ML18102B661
| ML18102B661 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/04/1997 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18102B662 | List: |
| References | |
| GL-89-15, GL-94-01, GL-94-1, LCR-S97-18, LR-N970563, NUDOCS 9711170095 | |
| Download: ML18102B661 (12) | |
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Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, 'Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N970563 LCR S97-18 NOV o*4 1997 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIE.SEL GENERATOR MAINTENANCE
_SALEM GENERATING STATION UNIT NOS. 1AND2 DOCKET NOS. 50-272 AND 50-311 FACILITY OPERATING LICENSE NOS. DPR 70 AND DPR-75 Ladies and Gentlemen:
In accordance with the requirements of 10CFR50.90, Public Service Electric & Gas Company (PSE&G) hereby requests a revision to the Technical Specifications (TS's) for Salem Generating Station Unit Nos. 1 and 2. In accordance with the requirements of the 10CFR50.91 (b)(1 ), a copy of this-submittal has been forwarded to the State of New Jersey.
The changes proposed herein revise the Emergency Diesel Generator (EOG)
Technical Specifications (TS) 3/4.8.1. Specifically, PSE&G proposes to delete surveillance requirement 4.8.1.1.2.d.1, which calls for the diesels to be subjected to an inspection based on vendor recommendations at least once per 18 months during shutdown. This proposed change is consistent with the NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," and is similar to a change approved at the Hope Creek Generating Station via License Amendment 74, dated June 29, 1995.
The proposed changes would also eliminate the accelerated testing requirements of TS Table 4.8-1 in favor of EOG performance monitoring in accordance with the maintenance rule of 10CFR50.65. The TS 4.8.1.1.4 requirement to submit a 30 day Special Report for diesel failures would also be deleted. These changes are consistent with the TS improvements endorsed by NRC Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," dated May 31, 1994. Similar changes have been approved by NRC_ for the Waterford Steam Electric Station, Unit 3(Amendment126, dated April 21, 1997) ~
and Turkey Point Units 3 and 4 (Amendments 181 and 175, dated December 28, 1995). I r
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NOV 04 1997 Document Control Desk 2 LR-N970563 The proposed changes have been evaluated in accordance with 10CFR10.91 (a)(1 ),
using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request does not involve a significant hazards consideration.
The technical justification for the requested changes is provided in Attachment 1. The 10CFR50.92(c) analysis supporting the no significant hazards determination is provided in Attachment 2. The marked-up Technical Specification pages affected by this proposal are provided in Attachment 3.
Due to the extended outage at Salem Unit No. 2, the 18 month inspection of surveillance requirement 4.8.1.1.2.d.1 would become overdue for all three EDG's prior to commencement of the next scheduled refueling outage. The earliest overdue date for the Unit No. 2 EDG's is January 26, 1998 for the 2A EOG. PSE&G therefore requests expeditious review and* approval of the proposed changes.
If you have any questions concerning the enclosed information, we would be pleased to discuss them with you.
Sincerely, Affidavit Attachments
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Document Control Desk 3 NOV 0 4 1997 LR-N970563 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Ms. M. Evans (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625 95-4933
REF: LR-N970563 STATE OF NEW JERSEY)
) SS.
COUNTY OF SALEM )
L. F. Storz, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Operations for the Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem, Unit Nos. 1 and 2 are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this 'f- day of /)/6 v e...,,n/x. ;-. , 1997
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No~ry Public of New Jersey RA A noWELl BARBA * .-
- NOTAIW PUBLIC OF NEW JERSEY My Commission Expires Dec. 2, 1998 23 My Commission expires on _ _ _ _ _ _m"""""n-'-21_so_3_ _ _ __
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Document Control Desk LR-N970563 Attachment 1 LCR S97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR MAINTENANCE REQUESTED CHANGE AND PURPOSE The following changes are proposed herein:
- 1. Delete Salem Generating Station (SGS) Unit 1 and 2 Technical Specification (TS) 4.8.1.1.2.d.1, which requires each Emergency Diesel Generator (EOG) be demonstrated operable at least once per 18 months during shutdown by:
"Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service."
- 2. Revise SGS Unit 1 and 2 TS 4.8.1.1.2.a and delete Table 4.8-1, to eliminate accelerated diesel generator testing requirements in lieu of monthly testing.
- 3. Delete SGS Unit 1 and 2 TS 4.8.1.1.4, to remove special reporting requirements for diesel failures.
- 4. TS Bases Section 3/4.8.1 and 3/4.8.2 are being revised to be consistent with changes 1, 2 and 3 above.
The purpose of these changes is to adopt TS improvements consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," and NRG Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," dated May 31, 1994 (GL 94-01 ).
These changes:
- Provide increased flexibility for performing preventive maintenance based on manufacturer's recommendations, and eliminate any potential conflict between maintenance intervals supported by the manufacturer and the 18 month interval prescribed by the current TS;
- Enable EOG maintenance to be dictated by performance as monitored in accordance with the maintenance rule (1 OCFRS0.65), in lieu of imposing accelerated surveillance test requirements if the number of failures in the last 20 tests exceeds one; and
- Eliminate the administrative burden of reporting EOG failures, deferring to the reporting criteria of 10CFRSO.72 and 10CFRSO.73.
The changes proposed herein consist of NRG-endorsed improvements to the EOG Technical Specifications.
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Document Control Desk LR-N970563 LCR S97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS
" EMERGENCY DIESEL GENERATOR MAINTENANCE BACKGROUND The SGS Unit 1 and 2 TS for EDG's generally conform to earlier versions of the Standard Technical Specifications based on Revision 1 of Regulatory Guide 1.108 and Generic Letter 84-15. The SGS TS include a requirement to perform a diesel inspection, based on the manufacturer's (ALCO) recommendations, at least once per 18 months during shutdown. The TS also requires the monthly EOG operability test to be performed on a weekly frequency if there have been more than one valid test failure in the past 20 tests, and require a 30-day Special Report for EOG failures.
JUSTIFICATION OF THE REQUESTED CHANGES 18-Month Inspection The inspection required per TS 4.8.1.1.2.d.1 is accomplished by performing a set of preventive maintenance (PM) activities in accordance with manufacturer's recommendations. Diesels in nuclear standby service applications are generally exposed to fewer operating hours and more controlled environmental conditions than other applications. The manufacturer endorses the performance of major PM's (e.g.,
valve clearance adjustments, crankshaft deflection and thrust measurements) on a refueling outage basis (one and one-half or two year nominal operating cycle), rather than on a prescribed calendar-year frequency.
The balance of the EOG surveillance requirements in TS 4.8.1.1.2 will continue to demonstrate operability of the EDG's. As indicated in revised Bases Section 3/4.8.1 and 3/4.8.2, PM based on manufacturer's recommendations will continue to be performed. The proposed change would effectively eliminate the prescribed "18 months during shutdown" frequency for the diesel inspection imposed by the current TS. The improved Standard Technical Specifications of NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants" do not include a requirement to perform a diesel inspection based on manufacturer's recommendations.
The inspections currently performed per TS 4.8.1.1.2.d.1 will be controlled as part of the preventive maintenance (PM) program. Changes to the PM program are controlled by the 10CFR50.59 process. The accompanying TS Bases change reflects our intention to continue to perform diesel PM's based on manufacturer's recommendations. As described below in the Accelerated Testing section, the EDG's are subject to the provisions of the maintenance rule of 10CFR50.65, which ensures acceptable levels of diesel reliability and availability.
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Document Control Desk LR-N970563 LCR S97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS
" EMERGENCY DIESEL GENERATOR MAINTENANCE The proposed change to TS 4.8.1.1.2.d.1 is similar to a change approved at the Hope Creek Generating Station (Docket No. 50-354) via License Amendment 74, dated June 29, 1995.
Salem Unit 2 returned from outage on August 30, 1997. Salem Unit 1 will return from its outage early in 1998. Both of these outages were over two years in length. The diesel generator inspections were performed during these outages, however because of the length of the outages, they will come due prior to the next refueling outages (1R13 for Unit 1, currently scheduled for September 1999, and 2R10 currently scheduled for January 1999). Issuance of the requested change to the Technical Specifications would avoid shutting the units down to comply with the existing surveillance requirements. The earliest overdue date for the Unit No. 2 EDG's is January 26, 1998 for the 2A EOG.
Original guidance provided by the manufacturer quoted a frequency of 2920 hours0.0338 days <br />0.811 hours <br />0.00483 weeks <br />0.00111 months <br /> operating hours between performance of major PM's. The Salem Diesels have an average total lifetime running hours (through September 24, 1997) of 1326 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.04543e-4 months <br />, less than half of the manufacturer's original number for operating hours between performances of the PM. The Unit 2 diesels have experienced an average of 60 operating hours since performance of their inspections during 2R09 and are projected to experience 35 additional hours each prior to the next refueling outage (2R10). At the time of preparation of this LCR the Unit 1 diesels were undergoing these same inspections and were projected to experience 65 additional operating hours each prior to 1R13. This includes 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an endurance run subsequent to the current inspections. In addition to the relatively low number of total operating hours on the diesels, the recent surveillance history has been very good. Unit 2 has had one failure in its last 100 valid diesel starts and Unit 1 has had 4 failures in its last 100 starts, the last Unit 1 failure having occurred in February 1996. The operating history and the continuation of the other surveillance requirements provide assurance of the reliability of the diesels through to the next refueling outages.
Accelerated Testing and Special Reporting Requirements NRC Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," dated May 31, 1994, endorses the elimination of accelerated EOG testing from the TS based on implementation of the maintenance rule for the EDG's. PSE&G conforms to the guidance of Regulatory Guide 1.160, Revision 1, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for the SGS Unit No. 1 and 2 EDG's, including the following key elements identified in Generic Letter 94-01:
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Document Control Desk SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS
- LR-N970563 LCR 597-18 EMERGENCY DIESEL GENERATOR MAINTENANCE
- performance criteria for EOG reliability and unavailability, under paragraph (a)(2) of 10CFR50.65;
- appropriate root cause determination and corrective action following a single maintenance-preventable failure; and
- goals and EOG performance monitoring under paragraph (a)(1) of 10CFR50.65 if any performance criterion is not met, or if a second maintenance-preventable failure occurs.
The objective of the Generic Letter 94-01 changes is to prevent EOG failures via maintenance, surveillance testing, performance monitoring and failure cause analysis, such that TS-required accelerated testing is not warranted. In addition, the reporting requirements of 10CFR50.72 and 50.73 obviate the need to report individual failures of EDG's via Special Reports. The associated Bases changes provide clarification that the accelerated testing and special reporting provisions of the Regulatory Guide 1.108-based TS are being superseded by the proposed TS based on maintenance rule implementation.
The proposed changes are consistent with the NRC-endorsed line item TS improvements and are similar to those approved for the Waterford Steam Electric Station, Unit 3 (Amendment 126, dated April 21, 1997) and Turkey Point Units 3 and 4 (Amendment 181 and 175, dated December 28, 1995).
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Document Control Desk LR-N970563 LCR-S97-18 SALEM GENERATING STATION UNIT NOS. 1AND2 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR MAINTENANCE REQUESTED CHANGE The proposed changes to the Salem Generating Station (SGS) Unit No. 1 and 2 Technical Specifications (TS) would: delete the TS 4.8.1.1.2.d.1 requirement for an 18 month diesel inspection based on manufacturer's recommendations; revise SGS Unit 1 and 2 TS 4.8.1.1.2.a and delete Table 4.8-1, to eliminate accelerated diesel generator testing requirements in lieu of monthly testing; and delete SGS Unit 1 and 2 TS 4.8.1.1.4, to remove special reporting requirements for diesel failures. In addition TS Bases Section 3/4.8.1 and 3/4.8.2 are being revised to be consistent with the proposed TS changes.
These changes:
- Provide increased flexibility for performing preventive maintenance based on manufacturer's recommendations, and eliminate any potential conflict between maintenance intervals supported by the manufacturer and the 18 month interval prescribed by the current TS;
- Enable EOG maintenance to be dictated by performance as monitored in accordance with the maintenance rule (1 OCFRS0.65), in lieu of imposing accelerated surveillance test requirements if the number of failures in the last 20 tests exceeds one; and
- Eliminate the administrative burden of reporting EOG failures, deferring to the reporting criteria of 10CFRSO.72 and 10CFR50.73.
The changes proposed herein consist of NRG-endorsed improvements to the EOG Technical Specifications.
BASIS Deletion of TS 4.8.1.1.2.d.1 requirement for an 18 month diesel inspection. Bases Section 3/4.8.1 and 3/4.8.2.
The proposed change is consistent with the improved Standard Technical Specifications (NUREG-1433). NUREG-1433 does not include a surveillance requirement to perform an inspection of the diesel generators in accordance with manufacturer's recommendations. The inspection is a preventive maintenance activity and is controlled by the plant preventive maintenance program and is in conformance with the provisions of the Maintenance Rule. Revisions to the preventive maintenance program are controlled using the 10CFRS0.59 process. In addition the Technical 1
Document Control Desk LR-N970563 Attachment 2 LCR-S97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR MAINTENANCE Specifications will continue to contain surveillance requirements that demonstrate the functional capability of the diesel generators.
Since PSE&G will utilize EDG performance history, engineering analyses and manufacturer's recommendations to perform diesel generator inspections/maintenance as appropriate, removal of the surveillance requirement 4.8.1.1.2.d.1 from the Technical Specifications will have no detrimental effect on operability or reliability of the diesel generators.
Revision of TS 4.8.1.1.2.a and deletion of Table 4.8-1, to eliminate accelerated diesel generator testing requirements in lieu of monthly testing, and deletion of TS 4.8.1.1.4, to remove special reporting requirements for diesel failures.
Revision of Bases Section 3/4.8.1 and 3/4.8.2 These changes incorporate recommendations and suggestions from Generic Letter (GL) 94-01 "Removal of Accelerated Jesting anq Special Reporting Requirements for Emergency Diesel Generators".
The objective of the changes recommended by Generic Letter 94-01 is to prevent EDG failures via maintenance, surveillance testing, performance monitoring and failure cause analysis, such that TS-required accelerated testing is not warranted. In addition, the reporting requirements of 10CFRSO.72 and 50. 73 obviate the need to report individual failures of EDG's via special reports. The associated Bases changes provide clarification that the accelerated testing and special reporting provisions of the Regulatory Guide 1.1 OB-based TS are being superseded by the proposed TS based on maintenance rule implementation.
- 1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change deleting the requirement for an 18 month diesel inspection is consistent with the improved Standard Technical Specifications (NUREG-1433) and does not result in any changes to the existing plant design. The Salem preventive maintenance program utilizes diesel generator performance history, engineering analyses and manufacturer's recommendations as appropriate for determining diesel generator inspection requirements. The Technical Specifications will continue to contain surveillance requirements that demonstrate the functional capability of the diesel generators. The change does not impact the ability of the diesel generators or the AC electrical power sources to perform their function, nor result in a significant increase in the consequences of any accident previously evaluated. The diesel generators will continue to function as designed.
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Document Control Desk LR-N970563 LCR-S97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR MAINTENANCE PSE&G has implemented the provisions of the maintenance rule for EDG's, including the appropriate regulatory guidance. This provides a program which assures EOG performance. The elements of this program include the performance of detailed root cause analysis of individual failures, effective corrective actions taken in response to individual failures, and implementation of preventive maintenance consistent with the Maintenance Rule. Additionally, the proposed changes (elimination of accelerated diesel generator testing requirements of TS 4.8.1.1.2.a in lieu of monthly testing and deletion of special reporting requirements for diesel failures), do not delete the surveillance requirements but rather set their frequency at every 31 days. Monitoring the effectiveness of EOG maintenance and continuing surveillance testing will ensure that the diesel generators will perform their intended functions and will minimize failures. As is noted in the recommendations of GL 94-01, because PSE&G is monitoring and maintaining EOG performance in accordance with the provisions of 10CFR50.65, there is no longer a need for special reporting requirements.
Since the changes do not affect the assurance of diesel generator reliability or I.. , ' ..
operability as discussed above, there is no significant increase in the probability or consequences of any accident previously evaluated.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously analyzed.
This request does not result in any change to the plant design nor does it involve a significant change in current plant operation.* The diesel generators are inspected utilizing diesel generator operating history, engineering analyses and manufacturer's recommendations as appropriate, and the remaining surveillance requirements continue to demonstrate the functional capability of the diesel generators.
Changing the surveillance frequency of TS 4.8.1.1.2.a to 31 days vice the existing frequency as determined by Table 4.8-1, does not create a new or different kind of accident. Deletion of special reporting requirements, appropriate in light of the monitoring and maintenance in conformance with 10CFR50.65, and reliance on the reporting requirements of 10CFR50.72 and 10CFR50.73, does not create the possibility of a new or different kind of accident.
The proposed changes do not result in any change to the plant design nor do they involve a significant change in current plant operation. No new failure modes will be introduced. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
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Document Control Desk LR-N970563 LCR-S97-18 SALEM GENERATING STATION UNIT NOS. 1AND2 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR MAINTENANCE
- 3. The proposed change does not involve a significant reduction in a margin of safety.
The proposed request does not adversely impact the reliability of the diesel generators.
As stated above, the diesel generator operating history, engineering analyses and the manufacturer's recommendations will be utilized as appropriate to perform diesel generator inspections. Additionally, other Technical Specification surveillance requirements will continue to demonstrate the functional capability of the diesel generators. The diesel generators will continue to perform their design functions.
Noting the monitoring and maintenance being performed in conformance with 10CFRS0.65, revision of the frequency of surveillance testing of 4.8.1.1.2.a does not adversely impact the reliability of the diesel generators. Deletion of the special reporting requirements of 4.8.1.1.4 does not impact the operability or the reliability of the diesel generators.
This request does not involve an adverse impact on diesel generator operation or reliability. Since the diesel generator function is not affected by the proposed change, this request does not involve a significant reduction in a margin of safety.
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