ML20236S082

Supplemental Application for Amend to License DPR-54, Consisting of Suppl 2 to Rev 2 to Proposed Amend 147, Concerning Diesel Generators

ML20236S082
Person / Time
Site:	Rancho Seco
Issue date:	11/17/1987
From:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML20236S084	List: ML20236S082 ML20236S088
References
AGM-NPP-87-379, TAC-63030, NUDOCS 8711240209
Download: ML20236S082 (9)

Text

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(gSMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT D P. O, Box 16830 Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA y-NOV 17 1987 -

AGM/NPP 87-379 O. S. Nuclear Regulatory Commission

'. Attn: Frank J. Miraglia, Jr.

- Associate Director for Projects Philips Bldg.

7920 Norfolk Avenue Bethesda, MD 20014 DOCKET 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54 PROPOSED AMENDMENT 147, REVISION 2, SUPPLEMENT 2

Dear Mr. Miraglia:

Based ond' iscussions between the District and NRC, the District supplements

' the April 1,1987 submittal of Proposed Amendment 147 Revision 2 and the September 22, 1987 submittal of Proposed Amendment 147, Revision 2, Supplement 1.

Attachment 1 is the District's response to NRC questions and comments on Proposed Amendment 147. Attachment 2 is the revised Proposed Amendment 147 pages which incorporate the changes agreed to in the discussions between the District and NRC.

The Safety Analysis and no significant hazards consideration in the District's April 1,1987 submittal of Proposed Amendment 147 Revision 2 are not changed or affected by this supplement.

P f 0

i RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

.. AGM/NPP 87-379 Frank J. Miraglia, Jr. NOV 171987 Please cor, tact me if you have any questions. Members of your staff with questions: requiring additional information or clarification may contact Mr. Robert Roehler at (209) 333-2935,' extension 4918.

Sincerely, y ose F. Fir 11t Assistant General Manager, '

Nuclear Power Production.

Sworn' to and subscribed before me this ' / day of November 1987.

/4/1 ld W U N4)lary Putnic' omunL BEAL l

1. M ". f IUDY E. LUNA r

-Attachments .

m;^g;gtg;gt;ga g cc: G. Kalman, NRC, Bethesda

^ ~ ~ ~ ~ ~ ~ 'j u, c- ny ., u, u mi A..D'Angelo, NRC, Rancho Seco 1

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ATTACHMENT 1 L  : DISTRICT RESPONSE TO NRC QUESTIONS AND COMMENTS ON PROPOSED AMENDMENT 147 L1 l1. "NRCls'taff withdrew question 1.

District Response: .N/A

2. ,3.7.2. A'1, 3.7.2.B.1_and 3.7.2.E.1 require demonstration of diesel t generator operability within 24. hours. Need to make it clear that this is onlyj required if. a diesel . generator has not been tested within 24 i hours to eliminate excessive. diesel generator starts. '

District: Response: . Statement added to only require testing if a diesel

-generator.has not been tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

- 3. '3.7i2.B.2,' 3.7.2.E.1; and 3.7.2.E.2 have no LC0 if diesel generators go

,, .'into preplanned preventive maintenance or testing.

, i District Response:' Statement for preplanned preventive maintenance and testing moved to Action b. in 3.7.2.B.2 and 3.7.2.E.1 and deleted statement from 3.7.2.E.2. Non-0PERABLE

' diesel generator LC0 is now applicable during preplanned preventive maintenance and testing.

4. -Provide justification for running diesel generators with no load and how long.no load run is acceptable.

District Resp'onse: Although operation of the diesel at low loads is not recommended for long durations, the District maintains that occasional, short term operation of the Rancho Seco EMD diesel engines (GEA and GEB) is not detrimental to the availability of emergency power. SRP Section 8.3.1.f indicates that EMD diesel engines should be provided with a heavy duty turbocharger mechanical gear drive assembly to assure optimum-availability after running the engines at no-load or light load for extended periods. The District has installed this assembly on its EMD diesels. These improvements, per discussion with the manufacturer, are the only effective modifications known to improve no-load operation. Past experience has shown that the EMD diesel engines have run for at  ;

least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with no-load or light load and then 1 accepted a load of 1500 kw and run for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at that load. Furthermore, the number of times that these diesels shall have to be started to satisfy Technical Specification Section 3.7.2 should be 1 minimal .

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i s [. , ! 4. LDistrict. Response: (Cont.)-

,y The design of the District's TDI (GEA2 and GEB2)

, diesels is fundamentally different from the EMD

o. diesels in several ways. Because of these

, differences, the TDI engines'are suitable for prolonged operation in no-load or light-load

' conditions. In fact, this' engine design' has

, undergone a special no-load endurance test for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> followed by the successful. application of a 57%

step' load.' Based on the above considerations, the L.l '

proposed Technical. Specifications should not 4: - >

adversely affect the operation and availability of

- the. District's EMD and TDI emergency diesel g

generators.

L5. _ : Justify two offsite sources or redefine offsite power sources in 3.7.2.A.1.

District Response: This specification has been revised to conform with Standard Technical Specifications and Generic Letter 84-15, 3.7.1. A has been revised and 3.7.1.C, 3.7.2.F m"

and 3.7.2.G have been deleted based on this change.

The District has combined the specification for the offsite lines and startup transformers because the

, , existing Technical Specifications are not consistent for this equipment and do not reflect the existing e plant design. The existing specifications allow all offsite. lines to be inoperable with no time limit, but allowed' unlimited operation with only one startup transformer inoperable while requiring the plant to shutdown if two startup transformers were inoperable. Based on the inconsistency for offsite power in the existing-Technical Specification, the

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District has revised the specifications per the guidance in Standard Technical Specifications, Generic Letter 84-15, and Regulatory Guide 1.93. The District considers this change to be appropriate  ;

because the redundant AC power system remains available. The offsite sources are historically very reliable and any degradation is generally easier to detect'and restore than the onsite AC power sources.

, 6. 3.7.2.B.2.b is not consistent with 3.7.2.E LCO for two diesel generator inoperability.

District Response: 3.7.2.B.2.b revised to refer to applicable two diesel

^ generator inoperable specification.

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- = = _ -

7. 3.7.2.B.2.a,' 3.7.2 E.1.a and 3.7.2.E.2.a are not consistent with 3.7.2.C

LCO for one offsite circuit inoperability.

' District Response: 3.7.2.B.2.a, 3.7.2.E.1.a and 3.7.2.E.2 have been revised to refer to applicable offsite circuit inoperable specification.

8. 3.7.2.B.3.C could have a diesel generator inoperable for 12 days.-

District Response: 3.7.2.B.3 deleted.

9. Justify 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LC0 in 3.7.2.B.3.b.

District Response: 3.7.2.B.3 deleted. This diesel generator combination has been moved to 3.7.2.E.2.

10. 3.7.2.B.2.b does not require diesel generators to be tested if not tested before LCO is terminated.

District Response: Added note to require testing to be completed.  ;

11. 3.7.2.B.2.b and 3.7.2.E.1.b requires testing once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No additional tests required for 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO. Testing once each additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for 7 day LCO.

. District Response: 3.7.2.B.2.b and 3.7.2.E.1.b revised.

12. In 3.7.2.E.1 use of "/" is confusing. Also should use "or" instead of Conina.

District Response: "or" added and "/" replaced with "and".

13. -3.7.2.C last paragraph is not clear as to when 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LC0 applies.

District Response: Statement added to clarify LC0 starts with initial condition.

14. 3.7.2.E.2, needs justification for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO.

District Response: The time was determined based on the guidance of Reg l Guide l.93. Two hours is judged to be the time required to complete the initial problem confirmation and coordinate the onsite shutdown activities for an orderly plant shutdown. This allows the offsite power dispatchers to take expedited actions to lessen the severity of the loss of this source to the grid.

This time and the associated actions avoids the potential risks of an immediate shutdown yet severely limits the plant's exposure time to this degraded condition. This also provides sufficient time to identify problems, ensure they will not effect shutdown and to deal with them if they are a minor problem, thus avoiding unnecessary plant shutdown.

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l 15.- 3.7.2.E.2 does not require surveillance for offsite circuits or remaining diesel generators.

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. District Response: Requirement added to survey the offsite lines.

This action does not require the remaining diesels to be tested since.two trains are considered to be out of service and the exposure of the remaining diesels to the increased starts and some possible common mode failure will not confirm that one good onsite source is available. The LC0 is only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, which is not sufficient time to test the remaining diesels. If {

one diesel is returned to OPERABLE then the ACTION of 3.7.2.B.2 would be required. ,

16. 3.7.2.E.2.b is:168 hour LC0 correct.

District Response: "168" deleted.

17. 3.7.2.E.2.b GEA/GEB is listed in this action item. Where are the other diesel ger.erator pairs listed?

District Response: GEA/GEB2, GEB/GEA2, and GEA2/GEB2 added to 3.7.2.E.2.b. ,

18.- 3.7.2.E.1 Action, does comma between GEA/GEA2, GEB/GEB2 mean "or"?

District Response: "or" added in place of comma.

19, 3.7.2.F, justify 205 hours0.00237 days <br />0.0569 hours <br />3.38955e-4 weeks <br />7.80025e-5 months <br />.

District Response: 3.7.2.F deleted, 205 hours0.00237 days <br />0.0569 hours <br />3.38955e-4 weeks <br />7.80025e-5 months <br /> deleted.

20. 3.7.2.F.a, no Action statement.

District Response: 3.7.2.F deleted.

21. 3.7.2.F this Tech Spec should be the same as loss of 2 lines.

District Response: . 3.7.2.F deleted. This specification has been revised to conform with Standard Technical Specifications and Generic Letter 84-15. 3.7.1. A has been revised and 3.7.1.C, 3.7.2.F and 3.7.2.G have been deleted based on this change.

22. 3.7.2.G, justify 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> LCO. l I

District Response: 3.7.2.G deleted. See Item 5. I l

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i 4l 23.- 3.7.2.G, why is this' different than loss of all lines?

District . Response: 3.7.2.G deleted. This specification has been revised

" to conform with Standard Technical Specifications and

Generic Letter 84-15. 3.7.1.A has been revised and 3.7.1.C, 3.7.2.F and 3.7.2.G have been deleted based on this change.

24, 3.7.2.H, existing Tech Specs say to verify other bus and equipment is operable,. justify. removing from Tech Specs.

District Response: Added statement from existing Technical l Specifications.

25.' .3.7.2.H.b, justify 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO.

District Response: 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO deleted.

- 26. 3.7.2.I, justify 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO.

District Response: ~2 hour LC0 ' deleted.

27. 3.7.2.J.C, ~ justify 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO.

District Response: 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO deleted.

28. 3.7.2.K.1, justify 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO.

District Response: The LC0 is consistent with the LC0 for Batteries and Battery Chargers.

29. 3.7.2.K.2, justify 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> LCO.

District Response: This specification has been deleted.

30. Tables 3.7-2 and 4.1-1, terminology is not consistent with table 3.7-1.

District Response: Table 4.1-1 revised to correctly identify specific relays.

31, 4.6.3. A, Note 1 allows fast starts to exceed 10 seconds except for every 184 days.

District Response: Note amended to require 10 second time whenever a fast start is performed.

32. Why aren't air start receivers in Tech Specs?

District Response: Pressure is constantly monitored with a low pressure alarm in the Control Room. Therefore a Technical Specification surveillance is not required to ensure t1e air start receiver is operable. NRC withdrew this comment.

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33. 4.6.3.A.S. Why isn't loading time included in this specification?

District Response: A.90 second loading time has been added. The District understands that Generic Letter 84-15 only requires this timed loading to be performed every 184 days. All other monthly testing will allow slow loading as recommended by the manufacturer to minimize mechanical stress and wear.

34 Item C.3 page 4-35c, Note 1 does not apply, Note 3 does.

District Response: Note 1 changed to Note 3.

35. Item 2 page.4-35c, why is Note 4 referenced?

District Response: Note 4 deleted.

36. . Note 6 page 4-35c, Note 6 is not necessary.

District Response: Note 6 deleted.

37. Why isn't 4.8.1.1.2.d.2 of Generic Letter 84-15 included?

District Response: This specification has been added.

38. Why isn't 4.8.1.1.2.d.3 of Generic Letter 84-15 included?

District Response: -This specification has been added.

39. Why isn't 4.8.1.1.2.d.8 of Generic Letter 84-15 included?

District' Response: This specification has been added.

40. NRC withdrew this comment.

41. .Why isn't the last sentence 4.8.1.1.2.d 7 of Generic Letter 84-15 included? I l

District Response: This specification has been added.

42. Why isn't 4.8.1.1.2.d.6.C of Generic Letter 84-15 included? ,

District Response: This specification has been added.

43. 4.6.3.E.2, this should be done every refueling. Remaining Section 4.6.3.E should be deleted.

District Response: 4.6.3.E.2 moved to Section 4.6.3.C. Remainder of

, 4.6.3 E deleted.

44. Page 4-35d, 4.8.1.1.2, item D is missing a sentence.

District Response: Item D corrected.

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'45. AddL"are in service".to 3.7.1.A.

' District Response:".Added "are:in service" to 3.7.1.A.

46.' _Where is the requirement to drain and clean the diesel generator' fuel tanks?

District Response: -The District commits to' drain and clean each fuel oil storage--tank for the _ diesel generators at least once

. per.10 years effective the date of this letter.

i OTHER CHANGES TO PROPOSED AMENDMENT 147:

.l The bases for Specification 3.7_ states that "The 35,000 gallons of fuel stored in _each storage tank permit operation of the diesel generators A and B for seven days.". Based on recent testing, the 7 day fuel consump' ion for diesel regenerators A and B cou l d exceed 35,000 gallons. Therefore, the District has

,: increased the' fuel storage requirement to 37,000 gallons. This changes 3.7.1.E.2,and the bases for 3.7. The fuel storage tanks for diesel generators

. A and'B each have a capacity of 50,000 gallons.

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