ML20151D707

Application for Amend to License NPF-36,reducing Test Frequency of Emergency Diesel Generators Per Recommendations of Generic Ltr 84-15

ML20151D707
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/15/1988
From:	Leonard J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20151D677	List: L-84-151, Forwards Application for Amend to License NFP-36,consisting of License Change Application 15.Amend Reduces Test Frequency of Emergency Diesel Generators Per Generic Ltr 84-15.Fee Paid ML20151D707 ML20151D714
References
GL-84-15, NUDOCS 8807250206
Download: ML20151D707 (6)

Text

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[ LONG ISLAND LIGHTING.' COMPANY Operating 7,1 cense NPF-36 Docket 50-322 License Change Application 15

.This: License Change Application requests modification to Operating License NPF-36 for the Shoreham Nuclear Power Station to-reduce. test l frequency of the Emergency Diesel Generators (EDGs) in accordance with the recommendations of Generic Letter 15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability", and to run the diesel generators at a minimum load during this testing, based on the recommendations of ip -the diesel generator manufacturer, in order to lessen EDG wear and_ degradation.

.g The request and supporting documentation are contained in Attachments 1 and 2 to this License Change Application.

A Long Island Lighting Company l

By . ;w_ k h6k4 oh D. Leonard, Jr.

N Vice President - Nuclear erations Subscribed and sworn to before me this /f* day of July 1988.

l Not' ark Public of N6w Yafk My Commission Expires: /% red 20 /99d UNDA A. CRAUy NOTARY PU8ut st,t, og ,;,, yg No.4816267 Qualifed in Suffe County

&mmisson Empires March 30.192p

..8807250206 DR 880715 ADOCK 05000322 PDC _.

_ _ _ _ _ ___-___-____.._u____________________2.________a_ _____________m ____________

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UNITED STATES OF AMERICA P NUCLEAR REGULATORY-COMMISSION g

a In the Matter of

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Long Island-Lighting CompanyJ

)- Docket No. 50-322

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SHORFHAM. NUCLEAR' POWER STATION - UNIT 1

' CERTIFICATE OF SERVICE I hereby certify that copias'of License Change Application 15 to t

the Operating License for Shoreham Nuclear Power Station _ Unit

'S l',' dated July g -1988,- have been served on the following by hand-deliver gor by deposit in~the United States ma n , first class, this _M_-' day.of Ju1*/.1988:

Mr. Jay Dunkleberger New York State-Energy Office 2 Rockefeller Plaza

'k Albany, New York 12223

.L. F. Britt, Manager Nuclear Licensing and Regulatory Affairs Subscribed and sworn to before me this /d day of July 1988 4

Notary Public of New p rk' My Commission Expires [/ared JO, /7%

llN04 A. CRATTY NOTARY PUBUC. State of Ne, yo,g No.4816261 QUS% 6 $dssk %nt bmmtS900 Espres Magg p'ggyg

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'" SNRC-1481 Attachment 1 Page 1 of 4 b Attachment 1 To License Change Application 15

1.0 DESCRIPTION

OF CHANGE' This change-reduces the number of starts and runs of the EDGs due to an engine or offsite circuit out of service, incorpor-

-ates loading of the EDGs during this testing, revises the

-table for determining diesel surveillance frequency, and provides for determination of EDG testing frequency on an individual engine basis. The changes as described below are shown inLAttachment 2, identified by revision bars in the right margins.

Action Statement 3.8.1.1.a has been revised to address only an inoperable offsite circuit rather than one inoperable off-site circuit or diesel generator. Individual diesel gener-ators will undergo Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 (with the diesel generators loaded to 1400 KW) if they.have not been successfully tested within-a prc/ious 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The current requirement is to demonstrate their operability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

Action Statement 3.8.1.1.b has been revised to addrets only an inoperable diesel generator rather than one inoperable offsite circuit and one inoperable diesel generator. The remaining operable diesel generators shall be demonstrated operable by performance of Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 if the first diesel generator has become inoperable due to any cause other than preplanned preventive maintenance or testing, such as fuel oil pump, jacket water pump, or cam galley inspections and/or mainten-

.ance. The current requirement is to demonstrate their operability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. The requirement for restoration of at least two offsite circuits and the remaining diesel generators is deleted. The inoperable diesel generator must be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> rather than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Action Statement 3.8.1.1.c is a new action statement to address inoperability of one offsite circuit and one diesel generator. The remaining A.C. sources must be demonstrated operable as in Action Statements 3.8.1.1.a and b. The inope able A.C. sources must be restored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or the reactor must be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restoration of at least 2 offsite circuits and all of the required diesel generators must be restored as in Action Statements 3.8.1.1.a and b.

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SNRC-1481 Attachment 1 Page 2 of 4 Action Statement 3.8.1.1.d _(previcusly Action Statement c) involves an editorial revision to change the referenced Action Statements to "b" and "c" rather than "a" and "b".

Action Statement 3.8.1.1.e (previously Action Statement d) has been revised to require performance of Surveillance Requirement 4.8.1.1.2.a.5 (with the diesel generator loaded to 1400 KW) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rather than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least every 8. hours thereafter. Successful performance of Surveillance Requirements 4.8.1.1.2.a.4 and 5 satisfies diesel generator test requirements for Action Statement 3.8.1.1.a.

Table 4.8.1.1.2-1 has been revised to review the results of diesel generator testing after 20 valid tests and 100 valid tests. The test schedule'is determined on a per diesel generator basis and criteria for determining the required test frequency have been added in the footnotes.

2.0 REASON FOR CIJANGE This change is requested in accordance with the recommenda-tions of Generic Letter 84-15 to reduce the frequency of diesel generator testing and, in accordance with the recom-mendations of the diesel generator manufacturer, to start and run the diesels at a minimum loud thereby reducing the amount of wear and degradation of the diesels. These changes should serve to-increase diesel generator availability by testing diesel generators on an individual basis and should improve relisbility by reducing the frequency of tests and runs.

Diesel ger.erators will also undergo testing at a load which will reduce engine stresses. The bases for the specific changes are presented in the following items a, b and c.

a) Individual testing of the diesel generators, which have not been successfully tested within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, has been incorporated to delete the requirement to test all remaining diesel generators. More frequent testing wou'd not provide significant additional assur-ance of operabi.ity and would increase engine wear.

b) Action Statements 3.8.8.1 a, b, c,e, and f have been modified with a footnote to run diesel generators at a load of 1400 KW. The requirement to run diesel gener-ators at 1400 KW during this testing is in compliance with, and well above, the manufacturer's recommended minimum load of 1050 KW, which corresponds to an intake air manifold pressure of 10 inches of mercury. Running diesel generators at 1400 KW per action statement requirements will help to decrease engine stresses associated with testing at the qualified load of 3300 KW and will help to reduce er.gine wear associated with operation at no or low load.

. . . l SNRC-1481 1

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Attachment 1 j

'Page 3 of 4 c) The revised test-schedule, based on the number of l failures in the previous 20 and 100 valid tests on a per diesel generator basis, is in accordance with the recommendation in Generic Letter 84-15 and allows fc_

the-evaluation of diesel generator operability more

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frequently-than if the results of only 100 valid tests are examined. The revisions in the "Test Frequency" column of Table 4.8.1.1.1-1 reduce the actual frequency to once per.7 days, so as to reduce engine wear and degradation.

3.0 BASIS FOR NO SIGNIFICANT HAZARDS FINDING The proposed Jicense change does not involve a significant hazards consideration because operation of the Shoreham Nuclear Power Station, in accordance with this change, would not:

(1)' involve a significant increase in the probability or consequences of an accident previously evaluated as it does not alter the onsite standby power supply system design or the system's operability and availability requirements. The diesel generators are required to supply the same emergency load service regardless of the

-proposed change. The reduction of test frequency, the independent testing and the loading to 1400 KW should reduce the potential for failures caused by excessive testing and running diesels at low or no load. Surveil-lance Testing of the diesel generators at a load of 3300 KW will continue to be performed every 31 days.

(2) create the possibility of a new or different kind of accident from any accident previously evaluated as on-site standby power supply system design and operability requirements are not affected by the proposed change.

(3) involve a significant reduction in a margin of safety as the diesel generators are required to supply the same emergency load service, regardless of the proposed change. Performance of diesel generator testing within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, upon inoperability of one or more offsite circuits (3.8.1.1 a, e), provides little additional assurance of diesel generator opera-bility than testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a previous surveillance test or within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Upon loss of offsite circuits, diesel generator reliability is not expected to be adversely affected, thus, surveillance testing within 24 or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides adequate assurance of diesel generator operability. It also allows time l for pre-test inspection, if required, and sequential l tcsting of diesel generators. The proposed requirement (3.8.1.1.b,c) that upon unplanned inoperability of the L _ _ _ , , _

SNRC-1481.

ei Attachment 1 Page 4 of 4 L

diesel b'eing tested, the remaining. diesels.are indi-vidually tested-within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is incorporated to determine if.a common mode-failure exists. Otherwise, testing of the remaining diesel generators is;not frequired. The addition of; Surveillance Requirement 4.8.1.l'.2.a.5 which includes running the diesel gener-ators at 1400 KW,.will demonstrate operability and availability without subjecting diesel generators to

- operating stresses which.can' occur by testing at the qualified load of 3300 KW. This requirement will also reduce the amount of wear associated with running diesel generators at no or low loads. Each diesel generator

' has aLtest' schedule based on its individual performance in previous surveillance. tests. Test schedules will now be determined by the number of fai-lures per 20 consecu-tive tests in addition to thn'100 consecutive tests originally identified (Table 4.8.1.1.2-1). The proposed tech spec changes are consistent with the guidelines of Generic. Letter 84-15. They will serve to reduce the number of diesel starts and runs, thereby reducing wear and tear and ultimately degradation and failure. The proposed changes should improve overall safety.

The Commission has provided guidance concerning the applicability of standards for determining whether a significant hazard consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration. Example (vii) relaten to a change to make a license conform to changes in regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations. While Generic Letter 84-15 is not a regulation, i.e., not mandatory, it comprises NRC guidelines which LILCO, by requesting this license

= change, is complying with. Similar to example (vii) no changes to facility operations are involved. The limiting conditions for operation and monthly diesel generator surveillance testing remain unchanged.

Based upon the above considerations and analyses, LILCO has determined that this proposed change does not involve e significant hazards consideration.

4.0 TIMING OF CHANGE Since this change should improve diesel generator reliability and availability, thereby enhance overall plant safety, LILCO requests that this change become effective as soon as possible.

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