ML14251A228

Supplemental Information Regarding Enhancements to Diesel Generator Surveillance Requirements License Amendment Request

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

Text

ExeLon Generation George Gellrich Site Vice President Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 410 495 5200 Office 717 497 3463 Mobile www.exeloncorp.com george.gellrich@exeloncorp.com September 3, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Supplemental Information Regarding Enhancements to Diesel Generator Surveillance Requirements License Amendment Request

References:

1. Letter from Mr. G. H. Gellrich (CCNPP) to Document Control Desk (NRC),

dated October 16, 2012, License Amendment Request re: Enhancements to Diesel Generator Surveillance Requirements

2. Letter from Ms. N. S. Morgan (NRC) to Mr. G. H. Gellrich (CCNPP), dated April 15, 2014, Request for Additional Information Regarding Enhancements to Diesel Generator Surveillance Requirements License Amendment (TAC No. ME9832 and ME9833)

In Reference 1, Calvert Cliffs Nuclear Power Plant, LLC submitted a license amendment request to revise Surveillance Requirements 3.8.1.8, 3.8.1.11, and 3.8.2.1, and add Surveillance Requirement 3.8.1.17 to Technical Specification 3.8.1, "AC Sources-Operating." In ongoing discussions with the NRC staff concerning this amendment request, it was determined that additional information was needed to complete the review. Attachment (1) and Enclosures provide the necessary supplemental information. To avoid confusion concerning the Technical Specification changes that are being requested, the Enclosures contain a complete set of Technical Specification marked up pages for this amendment request, as revised in Reference 2 and Attachment (1). Enclosures 1 and 2 supersede previously provided marked up Technical Specification and Technical Specification Bases pages.

This supplemental information does not change the No Significant Hazards Determination provided in Reference 1. No regulatory commitments are contained in this letter.

frOO'\

A.

Document Control Desk September 3, 2014 Page 2 Should 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 on September 3, 2014.

Respectfully, George H. Gellrich Site Vice President Exelon Generation Company, LLC GHG/PSF/bjd

Attachment:

(1) Supplemental Information Regarding Enhancements to Diesel Generator Surveillance Requirements

Enclosures:

1 Marked Up Technical Specification Pages 2 Marked Up Technical Specification Bases Pages cc: CCNPP Project Manager, NRC CCNPP Resident Inspector, NRC Region 1 Administrator, NRC S. Gray, DNR

ATTACHMENT (1)

SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TO DIESEL GENERATOR SURVEILLANCE REQUIREMENTS Calvert Cliffs Nuclear Power Plant September 3, 2014

ATTACHMENT (1)

SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TO DIESEL GENERATOR SURVEILLANCE REQUIREMENTS Please note that to avoid confusion concerning the Technical Specification (TS) changes that are being requested, the Enclosures contain a complete set of Technical Specification marked up 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 and Technical Specification Bases pages.

Original Submittal - SR 3.8.1.8 No changes are proposed to this Surveillance Requirement (SR) change submitted in Reference 1. The marked up pages are enclosed for completeness only.

Original Submittal - SR 3.8.1.11 The initial license amendment request (Reference 1) contained a change to Surveillance Requirement (SR) 3.8.1.11 that proposed twenty four (24) hour testing as recommended in Regulatory Guide 1.9, Revision 4. Additionally, the initial change removed the power factor requirements from the SR. Following discussions with the NRC staff, including responding to a request for additional information concerning this proposed change (Reference 2), an alternative change has been developed.

Exelon Generation (Exelon) is proposing that the existing SR 3.8.1.11 be split into two separate SRs, one that demonstrates the ability of the diesel generator (DG) to operate at appropriate accident load power factors and a separate SR to demonstrate the ability of the DG to operate for 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 a frequency of _>58.8 Hz and _<61.2 Hz, while maintaining an appropriate accident load power factor for four hours. This SR provides verification that the DG can be operated at a load greater than predicted accident loads for at least four hours once per 24 months. Operation at the greater than calculated accident loads clearly demonstrates the ability of the DG to perform its safety function. In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a DG load greater than or equal to calculated accident load and using a power factor chosen based on the calculated highest kW value of DG loads during the postulated design basis accidents. Enclosure 2 contains 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 can start 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 />. The proposed SR 3.8.1.17 would require that the DG start and run continuously at full load capability for 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 a lower loading in the remaining portion of the continuous run. The proposed loading and timing of the test have are the same as discussed in Reference 2. A note is added to the proposed SR to allow momentary transients outside the load and power factor limits without invalidating the test. The supporting TS Bases markup is contained in Enclosure 2.

Original Submittal - SR 3.8.2.1 This SR provides the surveillance requirements for an Operable DG in Modes 5, 6 and during movement of irradiated fuel assemblies. It currently includes a Note that states that certain SRs are not required to be performed in the course of meeting SR 3.8.2.1. The current SR 3.8.2.1 1

ATTACHMENT (1)

SUPPLEMENTAL INFORMATION REGARDING ENHANCEMENTS TO DIESEL GENERATOR SURVEILLANCE REQUIREMENTS includes SR 3.8.1.11 in the Note. The proposed change to SR 3.8.1.11 (above) does not change the purpose of the SR, it only proposes to change the required test time for the affected DG. Therefore, no change to SR 3.8.2.1 is proposed related to the inclusion of SR 3.8.1.11 in the Note. A new SR is proposed to be added, SR 3.8.1.17. This SR performs the other portion of the original SR 3.8.1.11;.therefore, it is proposed to be included in the Note to SR 3.8.2.1, just like SR 3,8.1.11.

Original Submittal - SR 3.8.1.17 Reference 1 requested the addition of a new SR, SR 3.8.1.17 to demonstrate the operation of the DGs during a loss of the offsite power source. Exelon hereby withdraws that change from consideration. In development of Reference 1, it was initially determined that SR 3.8.1.17 was needed to adequately test the shutdown sequencer being added to SR 3.8.1.8. After additional review and consideration, it has been determined that the existing process of testing the shutdown sequencer currently in use meets the requirements of SR 3.8.1.8 and no additional SR is needed. Further considerations are that the existing SR 3.8.1.15 provides a more rigorous test of the DG capabilities, since it starts the DG based on an undervoltage signal and loads it with accident loads. The loads actuated by the shutdown sequencer are less than or equal to the loads actuated by the emergency sequencer, therefore, the SR that requires the emergency sequencer loading is more conservative for DG operation than one that only requires shutdown sequencer loading.

References

1. Letter from Mr. G. H. Gellrich (CCNPPF) to Document Control Desk (NRC), dated October 16, 2012, License Amendment Request re: Enhancements to Diesel Generator Surveillance Requirements

2. 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 Diesel Generator License Amendment Request 2

ENCLOSURE 1 MARKED UP TECHNICAL SPECIFICATION PAGES Calvert Cliffs Nuclear Power Plant September 3, 2014

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.8 Verify interval between each sequenced load block is within + 10% of design interval for

~ oad seuen~cer. 2ZL/ lyl ~'S SR 3.8.1.9 ------------------- NOTE----------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition 184 days and achieves, in

• 10 seconds, voltage

> 4060 V and frequency > 58.8 Hz, and after steady state conditions are reached, maintains voltage Ž 4060 V and

• 4400 V and frequency of > 58.8 Hz and

• 61.2 Hz.

SR 3.8.1.10 Verify manual transfer of AC power sources 24 months from the normal offsite circuit to the alternate offsite circuit.

CALVERT CLIFFS - UNIT 1 3.8.1-13 Amendment No. 302 CALVERT CLIFFS - UNIT 2 Amendment No. 279

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 --------------

NOTE---------------

1. Momentary transients outside the load and power factor limits do not invalidate this test.

2. If performed with the DG synchronized with offsite power, the surveillance test shall be performed at the required power factor. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition, the power factor shall be maintained as close to the limit as practicable.

Verify each DG, operating at a lpower factor 24 months 2Boperates for tfhi'I loaded to Ž 4000 kW for DG 1A and Ž 3000 kW for DGs 1B, 2A, and 2B.

SR 3.8.1.12 Verify each DG rejects a load Ž 500 hp 24 months without tripping.

- PFC'e~jUeAC'-4 >A 0SS.C (01-Z Lzcr~1 0-, 0x%

CALVERT CLIFFS - UNIT 1 3.8.1-14 Amendment No. 302 CALVERT CLIFFS - UNIT 2 Amendment No. 279

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.16 For the LCO 3.8.1.c AC electrical sources, In accordance SR 3.8.1.1, SR 3.8.1.2, SR 3.8.1.3, with applicable SR 3.8.1.5, SR 3.8.1.6, and SR 3.8.1.7 are Surveillance required to be performed. Requirements CALVERT CLIFFS - UNIT 1 3.8.1-17 Amendment No. 302 CALVERT CLIFFS - UNIT 2 Amendment No. 279

AC Sources-Operating fJQA.L SR 3 - -I 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8 1 1 - - - - - - - - - O E-----...............

• .Momentarytasents outside the load and

/"powe atrlmts do not invalidate this Verify each DG operates for Ž!24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: 24 months aa. For 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 to 4200 kW for DG 1A, and __3150 kW and

_ 3300 kW for DGs lB, 2A, and 2B, and

b. For the remaining hours of test loaded to Ž!3600 kW for DG 1A, and Ž! 2700 kW and *5 3000 kW for OGs lB, 2A, and 2B.

CALVERT CLIFFS - UNIT 1 3.8.1- Amendment No. XXX CALVERT CLIFFS - UNIT 2 Amendment No. XXX

AC Sources-Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE F FREQUENCY SR 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 3.8.1.14t For the LCO 3.8.2.a and LCO 3.8.2.b AC In accordance sources required to be OPERABLE, the SRs of with applicable Specification 3.8.1, "AC Sources-Operating," SRs 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, are applicable.

SR 3.8.2.2 For the LCO 3.8.2.c and LCO 3.8.2.d AC In accordance sources required to be OPERABLE, the SRs with applicable required by SR 3.8.1.16, are applicable. SRs CALVERT CLIFFS - UNIT 1 3.8.2-4 Amendment No. 279 CALVERT CLIFFS - UNIT 2 Amendment No. 256

ENCLOSURE 2 MARKED UP TECHNICAL SPECIFICATION BASES PAGES Calvert Cliffs Nuclear Power Plant September 3, 2014

AC Sources-Operating B 3.8.1 BASES support continuous operation of standby power sources. This SR provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

The Frequency for this SR is 31 days. The 31-day Frequency corresponds to the design of the fuel transfer system. The design of fuel transfer systems is such that pumps will operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day tanks during or following DG testing. In such a case, a 31-day Frequency is appropriate.

SR 3.8.1.8 Under accident and loss of offsite power conditions loads are sequentially connected to the bus by the automatic load 4eseuencer (this SR verifies steps 1 through 5. The

- - sequencing 1ogic controls the permissive and closing signals to breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time S4kp~s interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying 3 4the next load, and that safety analysis assumptions S~wo.,0,Lo (..AocA regarding ESF equipment time delays are not violated. The UFSAR provides a summary of qn,**x the automatic loading of ESF gbuses.

The Freguecy of iis consivstent withD SR 3.8.1.9 )o'kt, v Coiz)a 4

See SR 3.8. .Co(\-c4x.*

./ c,"utquu'd Vý0 ,~r SR 3.8.1.10 *A Transfer of each 4.16 kV ESF bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. The 24 month Frequency of the Surveillance is based on B 3.8.1-26 Revision 48 CALVERT -

UNITS 1 CLIFFS - UNITS CALVERT CLIFFS & 2 1 & 2 B 3.8.1-26 Revision 48

AC Sources-Operating B 3.8.1 BASES engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.8.1.11 This SR provides verification that the DG can be operated at a load greater than predicted accident loads for at least ronce per 24 months. Operation at the greater than calculated accident loads will clearly demonstrate the ability of the DGs to perform their safety function. In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a DG load greater than or equal to calculated accident load and using a power factor

• 0.84 for No. 1A DG and

• 0.83 for Nos. 1B, 2A, and 2B DGs.

These power factors are chosen based on the calculated highest kW value of DG loads during the postulated design basis accidents.

In addition, the post-accident load for No. 1A DG is significantly lower than the continuous rating of No. 1A DG.

To ensure No. 1A DG performance is not degraded, routine monitoring of engine parameters should be performed during the performance of this SR for No. IA DG (Reference 9).

This SR is modified by two Notes, Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit will not invalidate the test.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as practicable.

When synchronized with offsite power, testing should be performed at a power factor of

• 0.84 for No. 1A DG and

< 0.83 for Nos. 1B, 2A, and 2B DGs. These power factors are representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor other than 5 0.84 for No.

CALVERT CLIFFS - UNITS 1 & 2 B 3.8. 1-27 Revision 48

AC.Sources-Operating B 3.8.1 BASES This SR is modified by a Note. The reason for the Note is to minimize mechanical wear and stress on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs.

SR 3.8.1.16 This 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, and 3.8.1.7). Performance of any SR for the LCO 3.8.1.c will satisfy 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'd cuvl :S R 3. I -11 3.8.1.15,#are not required to be performed for the LCO 3.8.1.c. Surveillance Requirement 3.8.1.10 is not required because this SR verifies manual transfer of AC power sources from the normal offsite circuit to the alternate offsite circuit, but only one qualified offsite circuit is necessary for the LCO 3.8.1.c. Surveillance Requirements 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 interval between sequenced loads. Surveillance Requirement 3.8.1.14 verifies the proper sequencing with offsite power.

Surveillance Requirement 3.8.1.9 verifies that the DG starts within 10 seconds. These SRs are not required because they do not support the function of the LCO 3.8.1.c to provide power to the CREVS and CRETS. Surveillance Requirements 3.8.1.13 and 3.8.1.15 are not required to be performed because these SRs verify the emergency loads are actuated on an ESFAS signal for the Unit in which the test is being performed. The LCO 3.8.1.c DG will not start on an ESFAS signal for this Unit.

REFERENCES 1. 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants"

2. UFSAR CALVERT CLIFFS - UNITS 1 & 2 B 3.8.,1-31 Revision 48

Insert SR 3.8.1.17 Reference 12 requires demonstration that the DGs can start 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 />, > 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 to 105-110% of the continuous service rating and the remainder of the time at a load equivalent to 90-100% of the continuous service rating. For the Nos. 1 B, 2A, and 2B DGs the SR reflects these loading ranges. For the No. 1A DG, since the post accident loading is significantly less than the continuous service rating, the post accident loading (<4000 kW) is used instead of the continuous service rating. Actual testing is performed at a load higher than the post accident loading.

The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions 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 may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

In addition, the post-accident load for No. 1A DG is significantly lower than the continuous rating of No. 1A DG. To ensure No. 1A DG performance is not degraded, routine monitoring of engine parameters 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 into consideration unit conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit will not invalidate the test.

AC Sources-Operating B 3.8.1 BASES

3. Regulatory Guide 1.9, Revision 3, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants," July 1993

4. Safety Guide 9, Revision 0, March 1971

5. NRC Safety Evaluation for Amendment Nos. 19 and 5 for Calvert Cliffs Nuclear Power Plant Unit Nos. 1 and 2, dated January 14, 1977

6. Regulatory Guide 1.93, Revision 0, "Availability of Electric Power Sources," December 1974

7. Generic Letter 84-15, Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability, July 2, 1984

8. Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators," October 1979

9. Letter from Mr. D. G. McDonald, Jr. (NRC) to Mr. C. H. Cruse (BGE), dated April 2, 1996, Issuance of Amendments 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 for Class 1E Power Systems for Nuclear Power Generating Stations"

' . NO-I-I1 Integrted Risk ManagementZ, CALVERT CLIFFS - UNITS 1 & 2 B 3.8. 1-32 Revision 48