATIONS DELETION

Background:

The river water system at the Joseph M. Farley Nuclear Plant (FNP) primarily serves as the make-up water system to the emergency cooling pond. The present plant technical specifications requires the river water system to be operable during plant operational modes 1 thru 4. Alabama Power Company proposes to remove the river water system from the plant technical specifications as justified by this safety evaluation.

Reference:

(1) Joseph M. Farley Units 1 and 2 Plant Technical Specifications 3/4.7.5, 3/4.7.6, B 3/4.7.5, and B 3/4.7.6.1 (2) Joseph M. Farley Nuclear Plant Final Safe ~ cy Analysis Report (3) Letter from Mr. F. L. Clayton, Jr. of Alabama Power Company to Mr.

S. A. Varga of the Nuclear Regulatory Commission, August 20, 1982 (4) letter from Mr. F. L. Clayton, Jr. of Alabama Power Company to Mr. S.

A. Varga of the Nuclear Regulatory Commission, August 3,1982 I. INTRODUCTION The purpose of this Safety Evaluation is to show that the removal of the river water system (RWS) from the Joseph M. Farley Nuclear Plant Technical Specifications is justified. This is accomplished by:

(a) a discussion of the safety implications of the river water system; (b) a discussion of the integrity of the FNP-Pond and Dam with a review of the standards and regulatory guides utilized in the design, construction, and operation of the FNP-Pond and Dam; (c) an evaluation of the probability of dam failure; and (d) a discussion of the licensing standards applied to the industry by the NRC.

ASSESSMENT II.A. River Water System The plant cooling water system at FNP (figure 1) provides cooling water for plant components during both normal and accident conditions. The cooling water system consists of a service water

1 I

Safety Evaluation Page 2 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion system for each unit and a comon river water system (RWS). The plant ultimate heat sink presently consists of the RWS, the emergency storage pond with dam (Pond 'and Dam), and a service water system for each unit. The ultimate heat sink is capable of delivering cooling water during all modes of plant operation to all equipment required to function under accident conditions. The safety-related portions of the plant cooling water system related to this change request are the service water system, the RWS and the Pond and Dam. In its present arranger 4ent, the RWS serves as a make-up water source to the Pond and Dam and also as a redundant, safety-related system to the Pond and Dam.

Since the RWS safety function is to serve as a backup system to the Pond and Dam, the plant safety aspects of the RWS become important as determined by the reliability of the Pond and Dam. In order to determine the significance of the RWS to plant safety, a safety assessment was performed. The result of the safety assessment is that for a design basis accident the impact on plant safety of the RWS is negligible. >

II.B. Pond and Dam The emergency storage pond with dam (Pond and Dam) are part of the plant ultimate heat sink. The Pond and Dam serve as a retention and settling reservoir for water pumped from the river prior to its use in the plant service water system. As such, the Pond and Dam is capable of providing sufficient cooling for at least 30 days when subject to maximum probable heat load with no make-up available (i.e., river water system) to permit simultaneous safe shutdown condition of both reactor units and maintain them in a safe shutdown condition during normal operation (worse case condition). In addition, during the event of an accident in one unit, the Pond and Dam is capable of providing sufficient cooling to permit safe control and cooldown of the accident and non-accident units and maintain them in a safe shutdown condition.

This safety assessment was performed in order to evaluate the integrity of the Pond and Dam and involved establishing a set of criteria by which the design, construction, and maintenance features of the FNP-Pond and Dam could be evaluated. The established criteria were:

(1) the establishment and implementation of a thorough quality assurance program during the construction phase, including:

field investigation prior to construction, and

l Safety Evaluation Page 3 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion lab testing and analysis of embankment. samples.

(2) the implementation of a continuing inspection and analysis program, including:

field measurement, and visual inspection.

(3) the extent to which the failure modes were addressed during design. The predominant failure modes are:

shear sliding, piping, overtopping, earthquake, and tornado.

The results of this assessment reaffirmed that the FNP Pond and Dam is a well designed, constructed, and maintained structure. In addition to being a sound structure it should be noted that the FNP-Pond and Dam is subject to the Alabama Power Company / Southern Company Services Dam Evaluation Program. This program utilizes the experience of Alabama Power Company and Southern Company Services personnel gained in the operation of dams to periodically inspect the Pond and Dam and to perform trend evaluation of the operating data recorded from the Pond and Dam. Thus, the detection of any abnormal trends which might develop during the operation of the Pond and Dam and which might compromise its integrity will be detected.

In concert with the aforementioned safety assessment of the integrity of the FNP-Pond and Dam, a second safety assessment was performed by Bechtel Power Corporation. This safety assessment was performed independent of the first assessment and involved a review of the geotechnical and seismic standards and procedures used in the design and construction of the FNP-Pond and Dam. The purpose of this review was to establish that the Pond and Dam was designed and constructed in accordance with all applicable government and industry standards. The conclusion of this review is that the accepted industry standards and procedures current at the time of design and construction were used and satisfied. In the case of the dynamic finite element analysis developed to check the stability and liquefaction potential of the dam and dike, state-of-the-art techniques were used. The NRC regulatory guide series that pertains to the design of the FNP-Pond and Dam and which were in existence at the time of the design, are referred to in the FNP-Final Safety Analysis

Safety Evaluation Page 4 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion Report (FSAR - Appendix 3A). It is important to note that the Farley Nuclear Plant, including the Pond and Dam, was reviewed and licensed in accordance with the NRC requirements. In summary, the storage pond, dam and dike were designed and constructed in accordance with NRC requirements as documented in the FNP - Final Safety Analysis Report.

II.C. Das Failure Assessment The Farley Nuclear Plant (FNP) has a 59 foot earth-fill dam and supporting dike that serves to enclose the 1570 acre-foot of water within the emergency cooling pond. In order to assess the integrity of the FNP-Dam, an analysis was performed to determine the frequency of dam failure.

The analysis of the dam failure frequency was broken-down into two classifications:

(a) failure due to external events, and (b) failure due to random events.

The failure causes due to external events encompasses tornados, floods and earthquakes. These were events evaluated in detail during the licensing process (with the supporting documentation to be found in the plant FSAR). The results of this external events analysis are as follows:

(a) The Farley Nuclear Plant is located in seismic risk zone 1 of the country. This equates to seismic activity of a low magnitude.

(b) The Farley Nuclear Plant, including Pond and Dam, is designed to withstand a seismic intensity VI (modified Mercalli scale) earthquake which is a larger intensity earthquake than is probable to ever occur at the site (the largest intensity earthquake to have occurred historically in the vicinity of the site is intensity V (modified Mercalli scale).

(c) The top of the pond's spillway is at the 186 ft. elevation (el.) and sized to handle the water flow produced by the probable maximum flood so as to maintain pond level at a maximum of 192.2 ft. el.

(d) The top of the FNP Dam is situated above the probable maximum flood elevation of the pond (192.2 ft. el.). The top of the dam is at 198.6 ft. el. which thereby protects the dam from failure due to overtopping.

Safety Evaluation Page 5 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion (e) The dam is protected by a downstream fill which extends 200 feet out from the toe. This fill is basically a spoil area and is not necessary for dam stability. The top of the' fill varies from 153 to 158 ft. el. ~

(f) The river that is adjacent to the plant is estimated to have a probable maximum flood level of 144.2 ft. el. Thus natural flooding or upstream dam failure would flow through the river and not produce severe forces on the dam.

(g) The dam is a category I structure and, as such, has been designed to withstand a 115 mph wind which has a recurrence interval estimated to be at least 100 years.

(h) Slope stability analysis of the dam was performed using state-of-the-art methodology. The stability analysis was performed using the modified-Bishop circular are method of slices. The resulting minimum factor of safety against liquefaction was computed to be 1.2 which was found to be acceptable to the NRC as shown in the FNP-Safety Evaluation Report. s Based on the results of the FSAR external events analysis described above, the external events portion of the dam failure frequency was qualitatively determined to be negligible in comparison to the random frequency of dam failure.

The analysis of the failure frequency due to random events was performed with dam failure defined to be uncontrolled release of the pond's content. The predominant modes of failure that were considered includes:

s piping, and structural failure of the foundation or_ abutments.

The methodology used to determine the dam failure frequency included development of a generic data base applicable to the FNP Dam and estimation of the failure frequency by a statistical Bpysian approach. The resulting estimated to be 1.9 x 10 pneric faflure failures frequency per year for-thedistribution is mean value of dam failure with a 95% confidence bound of 3.7 x 10-5, It should be noted that the four failures of ancillary equipment affecting diesel generator testing identified in Attachment 4 would-have been detected by testing at any load rating and are not indicative of the load carrying capability of the diesel generators.

Safety Evaluation Page 6 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion In addition to the above generic design features, the following FNP specific design features have been identified as relevant factors that tend to reduce the reported failure frequency:

Instrumentation and monitoring; regular inspection and maintenance program; onsite personnel; responsiveness of the owner to potential problems; detailed geologic investigations conducted prior to site selection; and, l

design techniques used.

These FNP specific design features enhance the generic dam design features and, in the opinion of Alabama Power Company, reduce the failure frequency to at least 1.9 x 10-7 failures per year.

II.D. Licensing l A review of the nuclear power plants in the United States which have

similar ultimate heat sinks to FNP (pond and dam) was performed.

This review was performed in order to establish how the make-up water sources for the ultimate heat sinks at other plants were treated in their technical specifications. This review included operating plants, NT0Ls and plants under construction. The results of this review revealed that no other nuclear power plant with a man-made ultimate heat sink had Technical Specifications on the make-up water sources to the ultimate heat sink except FNP. Thus the deletion of the RWS from the FNP Technical Specifications complies with existing NRC licensing practice.

III. Findings The purpose of this safety evaluation was to determine if removal of the RWS from the FNP Technical Specifications is justifiable. The above safety evaluation reveals:

(1) the RWS is a redundant water source to the service water system; (2) the RWS serves primarily as a make-up water source to the Pond and Dam;

Safety Evaluation Page 7 Farley Nuclear Plant - Units 1 and 2 River Water System Technical Specifications Deletion (3) the impact on plant safety of the RWS for design basis accidents is negligible; (4)_ the FNP-Pond and Dam is subject to a foresighted evaluation program to ensure the safe operation of the dam; (5) the FNP-Pond and Dam was designed and constructed and is operated in compliance with applicable industry and government standards to ensure its integrity and the safe operation of the plant; (6) the likelihood of dam failure due to an external event is negligible in comparison with random events; (7) the generic dam failure frequence was found to be 1.9 x 10-5 with a site-s to be 1.9 x 10-7; pecific and dam failure frequency estimated (8) the removal of the RWS fron FNP Technical Specifications complies with existing NRC licensing practice.

Attachment 3 includes the proposed change to the Farley Unit I and 2 Technical Specifications.

Conclusion:

The conclusion of the safety evaluation is that removal of the RWS from the FNP Technical Specifications:

(1) will not involve an unreviewed safety question; (2) will not degrade plant safety; and, (3) is justifiable.

It should be noted that regardless of the Technical Specification status of the River Water System, this system will be maintained at a high level of availability in order to ensure reliable makeup to the pond (support r.ormal plant operations).

The proposed changes to Techncial Specifications 3/4.7.5 and 3/4.7.6 do not involve an unreviewed safety question as defined by 10 CFR 50.59. These Technical Specification changes will not significantly affect the safe operation of Farley Nuclear Plant Units 1 and 2.

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ATTACHMENT 2 Safety Evaluation for Proposed Changes to the FNP-1 and 2 Technical Specifications Section 4.8.1.1.2.c.5 I. BACKGROUND During the NRC review process of the proposed changes to the J.

M. Farley Nuclear Plant Diesel Generator Technical Specifications Section 3/4.8.1.1 submitted by Alabama Power Company letter dated October 28, 1981, the NRC Staf f changed paragraph 4.8.1.1.2.c.5 to require the diesel generator 24-hour load tests to be conducted at the 2000-hour rating vice the continuous rating.

The NRC Staff required this change because the estimated load on diesel generator 1-2A and 1C approaches the 2000-hour rating for FSAR Table 8.3-2 events 1, 2, 3 and 4 for two-unit operation.

The NRC required change was reviewed with the diesel generator manufacturer who agreed with the need for a 24-hour load test but recommended that the test be conducted at 60-90% of the continuous load rating. The manufacturer emphasized that the diesel generator will operate for at least 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> at the 2000-hour rating but reiterated that load tests at loads greater than the 60-90% load range do not contribute to either the dependability or longevity of the diesel generators. Therefore, the 24-hour load test at the 2000-hour load rating exposes the diesel generators to an unnecessarily high loading without concomitant benefits.

It should be noted that the current FSAR Table 8.3-2 includes loading the river water pumps ento the FNP diesel generators during LOSP, LOCA and all safety injection conditions. Without these loads, the diesel generator maximum loads would be approximately equal to the continuous rating and thereby justifies the requested decrease in the 24-hour diesel generator testing requirements.

II. REFERENCE A. Technical Specification 4.8.1.1.2.c.5

.B. Alabama Power Company's letter to NRC (F. L. Clayton to S. A.

Varga dated August 3, 1982)

III. BASES Upon deletion of the river pumps from the FSAR described LOSP events, the diesel generator maximum loads would be approximately equal to the continuous rating. In addition, the service water dam has been proven capable of withstanding a seismic event as described in Attachment 1.

ATTACHMENT 2 Safety Evaluation Page 2 i

r N

As shown.in Table 1 the maximum loads, with the deletion of the river water pumps, applied to the FNP diesel generators is less than the continuous rating except for one event. In this event diesel generator 1C is loaded above continuous rating by only 46 KW. This change in diesel generator' loading, assuming the river water pump deletion is approved, complies with the vendor's

, position that testing at loads greater than 60-90% continuous i

rating do not contribute to either dependability or longevity of 4

the diesel generators and are believed by Alabama Power Company to be sufficient bases for which to change the 24-hour load test requirements.

An additional change involves clarification of the requirement to demonstrate hot restart capability. The current version of the -

test requirement states that the diesel generator must be tripped from the 2000-hour load condition and hot restart capability demonstrated within 10 minutes. The requirement to trip from the 2000-hour load condition implies that the diesel may not be manually unloaded before it is tripped. Since the diesel generator is loaded during the test by adjusting the frequency and voltage control circuits against the grid, tripping from such a condition could cause difficulties with hot restart due to the diesel generator controls being set for the 2000-hour test load ,

conditions. This is not the condition of a diesel generator

following a trip from accident equipment loads. Therefore, the proposed Technical Specification has been changed to accurately reflect actual accident conditions.

1 Based on the manufacturer's recommendations on load tests and the action outlined above for loss of Off-Site Power events, Alabama 4 Power Company believes that the proposed Technical Specification change is sufficient to demonstrate the dependability of the diesel generators.

Attachment 3 includes the proposed Unit 1 and 2 Technical Specification change for the maximum test load and the hot restart testing requirements.

IV. CONCLUSION i The proposed change to Technical Specification 4.8.1.1.2.c.5 does L not involve an unreviewed safety question as defined by

.10CFR50.59. This Technical-Specification change will not significantly affect the safe operation of Farley Nuclear Plant Units 1 and 2.

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TABLE 1 - FARLEY NUCLEAR PLANT MAXIMUM DIESEL GENERATOR (D.G.) LOADS Maximum Load FSAR Section 8.3 (Event No.)

Continuous 2000 Hour With River Without River D.G. Rating Rating Water Pomps Water Pumps 1-2A 4075 4353 4348 (1,4) 3885 (2,6)

IB 4075 4353 3974 (2,6) 3974 (2,6) 2B 4075 4353 3897 (3,7) 3897 (3,7)

Ic 2850 3100 3092 (1,2) 2896 (3) 2C 2850 3100 2523 (1,2,3) No Load r

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