ML023380304

License Amendment Request 189 to Kewaunee TS Regarding Modification of Diesel Generator Inspection Requirements

ML023380304
Person / Time
Site:	Kewaunee
Issue date:	11/22/2002
From:	Coutu T Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-02-101
Download: ML023380304 (16)

Text

Kewaunee Nuclear Power Plant Point Beach Nuclear Plant N490 Highway 42 6610 Nuclear Road Kewaunee, Wl 54216-9511 Two Rivers, WI 54241 NMC 920.388 2560 920 755 2321 Committed to Nuclear Excellence Kewaunee / Point Beach Nuclear Operated by Nuclear Management Company, LLC NRC-02-101 November 22, 2002 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Ladies/Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant License Amendment Request 189 To The Kewaunee Nuclear Power Plant Technical Specifications Regarding Modification Of The Diesel Generator Inspection Requirements The Nuclear Management Company (NMC) is submitting this license amendment request (LAR) to the Kewaunee Nuclear Power Plant (KNPP) Technical Specifications (TS) to revise Section 4.6, "Periodic Testing of Emergency Power System."

This amendment request will allow KNPP to inspect the diesel generators (DGs) at least once per refueling frequency either while the plant is operating or during a refueling outage. Current TS do not prevent conducting DG inspections while generating, however, it does require an inspection during the refueling outage. The change will provide flexibility in the scheduling of maintenance activities, reduce plant refueling outage duration, and increase the DG availability when the plant is shut down.

In addition, TS section 4.6 will be converted to WORD format, correct minor typographical and format inconsistencies, and standardize naming conventions as part of a continuing effort to improve KNPP's TS. A standardized naming convention will be used to fix one of these inconsistencies. The time between refueling outages has been called operating cycle, 18 months, or refueling outage interval. In section 4.6 of the TS, each of these descriptions will be changed to "refueling interval" to provide a consistent and accurate description of this time. The health and safety of the public will not be adversely affected by the proposed change. This submittal is not risk informed because it doesn't change KNPP's licensing basis for diesel LCO's. to this letter contains a description, a safety evaluation, a significant hazards determination, and environmental considerations for the proposed change. Attachment 2 contains the strike-out Technical Specification page: TS 4.6-1. Attachment 3 contains the affected Technical Specification page as revised: TS 4. 6-1. contains the strike-out Technical Specification Bases page: TS B4.6-2. Attachment 5 contains the affected Technical Specification Bases page: TS B4.6-2.

Docket 50-305 NRC-02-101 November 22, 2002 Page 2 NMC requests approval of this LAR by April 1, 2003. The selected approval date allows KNPP to inspect the DGs before the next refueling outage scheduled for April 2003 and not be required to perform additional inspections during the outage. This amendment is not required to allow continued safe full power operation and does not contain proprietary information.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 18, 2002.

Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant TLM Attach.

cc -

US NRC, Region LII US NRC Senior Resident Inspector Electric Division, PSCW

ATTACHMENT 1 Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated November 22, 2002 LICENSE AMENDMENT REQUEST 189 Description of the Proposed Change Safety Evaluation Significant Hazards Determination Environmental Considerations

Docket 50-305 NRC-02-101 November 22, 2002, Page 1 Introduction The proposed change will revise the Technical Specifications (TS) to allow inspection of the diesel generators (DGs) anytime. Current TS require performing an inspection during the refueling outage regardless of when the last inspection was performed. The proposed change will require an inspection at least once per refueling interval, which occurs every 18 months.

Description of Proposed Change to Technical Specification TS 4.6, "Periodic Testing of Emergency Power System" The plant is designed to have at least one external source and one standby source (diesel generator) of electrical power available to accomplish safe shutdown, containment isolation, and to operate required engineered safety features equipment following an accident.

Each diesel generator is connected to one 4160-V safety features bus and has sufficient capacity to start, sequentially load, and operate the engineered safety features equipment supplied by that bus. The set of safety features equipment items supplied by each bus is alone, sufficient to maintain adequate cooling of the fuel and maintain containment pressure within the design value in the event of a loss-of-coolant accident.

Each diesel generator starts automatically upon low voltage on its associated bus, and both diesel generators start in the event of a safety injection signal. A minimum of seven days fuel supply for one diesel generator is maintained by requiring 36,000 gallons of fuel oil, thus ensuring adequate time to restore off-site power or to replenish fuel.

The arrangement of the auxiliary power sources, equipment, and TSs ensure that no single fault condition will deactivate more than one redundant set of safety features equipment items and will therefore, not result in failure of the plant protection systems to respond adequately to a loss-of-coolant accident.

The proposed change will revise the TS 4.6.a.3 to allow inspection of the DGs either during operation or a refueling outage. This change will provide flexibility in outage scheduling and potentially reduce outage critical path time since the DG inspection work would no longer have to be performed during an outage. In addition, this will increase the DG availability when the plant is shutdown.

The TS section is being converted to WORD format to conform to the standard software used at KNPP. In addition to the conversion, minor typographical, grammatical, format inconsistencies, and unstandardized naming conventions will be corrected.

To provide a standardized naming convention TS 4.6.2, TS 4.6.4, TS 4.6.5, andTS 4.6.6 are changed to indicate a surveillance test interval (STI) of at least once per refueling interval. This change provides consistency in TS 4.6 as this interval is the same as at least once per 18 months or at least once per operating cycle. The STI of at least once per refueling interval is also consistent with definition TS 1.0.i.5 and Table TS 1.0-1.

Docket 50-305 NRC-02-101 November 22, 2002, Page 2 Changes are also being made to the basis section for TS 4.6 to add the basis to explain the STI of once per refueling interval and remove the reference to the various STI's as the STI is contained in the TS itself.

Safety Evaluation for Proposed Change to T.S 4.6 "Periodic Testing of Emergency Power System" The proposed change will modify TS 4.6.a.3, which requires each diesel generator to be inspected at each major refueling outage. The proposed change will modify the inspection to occur at least once per refueling interval, which does not require KNPP to do these inspections during an outage. The inspection frequency will stay 18 months but would credit inspections while at power or during an outage instead of just during a refueling outage. The health and safety of the public will not be adversely affected by the proposed change because it does not change KNPP's licensing bases for diesel LCO's.

The NRC has previously approved a similar request. For example, Millstone 3 was issued license amendment number 194 on February 2, 2001 in which they removed the Diesel Generator (DG) surveillance requirements (SR) from technical specifications (TS) and into their maintenance program. One of the SRs they removed was the inspection of their DG every 18 months.

Millstones safety evaluation specifically acknowledged the reason for their TS change was to remove the requirement of inspecting the DG's only during the refueling outages and the ability to perform the inspection at power.

Another issue associated with the DG is station blackout (SBO). Regulatory Guide 1.155, August 1988, describes the suggested reliability (availability) of onsite emergency ac power. The regulatory guide discusses the recommendation of scheduling regular DG maintenance during shutdown to assure low reliability numbers for each of the DGs. Per KNPP letter from K. H.

Evers to NRC, dated March 30, 1990 (NRC-90-39), our targeted reliability number is 0.95, which is based on emergency ac power characteristics and configuration as analyzed by Table 2 of Regulatory Guide 1.155.

A reliability factor of 0.95 gives 438 hours0.00507 days <br />0.122 hours <br />7.242063e-4 weeks <br />1.66659e-4 months <br /> per year of DG unavailability before exceeding the recommended levels. NMC expects to complete the DG inspection in three days. A three day inspection would add approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (16.4%) to the yearly limit. KNPP averages 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of DG unavailability per year for the last 6 years. Adding this average to the expected inspection time will give a total of 162 hours0.00188 days <br />0.045 hours <br />2.678571e-4 weeks <br />6.1641e-5 months <br /> or 37% of the recommended level per Regulatory Guide 1.155. Even if the full TS allowed outage time of seven days was added to the average unavailability of the DG, the reliability factor would still be greater than 0.95.

The Standard Review Plan (NUREG-0800, page 8.3.1-19) states the following regarding inspecting electrical power systems and general design criterion 18. "The a-c power system is designed to be testable during operation of the nuclear power generation station as well as during those intervals when the station is shutdown. This meets the positions of Regulatory Guide 1.118." This statement supports NMC's request to inspect the DG during operation.

Docket 50-305 NRC-02-101 November 22, 2002, Page 3 Standard IEEE 387-1977 titled IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations states in section 6.7 that "Separate preventive maintenance, inspection, and testing programs shall be established for the engine-generator and all supporting systems based on the manufacturer's recommendations, including time interval for parts replacement." The DG Recommended Maintenance Program does not specify that the inspections be done during a refueling outage. They use the term "refuel cycle (18-24 months)" or, "refuel interval", or "vendor recommended frequency". As the diesel will remain on an 18-month inspection interval, IEEE387 and the vendor recommendations are also being met Based on the details of these several examples along with the fact that the LCO for each DG will not be changing, the health and safety of the public will not be adversely affected by the proposed changes.

The proposed changes to convert TS section 4.6 to WORD, correct typographical, grammatical, formatting, and standardized naming conventions errors are administrative.

The intent or interpretation of these specifications is not changed and therefore has no safety significance.

Administrative changes have no effect on the public.

Significant Hazards Determination for Proposed Change to TS 4.6, "Periodic Testing of Emergency Power System" This license amendment request will allow KNPP to inspect the diesel generators (DGs) while the plant is operating and not also have to conduct inspections while in a refueling outage. It will provide flexibility in the scheduling of maintenance activities, reduce plant refueling outage duration, and increase the DG availability when the plant is shut down.

The format, typographical, grammatical, and standardized naming convention changes in addition to the WORD conversion are administrative in nature The proposed change was reviewed in accordance with the provisions of 10 CFR 50.92 to determine that no significant hazards exist. The proposed change will not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The DGs are accident mitigating equipment, not accident initiating equipment.

Consequently, there will be no impact on any accident probabilities by the approval of the requested amendment.

The proposed change does not affect the performance of any equipment used to mitigate the consequences of an analyzed accident. Consequently, no analysis assumptions are violated and there are no adverse effects on the factors that contribute to off-site or on-site dose as the result of an accident.

Docket 50-305 NRC-02-101 November 22, 2002, Page 4 The format, typographical, grammatical, and standardized naming convention changes in addition to the WORD conversion are administrative in nature and therefore have no impact on accident initiators or plant equipment.

Based on the above, the proposed administrative changes and permitting DG inspections to be performed during plant operation does not involve a significant increase in the probabilities or consequences of an accident previously evaluated.

2.

Create the possibility of a new or different kind of accident from any accident previously evaluated.

No new accident mechanisms would be created as a result of NRC approval of this amendment request since no changes are being made to the plant that would introduce any new accident mechanisms. Equipment would be operated in the same configurations with the exception of the mode in which the inspection is credited. The inspection will be performed within the current approved Technical Specification limiting condition for operation (LCO). This amendment request does not impact any plant systems that are accident initiators or adversely impact any accident mitigating systems.

The proposed administrative changes do not involve any modifications to the physical plant or operations. Administrative changes do not contribute to accident initiators nor do they produce a new accident scenario. Based on the above, implementation of the proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in the margin of safety.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include fuel cladding, the reactor coolant system, and the containment system. The proposed change to the inspection timing for the DGs do not affect the operability requirements for the DGs, as verification of such operability will continue to be performed as required.

Continued verification of operability supports the capability of the DGs to perform their required function of providing emergency power to plant equipment that supports the fission product barriers. Consequently, the performance of these fission product barriers will not be impacted by implementation of this license amendment request and therefore does not involve a significant reduction in the margin of safety.

The administrative changes do not affect plant equipment or operation. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Docket 50-305 NRC-02-101 November 22, 2002, Page 5 Based upon the above analysis, the proposed change will not significantly increase the probability or consequences of any accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in the margin of safety. Therefore, the proposed change meets the requirements of 10CFR50.92 and involves no significant hazard consideration.

Environmental Considerations The NMC has determined that the proposed amendment involves no significant hazard considerations. There are no changes in the types of effluents that may be released off-site. There are no increases in the individual or cumulative occupational radiation exposure. Accordingly, this proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with this license amendment request.

ATTACHMENT 2 Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated November 22, 2002 LICENSE AMENDMENT REQUEST 189 Strike Out TS Pages:

TS 4.6-1

4.6 PERIODIC TESTING OF EMERGENCY POWER SYSTEM APPLICARIL ITY Applies to periodic testing and surveillance requirements of the emergency power system.

QBh1EG.TLVE To verify that the emergency power sources and equipment are OPERABLE.

SPEFCIFICATION The following tests and surveillance shall be performed:

a. Diesel Generators

1. Manually-initiated start of each diesel generator, and assumption of load by the diesel generator.

This test shall be conducted monthly, loading the diesel generator to at least 2600 KW (nominal) for a period of at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

2. Automatic start of each diesel generator, load shedding, and restoration to operation of particular vital equipment, all initiated by a simulated loss of all normal a-c station service power supplies together with a simulated safety injection signal.

This test will be conducted at each REFUELNG refuelninterval to ss

-ensure that each diesel generator will start and assume required loads to the extent possible within 1 minute, and operate for > 5 minutes while loaded with the emergency loads.

3. Each diesel generator shall be inspected at

,each-,ejor-REFUEI-NG-*,.tageleast once per refi leling intprval.

4. Diesel generator load rejection test in accordance with IEEE 387-1977, Section 6.4.5, shall be performed at least once per IS ron~tsr-fueln r

5. Each diesel generator shall be loaded to 2950 KW (nominal) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> every operatingeyeleat Ieast once per refi,Iling interval

6. Safeguard bus undervoltage and safeguard bus second level undervoltage relays shall be calibrated at least once per -opefatilg-eyelerefl eblianirL.

Amendment-LARNo.

-491_89 TS 4.6-1 G4141-822/95*20-

ATTACHMENT 3 Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated November 18, 2002 LICENSE AMENDMENT REQUEST 189 Affected TS Pages:

TS 4.6-1

4.6 PERIODIC TESTING OF EMERGENCY POWER SYSTEM APPLICARILITY Applies to periodic testing and surveillance requirements of the emergency power system.

Q.J1FrITVE To verify that the emergency power sources and equipment are OPERABLE.

RPECIFICATION The following tests and surveillance shall be performed:

a. Diesel Generators

1. Manually-initiated start of each diesel generator, and assumption of load by the diesel generator.

This test shall be conducted monthly, loading the diesel generator to at least 2600 KW (nominal) for a period of at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

2. Automatic start of each diesel generator, load shedding, and restoration to operation of particular vital equipment, all initiated by a simulated loss of all normal a-c station service power supplies together with a simulated safety injection signal.

This test will be conducted at each refueling interval to ensure that each diesel generator will start and assume required loads to the extent possible within 1 minute, and operate for ; 5 minutes while loaded with the emergency loads.

3. Each diesel generator shall be inspected at least once per refueling interval.

4. Diesel generator load rejection test in accordance with IEEE 387-1977, Section 6.4.5, shall be performed at least once per refueling interval.

5. Each diesel generator shall be loaded to 2950 KW (nominal) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at least once per refueling interval.

,6.

Safeguard bus undervoltage and safeguard bus second level undervoltage relays shall be calibrated at least once per refueling interval..

TS 4.6-1

ATTACHMENT 4 Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated November 18, 2002 LICENSE AMENDMENT REQUEST 189 Strike Out TS Bases Pages:

TS B4.6-2

R...H.ELIN..nt..al Diesel Generator Inspection-LTS 4.6.a 3)

Inspections a re p erformed a t R EFUELING outage i ntervals Iea*t once per refeling interva! ji erder-to maintain the diesel generators in accordance with the manufacturers' recommendations.

The inspection procedure is periodically updated to reflect experience gained from past inspections and new information as it is available from the manufacturer.

The ahility tn ins~pect the diesel generators* antime diring the refelleing interval give*s the plant flexihility in schedifling maintenance arfivities*

Additionally the op~tinn of performina in.*,ectionn nn-line.can red, ice pnlant RFFI IF/ ING oi tane di iration and increas*e the DlG availahility when the 48-;Aonth-Load Rejection Test- (TS 4-6-a.4)

The load rejection test demonstrates the capability of rejecting the maximum rated load without overspeeding or attaining voltages which would cause the diesel generator to trip, mechanical damage, or harmful overstresses.

Gnprstinng

• -,le Short-Term Load Test- (TS 4-6,a.5)

Loading the diesel generators to their short-term rating will demonstrate their capability to provide a continuous source of emergency AC power during a load perturbation of up to 112% of the diesel generator's continuous rating.

Station Batteries- (TS 4.6.b)

Station batteries will deteriorate with time, but precipitous failure is extremely unlikely.

The surveillance specified is that which has been demonstrated over the years to provide indication of a cell becoming unserviceable long before it fails.

If a battery cell has deteriorated, or if a connection is loose, the voltage under load will drop excessively, indicating need for replacement or maintenance.

Afnendment-LAR.No. 41-9189 TS B4.6-2 04V1_1-822/952002

ATTACHMENT 5 Letter from Thomas Coutu (NMC)

To Document Control Desk (NRC)

Dated November 18, 2002 LICENSE AMENDMENT REQUEST 189 Affected TS Bases Pages:

TS B4.6-2

4 Diesel Generator Inspection (TS 4.6.a.3)

Inspections are performed at least once per refueling interval to maintain the diesel generators in accordance with the manufacturers' recommendations. The inspection procedure is periodically updated to reflect experience gained from past inspections and new information as it is available from the manufacturer.

The ability to inspect the diesel generators anytime during the refueling interval gives the plant flexibility in scheduling maintenance activities. Additionally, the option of performing inspections on-line can reduce plant REFUELING outage duration, and increase the DG availability when the plant is shut down.

Load Rejection Test (TS 4.6-a-4)

The load rejection test demonstrates the capability of rejecting the maximum rated load without overspeeding or attaining voltages which would cause the diesel generator to trip, mechanical damage, or harmful overstresses.

Short-Term Load Test (TS 4.6_

5)

Loading the diesel generators to their short-term rating will demonstrate their capability to provide a continuous source of emergency AC power during a load perturbation of up to 112% of the diesel generator's continuous rating.

Station Batteries (TS 4.6.b)

Station batteries will deteriorate with time, but precipitous failure is extremely unlikely.

The surveillance specified is that which has been demonstrated over the years to provide indication of a cell becoming unserviceable long before it fails.

If a battery cell has deteriorated, or if a connection is loose, the voltage under load will drop excessively, indicating need for replacement or maintenance.

TS B4.6-2