ML20202C285

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Safety Evaluation Supporting Amend 59 to License NPF-86
ML20202C285
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 01/21/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20202C283 List:
References
REF-GTECI-B-56, REF-GTECI-EL, TASK-B-56, TASK-OR GL-94-01, GL-94-1, NUDOCS 9901290365
Download: ML20202C285 (5)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 59 TO FACILITY OPERATING LICENSE NO. NPF-86 l

NORTH ATLANTIC ENERGY SERVICE CORPORATION SEABROOK STATION. UNIT NO.1 DOCKET NO. 50-443 l

1.0 INTRODUCTION

By letter dated March 2,1998, North Atlantic Energy Service Corporation (NAESCO) subr "nd

, a request for changes to the Seabrook Station Technical Specifications (TS). The requested l

changes would eliminate the accelerated testing and special reporting requirements for emergency diesel generators in TS 4.8.1.1.2a,4.8.1.1.3, Table 4.8-1, and 4.8.1.2, in accordance with Generic Letter (GL) 94-01.

2.0 BACKGROUND

The NRC issued GL 94-01 on May 31,1994, in response to the Commission decision on SECY-93-044, " Resolution of Generic Safety issue B-56, ' Diesel Generator Reliability'." The GL advised licensees that they could request a license amendment to remove accelerated testing and special reporting requirements for emergency diesel generators (EDG) from plant TS.

However, the GL indicated that licensees must have a maintenance program for monitoring and maintaining EDG reliability in order to modify the TS. The GL specified that the licensee's maintenance program must meet the requirements of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"(the Maintenance Rule),

and Regulatory Guide (RG) 1.160,

  • Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.". implementation of 10 CFR 50.65 for all safety significant plant equipment, including the EDG's, would eliminate unnecessary EDG testing, and improve overall EDG reliability.

1 3.0 EVALUATION l

3.1 Technical Specification Changes Proposed by NAESCO in their License Amendment Request (LAR) 97-06, NAESCO proposed to revise the current Seabrook TS to remove EDG accelerated testing and special reporting requirements as follows:

3.1.1 Chance 1 re: TS 4.8.1.1.2a: The licensee proposes to change Surveillance Requirement (SR) 4.8.1.1.2a. to specify EDG testing at least once every 31 days.

1 9901290365 990121 PDR ADOCK 05000443 P

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j i This proposed change will eliminate the accelerated testing requirements for diesel generators as specified in Table 4.8-1 of the TS. This proposed change is consistent with GL 94-01 guidance. Removal of accelerated testing was recommended in GL 94-01 to eliminate unnecessary testing of diesel generators and to improve the overall reliability of diesel generators. The licensee's March 2,1998, letter indicates that, as required by GL 94-01, the Maintenance Rule Program established for the Seabrook Station is consistent with the provisions of 10 CFR 50.65, RG 1.160, and Nuclear Utility Management and Resources Council guideline NUMARC 93-01," Industry Guide for Moriitoring the Effectiveness of Maintenance at Nuclear Power Plants." Accordingly, the staff finds the proposed change to be acceptable.

Because the licensee is required to monitor and maintain EDG performance in accordance with 10 CFR 50.65, there is no need to duplicate this requirement in the plant TS.

3.1.2 Chance 2 re: Table 4.8-1: The licensee proposes to delete TS Table 4.81," Diesel Generator Test Schedule."

This proposed change is consistent with the elimination of accelerated testing requirements for diesel generators, as recommended in GL 94-01, and is acceptable. Since revised SR 4.8.1.1.2a. will specify EDG test frequency, the table is no longer needed, and it is appropriate to remove the table from the TS.

3.1.3 Chanae 3 re: TS 4.8.1.1.3 and TS 4.8.1.2: The licensee proposes to delete SR 4.8.1.1.3. and reference to SR 4.8.1.1.3 in SR 4.8.1.2 to remove EDG failure reporting requirements from the TS.

This proposed change is consistent with GL 94-01 guidance and is acceptable. Title 10 of the Code of Federal Regulations, Part 50.72 "Immediate Notification Requiremer.ts for Operating Nuclear Power Reactors," and Part 50.73 " Licensee Event Report System" require NAESCO to notify the NRC about EDG performence problems. The licensee's March 2,1998, letter specifically states that reporting requirements for EDG failures will continue to be complied with in accordance with the provisions of 10 CFR 50.72 and 50.73.

3.2 The Seacoast Anti-Pollution League (SAPL) Opposition to Proposed TS Revisions On May 22,1998, The Seacoast Anti-Pollution League (SAPL) wrote to the Commission expressing, among other things, concern that changes in the diesel generator testing schedules might reduce plant safety. SAPL's letter documented formal opposition to severallicensee applications for TS revisions, including LAR 97-06. SAPL expressed concern that the proposed TS revision results in lowering the testing standards for the EDGs, and increases the risk to on-and off-site personnelin the event of an accident at the plant.

GL 94-01 specifically focuses on resolution of Generic Safety issue B-56," Diesel Generator Reliability," and has resulted in changes '.o the regulatory guidance related to EDG surwillance testing intended to enhance EDG reliability and availability. The staff believes that unnecessary testing of EDGs promotes premature aging and component failure due to accelerated testing requirements which are counterproductive to nuclear plant safety.

. GL 94-01 provides for enhanced reliability of EDG's by shifting the specific requirements governing EDG testing from the TS to a comprehensive maintenance orogram designed to meet the provisions of 10 CFR 50.65, the Maintenance Rule. Implementation of the Maintenance Rule in accordance with RG 1.160 and associated Nuclear Utility Management and Resources Council guideline NUMARC 93-01 as proposed in GL 94-01, includes the performance of necessary corrective maintenance, performance of detailed root cause analysis of individual EDG failures, and implementation of preventive maintenance activities focused on enhancing EDG reliability and performance.

The licensee's March 2,1998, letter states that, since the implementation of the 10 CFR 50.65 Maintenance Rule at the Seabrook Station in July 1996, both EDGs have demonstrated acceptable performance. The licensee's decisions concerning balancing the benefits of preventive maintenance and time out of service necessan' to conduct maintenance activities have resulted in highly reliable EDGs with unavailability facto-consistent with assumptions in the Seabrook Station PRA. The NRC staff's 1997 baseline mspection of the Seabrook Station Maintenance Rule Program found that the design of the program and its implementation were consistent with the requirements of 10 CFR 50.65.

Based on these considerations, the staff finds that SAPL's concerns, regarding lowering of EDG testing standards and increased post-accident risk to the public resulting from the licensee's application for TS revisions implementing the guidance of GL 94-01, are not valid.

3.3 Conclusion The staff has evaluated the licensee-proposed changes documented in Section 3.1. The staff finds that the proposed TS changes are acceptable because, the changes are either formulated to improve the reliability and performance of the emergency diesel generators; or they are administrative and intended to clarify the TS.

4.0 S_ TATE CONSULTATION in accordance with the Commission's regulations, the State of New Hampshire and the Commonwealth of Massachusetts officials were notified of the proposed issuance of the amendments. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves 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 issued a proposed finding that the amendment involves no significant hazards consideration (63 FR 19971). Public comments

. from The Seacoast Anti-Pollution League were received. The staff response to the comments conceming LAR 97-06 is provided in section 3.2 of this safety evaluation. The comments do not affect the staff's proposed no significant hazards consideration determination. Accordingly, the amendment meets 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 amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation of the Seabrook Station in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: S. Patrick Sekerak Date: January 21, 1999 i

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7.0 REFERENCES

1.

U.S. NRC paper SECY-93-044," Resolution of Generic Safety issue B-56, ' Diesel l

l Generator Reliability'," February 22,1993.

2.

U.S. NRC Regulatory Guide 1.160, Rev. 2, " Monitoring the Effectiveness of Maintenance at Nuclear Power P6nts," March 1997.

l 3.

U.S. NRC Generic Letter 94-01," Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," May 31,1994.

1 4.

NUMARC 93-01, Rev. 3, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Energy institute, May 1996.

5.

NRC Maintenance Rule Team inspection Report No. 50-443/97-80, March 31, 1997.

6.

The Seacoast Anti-Pollution League letter re: North Atlantic Energy Services Corp.,

Docket No. 50-443, Seabrook Station, Unit 1, Rockingham County, New Hampshire, May 22,1998.

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