ML20029C022

Application for Amend to License DPR-62,changing Tech Spec 4.8.1.1.2.d to Permit one-time Extension of Surveillance Interval for Diesel Generator Until 911031 to Permit Surveillances to Be Performed During Reload Outage 9

ML20029C022
Person / Time
Site:	Brunswick
Issue date:	03/18/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029C023	List: ML20029C022 ML20029C025
References
NLS-91-066, NLS-91-66, NUDOCS 9103250100
Download: ML20029C022 (7)

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_;g P.O. Box 1661 e RaWgh, N C. N602 - l SERIAL: - NLS 91-066-MAR 181991 10CFR50.90 0; E. VAUGHN . 91TSB01 ,

V6ce President i Nucteer Services Department ' h United States, Nuclear Regulatory Commission ATTENTION: Document Control Desk

-Washington,.DC--20555

-BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 1 DOCKET No.L 50-324/ LICENSE NO. DPR 62

-REQUEST FOR LICENSELAMENDMENT  ;

i ONE-TIME EXTENSION-0F DIESEL CENERATOR SURVEILLANCE INTERVAL Centlemen:.

In accordance with the Code of Federal Regulations,; Title 10 -Parts 50.90 k Land 2.101,1 Carolina. Power &. Light Company hereby requests'a revision-to the nTechnical; Specifications for the Brunswick Steam Electric Plant-(BSEP),

iUnit-2.

1 Technical 1 Specification 4.~8.1.1.2.d requires certain surveillances l f(4.8.1.1.2;d.1 through 4.8.1.1.2.d.7) of the emergency diesel generators be 1' performedj"Atileast' once per 18 months during. shutdown." The proposed

- amendment allows a: one-time only extension of' the surveillance interval Jassociated with Technical Specification-4.8.1.1.2.d until October- 31,.1991.

'This extension' allows performance of the required surveillances during the-.

Lupcoming Unit:2 Re1~oad 9 outage, currently; scheduled to begin in September i

1991.

Enclosure,1 provides-a detailed description of the proposed changes and the  ;

' basis-for;the changes,- -,

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1 Enclosure 2-details.the basis for the Companyfs determination that the -

. proposed changas do not involve a significant hazards consideration, h

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Enclosure .-3 provides the proposed Technical Specification page for Unit 2.

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. Technical. Specification 4.8.1.1.2.d required surveillances start becoming du_e-1

by

Ju_1y 29, 1991 for diesel generator 3 and July 30,- 1991 for diesel generator 1

-4;(these dates: include.the 25% extension allowed by Technical Specification .i L4.0.2). ; currently,. these surveillances are planned;to be performed during the -

Unit 2 surveillance. testing . outage scheduled to begin in June 1991. These-surveillances ~ represent ~a :significant portion of ~ the required work for- this i outage. . Issuance of the requestod amendment will' allow performance of=the H surveillances during the, upcoming Unit =2 Reload 9 outage currently ~ scheduled to begin in September 1991, thereby saving approximately 1 week of critical-path outage time during the Spring 1991 outage. Therefore, in order to realize this reduction in outage duration', CP&L requests that the NRC approve g/ .

9103250100 910318 Yl I PDR ADOCK 05000324 I p PDR ,

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• Document Control Desk NLS 91 066 / Page 2 e the requested license amendment by May 15, 1991. Issuance of this amendment,

!along with other actions being pursued by CP&L may obviate the need for a mid-

~ cycle outage on Unit 2.

In. order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed _ ,

amendments -Ionce approved by the NRC, be issued with an effective date to be -i no later than 60 days from the issuance of the amendment.

On. February 19, 1991,- CP&L submitted a license amendment request entitled Request for License Amendment, 24 Month Diesel Generator Surveillance Interyc1 (NLS 91 020). .This submittal was made in anticipation of generic guidance regarding 18 month surveillance intervals expected to.be issued by the NRC in the first quarter-of 1991. Based on discussions with the NRR staff, the decision was made to-re submit.the diesel generator license-amendment as a one time _only extension because issuance of the Generic Letter was not expected in time to support CP&L's need date of May 15, 1991. As such, this suba.lttalisupersedes,.in its entirety, the February 19, 1991 license amendment request regarding: diesel generator surveillance intervals. Please refer any questions regarding this submittal to Mr. M. R. Oates at (919) 546 6063.

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Yours very truly,

/ y n C. E. Vaughn GEV/ MAT

Enclosures:

1. " Basis for. Change Request

2. :10 CFR-50.92 Evaluation-

3. Technical Specification Page - Unit'2

cc: -Mr. Dayne-H.. Brown Mr. S. D. Ebneter-Mr. N. B 'Le-

- Mr. R. L. Prevatte -

G. E. Vaughn, having-been first duly sworn, did depose and say that the infor-madon . contained herein is true and correct to the best of his information, t knowledge. and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company, pHttilipp, N& * $ $

Notary (Seal) [ ggy Q, My comnission expires: d2[b/qp j m j

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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2  !

NRC DOCKET 50-324 OPERATINC LICENSE DPR.62 REQUEST FOR LICENSE AMENDMENT ONE-TIME EXTENSION OF DIESEL CENERATOR SURVEILLANCE INTERVAL BASIS FOR CHANCE REQUEST-Proposed Change Technical Specification 4.8.1.1.2.d requires that certain surveillances (4.8.1,1.2.d.1 through 4.8.1.1.2.d 7) of the emergency diesel generators be performed "At least once per 18 months during shutd:vn." The proposed amendment allows a one-time only extension of the surveillance interval associated with-Technical Specification 4.8.1.1.2.d until October 31, 1991.

This extension allows performance of the required surveillances during the upcoming Unit 2 Reload 9 outage, currently scheduled to begin in September 1991.

Basis 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.

Typically, diesel generator surveillances are performed near the beginning of a refueling outage'due to the availabilit; of an outage window. This was the ,

case-.for_the Unit 2 Reload 8 outage during which portions of the recirculation  !

piping were replaced. The pipe _replacemunt effort resulted in a 23 week outage. _ The Unit 2 core was designed to provide an 18 month operating cycle with an assumed availability.of 85%. Due to the extended Unit 2 Reload 8 outage, past performance of the required diesel generator surveillances during outage windows available early in_the outage, and the-Unit 2 core design,

Technical Specification 4.8.1.1.2.d surveillances start becoming due by July 29, 1991 for diesel generator 3 and July -30, 1991 for diesel generator 4; prior to-the planned September 7, 1991 start of the Unit 2' Reload 9 outage.

The proposed amendment allows a 'one-time only extension of the surveillance Linterval associated with Technical Specification 4.8.1.1.2.d until October 31, 1991. This extension allows performance of the required surveillances during the~ upcoming Unit 2 Reload 9 outage. The justification for the extended surveillance interval _ is based on the high degree of 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 4.8.1.1.2.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 El-1 l

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t extending the surveillance interval by a maximum of approximately 3 months for diesel generators 3 and 4 would be negligible.

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 Unit 2 Cycle 9 the diesel generators 3 and 4 have been run only 40.5 and 40.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> respectively from April, 1990 through February, 1991.

These run times are well below the vendor's recommended 1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency.

Based on the above, the proposed one time extension of the Technical Specification 4.8.1.1.2.d diesel generator surveillance interval will not significantly affect the diesel generators' abilit y to perform their intended safety function.

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i 4 - ENCLDSURE 2 BRUNSWICK STEAM ELECTRIC PLANT,_ UNIT 2 NRC DOCKET 50 324'  ;

OPERATINC LICENSE DPR 62 REQUEST FOR LICENSE AMENDMENT

,0NE TIME EXTENSION OF DIESEL GENERATOR' SURVEILLANCE INTERVAL BASIS FOR CHANGE 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 ',

.c'onsideration if operation ofLthe facility in accordance with the proposed amendment would-not: (1)-involve a significant_ increase in the probability or. ,

consequences' offan accident previously evaluated, (2) create the possibility of a new or different-kind of-accident from'any accident'previously evaluated,

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- 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'nct involve a significant hazards consideration. The bases for this determination are as follows:

Proposed Chad &E- '

? Technical Specification 4.8.1.1.2.d-requires certain surveillances- 1

..(4.8.1.1.2.d.1 through 4;8.1.1.2.d 7) of the emergency diesel generators be

performed "At least once 'per? l8 months duringLshutdown." The proposed amendment- allows a one-time lonly' extension- ofithe surveillance interval j associated.with Technical Specification 4.8.1.1.2.d:until October 31, 1991.

.This extensionLallows performance of the-required surveillances during the-upcoming Unit 2 Reload 9 outage, currently'schedulod'to:begin in Septemberz

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'1991. 1 Basis  ;

The change 'does not involve a;significant hazards consideration-for the

-following reasons:

11.- -The. proposed amendment does_not involve.a significant increase in the~ d l probability or consequences of_an accident previously evaluated ~ . , <

-A one-time extension of Technical Specification 4.8.1.1.2.d surveillances for diesel generators- 3 and 4 until- October 31, 1991 will' notLresult in a significant increase in.the probability of the: diesel.

(generators _failing to perform _their= intended safety function' - .

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' Historically, the diesel generators have demonstrated a high degree of treliability! Over the past five years there have been.no failuresaof the surveillances required by Technical 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 E2-1 e

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4 testing history demonstrates the high reliability of the Brunswick diesel generators.

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 Unit 2 Cycle 9 the diesel generators 3 and 4 have been run only 40.5 and 40.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> rec ectively from April,1990 through February, 1991. These run times ara well below the vendor's recommended 1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency.

The diesel generator surveillance requirements are intended to maintain diesel generator reliability at a level which assures that adequate electrical power is availab!' 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 one-time extension of the surveillance frequency will not adversely affect diesel Benerator availability. As stated above, past diesel generator performance has indicated a high degree of reliability over an extended period of time. Thus, extending the surveillance interval until October 31, 1991 will 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 interval 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 cannot create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed amendment does not involve a significant reduction in the margin of safety. Extending the diesel generator surveillance interval to October 31, 1991 for diesel generators 3 and 4 will not result in a significant increase in the probability of the diesel generator failing to perform its intended safety function. The diesel generators have demonstrated an extremely high degree for reliability. Over the past five years there have been no failures of the surveillances required by Technical specifications 4,8.1.1.2.d.1, d.2, d 3, d.4, d.-5, d.6, and d.7. Ac such, the effects of a one time extension of the surveillance interval would be negligible. 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 Unit 2 Cycle 9 the diesel generators 3 and 4 have been run only 40.5 and 40.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> respectively from April, 1990 through February, 1991. These run times are well below the vendor's recommended 1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency and, therefore, diesel generator reliability will not be adversely affected by delaying the inspection required in Technical Specification 4.8.1.1.2.d.1 until October 31, 1991. In E2-2

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addition, there are no changes to the surveillance acceptance criteria.

.Therefore, the proposed amendment does not involve a=significant ,

reduction in the margin of safety.

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