ML20198B930
| ML20198B930 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/17/1991 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20198B934 | List: |
| References | |
| NLS-91-097, NLS-91-97, NUDOCS 9106270134 | |
| Download: ML20198B930 (7) | |
Text
Carolina Power & Light Company P O Bon 1551 e Aaleigh N C. 27602 SERIAL:
NLS-91 097 JUN li 1991 10CrR50.90 0 E. VAUGHN Vice President Nscitsar Seroces Department United States Nuclear Regulatory Conuaission ATTENTION:
Document Control Desk Washington, DC 20555 ERUNSWICK STEAM ELECTRIC PIANT, UNIT NO. 2 DOCKET NO. 50-324/ LICENSE NO. DPR-62 REQUEST FOR LICENSE AMENDMENT ONE-TIME EXTENSION OF DIESEL GENERATOR SURVEILIANCF INTERVAL TECilNICAL SPECIFICATION 4.8.1.1.2.D.1 Gentlemen:
l In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP),
Unit 2.
Technical Specification 4.8.1.1.2.d requires that certain surveillances (4.8.1.1.2.d.1 through 4.8.1.1.2.d.7) of the emergency diesel generators be performed at least once per 18 months during shutdown.
The proposed amendment allows a one-time only extension of the surveillance interval associated with Technical Specification 4.8.1.1.2.d.1 until November 21, 1991.
The proposed change was originally requested as part of the Company's March 18, 1991 license amendment request (NLS-91-066) which extended the surveillance interval associated with Technical Specifications 4.8.1.1.2.d.1 through 4.8.1.1.2.d.7.
Technical Specification requirements 4.8.1.1.2.d.2 through 4.8.1.1.2.d.7 were completed during an April 1991 Unit 2 outage. At the NRR Project Manager's request, the March 18, 1991 license amendment reouest was withdrawn (NLS-91-143, datea May 31, 1991) and this change is being submitted.
- evides i detailed description of the proposed changes and the basis for the change l details the basis for the Company's determination that the proposed changs do not involve a significant hazards consideration. provides the proposed Technical Specification pages for Unit 2.
In the interest of time, a typed rather than hand marked page is being provided.
In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina with a copy of the proposed license amendment.
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I Document Control Desk NLS 91-097 / Page 2 in order to allow time for procedure revision ano orderly incorporation into copics of the Technical specifications, CP&L requests that the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.
Please refer any questions regarding this submittal to Mr. M. R. Oates at j
(919) $46 6063.
Yours very truly, l
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G. E.Vau(hn GEV/ MAT
Enclosures:
cc:
Mr. Dayne 11. Brown Mr. S. D. Ebneter Mr. N. B. Le Mr. R. L. Prevatte i
G. E. Vaughn, having been first duly sworn, dio depose and say that the infor-mation contrained herein is true and correct
'.o the best of his information, and belief; and the sources of $
information are of ficerpi"" st knowledge and agents of Ca;;1ina Power 6 Light Cor p # t,h,,"Ch[,
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNIT 2 NRC DOCKET No. 50-324 OPERATING LICENSE NO. DPR-62 REQUEST FOR LICENSE AMENDMENT ONE TIME EXTENSION OF DIESEL GENERATOR SURVEILLANCE INTERVAL TECHNICAL SPECIFICATION 4.8.1.1.2.D.1 EA?IS FOR CHANGE RFOUEST Proposed Channe Technical Specificacion 4.8.1.1.2.d tequires that certain surveillances (4.8.1.1.2.d.1 through 4.8.1.1.2.d.7) of the emergency diesel generators be performed at 1 cast once per 18 months during shutdown. The proposed amendment allows a one-time only extension of the surveillance interval associated with Technical Specification 4.8.1.1.2.d.1 until November 21, 1991.
Basis Technical Specification 4.8.1.1.2.d requires certain surveillances (4.6.1.1.2.d.1 through 4.8.1.1.2.d.7) of the diesel generators be performed at least once per 18 months during shutdown. This 18 month interval has caused di.ficulties in the scheduling of the diesel generator surveillances.
Typically, diesel generator surveillances are performed near the beginning of refueling outage due to the availability of an outage window. This was the a
case for the Unit 2 Roload 8 outage during which portions of the recirculation pipir.g we.s replaced.
The pipe replacement effort resulted in a 23 week outage The Unit 2 core was designed to provide an 18 month operating cycle with an assumed availability of 85%.
Due to the extended Unit 2 Reload 8 outage, past performance of the required diesel generator surveillances during outage windows available early in the outage, anu the Unit 2 core design, Technical Specification 4.8.1.1.2.d.1 surveillances become due by October 3, 1991 for diesel generator 3 and September 25, 1991 for diesel generator 4.
This is prior to the planned surveillance outage window in the Unit 2 Reload 9 outage. The Reload 9 outage is currently forecasted to begin on September 12, 1991. The proposed amendment allows a one-time only extension of the surveillance interval associated with Technical Specliication 4.8.1.1.2.d.1 until November 21, 1991. This extension allows performance of the required vendor recommended surveillances during the appropriate Unit 2 Reload 9 outage window.
The purpose of the Technical Specification 4.8.1.1.2.d.1 required surveillance is to ensure that the diesel generators are functioning properly and to inspect for any potential problems.
This is accomplished via a partial tear down of the diesel generator, in accordance with plant procedure MST-DG500.
This procedure takes approximately six days to complete and is accomplished in five parts.
The first part consints of a review of oil and water analyses, periodic tests, and work orders, completed during the surveillance interval, to determine if there are any particular areas developing trends that may require additional investigation.
Parts 2 and 3 consist of inspections and El-1
preventive measures recommended by the diesel manufacturer plus any checks that may be advised based on Part 1 inver.t2gations.
Part 4 consists of system checks and maintenance engine testing of the auxiliary lube oil pump, the motor driven fuel oil pump, the motor driven jacket water pump and the engine to determine if the diesel generator is ready to be tested for operability.
Finally, Part 5 is a final operability test of the diesel while running.
Some exampler of the items checked during performance of MST-DG500 include 1.
Crank case for cleanliness.
2.
Lube oil system integrity.
3.
Gear train for pitting or wear.
4.
Camshaft area for metal particles 5.
Air start valves for freedom of movement.
6.
Traps and strainers for cleanliness and degradation.
7.
General condition of generator including brushes, collector ringt and brush rigging.
On March 29, 1990, Unit 2 was shut n and Technical Specification requirements 4.8.1.1.2.d.2 throug.
.8.1.1.2.d.7 were completed.
In addition, CP&L performed inspections, repai and operability testing of diesel generators. Many of the items normally checked during performance of MST-DG500 were checked during the recent Unit 2 outage. The not effect of performing Technical Specifica* ion requirements 4.8.1.1.2.d.2 through 4.8.1.1.2.4.7 and completing ot.ier maintenance and repair activities on the diesel generators has been to increase overall diesel generator reliability and to ensure that the diesel generators are functioning properly.
This increased confidence in diesel generator reliability more than offsets the ef fects of the proposed extension of the Technical Specification 4.8.1.1.2.d.1 diesel generator surveillance interval.
In addition, the diesel manufacturer has indicated that diesel generator reliability can be maintained by performing the tear-down inspection required in Technical Specification 4.8.1.1.2.d.1 once pc-1000 hours of diesel operation.
During a typical fuel cycle, a diesel generator is run far less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (anywhere from approximately 80 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />).
These run times are well below the vendor's recommended 1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency.
Based on the above, the proposed one-time extension of the Technical Specification 4.8.1.1.2.d.1 diesel generator surveillance interval will not eignificantly affect the diesel generators' ability to perform their intended safety function.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PIANT, UNIT 2 NRC DOCKET No. 50-324 OPERATINC LICENSE NO. DPR 62 REQUEST FOR LICENSE AMENDMENT ONE-TIME EXTENSION OF DIESEL CENERATOR SURVEILLANCE INTERVAL TECHNICAL SPECIFICATION 4.8.1.1.2.D.1 10 CFR 50.92 EVALUATION i
The Commission has provided standards in 10 CFR 50.92(c) for determining 1
whether a significant hazards co.;aideration exists. A proposed amendment to an operating license for a-facility involves no significant hazards
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consideration if operation of the facility in accordance with the proposed anendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. _ Carolina Power & Light Company has reviewed this proposed license amendment request and determined thac its adoption would not involve a significant hazards consideration. The bases for this determination are as follows:
i I
Proposed Chance
'lechnical Specification 4.8.1.1.2.d requires that certain surveillances (4.8.1.1.2.d.1 through 4.8.1.1.2.d.7) of the emergency diesci generators be performed at least once per 18 months during shutdown. The proposed amendment allows a one-time only extension of the surveillance interval associated with Technical Specification 4.8,1,1.2.d.1 until November 21, 1991.
Basis The change does not involve a-significant hazards consideration for the following reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
A one time extension of Technical Specification 4.8.1.1.2.d.1 vendor recommended surveillances for diesel generators 3 and 4 until November 21, 1991 will not result in a significant increase in the probability of the diesel generators failing to perform their intended safety function.
The purpose of the Technical Specification 4.8.1,1,2.d.1 required surveillance is to ensure that the diesel generators are functioning properly and to inspect for any potential problems. This is accomplished via a partial tear down of the diesel generator, in accordance with plant procedure MS7-DC500, This procedure takes approximately six days to complete and is accomplished in five parts. The first part consists of a review of oil and water analyses, periodic tests, and work orders, completed during the surveillance interval, to determine if there are any particular areas developing i
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trends that may require additional investigation.
Parts 2 and 3 consist of inspections and preventive measures recommended by the diesel manufacturer plus any checks that may be advised based on Part 1 investigations.
Part 4 consists of system checks and maintenance engine testing of the auxiliary lube oil pump, the motor driven fuel oil pump, the motor driven jacket water pump and the engine to determine if the diesel generator is ready to be tested for operability.
Finally, Part 5 is a final operability test of the diesel while running.
On March 29, 1990, Unit 2 was shutdown and Technical Specification requirements 4.8.1.1.2.d.2 through 4.8.1.1.2.d.7 were completed.
In addition, CP&L performed inspections, repairs, and operability testing of diesel generators.
Many of the items normally checked during performance of MST-DG500 were checked during the recent Unit 2 outage.
The net effect of performing Technical Specifi;ation requirements j
4.8.1.1.2.d.2 through 4.8.1.1.2.d.7 and completing other maintenance and repair activities on the diesel generators has been to increase overall diesel generator reliability and to ensure that the diesel generators are functioning properly. This increased confidence in diesel generator reliability more than offsets the effects of the proposed extension of the Technical Specification 4.8.1.1.2.d.1 diesel generator surveillance interval.
In addition, the diesel manufacturer has indicated that diesel generator reliability can be maintained by performing the tear-down inspection required in Technical Specification 4.8.1.1.2.d.1 once per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of-diesel operation.
During a typical fuel cycle, a diesel generator is run far less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (anywhere from approximately 80 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />).
These run times are well below the vendor's recommended J
1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency.
The diesel generator surveillance requirements are intended to maintain diesel generator reliability at a level which assures that adequate electrical power is available under the most limiting accident conditions within the accident analysis for the Erunswick Plant.
The most limiting accident condition includes the loss of all off-site power and the assumed single failure of one diesel generator.
Based on the above discussion, the proposed one-time extension of the surveillance frequency for Technical Specification 4.8.1.1.2.d.1 will not adversely affect diesel generator availability or reliability. Thus, extending the Technical Specification 4.8.1.1.2.d.1 surveillance incerval until November 21, 1991 (approximately 2 months) will not involve a significant increase in the probability of a previourly evaluated accident.
There are no physical changes to the diesel generstors or their manner of operation nor are there any changes to the surveillance acceptance criteria as a result of the proposed amendment.
Recent completion of Technical Specification requirements 4.8.1.1.2.d.2 through 4.8.1.1.2,d.7 and completion of other maintenance and repair activities on the diesel generators has ensured continued diesel generator reliability.
Since l
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diesel generator teliability i s being maintained at acceptable levels, diesel generator failures beyond the already designed and analyzed for single failure are no more likely to occur during the requested extension of the Technical Spr.cification 4.8.1.1.2.d.1 surveillance interval until November 21, 1991 (approximately 2 months). As such, the proposed amendment will not '.nvolve a significant increase in the consequences of a previously evaluated accident.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The propcaed amendment only extends the surveillance interval for Technical Specification 4.8.1.1.2.d.1.
There is no change to tho plant or its manner of operation. Also, there are no changes to the surveillance acceptance criteria. Therefore, the proposed change cannot create the possibility of a new or different kind of accident from any previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the margin of safety.
Extending the Technical Specification 4.8.1.1.2.d.1 surveillance interval to November 21, 1991 for diesel generators 3 and 4 will not result in a significant increase in the probability of the diesel generator failing to perform its intended safety function. There are no changes to the diesel generators or their manner of operation nor 4
are there any changes to the surveillance acceptance criteria as a result of the proposed amendment.
The diesel manufacturer has indicated that diesel generator reliability can be maintained by performing the tear down inspection required in Technical Specification 4.8.1.1.2.d.1 once per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of diesel operation.
During a typical fuel cycle, a diesel generator is run far less than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (anywhere from approximately 80 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />).
These run times are well below the vendor's recommended 1000 hour0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> diesel generator inspection frequency.
In addition, during an cutage which began on March 29, 1990, Technical Specification requirements 4.8.1.1.2.d.2 through 4.8.1.1.2.d.7 were completed.
CP&L also performed inspections, repairs, and operability testing of diesel generators. Many of the items checked during performance of MST-DGS00 were checked during the recent Unit 2 outage.
The not effect of these actions has been to increase overall diesel generator reliability.
This increased confidence in diesel generator reliability more than offsets the effects of the proposed extension (approximately 2 months) of the Technical Specification 4.8.1.1.2.d.1 diesel generator surveillance interval until November 21, 1991.
Based on this reasoning, the effects of a one-time extension of the surveillance interval would be negligible and the proposed amendment does not invclve a significant reduction in the margin of safety.
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