PY-CEI-NRR-0778, Application for Amend to License NPF-58,revising Wording of Tech Spec 4.8.1.1.3 to Allow Reporting to Be on Per Diesel Generator Basis & Table 4.8.1.1.2-1 Clarifying Number of Failures Determined & Reduction of Test Frequency.Fee Pai

Application for Amend to License NPF-58,revising Wording of Tech Spec 4.8.1.1.3 to Allow Reporting to Be on Per Diesel Generator Basis & Table 4.8.1.1.2-1 Clarifying Number of Failures Determined & Reduction of Test Frequency.Fee Paid

ML20196C896
Person / Time
Site:	Perry
Issue date:	02/09/1988
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196C902	List: ML20196C905 PY-CEI-NRR-0778, Application for Amend to License NPF-58,revising Wording of Tech Spec 4.8.1.1.3 to Allow Reporting to Be on Per Diesel Generator Basis & Table 4.8.1.1.2-1 Clarifying Number of Failures Determined & Reduction of Test Frequency.Fee Pai
References
PY-CEI-NRR-0778, PY-CEI-NRR-778, NUDOCS 8802160270
Download: ML20196C896 (5)

Text

O THE CLEVELAND ELECTRIC ILLUMiN ATING COMPANY PO BOX 97 e PEAAY. OHIO 440s1 e TELEPHONE (216) 259 3737 e ADDRESS io CENTER ROAD Serving The Best Location in the Nation PERRY NUCLEAR POWER PLANT Al Kaplan MCE PRESIDENT NuctEAa caoup Feb rua ry 9, 1988 ,

PY-CC1/NRR-0778 L Doc ume nt Control Desk U.S. Nuclear Regulatory Commission Was hing ton , D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Technical Specification Change Request Ge ntle me n :

The Cleveland Electric Illuminating Company (CCI) hereby requests amendment of l Facility Operating License NPF-53 for the Perry Nuclear Power Plant. Uni t 1. I In accordance with the requirements of 10 CFR 170.12 a check in the amount of S150.00 will follow under separate letter. In accordance with the requirements of 10 CFR 50.91(b)(1), a copy of this request for amendment has been sent to the State of Ohio as indicated below. l l

This amendment requests revision of the wording of Technical Specification 4.8.1.1.3 to allow reporting to be on a per diesel generator basis. The a mend me nt also requests revision of notes to Technical Specification Table 4.8.1.1.2-1 to clarify how the number of f ailures is determined and how test frequency can be reduced by performance of overhauls and tests. A copy of the proposed change to the Technical Specification is enclosed.

Should you have any questions, please f eel f ree to call me.

I Very truly yours, llk . * . .n.- 'Y Al Kaplan 8802160270 0 0 40 PDR ADOCK O PDR Vice President p Nuclea r Group AK: cab At tac hme nt / Enclo su re cc: K. Connaughton T. Colburn J. Harris (State of Ohio) g m

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• Att:ch::nt 1 PY-CEI/NRR-0778 L Page 1 of 4 Summary This proposed amendment to the Perry Nuclear Power Plant Technical Specification clarifies the note to Technical Specification Table 4.8.1.1.2-1.

The clarification is to document that appropriate overhauls to a like nev condition can be used to reduce the number of previous test failures, if the overhaul performed vould correct deficiencies which vere directly responsible for past diesel generator test failures. The requirement for having the overhaul, including appropriate post-maintenance operation and testing, approved by the manufacturer and the requirement for a demonstration of reliability by testing remains intact. This change also clarifies a footnote on Table 4.8.1.1.2-1 which increases the flexibility of performing tests, and changes the reporting requirements of Technical Specification 4.8.1.1.3 to a per diesel generator basis from a per auclear unit basis.

Safety Analysis Technical Specification Table 4.8.1.1.2-1, "Diesel Generator Test Schedule", is ,

a table which defines test frequency of the individual Diesel Generators based on the number of valid failures in the last 20 and last 100 valid tests. A note to the table explains the criteria for determining the number of failures and number of valid tests. The note also discusses how the previous test 4 failure count can be reduced. The present wording indicates that the failure count may be reduced to zero if a complete diesel overhaul to like new conditions is completed. The proposed revision vould allow the failure count to be reduced if an appropriate overhaul / redesign is completed. This overhaul / redesign must be approved by the manufacturer. The manufacturers a approval ensures that the overhaul is detailed enough to completely correct the root cause, and permit the diesel to operate in a like-new condition. The failure count vould then be reduced by the number eliminated by the approved overhaul.

J Generic Letter 84-15 discussed proposed NRC Staff Actions to improve and maintain Diesel Generator operability. The Attachment to Enclosure 3 of this Generic Letter discusses what the NRC Staff determined at that time to be an j acceptable diesel generator requalification criteria if the number of failures

, in the last twenty valid tests or in the last one hundred valid tests is excessive. The NRC's requalification program required 14 successful consecutive tests without a failure, but did not require any diesel generator overhaul prior to the requalification testing.

Enclosure 1 to the Generic Letter also discussed the NRC's conclusion that excessive testing results in degradation of diesel engines.

By permitting appropriate overhauls to reduce the number of test failures, and maintaining the requirement for the 14 successful consecutive tests, CEI is meeting or exceeding the NRC staff's position as defined in Generic Letter 84-15. The overall number of diesel generator tests vill be reduced, since the subsystem overhaul vill allow the normal surveillance testing frequency to be

reduced from veekly to monthly. This concept gives CEI the ability to aggressively attack those parts of the diesel generator which are causing diesel generator test failures without causing a complete diesel ovethaul when there is no need for one.

l Attechment 1 PY-CEI/NRR-0778 L Page 2 of 4 I

I The NRC has been very involved in the evaluation of the Transamerica Delaval, Inc. (TDI) Diesel Generator Operability Reliability program. On July 8, 1986 the NRC Staff issued "Safety Evaluation Report Regarding the Operability / Reliability of the Emergency Diesel Generators manufactured by Transamerica Delaval, Inc. - Perry Nuclear Pover Plant (Units 1 and 2)". The NRC Staff concluded that the continued reliability / operability of the TDI diesel engines for the forty year life of the Perry Nuclear Pover Plant vill be assured by implementation of.the maintenance / surveillance programs discussed in i the SER. This included a requirement to perform a complete diesel overhaul j every ten years. The NRC Staff concurred that there was a reasonable basis to conduct the major engine overhauls at 10 year intervals based on 1) the -

comprehensive design reviev/ quality revalidation effort conducted for each of  ;

the engine components, 2) the limited number of operating hours for engines in nuclear standby service, and 3) the fact that a sample inspection of major engine components vill be performed on a one time basis following five years i service.

To perform an unnecessary complete overhaul of the diesel generator, prior to i the ten year period vould not increase the reliability of the diesel generator.  !

Therefore, CEI concludes that permitting subsystem overhauls and subsequent requalification testing to reduce the number of valid test failures vill enhance safety since it vill

1) Reduce the number of diesel generator tests.

, 2) Permit aggressive, yet meaningful corrections to diesel generator problems.

3) Prevent unnecessary complete diesel generator overhauls.

Changing the footnote from the first column to the last column permits the

., footnote to apply to both failure columns. This clarified footnote applies the veekly test frequency when reliability does not meet 95% and re-establishes the acceptance of diesel performance without requiring excessive testing. This change has been previously approved for numerous other opeca.ing nuclear power facilities.

The proposed changes to Technical Specification 4.8.1.1.3 changes the reporting requirement from a per nuclear unit basis, to a per diesel generator basis.

Test failures are already determined on a per diesel generator basis as discussed in the footnote to Table 4.8.1.1.2-1. The purpose of this is to

. avoid excessive testing of all diesel generators due to failures experienced on I one diesel generator. The reporting requirement is being changed to a per diesel generator basis to be consistent with the testing criteria, and to avoid the need for a dual counting system, one for determining test frequency and one for determining reports. The testing frequency determination assures that a reliability of 95% is maintained.

i Significant Hazards Analysis 4

The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's j Regulations, 10 CFR 50.92, which state that the operation of the facility in accordance with the proposed amendment would not (1) involve a significant i

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. Attcch=nt 1 PY-CEI/NRR-0778 L Page 3 of 4 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. CEI has revieved the proposed change with respect to these three factors.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

This proposed change does not change any of the =quirements to demonstrate the reliability of the diesel generator following an appropriate overhaul. The purpose of the proposed change is to clarify the present wording to provide the flexibility, with the manufacturer's approval, to overhaul those parts of the diesel generator which have been causing test failures, without unnecessary overhauls of other parts of the diesel which have been demonstrated to be reliable. Since the reliability must be demonstrated after the overhaul the proposed change does not involve any increase in the probability or consequences of an accident previously evaluated. The footnote change to Table 4.8.1.1.2-1 and the change to 4.8.1.1.3 are clarifications and as such do not change the reliability of the diesel generator. Therefore the changes do not increase the probability or consequences of a previously evaluated accident.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

This proposed change is a clarification of what an adeauate overhaul of the diesel generator encompasses, for the purpose of reducing the amount of testing performed on the diesel generator. The proposed change still requires that any portion of the dies 91 generator that has caused test failures be overhauled to like new conditions, approved by the manufacturer, and tested to ensure reliability prior to reducing the number of valid test failures. The change vould eliminate the need for doing unnecessary maintenance on the diesel generator. The Table 4.8.1.1.2-1 footnote change and the change to 4.8.1.1.3 are clarifications which can not create the possibility of a new or different kind of accident. As such no new or different kind of accident can be introduced by this change.

The proposed change does not involve a significant reduction in the margin of safety.

As discussed in the safety analysis section above, the proposed change contains additional requirements above vhat the NRC staff found acceptable in Generic Letter 84-15. These additional requirements (an overhaul approved by the manufacturer) do not involve a reduction in the margin of safety. The ability to correct knovn diesel generator problems without the time consuming and unnecessary requirement to perform a complete diesel generator overhaul should be an increase in the margi' of safety. This in combination with the ability to reduce the number of diesel generator starts by reverting back to monthly testing intervals should also enhance the safety margin.

Attachaont PY-CEI/NRR-0778 L Page 4 of 4 The Table 4.8.1.1.2-1 footnote change and the change to 4.8.1.1.3 are clarifications and as such does not involve a reduction in the margin of safety. Therefore the proposed changes do not involve a significant reduction in the margin of safety.

Environmental Impact The Cleveland Electric Illuminating Company has reviewed the proposed Technical Specification change against the criteria of 10 CFR 51.22 for the environmental '

considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of j effluents that may be released offsite, nor significantly increase individual

or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification change meets the criteria '

given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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