ML20126E172

Application for Amend to License NPF-42,consisting of Proposed Change,Revising TS Table 4.8-1,DG Test Schedule,To Elimimate Requirement to Increase Testing Frequency Upon Experiencing Five or More Failures in Last 100 Valid Tests

ML20126E172
Person / Time
Site:	Wolf Creek
Issue date:	12/22/1992
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20126E174	List: ML20126E172 ML20126E192
References
GL-84-15, NA-92-0121, NA-92-121, NUDOCS 9212290040
Download: ML20126E172 (10)

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LF W@ NUCLEAR OPERATING C CREEK  :

notei c Hagan  :

Vo Prmder;1 Nmhat Aswant.e .

I December 22, 1992 NA 92-0121 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk -

Hail Station P1-137 Vashington, D. C. 20555

Subject:

Docket No. 50-482: Revision to Technical Specification  :

Table 4.8-1. Diesel Generator Test Schedule i

i Gentlement This letter transmits an application for amendment to Facility Operating

'1 cense No. NPF-42 for Wolf Creek Generating Station (WCGS).

, This license ,

amendment request proposes a revision to Technical Specification Table 4.8-1, i Dierel Generator Test Schedule. to eliminate the requirement to increase >

testing frequency upon experiencing five or more failures in the last 100

• valid tests. The proposed change is consistent with the guidance.provided in '

Generic Letter 84-15, " Proposed Staff Actions to Improve and Maintain . Diesel Generator Reliability.'

Attachment I 1.rovides a safety evaluation along with a detailed description'of ,

the proposed change. Attachment II. provides a .significant hazards-consideration determination and Attachment III provides; an environmental' impact determination.. The specific changes to1the technical specifications 5 proposed by this r3 quest are provided in Attachment 'IV.

In accordance with 10.CFR 50.91, a copy of this application, with attachments, is being - provided to the designated Kansas State Official. This ' proposed -

revision to the WCGS technical specifications will be. fully implemented within 30 days of formal Nuclear Regulatory Commission approval.

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9212290040 921222 PDR ADOCK 05000482

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PO Box 411/ Durlington. KS 66839 / Phone (316) 36458831 .

. An Equal opportututy Emplayw IAT/HC/ VET . .s

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!!A 92-0121 Page 2 of 2 If you have any questions concerning this matter, please contact me at (316)364 8831 Ext. 4002 or Mr. Kevin J. Moles of ray staff at Ext. 4565.

Very truly yours, M

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/ Robert C. llagan ['

'Vice President _

Nuclear Assurance RCH/jra Attachments: I - Change Description and Safety Evaluation II - Significant Har.ards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Change cci G. W. Allen (KDilE), w/a A. T. Ilowell (NRC), w/a J. L. M11hoan (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a w

STATE OF KANSAS )

) SS CollNTY OF COFFEY )

Robert C. llagan, of lawful age, being first duly sworn upon oath says that he in Vice President Nuclear Assurance of Wolf Creek 11uclear Operating Corporations that he has read the foregoing document and knows the content thereof: that he has executed that same for and on behalf of said Corporation with full power and authority to do so: and that the facts' -

therein stated are true and correct to the best of his knowledge, information and belief.

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Rober't C. Hagan //

Vide President V Huclear Assurance SUBSCRIBED and sworn to before me this c) 3 day of 0 C4 - . 1992.

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. Notary Public DENISE L LAWHORf1 s% NOT ARY PUEttC

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- Attaciunent I to' flA 92-0121 _

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Change Description and Safety Evaluation '!

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Attachment I to NA 92-0121 Page 2 of 3 e Change Description and Safety Evaluation Descript lon of Proposed Cha_n213, Technical Specification Table 4.8-1. Diesel Generator Test Schedule, provides criteria for determining whether a diesel generator should be tested at the normal frequency of every 31 days or at an _ accelerated frequency of every 1 days. The criteria for accelerated testing are either 2 or more failures of the last 20 tests or 5 or more f ailures of the last 100 tests. The table contains a footnote stating 'The associated test frequency shall be maintained _

until seven consecutive f aillure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one.' The footnote is applied to the conditions of 2 or more failures in the 1ast _ 20 valid diesel tests. The proposed change will eliminate the 5 of 100 criterion f rom the table and the implied requirement for performing as sainy as 99 tests at the accelerated test frequency, making the footnote the only criterion for returning-to the normal test frequency.

Reason for Channe The technical specification requires increased frequency of diesel testing in the event of an increased rate of diesel test failure. The current technical specification provides two criteria for increasing the test frequency. The test frequency is increased if the total number of failures equals _or exceeds 2 out of the last 20 tests or 5 out of the last 100 tests. In each case the test frequency increases _from once per 31 days to once per 7 days. A footnote is applied for meeting the 2 out of 20 criterion. The' footnote allows _the return to the 31 day test interval following the completion .of- 7 consecutive failure free tests and provided that the total number of failures in the last 20 tests is 1 or less. No such provicions is made for the increased testing frequency due to_ meeting the 5 out of 100 criterion.__ A series of five diesel failures relatively close together can -lead to an increased diesel testing frequency for a longer period of time than is necessary to demonstrate continued diesel reliability.

The purpose of accelerated testing is to quickly demonstrate that reliability has not degraded. This is sufficiently demonstrated by meeting the_1. in 20 requirement in conjunction with the 7 consecutive successful starts. More frequent testing - beyond that required by the - footnote is - not necessary to-provide an expedited demonstration of continued reliability.

On July 2. 1984, the NRC Staff issued _ Generic Letter 8415, ' Proposed Staf f Actions to improve and Mainta? Jiesel Generator Reliability.' Enclosure 3-of-Generic Letter 84 provided an example technical- specification for maintaining diesel generator reliability. . The proposed revision to Technical Specification Table 4.8-1 is- consistent with Table 4.8.1 of. the . example technical specification in Generic Letter 84-15.

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i Attachment I to NA 92-0121 a Page 3 of 3

.i The intent of Generic Letter 84-15 was to provide guidance on maintaining diesel generator reliability. This Generic Letter includes the concept of increasing the test frequency as an acceptable method of demonstrating restored reliability. It also expresses the NRC staff's conclusion that excessive testing may result in degradation of diesti engines. The proposed

-technical specification change removes the possibility of a ci wation requiring additional diesel generator testing beyond that which demonstrates ,

that reliability is being maintained.

Evaluation of Proposed Channen The requirement ta successfully complete 7 consecutive failure free tests along with the additional requirement of no more than 1 failure out of the ,

last 20 tests is sufficient to demonstrate that the diesel generator reliability has 140t degraded. Fulfilling this requirement for terminating the .

-increased surveillance frequency is sufficient to distinguish between random failures that occur close together and. the possibility of actual diesel generator degradation. The level of confidence established by meeting the requirements of the footnote has been found acceptable as indicated by Generic Letter 84-15. Continuing with the accelerated testing program beyond . this 4

point is considered to be unnecessary testing that would subject a diesel ,

generator to additional wear and degradation with an insignificant impact on reliability.

Based on the above, it has been concluded that the 5 of 100 criterion for accelerated testing can be removed from. Table 4.9-1 of the technical -

specifications and the 2 of 20 criterion for accelerated diesel testing is a sufficient to maintain diesel reliability without causing the potential .for excessive diesel testing. t h

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e Attachment 11 to NA 92 0121 Page 1 of 2 Attaciunent II Significant !!azards Consideration Deteratnation-

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Attachment II to NA 92-0121 ,

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Significant 11azards Consideration Determination The proposed license amendment would revise Technical Specification Table '

4.8-1 to eliminate the requirement to increase testing frequency upon >

experiencJng five or more failures in the last 100 valid tests.

This proposed change has been teviewed against the standards provided in 10 CFR 50.92. Each standard is discussed below.

Standard I - Involve a slanificent increase in the Probability or Consecuences of an Accident Previously Evaluated The proposed change affects only the criteria for entering and leaving the accelerated diesel generator testing schedule. The operability requirements and limiting conditions for- operation remain unchanged. The return to a normal testing frequency following a series of diesel failures that exceeded 2 out of the last 20 tests would be made only after 7 successful tests without a fallure and at least 20 tests without more than 1 failure. Continued testing on a weekly rather than a monthly schedule will not significantly improve the ability to determine whether the most recent failure indicated a sudden change in diesel reliability. Thus, the ability of the diesel generators to provide emergency electrical power -would not be diminished. Therefore, the proposed change will not increase the probability or consequences of any accident previously evaluated.

Standard II - Create the Possibility of a New or Different Kind of Accident from Any Previousiv Evaluated The proposed change does not involve any change in plant design or in the manner of any other plant operation. The criteria for initiating and suspending accelerated diesel testing are being slightly changed. This change does not result in a significant difference in the monitoring - of diesel generator reliability. Therefore, the proposed change does not create the possibility of any new or dif f erent kind of accident from those previously evaluated.

Standard III - Involve a SIRnificant Reduction in the Marnin of Safety The diesel generators will continue to provide a redundant source of acceptably reliable onsite power. The revised criteria - for -initiating _and suspending accelerated diesel testing have an insignificant effect on diesel generator reliability and are acceptable according to Generic ' Letter 84-15.-

In addition, the changes eliminate excessive testing, which can have an adverse effect on diesel reliability, beyond that necessary to demonstrate

, continued reliability. . Therefore, the revision to the test _'. frequency l- requirements does not involve a significant reduction in the margin of safety.

Based on the above, it is concluded that the proposed technical specification change does not involve a significant hazards consideration.

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Attachment. III to NA 92-0121 Page 1 of 2 .

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Attachment III i

Environmental Impact. Determination s

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Attachment III to NA 92-0121 Page 2 of 2 Environmental Impact Determination 10 CFR 51.22(b) specifies the criteria for categorical exclusions f rom the requirements for a specific environmental assessment per 10 CFR 51.21. This amendment request meets the criteria specified in 10 CFR 51.22(c)(9). The-specific criteria contained in this section are discussed below.  ;

(1) the amendment involves no significant hazards consideration  !

-l As demonstrated in the Significant Hazards Consideration Determination ' in Attachment II, the requested license amendirent does not involve any significant hazards consideration.

(ii) there is no significant change in the types or significant increase in- I the amounts of any effluents that may be released off-site The requested license amendment involves no change to the facility and does ,

not involve any change -in the manner of operation of any plant. systems involving the genrration, collection or processing of radioactive materials or other types of effluents. Therefore, no increase in the amounts of effluents or new types of effluents would be created.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure

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- The requested license amendment involves no change to the physical facility and does not involve any change in the manner of operation , of any plant systems involving the generation, collection or processing of radioactive materials or other types of effluents. Furthermore, implementation of this proposed change will not involve work activities which could contribute. to occupational radiation exposure. Therefore, there will be no increase in Individual or cumulative ~ occupation radiation exposure associated with this proposed change.

Based on the above, it Js concluded that there will be no impact on the environment resulting from this change. This change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to specific environmental assessment by the Commission.

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