ML20029A550

Application for Amends to Licenses DPR-62 & DPR-71,changing Tech Spec 4.8.1.1.2.d to Increase Surveillance Interval for Emergency Diesel Generators from 18 to 24 Months

ML20029A550
Person / Time
Site:	Brunswick
Issue date:	02/19/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029A551	List: ML20029A550 ML20029A552
References
NLS-91-020, NLS-91-20, NUDOCS 9102250207
Download: ML20029A550 (7)

Text

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1 Coronna Power & UgM Compsh P O. Dos 1651

• Raleigh N C. 27002 SERIAL: NLS 91-020 FEB 191991 10CFR50.90 G. E. vAUGHN Vice President Nuc est Servees Department United States Nuclear Regulatory Commission A'ITENTION: Document Control Desk Washington, DC 20555

. BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR 71 & DPR 62

- REQUEST FOR LICENSE AMENDMENT '

24-MONTil DIESEL GENERATOR SURVEILLANCE INTERVAL Gentlement-s In accordance v>lth the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101,

. Carolina Power & Light Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (llSEP), Units 1 and 2.

Technical S;iecification 4.8.1.1.2.d requires certain surveillances of the emergency diesel igenerators be performed "At least once per 18 months " ." The proposed amendment revises the surveillance interval associated with Technical Specification 4.8.1.1.2.d from 1 18 months to 24 months.

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

Enclosure 2 details the basis for the Company's determination that the proposed changes do not invalve a^significant hazards consideration.

Enclosure 3 provides th'e proposed Technical Specification pages for Unit L Enclosure 4 provides the proposed Technical Specification pages for Unit 2. <

Currently, Surveillance Requirement 4.8.L1.2.d inspections are planned to be performed

< .during t.he Unit 2 surveillance testing obtage scheduled to begin in June 1991; These

surveilla'nces represent a significant portion of the required work for this outage.

Issuance of the requested amendment will allow performance of the surveillances during the upcom_ing Unit 2 Reload 9 outage currently scheduled to begin in September 1991,

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thereby saving approximately 1 week of critical path outage time during the Spring 1991  ;

g outage. Therefore, in order to realize this reduction in outage duration, CP&L requests

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Document Control Desk j NLS 91020 / Page 2 l that the NRC approve the requested license amendment by hiay 15,1991, in order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.

Please refer any questions regarding this submittal to hir. hi. R. Oates at (919) 546 6063.

Yours very truly, ay l

/ n G. E. Vaughn GEV/ MAT

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Technical Specification Pages - Unit 1 4 Technical Specification Pages Unit 2 cc: hir. Dayne II. Brown hir. S. D. Ebneter hir. N. B.12 Mr. R. L Prevatte G. E. Vaughn, having been firsi 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 & Ught Company.

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l 1- ENCLOSURE 1 BRUNSWICK STEAhi ELECI'RIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50 325 & 50-324 OPERATING LICENSES DPR-71 & DPR 62 REQUEST FOR LICENSE AhiENDhiENT 24 hiONTil DIESEL GENERATOR SURVEILLANCE INTERVAL BASIS FOR CilANGE REQUEST Proposed Change Technical Specification 4.8.1.1.2.d requires certain surveillances of the emergency diesel generators be performed "At least once per 18 months ." The proposed amendment revises the rurveillance interval associated with Technical Specification 4.8.1.1.2.d from 18 months to 24 months.

Basis Brunswick 1 and Brunswick 2 were designed and are operated with a shared configuration of the four diesel generators. Diesel generators 1,2,3, and 4 supply emergency buses El, E2, E3, and E4 respectively. Emergency buses El and E2 are associated with Brunswick-1 c.nd E3 and E4 with Brunswick 2. In addition, selected redundant loads, suti, as two residual heat removal pumps, are normally sup;) lied by the opposite onit's emergency buses. While performing the required inspection of a given diesel generator, the loads associated with that diesel generator are subject to their Limiting Condition for Operation requirements.

Technical Specification 4.8.1.1.2.d requires certain surveillances (4.8.1.1.2.d.1 through 4.8.1.1.2.d.7) of the diesel generators be performed at least once per 18 months during shutdown. This 18 month interval has caused difficulties in the scheduling of the diesel generator surveillances. The Brunswick cores are designed to provide extended operating cydes, in addition, Brunswick Plant outages have historically been of sufficient duration that either the diesel generator inspection would be required to be performed at the beginning of the outage to satisfy the 18 month surveillance interval and again at the enri af the outage so that the 18 month interval would not expire prior to the next scheduled refueling outage or schedule a mid-cycle surveillance outage for diesel gener~or surveillances. These two factors make an 18 month diesel generator surveillance interval impractical.

The proposed amendment revises the interval at which the seven surveillances (4.8.1.1.2.d.1 through 4.8.1.1.2..d.7) associated with Technical Specification 4.8.1.1.2.d are performed from at least once per 18 months to at least once per 24 months. The justification for the extended surveillance interval is based on the high degree of El-1

i reliability demonstrated by the Brunswick diesel generators and discussions with the  !

diesel manufacturer.

Over the past five years there have been no failures of the surveillances required by )

Technical Specifications 4.5.2.1.2.d.1, d.2, d.3, d 4, d.5, d.6, and d.7. This successful diesel Eenerator testing history demonstrates the high reliability of the Brunswick diesel 4

- generators. As such, the effects of extending the surveillance ir.terval to 24 months would be negligible and will actually improve overall diesel generator availability l because the diesel generators will not be required to be removed from service as frequently as is currently necessary.

In addition, the diesel manufacturer has indicated that diesel generator reliability can be maintained by performing the tear-down inspection required in Technical Specification 4.8.1.1.2.d.1 once per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of diesel operation. During a typical fuel cycle, a diesel

- generator will be run far less than 1000 bours (anywhere from approximately 80 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />).

Based on the above, the proposed extension of the 18 month diesel generator surveillance interval to 24 months will not significantly affect the diesel generators' ability to perform their intended safety function.

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4 ENCLOSURE 2 URUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 d: 50-L OPERATING LICEN3ES DPR 71 & DPR-62 REQUEST FOR LICENSE AMENDMENT 2/ MONTil DIESEL GENERATOR SURVEILLANCE INTERVAL BASIS FOR CilANGE REQUEST

_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 accioent from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this determinat!an are as follows:

Prooosed Change

. Technical Specification 4.8.1.1.2.d requires certain surveillances of the emergency diesel generators be performed "At least once per 18 months ".' The proposed amendment revises the surveillance interval associated with Technical Specification 4.8.1.1.2.d from 18 months to 24 months.

. DAL The 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.

Extending the diesel generator surveillance interval from 18 months to 24 months will not result in a significant increase in the probability of the diesel generators failing to perform their intended safety function, llistorically, the diesel generators have demonstrated a high degree of reliability. Over the past five years there have been no failures of the surveillances required by Technical E21

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Specifications 4.8.1.1.2.d.1, d.2, d.3, d.4, d.5, d.6, and d.7. This successful diesel generator testing history demonstrates the high reliability of the Brunswick diesel generators. As such, the effects of extending the suncillance interval to 24 months would be negligible and will actually improve overall diesel generator availability because the diesel generators will not be required to be removed from service as frequently as is currently necessary.

In addition, the diesci manufacturer has indicated that diesel generator reliability can be maintained by performing the tear-down inspection required in Technical Specification 4.8.1.1.2.d.1 once per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of dicsci operation. During a typical fuel cycle, a diesel generator will be run far less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (anywhere from approximately 80 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />). Therefore, the proposed amendment does not involve a significant increase in the probability of a previously evaluated accident.

The diesel generator surveillance requirements are intended to maintain diesel ,

generator reliability at a level which assures that adequate electrical power is ,

available under the most limiting accident conditions within the accident analysis for the Brunswick Plant. The most limiting accident condition includes the loss of all off site power and the assumed single failure of one diesel generator. The proposed surveillance frequency will not adversely affect diesel generator availability. As stated above, past diesel generator performance has indicated a high degree of reliability over an extended period of time, increasing the inspection interval to 24 months will not significantly affect this reliability. In addition, the vendor e commendation for tear down inspect!an of the diesel

- generators at least once per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of diesel operation is not affected by the revised surveillance interval since during a typical fuel cycle a diesel generator will be run significantly less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. As such, the proposed surveillance interval maintains an adequate level of assurance of diesel generator availability in the event of a design bases accident and, therefore, the proposed amendment does not involve a significant increase in the consequences of a previously evaluated accident.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed amendment only extends the surveillance intaval for the diesel generators. There is no change to the plant or its manner of operation. Also, there are no changes to the surveillance acceptance criteria. Therefore, the proposed change can not create the possibility of a new or different kind of accident from any previously evalunted.

3. The proposed amendment does not 'nvolve a significant reduction in the margin of safety. As demonstrated in items 1 and 2 above, exten(ing the diesel generator E2-2 l

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4 1 surveillance interval from 18 months to 24 months will not significantly affect diesel generator reliability, availability, or the ability of the diesel generators to perform their intended safety function. Past diesel generator performance has indicated a high degree of reliability over an extended period of time, increasing the inspection interval to 24 months will not significantly affect this reliability, in addition, there are no changes to the surveillance acceptrince criteria. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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