ML20134K137

Safety Evaluation Supporting Amends 170 & 152 to Licenses NPF-9 & NPF-17,respectively

ML20134K137
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/12/1996
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20134K133	List: ML20134K137 NUREG-1366, Amends 170 & 152 to Licenses NPF-9 & NPF-17,respectively, Incorporating Guidance & Recommendations for Diesel Generators Contained in NUREG-1366,GL 93-05,Gl 94-01 & NUREG-1431
References
NUDOCS 9611180272
Download: ML20134K137 (14)

Text

, f,n:

h UNITED STATES g

g NUCLEAR REGULATORY COMMISSION o

4" WASHINGTON D.C. 20665-0001 s...../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0. 170 TO FACILITY OPERATING LICENSE NPF-9 AND AMENDMENT NO.152 TO FACILITY OPERATING LICENSE NPF-17 DUKE POWER COMPANY MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370

1.0 INTRODUCTION

By letter dated December 14, 1995, as supplemented by letters dated May 16 and August 29, 1996, Duke Power Company (the licensee) subnitted a request for changes to the McGuire Nuclear Station, Units I and 2, Technical Specifications (TS). The requested changes would incorporate guidance and recommendations for diesel generators contained in NUREG-1366, " Improvements j

to Technical Specifications Surveillance Requirements," Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," GL 94-01, " Removal of Accelerated Testing and Reporting Requirements for Emergency Diesel Generators," and NUREG-1431, " Revised Standard Technical Specifications for Westinghouse PWRs." The August 29, 1996, letter provided clarifying information that did not change the scope of the December 14, 1995, application and the initial proposed no significant hazards consideration determination.

By letter dated May 16, 1996, the licensee withdrew the proposed change to the full-load rejection Surveillance Requirement 4.8.1.1.2e.3.

Also, by letter dated August 29, 1996, the licensee withdrew the proposed changes in (1)

Surveillance Requirements 4.8.1.1.2c and 4.8.1.1.2d regarding using at least one air tank with no compressors for starting the diesel and lowering the maximum tank pressure from 220 psig to 210 psig, and (2) TS Section 6.8.4h regarding the diesel fuel oil surveillance testing. None of these withdrawn requirements affect the staff's conclusion.

2.0 BACKGROUND

The NRC staff has completed a comprehensive examination of surveillance requirements (SRs) in the TS that require testing at power. The evaluation is documented in NUREG-1366. The NRC staff found that although most testing at power is important, safety can be improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated by reducing the amount of testing at power that is required by TS.

Subsequently, the NRC 1

issue GL 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." Additionally, in response to the NRC's decision on SECY-93-044, Resolution of Generic Safety Issue B-56, " Diesel Generator Reliability," the NRC issued GL 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel i

Generators."

In this GL the staff recommended that licensees be allowed to 9611180272 961112 PDR ADOCK 05000369 P

PDR J

I i

a,

i t.

t voluntarily adopt the accelerated testing provisions of the Improved Standard TS upon the implementation of the provisions of the " Maintenance Rule" for the EDGs, including the applicable regulatory guidance, which will provide a program to assure EDG performance. Duke Power Company is proposing to modify McGuire, Units 1 and 2 TS incorporating recommendations and guidance in the above GLs. Additionally, Duke Power will be using guidance in NUREG-1431,

" Revised Standard Technical Specifications for Westinghouse PWRs," in their effort to improve the McGuire TS.

i 3.0 EVALUATION The proposed' changes to the Duke Power Technical Specification (TS) are being made to improve the current TS Action Statements and Surveillance Requirements for the diesel generators (DGs) at McGuire Nuclear Power Station, Units 1 i

and 2.

The following changes will incorporate the guidance and l

recommendations contained in NRC Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reauce Surveillance Requiremants for Testing During Power Operation," Generic Letter (GL) 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," and NUREG-1431, " Revised Standard Technical Specifications for Westinghouse PWRs."

3.1 Proposed Chanaes to McGuire TS Duke Power is proposing the following additions and deletions to McGuire TS Section 3/4.8.1 "A.C. Sources." The strikeouts represent the deletions and the bolded text represents the additions:

3.1.1 Chanae 1: Action Statement a.

With an offsite circuit of the above required A.C. electrical power a.

sources inoperable, demonstrate the OPERABILITY of the remaining A.C. S:;r:: (required offsite cfrruft) by performing Surveillance Requirement 4.8.1.1.la within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter;

r

tely d

n n:tr:t: th: :p:r:bility Of t=: di:::1 ;;; r:t:r: by p:rfe ria; Sur;;ill:::: ":;uir:n nt 4.0.1.1.2:.? ::d 4.0.1.1.20.5 with 24 5: r: cale:: thi: : r;;ill:::: r:q;ir:nnt ::: p:r'ecmed within th: preui :: 24 5::r: ::1::: the di ::1 i: :p;r:tiag, restore

t 1 ::t t; Off:ite (the required offsite) circuits ::d t:0 di:::1 generatees to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD-SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The above changes are consistent with the following recommendations in GL 93-05:

with the offsite circuit of the above required A.C. electrical power i

sources inoperable...

t 4

l t

1 i (Delete the following requirement to test EDGs: If either generator 2

has not been successfully tested within the past 24_ hours, demonstrate the operability by performing Surveillance Requirement j

4.8.1.1.2a.5 and 4.8.1.1.2a.6 for each such diesel generator, separately, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.)

Additionally, the wording "A.C. Sources" will be replaced by " required offsite source." This is being done because there will no longer be a requirement to 4

test the remaining EDGs for this action statement. Therefore, the only A.C.

source to test would be the remaining offsite circuit. This is considered an administrative change.

1 3.1.2 Chanae 2: Action Statement b.

b.

With one offsite circuit and one diesel generator of the above i

required A.C. electrical power sources inoperable *r demonstrate the OPERABILITY of the remaining A.C. ::er:c (required off:ite circuit) i by performing Surveillance Requirement 4.8.1.1.la within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at lest once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; demonstrate

• the operability i

i of the remaining diesel generator by performing Surveillance Requirement 4.8.1.1.2a.4 and 4.8.1.1.2a.5 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (or verify within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that no potential connon mode failure for the I

remaining diesel exists;)

enl::: thi

erecill:::: :: perf:r;;d within th: pr;vi::: 2t heveer er enl::: the di:::1 i: Oper: ting ** restore...

statement d.

• dic::1 ;;;;r:ter :h:ll b; ::::id:r:d t be in:per:ble fr;; the ti; Of f:iler: entil it ::ti:fi:: the r:quir ::nt: Of Surveill::::

R:quir:;;nt; ?.0.1.1.20.t) :nd t.0.1.1.2.5).

Tht: t::t i: r:;uired t: bc :;;pleted r:;;rdle:: Of ch:n th:

in:per:ble di:::1 g:n:r:ter 1: r :ter:d t: OPER^,SLE :t:te:. The pr:vi icn: Of :p::"ft::ti:n 3.0.2 :r: :t :pplic:bl:.

This action is not required if the inoperability of the diesel was due to an inoperable support systen, an independently testable component, or preplanned testing or nafntenance. If required, this action is to be completed reganfless of when the inoperable diesel generator is restored to OPERABLE status. The provisions of Specification 3.0.2 are not applicable.

The above changes are consistent with the following recommendations in GL 93-05:

With an offsite circuit of the above required A.C. electrical power sources inoperable...

(Deleted the following requirement to test EDGs: "If either diesel generator has not been successfully tested within the past 2 ours,

i i

i

i demonstrate its OPERABILITY by performing Surveillance Requirements 4.8.1.1.2a.5 and 4.8.1.1.2a.6 for each such diesel generator, separately, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.")

and i

... If the diesel generator became inoperable due to any cause other j

than an inoperable support system, an. independently testable component, or preplanned preventative maintenance or testing, i

demonstrate the OPERABILITY of the remaining OPERABLE diesel 1

generator by performing Surveillance Requirements 4.8.1.1.2a.5 and i

4.8.1.1.2a.6 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the absence of any potential common mode failure for the remaining diesel generator is j

demonstrated.

l The deletion of "A.C. Sources" and the addition of " required offsite source" is being made because there will no longer be a requirement to test the remaining EDGs for this action statement. Therefore, the only A.C. source to test would be the remaining offsite circuit. Additionally, Duke Power is also 1

i proposing to delete, from the TS Bases, any reference to testing the remaining EDGs when an offsite source becomes unavailable. This is being made because j

this requirement has been eliminated from the NUREG-1431 per GL 93-05.

i l

The deletion of the footnote

• is considered to be an administrative change because it only clarifies what is considered to be an inoperable EDG and this i

definition already exists in the current McGuire TS Section 1.0.

a 3.1.3 Chanae 3: Action Statement d.

d.

"With a diesel generator of the above required A.C. electrical power sources inoperable *r demonstrate the OPERABILITY of the A.C.

offsite sources by performing Surveillance Requirement 4.8.1.1.la j

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; : d 1 ::

th: in;;;r:bility Of th: di:::1 ::: d : t: pr:;1::::d t:: ting r

int:::::: demonstrate

• the OPERABILITY of the remaining diesel generator by performing Surveillance Requirements 4.8.1.1.2a.4 and 4.8.1.1.2a.5 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> er ::1::: th: di:::1 i: :;:r: ting **,

(or verifying within 24 ours that no potential common mode failure for the ressining diesel exists;) restore diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

A di:::1 ;:::r:ter :h:11 bc ::::ider:d t: be in:;:r:ble fr;; th:

ti:: Of f:iler: ::til it ::t!:fic: the r ;;ir: ;nt: Of Serv:ill::::

3:;uir;;;nt: 1.S.1.1.20.1) ::d 1.S.1.1.20.5)

Thi: t::t i: r:;uir:d t: 5: ::r;10ted re;;rdle:: Of th: the in:;;r:51: dit:01 g:::r:ter i: re:tered t: OPEP.ASLE :t:te:. The pr:vi:i::: Of S; :ific:tica 3.0.2 :r: :t :pplic:ble.

i l 1 l

GjTliiFsit%s!1sfistTNqsWidfi fJtki[lW6piiR6111 tPioEthsidisiil{wii hs61tofantin6per'ablelsupportisystesNan11adependentliftestabli ^

.componentEbrJ prepl anneditest't agisrz aa thtsnancfGIf; Ngui red Mthi s pionUMtolbej completed (regardlesslogwhenithe} inoperable [diess[

ratoraistrestored{to?0PERABLEdtatusuThef rovisionsief

,_ l l Q cation ]!0jgiafe j o Q pplijable f ~ " p~ ~~ ~ ^ ^

]

The above changes are consistent with NUREG-1431 and the following recommendations in GL 93-05:

... If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Surveillance Requirements 4.8.1.1.2a.5) and 4.8.1.1.2a.6 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the absence of any potential common mode failure for the remaining diesel generator is demonstrated.

3.1.4 Chanae 4: Action Statement e.

With two of the above required offsite A.C. circuits inoperable, e.

p;r:tely d:::nstrate th: OPEP2SILITY cf t:0 diesel generator; by perf =ing Serveillane: P,:quirc:ent: i.0.1.1.20.4) :nd 4.0.1.1.20.5) tithin 0 heer, unles: the dit:01 g:ncr tcr: :lr :dy Oper: ting; i

restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. With only one offsite source restored, follow action statement a.

The above changes are consistent with the following recommendations of GL 93-05:

With two of the above required offsite A.C. circuits inoperable, restore...

(Deleted the following requirement to test EDGs; demonstrate the OPERABILITY of two diesel generators separately by performing the requirements of Specifications 4.8.1.1.2a.5 and 4.8.1.1.2a.6 within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, unless the diesel generators are already operating,)"

3.1.5 Chanae 5: Surveillance Reauirement 4.8.1.1.2a.5) 5)

" Verify the generator is synchronized, loaded t: grc:t:r th:

Or

:1 t: 2000 kW in 10:: th:n Or :q :1t 50 ::: nd:, :nd 10 1000 kW

?: thin 10 minute:

~

and operates (at 3600-4000 kW ***)

for at least 60 minutes.

. _. ~

o n

I i

i i Olesel generator loadings may be done in acconiance with the nanufacturer's recommendations. The purpose of the load range is to prevent overloading the engine, and aceentary excursions outside of l

the load range shall not invalidate the test.

i The above changes are consistent with the following recommendations in GL 93-05 and NUREG-1431 and are therefore acceptable:

i j

TS 4.8.1.1.2:

4 a.

In accordance with the frequency specified in Table 4.8-1 l

on a STAGGERED TEST BASIS by:

6)

Verify the generator is synchronized, loaded to t

greater than or equal to [ continuous rating] kW in accordance with the manufacturer's recommendatitns, a'

and operates with a load greater than or equal.te j

[ continuous rating] for at least 60 minutes, and 1

(Replace "less than or equal to [60] seconds" with "accordance with the manufacturer's recommendations.")

NUREG-1431 is consistent with Regulatory Guide 1.9, Rev. 3 which states:

i Demonstrate startup from standby conditions, and verify that required design voltage and frequency is attained. For these tests, the emergency diesel generator can be slow-started and reach rated speed on a prescribed schedule to minimize stress and wear.

j Demonstrate 90 to 100 percent of continuous rating of the emergency diesel generator, for an interval not less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and until j

temperature equilibrium has been attained.

Additionally, Note 2 of NUREG-1431, for this surveillance, states that momentary transients, because of changing loads, do not invalidate this test, which is consistent with the NUREG-1431.

i j

3.1.6 Chanae 6: Surveillance Reauirement 4.8.1.1.2e.8)

]

8)

Verify, during shutdown, the diesel generator... and 57Hz within 11 secondsr***(ii)

If th:r: i:

t::t f:il;r: durir.g the 20 5: r t.e:t r:n, th: het

___........... u. _,____;

____3..

.u.

e, u.._....

i l'..'.'.'..'.'.2" ' ' ' "i'. !'. E'11"..'.I. ". :'.2"1

'".2';" ".T 'i_ ',""'.'.__"

r 10:d:d 5:t ::n 2000 :nd 1000 k"."

If the hot restart is not satisfactorily completed, it is not i

necessary to repeat the preceding 24-hour test.

Instead, the diesel generator may be operated at 3600-4000 kW *** for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until 4

operating temperature has stabilized.

f l

I 2

1 2 i

i The above changes are found to be consistent with the following 1

recommendations in GL 93-05:

1 TS 4.8.1.1.2:

i i

e. At least once per 18 months, during shutdown, by:

7)

Verifying the diesel generator operates for at least i

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...Within 5 minutes after completing this 24-hour test, perform specification

'4.8.1.1.2.a.5);*...

i (Replaced TS "4.8.1.1.2.e.6).b)" [ simulated loss-of-offsite power start and load test) with "4.8.1.1.2.a.5)" (EDG start test).)

If Specification 4.8.1.1.2.a.5) is not satisfactorily l

completed, it is not necessary to repeat the preceding 24-hour test.

Instead, the diesel j

generator may be operated at [ continuous rating] kW

]

for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized.

4 j

3.1.7 Chanae 7: Surveillance Reauirement 4.8.1.1.2.a i

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

a.

In ::::rd:::: with th: fr:;;:::y :;;;ift:d in T:51: t.0.1 (at least once per 31 days) on a STAGGERED TEST BASIS, by:

4 p

I Additionally, Duke Power is eliminating Table 4.8-1 " Diesel Generator Test Schedule" and the associated footnotes.

i The above changes are consistent with the following recommendations in i

GL 94-01 and are therefore acceptable:

4 l

Licensees may now implement the provisions of the maintenance rule for EDGs,-including the applicable regulatory guidance which will 1

l provide a program to assure EDG performance. Therefore, the requirements for accelerated testing of individual EDGs would no longer exist.

3.1.8 Chanae 8: Surveillance Reauirement 4.8.1.1.3

,4 i

' S.1.1.3 R:;:rt:

^11 di ::1 ;:::r:ter f:iler::, :: lid er :: :: lid, 1

h:ll be r:;:rted t the C:: f::i: ;;r::::t t: S;::ift::ti:n 5.9.2 i

eithin 30 d:y:.

R:;:rt: Of di:::1 ;;;;r:ter f:il;r:: :h:11 ft:1 d: th

)

inf:r :ti r:::::::d:d in R:;;1:t:ry P::iti n c.3.5 Of Regel:tery Cuid:

i 1.108, R:ri:i:n 1, ". ;;;t 1977.

If the :::t:r of f:il;r:: in the 1::t i

100 :: lid t::t: (: : p:r :::le:r : it 5::t:) i: gr::ter th:2 er :;c:1 t:

I l

7 -45: r;;;rt :h:ll 5: : ;;l::::ted t includ: th: :dditi:::1 inf:r:: tic:

7 j

re::::::d:d in R:;;1:t:ry P::itie C.3.5 Or r:g;1:t:ry ;;id: 1.108, R:rizi 1, ".:; :t 1977.

1 4

1

i 1

1 1

i The above change is consistent with the following recommendations in GL 94-01 and is therefore acceptable:

i i

Licensees may request the removal of the TS provisions for accelerated testing and special reporting requirements for EDGs at this time. However, when requesting this license amendment, licensees must commit to implement within 90 days of the issuance of i

the license amendment a maintenance program for monitoring and maintaining EDG performance consistent with the provisions of Section 50.56 of Title 10 of the Code of Fedaral Regulations (10 CFR 50.65), " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance (as i

applicable to EDGs) of Regulatory Guide (RG) 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

Additionally, Duke Power will be making administrative changes to the TS Bases for McGuire which will add references to GL 93-05 and GL 94-01.

}

i I

j 3.1.9 Chanae 9: Surveillance Reauirement 4.8.1.1.2a.4) l

4) Verifying (**) the diesel starts form -"

' (standby (prelube))

condition and (maintain the steady-state generator voltage and frequency j

at 4160 i 420 volts and 60 1 1.2 Hz, respectively.) ::::ler:te: t: :t i

le::t i"" rp in le:: th:n r :;;:1 to 11 ::::nd:*. Th: ;:::r:ter

{

v:lt:;: ::d fr:;;;;;y :h:ll b; :t 1:::t 1150 volt: ::d 57 H: within 11

nd: fter th: :t:rt :ign:1.

I

• • Once per 184 days, start the engine from standby (prelube) condition, j

and verify generator reaches 1 3750 volts and 1 57 Hz in $ 11 seconds.

The above changes are consistent with the following reco nendations in NUREG-1431 and are therefore acceptable:

l SR 3.8.1.2 and 3.8.1.7 i

In order to reduce stress and wear on diesel engines, some i

manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading.

and I

i SR 3.8.1.7 requires that, at a 184 day frequency, the DG starts from standby conditions and achieves required voltage and frequency 1

within 10 seconds. The 10 second start requirement supports the i

assumptions of the design basis LOCA analysis in the FSAR, Chapter j

(15].

1 a

1 4

j 1

i

.. In the McGuire TS, the time required for the EDG to achieve adequate voltage i

and frequency deviates for the time specified in NUREG-1431. However, the J

NUREG-1431 basis for this surveillance requirement states that the time, voltage, and frequency elements should be derived from McGuire's accident j

analysis, which demonstrates the plant's response to a design basis large break loss-of-coolant ' accident (LOCA). The voltage, frequency, and time used j

at McGuire for this surveillance requirement are supported by their original TS, and their origin'al licensing documents for the plant.

3.1.10 Chanae 10: Surveillance Reauirement 4.8.1.1.2e.5)

5)...The generator voltage and frequency shall be at least 4MG (3470) volts and 57 Hz with 11 seconds after the auto-start signal;...

The above changes are consistent with the following requirements of NUREG-1431 and are therefore acceptable:

Verify on a actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts form standby condition and:

f a.

In s [10] seconds after auto-start an during tests, achieves voltage 1 [3740] V and 1 [4580] V; b.

In s [10] seconds after auto-start and during tests, achieves frequency 1 [58.8) Hz and s [61.2] Hz; The time required for the EDG to achieve adequate voltage and frequency i

deviates from the time in NUREG-1431. However, as stated above, the i

NUREG-1431 basis for this surveillance requirement states that the time, voltage, and frequency elements should be derived from McGuire's accident analysis, which demonstrates the plant's response to a design basis large i

break loss of coolant accident (LOCA). The time, voltage, and frequency used in this surveillance requirement at McGuire are supported by their original TS, and their original licensing basis documents for.the plant. The i

change from 488 rpms to 57 Hz is considered to be administrative because 488 rpms corresponds to 57 Hz, and does not change the original intent of this i

surveillance requirement.

3.1.11 Chance 11: Surveillance Reauirement 4.8.1.1.2e.8)

8) Verify, during shutdown, the diesel generator operates for at least 24 i

hours. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test, the diesel generator shall be loaded between 4200 kW and 4400 kW **(***) and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of the test, the diesel shall be loaded between 3800-hW (3600 kW) and 4000 kW ** (***).

The generator voltage and frequency shall be at i

least 4MG-V (3740 F) and 57 Hz within 11 seconds after the start signal.

...Within 5 minutes of shutting down the diesel generator, restart the diesel generator and verify that the generator voltage and frequency reaches at least 4MO-V (3740 F) and 57 Hz within 11 seconds. *** (ii) l rTm+-u

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it if the het restart is not satisfactorily completed, it is not necessary to twpeat the preceding 24-hour test. Instead, the diesel generator may be operated at 3600- 4000 W *** for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized.-

l The guidance and recommendations in NUREG-1431 for the 24-hour test are consistent with RG 1.9, Rev. 3, in which it is stated:

Demonstrate full load carrying capability at a power factor between

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0.8 and 0.9 for an interval of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are at a load equal to 105 to 110 percent of the continuous rating of the emergency diesel generator, and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> are at a load equal to 90 to 100 percent of its continuous rating. Verify that voltage and frequency requirements are maintained.

t The NRC staff identified a concern with this change because there was no power factor specified in the proposed TS by the licensee.

It_was concluded that l

Duke Power must use a power factor for the 24-hour endurance test surveillance to be consistent with recommendations and guidance of RG 1.9, Rev. 3, and-NUREG-1431.

In a response to NRC request for additional information (RAI) l dated March 26, 1996, the licensee stated that this test is conducted using a 0.8 power factor, which is consistent with NUREG 1431.

i The additional proposed changes to this section of the McGuire TS are consistent with the following recommendations in GL 93-05 and are therefore acceptable:

l TS 4.8.1.1.2:

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e. At least once per 18 months, during shutdown, by:

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7)

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...Within 5 minutes after completing this 24-hour test, perform specification 4.8.1.1.2a.5);*...

(Replaced TS "4.8.1.1.2e.6).b)" (simulated loss-of-offsite power start and load test) with "4.8.1.1.2a.5)" (EDG start i

test).)

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If Specification 4.8.1.1.2a.5) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test.

Instead, the diesel generator may be operated at (continuous rating] kW for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized.

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., 3.1.12 Chanae 12: Surveillance Reauirement 4.8.1.1.2e.15) and f.

15) Verifying, during shutdown #, that with all diesel generator air start receivers pressurized to less than or equal to 220 psig and the compressors secured, the diesel generator starts at least 2 times from riier.t (standby (prelube)) conditions and accelerates to at least '** re; (57) Hz in less than or equal to 11 seconds.

and f.

At least once per 10 years... at least 2 rp; (57 #z) on less than or equal to 11 seconds; and The above changes are consistent with the following recommendations in NUREG-1431 and are therefore acceptable:

SR 3.8.1.2 and 3.8.1.7 In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading.

and SR 3.8.1.20 Verify when started simultaneously from standby condition, each DG achieves, in s [10] seconds, voltage 1 [3774] V and, [4576), and frequency 2 [58.8] Hz and 5 [61.2] Hz.

The time required for the EDG to achieve adequate voltage and frequency deviates for the time in NUREG-1431. However, as stated before, the NUREG-1431 basis for this surveillance requirement explains that the time, voltage, and frequency elements should be derived from the accident analysis, which demonstrates the plant's response to a design basis large break loss of coolant accident (LOCA). The voltage, frequency, and time used at McGuire for this surveillance requirement are supported by their original TS, and their original licensing ba. sis documents for the plant.

1. This....PM activity alone.

Currently, footnote "#" is part of the TS Surveillance Requirement Section 4.8.1.1.2e.14 regarding the surveillance of EDG lockout features. Adding footnote "#" to the TS Surveillance Requirement Section 4.8.1.1.2e.15 will also allow the surveillance of EDG air starting system to be performed during preplanned Preventative Maintenance (PM) activities that would result in the diesel generator being inoperable. The surveillance can be performed as long

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as it does not increase the time the diesel generator is inoperable for PM activity that is being performed. The footnote is only applicable at that time and will not be utilized for operational convenience.

Based on its review, the staff determines that the proposed footnote will not increase in the consequences of an accident previously evaluated and will provide added flexibility in plant operations.

The proposed change is, j

therefore, acceptable.

I The change of " ambient" to " standby (prelube)," is considered to be an administrative change and is, therefore, acceptable.

l 3.1.13 Chanae 13: TS Bases j

Duke power is proposing to insert the following statement to the TS Bases:

l Since the McGuire emergency diesel generator manufacturer (Nordberg) is j

no longer in business, McGuire engineering is the designer of record.

Therefore, the term " manufacturer's (or vendor) recommendations" is taken to mean recommendations as determined by Mcguire engineering (with i

specific industry Nordberg input as available) that were intended for i

nuclear class diesel service taking into ac:ount McGuire diesel generator i

maintenance and operating history and industry experience where applicable.

j The staff would expect that the licensee, in the absence of manufacturer's

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guidance, would use prudent engineering judgment when conducting testing, preventive, and corrective maintenance on the EDG. However, this does not require the removal of the " manufacturer's recommendations" or " vendors recommendations" from the McGuire TS.

The staff concluded that the licenses i

can accomplish the same thing without removing " manufacturer recommendations"

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from the TS. Therefore, the staff suggested the following changes to the proposed insert in NRC RAI dated March 26, 1996:

Since the McGuire emergency diesel generator manufacturer (Nordberg) is no longer in business, McGuire engineering is the designer of 1

record. Therefore, in the absence of manufacturer recommendations, j

McGuire engineering will determine what are the appropriate actions required for the nuclear class diesel service taking into account McGuire diesel generator maintenance and operating history and industry experience where applicable.

In response to this NRC concern identified in NRC RAI dated March 26, 1996, the licensee has proposed to insert the above paragraph and this is therefore acceptable.

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j 4.0 STAFF CONCLUSIONS i

4.1 Summary of Chanaes Related to GL 93-05 The NRC staff has completed a comprehensive examination of surveillance j

requirements in the TS that require testing during power operation. This effort is a part of the NRC Technical Specification Improvement Program (TSIP). The results of this work are reported in NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements," dated December 1992.

In performing this study the staff found that, while the majority of the testing 4

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at power is important, some testing can be eliminated. The staff encourages l

licensees who plan to adopt suggested line-item TS improvements in GL 93-05 to propose TS changes that are consistent with the guidance in the GL. As part of this amendment request, Duke Power Company has proposed changes 4

i related to GL 93-05, "Line-Item Technical Specifications Improvements to.

Reduce Surveillance Requirements for Testing During Power Operation." The i

i staff has reviewed the proposed changes and found them consistent with the guidance and recommendations in GL 93-05, and therefore acceptable.

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i 4.2 Summary of Chanaes Related to GL 94-01 J

i In' GL 94-01, the NRC staff concluded that licensees may request the removal of l

j the TS provisions for accelerated testing and special reporting requirements for EDGs at this time. However, when proposing this amendment reouest.

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i licensees must commit to implement within 90 days of the issuance of the licensing amendment a maintenance program for monitoring and maintaining EDG performance consistent with the provisions of Section 50.65 of Title 10 of the Code of federal Regulations, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and.the guidance of Regulatory Guide j

(RG) 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power j

Plants." The staff encourages licensees who plan to adopt suggested improvements in GL 94-01, " Removal of Accelerated Testing and Reporting Requirements for Emergency Diesel Generators," to propose TS changes that are

= consistent with the guidance in the GL. Duke Power has proposed TS changes j

related to GL 94-01 and has committed to implementing the maintenance programs t

at McGuire at the beginning of 1996, prior to issuance of this amendment i

L request. The staff has reviewed the proposed changes and found them l

. consistent with the guidance and recommendations in GL 94-01, and therefore

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acceptable.

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4.3 Se-ry of Chanaes Related to NUREG-1431

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l This NUREG contains improved Standard Technical Specifications (STS) for Westinghouse plants and documents the positions of the NRC based on the Westinghouse Owners Group's proposed STS. This NUREG is the result of i

extensive technical meetings and discussions among vendors, and the Nuclear Management and Resource Council. The improved STS are used as the basis for 3

i developing improved plant-specific TS by individual nuclear power plant licensees. Duke Power has proposed TS changes related to NUREG-1431. The i

staff reviewed the proposed changes and found the changes consistent with the j

guidance and recommendations in NUREG-1431, and, therefore, acceptable.

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5.0 STATE CONSULTATION

s In accordance with the Commission's regulations, the North Carolina State official was notified of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIliRATION The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously i t ied a proposed finding that the amendments involve no significant hazaros consideration, and there has been no public comment on such finding (61 FR 28612 dated J;ne 5,1996). Acc.ordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

I 7.0 CONCLUSigi The Commission nas concluded, based on the considerations discussed above,

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that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by ci$ ration in the proposed manner, (2) such activities will be conducted in cr.ripliance with the Commission's regulat;uns, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

M. Pratt D. Shum Date:

November 12, 1996 t