ML20101J599

Application for Amend to License DPR-16,deleting Spec Which Requires Thorough Insp of EDG Every 24 Months During Shutdown

ML20101J599
Person / Time
Site:	Oyster Creek
Issue date:	03/25/1996
From:	Roche M GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101J601	List: ML20101J599 ML20101J609
References
6730-96-2086, NUDOCS 9604020061
Download: ML20101J599 (10)

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GPU Nuclear Corporation o Nuclear

=e388 Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

March 25,1996 6730-96-2086 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 1 Gentlemen:

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Subject:

Oyster Creek Nuclear Generating Station (OCNGS)

Docket No. 50-219 Technical Specification Change Request (TSCR) No. 230 Delete Emergency Diesel Generator (EDG) Inspection Requirement and Modify Allowed Outage Time (AOT)

This revision is being submitted as two lines were inadvertently omitted from the cover letter of the original submittal. This does not affect the technical content of this submittal in any way. 1 In accordance with 10 CFR 50.4(b)(1). enclosed is Technical Specification Change Request (TSCR) No. 230. Also enclosed is a Certificate of Service for this request certifying service to the chief executive of the township in which the facility is located, as well as the designated official of the State of New Jersey Bureau of Nuclear Engineering.

The purpose of this TSCR is to delete a specification which requires a thorough inspection of the Emergency Diesel Generator (EDG) every 24 months during shutdown. Inspecting the diesels and overhauling them, if necessary, is prudent, recommended by the vendor and will continue. GPUN believes that it is inappropriate to incorporate this requirement into the technical specifications. The inspection will be included in the facility's maintenance program with the option of performing the inspection during the operating cycle. In addition, this TSCR proposes to delete the phrase "in any thirty day period" from a specification concerning Allowed Outage Time (AOT). GPUN believes that the inspection of the EDG is more appropriately k)cated in the maintenance program than in the Technical Specifications. Each of these changes is consistent with NUREG 1433 " Standard Technical Specifications General Electric Plants BWR/4."

9604020061 960325 PDR ADOCK 05000219 P pgg GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation i

C321-96-2086 l Page 2 l

t A portion of a specification which concerns engineered safety features (ESF) normally served by l the operable diesel has also been deleted. The conditions it addresses are covered by another l specification. Furthermore, an AOT of 14 days (rather than 7 days) is proposed for periodic EDG  ;

inspection and overhaul if necessary. A risk analysis was prepared comparing the Core Damage l

Frequency (CDF) of the two AOT periods. The proposed change would result in an absolute core damage frequency increase of 1.2 E-7 per year. According to the EPRI "PSA Application Guide" (TR-1053%, Aug.1995) that value is Non-Risk-Significant.

t In addition, one specification has been repositioned but not changed. Finally, several wording l

! changes were made to enhance clarity and to correct two minor typographical errors.

l GPU Nuclear considers this submittal to be a Cost Beneficial Licensing Action (CBLA). A savings l

of rnore than $100K will be realized through the use of in-house labor rather than contractors and a reduction in the need for electrical cross ties during outages. Furthermore, the scheduling of system outage windows will be facilitated and outage duration may be reduced. To permit sufficient time to adjust system outage windows and other planning considerations, GPUN requests J l that this request be approved by April 30,1996.  ;

. Pursuant to 10 CFR 50.91(a)(1), enclosed is an analysis applying the standards in 10 CFR 50.92 to make a determination of no signi0 cant hazards consideration.

Very truly yours, l

h Michael B. Roche Vice President & Director Oyster Creek

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Attachments

DPK/ pip cc: Administrator, Region I (2 copies)

NRC Project Manager i NRC Resident inspector

GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION Facility Operating License No. DPR-16 Technical Specification Change Request No. 230 Docket No. 50-219 Applicant submits, by this Technical Specification Change Request No. 230, to the Oyster Creek Nuclear Generating Station Operating License, a change to pages 3.7-1,3.7-2,4.7-1 and 4.7-2.

< BY h Michael B. Roche Vice President and Director l Oyster Creek 1

Sworn and Subscribed to before me this 25thday of March, 1996.

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&2 A Notary Public of NJ l

l GERALDINE E. LEVIN NOTARYPLSUC 0FEWKJBEY l MyCommissionEmpirus v6/03 Mood i

. l GPU Nuclear Corporation Post Office Box 388 Nhl5 f Route 9 South Forked River, New Jersey 08731-0388 609 971 4000 Wnter's Direct Dial Nuc.1ber:

March 25, 1996 C321-96-2086 1

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l Mr. Kent Tosch, Director

, Bureau of Nuclear Engineering Department of Environmental Protection CN 411 Trenton, NJ 08625

Dear Mr. Tosch:

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Subject:

Oyster Creek Nuclear Generating Station i Facility Operating License No. DPR-16 Technical Specification Change Request No. 230 l Pursuant to 10 CFR 50.91(b)(1), please find enclosed a copy of the subject document which was l

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filed with the United States Nuclear Regulatory Commission on March 25, 1996. l l

Very truly yours.

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! Michael B. Roche Vice President & Director Oyster Creek  ;

1 Attachment DPK/ pip l

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l l GP J Nucl ear Corporation is a subsidiary of General Public Utilit.es ';orporation

GPU Nuclear Corporation J NUCIO8r n,e n:S

• 38 Forked River, New Jersey 087310388 609 971-4000 Writer's Direct Dial Number:

March 25, 1996 C321-96-2086 The Honorable John C. Parker Mayor of l2cey Township 818 West 12cey Road Forked River, NJ 08731

Dear Mayor Parker:

Enclosed herewith is one copy of Technical Specification Change Request No. 230, for the Oyster Creek Nuclear Generating Station Operating License.

This document was filed with the Uni'.ed States Muclear Regulatory Commission on March 25. 1993 Very truly yours, 3 bf Michael B. Roche Vice President & Director Oyster Creek Attachment DPK/ pip GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

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UNITED STATES OF AMERICA I

NUCLEAR REGULATORY COMMISSION l

In the Matter of )

) Docket No. 50-219 GPU Nuclear Corporation )

1 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 230, for Oyster Creek Nuclear Generating Station Operating uicense, filed with the U.S. Nuclear Regulatory Commission on l 1996 has this day of March 25, 1996, been served on the Mayor of Lacey Township, Ocean County, New Jersey by deposit in the United States mail, addressed as follows:

i The lionorable John Parker Mayor of Lacey Township '

- 818 West 12cey Road Forked River, NJ 08731 l

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BY Michael B. Roche Vice President and Director Oyster Creek l

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l .' TECHNICAL SPECIFICATION CilANGE REQUEST (TSCR) No. 230 GPU Nuclear requests that the following changed replacement pages be inserted into existing Technical Specifications:

Replace existing pages 3.7-1, 3.7-2,4.7-1 and 4.7-2 with the attached revised replacement pages 3.7-1,  !

3.7-2, 4.7-1 and 4.7-2. '

11. REASON FOR CilANGE i

This change includes several distinct aspects. First, Oyster Creek's current Technical Specifications (TS) l include a requirement that the emergency diesel generators (EDG) be given a thorough inspection at least i once every 24 months during shutdown. Inspecting the diesels and overhauling them, if necessary, is prudent and recommended by the vendor. GPUN believes, however, that it is inappropriate to incorporate this requirement into the Technical Specifications. Rather, it should be part of the facility's maintenance program. NUREG-1433 " Standard Technical Specifications General Electric Plants BWR/4" does not include a requin ment to inspect EDG's.

An additional restriction contained in the Oyster Creek TS, concerns allowed outage time (AOT). The current specification permits the reactor to remain in operation for a period of seven days with one EDG  !

out of service provided certain conditions are met. The specification also includes the phrase "in any 30 day period". This restrictive element is another constraint which is not contained in the Standard Technical Specifications (STS). A segment of speciGcation 3.7.C.2 states that during a repair period (of an EDG) that no engineered safety features (ESF) supported by the operable diesel may be out of service. Virtually all ESFs are subject to specification 3.0.B which addresses normal and emergency power requirements.

Other aspects of the change also concem AOT and the inspection of the EDGs while operating. If the TS xhich requires EDG inspection during shutdown were removed, GPUN could schedule such activities during operating periods. Such inspections would be expected, planned for and permit greater availability of the EDGs during planned shutdowns. To provide operational Dexibility, it is proposed that the AOT for scheduled periodic inspections be extended to 14 days, although recent history has shown that it is very unlikely that the 14 days would be required.

Finally, several wording changes have been made to enhance clarity. The phrase "becomes inoperable" in specifications 3.7.C.2 and 3 have been changed to "is inoperable" and "are inoperable", respectively.

Thus, the need to interpret "becomes inoperable" is obviated when entering the LCO intentionally. A phrase has been added to specification 4.7.A.5 to reDect the possibility that some activities may now be performed during the operating cycle. Also, two minor typographical errors on pages 3.7-1 and 4.7-1 have been corrected. On 3.7-1 the word " charger" has replaced the word " changer" which was incorrect.

On page 4.7-1 a lower case "b" in a reference to specification 4.7.B has been corrected.

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111. SAFETY EVALUATION JUSTIFYING CilANGE l

The Bases of Oyster Creek TS 3.7 " Auxiliary Electrical Power" states that the objective is to " assure an ,

adequate supply of power with at least one active and one standby source of power available for operation  !

of equipment required for a safe plant shutdown." The plant's main generator is not credited, however, since it is not available during shutdown. The Bases also cite the probability analysis in the Oyster Creek FDSAR . Appendix L which is based on one diesel and shows that even with only one diesel, the l probability of requiring engineered safety features at the same time as the second diesel fails is quite small.-

Since that analysis was performed, the reliability of the diesels has been enhanced and, although not analyzed for accident conditions, an additional source of AC power has been installed. If this action is approved, EDG inspections could be conducted while the reactor is online. Periodic inspections and ,

overhaul of the EDGs during plant operations would contribute to improved EDG reliability during plant operations as well as improved availability during plant shutdown. If inspections were performed during l plant operations, one active and one standby source of power would be available. The JCP&L Combustion l Turbines would provide an Alternate AC source consistent with GPUN's Station Blackout (SBO) commitments.

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l In September 1992, the NRC issued NUREG-1433 which reflects the generic requirements for General  ;

Electric plants. The STS include definitions, LCOs and t,urveillance requirements. This document does '

l i not include a specification concerning the inspection of EDGs. Similarly, while there is a limit on the j amount of time that a reactor can operate with an EDG out of service, each occurrence is independent and l not further constrained. 1 This change retains the specification which requires that with an EDG inoperable, the reactor may remain

in operation for a period not to exceed seven days. An exception to this requirement, however, is added to ,

! extend the AOT to fourteen days when an EDG is inoperable due to its periodic inspection.  ;

if specification 4.7.A.3 were deleted and relocated to the plant's maintenance program, GPU Nuclear [

could inspect, and overhaul if required, the EDGs during reactor operations. Such an inspection would be l planned well in advance, ensuring that there would be no conflicting work and all components required to i be operational would be in service. The fourteen day time frame would provide sufficient time to thoroughly inspect the EDGs, perform needed repairs, allow for any unanticipated delay in the delivery of parts and permit reassembly. An analysis was performed utilizing PRA techniques which considers the s

change in Core Damage Frequency (CDF) based on extending the AOT from seven days to fourteen days.

l The change in CDF is a 3.85 % increase which equates to an absolute core damage frequency increase of .

1.2E-7. Using the EPRI "PSA Application Guide", this proposed change is classified as Non-Risk- l Significant. In addition, the analysis conservatively assumes that the entire fourteen day period would be  ;

used. Recent operational history indicates that it is very unlikely that the full fourteen days would be required for the periodic inspection. j i

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Inspecting the EDGs while the reactor is on line obviates the need to inspect them when the unit is shutdown. The diesel generator batteries capacity test may also be performed during the operating cycle.-

While other tests and activities relative to the EDGs will continue to take place during shutdown, the percentage of time that they are available during shutdown will significantly increase. As a result, shutdown risk would be reduced.

In addition, a statement requiring all engineered safety features normally served by the operable diesel to be operable during repair periods is being deleted. For the ESFs which have LCOs this requirement is covered by specification 3.0.B. which addresses normal and emergency power requirements. Several ESFs do not have LCOs, these ESFs do not have power requirements or are not supported by the EDGs. Hence, l

the provision does not apply.  !

Finally, one specification has been moved to a more appropriate location, several wording changes were made to enhance understanding and two minor typographical errors have been corrected. These changes are purely administrative in nature. As such, they have no effect on safety.

l IV. NO SIGNIFICANT HAZARDS CONSIDERATION GPU Nuclear has determined that this TSCR poses no significant hazard as defined by the NRC in 10 CFR 50.92.  !

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1. State the basis for the determination that the proposed activity will or will not increase the l i

probability of occurrence of the consequences of an accident.

i The proposed activity deletes the requirement to inspect EDGs during shut down from the  !

l Technical Specifications. It further modifies the operability of a single EDG for a limited and l

l defined period of time. These changes do not affect the design or performance of the EDGs or ,

l their ability to perform their design function. Analysis using PRA techniques indicates the changes do not significantly increase the probability or consequences of an accident. l l l

2. State the basis for the determination that the activity does or does not create a possibility of an  ;

accident or malfunction of a different type than any previously identified in the SAR.

The EDGs are not the source of any accident described in the SAR. These changes do not modify l

the design or performance of the EDGs and do not affect plant functions or actions. Therefore, the proposed change does not create the possibility of an accident or malfunction of a different type than those previously identified.

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3. State the basis for the determination that the margin of safety is not reduced. The proposed changes f

! are designed to improve EDG reliability and availability during shutdown periods by providing  !

flexibility in the scheduling and performance of maintenance. The surveillance intervals are i

, unchanged and operability requirements are only modified to an acceptable degree. The proposed activity does not alter the basis of any technical specification that is related to the establishment or maintenance of a nuclear safety margin. Therefore, the margin of safety is not significantly j reduced by this action.

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. V. IMPLEMENTATION i GPUN requests that the amendment authorizing thk change be effective upon issuance.

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