ML18005A201
| ML18005A201 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/29/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Lieberman J, Murley T, Taylor J NRC OFFICE OF ENFORCEMENT (OE), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8711130246 | |
| Download: ML18005A201 (7) | |
Text
REGULA Y INFORMATION DISTRIBUTIC YSTEM (RIDS)
ACCEShION NBR: 8711130246 DOC. DATE: 87/10/29 NOTARIZED:
NO DOCKET FACIL: 50-400 Shearon Harris Nuclear Power Planti Unit ii Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION QRACEi J. N.
Region 2i Ofc of the Director RECIP. NAME RECIPIENT AFFILIATION MURLEYIT. E.
Office of Nuclear Reactor Regulationi Director (Post 870411 TAYLOR'. M.
Regional Operations 5 Generic Requirementsi EDO (Pre 870413 LIEBERMANiJ.
Of c of Enf orcement (Post 870413)
SUBJECT:
Documents that util granted discretion for compliance w/emergency diesel generator load regect test criteria on 871016. Test results consider ed acceptab le if generator voltage does not exceed 110/ of voltage at start of test.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: General (50 Dkt>-Insp Rept/Notice of Vio ation Response NOTES: Application for permit renewal filed.
05000400 REC IP IENT ID CODE/NAME PD2-1 PD INTERNAL:
AEOD NRR MORISSEAUi D NRR/DOE* DIR NRR/DREP/RPB NRR/PMAS/ ILRB OQC/HDS1 RES DEPY QI COPIES LTTR ENCL 1
1 1
1 1
1
'.1 1
1 1
1 1
1 1
RECIPIENT ID CODE/NAME BUCKLEY'S B DEDRO NRR/DLPG/PEB NRR/DREP/EPB NRR/DRIS DIR EBERMANi J REQ FIL R
ILE 01 COPIES LTTR ENCL 2
2 1
1 1
1 1
1 1
1 1
1 1
1 EXTERNAL:
LPDR NSIC 1
1 1
1 NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 21
.QGT 2 9 198't MEMORANDUM FOR:
Thomas E. Murley, Director, Office of Nuclear Reactor Regulation James M. Taylor, Deputy Executive Director for Regional Operations James Lieberman, Director, Office of Enforcement FROM:
SUBJECT:
J.
Nelson Grace, Regional Administrator ENFORCEMENT DISCRETION FOR SHEARON HARRIS NUCLEAR POWER PLANT, UNIT. 1, DOCKET NO; 50-400/LICENSE NO. NPF-63 The purpose of this memorandum is to document that on October 16, 1987, Carolina Power and Light Company was granted discretion for complying with the emergency diesel generator load reject test criteria in Technical Specification surveil-lance requirement 4.8. 1. 1.2.f. 11.
Specifically, test results will be consid-ered acceptable if the generator voltage does not exceed 110 percent of the diesel generator voltage at the start of the test, rather than the 7590 volts currently required by the specification.
The need and safety basis for this discretionary enforcement is described in the enclosed letters from Carolina Power and Light Co. dated October 15,
- 1987, and October 16, 1987.
NRR is preparing an exigent Technical Specification amendment based upon these documents.
Prior to discretion being granted,. the technical issues and possible NRC options were discussed by telephone between Region II and NRR.
Participants in this conversation were A. F. Gibson and H.
C.
Dance of Region II, and G.
C. Lainas, E.
G.
Adensam and B.
C. Buckley of NRR.
Subsequent to this conversation, the issues and extent of enforcement discretion were discussed with the licensee.
Participants in this conversation are listed in the enclosed CP&L letter dated October 16, 1987.
Enclosures:
1.
CP&L Letter dated 10/15/87 2.
CP&L Letter dated 10/16/87 3.
Region II Memo dated 10/22/87 J.
Nelson Grace 87iii3024h 87i029 PDR ADOCK 05000400 P
PDR cc w/encls:
A. Gibson L. Reyes G. Lainas, NRR G. Maxwell, Sr. Resident, SHNPP RII PFre ickson:cdg 10/~/87 RII AGibs 10/~V/87 RIIJ DVerre) 1 i 10/z"f87 RII'I I
GJenkins rnst 10~/87 10~)/87 RI I VBrownlee 10/ ~"f87 RI Reyes 10@+07
Carglna Power a Light Company HARRIS NUCLEAR PROJECT P.
Oi Box 165 Nett Hi.ll> Horth Carolina 27562 October 15>
1987 10CFR50+90 File Numbers SHF/10-13510 Letter Number:
HO"8705200 United States Nuclear Regulatory Commission ATTENTIONS Document Control Desk Mashington, DC 20555 SHEARON HARRIS NUCLEAR POMER PLANT DOCKET NOo 50 400/LICEHSE NOo NPF-63 REQUEST FOR EXIGENT LICENSE AMENDMENT DIESEL GENERATOR SURVEILLANCE Gentlemenl
SUMMARY
In accordance with the Code of Federal Regulations, Title 10>
Parts 50.90 and 2.101, Carolina Power 4
Light Company hereby requests an exigent amendment to the Tcchnical Specifications for the Shearon Harris Nuclear Power Plant (SHNPP).
The proposed amendment revises Survei11ance Requirement 4.8.1. 1.2if.l}
to ensure that during a load re)ection test, the generator voltage does not exceed 110 percent of the diesel generator voltage at the start of the test, rather than the 7590 volts currently required by the specification.
DISCUSSIOH Surveillance Requirement 4.1.1.2.f.ll currently requirest Verifying the generator capability to re)ect a load of between'200 and 6400 kM 'ithout tripping.
The generator voltage shall not exceed 7590 volts during and following the load rejection',
5~r'C u/MC nant,') hh/ 1 /hC1
United States Nuclear Regulator Commission Page 2
The purpose of the sux'veillance is to demonstrate that a
load rejection does not result in (1) an emexgency diesel generator overspeed trip and (2) that the voltage xegulator is functioning propex'ly such that the diesel generator is <<vailable for emergency service xf needed immediately followi.ng a load rejection.
The 7590 volt generatox'oltage limit was established at 110 percent of a
nominal generator.
starting voltage of 6900 volts.
Verification -of the maximum generator voltage is performed to check the operability of the voltage regulatori Kf the regulator is operating properly during a
load reject situation, generator voltage will momentary'ily increase to some value (typically less than 110 pex'cent of the starting voltage) and then decrease to the no"load voltages As such, a specific maximum value for generator voltage is not required to ensure diesel generator voltage xegulator operability>
On October 13,
- 1987, Carolina Power 6 Light Company attempted to perform this 18 month surveillance requirement for diesel lB-SB.
The test was unsuccessful due to exceeding thc 7590 volts generator, voltage limit.
The diesel generator operated as required)
- however, existing conditions at the time the surveillance was pe~formed made it impossible to satisfy the surveillance requirement.
Plant loads are established so that the design loading limits of the diesel gencratoxs are not challenged during emergency operation.
As
- such, these loads are not sufficient to achieve a load of between 6200 and 6400 kM on the generator.
Therefore, it is necessary to parallel the diesel generator to the system grid to increase the generator load to the technical specification required value.
awhile connected to the grid the voltage on the generator must be maintained in excess of system voltage to ensure proper operation of the emergency diesel generator in accordance with its design limit for power factor, Demand on the system grid wss relatively low at the time of performing Surveillance Requirement 4.8.1.1.2, f. 11, resulting in an overall high system voltage.
As such, voltage on the generator was appx'oximatcly 7350 volts at thc start of the test, well above the 6900 volt nominal starting voltage used to establish the lip percent limit of 7590 volts in the techntical specification.
Duxing the surveillance, the voltage on the generator reached 7850
- volts, exceeding the Tcchnical Specification limi.t of 7590 volts but not exceeding 8085
- volts, 110 percent of the initial test voltage of 7350 volts.
The proposed change to Surveillance Requirement 4.8.1.1.2.f,ll will limit generator voltage to less than or equal to 110 percent of the voltage on the generator at the start of the test.
The proposed limit of 110 percent is well within the
~ ~
~ e leer h thChhh /1 lh01
United States Nuclear Regulator Coneission Page 3
desi.gn capability of aha diesel generator.
The revised surveillance requirement vill ensure verification of diesel generator capability to satisfactorily withstand a full load rejection vithin the original intent of the 'urveillance Requirement 4.8.1.1.2.E. l 1 vhile allowing sufficient flexibility to perform the surveillance independent of system grid voltage conditions.
SIGHIPTGANT HAZARDS AMALYS?S The Commission has provided standards in 10 CFR 50.92(c) for determining vhether a significant hazards consideration exists.
A proposed amendment to an operating licenie for a facility involves no,significant haiards consideration if operation of the facility in accordance vi.th the proposed amendment would not!
(1) involve a significant increase in the probability or consequences of an accident previously evaluated>
(2) czcate the possibility of a
new or different kind of accident from any accident previously evalua'ted>
or (3) invoivc a significant reduction in a margin of safety.
Carolina Power 5 Light Company has reviewed this request and determined that; 1.
The proposed amendment does not involve a
significant increase in the probability or consequences of any accident previously evaluated because the change does not affect the method in vhich the diesel generators, or any other safety
- system, perform their intended safety function.
Diesel generator and voltage regulator operability is still ensured and the intent of Surveillance Requizement 4.8.1.1.2.f. 11 to verify the ability of the diesel generator to perform satisfactorily during a
full load rejection is still fulfillcd by the revised surveillance 'equirement.
The revision merely allovs the operational flexibilityto perform the required surveillance without reliance on system grid voltage conditions.
2.
The pzoposed amendment does not create the possibility of a
nev or different kind of accident than previously evaluated.
As stated
- above, no physical change to any safety related
- system, nor change in the method in vhich any safety system perf orms its intended function result from the proposed amendment.
Therefore, the proposed amendment cannot create the possibility of a nev or different kind of accident than previously evaluated.
3.
The proposed amendment does not involve a
significant reduction in a
margin of safety.
Diesel generator and voltage regulatoz operabili.ty and the ability to incur a load rejection vithout a diesel generator overspced trip or excess voltage is adequately ensured by the revi.sed surveillance requirement.
As such, the margin of safety is not affected by the proposed amendment.
MEM/MS"8705200/3/OSl
United States Nuclear Regulator Commission Page 4
Based on the above reasoning, CPKL has determined that the proposed amendment does not involve a
significant.
hasards considerationi ENVIRONMENTAL ASSESSMENT Carolina Poser 5
Light Company has reviewed this request and determined that 'the proposed amendment changes a requirement vith respect to the use of a facility component located
~ithin the restricted
- area, aa defined in 10 CFR Part 20, end changes a
surveillance requirement.
Operation in accordance
~ith the proposed revision vi11 not result in a significant increase in the amounts oz a significant change in the types of any effluenta that may b>>
released offsite nor Mill it result in a
significant increase in individual or cumulative occupational radiation exposure.
The Company has previously determined that the proposed amendment does not involve a significant haeards consideration.
Baaed on the above reasoning, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51o22(e) (9) e Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmenta1.
assessment need to be prepared in connection vith the issuance of the amendment.
DISCUSSION OF EXIGENCY SHNPP is currently in a maintenance outage and scheduled to return to service on November 4,
1987.
Diesel generator surveillance testing ia cri.tical path, any delay in completion Mill directly affect the length of the outage.
Testing of diesel generator 1A"SA cannot begin until diesel generator 1B-SB can be declared operable.
The Company had no previous reason to suspect that failure of this surveillance requirement yould occur.
Previous testing uas performed Mhen system grid demand uas much higher andt therefore, system voltage and diesel generator voltage was proportionally lower.
As
- such, sufficient mazgin existed to successfully pezform the surveillance requirement.
Therefore>
an emergency license amendment is required to be issued by Octobez 16, 1987 in order to avoid delay of startup of the unit.
ADMINISTRATIVE INFORMATION The revised SHNPP TS page is provided in Enclosure 1.
The Company haa evaluated this request in accordance vith the provisions of 10 CFR 170.12 and detezmined that a license amendment application fee ia requized, A check for $ 150 ia enclosed in payment of this fee.
In accordance Mith 10 CFR 50.91, the Company has forwarded a
copy of this request to.Mr.
Dayne H.
Brown of the State of North Carolina.
MEN/MS"8705200/4/OS1
United States Nuclear Reg'ulator Commission Page 5
Please
- refer questions regarding Mr. David C. McCarthy at (919) 836"7715.
this submittal to RAW:dj Enclosures Yours very truly~
8@/~
Ri A. Watson Vice President Harris Nuclear Project cc'.
Mr. D. H. Brown (State of NC)
Mr. B.
C. Buckley (NRC)
Dr. J. Nelson Grace (NRC"R Mr. G. Pi Maxwell (NRC-SHNPP)
R.
A.
- Watson, having been fbi.rst duly sworn, did'epose and say that the information contained herein is true and correct to the best of his information, knowledge and belief) and the sources of his information are officers, employees, contractors, and agents of Carolina Power 6 Light Company.
My eoaun1ssion expires:
Z~/2F Notary (Seal MEM/MS-8705200/5/OS1