ML20209D231

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Application for Amend to License NPF-36,modifying Certain Emergency Diesel Generator License Conditions to Form Basis for Qualification of Tdi Emergency Diesel Generators Over Entire Life of Plant.Supporting Documentation Encl
ML20209D231
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/24/1987
From: Leonard J
LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20209D219 List:
References
NUDOCS 8704290208
Download: ML20209D231 (11)
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LONG ISLAND LIGHTING COMPANY Operating License NPF-36 Docket 50-322 License Change Application 8 This License Change Application requests modification of certain emergency diesel generator (EDG) license conditions. Operating License NPF-36 for the Shoreham Nuclear Power Station mandates certain EDG conditions as described in Attachment 3 to the license. These license conditions provide a basis for the qualification of the TDI EDGs through the first cycle of plant operation. This request proposes licensing conditions that form a basis for qualification of the TDI EDGs over the entire life of the plant. The new conditions are a combination of the existing license conditions, required during the first fuel cycle and through the first refueling outage, and the requirements of NUREG-1216 for the balance of the plant life.

The request and supporting documentation are contained in the Attachment to this License Change Application.

Long Island Lighting Company By h ,q 24 Jo sy. Leonard, Jr. /'

Og42gg((((0003g2 Vi e I resident - Nuclear O e::ations P

Subscribed and sworn to before me this dY day of April 1987.

NOTARY BL C Sta e f cw Ycelr (

QuahfM m sum cowy Notary'Public of New Ydlif Ocmmissen spores March 30, IJf My Commission Expires: N/areb 30. )3I

O Attachment To License Change Application 8

1.0 DESCRIPTION

OF CHANGE The detailed maintenance and surveillance requirements are shown in Exhibit A, Pages 1 - 7 (Attachment 3 to NPF-36).

The new proposed license amendments combine the existing license conditions during the first fuel cycle and through the first refueling and then utilize the requirements of NUREG-1216 for the balance of plant life.

2.0 REASON FOR CHANGE These changes allow LILCO to implement the staff's requirements which establish the basis for the continued qualification, reliability and operability of the TDI engines over the entire life of the plant. These license condition changes involve detailed maintenance and surveillance activities for critical engine components. When implemented they will ensure proper and safe operation of the engines and maintain their adequacy and availability for nuclear standby service. These proposed license condition changes do not affect any plant conditions or parameters nor do they involve any Technical Specification changes. Finally, these proposed license changes incorporate all of the TDI Owner's Group or PNL recommendations, which were reviewed and approved by the Staff in NUREG 1216.

3.0 BASIS FOR NO SIGNIFICANT HAZARDS FINDING The proposed license condition changes do not involve a significant hazards consideration because operation of the Shoreham Nuclear Power Station Unit 1, in accordance with this change, would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed license conditions as mandated through the Staff's final SER (NUREG-1216), establish the basis for the continued design adequacy and qualification of the SNPS TDI engines for nuclear standby service, as required by GDC 17 of Appendix A to 10 CFR 50. The incorporation of the most critical periodic maintenance /

surveillance inspections for certain Phase I engine components as license conditions will ensure continued reliability and operability of these units over the life of the plant. These proposed license conditions do not involve any changes in the system's design and operability requirements nor in the plant operating conditions or parameters.

(2) create the possibility of an accident that is different than already evaluated in the USAR. The proposed license conditions involve maintenance and surveillance activities for critical engine components in order to ensure proper and safe operation of the engines and maintain the adequacy and availability of these units for nuclear standby service. These proposed license condition amendments do not affect any plant conditions or parameters nor do they alter the system design and operability requirements. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated cannot be created.

(3) involve a significant reduction in the margin of safety as defined in the bases to Technical Specifications 3/4.8. All required inspections for critical engine components that are incorporated in these proposed license conditions meet or exceed those recommended by the vendor and the TDI EDG Owner's Group DR/QR program.

These inspections do not alter the functional safety requirements of the emergency diesel generators, thus there is no impact on the results and conclusions of the USAR Chapter 15 analyses and no impact on the margin of safety. Also, all requirements of the existing license conditions as imposed by the NRC are maintained until startup from the first refueling outage. Furthermore, all proposed new license conditions for post first fuel cycle have been reviewed and approved by the NRC staff and documented in NUREG-1216. Therefore, the proposed license changes do not involve a significant reduction in the margin of safety.

CONCLUSION The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration. Example (ii) relates to a change that consitutes an additional limitation, restriction or control not presently included in the technical specifications:

for example, a more stringent surveillance requirement. Example (vii) relates to a change to make a license conform to changes in the regulations.

In this case, the proposed changes described above are similar to both Example (ii) and Example (vii).

First, these proposed license changes constitute additional controls and conditions not presently included in facility operating license NPF-36. For example, the conditions pertaining to the turbochargers do not currently exist. Second, these l proposed changes will make NPF-36 conform to the finding and l recommendations in the NRC Staff Safety Evaluation Report of the Operability / Reliability of Emergency Diesel Generators manufactured by Transamerica Delaval, Inc. (NUREG-1216).

Therefore, based upon the above considerations, TDI Owners Group analyses, PNL analysis and the NRC Staff Safety Evaluation Report, LILCO has determined that this proposed change does not involve a significant hazards consideration.

4.0 TIMING OF CHANGE This proposed license conditions will require several station procedure changes. LILCO expects to have the appropriate station procedures changed and approved by the end of June, 1987.

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EXHIBIT A ATTACHMENT 3 Emergency Diesel Generator (EDG) 101, 102 and 103 License Conditions A. General Changes to the maintenance and surveillance program for the TDI diesel engines, as identified in NUREG-1216, Section 2.3,

" Maintenance / Surveillance Program" shall be subject to the provisions of 10 CFR 50.59.

The frequency of the major engine overhauls referred to in the license conditions below shall be consistent with Section IV.1, " Overhaul Frequency" in Revision 2 of Appendix II of the Design Review / Quality Revalidation report which was transmitted by letter dated May 1, 1986, from J. George, Owners Group, to H. Denton, NRC.

B. Cylinder Block The following inspection requirements are as defined in Failure Analysis Associates, Inc. (FaAA) report entitled,

" Design Review of TDI R-4 and RV-4 Series Emergency Diesel Generator Cylinder Blocks" (FaAA report no. FaAA-84-9-ll.1) and dated December 1984. The inspection intervals (i.e.,

frequency) shall not exceed the intervals calculated using the cumulative damage index model in the subject FaAA report.

Liquid-penetrant testing or a similarly sensitive nondestruc-tive testing technique should be used to detect cracking, and eddy current should be used as appropriate to determine the crack depth.

1. EDG 101, 102 and 103 cylinder block top surface shall be inspected for " ligament" cracks, " stud-to-stud" cracks and " stud-to-end" cracks at each major engine overhaul.
2. The licensee shall perform eddy current testing or boroscopic examination between adjacent cylinder heads l after any operation of EDG 101 or 102 at greater than  ;

1750 KW. -

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3. EDG 101 and 102 cylinder block top surface shall be partially inspected at each refueling outage to deter-mine whether or not cracks have initiated on the top surface exposed by the removal of two cylinder heads.

This process should be repeated over four refueling outages until the entire block top has been inspected.

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4. If any inspection reveals cracks in the cylinder blccks between stud holes of adjacent cylinders (" stud-to-stud" cracks) or " stud-to-end" cracks, this condition shall be reported promptly to the NRC staff and the affected engine shall be considered inoperable. The engine shall not be restored to " operable" status until the proposed disposition and/or corrective actions have been approved by the NRC staff.
5. In addition to the above, the following license conditions are applicable during the first fuel cycle and through the first refueling outage. l
a. During any period of continuous operation following automatic diesel generator initiation, the licensee shall perform daily visual inspections of the area between adjacent cylinder heads and the general block top. The licensee shall also perform visual inspections of the same areas under intense light during the monthly surveillance testing. This condition is applicable to EDGs 101, 102, 103.
b. Following any loss of offsite power event which results in the automatic starting of any EDG, the licensee shall inspect the top surface of the block exposed by the removal of two appropriate cylinder heads from each of the three EDG engines. Inspec-tions shall be by liquid penetrant, with eddy current for any identified cracks, to determine the
presence of new cracks and the depth of any new or old cracks.
c. The licensee shall perform a liquid penetrant and, as appropriate, UT inspection of the cylinder liner landing at any time a cylinder liner is removed for any other reason. This condition is applicable to EDGs 101, 102 and 103.
d. Examination of the block top between cylinder heads as required by item 2 above will be performed by eddy current inspection only.

C. Cylinder Block Cam Gallery Cracks Cam gallery saddle locations nos. 2 and 8 on the EDG 101 and 102 blocks will be inspected by LILCO every three months, or after 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of operation at or above a load of 1800 KW, whichever comes first. These inspections shall be performed from the time the EDGs are initially placed in operation for emergency standby service until the first refueling outage.

Liquid penetrant examinations of the nos. 2 and 8 saddle locations shall be performed to monitor the length of the cracks, followed by TSI depth gauge measurements of the cracks to monitor their depth.

7 D. Crankshafts

1. EDGs 101, 102, and 103 shall not be operated at power levels greater than_3400 KW*, as indicated by the l installed power meter in the Shoreham control room. If.

an' engine is operated at a power level greater than 3400 KW, for any time, (1) the engine shall be removed,from service as soon as is safely possible, (2) the engine '

shall be declared inoperable, and (3) the crankshaft "

shall be inspected in accordance with the provisions of conditions D.4 and D.5.

2. For the first fuel cycle EDGs 101, 102, and 103 are each limited to two hours of cumulative operation at loads between 3300 and 3400 KW, in addition to the monthly surveillance tests. If this limit is exceeded, (1) the engine shall be removed from service.as soon as is safely possible, (2) the engine shall be declared i inoperable, and (3) the crankshaft shall be inspected in 1 accordance with the provisions of conditions D.4 and D.5 below.

! 3. Following the satisfactory inspections of the EDGs 101, 102 and 103 crankshafts at the first refueling outage, if the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ** cumulative load limit of 3300 to 3400 KW, described in D.2 above is exceeded, a crankshaft inspection pursuant to items D.4 and D.5 shall be performed at the next refueling outage.

4. At each refueling outage, the licensee shall measure and record hot and cold web deflection readings on each of the diesels.
5. At the first refueling outage, the licensee shall inspect the crankpin journals numbered 5, 6 and 7 and the main bearing journals between crankpins 5, 6 and 7, including the associated oil holes and fillets in all of these journals, using LP and ET as appropriate. This condition is applicable to EDGs 101, 102 and 103.
6. During the second and third refueling outages, inspect the fillets and oil holes of two of the three most heavily loaded crankpin journals in each crankshaft, using liquid penetrant. Indications found should also be evaluated with eddy current methods as appropriate.
7. Following the third refueling outage, inspect the fillets and oil. holes of the (a) three most heavily loaded crankpin journals (Nos. 5, 6, and 7) and (b) the main journals located between crankpin journals 5, 6 and 7, at the refueling outage corresponding to an approximately five year interval between crankshaft inspections.

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  • Momentary transients (not exceeding 5 sec) that result from i changing bus loads need not be considered as an overload.

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    • If there are multiple overload events since the previous l

crankshaft inspection, then the time criterion applies to the total accumulated time in the load' range.

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E. Cylinder Heads

1. Cylinder heads purchased as replacements will be inspected in accordance with paragraphs (a) and (b) are subject to paragraph (c) below.

(a) Perform an ultrasonic inspection of the firedeck of all the cylinder heads at six locations to verify that the minimum thickness requirements of .400 inch is met. The six locations are specified as follows:

(i) The first location is on the firedeck between the exhaust gas ports approximately directly between the two exhaust gas ports.

(ii) The second location is approximately 1 1/2" from the first location in a direction toward the exhaust side of the cylinder head.

(iii) The third location is approximately 2" from the first location in a direction toward the intake side of the cylinder head.

(iv) The fourth location is approximately midway j between the injector port and the exhaust port on the governor side . the head.

(v) The fifth location is approximately directly between the two intake gas ports.

(vi) The sixth location is approximately midway between the injector and exhaust port on the flywheel side of the head.

l Cylinder heads not meeting this thickness requirement l shall not be used.

(b) Perform surface inspection (either liquid penetrant i or magnetic particle) of intake and exhaust valve seats and the firedeck area between the exhaust valves to verify that they are free of unacceptable {

surface defects. Cylinder heads with unacceptable and irreparable surface defects shall not be used.

Acceptance criteria are as specified in ASME III, paragraph NB-5350.

(c) Ascertain from shop records or otherwise whether any heads have through-wall weld repairs of the firedeck where the repair is performed from one side only. Any such heads shall not be used.

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2. Any head which leaks due to a crack shall be replaced.
3. The air roll test described below shall be performed as specified except when the plant is already in an Action Statement of Technical Specification 3/4.8.1, " Electric Power Systems, A.C. Sources:

( The licensee shall bar the engines over with the barring device and roll the engines over with the airstart system, with the cylinder stopcocks open, prior to each l planned start, unless that start occurs within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a shutdown. In addition, after engine operation, the engines shall be barred and rolled over with-the air-start system and with the cylinder stopcocks open after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, but no more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after engine shutdown and then rolled over once again approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after each shutdown. In the event an engine is removed from service for any reason other than the rolling over procedure prior to expiration of the 8-hour or 24-hour periods noted above, that engine need not be rolled over while it is out of service. The licensee shall air roll the engine over with the stopcocks-open at the time it is returned to service. The origin of any water detected in the cylinder must be determined and any cylinder head which leaks due to a crack shall be replaced. The above post operational air roll test may be discontinued following the first refueling outage subject to the following conditions:

(a) All cylinder heads are Group III heads (i.e., cast after September 1980).

(b) Quality revalidation inspections, as required by El above, have been completed for all cylinder heads.

(c) Group III heads continue to demonstrate leak free performance. This should be confirmed with TDI prior to deleting air roll tests.

F. Turbochargers

1. The turbocharger thrust bearings shall be visually inspected for excessive wear after 40 non-prelubed starts since the previous visual inspection.

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2. Turbocharger rotor axial clearance shall be measured at each refueling outage to verify compliance with TDI/

Elliott specifications. In addition, thrust bearing measurements shall be compared with measurements taken previously to determine a need for further inspection or corrective action.

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3. Spectrographic and ferrographic-engine-oil analysis shall be performed quarterly to provide early evidence of bearing degradation. Particular attention shall be paid to copper level and particulate size which could signify thrust bearing degradation.
4. The nozzle ring components and inlet guide vanes shall be visually inspected for missing parts or parts showing distress on a one-turbocharger-per-refueling-outage basis. -In-addition,-these inspections shall be per-formed for all turbochargers at each turbocharger over-haul (i.e., at approximately 5-year intervals). If any missing parts or distress is noted, the entire ring assembly shall be replaced and the subject turbocharger shall be reinspected a the next refueling outage.

G. EDG 3300 KW Alarm The licensee shall install-a distinctive visual and audible alarm for each diesel generator in the main control room that will be set no higher than 3300 KW for operation.

H. Procedures and Training

' Prior to operation at reactor power levels greater than 5%,

the licensee shall complete, in a manner acceptable to NRC staff, the development of suitable procedures and training to minimize the likelihood of operator errors that could result-in EDG overload.

I. Inspection Results and Restart If any of the engine inspections required by paragraphs B, C and D above identify a degraded component condition, the associated engine shall be declared inoperable until the results of the inspection and further analyses by the licensee of the degraded condition have been reviewed, and further operation of the engine has been approved by the NRC staff.

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