ML20099E164

Application to Amend Licenses DPR-57 & NPF-5,in Response to Generic Ltr 84-15, Proposed Staff Actions to Improve & Maintain Diesel Generator Reliability. Amend Revises Tech Specs Re Limiting Conditions for Operation.Fee Paid

ML20099E164
Person / Time
Site:	Hatch
Issue date:	11/07/1984
From:	Conway R GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20099E167	List: ML20099E164 ML20099E184
References
GL-84-15, NED-84-085, NED-84-85, TAC-55865, TAC-558655, TAC-55866, TAC-56522, TAC-56523, NUDOCS 8411210140
Download: ML20099E164 (14)

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" ;:Gootgd Power Company _-.

- 333 Pedmcnt Avenue '

t Ahanta Georg:a 30308 ^ -

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<'r l PotioHce Bot 4545 A!!arna Georgo 30302

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p ;jR. E. Conway

, Senior vice Prescent NED-84-085 h 2 -

November 7, 1984 E

. Director of Naclear Reactor IW p at l on i

Attention: Mr.; Jbbn F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing ~

U. S. Maclear Reg.41atory Oommission -

' Nashington, D. C. 220555 NRC DOGETS 50-321, 50-366 OPERATING LICDBES DPR-57, NPF-5 EDWIN 'I. HA701 NUCIEAR MANT LNI'IS 1, -2 RESIONSE TO NRC GENERIC IRITFR 84-15/ REQUEST TO AME20 DIESEL GENERATOR 1EOMICAL SPECIFICATIONS Gentlemen Georgia Power @npany (GPC) has completed a review of NRC Generic Intter-84-15, " Proposed Staff Actions to Inprove and Maintain Diesel ' Generator Reliability". Enclosure 1 of this letter and its attachmento form GPC's response. Included as part of our response and in accordance with the provisions of- 10 'CER 50.90, as realired by 10 CER 50.59(c) (1), GPC' bereby subnits a' reglest to amend diesel generator Technical Specifications 'for Plant Hatch Units 1 and 2. The proposed changes '(Attachnent 1) would revise the 'mchnical Specifications associated with the Limiting conditions for Operation, surveillance Regiirements, and bases for diesel generator operability. GPC and' the diesel merufacturer (Colt Indastries) have determined that some of the current Technical Specification airveillance regiirements are not beneficial to the reliable performance of the onsite emergency. power system. The proposed c.hanges to the 'mchnical Specifications provide improvements ' which we believe will enhance the reliability of the diesel generators. We have - previcusly addressed cur concern in our-letter dated Jaruary 9,1984 which was prepared as a response to - your letter (Generic Letter 83-41) dated December 16, 1983, regarding

' fast cold starts of diesel generators.

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GeorgiaPowerk o ,

Director of Maclear Reactor Regalation

' Attentions 'Mr. Jbhn F. Stolz, Chief Operating Reactors Branch No.-4 November 7,:1984 Page 'Dso The proposed changes have' been reviewed and approved by the Plant Review Board and the' Safety Review Board and have been determined not to constitute

' an unreviewed safety gaestion.

The= probability of ocairrence or the consegnances of an accident or malAnnction of egaipsant important to safety wtmald not be increased above those ' analysed in the PSAR harmee the operation of safety-related egnigment 'is not affected by the proposed changes. - The possibility of an accident or malainction of a different type than any analyzed in the- PSAR would not remalt from these changes bacalma no

. new mode of failure is introdLiced. - As stated above, the proposed changes to the Technical Specifications provide improvements ' which enhance D/G reliability, thus the margin of ' safety < would not be reduced by these proposed changes. Also, the proposed changes have been evaluated and determined not to-involve significant hazards considerations. Enclosed is a complete - safety evaluation as reg 11 red by ' OR . 50.59 (Attachment 2), and a' significant hazards review as reglired by 10 GR 50.92 (Attachment 3).

R1ralant to 10 OR 170.21 a check for the amendment application of

$150.00 is enclosed.

R1ratant to the reglirements of 10 OR 50.92, J. L.. Imdbetter of the Georgia' Department of Natural Resources will be sent a copy of this letter and all applicable attachments.

R. E. (bnway states that he is Senior Vice President of Gecrgia Power Company and is althorized to exealte this oath on behalf of Georgia Power (bapany, and that to the best of his knowledge and belief the facts set forth in this letter are true.

GDRGIA ICHER COMPA!N By: ' b

, R. E.

1 and albecribed before um this 7th day of November,1984.

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/' l - g g Notary Riblic e .e i m w CTAb _g,ca.ia s.,a, uyains Ehclosure xc: H. C. Nix, Jr.

Eenior Resident Inspector

, .J. P. O'Reilly, (IEC-Region II)

J. L. Ischetter

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Enclomare 1 r l

Information Romested to Address Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability (Generic Intter 84-15) 4 l I e k

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Mtam 1 - Rekction' in Masbar of Cold Fast Start &arveillance i hets for Diesel Generators 1his item is directed towards re& cing the mober of cold fast. start

, marveillance tests for diesel generators whid . the staff has . determined results' in premature - diesel engine degradation. %e details relating to this subject are provided in mclosure 1 of Generic Intter 84-15. Licensees are reenested to describe' their current . programs to avoid cold fast start surveillance testing or their ' intended actions to .re&ce cold fast start marveillance testing for diesel generators.

Osorgia Power -has long been concerned with the. reliability of the diesel generators at' Plant Hatch. . his is demonstrated by Georgia Power's initiation of a Diesel Generator Reliability Study, 'in the latter part of 1980, to determine the '. reliability of the diesels and provide reccomended actions for owing ' diesel reliability. %e results of _ this study,-

published in ary of 1982, showoci that the availability of the Plant Hatch diesels was better than the national average. However, Georgia Power was still concerned with the mober of diesel failures and in the fall of 1982 L formed a Diesel Generator Task Force to resolve . diesel generator problems with respect to testing reesirements, replatory concerns and

• failure re&ction.

%e Diesel Generator Task Mrce members include design, licensing and site engineers as well as representatives from colt In& stries, the diesel's memfacturer. h Task Force has currently developed fifty-six action items of which only ten remain open. Although the Task Force did not use NWEG-0660, "mhancement of On-site anergency Diesel Generator Reliability",

as' a pide, many of the action items developed were .. recommendations of NWEG-0660 (see discussion in response to item 3). %e action items include proce&ral, lesign and technical specification changes. Several of these action items are directly related to the re&ction in the mober of cold fast starts.

In the fall of 1982 tte Task Force implementated two proce&ral changes.

De first proce&ral change incorporated a four mimte prelubrication time preceding all engine startc except actual or simulated emergency starts.

nis change will re&ce the number of cold fast starts on the diesel s generators. We second change revised loading and unloading - proce&res, which includes loading the diesels in incremental steps in accordance with the anmfacturer's reconwendations. %is proce&ral change will decrease the m ober of cold fast starts.

As discussed in Georgia Power letter dated January 9,1984 on fast cold starts of diesel generators, a lube oil keep warm / circulation system was installed on diesels 2A and 2C and the swing diesel IB tring the recent Page 1 3 9 vm tw A v '

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• r (mit 2 oreAmeling' cutage. A' lube. oil keep wataVcirculation ' system is schechsled to be -. installed on the Unit 1 diesels charing . the = current 1984

outage. . Thei installation of . this . system J was rarv=== ruled by - the diesel

, . memfacturer. : Se lube oili system will'aatomatically provide prelubrication -

o upon normal and emergency startup, while the keep wara/ciroslation system

~~will provide better lubrication by contimously circulating warm oil through

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' > the header. _ De addition of this ' system should . significantly enhance the-

-overall' performance and reliability of the diesel generators.

-In addition to thei prococharal' and design' changes already discussed, ' the Diesel Generator Task- 1%rce has been , developing : proposed technical specification changes to eliminate the excessive . testing reunirements.- Se-proposed changes should rectice the msber of ' cold fast starts, : improie diesel performance and increase - overall reliability of the diesel generators. Sese proposed Unit 1 'and Unit 2 Technical Specifications are being anbeitted as part of this response and are included as Attachment 1.

Se proposed Unit 1 Technical Specifications include eliminating diesel generator testing when 'certain emergency core cooling systens -(i.e., core-spray and low presaire coolant injection) and essential service water systems (i.e., plant service water and IUR service water) are declared

-inoperable, as reccamended in Generic Intter 84-15.

Several other proposed diesel generator technical specifications for both units will help eliminate excessive testing- and increase. diesel reliability. It is proposed that the test schedLile be revised so that routine testing is done only in faarteen or seven day. intervals and that these intervals be determined by the mnber of failures per diesel . ratter than per melear unit basis. It is proposed that the testing reesirements, when an onsite AC ~ saarce(s) and/or offsite power souroe(s) is declared

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inoperable, be revised to allow more . time for testing and loading' the diesels. Finally it is proposed to recisce the frecuency of the~ atusite tests, which recuire five successive starts of the diesels to verify tre capability of the air start receivers, and that the overload test be revised to reatire the overload operation to occur in the last two hours of the twenty-four hour test. All of these technical specification changes are being proposed per the diesel marufacturer's recensendations and are compatible with the reconmendations contained in Generic Intter 84-15.

Item 2 - Diesel Generator Reliability Data 21s item reezests licensees to furnish the current reliability of each diesel generator at their plant (s), based on surveillance test data.

Licensees are rentested to provide the information recuested in Encionare 2 of Omneric Intter 84-15. .

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Response:-

%e. reliability of the ' diesel generators at Hatch Nuclear . Plant' has been .

determined- in accordance with 'Regalatory Gaide 1.108 position C.2.e and is-L provided below.' Table 1 provides the maber of failures -in tre last 20 and ~

100 . valid demands through Aagust 1984 and ' the ' associated . reliability ' for-each diesel. Table 2 lists the time history -(failure date) for .the > three

- diesel 2C failures. _:a,

.in developing this response to Generic Ietter 84-15 'tre Diesel. Generator F.eliability Study, psblished in February .of 1982, was updated. %e data from this original study went from startup for both units to mid-1981. In' comparing the resalts of ' the original. study to the data collected face the

. last three years trere is a 'significant inprovement in diesel reliability, with four diesels having 'no failures in the last- 456 tests. %e only exception- is diesel 2C whose reliability has remained about the same. %is -

might be attrituted to the fact that diesel 2C has been tested over twicef as nuch as any other diesel-in the same time, period. With the incorporation of-the proposed technical specifications provided in Attactment. 1, this excessive testing will be redaced. . In addition, the_ design and procedaral

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changes _ developed by the Diesel Generator Task Force, as .disatssed in - the responne to Item 1'above, shaald increase the reliability .of tie aiesels.

Regarding the casestion conceraing records, Georgia Power does maintain a log '

of diesel generator trials and failures for each diesel. Tests which are valid according to Regulatory G11de -1.108 position'. C.2.e are entered.

Failures are indicated and a brief description 'is entered indicating tre .

casse of the failure. %is log does not include all tre provisions ~ of ,

Regalatory Gaide 1.108 position C.3.a.~ However Georgia Power feels that the  ;

information given in the. log and in' the procediral data steets are adecniate for determining diesel reliability.

A yearly data report is currently not maintained for the diesel generators. ,

However the proposed technical specifications for both units, provided in Attachment 1 to this response, recnires that an anmal report be mitaitted to the IRC in lieu of the reportable ocmtrences reca11rement -(Unit' 2  :

'mchnical Specification 4.8.1.1.3) . ' 'Ite anmal report would provide the NRC -

with the mmber of valid tests and the mmber of failures to start on demand

• and would provide a monitor on diesel reliability.

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h 9 5 Item 3 - Diesel Generator Reliablity , ' _

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- - Licensees 'are recanested: to_ describe their; progrant, fif any, for . attaining and

msintaining a reliability goalffor their Mamal generators. An example of f a -

) performance TechnicalE Specification 1 to mapport a" desired diesel-. generator .

n - reliability goal;has .been provided byhthe staff in Enclomare ;3. of Generic

.Istter 84-15. Licensees are recanested J tof comment ' on, andc compare their-

existing program . 'or any ; p- . - a ; program with the example - performance

- ~ specification.,

- Response:; .

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Georgia ^[ Power has'-several ongoing' activities ~ designed to improvei and-maintain f diesel generator reliability. , - In ithe ' fall : of 1982. the Diesel' Oenerator Task Mrce began implementing the fifty-six action ' items referred to in the response to Item 1 above. Although NUREG-0660, . "Enharamont- of On-site Snergency Diesel Generator Reliability", was not used as a guideiin developing the action items, the Task lBorce action items address many of the-recommendationsv of NUREG-0660. - Table- 3Dprovides a manmary : of :which

-recommendations were addressed and how they were _ implemented. Also, a list .

of Task ' Force action . items not . reconmended by NUREG-0660 but- whichS are

-significant.. to Georgia _ Power's program for improving diesel reliability 'is

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provided in Table 4.

'Ite major Task l Force ~ action - item involved revising - the Hatch Technical Specifications; 'Ite. revised technical specifications proposed changes to the marseillance and, testing performed to demonstrate' diesel generator reliability per ~ the diese1~. mamfacturer's recommendations.- 'Ite proposed technical specifications are enclosed ' as Attachment 1. 'Ihese changes, as aanmarized in the response to Item 1 and discussed in ~ detail in the safety evaluation (Attachment 2) and significant hazard evaluation (Attachment 3) will' redice the mmber of cold fast starts, eliminate excessive testing and redace the -frecalency of abisite testing. Georgia Power .is confident that these changes will inprove diesel performance and ~ increase diesel-reliability. Also, the proposed technical specifications will recalire that an anmal report on diesel reliability be' mitatitted to the Mtc as discussed in' the response to Item 2. ' Itis ' report will allow diesel reliability to- be

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monitored.-

A trend analysis was performed using the data collected for the response to ~

cItem 2. As stated in the response to Item 2 this data shows an increase in diesel reliability oser the last three years as conpared to the reliability ,

prior to mid-1981. Since the Task Force has been implementing-recommendations for the last - two years, scue of this inprovement may be attrituted to their activities. ,

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considering the overall high reliability (of the diesels d2 ring the past

- three years, Georgia Rwer. believes that with the ongoing work of tre Diesel Generator Task Force, whose main objective is to improve diesel reliability, and with NRC approval of the proposed technical specifications (Attactment

1) that the current Georgia Rwer programs are attaining and will contirue to maintain a high reliability goal. For these reasons Georgia Power is of the opinion that the proposed changes to .the- technical specifications contained -in Attachment 1 are in our best interest for maintaining high diesel generator reliability in lieu of the performance specifications contained- in Generic Letter 84-15. In addition the surveillance - testing regiirements contained in Generic Intter 84-15 are not consistent with those recomended by the diesel generator marufaciturer.

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Table 1: Diesel Generator Reliability' Failures in Failures in lart Reliability- . last Reliability

- Diesel 20 Demands (20 Demands) 100 Demands (100 Demands)

^1A 0 '1004 - 0 100%

. -IC 0 1004- 0 100%

1B* 0 100% 0. 1004 2A 0 1004 0 1004 2C 1 954 3 974

• Diesel 1B is a swing diesel and serves both units.

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i Table 2: Time History of Failures-t

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Diesel Failure 'Date' ,

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'Imble 3: MJRI!G-0660 GMPARISON .

MatEG-0660 Item anbiect Task Pbece Action A-1 Air Driers in Air- .%e Diesel Generator' Task Start system Pbece fourd that moisture

- related failures were not a

. recurring problem in the starting air system therefore air driers would not be beneficial.

A Air Qaality In 'It was found that the Diesel Generator problems disoissed in ,

Room NURFG-0660 do not exist at Plant Patch, therefore no correctite actions were initiated.

A-3 'Iurtocharger Heavy Plant Hatch tas Eliott type Daty Gear Drive "H" turbo chargers and ras experienced no problems. ,

%erefore this reconnenda-tion is not applicable.

A-4 Personnel Training %e diesel mamfacturer has cordicted a class for operators, maintenance persovinel and engineers.

Georgia power is working with Colt Ird2stries to I develop a training ccurse  !

to be talght on a regalar basis B-1, 2 Pre-Lute Sgine The procedures have been Starts -

revised to include a four mirute prelube. Also, a lute oil keep warm / s ciraalation system has teen installed on Unit 2 and is being installed on Unit 1.

B-3 Testing, Test 'Ite proposed 'mchnical loading and Specifications revise the Preventive surveillance realirenents Mainter ance - per the diesel generator marufacturer's reconnenda-tions.

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Table 3: NLAtBG-0660 CINPNtISON (ODNTINUED)

MatEG-0660 ,

Item albject Task Force Action B-3a Minimi::ing no-load %e plant procedsres have and light load been revised to set mininum operations loading of Diesels at 25%

of rated load.

B-3b heting Frentencies %e proposed technical specifications revise tre test frestencies per tre diesel marufacturer's recom-sendation.

B-3c Maintenance 1be procedsres were reviewed Procedtres by site engineers and tre diesel tratufacturer and revised accordingly.

B-4 " Root Casse" and The Task Force immstigates Corrective Action probless to determine casses and implements action items to correct them.

C-1 DG Boom Ventila- Plant Itatch has experienced .

tion and comtus- no problems. 1herefore no tion Air Inlet corrective action has been taken. %e roads are paved and the grcunds are properly prepared marrcund-ing the diesel tuilding.

%erefore dast is not a

' problem.

C-2a niel Storage and Plant IIntch has no drain Handling gravity line at the bottom of the -

drains in tulk tank. Ilowever, fuel oil storage filel tanks analysin is performed once per 92 days to check for water por the Technical Specifications (Unit 1 -

4.9.A.2.D and Unit 2 -

4. 0.1.1. 2.D. ) . Nointure in fuel has not been a problem at plant !!atch.

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. r Tht4e 3: R5BG-0660 CGtPNLISCW MK4rtDRED) masG-0660 Item &aldect Task Perce Action C-2b '

' Rael Storage and Plant Hatdi fkael supply Handling Rael pamps are engine driven as L anpply masps . recommended. 'Itse fuel supply to this engine driven pump is gravity.

fed.

C-3 High 'Itaperature Plant Hatch diesels use Inaalation for class F inaalation which Overload is designed for a 105'c temperature rise (resistance method)

C-4 Engine Cooling 'this was included in the Water 'Itaperature ' original diesel generator Ctntrol design.

C-5 concrete Floors- nas to the age of tre floors Painting in the diesel generator tuilding, tre concrete has properly set. W refore,

-cmabling and dust experienced from new .

concrete is no problem.

l C-6 Instm ment and Plant Hatch has experienced controls Mxanting no problems with the instmments and controls.

W refore no corrective

action has teen taken. W l 'instmments are nannted on the same concrete pad as the diesel tut not directly ,'

l on the diesel itself.

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Table 4:' Major Task Force Action Items Not Included in the Reconnendations of ICREG-0660

1. Replace ' diesel generator starting . air compressor : pressure - switch to correct setpoint drift problems.

2.. Revise ' operating procochares ' according to diesel marufacturer's roccamendations.

~3. Install more reliable governor booster units to deter start failures or long starting times.

4. Install sample test point for oil analysis on diesels 'and l incorporate oil analysis into diesel operating procedtares. alch an analysis may detect potential failures.-

'5. Remove the practice of 'barring-over the diesel from 'the procediares to prevent damage to the diesel, per mamfacturer's reconsnendations.

6. Remove cylinder relief valtes from diesel generators becaise trey leak and create a potential fire hazard. Dese ' valves were intended for  ;

melear alb;narine service only.

7. Replace unloader bonnets with brass sleeved bonnets to correct corrosion problems associated with conpressor unloader valves.

8. Install an air filter on the air compressors for better mality air.

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