ML20056E608

Discusses Info Re Request for Enforcement Discretion from TS 4.8.1.1.2.e to Avoid Unnecessary Shutdown of Unit 1

ML20056E608
Person / Time
Site:	McGuire
Issue date:	08/17/1993
From:	Mcmeekin T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9308240330
Download: ML20056E608 (7)

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Duke Pouer Comparty TCifwum

&!cCaire Nudear Generadon Department Ihe President

!!?00 Hcgm ferry Road (AfGulA)

(704)R15-4800 Humersville NC30TM.M5

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DUKEPOWER August 17, 1993 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

McGuire Nuclear Station, Unit 1 Docket No:

50-369 T.S.

4.8.1.1.2.e.8, Diesel Generator Hot Restart Test Request for Enforcement Discretion

Dear Sir:

This letter constitutes a request for enforcement discretion from the requirements of Technical Specification (TS) 4.8.1.1.2.e.8.

This relief is requested to avoid an unnecessary shutdown of McGuire Unit 1.

On February 1, 1993, the NRC issued Amendment No. 135 to Facility Operating License NPF-9 and Amendment No.117 to Facility Operating License NPF-17 for the McGuire Nuclear Station, Units 1 and 2.

l These Amendments changed, among other things, TS 4.8.1.1.2.e.8 to require hot restart of the diesel generator (DG) within 5 minutes l

of completing the 24-hour DG endurance run. During the review of L

this Technical Specification change by the McGuire site staf f, this revised requirement was not correctly incorporated into applicable procedures. As a result, during the recently completed McGuire Unit I

refueling

outage, the hot restart test was performed in conjunction with the ESF test rather than the 24-hour run.

Both Unit 1 DG's are currently considered operable based on the previous surveillance test. The 18 months plus grace period for these tests runs out on September 7,

1993 for the

'A' DG and October 1, 1993 for the

'1B' DG. In order to avoid an unnecessary shutdown of McGuire Unit 1, Duke requests NRC approval for_a one time waiver from the requirements of TS 4.8.1.1.2.e.8 to allow the 1A and-1B DG's to be run'for at least two hours before conducting a hot restart test. Unit I would remain at power during the conduct of this test. This test would be conducted to satisfy the TS-Surveillance requirement for the hot restart test.

The following information is attached:

1) A discussion' of the circumstances which led to this request, 2) The safety basis for the request (includes tne safety significance, potential consequences of the proposed course of action, compensate y h@

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Document Control Desk Page 2 August 17, 1993 measures, and justification for the duration of the request), 3)

The basis for the conclusion that this request does not have a potential adverse impact on the public health and safety, and 4)

The basis for the conclusion that this request does not involve adverse consequences to the environment.

The McGuire Nuclear Station Site Management Team reviewed and approved this request for enforcement discretion on August 13, 1993. Should there be any questions concerning this request or if additional-information is required, please call R.

O.

Sharpe at 4

(704) 875-4447.

l Very truly yours, T. C. McMeekin i

l xc:

Mr.

S.D.

Ebneter Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta St.,

NW, Suite 2900 Atlanta, Ga.

30323 Mr. Vic Nerses j

U.S.

Nuclear Regulatory Commission i

Office of Nuclear Reactor Regulation Mail. Stop 14H25, OWFN Washington, D.C.

20555 Mr. G.F. Maxwell i

NRC Senior Resident Inspector McGuire Nuclear Station l

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Circumstances Which Led to Request for Enforcement Discretion i

On February 1, 1993, the NRC issued Amendment No. 135 to Facility i

Operating License NPF-9 and Amendment No.ll7 to Facility Operating l

License NPF-17 for the McGuire Nuclear Station, Units 1 and 2.

These Amendments changed, among other things, TS 4.8.1.1.2.e.8 to require hot restart of the diesel generator (DG) within 5 minutes of completing the 24-hour DG endurance run. During the review of this Technical Specification change by the McGuire site staff, this revised requirement was not correctly incorporated into applicable procedures. As a result, during the recently completed McGuire Unit l

refueling outage, the hot restart test was performed in l

conjunction with the ESF test rather than the 24-hour run. The hot j

restart of the 1A DG was preceded by operation of the DG at full load (4000 kW) for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 57 minutes and for the 1B DG for 1 i

hour and 46 minutes.

On July 30, 1993, performing the 2B DG 24 i

hour test on McGuire Unit 2,

the procedure deficiency was i

identified and the procedure was corrected. The hot restart was i

successfully performed after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test on both Unit 2 DG's during the current outage (2EOC8).

Both Unit 1 DG's are currently considered operable based on the I

previous surveillance test. The 18 months plus grace period for these surveillances runs out on September 7, 1993 for the

'A' DG and on October 1, 1993 for the '1B' DG.

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i Safety Basis For The Request Safety Significance and Potential Consequences of the Proposed

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Course of Action.

l During a refueling outage, various maintenance and surveillance activities are performed on each DG in order to demonstrate and assure continued reliable operation of the DG. Prior to Amendment i

135/117, the TS 4.8.1.1.2.e.7 required operation of the DG for one hour at 4000 kW to achieve temperature stability. Within 5 minutes of shutting the DG down, a hot restart was performed (this start initiated the ESF test). Amendment 135/117 deleted TS 4. 8.1.1. 2.e.7 I

and added the hot restart test to TS 4.8.1.1.2.e.8 to be performed following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run. A footnote was also added to allow the hot restart to be performed prior to completing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run provided the DG hed operated for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at or 1

near full load. This was added to address the potential of a test j

f ailure during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run and to preclude excessive testing of a DG simply to achieve operating temperature.

The TS 4.8.1.1.2.e.7 surveillance was successfully completed during the EOC7 outage and is the basis for the current operability of the f

1A and IB DG's. Since the Test Procedure that was used to conduct the outage surveillance testing had not been revised for the EOC8 outage to incorporate the deletion of TS 4.8.1.1.2.e.7, the hot i

restart was performed as it had been during the EOC7 outage.

Following a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 57 minute run on the 1A DG and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 46 minute run on the 1B DG, the hot restart test had been initiated.

Even though the run time prior to initiating the hot restart was >

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the 1A DG, recording the time to reach specified voltage was not required.

Therefore, Duke Power proposes to complete the TS 4.8.1.1.2.e.8 surveillance requirement by running i

each DG for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> followed by a hot restart within 5 minutes of shutdown. This test would be performed in conjunction with the next scheduled (TS 4.8.1.1.2.a) DG start with Unit 1 at power. This test configuration is considered acceptable for the following reasons:

1)

Initiation of the hot restart test following 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of DG operation at or near full load will ensure that the DG has reached an acceptable temperature (normal operating temperature) for conducting the hot restart.

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2)

Operation of the DG for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> tied to the offsite grid is not significantly longer than the DG runs that are j

routinely performed with the Unit at power to satisfy TS j

4.8.1.1.2.a.

3)

Initiation of a hot restart will add one additional start cycle to each DG but will not cause wear any greater than other routine DG tests.

The results of the above evaluation support the conclusion that there is no safety significance to a one-time performance of a hot e w -

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4 restart test on the 1A and IB DG's.

Compensatory Measures A hot restart test will be performed on the 1A and IB DG's during the next scheduled DG testing day (tentatively August 23, 1993 for DG 1A and August 30, 1993 for DG 1B).

Duration of the Request The requested duration for the enforcement discretion is for a one-time conduct of hot restart tests on the 1A and 1B DG's with the unit at power.

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Impact on Public Health and Safety Duke Power Company (Duke) has made the determination that this request involves a No Significant Hazards Consideration by applying the standards established by NRC regulations in 10 CFR 50.92. This ensures that operation of the facility in accordance with the one time waiver of the requirements of TS 4.8.1.1.2.e.8 to allow a hot restart test of the lA and 1B DG's would not:

(1)

Involve a

significant increase in the probability or consequences of an accident previously evaluated:

Performance of a DG hot restart test with the unit at power will not significantly effect the DG's ability to provide emergency power in the unlikely occurrence of a design basis event. The test will be performed in conjunction with other DG tests that are required by the Technical Specifications. The proposed testing offers no more risk than that currently incurred to meet TS 4.8.1.1.2.a. There is no increase in the probability of an accident since no accident initiators are involved with this change.

Create the possibility of a new or different kind of accident from any accident previously evaluated Performance of a hot restart with the unit at power will not create any failure modes not bounded by previously evaluated accidents.

Consequently, this proposed test will not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3)

Involve a significant reduction in a margin of safety This proposed test will not involve a significant reduction in a margin of safety. No operating parameter, setpoint or design limit is affected. No fission product barrier is degraded; therefore, no margin of safety as defined in the basis for any Technical Specification will be reduced.

Environmental Impact Statement Duke Power Company has reviewed this request to allow a one time bot restart test of the 1A and 1B DG's against the criteria of 10 CFR 51.22 for environmental considerations. As shown above, the proposed change does not involve any significant hazards consideration, nor significant increase in the types and amounts of effluents that may be released offsite, nor significantly increase the individual or cumulative occupational radiation exposures.

Based on this, the request for revision to the acceptance criteria for secondary containment bypass leakage meets the criteria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

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