ML14251A228

Calvert Cliffs, Units 1 and 2 - Supplemental Information Regarding Enhancements to Diesel Generator Surveillance Requirements License Amendment Request

ML14251A228
Person / Time
Site:	Calvert Cliffs
Issue date:	09/03/2014
From:	Gellrich G H Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9832, TAC ME9833
Download: ML14251A228 (17)

Text

George GellrichExeLon Generation Site Vice PresidentCalvert Cliffs Nuclear Power Plant1650 Calvert Cliffs ParkwayLusby, MD 20657410 495 5200 Office717 497 3463 Mobilewww.exeloncorp.comgeorge.gellrich@exeloncorp.comSeptember 3, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2Renewed Facility Operating License Nos. DPR-53 and DPR-69NRC Docket Nos. 50-317 and 50-318Subject: Supplemental Information Regarding Enhancements to Diesel GeneratorSurveillance Requirements License Amendment RequestReferences: 1. Letter from Mr. G. H. Gellrich (CCNPP) to Document Control Desk (NRC),dated October 16, 2012, License Amendment Request re: Enhancements toDiesel Generator Surveillance Requirements2. Letter from Ms. N. S. Morgan (NRC) to Mr. G. H. Gellrich (CCNPP), datedApril 15, 2014, Request for Additional Information Regarding Enhancementsto Diesel Generator Surveillance Requirements License Amendment (TACNo. ME9832 and ME9833)In Reference 1, Calvert Cliffs Nuclear Power Plant, LLC submitted a license amendmentrequest to revise Surveillance Requirements 3.8.1.8, 3.8.1.11, and 3.8.2.1, and addSurveillance Requirement 3.8.1.17 to Technical Specification 3.8.1, "AC Sources-Operating." Inongoing discussions with the NRC staff concerning this amendment request, it was determinedthat additional information was needed to complete the review. Attachment (1) and Enclosuresprovide the necessary supplemental information. To avoid confusion concerning the TechnicalSpecification changes that are being requested, the Enclosures contain a complete set ofTechnical Specification marked up pages for this amendment request, as revised inReference 2 and Attachment (1). Enclosures 1 and 2 supersede previously provided marked upTechnical Specification and Technical Specification Bases pages.This supplemental information does not change the No Significant Hazards Determinationprovided in Reference 1. No regulatory commitments are contained in this letter.frOO'\

A.Document Control DeskSeptember 3, 2014Page 2Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver,Director-Licensing, at (410) 495-5219.I declare under penalty of perjury that the foregoing is true and correct. Executed onSeptember 3, 2014.Respectfully,George H. GellrichSite Vice PresidentExelon Generation Company, LLCGHG/PSF/bjdAttachment:(1) Supplemental Information Regarding Enhancements to Diesel GeneratorSurveillance RequirementsEnclosures: 1 Marked Up Technical Specification Pages2 Marked Up Technical Specification Bases Pagescc: CCNPP Project Manager, NRCRegion 1 Administrator, NRCCCNPP Resident Inspector, NRCS. Gray, DNR ATTACHMENT (1)SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TODIESEL GENERATOR SURVEILLANCE REQUIREMENTSCalvert Cliffs Nuclear Power PlantSeptember 3, 2014 ATTACHMENT (1)SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TO DIESELGENERATOR SURVEILLANCE REQUIREMENTSPlease note that to avoid confusion concerning the Technical Specification (TS) changes thatare being requested, the Enclosures contain a complete set of Technical Specification markedup pages for this amendment request, as discussed below and as revised in Reference 2.Enclosures 1 and 2 supersede previously provided marked up Technical Specification andTechnical Specification Bases pages.Original Submittal -SR 3.8.1.8No changes are proposed to this Surveillance Requirement (SR) change submitted inReference 1. The marked up pages are enclosed for completeness only.Original Submittal -SR 3.8.1.11The initial license amendment request (Reference 1) contained a change to SurveillanceRequirement (SR) 3.8.1.11 that proposed twenty four (24) hour testing as recommended inRegulatory Guide 1.9, Revision 4. Additionally, the initial change removed the power factorrequirements from the SR. Following discussions with the NRC staff, including responding to arequest for additional information concerning this proposed change (Reference 2), an alternativechange has been developed.Exelon Generation (Exelon) is proposing that the existing SR 3.8.1.11 be split into two separateSRs, one that demonstrates the ability of the diesel generator (DG) to operate at appropriateaccident load power factors and a separate SR to demonstrate the ability of the DG to operatefor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.As shown in Enclosure 1, the proposed SR 3.8.1.11 would require that the DG operate at afrequency of _> 58.8 Hz and _< 61.2 Hz, while maintaining an appropriate accident load powerfactor for four hours. This SR provides verification that the DG can be operated at a loadgreater than predicted accident loads for at least four hours once per 24 months. Operation atthe greater than calculated accident loads clearly demonstrates the ability of the DG to performits safety function. In order to ensure that the DG is tested under load conditions that are asclose to design conditions as possible, testing must be performed using a DG load greater thanor equal to calculated accident load and using a power factor chosen based on the calculatedhighest kW value of DG loads during the postulated design basis accidents. Enclosure 2contains a markup of the appropriate TS Bases to reflect the proposed TS.Exelon also proposes a new SR 3.8.1.17 (see Enclosure 1) to demonstrate that the DG canstart and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Theproposed SR 3.8.1.17 would require that the DG start and run continuously at full load capabilityfor not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with a higher loading in the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the continuous run and alower loading in the remaining portion of the continuous run. The proposed loading and timingof the test have are the same as discussed in Reference 2. A note is added to the proposed SRto allow momentary transients outside the load and power factor limits without invalidating thetest. The supporting TS Bases markup is contained in Enclosure 2.Original Submittal -SR 3.8.2.1This SR provides the surveillance requirements for an Operable DG in Modes 5, 6 and duringmovement of irradiated fuel assemblies. It currently includes a Note that states that certain SRsare not required to be performed in the course of meeting SR 3.8.2.1. The current SR 3.8.2.11 ATTACHMENT (1)SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TO DIESELGENERATOR SURVEILLANCE REQUIREMENTSincludes SR 3.8.1.11 in the Note. The proposed change to SR 3.8.1.11 (above) does notchange the purpose of the SR, it only proposes to change the required test time for the affectedDG. Therefore, no change to SR 3.8.2.1 is proposed related to the inclusion of SR 3.8.1.11 inthe Note. A new SR is proposed to be added, SR 3.8.1.17. This SR performs the other portionof the original SR 3.8.1.11;.therefore, it is proposed to be included in the Note to SR 3.8.2.1, justlike SR 3,8.1.11.Original Submittal -SR 3.8.1.17Reference 1 requested the addition of a new SR, SR 3.8.1.17 to demonstrate the operation ofthe DGs during a loss of the offsite power source. Exelon hereby withdraws that change fromconsideration. In development of Reference 1, it was initially determined that SR 3.8.1.17 wasneeded to adequately test the shutdown sequencer being added to SR 3.8.1.8. After additionalreview and consideration, it has been determined that the existing process of testing theshutdown sequencer currently in use meets the requirements of SR 3.8.1.8 and no additionalSR is needed. Further considerations are that the existing SR 3.8.1.15 provides a morerigorous test of the DG capabilities, since it starts the DG based on an undervoltage signal andloads it with accident loads. The loads actuated by the shutdown sequencer are less than orequal to the loads actuated by the emergency sequencer, therefore, the SR that requires theemergency sequencer loading is more conservative for DG operation than one that onlyrequires shutdown sequencer loading.References1. Letter from Mr. G. H. Gellrich (CCNPPF) to Document Control Desk (NRC), datedOctober 16, 2012, License Amendment Request re: Enhancements to Diesel GeneratorSurveillance Requirements2. Letter from Mr. G. H. Gellrich (Exelon) to Document Control Desk (NRC), dated May 30,2014, Response to Request for Additional Information Regarding Enhancements to DieselGenerator License Amendment Request2 ENCLOSURE 1MARKED UP TECHNICAL SPECIFICATIONPAGESCalvert Cliffs Nuclear Power PlantSeptember 3, 2014 AC Sources-Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.8 Verify interval between each sequenced loadblock is within + 10% of design interval for~ oad seuen~cer. 2ZL/ lyl ~'SSR 3.8.1.9 -------------------NOTE----------------All DG starts may be preceded by an engineprelube period.Verify each DG starts from standby condition 184 daysand achieves, in 10 seconds, voltage> 4060 V and frequency > 58.8 Hz, and aftersteady state conditions are reached,maintains voltage 4060 V and 4400 V andfrequency of > 58.8 Hz and 61.2 Hz.SR 3.8.1.10 Verify manual transfer of AC power sources 24 monthsfrom the normal offsite circuit to thealternate offsite circuit.CALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 23.8.1-13Amendment No. 302Amendment No. 279 AC Sources-Operating3.8.1SURVEILLANCEREQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.11--------------NOTE---------------1. Momentary transients outside the loadand power factor limits do notinvalidate this test.2. If performed with the DG synchronizedwith offsite power, the surveillancetest shall be performed at the requiredpower factor. However, if gridconditions do not permit, the powerfactor limit is not required to be met.Under this condition, the power factorshall be maintained as close to thelimit as practicable.Verify each DG, operating at a lpower factor2Boperates for tfhi'Iloaded to 4000 kW for DG 1A and 3000 kWfor DGs 1B, 2A, and 2B.SR 3.8.1.12 Verify each DG rejects a load 500 hpwithout tripping.24 months24 months-PFC'e~jUeAC'-4 >A 0SS.C Lzcr~1 (01-Z 0-, 0x%CALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 23.8.1-14Amendment No. 302Amendment No. 279 AC Sources-Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.16 For the LCO 3.8.1.c AC electrical sources, In accordanceSR 3.8.1.1, SR 3.8.1.2, SR 3.8.1.3, with applicableSR 3.8.1.5, SR 3.8.1.6, and SR 3.8.1.7 are Surveillancerequired to be performed. RequirementsCALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 23.8.1-17Amendment No. 302Amendment No. 279 fJQA.L SR 3 --I -1-AC Sources-Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8 1 1 ---------O E-- ---...............outside the load and/"powe atrlmts do not invalidate thisVerify each DG operates for ! 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:a. For a 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test loaded to4200 kW for DG 1A, and __ 3150 kW and_ 3300 kW for DGs lB, 2A, and 2B, andb. For the remaining hours of test loadedto ! 3600 kW for DG 1A, and ! 2700 kWand 5 3000 kW for OGs lB, 2A, and 2B.24 monthsCALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 23.8.1-Amendment No. XXXAmendment No. XXX AC Sources-Shutdown3.8.2SURVEILLANCE REQUIREMENTSSURVEILLANCE F FREQUENCYSR 3.8.2.1--------------------NOTE----------------The following Surveillance Requirements(SRs) are not required to be performed:SR 3.8.1.11, SR 3.8.1.12, a SR 3.8.1.14tFor the LCO 3.8.2.a and LCO 3.8.2.b ACsources required to be OPERABLE, the SRs ofSpecification 3.8.1, "AC Sources-Operating,"except SR 3.8.1.4, SR 3.8.1.8, SR 3.8.1.10,SR 3.8.1.13, 3.8.1.15, and SR 3.8.1.16, areapplicable.In accordancewith applicableSRsSR 3.8.2.2 For the LCO 3.8.2.c and LCO 3.8.2.d AC In accordancesources required to be OPERABLE, the SRs with applicablerequired by SR 3.8.1.16, are applicable. SRsCALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 23.8.2-4Amendment No. 279Amendment No. 256 ENCLOSURE 2MARKED UP TECHNICAL SPECIFICATION BASES PAGESCalvert Cliffs Nuclear Power PlantSeptember 3, 2014 AC Sources-OperatingB 3.8.1BASESsupport continuous operation of standby power sources. ThisSR provides assurance that the fuel oil transfer pump isOPERABLE, the fuel oil piping system is intact, the fueldelivery piping is not obstructed, and the controls andcontrol systems for automatic fuel transfer systems areOPERABLE.The Frequency for this SR is 31 days. The 31-day Frequencycorresponds to the design of the fuel transfer system. Thedesign of fuel transfer systems is such that pumps willoperate automatically or must be started manually in orderto maintain an adequate volume of fuel oil in the day tanksduring or following DG testing. In such a case, a 31-dayFrequency is appropriate.SR 3.8.1.8Under accident and loss of offsite power conditions loadsare sequentially connected to the bus by the automatic load4ese uencer (this SR verifies steps 1 through 5. The--sequencing 1ogic controls the permissive and closing signalsto breakers to prevent overloading of the DGs due to highmotor starting currents. The 10% load sequence timeS4kp~s interval tolerance ensures that sufficient time exists forthe DG to restore frequency and voltage prior to applying3 4the next load, and that safety analysis assumptionsS~wo.,0,Lo (..AocA regarding ESF equipment time delays are not violated. TheUFSAR provides a summary of the automatic loading of ESFgbuses. The Freguecy of iis consivstent withDSR 3.8.1.9 )o'kt, v Coiz)aCo(\-c4x.* c,"utquu'd 4Vý0 ,~rSee SR 3.8. ../SR 3.8.1.10 *ATransfer of each 4.16 kV ESF bus power supply from thenormal offsite circuit to the alternate offsite circuitdemonstrates the OPERABILITY of the alternate circuitdistribution network to power the shutdown loads. The24 month Frequency of the Surveillance is based onCALVERT CLIFFS -UNITS 1 & 2 B 3.8.1-26 Revision 48CALVERT CLIFFS -UNITS 1 & 2B 3.8.1-26Revision 48 AC Sources-OperatingB 3.8.1BASESengineering judgment, taking into consideration the unitconditions required to perform the Surveillance, and isintended to be consistent with expected fuel cycle lengths.Operating experience has shown that these components usuallypass the SR when performed at the 24 month Frequency.Therefore, the Frequency was concluded to be acceptable froma reliability standpoint.SR 3.8.1.11This SR provides verification that the DG can be operated ata load greater than predicted accident loads for at leastronce per 24 months. Operation at the greaterthan calculated accident loads will clearly demonstrate theability of the DGs to perform their safety function. Inorder to ensure that the DG is tested under load conditionsthat are as close to design conditions as possible, testingmust be performed using a DG load greater than or equal tocalculated accident load and using a power factor 0.84for No. 1A DG and 0.83 for Nos. 1B, 2A, and 2B DGs.These power factors are chosen based on the calculatedhighest kW value of DG loads during the postulated designbasis accidents.In addition, the post-accident load for No. 1A DG issignificantly lower than the continuous rating of No. 1A DG.To ensure No. 1A DG performance is not degraded, routinemonitoring of engine parameters should be performed duringthe performance of this SR for No. IA DG (Reference 9).This SR is modified by two Notes, Note 1 states thatmomentary transients due to changing bus loads do notinvalidate this test. Similarly, momentary power factortransients above the limit will not invalidate the test.Note 2 ensures that the DG is tested under load conditionsthat are as close to design basis conditions as practicable.When synchronized with offsite power, testing should beperformed at a power factor of 0.84 for No. 1A DG and< 0.83 for Nos. 1B, 2A, and 2B DGs. These power factorsare representative of the actual inductive loading a DGwould see under design basis accident conditions. Undercertain conditions, however, Note 2 allows the surveillanceto be conducted at a power factor other than 5 0.84 for No.CALVERT CLIFFS -UNITS 1 & 2B 3.8. 1-27Revision 48 AC.Sources-OperatingB 3.8.1BASESThis SR is modified by a Note. The reason for the Note isto minimize mechanical wear and stress on the DGs duringtesting. For the purpose of this testing, the DGs must bestarted from standby conditions, that is, with the enginecoolant and oil continuously circulated and temperaturemaintained consistent with manufacturer recommendations forDGs.SR 3.8.1.16This SR lists the SRs that are applicable to the LCO 3.8.1.c(SRs 3.8.1.1, 3.8.1.2, 3.8.1.3, 3.8.1.5, 3.8.1.6, and3.8.1.7). Performance of any SR for the LCO 3.8.1.c willsatisfy both Unit 1 and Unit 2 requirements for those SRs.Surveillance Requirements 3.8.1.4, 3.8.1.8, 3.8.1.9,3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.14, c'dcuvl :S R 3. I -11 3.8.1.15,#are not required to be performed for theLCO 3.8.1.c. Surveillance Requirement 3.8.1.10 is notrequired because this SR verifies manual transfer of ACpower sources from the normal offsite circuit to thealternate offsite circuit, but only one qualified offsitecircuit is necessary for the LCO 3.8.1.c. SurveillanceRequirements 3.8.1.4, 3.8.1.11, &a4 3.1.8.12 are not-required because they are tests t at ea with loads.Surveillance Requirement 3.8.1.8 verifies the intervalbetween sequenced loads. Surveillance Requirement 3.8.1.14verifies the proper sequencing with offsite power.Surveillance Requirement 3.8.1.9 verifies that the DG startswithin 10 seconds. These SRs are not required because theydo not support the function of the LCO 3.8.1.c to providepower to the CREVS and CRETS. Surveillance Requirements3.8.1.13 and 3.8.1.15 are not required to be performedbecause these SRs verify the emergency loads are actuated onan ESFAS signal for the Unit in which the test is beingperformed. The LCO 3.8.1.c DG will not start on an ESFASsignal for this Unit.REFERENCES 1. 10 CFR Part 50, Appendix A, "General Design Criteriafor Nuclear Power Plants"2. UFSARCALVERT CLIFFS -UNITS 1 & 2B 3.8.,1-31Revision 48 Insert SR 3.8.1.17Reference 12 requires demonstration that the DGs can start and run continuously at full loadcapability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, > 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to105-110% of the continuous service rating and the remainder of the time at a load equivalent to90-100% of the continuous service rating. For the Nos. 1 B, 2A, and 2B DGs the SR reflectsthese loading ranges. For the No. 1A DG, since the post accident loading is significantly lessthan the continuous service rating, the post accident loading (<4000 kW) is used instead of thecontinuous service rating. Actual testing is performed at a load higher than the post accidentloading.The DG starts for this Surveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.3 and for gradual loading,discussed in SR 3.8.1.4 are applicable to this SR.The load band is provided to avoid routine overloading of the DG. Routine overloading mayresult in more frequent teardown inspections in accordance with vendor recommendations inorder to maintain DG OPERABILITY.In addition, the post-accident load for No. 1A DG is significantly lower than the continuous ratingof No. 1A DG. To ensure No. 1A DG performance is not degraded, routine monitoring of engineparameters should be performed during the performance of this SR for No. 1A DG(Reference 9).The 24 month frequency is consistent with the recommendations of Reference 12, takes intoconsideration unit conditions required to perform the Surveillance; and is intended to beconsistent with expected fuel cycle lengths.This SR is modified by a Note. Note 1 states that momentary transients due to changing busloads do not invalidate this test. Similarly, momentary power factor transients above the limit willnot invalidate the test.

AC Sources-OperatingB 3.8.1BASES3. Regulatory Guide 1.9, Revision 3, "Selection, Design,Qualification, and Testing of Emergency DieselGenerator Units Used as Class 1E Onsite Electric PowerSystems at Nuclear Power Plants," July 19934. Safety Guide 9, Revision 0, March 19715. NRC Safety Evaluation for Amendment Nos. 19 and 5 forCalvert Cliffs Nuclear Power Plant Unit Nos. 1 and 2,dated January 14, 19776. Regulatory Guide 1.93, Revision 0, "Availability ofElectric Power Sources," December 19747. Generic Letter 84-15, Proposed Staff Actions to Improveand Maintain Diesel Generator Reliability, July 2, 19848. Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systemsfor Standby Diesel Generators," October 19799. Letter from Mr. D. G. McDonald, Jr. (NRC) toMr. C. H. Cruse (BGE), dated April 2, 1996, Issuance ofAmendments for Calvert Cliffs Nuclear Power Plant,Unit 1 (TAC No. M94030) and Unit 2 (TAC No. M94031)10. IEEE Standard 308-1991, "IEEE Standard Criteria forClass 1E Power Systems for Nuclear Power GeneratingStations"' .NO-I-I1 Integrted Risk ManagementZ,CALVERT CLIFFS -UNITS 1 & 2B 3.8. 1-32Revision 48