View source for B12414, Application for Amend to License NPF-49,extending 18-month Surveillance Testing Requirements for Diesel Generator Up to 4 Months Beyond Max Allowed by Tech Spec Section 4.0.2,on one-time Basis

{{Adams
| number = ML20209H874
| issue date = 01/30/1987
| title = Application for Amend to License NPF-49,extending 18-month Surveillance Testing Requirements for Diesel Generator Up to 4 Months Beyond Max Allowed by Tech Spec Section 4.0.2,on one-time Basis
| author name = Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000423
| license number = 
| contact person = 
| document report number = B12414, TAC-66377, NUDOCS 8702060159
| package number = ML20209H880
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 4
| project = TAC:66377
| stage = Request
}}

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J *,*o.',Z',  "C ', "O.'co*.-                                      (203) 66 5 5000 January 30,1987 Docket No. 50-423 B12414 Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attn:      Document Control Desk Washington, D.C. 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Diesel Generator 18-Month Surveillance Requirements Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License, NPF-49 by incorporating the attached proposed change into the technical specifications of Millstone Unit No. 3.
Specifically, the proposed change to Technical Specification Section 4.3.'.l.2f (part 1) and an addition of Section 4.0.6 will extend on a one-time basis the 13 month surveillance testing requirements up to 4 months beyond the maximum allowed by Technical Specification Section 4.0.2. This would allow the plant to complete the present fuel cycle and shut down on or before January,1983. This extension is for the Diesel Generator which must be tested during an extended outage.        For the above surveillance requirement which is affected by the extension, it is our intention to use the test dates during the first refueling outage as initiation dates to determine the intervals defined by Technical Specification Section 4.0.2 for subsequent surveillances.
The Technical Specification Provision 4.0.2 defines the intervals for surveillance requirements testing as follows:
                  "a.      A maximum allowable extension not to exceed 25% of the surveillance interval, but
: b.      The combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval."
Within many of the surveillance requirements for systems and components for Millstone Unit No. 3, a frequency of 13 months is specified.                         Many of the surveillances clearly state, "18 months at shutdown," which we believe was intended to indicate that the tests were to be done during the refueling outage.
The subject surveillance test is currently due in May,1987, but the refueling outage is not scheduled to begin until about January,1988. An extension to                                        uq 3anuary,1988 exceeds the stated allowable extension of 25% of the surveillance So 'g
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interval and the potential exists that the combined time interval for the next three consecutive surveillance intervals may exceed the 3.25 times specified surveillance interval. To avoid the possibility of not meeting the operability requirements for a Limiting Condition for Operation, a one-time extension of the eighteen (18) month diesel generator inspection will be necessary. This extension would allow performance of the subject surveillance in a rational, orderly manner during the refueling outage.
The diesel generator manufacturer maintenance instructions list this inspection as an annual / refuel inspection indicating it should be performed during the refueling outage. It can also be inferred from the technical specifications that this be performed during a refueling outage from its reference to "18 months at shutdown."
In addition, the diesel generators, which are only used for standby service, log very few hours of operation on a yearly basis. Therefore, engine wear is minimal and the extension should have no impact. The diesel generator manufacturer concurred with this conclusion. This proposed change does not change any of the other inspections required per Technical Specification 4.8.1.1.2.f.
Safety Evaluation NNECO has reviewed the attached proposed change pursuant to 10CFR50.59 and determined that it does not represent an unreviewed safety question.
Effect on Design Basis Accident Analysis The proposed change has no effect on the design basis accidents since it only proposes to extend the diesel inspection interval.            The diesel generator manufacturer has reviewed the proposed change and has no objection to extending the 18 month surveillance inspection by eight months (i.e., from May 1987 to January 1988).        In addition, the diesel generators are currently performing well (i.e., 31 failure in last 100 valid tests). Therefore, an increase in the inspection schedule will not change diesel generator performance, and will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
Potential for Creation of an Unanalyzed Accident There are no failure modes associated with this proposed change. Since the proposed change addresses an inspection interval change, it will not create the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
Effect on the Margin of Safety The basis of the technical specifications for Section 4.3.1.1.2f (part 1) is the manufacturer's recommendation on diesel inspection. Since the manufacturer has no objection to the proposed change, there is no impact on the basis of the technical Specification. Therefore, this change does not reduce the margin of safety as specified in the basis of any technical specification.

Summary and Conclusions Based on the foregoing assessment, the changed proposed herein is considered safe and does not represent an unreviewed safety question as defined in 10CFR50.59 since it does not:
: 1. Increase the frequency of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report;
: 2. Create the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report;
: 3. Reduce the margin of safety as defined in the basis for any technical specification.
In accordance with 10CFR50.92, NNECO has reviewed the attached proposed change and has concluded that it does not involve a significant hazard consideration. The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. Moreover, the Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (March 6, 1986, 51 FR_ 7751) of amendments that are considered not likely to involve significant hazard considerations. Although the proposed change herein is not enveloped by a specific example, the proposed change would not involve a significant increase in the probability or consequences of an accident previously analyzed. The proposed change will extend on a one-time basis the IS month surveillance testing requirements up to 4 months beyond the maximum allowed by Technical Specifications Section 4.0.2.
Currently, the diesels are tested once per 31 days on a staggered basis as required by Technical Specifications Table 4.8-1. The surveillance requirements are to determine operability. The operability has been demonstrated more frequently than the IS-month requirement; therefore, the confidence for operability is quite high for the proposed extension. For the diesel generator system, there is no change to equipment, setpoints, or operation for which operability has been sufficiently demonstrated less frequently than 13 months, and therefore, the proposed change would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved the attached proposed revision and concurs with the above determinations.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of the proposed amendment.
Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.00.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY f . 7o .
y
                                                        ~
E. J.       ka Senior V e President

_4 cc:   Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 Dr. Thomas E. Murley Regional Administrator Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
: 3. T. Shediowski, Sr. Resident Inspector, Millstone Unit No. 3 STATE OF CONNECTICUT )
                                    ) ss. Berlin COUNTY OF HARTFORD            )
Then personally appeared before me E. 3. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
ALui Notary Public(/
b My Commission Expires March 31,1988
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