ML18010B099

Application for Amend to License NPF-63,removing License Conditions for Edgs,Specified by Condition 2.D(8) & Imposed by NUREG-1216 Re SER on Operability of EDGs Mfg by Transamerica Delaval,Inc

ML18010B099
Person / Time
Site:	Harris
Issue date:	05/15/1993
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1216 NLS-93-118, NUDOCS 9305210070
Download: ML18010B099 (28)

Text

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REGULATO INFORMATION DISTRIBUTIONSTEM (RIDE)

ACCESSIOQ NBR:9305210070 DOC.DATE: 93/05/15 NOTARIZED: YES DOCKET FACIL:50'-"400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400

.AUTH.NAME AUTHOR AFFILIATION VAUGHN,G.E.

Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-63,removing license conditions for EDGs,specified by condition 2.D(8) a imposed by NUREG-1216 re SER on operability of EDGs mfg by Transamerica Delaval,Inc.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution D

NOiES:Application for permit renewal filed.

05000400 RECIPIENT ID CODE/NAME PD2-1 LA LEFN 1NTERNAL: ACRS NRR/DORS/OTSB NRR/DSSA/SCSB NRR/DSSA/SRXB OC/LFMB

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D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION

'ISTS FOR DOCUMENTS YOU DONT NEED!

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Carolina Power & Light Company P.O. Box 165 ~ New Hill,NC 27562 G.E. VAUGHN Vice President Harris Nuctear Plant NAY 15 1993 SERIAL:

NLS-93-118 10 CFR 50.90 United States Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR MAINTENANCE AND SURVEILLANCE Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50,90 and 2.101, Carolina Power

& Light Company (CP&L) hereby requests a revision to the Operating License (OL) for the Shearon Harris Nuclear Power Plant (SHNPP).

The proposed amendment would remove license conditions for the Emergency Diesel Generators (EDG) specified by condition 2.D.(8) and defined in Attachment 1 to Operating License NPF-63, as originally imposed by NUREG-1216, "Safety Evaluation'eport Related to.the Operability of Emergency Diesel'enerators Manufactured by Transamerica Delaval, Inc.,n dated August 1986.

These license conditions currently require engine teardowns for component inspections;

however, inspections that have been performed to date across the industry have not shown any significant wear patterns or problems that could not have been detected by other means (such as trending operational parameters) which do not require extensive teardown.

The TDI Owners Group provided an evaluation and justification for removal of license conditions in a generic submittal to the NRC dated December 8,

1992.

Subsequently, lead plant requests for license amendments have been submitted for Duke Power Company's Catawba Nuclear Station and Gulf States Utilities Company's River Bend Station.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details, in accordance with 10 CFR 50.91(a),

the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

no environmental assessment needs to be prepared in connection with the issuance of the amendment.

93052l 0070;,9305 i5 PDR ADOCK 05000400 P

PDR (1992AHHP)

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Dcpument Control Des MLS-93-118 / Page 2

In accordance with 10 CFR 50.91(b),

CPSL is providing the State of North Carolina with a copy of the proposed license amendment.

The next refueling outage for SHNPP is. currently scheduled to begin in March 1994.

Due to the extensive planning required to support EDG maintenance and other outage work, CPSL requests that this amendment be issued by December 15, 1993.

In order to allow time for procedure revision and orderly incorporation into copies of the Operating License, CP&L requests that the proposed amendment, once approved by the NRC, be issued such that implementation will occur within 60 days of issuance of the amendment.

Please refer any questions regarding this"'submittal to Mr. R.

W. Prunty at (919) 546-7318.

Yours very truly, LSR/jbw

Enclosures:

1.

Basis for Change Request 2.

10 CFR 50.92 Evaluation

'.'nvironmental Considerations cc:

Mr. Dayne H. Brown Mr. S.

D. Ebneter Mr. N. B.

Le Mr. J.

E. Tedrow G.

E. Vaughn, having been first duly sworn, did depose 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 commission expires:

P/jg/gcf-Notary (Seal)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 1 of 8 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR MAINTENANCE AND SURVEILLANCE BASIS FOR CHANGE RE UEST

~Back round The Transamerica Delaval, Inc.

(TDI) Owners Group was formed in late 1983.

following the crankshaft failure of an Enterprise emergency diesel generator (EDG) at the Shoreham Nuclear Plant.

The Owners Group developed a detailed Program Plan to provide for generic design review and quality reverification (DR/QR) of Enterprise EDGs.

This plan was reviewed and approved by the Nuclear Regulatory Commission (NRC) in a Safety Evaluation Report (SER) dated August 13, 1984.

Following issuance of the

SER, the Owners Group member utilities developed and implemented the DR/QR in response to and in accordance with the Program Plan.

The specific details of the DR/QR were submitted to the NRC for review and the results of this review were documented in NUREG-

1216, "Safety Evaluation Report Related to the Operability and Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc.," dated August 1986.

NUREG-1216 outlines specific provisions that were incorporated as a condition of the Shearon Harris Nuclear Power Plant (SHNPP) Operating License.

These conditions were imposed on SHNPP, as well as other plants with Enterprise EDGs being licensed at the time, since little operating history of these engines was available at the time of the DR/QR review.

Since that time, the industry has accumulated over 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, of operation of these engines.,

The inspections required by the license conditions have not revealed any problems from operation of the engines, and many utilities have determined that more damage is actually being done to the engines during teardown and inspection than from operation.

The bases for these conclusions are documented in the generic submittal of the TDI Owners Group entitled "Generic Licensing Submittal for Emergency Diesel Generators, Conditions of License for Utilities with Enterprise Engines,"

dated December 8,

1992 in a letter from J.

B. George and C.

W. Hendrix to the NRC.

That document is incorporated by reference to this request for license amendment and is the basis by which the following proposed change is sought.

Pro osed Chan e

The proposed amendment would remove license conditions for the Emergency Diesel Generators (EDG) specified by condition 2.D.(8) and defined in Attachment 1 to Operating License NPF-63, as originally imposed by NUREG-1216, "Safety Evaluation Report Related to the Operability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc.," dated August 1986.

Specifically, both condition 2.D.(8) and Attachment 1 to the Operating License would be removed.

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 2 of 8 Basis The primary function of the EDGs is to provide emergency AC power to the vital busses upon a safety injection signal or loss of off-site power.

The continued reliability and availability of the EDGs is contingent upon performing appropriate maintenance to the engines.

Sections 4.0 and 5.0 of the TDI Owners Group December 8,

1992 generic submittal provide the unavailability and unreliability data for Enterprise EDGs operated by the TDI Owners Group.

Data for the SHNPP engines are represented as Nos.

3 and 12 in the tables.

While the SHNPP unavailability and unreliability are slightly higher than some other engines, they are considered by the industry and NRC to be acceptable.

Further, CP6L expects these figures to improve by reducing engine teardowns currently required.

The following is an item-by-item discussion of the conditions currently required by Attachment 1 to the SHNPP Operating License:

Item 1:

Changes to the maintenance and surveillance programs for the TDI diesel

engines, as identified in Shearon Harris SSER No. 4, shall be subject to the provisions of 10 CFR 50.59.

The frequency of the major engine overhauls referred to in the license conditions below shall be consistent with Section IV.1. "Overhaul Frequency" in Revision 2 of Appendix II of the Design Review/Quality Revalidation report which was transmitted by letter dated May 1,

1986, from J.

George, Owners Group, to H. Denton, NRC.

CP&L Position:

The requirements of 10 CFR 50.59 are already a legal requirement and CPSL has a program for conducting reviews per 10 CFR 50;59.

Maintenance practices and changes to maintenance programs for safety-related equipment, including the EDGs, are subject to this program.

Having a s'eparate license condition is redundant and unnecessary; therefore, removal of this item is requested.

Based on CPGL and industry experience to date, licensees should have the freedom under 10CFR50.59 to revise their programs to incorporate enhancements that will increase engine availability and reliability.

This includes engine overhaul frequency.

Recent studies performed for the NRC (NUREG/CR-5078, PNL-6278) indicate that for approximately two years following a major engine

overhaul, EDGs, regardless of their manufacturer, exhibit increased unreliability.

This increase is attributed to several causes.

First, there is a high potential to introduce dirt and other substances that may harm the engine during disassembly.

Also, disturbing a precision fit system that "wears in" to seat mating surfaces (e.g.,

rings and liners, crankshafts and

bearings, connecting rods and bearings, etc.)

can result in alteration of wear patterns that may increase wear or actually cause wear to start and decrease the life of the component.

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 3 of 8 The results of the End of Cycle 2, One-Time 5-year, and recommended 5-year component inspections at SHNPP have shown minimal or no wear on major engine components and very few other component-related problems.

Performance of a complete engine overhaul on a time-based frequency is not appropriate and can lead to reduced reliability and increased unavailability.

Overhauls should be performance-based on condition monitoring and trending analysis, and thus, a

pre-specified interval should not be set.

Based on this and the data provided in the Owners Group December 8,

1992 submittal, CPGL requests that the requirement for an.overhaul frequency on a time-dependent basis be deleted.

Item 2:

Connecting rod assemblies shall be subjected to the following inspections at each major engine overhaul:

a.

The surfaces of the rack teeth shall be inspected for signs of fretting.

If fretting has occurred, it shall be subject to an engineering evaluation for appropriate correction action.

b. All connecting-rod bolts shall be lubricated in accordance with the engine manufacturer's instructions and torqued to the specifications of the manufacturer.

The lengths of the two pairs of bolts above the crankpin shall be measured ultrasonically pre-and post-tensioning.

c.

The lengths of the two pairs of bolts above the crankpin shall be measured ultrasonically prior to detensioning and disassembly of the bolts. If bolt tension is less than 93 percent of the value at installation, the cause shall be determined, appropriate corrective..action shall*be..taken, and the interval between checks of bolt tension shall be re-evaluated.

d. All connecting-rod bolts shall be visually inspected for thread damage (e.g., galling), and the two pairs of connecting rod bolts above the crankpin shall be inspected by magnetic particle testing (MT) to verify the continued absence of cracking.

All washers used with the bolts shall be examined visually for signs of galling or cracking, and replaced if damaged.

e.

Visual inspection shall be performed of all external surfaces of the link rod box to verify the absence of any signs of service induced distress.

f. All of the bolt holes in the link rod box shall be inspected for thread damage (e.g., galling) or other signs of abnormalities.

In addition, the bolt holes subject to the highest stresses (i.e.,the pair immediately above the crankpin) shall be examined with an appropriate nondestructive

" method to verify the continued absence of cracking.

Any indications shall be recorded for engineering evaluation and appropriate corrective action.

(1992AHHP )

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NLS-93-118 Page 4 of 8 CP&L Position:

The provisions for inspecting connecting rod assemblies are discussed in Section 3.52 of the TDI Owners Group generic submittal.

There have been no major problems with these components since completion of the DR/QR effort at SHNPP.

The reason for problems with connecting rods during early operations in the industry dealt with inadequate bolt preload.

The results presented in the generic submittal note that many hundreds of checks have been made on connecting rod bolts to determine if any relaxation of preload has occurred during operation.

These inspections have revealed no problems.

During Refueling Outage No. 4 at SHNPP, residual elongation measurements prior to connecting rod disassembly for engine 1B-SB were 99 percent of the elongation obtained during assembly of the connecting rods during Refueling Outage No

~ 2.

This confirms that relaxation has not occurred and the design changes implemented during the DR/QR have been effective, in'ealing with the concerns about this component.

Based upon the information presented in the generic submittal, this condition should be deleted for SHNPP.

Item 3:

The cylinder blocks shall be subjected to the following inspections at the interval specified in the inspections:

a.

Cylinder blocks shall be inspected for "ligament" cracks, "stud-to-stud" cracks and "stud-to-end" cracks as defined in a report by Failure Analysis Associates, Inc.

(FaAA) titled, "Design Review of TDI R-4 and RV-4 Series

<-Emergency>Diesel Generator. Cylinder.,Blocks."

(FaAA report...no..

FaAA;..84-9; 11.1),

dated December 1984.

(Note that the FaAA report specifies additional inspections to be performed for blocks with "known" or "assumed" ligament cracks).

The inspection intervals (i.e., frequency) shall not exceed the intervals calculated using 'the cumulative damage index model in the subject FaAA report.

In addition, inspection method shall be consistent with or equivalent to those identified in the subject FaAA report.

b.

In addition to inspections specified in the aforementioned FaAA report, blocks with "known" or "assumed ligament cracks" (as defined in the FaAA report) shall be inspected at each refueling outage to determine whether or not cracks have initiated on the top surface exposed by the removal of two or more cylinder heads.

This process shall be repeated over several refueling outages until the entire block top has been inspected.

Liquid-penetrant testing or a similarly sensitive nondestructive testing technique shall be used to detect cracking, and eddy current shall be used as appropriate to determine the depth of any cracks discovered.

(1992AHNP)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 5 of 8

c. If inspection reveals cracks in the cylinder blocks between stud holes of adjacent cylinders ("stud-to-stud" cracks) or "stud-to-end" cracks, this condition shall be reported promptly to the NRC staff and the affected engine shall be considered inoperable.

The engine shall not be restored to "operable" status until the proposed disposition and/or corrective actions have been approved by the NRC staff.

CP&L Position:

A thorough design review of this component was completed during the initial DR/QR review.

A finite element structural model revealed certain block areas that are subject to higher stresses than other areas.

A fracture mechanics analysis revealed that crack initiation is possible in certain circumstances;

however, these cracks were shown to arrest and not to propagate.

These potential cracks were found to be in areas that would produce a flow path for water to the block exterior and would be evident by visual check.

It was also shown that some of the block castings made during the construction of the Enterprise engines. may contain Widmanstaetten graphite which is an inclusion that weakens a grey cast iron casting.

SHNPP has tested for Widmanstaetten evidence of any of this material in inspection was performed on the EDG and no indications of cracking were graphite inclusions and has found no any of the blocks on either engine.

An 1A-SA blocks during Refueling Outage No.

4 found.

The original design and quality review of this component was noted to be conservative by the TDI Owners Group.

In addition, PNL-5600 noted that "If cumulative results iof these inspections over several power plant fuel cycles show that one or more of the inspections reveal nothing of significance, the scope a'nd frequency of the inspections could be reconsidered."

As a result of the previous inspections and the fact that no Widmanstaetten graphite has been found in the SHNPP engines, the design review has indeed shown the analysis to be conservative and that future inspections are not warranted.

Future maintenance programs should consider inspections any time the block top surface is exposed for other reasons, but this should not be a requirement.

This position is support by the TDI Owners Group generic submittal, Section 3.0.

CP&L therefore requests that this condition be removed.

Item 4:

The following air roll test shall be performed as specified below, except when the plant is already in an Action Statement of Technical Specification 3/4.8.1, "Electric Power Systems, A.C. Sources":

The engines shall be rolled over with the airstart system and with the cylinder stopcocks open prior to each planned start, unless that start occurs within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a shutdown.

The engines shall also be rolled over with the airstart system and with the cylinder stopcocks open after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, but no more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after engine shutdown and then rolled over again approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after each shutdown.

(In the event an engine is removed from service for any reason other than the rolling over procedure prior to expiration of the 8-hour or 24-hour periods noted above, that engine need not be rolled over while it is out of service.

The licensees shall air roll the engine over with the stopcocks open at the time it is returned to service).

The origin of any water detected in the cylinder must be determined

<1992AHNP)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 6 of 8 and any cylinder head which leaks due to a crack shall be replaced.

The above air roll test may be discontinued following the first refueling outage subject to the following conditions:

a. All cylinder heads are Group III heads (i.e., cast after September 1980).

b.

Quality revalidation inspections, as identified in the Design Review/Quality Revalidation report, have been completed for all cylinder heads.

c.

Group III heads continue to demonstrate leak-free performance.

This shall be confirmed with TDI prior to deleting air roll tests.

CP&L Position:

The purpose of this requirement is to prevent damage to the engine should a

leak occur that would allow fluid into a cylinder, creating high hydraulic loads should a start be attempted.

CP&L believes that this practice is of value and does not intend to delete it from its operational procedures at this time.

However, since the merits of performing this action are well known and understood, it should not be a condition of the Operating License.

Reliability'nd availability goals are positive incentives for continuing this practice.

Therefore, CP&L requests that this item be removed as a condition of the Operating License, consistent with other utilities.

Section 3.12 of the TDI Owners Group generic submittal addresses concerns related to the Group I, II, and III heads.

SHNPP has had no significant problems with heads in operation and has only Group III heads in service.

Item 5:

Periodic inspections of the turbochargers shall include the following:

a.

The turbocharger thrust bearings shall be visually inspected for excessive wear after 40 no-prelubed starts since the previous visual inspection.

b.

Turbocharger rotor axial clearance shall be measured at each refueling outage to verify compliance with TDI/Elliott specifications.

In addition, thrust bearing measurements shall be compared with measurements taken previously to determine a need for further inspection or corrective action.

c.

Spectrographic and ferrographic engine oil analysis shall be performed quarterly to provide early evidence of bearing degradation.

Particular attention shall be paid to copper level and particulate size which could signify thrust bearing degradation.

(1992AHMP)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 7 of 8 CP&L Position:

Periodic inspections of turbochargers is discussed in detail in Section 3.16 of the TDI Owners Group generic submittal of December 8,

1992.

The major issues dealing with turbochargers pertain to lubrication and fatigue of s'tationary vanes in the turbocharger casing.

With respect to the stationary vanes, there have been a total of four cases (industry wide) where missing vanes have been found and these missing vanes have passed through the rotating vane group without degradation of the turbocharger performing its design function.

Based on this operational history and the fact that SHNPP has not experienced any failures of this component, CP&L believes that future inspections of this item as a condition of the Operating License are unwarranted.

Regarding lubrication and bearing wear, the TDI Owners Group recommended design modifications to provide oil,flow to the turbocharger bearing while in standby or during unplanned and planne'd starts to improve bearing life.

These recommendations have been implemented at SHNPP to provide a continuous drip lubrication flow during standby.

For planned starts, SHNPP operates the installed electric-driven full flow auxiliary lube oil pump to establish proper oil pressure prior to start.

Also, CP&L intends to continue performing oil analysis in accordance with the vendor recommendations.

Therefore, CP&L requests that this license condition be removed.

Item 6:

Item 6 of Attachment'1 to the SHNPP Operating'License deals with requirements to be met prior to restart following the first refueling outage.

Accordingly, these requirements have been met. It is therefore no longer necessary to have this item contained in the Operating License.

Conclusions Removal of the TDI Diesel Engine Requirements from the SHNPP Operating License does not alter the Technical Specification 3.8.1 r'equirement to perform EDG maintenance in accordance with the TDI Owners Group recommendations.

A failure of an Emergency Diesel Generator (EDG) is not an initiator for any Final Safety Analysis Report (FSAR) Chapter 15 accident scenario.

Accordingly, there can be no increase in the probability of any accident previously evaluated.

Eliminating the teardowns and inspections would actually decrease the consequences of an accident because the availability and reliability of the engine would increase as a result of less frequent teardowns.

Therefore, removal of the existing conditions from the Operating License will not result in an increase in the consequences of an accident previously evaluated.

The removal of license conditions will not involve any modifications or additions to plant equipment and the design and operation of the unit will not be affected.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(1992AHHP)

ENCLOSURE 0 SERIAL:

'NLS-93-118 Page 8 of 8 The proposed removal of license conditions does not affect any parameters which relate to the margin of safety as defined in'he SHNPP Technical Specifications.

However, based upon both CP&L-specific and industry operating experience with these

engines, as well as NRC-sponsored studies, it is probable that the overall margin of safety for the plant will be increased based on a higher availability and reliability.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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ENCLOSURE 0 SERIAL:

NLS-'93-118 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR MAINTENANCE AND SURVEILLANCE 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists.

A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

Carolina Power 6 Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination.

The bases for this determination are as follows:

Pro osed Chan e

The proposed amendment would remove license conditions for the Emergency Diesel Generators (EDG) specified by condition 2.D.(8) and defined in Attachment 1 to Operating License NPF-63 as originally imposed by NUREG-1216, "Safety Evaluation Report Related to the Operability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc.," dated August 1986.

Specifically, both condition 2.D.(8) and Attachment 1 to the Operating License would be removed.

Basis This change does not involve a significant hazards consideration for the following reasons:

1.

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

A failure of an Emergency Diesel Generator (EDG) is not an initiator for any Final Safety Analysis Report (FSAR) Chapter 15 accident scenario.

Accordingly, there can be no increase in the probability of any accident previously evaluated.

Eliminating the teardowns and inspections would actually decrease the consequences of an accident because the availability and reliability of the engine would increase as a result of less frequent teardowns.

Therefore, removal of the existing conditions from the Operating License will not result in an increase in the consequences of an accident previously evaluated.

2.

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The removal of license conditions will not involve any modifications'r additions to plant equipment and the design and operation of the unit will not be affected.

Therefore, the proposed change does not create the (1992AHHP)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 2 of 2 possibility of a new or different kind of accident from any accident previously evaluated.

3.

The proposed amendment does not involve a significant reduction in the margin of safety.

The proposed removal of the Emergency'iesel Generator license conditions from the Operating License does not affect any parameters which relate to the margin of safety as defined in the Technical Specifications.

However, based upon both plant-specific and industry operating experience with these engines, it is probable that the overall margin of safety for the plant will be increased based on a higher availability.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

(1992AHNP )

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.

50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR MAINTENANCE AND SURVEILLANCE ENVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.

A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not:

(1) 'involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site; (3) result in an increase in individual or cumulative occupational radiation exposure.

Carolina, Power

& Light Company has reviewed this request and determined that the proposed amendment'eets the eligibilitycriteria 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 needs to be p'repared in connection with the issuance of the amendment.

The basis for this determination follows:

Pro osed Chan e

The proposed amendment would remove license conditions for the Emergency Diesel Generators (EDG) specified by condition 2.D.(8) and defined in Attachment 1 to Operating License NPF-63 as originally imposed by NUREG-1216, "Safety Evaluation'l Report Related

'to, the Operability of Emergency Diesel Generators Manufactured by. Transamerica Delaval, Inc.," dated August 1986.

Specifically, both condition 2.D.(8) and Attachment 1 to the Operating License would be removed.

Basis The change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1.

As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.'.

The proposed amendment does not result in a significant change in the types or significant increase in the amounts of'any effluents that may be released off-site.

The proposed amendment does not introduce any new equipment, nor does it require existing systems to perform a different type of function than they are currently designed to perform.

As such, the change can not affect the types or amounts of any effluents that may be released off-site.

(1992AHHP)

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ENCLOSURE 0 SERIAL:

NLS-93-118 Page 2 of 2 3.

The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

The proposed change does not result in additional work or surveillances within radiation controlled areas and does not affect personnel radiation exposure.

Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

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