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REQUL RY INFORMATION DISTRIBUTI SYSTEN (RIDS)jl

AUTH. NAt'1E AUTHOR AFFILIATIONHEI SERp H W Penn sg 1 vani a Power 5 Light Co.

REC IP. NANE RECIPIENT AFFILIATIONADENSAN F. BNR Prospect Directorate 3

SUBJECT: Forwards application for revised Amends 83 Cr 3b to LicensesNPF-14 5 NPF-22'espectivelgi revising Tech Specs to reducenumber of required diesel generator starts in actionstatements or 18-month surveillance tests.

A 0'"DIBTRIBUTION CODE: AO56D COP IEB RECEIVED: LTR NCL ll I ZE:TITLE: OR Submittal: Fast Cold Starts of Diesel Qenerators QL-83-41 <QL-8 -15

"ACCESSION NBR: Sb072301b8 DOC. DATE: Sb/07/17 NOTARIZED: NO DOCKET 0FAG IL:50-387 Susquehanna Steam Electric Stati one Unit 1. Pennsglva 05000387

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0Pennsylvania Power 8 Light CompanyTwo North Ninth Street ~ Allentown, PA 18101 ~ 215 l 770-5151

Harold W. Keisert/lce President-Nuclear Operations21 5/770-7502

JUL >7 I86Director of Nuclear Reactor RegulationAttention: Ms. E. Adensam, Project DirectorBWR Project Directorate No. 3Division of BWR LicensingU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

SUSQUEHANNA STEAM ELECTRIC STATIONREVISION TO PROPOSED AMENDMENTS 83AND 36 TO NPF-14 AND NPF-22DIESEL GENERATOR RELIABILITYTECHNICAL SPECIFICATION CHANGESPLA-2684 FILE R41-2,8024,A17-2

Docket Nos. 50-387and 50-388

Reference: PLA-2633 dated April 23, 1986

Dear Ms. Adensam:

The referenced letter requested changes to Technical Specification 3.8.1.1which would reduce the number of required diesel generator starts when in anaction statement or during the 18 month surveillance tests. Comments andrequests for additional information from your staff necessitated modificationsto those proposed changes. Modifications which respond to your Staff'sconcerns to the proposed changes are provided under this letter. All proposedchanges are provided in this'letter, therefore this submittal supersedes ourprevious submittal.

These proposed changes are consistent with NRC Generic Letter 84-15 and do notreduce the ability of the diesels to mitigate the consequences of an accidentbut are intended to increase the diesel's reliability by not excessivelytesting them. Also FSAR Sections 9.5.4.8, 8.3.1.4.7 and SER Section 8.3.1were reviewed and there is no conflict between these sections and the proposedchanges. All references to our new "E" diesel generator have been deleted.The changes associated with the "E" diesel generator will be handled in aseparate submittal. A description of each change, including a justification,is provided below.

Footnote lI

This footnote is being deleted since all work associated with tying in the new"E" diesel generator has been completed and therefore this footnote is nolonger required. This proposed change is an administrative change.

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Pro osed 3.8.1.1 Action Statement a.

This action statement covers the responses when declaring one offsite circuitinoperable. Making this a separate action statement from the existing actionstatement is an administrative change. There are also three technical itemsincluded within this proposed action statement.

The performance of Surveillance Requirement 4.8.1.1.2.a.4, demonstration ofdiesel operability, will be done:

1) Within 24 hours of declaring the offsite circuit inoperable,

2) The diesel will not be started if successfully tested in the previous24 hours.

3) If Surveillance Requirement 4.8.1.1.2.a.4 was not performed in theprevious 24 hours it will be performed once on each remaining dieselfor this action statement within 24 hours.

Basis:

The reason to perform diesel operability tests following the loss of oneoffsite circuit is to ensure that the backup power source will be availableand capable of starting as designed. The present action statement requiresverification of diesel starting within four hours and then once every eighthours thereafter. Demonstration of diesel starting capability within fourhours of a loss of an offsite power source and subsequent testing every eighthours thereafter is both excessive and unwarranted. The diesel manufacturer,Cooper Energy Services, agrees that starting them every eight hours does notdemonstrate reliability and does not recommend starting the diesels thisfrequently. Starting the diesels once in 24 hours without retesting isconsistent with Generic Letter 84»15.

If the diesel has been tested in the previous 24 hours there is adequateassurance that the diesel will start. The diesel reliability is not suspectdue to a loss of an offsite circuit.

Pro osed 3.8.1.1 Action Statement b.

This action statement covers the appropriate responses when declaring oneemergency diesel generator inoperable. Making this a separate actionstatement for an inoperable diesel generator is merely an administrativechange. There are also two technical items included within this proposedaction statement:

The performance of Surveillance Requirement 4.8.1.1.2.a.4, demonstration ofdiesel operability, will be done:

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1) If the remaining operable diesels must be started they will bestarted within 24 hours.

2) If the diesels are to be started within 24 hours they will only bestarted once to demonstrate operability.

Basis:

The reason to perform a diesel operability test following the loss of anotherdiesel, is to ensure that the remaining diesel will be available and capableof starting as designed. Specifically, an operability test of the remainingdiesel provides assurance that the remaining operable diesels are not subjectto the same failure (i.e., common mode failure). Rather than relying onprevious surveillance testing, operability testing within 24 hours is proposedconsistent with Generic Letter 84-15.

As discussed in Item 3.8.l.l.a above, repetitive operability testing everyeight hours following the initial confirmation of diesel availability isunwarranted and counterproductive. To be consistent with the philosophy ofreducing excessive testing and thereby enhancing diesel reliability, only oneoperability start is proposed as confirmation of the remaining

diesels'vailability.

Pro osed 3.8.1.1 Action Statement c

This action statement covers the appropriate responses when declaring oneoffsite circuit and one diesel generator inoperable. In the existingTechnical Specifications this is action statement b. The proposed actionstatement has two technical changes:

The performance of Surveillance Requirement 4.8.1.1.2.a.4, demonstration ofdiesel operability, will be done:

1) If the remaining operable diesels must be started they will bestarted within 8 hours.

2) If the diesels are to be started within 8 hours, they will only bestarted once to demonstrate operability.

The present requirement is to perform Surveillance Requirement 4.8.1.1.2.a.4within three hours and at least once per 8 hours thereafter.

Basis:

The proposed changes are consistent with the changes to action statement b.These changes are also consistent with Generic Letter 84-15.

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Page 4 SSES PLA-2684,File R41-2,S024,A17-2Ms. E. Adensam

Pro osed 3.8.1.1 Action Statement d

This action statement covers the verification to be performed when a dieselgenerator is inoperable. This statement currently refers back to ACTION a orb, this is changed to ACTION b or c. This change is needed since old ACTION awas split into ACTION a & b, and b is the applicable reference for the subjectstatement. Old ACTION b is now ACTION c, hence the change to b & c. This isnot a technical change.

Pro osed 3.8.1.1 Action Statement e

This action statement covers the appropriate responses when declaring bothoffsite circuits inoperable. The proposed action statement has one technicalchange and one clarification. The performance of Surveillance Requirement4.8.1.1.2.a.4, demonstration of diesel operability, will be performed 8 hoursafter a loss of both offsite circuits. The present requirement is to performSurveillance Requirement 4.8.1.1.2.a.4 within 4 hours.

Basis:

The proposed change is consistent with those made for action statements a, b,and c above. As previously noted, loss of an offsite circuit does not suggestthat the diesels have become less reliable. This change is also consistentwith Generic Letter 84-15.

Pro osed 3.8.1.1 Action Statement fThe action statement covers the appropriate responses when two dieselgenerators are declared inoperable. The proposed action statement has onetechnical change.

The performance of Surveillance Requirement 4.8.1.1.1.a, verification ofbreaker alignment, will be performed within one hour after entering the actionstatement and at least once per 8 hours thereafter.

Basis:l

The proposed change is consistent, with action statements a, b & c'bove. Thischange is also consistent with Generic Letter 84-15.

4.8.1.1.2.d.3 Surveillance Re uirement

This surveillance indicates generator voltage shall not exceed 4360 volts.The number "4360" is a typographical error which was made when NRC issuedAmendment No. 36. The correct value is 4560. This is an administrativechange.

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Pro osed 4.8.1.1.2.d.4 Surveillance Re uirement

This proposed surveillance requirement will demonstrate the diesel's abilityto respond to a loss-of-offsite power (LOOP) in conjunction with 'an ECCSactuation test signal, a LOOP by itself, and an ECCS signal without a LOOP.These three cases will be demonstrated with only one start of the diesel.

There are three changes 'in this surveillance requirement:

1) The diesel will not be started for the simulated LOOP by itself.2) The diesel will not be started for the ECCS actuation test signal,

without a LOOP.

3) A new surveillance has been incorporated which describes testing ofthe LOCA relays.

Basis:

Safety functions occur as a result of:

a. Loss-of-offsite power (LOOP)b. ECCS actuation signal (LOCA)c. A combination of a LOOP and a LOCA signald. Either a LOOP or a LOCA signal

The circuits for LOOP and LOCA are independent. Testing these functionssimultaneously is acceptable. The only advantage of testing these functionsnon-concurrently is to verify that one signal is not dependent upon the othersignal. However, there is no reason to assume that the circuits have becomedependent upon each other.

Testing for actions which occur as a result of a concurrent LOOP and LOCAsignals should be tested with concurrent LOOP and LOCA signals. Since bothsignals are required for actuation, both signals should be present duringtesting.

Testing for item d. above is the only item where each signal should beindividually actuated. One trip is defeated while the other is tested. Thenthe other trip is defeated while the first trip is tested.

In summary, testing of the LOOP and LOCA functions concurrently is acceptableas long as those functions which occur due to either signal are tested withonly one signal at a time.

Pro osed 4.8.1.1.2.d.5 Surveillance Re uirement

This surveillance requirement is currently 4.8.1.1.2.d.7 and describes the 24hour load test to be performed and a restart within five minutes of this loadtest.

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The proposed surveillance requirement deletes the restart of the engine within5 minutes after the completion of the 24-hour test and deletes the asteriskednote associated with this section.

Basis:

This is essentially an administrative change in that the restart test is beingdeleted from the 24 hour load run section, however, the restart test will berequired in the next test, Surveillance Requirement 4.8.1.1.2.d.6. The effectof this change is to allow the restart test to be performed within 5 minutesof completing a 1-hour 4000 KW run or within 5 minutes of reaching stableoperating temperatures.

Pro osed 4.8.1.1.2.d.6 Surveillance Re uirement

This surveillance requirement is part of present 4.8.1.1.2.d.7 and describesthe restart test of the diesel generator.

The proposed change has the same requirements as prescribed in the existingTechnical Specification however, it removes it from the 24-hour load run test.

Basis:

The basis for this change is consistent with that of Surveillance Requirement4.8.1.1.2.d.5.

Pro osed 4.8.1.1.2.d.7 Surveillance Re uirement

This surveillance requirement is currently 4.8.1.1.2.d.8 and requires that averification be performed to assure that the auto-connected loads to eachdiesel generator do not exceed the 2000 hour rating of 4700 KW.

The proposed surveillance requirement has one change.

The verification of the auto-connected loads will be done by calculation.

Basis:

This test is to assure that the 2000 hour rating of the diesel generator isnot exceeded. It is more suitable to demonstrate this by calculation ratherthan test for the following reasons:

All the auto connected loads are known and the sum of these. loads canbe compared to the 2000 hour'rating.

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All the auto connected loads would not necessarily be running at fullload.

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o By calculation the two unit loads could be considered rather than theloads associated with one unit.

4.8.1.1.2.d.ll (existin )

The requirement to verify the fuel transfer pump transfers fuel from each tankto the engine mounted day tank of each diesel generator has been deleted.

Basis:

Regulatory Guide 1.108 recommends this surveillance if the practice is part ofnormal operating procedures. At Susquehanna, this transferring is not part ofnormal operating procedures and should not be verified in the TechnicalSpecifications. Fuel transfer from the fuel oil tank to the correspondingdiesel generator day tank is tested every 31 days. There is no impact onsafety since no credit is taken for this capability in any safety analyses.

Pro osed 4.8.1.1.2.d.ll Surveillance Re uirement

This surveillance requirement is currently 4.8.1.1.2.d.l3 and requiresverification that the listed diesel generator lockout features prevent dieselgenerator starting and/or operation only when required. The proposedsurveillance is a rewrite of the existing surveillance which more accuratelyreflects how the lockout features are verified.

Basis:

This change is administrative.

Pro osed Chan e 4.8.1.1.3 — Re orts

This section requires all diesel failures, valid or non-valid, to be reportedto the Commission. The proposed change revises the method for determining thenumber of failures in the last 100 valid tests from a per nuclear unit basisto a per diesel generator basis.

Basis:

Consistent with criteria established for Table 4.8.1.'1.2-1 (See justificationfor that Table).

Pro osed Chan e to Table 4.8.1.1.2-1

The subject table lists the frequency of diesel tests as a function offailures. The proposed change, changes the valid tests per nuclear unit basisto a per diesel generator basis.

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Basis:

The current test frequency is determined on a per nuclear unit basis. Thisrequires that all the diesel be tested even if one has been unreliable. Thisunnecessarily tests the reliable diesels more frequently than would normallybe required. The change to a per diesel basis would demand that the lessreliable diesels be tested to prove reliability. This change is consistentwith Generic Letter 84-15.

The proposed changes do not:

(1) involve an increase in the probability or consequences of an accidentpreviously evaluated. The proposed changes reduce test frequenciesand modify loading requirements consistent with manufacturer'srecommendations. These changes are expected to enhance dieselreliability by minimizing severe test conditions and required numberof starts. In this regard there is no increase in the probability ofan accident. The consequences of any previously evaluated accidentare not increased since the changes only involve diesel loadings andtest frequencies. There are no physical modifications to the dieselgenerators as a result of these changes. Therefore the limitingaccident is the failure of one diesel generator which has beenevaluated in Section 8.3 of the Final Safety Analysis Report.

(2) create the possibility of a new or different kind of accident fromany accident previously evaluated. As stated in Part I, the proposedchanges are intended to enhance diesel reliability. Any accidentcreated as a result of these changes would be no worse than thefailure of a diesel generator which has been evaluated.

(3) involve a reduction in a margin of safety. The margin'f safety hasbeen determined acceptable assuming the loss of one diesel generator.The proposed changes will enhance diesel reliability thereby reducingthe probability of a loss of a diesel generator.

We request these amendments be approved and made effective on September 1,1986.

If you have any questions, please contact D. J. Walters.

Very truly yours,

H. W. KeiserVice President-Nuclear Operations

cc: M. J. Campagnone NRCL. R. Plisco NRC

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