ML20197F771

Application for Amend to License NPF-58,revising TS 3.8.1, AC Sources - Operating, to Be Consistent W/Recommendations in GL 94-01, Removal of Accelerated Testing & Special Reporting Requirements for Edgs

ML20197F771
Person / Time
Site:	Perry
Issue date:	12/23/1997
From:	Myers L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20197F776	List: ML20197F787 PY-CEI-NRR-2245, Application for Amend to License NPF-58,revising TS 3.8.1, AC Sources - Operating, to Be Consistent W/Recommendations in GL 94-01, Removal of Accelerated Testing & Special Reporting Requirements for Edgs
References
GL-94-01, GL-94-1, PY-CEI-NRR-2245, NUDOCS 9712300292
Download: ML20197F771 (9)

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MryNucbar Pows: Plant '

.9= nP 10 Center Road ynfr PO Bot 97

, Wry Ohio 44061 i LowO & 4402MS915 Fax:440 2808029 :

. Mce Presdent .

December 23,1997

' PY-CEl/NRR 2245L ,

United States Nuclear Regulatory Commission Document Control Desk

' Washington, DC 20555 Perry Nuclear Power Plant, Unit i Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90: Proposed Revision to Technical Specification 3.8.1,"A.C. Sources - Operating" Ladies and Gentlemen:

Nuclear Cgulatory Commission (NRC) review and approval of a license amendment for the Perry Nuclear Power Plant (PNPP) is requested.- The proposed amendment would revise Technical Specincation 3.8.1,"A.C. Sources - Operating" consistent with the recommendations in NRC Generic Letter (GL) 94 _01," Removal of Accelerated Testing and Special 1 eporting Requirements for Emergency Diesel Generators". As noted in the titic of the NRC letter, one of -

the p.aposed Technical Specification changes is deletion of the special diesel generator reporting requirements. However, at PNPP, the special diesel generator reporting requirements were relocated from the Technical Specification to the PNPP Operational Requirements Manual as part of the TeclWcal Specifications improvement effort, Amendment 69. These requirements will be removed from the PNPP Operational Requirements Manual upoa approval cf this f amendment request, using the provisions of 10 CFR 50 59.

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Attachment i piovides the Surnmary, Description of the Proposed Technical Specification .

Change, Safety Analysis, and Environmental Consideration. Attachment 2 provides the Significant llazards Consideration. Attachment 3 provides the annotated Technical Specification

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pages reflecting the proposed changes as suggested in GL 94-01. Attachment 4 provides the proposed Technical Specification bases changes for information only. Attachment 5 includes the proposed Operational Requirements Manual changes for informational only. Attachments 4

= and 5 are maintained under licensee - controlled administrative processes.

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if you have questions or require additional informat:on, please contact Mr. Ilenry L 11cgrat,3

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2 Manager - Regulatory Affairs, at (440) 283-5606.'

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• i for Lew W. Myers.

Attachments cc: NRC Project Manager NRC Resident Ir.spector .

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PY-CEl/NRR-2245L I Page1of4 j

SUMMARY

This license amendment request proposes changes to Technical Speci0 cation surveillances to remove the requirements related to accelerated testing of the standby emergency diesel generators (DGs), consistent with the recommendations in Nuclear Regulatory Commission (NRC) Generic Letter (GL) 94-01," Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators". The term " accelerated testing" is used to describe the circumstance in which more frequent testing of a diesel generator (DG) is required when four or more failures of the DG have been experienced in the last 25 valid tests.

Technical Speci0 cation Surveillance Requirement (SR) 3.8.1.2 currently requires verification that each DG starts from standby conditions and achieves voltage 23900 V and s4400 V and frequency 258.8 llz and s61.2 ilz in accordance with the frequency given in Table 3.8.1-1,

" Diesel Generator Test Schedule".

Technical Speci0 cation SR 3.8.1.3 currently requires verification that each DG operates for 260 minutes at a load 25600 kW and s7000 kw for Division I and 2 DGs, and 22600 kW for Division 3 DG in accordance with the frequency given in Table 3.8.1-1," Diesel Generator Test Schedule".

The frequency specined in Table 3.8.1-1 is normally 31 days. Ilowever, should a DG experience four or more failures in the last 25 valid tests, the test frequency increases to 7 days (but not more frequently than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

In GL 94-01, the NRC proposed that the requirements for accelerated testing can be de'eted following implementation of a maintenance program meeting the requirements of 10 CFR 50.65,

" Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" and the guidance provided in Regulatory Guide 1.160, Revision 1," Monitoring the Effectiveness of Maintenance at Nuclear Power P' ants"(as applicable to the DGs). PNPP has implemented such a maintenance rule program. GL 94-01 also allowed the removal of the require nent for special reporting of DG failures. At PNPP, that requirement has previously been relocated out of the Technical Specifications into the PNPP Operational Requirements Manual in accordance with the provisions of 10 CFR 50.59.

DESCRIP110XOF Tile PROPOSED TECIINICAL SPECIFICATION CIIANGE The following changes to the Technical Speci0 cations are proposed under this amendment request:

• Surveillance Requirements 3.8.1.2 and 3.8.1.3 are being revised to delete the references to Table 3.8.1-1 for the frequency of the surveillance. The frequency for these surveillances will be 31 days.

• Technical Specification Table 3.8.1-1 is being deleted.

Attachment I PY-CEt/NRR-2245L Page 2 of 4 At:achment 3 contains an annotated copy of the affected Technical Speci6 cation pages. The changes to the Technical SpeciGcations are consistent with the guidance provided as Enclosure 2 to Generic Letter 94-01. In addition, the bases for SRs 3.8.1.2 and 3.8.1.3 will be revised to remove references to Table 3.8.1 1 and to remove references to the frequency of 31 days as being " normal", as it will be the only frequency for conducting these surveillances.

[ Note: The Technical Speci6 cation Bases will be revised under the PNPP Bases Control Program to reDect the changes described above. Attachment 4 contains the proposed Bases changes and is provided "for information only". In addition, Attachment 5 is also provided "for information only" and provides the proposed changs to the Operational Requirements Manual (ORM). The proposed changes to the ORM reflect the removal of the requirement ter accelerated testing, the removal of references to Technical Speci0 cation Table 3.8.1-1 (which is being proposed for deletion), and the removal of the requirement for dicsel ge terator special reporting.]

SAFETY ANALYSIS The standby A.C. power sources at Perry consist of three diesel generators: one for Division 1, one for Division 2, and one liigh Pressure Core Spray (llPCS) diesel generator for Division 3.

The diesel generator system is designed so that with a loss of offsite power and a loss of any one of the diesel generators, the remaining diesel generators are capable of supplying power to equipment for safe shutdown of the plant under normal or accident conditions.

The Division I and 2 DGs are used to supply power to their respective safety buses when offsite power is unavailable. They are automatically started upon a loss of voltage on their associated 4.16 kV buses, or by a LOCA signal, if otTsite power is available to the buses during LOCA initiation, the Division I and 2 DGs start, but are not automatically connected to the buses, and are IcIl nmning on standby. If offsite power is not available, the required loads are automatically sequenced onto the diesel generators.

The Division 3 DG is the llPCS DG, which is used to supply power to the llPCS safety bus when offsite power is not available. It starts automatically on a signal from the plant protection system (low water level or high drywell pressure - LOCA initiation signals) or upon detection of IIPCS supply bus undervoltage or degraded voltage condition. When the preferred power supply is unavailable, the llPCS DG is automatically connected to the bus.

The NRC issued Generic Letter 94-01 to advise licenses that they may request a license amendment to remove accelerated testing and special reporting requirements for DGs frcm the plant Technical Specifications. The generic letter requests that, when submitting the license amendment, licenses commit to implement within 90 days of the issuance of the license amendment a maintenance program for monitoring and maintaining DG performance consistent with the provisions of 10 CFR 50.65," Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" and the guidance of Regulatory Guide 1.160," Monitoring the Effectiveness of Maintenance at Nuclear Power Plants", as it relates to DGs.

Attachment !

PY-CEl/NRR-2245L Page 3 of 4 Generic Letter 94-01 states that a maintenance program for monitoring and maintaining DG performance in accordance with the provisions of the maintenance rule and " consistent with" the guidance of Regulatory Guide 1.160 would provide a basis for the NRC staff to approve a license amendment request to remove the accelerated testing and special reporting requirements for the DGs from plant Technical Specifications. The Perry Nuclear Power Plant is in compliance with the provisions of 10 CFR 50.65 and has implemented a maintenance program consistent with the guidance of Regulatory Guide 1.!60, as defined in Enclosure 1 of Generic Letter 94-01, On Page 2 of Enclosure 1, the NRC Staff notes that a commitment to implement the maintenance rule consistent witt. the guidance of Regulatory Guide 1.160 as applicable for DGs is a commitment to (1) implement the endorsed NUMARC guideline,93-01, with the exception of the reference to NUMARC 87-00 on the use of trigger values and (2) fulfil; the NRC staff expectations discussed in Regulatory Guide 1.160.

The 31-day frrquency for DG testing is consistent with industry guidance for the assessment of diesel generator performances and k not affected by this activity. The goal of Technical Specification Surveillances 3.8.1.2 and 3.8.1.3 and the Maintenance Rule are to assure that the DGs are capable of performing their intended function when called upon. The Maintenance Rule concept is to provide a program that includes monitoring the reliability and corrective actions completed to ensure that an established reliability goal for the DGs is met. Accelerated testing was also intended to achieve the goal of ensuring DO reliability but in a different way.

Specifically accelerated testing provided a means to collect timely test data to establish a numerical confidence level associated with DG reliability. Although tbc means of achieving the goal differs between the Maintenance Rule progrr.m and acselerated testing, the goal of ensuring DG reliability is the same.

Because the goal of accelerated testing and the maintenance rule is the same (to ensure diesel generator reliability) and because the NRC has acknowledged that the Maintenance Rule program for the diesel generators provides an acceptable method of ensuring diesel reliability and has concluded that accelerated testing need not be included in the Maintenance Rule program for the DGs, the requirement to perform accelerated testing can be removed from the Technical Specifications.

The NRC has also acknowledged, in Generic Letter 94-01, that licensees would continue to comply with the provisions of 10 CFR 50.72 and 10 CFR 50.73 for reporting and that special reporting ofindividual diesel failures (in addition to the requirements of 10 CFR 50.72 and 10 CFR 73) is not necessary.

ENVIRONMENTAL CONSIDERATIONS The proposed Technical Specification change request was evaluated against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not significantly increase individual or cumulative occupational radia: ion exposures, does not significantly change the types or significantly increase the amounts of effluents that may be released off-site and, as discussed in Attachment 2, does not invol ve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed Technical Specification change meet. the criteria given in 10 CFR S t.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

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Attachm,nt 1 I PY-CEl/NRR-22 :

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CO$1MITMENTS WITIIIN TIIIS LETTER There are no regulatory commitments contained in this document. Any actions discussed in this document represent intended or planned actions, are deacribed for the NRL's information, and are not regulatory commitments. Please notify the Manager - Regulatory Affairs at the Perry Nuclear Power Plant of any quesilons regarding this document or any associated regulatory commitments.

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Attachment 2 PY-CEl/NRR-224fL Pageiof2 SIGNIFICANT IIAZARDS CONSIDi' RATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations,10 CFR 50.92, which state that the operation of the facility !a accordance with the proposed amendment would not (1) involve a signincant increase in the probability or consequences of an accident previously evaluated,(2) create the porsibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.

The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed change does not involve a signiGeant hazard because:

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

The proposed changes do not signi0cantly increase the probability of occurrence of a previously evaluated accident because the standby diesel generators (includmg the liigh Pressure Core Spray (IIFTS) diesel generator) are not initiators of previously evaluated accidents. The standby diesel generators mitigate the consequences of previously evaluated accidents involving a loss of offsite power. The Perry Nuclear Power Plant (PNPP) program developed to meet the Maintenance Rule (10 CFR 50.65) will continue to ensure the diesel generators perform their ftmetion when called upon. The change to the surveillance frequency does not affect the design of the diesel generators, the operational characteristics of the diesel generators, the interfaces between the diesel generators and other plant systems, the function, or the reliability of the diesel generators. Thus, the diesel generators will be capable of performing ,cir accident mitigation function, there is no impact to the radiological consequences of any accident analysis, and the probability and consequences of previously evaluated accidents are not increased by this activity.

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

The proposed activity involves a change to the frequency for speci6c Technical SpeciGcation surveillance requirements. No physical or operational changes to the diesel generators or supporting systems are made by this activity. Since the proposeo changes do not involve a change to the plant design or operation and thus no new system interactions are created by this change, these changes do not produce any parameters or conditions that could contribute to the initiation of accidents ditTerent from those already evaluated in the USAR.

The proposed changes only address the methods used to ensure diesel generator reliability.

Thus, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

- The proposed changes involve the methods used to ensure diesel generear performance and .

reliability. No changes, other than to frequency, are made to Technical Specification Surveillance Requirements 3.8.1.2 and 3.8.1.3. The NRC, in Generic Letter 94-01, has acknowledged the acceptability of the use of the Maintenance Rule program for the DGs to ensure diesel generator performance in lieu of accelerated testing. These proposed changes do not involve a change to the plant design or operation, and thus do not affect the design of-the diesel generators, the operational characteristics of the diesel generators, the interfaces -

between the diesel generators and other plant systems, or the function or reliability of the diesel generators. Because the diesel generator performance and reliability will continue to

. be ensured by the DG program to meet the Maintenance Rule, the proposed changes do not ,

result in a significant reduction in the margin of safety.

On the basis of the above, it has been determined that the license amendment request does not involve a significant hazards consideration. As this license amendment request concerns a proposed change to the Technical Specifications that must be reviewed by the Nuclear Pagulatory Commission, this license amendment request does not constitute an unreviewed safety question.

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Attachment 3 PY-CEl/NRR 2245L -

Page 1 of 4 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS-

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