PY-CEI-NRR-1927, Application for Amend to License NPF-58 Re Removal of License Conditions for Tdi EDGs Specified by Paragraph 2.c & Defined in Attachment 2 to Operating License

Application for Amend to License NPF-58 Re Removal of License Conditions for Tdi EDGs Specified by Paragraph 2.c & Defined in Attachment 2 to Operating License

ML20087H937
Person / Time
Site:	Perry
Issue date:	04/28/1995
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20087H940	List: ML20087H941 PY-CEI-NRR-1927, Application for Amend to License NPF-58 Re Removal of License Conditions for Tdi EDGs Specified by Paragraph 2.c & Defined in Attachment 2 to Operating License
References
PY-CEI-NRR-1927, NUDOCS 9505050133
Download: ML20087H937 (5)

Text

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GNTER00Ct ENERGY PERRY NUCLEAR POWER PLANT Mail Address: D0nald C. ShettOn P.O. BOX 97 O CENTER ROAD PERRY, OHIO 44081 SENIOR VICE PRESIDENT PERRY, OHIO 44081 NUCLEAR (21e) 259-3737 April 28, 1995 PY-CEI/NRR-1927L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request:

Operating License NPF-58, License Condition 2.C.(9) and Attachment 2 Gentlemen Enclosed is an application for amendment of the Facility Operating License (NPF-58) for the Perry Nuclear Power Plant. This Licenss Amendment application proposes the removal of license conditions for the Transamerica Delaval, Inc. (TDI) Emergency Diesel Generators (EDG) specified by paragraph 2,C.(9) and defined in Attachment 2 to the Operating License. This request is based on the recommendations and NRC conclusions in Topical Report TDI-EDG-001-A, " Basis for Modification to Inspection Requirements for Transamerica Delaval, Inc., Emergency Diesel Generators".

A Summary, Description of Proposed Changes, Safety Analysis, and an Environmental Consideration are provided in Attachment 1. Attachment 2 ,

provides a copy of the marked up Operating License pages. Attachment 3 l provides the Significant Hazards Consideration. Issuance of the Amendment is requested by October 1, 1995, to support planning efforts for RF05.

If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 280-5833.

Very truly yours,

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<v- Doriald C. Shelton TAHisc Enclosure Attachments cc: NRC Project Manager NRC Region III NRC Resident Inspector Office State of Ohio operoi.no compon.es i

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I, Robert V. Schrauder, being duly sworn state that (1) I am Director, Perry ,

Nuclear Services Department of the Cleveland Electric Illuminating Company,  !

(2) I am duly authorized to' execute and file this certification on behalf of'  !

The Cleveland Electric Illuminating Company and Toledo Edison Company, and as the duly authorized agent for Duquesne Light Company, Ohio Edison  !

Company, and Pennsylvania Power Company, and (3) the statements set forth  !

herein are true and correct to the best of my knowledge, information and  !

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RoTert W. Schrauder  !

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Attachment 1 PY-CEI/NRR-1927L Page 1 of 3

SUMMARY

Currently, the Perry Nuclear Power Plant (PNPP) Operating License (NPF-58) contains conditions regarding special Emergency Diesel Generator (EDG) inspection requirements as specified by item 2.C.(9),

"TDI Diesel Generator Reliability (Section 9.6.3, SSER #6, 8 & 10)",

and Attachment 2, "Transamerica Delaval, Inc. (TDI) Diesel Engine Requirements". These requirements are stipulated as part of the Design Review / Quality Revalidation (DR/0R) program for Transamerica Delaval, Inc. (TDI) EDGs, as endorsed by NUREG-1216, " Safety Evaluation Report Related to the Operability of Emergency Diesel Generators Manufactured by Transauerica Delaval, Inc." A change is proposed to delete these conditions from the operating license, such that the total program for maintaining EDG reliability vill be controlled by the licensee under the provisions of 10 CFR 50.59.

DESCRIPTION OF PROPOSED CHANGES This requested change vill delete both item 2.C.(9) and Attachment 2 of the Operating License in their entirety. The basis for this proposed change is the TDI Owners Group submittal, " Generic Topical P,eport TDI-EDG-001-A, Basis for Modification to Inspection Requirenents for Transamerich Delaval, Inc., Emergency Diesel Generators" (Tupical Report) and the generic NRC safety evaluation report " Safety Evaluation, Inspection Requirements for Transamerica Delaval Inc.

Diesel Generators" dated March 17, 1994 (published as NUREG-1416, Operational Experience and Maintenance Programs Of Transamerica Delaval, Inc. Diesel Generators, in May 1994). These documents conclude tnat there is adequate justification for removing the license requirements associated with NUREG-1216 from utilities' licenses.

These documents, along with their assumptions and analyses, have been reviewed and found to be applicable to the PNPP TDI diesel generators.

The DR/0R program has provided substantial operational data and inspection results to demonstrate the suitability of the TDI engines for nuclear service. Therefore it is appropriate that TDI EDGs be treated in the same manner as other EDGs within the nuclear industry without the special requirements in operating licenses. Removal of the prescriptive teardown and inspection requirements from licenses vill allow flexibility in determining the best way to monitor engine conditions while maintaining reliability and reducing EDG unavailability.

Current Technical Specification surveillance requirements vill continue to demonstrate satisfactory performance in accordance with NRC requirements. The PNPP program to monitor and maintain the TDI diesel engines vill be developed using the principles of the TDI Owners' Group endorsed Cooper-Enterprise Preventive Maiatenance Plan (PMP), and shall be subject to the provisions of 10 CFR 50.59. This vill provide the foundation for transition to the performance-based requirements of the Maintenance Rule.

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Attachment 1 PY-CEI/NRR-1927L Page 2 of 3 SAFETY ANALYSIS The TDI Ovners Group, of which PNPP is a member, was formed in late 1983 following the crankshaft failure of a TDI EDG at the Shoreham Nuclear Plant. The Ovners Group developed the detailed program to provide for generic design review and quality revalidation of TDI EDGs for nuclear service. This DR/0R program was reviewed by the NRC and endorsed in NUREG-1216. Portions of the DR/0R vere incorporated into the PNPP Operating License as item 2.C.(9) and Attachment 2.

The DR/0R program imposed intrusive inspection requirements on the TDI owner utilities based on the limited operating history of the engines.

The intent was to ensure reliable operation by routine inspection of critical compcaents and allow for development of an equipment history file. The recent Topical Report described above documented substantial operational history without significant failure. The additional inspectians required by the license condiuons have not revealed any significant problems from operation of the engines. NRC sponsored research (NUREG/CR-5057, " Aging Hitigation and Improved Programs for Nuclear Service Diesel Generators, Pacific Northwest Laboratory, December 1989) also indicates that during shakedown periods subsequent to teardown, engine unreliability may increase due to the possibility of intrusive inspections introducing foreign raterial and " fit year-in" or break-in periods for new components.

The TDI engines at PNPP have been inspected in accordance with the DR/0R requirements, including one 5-year inspection on each engine.

These inspections have noted no appreciable component degradation. For the three year period ending with fourth quarter 1994, PNPP TDI EDGs have experienced no failures and during the same period attained an unavailability ratio better than the INP0 industry goal. However, the teardowns specified by the DR/0R require a significant nmount of time to perform, often as an outage critical path activity, during which time the EDG is unavailable to supply emergency power. This can result in outage scheduling concerns and an adverse impact on shutdown risk.

The primary purpose of the EDGs is to provide a reliable source of AC power to the emergency buses upon a loss of offsite power. It has been shown that the maintenance activities can affect the reliability and availability of EDGs. The requirement to perform a complete overhaul every ten years adds to the unavailability and alsc, could contribute to increased unreliability. As indicated in the Generic SER, the NRC  ;

concurs with the Owners' Group that by combining predictive  :

maintenance, surveillance, and inspections as in the Owners' Group  ;

preventive maintenance plan, considerable flexibility in the frequency of performing engine teardowns can be achieved without secrificing engine reliabilit7 Increasing the availability and reliability of EDGs vould have no adverse effect on safety. )

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PY-CEI/NRR-1927L Page 3 of 3 Based on the inspection results and operational performance of the PNPP engines, it is appropriate that PNPP have the ability to address its maintenance program as necessary to incorporate enhancements that will maintain reliability and improve availability while minimizing associated shutdown risk, including major overhaul frequency.

ENVIR6NMENTAL CONSIDERATION This proposed Operating License amendment has been reviewed against the criteria of 10 CFR 51.22 for environmental considerations. As shown above and in Attachment 3, the proposed change does not involve a significant hazards connideration, does not increase the t;' pes and amounts of effluents that may be released offsite, and does not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, it has been concluded that the proposed Operating License amendment 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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