ML20147F121

Forwards Recommendations Re Changes to RG 1.108 & Changes to the Standard Tech Specs on Diesel Testing

ML20147F121
Person / Time
Issue date:	12/08/1978
From:	Tondi D Office of Nuclear Reactor Regulation
To:	Hintze A NRC OFFICE OF STANDARDS DEVELOPMENT
References
RTR-REGGD-01.108, RTR-REGGD-1.108 NUDOCS 7812210335
Download: ML20147F121 (4)

Text

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f j  % UNITED STATES 3* k NUCLEAR REGULATORY COMMisslON E Ill)Ip)f }

WASHINGTON, D. C. 20555

.j / December 8, 1978 MEMORANDUM FOR: Al Hintze, Reactor Systems Standards Branch, Office of Standards Development THRU: G. Lainas, Chief, Plant Systems Branch, g Division of Operating Reactors FROM: D. Tondi, Section Leader, Plant Systems Branch, Division of Operating Reactors

SUBJECT:

RECOMMENDED CHANGES TO R. G.1.108 As a result of a staff meeting to review a Florida Power and Light proposed Technical Specification change for the Turkey Point nuclear plant, some suggested changes for R. G. 1.108 have been prepared.

These are given below. Also, as a result of the same meeting a set of recomended changes to the Standard Technical Specification on diesel testing was prepared. These are in my note to Don Brinkman which is attached for your information.

The proposed changes for R. G. 1.108 are as follows:

1. Section C.2.a (1) and (2) - These two positions should be combined to recomend startup by; (1) Simulating loss of offsite power alone.

(2) Simulating an ESF actuation signal alone.

(3) (1) and (2) simultaneously, and for each startup where loss of offsite power is included that emergency busses are de-energized and loads are shed, and for each startup the unit can start automatically and attain the required voltage and frequency within acceptable limits and time and then energize permanently connected loads, energize auto-connected loads and operate for > 5 minutes. One of these tests where an ESF actuation signal is used should verify bypass of diesel trips which are supposed to be bypassed when the ESF signal is received. One of these tests should include verification that diesel generator lockout features are operable only when required, l

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y See STS Sections 4.8.1.1.2c.4.5&7 and my attached comments on these parts of the STS.

Reasons: More clearly delineate starting means and recommend testing each. Clearly tie recommenddtesting of load shed and sequencing features. Loads should be required to be energized for a nominal time (suggest 5 minutes) to assure voltage and frequency have stab 11 zed.

2. Note that Section 4.8.1.1.2c.8 of STS requires the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> test at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating be run at the beginning of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test as opposed to R. G. 1.108, Position C.2.a (3) which doesn't sty when the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> test should be run. Since running the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> test first is current Regulatory practice, Regulatory

> Guide 1.108 should be revised accordingly. Alternatively, this could be included in the next revision of R. G.1.9.

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3. Position C.2.a (4) should be divided into two items, one for rejection of the largest load and another for full load rejection.

For rejection of the largest load, checks should be made of voltage and frequency as in STS 4.8.1.1.2.c.2. For rejection of total load, check should be made of capability to not overspeed (see STS 4.8.1.1.2.c.3) and voltage (see attached i comments on STS).

! Reason : Frequency usually has tighter limits and is important where loads remain energized in the test where only the largest load is rejected. Voltage and overspeed are appropriate to full load rejection.

, 4. Position C.2.a (5) should be modified by changing the word

imediately" to "within 5 minutes."

Reason: I&E has informed us that "imediately" is not enforceable uniformly. 5 minutes is current regulatory practice.

5. Position C.2.a (8) should be revised to more explicitly refer to the override of the test mode by a safety ir.jection signal.

i Suggest use of the wording from S1S Section 4.8.1.1.2.c.11.

6. Position C.2.b should require 4 separate tests using:

Manual start, Simulated loss of offsite power only, Simulated loss of offsite power and ESF actuation test signal and, (4) ESF actuation test signal only.

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c During one of these tests proper simultaneous operation of all load sequences should be verified.

Reason: Confirm that modifications haven't degraded independence of ar:y starting means or sequencers. Note I've recomended the name change to STS Section 4.8.1.1.2.d.

7. The provisions of STS Section 4.8.1.1.2.c.6 should be added to R. G. 1.108. It says:

"6. Verifying that on a simulated loss of the diesel generator (with offsite power not available) the loads are shed from the emergency busses and tnat subsequent loading of the diesel generator is in accordance with design requirements."

This is an 18 month test in STS.

Reason: Assure that this feature is operable.

8. The provisions of STS Section 4.8.1.1.2.c.9 should be added to R. G. 1.108. It says:

"9. Verifying that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of kw."

This is an 18 month test.

Reason: Assure loads have not been inadvertently added which would exceed the diesel rating.

9. Position C.2.c (1) of R. G.1.108 should be amended by recom-mending explicitly that the various auto-start and the manual start features are confirmed operable. Sequential testing of each of these features would be acceptable. See my recomended change to STS Section 4.8.1.1.2.a.4 for details and reasons.

In addition, this position (C.2.c.(1) ) should recommend verification that:

(1) at the end of the test the diesel generator is aligned to i provide standby power to the associated emergency busses, and; (2) The automatic load sequence timer is operable with the interval between each load block within 10% of its design

interval.

Reason: Verify these features consistent with current Regulatory Practice as in STS Section 4.8.1.1.2.a.6&7.

Should you have any questions on this matter, please contact E. C. Wenzinger on 492-8077.

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D. Tondi, Section Leader Plant Systems Branch Division of Operating Reactors

Enclosure:

As stated cc w/ enclosure:

V. Stello D. Eisenhut G. Lainas F. Rosa R. Fitzpatrick G. Knighton D. Brinkman G. Arlotto W. Morrison D. Sullivan D. Tondi S. Rhow M. Chiramal E. Wenzinger

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