ML20069P440

Proposed Amend to OL (PCOL-94/02),removing License Conditions for EDGs Associated w/NUREG-1216

ML20069P440
Person / Time
Site:	Grand Gulf
Issue date:	06/17/1994
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1216 GNRO-94-00090, GNRO-94-90, NUDOCS 9406240201
Download: ML20069P440 (14)

Text

_ - - - - --- - - - _ - - - - - --_ - -

g

-f Entergy Operations,Inc.

_ ENTERGY r o in 7z P.1 GM + t M3 39150 TJ fin 143? 2800 C. R. Hutchinson

1. u n, we a, n a (tl,f'td I kM I'L k?h t)I fa'.llt 49 June 17, 1994 U. S. Nuclear Regulatory Commission Mail Station PI-37 Washington. D.C. 20555 Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Operating License Amendments Emergency Diesel Generator Maintenance and Surveillance Proposed Amendment to the Operating License (PCOL-94/02)

GNRO-94/00090 Gentlemen:

This letter contains proposed amendments to the Grand Gulf Nuclear Station (GGNS)

Operating License. These proposed changes would remove license conditions for Emergency Diesel Generators (EDGs) associated with NUREG-1216. These license requirements came about as a result of concerns with the reliability oflarge bore, medium speed, standby diesel generators manufactured by Transamerica Delaval, Inc. (TDI). NUREG-1216 called for extensive periodic engine teardowns as the major part of a maintenance and surveillance program for the TDI engines. The inspections that have been performed to date have not shown any unusual wear patterns that would have caused engine failure. The health of the majority of the components inspected during these teardowns could be determined by other methods such as monitoring and or trending of operational parameters.

The TDI Owners Group Topical Report, (Reference 1), contains the submittals to remove the NUREG-1216 requirements. On March 17,1994, the N'RC issued a generic safety evaluation report (SER), (Reference 2), granting approval to remove the license requirements associated with NUREG-1216 from utilities licenses. On the bases ofNRC generic approval in the SER dated March 17,1994, Entergy Operations requests removal of the NUREG-1216 requirements from the GGNS Operating License.

- ., I c ,,

(, -d b .OL G9405101 940624o201 940617 PDR l P ADOCK 050oo416 .{

PDR {

Y June 17, 1994  !

GNRO-94/00090 Page 2 of 4 Entergy Operations agrees that the owners group submittals as well as the generic SER are representative of the design and operation of the TDI engines at GGNS. Entergy Operations is in agreement with all points of.NRC's SER with the clarification noted in Attachment 2.

Attachment 2 provides a description of the proposed changes, associated justification, and the No Significant Hazards considerations basis. Attachment 3 is a copy of the marked-up pages.

In accordance with the provisions of 10CFR50.4, the signed original of the requested amendment is enclosed. This amendment request has been reviewed and accepted by the Plant ,

Safety Review Committee ad the Safety Review Committee. {

It is requested that approval olthis PCOL be granted by September 1,1994 in order to finalize plans for RF07 scheduled for spilng 1995. This submittal cupercedes all previous commitments.

If you have any questions concerning this PCOL, please contact James Owens at (601) 437- l 6483. t l

Yours truly, d/ V' yL -

N CRH/JEO/mte '

attachments: 1. Aflirmation per 10CFR50.30

2. GGNS PCOL-94/02 '

3. Mark-up of Affected Pages cc: (See Next Page) j

]

l

\

G9405101

s

.5une17,1994 GNRO-94/00090 Page 3 of4 cc: Mr. R.11. Bernhard (w/a)

Mr. II. W. Keiser (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. II. L. Thomas (w/o)

Mr. Stewart D. Ebneter (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/2)

Omce of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13113 Washington, D.C. 20555 i Dr. Eddie F. Thompson (w/a)

State IIealth Omcer State Board of ficalth P.O. Box 1700 ,

Jackson, Mississippi 39205 ,

i i

i G9405101 l

t fune 17, 1994 GNRO-94/00090 Page 4 of 4 bec: Mr. D. G. Bost (w/a)

Mr. C. A. Bottemiller (w/o)

Mr. L. F. Dale (w/a)

Mr. L. F. Daughtery (w/o)

Mr. J. G. Dewcase (w/a)

Mr. M. A. Dietrich (w/a)

Mr. B. S. Ford (w/a)

Mr. J. O. Fowler (w/a)

Mr. C. C. Hayes, Jr. (w/a)

Mr. C. V. Hicks (w/a)

Mr. L. W. Laughlin (W3) (w/a)

Mr. W. E. Long (w/a)

Ms. S. B. Mahoney (w/a)

Ms. D. R. McCorkle (w/o)

Mr. M. J. Meisner (w/o)

Mr. D. C. Mims (ANO) (w/a)

Mr. D. L. Pace (w/a)

Mr. R. L. Patterson (w/o)

Mr. W. R. Patterson (w/a) ,

Mr. S. A. Saunders (w/a)

File (LCTS)(w/a)

File (Hard Copy)(w/a)

File (RPTS)(w/a)

File (NS&RA)(w/a)

File (Central)(w/a)(16)

Mr. B. M. Burmeister (w/a)

Gulf States Utilities Company (River Bend Station)

P.O. Box 220 St. Francisville, LA 70775 Mr. B. S. Ferrell (w/a) ,

Mail Stop E210 Cleveland Electric illuminating Company (Perry Power Station)  :

P.O. Box 97 l Perry, Ohio 44081 Mr. D. A. Shelton (w/a)

Mail Stop V-920 lilinois Power Company (Clinton Power Station)

P.O. Box 678 Clinton,IL 61727 G9405101 l

Attachment I to GNRO-94/00090 .

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 i

IN THE MATTER OF  :

MISSISSIPPI POWER & LIGHT COMPANY l and SYSTEM ENERGY RESOURCES, INC. .

and ,

SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.

AFFIRMATION I, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of ,

Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of ,

the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice -

President, Operations GGNS of Entergy Operations, Inc.; and that the statements ma e and the matters set forth therein are true and correct to the best of my owle e, inf ma ' and belief.

s

- b1

~C. li.ilutchinson STATE OF MISSISSIPPI ,

COUNTY OF CLAIIiORNE

.r SUBSCRIBED AND SWORN TO befa 'l above named, this _ f 7@ day of L;e me, .1994.

uALL a Notary Public, in and for the Cou b

(SEAL) k]DuNLIN.0,In$)lbt-)

g Notary Public My commission expires:

m s m ra r m r- np y r..,.,,

,Il{C w ... ..rtP\ ^J:

D;v r ??;

D J,R.,

. p :; m. n, f ~$,.,

G9405101 l

- - - - - - -~ -

Attachment 2 to GNRO-94/00090 ,

?

I A.

SUBJECT:

i

1. PCOL-94/02: Deletion of the License Requirements imposed by NUREG-1216

2. Affected Operating License Pages

a. Reliability of Diesel-Generators, Page 10 of the Operating License, Item 25 (b).

b. Attachment 2 to the Grand Gulf Nuclear Station Operating License,- Pages (all). t H. DISCUSSION:

The TDI Owners Group was formed in late 1983 as a result of the failure of a crankshaft at the Shoreham Nuclear Plant. The crankshaft failure at Shoreham raised questions about the overall suitability of the TDI engines for nuclear service. In response to these concerns, the owners developed a detailed plan to review the design and validate the  !

acceptability of the TDI engines for nuclear service. This program, the Design Review / Quality Revalidation (DR/QR) program, was reviewed by the NRC and endorsed as NUREG-1216. The DR/QR program sen>ed the purpose for which it was intended, j that being to ensure the TDI engines were suitable for nuclear service. It is on the basis of the following information and the NRC's Safety Evaluation Report dated March 17, 1994, that removal of the requirements of NUREG-1216 from the Grand Gulf Operating  !

License is requested.

The Owners Group submittals included data from past engine teardowns and reliability ,

and availability data for all the TDI engines currently in nuclear service. The Owners Group submittals also included plant specific differences in design of the engines (e.g.

Grand Gulfs 17/8" connecting rod bolts). It is Entergy's position that the TDI Owner's Group submittals cover the entire spectrum of design issues for the TDI engines.  !

Entergy Operations views the NRC's Generic Safety Evaluation as a positive step in {

improving both reliability and availability of the TDI engines. However, one point of the SER bears clarification. The SER on page 9, paragraph 5, implies that all licensees are committed to implement slow starts. Entergy agrees that slow starts reduce stress and wear on internal engine components. Our experience, however, has shown that fast starts have not adversely affected engine performance or resulted in excessive or rapid ,

engine wear when proper pre-lubrication procedures are used prior to planned engine - i starts. Our operating procedure controls require pre-lubrication of the diesel with the Auxiliary Lube Oil Pump immediately prior to starting the engine. This method has proven very effective in maintaining very low wear rates on internal engine components and turbocharger thrust bearings. We believe that our pre-lubrication controls are equivalent to slow starts in addressing the underlying concerns associated with cold fast starts. On the other hand, we do commit to evaluate implementation of slow start G9405101 ,

t Attachment 2 to GNRO-94/00090 t

capability if wear monitoring, through lubricating oil analysis or other reliable methods, i reveals an excessive wear rate.  !

C. JUSTIFICATION:

The following information provides thejustification for PCOL-94/02.  !

1. The Owners Group submittals contained in Reference 1, provided data from teardowns and inspections of all the TDI engines currently in nuclear service. This data did not reveal any unusual or abnormal wear patterns for the components inspected. Given past inspection results and the better than required average reliability for these machines, it is no longer necessary to subject the TDI engines to l

a program of strict time based teardowns that are more stringent than requirements for other manufacture's engine.  ;

2. The teardowns called for in NUREG-1216 require a significant amount of time to perform, causing outage scheduling problems and increased outage risk. During these inspections the diesel generator is not available to perform its design function of supplying emergency power. With recent studies highlighting the risk i associated with shutdown reactors, having emergency power available has proven to be a vital contributor to reducing outage risk.

3. As pointed out in the NRC safety evaluation report for the owners group generic submittal, research (Reference 3) has indicated the potential negative consequences ofintmsive inspections (engine teardowns) on engine reliability. This study showed a marked decrease in reliability immediately following intmsive inspections. After the components of the engine are broken in (wear in period) there is a extended period ofincreased reliability lasting until the machinery reaches the end ofits lifetime.

4. The Owners Group report envelopes Grand Gulf design and operation.

D. NO SIGNIFICANT IIAZARDS CONSIDERATION:

10CFR50.92 states that a proposed amendment involves no significant hazards consideration if operation in accordance with the proposed amendment would not:

1. Involve a significant increase in the probability or the consequences of an accident previously evaluated:

The proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. Elimination of the required L teardowns and inspections has no effect on the probability of an accident occurring, because the diesel generators are not accident initiating equipment. Also, deleting G9405101

I Attachment 2 to GNRO-94/00090

.+

the teardowns and inspections would decrease the consequences of an accident because the availability of the engines would increase as a result of the less frequent teardowns. Additionally, the high average reliability of the TDI engines would not be negatively affected due to this change. _ NRC research has shown there is a period of decreased reliability immediately following intrusive teardowns, (break in period), followed by a long period of high reliability.

2. Create the possibility of a new or different kind of accident from any previously evaluated: <

The proposed amendment would not create the possibihty of a new or different kind of accident from any accident previously evaluated. The proposed amendment will not cause any physical change to the plant or the design or operation of the diesel units.

3. Involve a significant decrease in the margin of safety.

The proposed amendment would not involve a significant reduction in a margin of safety. The proposed amendment willincrease the reliability and availability of the EDGs and therefore will not result in a decrease in a margin of safety at Grand Gulf.

E.

REFERENCES:

1. Transamerica Delaval, Inc. Emergency Diesel Generators Owners Group, Generic Topical Report, TAC-M85325, " Basis for Modification to Requirements for Transamerica Delaval, Inc. Emergency Diesel Generators," dated April 28,1994.

2. NRC Safety Evaluation Report , " Operability and Reliability Review of Emergency j Diesel Generators Manufactured by Transamerica Delaval, Inc." dated March 17,  !

1994.

3. NUREG/CR-5057, K. R. Hoopingarner and F. R. Zaloudek, " Aging Mitigation and Improved Programs for Nuclear Service Diesel Generators," Pacific Northwest Laboratory, PNL-6397, December 1989.

l G9405101

i l

l

'l I

ATTACIIMENT 3 MARK-UP OF AFFECTED OPERATING LICENSE PAGES i

G9405101 i

l r \

(24) Interplant Comunication Systems (Section 9.6.1.2, SER, SSER #2, SSER

1. 4, 55ER #5)

Tests of the comunication systems used to mitigate the consequences of an event and attain a safe plant shutdown shall be completed during preoperational and startup tests. An evaluation of the test results shall be provided for NRC review within 90 days after test completion. Any system modifications found necessary as a result of NRC review shall be completed prior to startup following the first refueling outage.  ;

i (25) Reliability of Diesel-Generators (Sections 8.3.1, 9.6.3 through 9.6.7, 5ER, 55ER #2, 55ER f4, 55ER #6)

' (a) Prior to startup following the first refueling outage, a heavy Y@ge- duty turbocharger gear drive assembly shall be installed on all EMD diesel-generators.

._. , , ~ - -

m~r<

(b) E0! : hall e 51y with SI :=rgency diesel generator reqeire.ariti l sp ified in I,tiacha nt 2 to thi: licen::. ,

(26) Turbine Dise Integrity (Section 10.2.1, SER, SSER #1)

E01 shall ultrasonically inspect the bores and keyways of the low \

pressure turbine discs for indications of cracking prior to exceeding

• 50,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation. All unacceptable indications and their dispositions shall be reported prior to startup for the next cycle of operation. These inspections shall continue on a 50,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> interval until the potential for turbine disc cracking has been assessed and an acceptable alternate inspection schedule has been established.

(27) Circulating Water System (Section 10.4.5, SER)

E01 shall not fill the Unit 2 circulating water system (including l the natural draft cooling tower basin) until Unit 1 flooding concerns related to this system are resolved to the satisfaction of the NRC staff.

(28) Advisor to the Vice President MP&L shall have on its nuclear operations staff, one or more corporate l  !

management officials or advisors (who may be either permanent employees or contracted consultants) who have substantial connercial nuclear power plant operating management experience and who will advise on all decisions affecting safe operation of the plant. This requirement shall be in effect until the plant has accumulated at least 6 months at power levels above 90 percent of full power.

1 10 Amendment No. (

l i

Attachment 2 Transamerica Delaval Inc. (TDI) Diesel Generator

/

Maintenance and Surveillance Requireme'nts i

(NUREG-1216, August 1986)

1. Maintenance and Surveillance Program i

E0Ishallimplementandmaintainineffectteprovisionsofthemaintenancej i and surveillance program for the TDI emergepcy diesel generators at GGNS '

Unit 1 as identified in the MP&L letter d ted Juiy 18, 1986 (AECM-86/0172) and as approved in the staff's Safety Ev uation Report atta:hed to the  !

2 and letter NRC dated December 9, 1986, subj t to the provisions of paragraphs 3 below, i i

2. Changes fh((

EDI mayprior without makeapproval changes ofto the the appro ed maintenance and surveillanct program Co ission  !

provided the changes do rot adverse-ly affect the operability or r iability of the diesel generators or involve changes in the Phase Surveillance requirements of paragraph 3 below or otherwise change li nse conditions or Technical Specifications or result in an unreviewed saf y question as defined in 10 CFR 50.59. E01 l shall maintain in auditabl form, a current record of all such changes, including an operability analysis and reliabiof he effects of the change on diesel generator ty, and shall make such records available to NRC inspectors upon reques . All changes to the program shall be reported annually to the Direc or of the Office of Nuclear Reactor Regulation, along with the FSAR revisi ns required by 10 CFR 50.71(e).

3. Phase 1 Component urveillance Requirements E0I shall compl with the following requirements: (

3.1 Connecti o Rods Conne ing rod assemblies shall be subjected to the following insp tions at each major engine overhaul *:

a.

The surfaces of the rack teeth shall be inspected for signs of fretting. If fretting has occurred, it shall be subject to an engineering evaluation for appropriate corrective action.

• The f equency of the major engine overhauls referred to in these requirements shal be consistent with Section IV.1. " Overhaul Frequency" in Revision 2 of App ndix II of the Design Review / Quality Revalidation report which was transmitted by MP&L letter dated July 18, 1986.

1 Amendment No.-& (

i

b. All connecting-rcri bolts shall be lubricated in accordance with  ;

the engine manufacturer's instructions and torqued to the speci-  ;

fications of the itianufacturer. The lengths of the two pairs of )

bolts above the crankpin shall be measured ultrasonica y pre and post-tensioning.

/

c. The lengths of the two pair of bolts above the cra pin shall be measured ultrasenically prior to detensioning'/ d disassembly of the bolts. If bolt tension is less than an e ivalent of 2400 ft-lbs, the cause shall be detemined, app opriate ,

corrgetiye action shall be taken, and the int val between  !

checks f bolt tensien shall be re-evaluated

! /f

d. g 17 connecting-rod boits shall be visuall inspected for thread damage (e.g., galling) and the two pair of connecting rod

.holtsabovethecrankpinshallbeinsoetedbymagneticparticle t All Wes,shersting (MT) used to verify with theshall the bolts continued a sence b xamined of cracking.

visually for signs

'ofggalling or cracking, and replace /eif damaged,

e. A hisual inspection shall be perf rmed of accessible external  %

's faces of the link rod box to erify the absence of any signs .

N of service induced distress.

f'

f. All of the bolt holes in th link rod box shall be inspected

.firthreaddamage(e.g.,g ling) or other signs of abnomalities.

j N 'l; addition, the bolt hol subject to the highest stresses (i.e.. I

'the pair immediately abo e the crankpin) shall be examined with an appropriate nondestr etive method to verify the continued absence of cracking, ny indications shall be recorded for i engineering evaluati and appropriate corrective action. ,

g. If the diesel gen ators are operated in excess of 5740 KW steady state, all conne ing rods shall be disassembled and inspected at an interval f approximately 5 years coincident with the end of a fuel cycl , except that connecting rod disassembly and inspection i not required for limited post maintenance testing over 5740 K for the purpose of seating new piston rings as described the MP&L letter dated December 6, 1985 (AECM-85/0395).

3.2 Cylinder Bio

a. Cyli er blocks shall be inspected for " ligament" cracks, i "st -to-stud" cracks and " stud-to-end" cracks as defined in a re rt by Failure Analysis Associates, Inc. (FaAA) entitled, sign Review of TDI R-4 and RV-4 Series Emergency Diesel enerator Cylinder Blocks" (FaAA report no. FaAA-84-9-11.1) dated December 1984.** (Note that the FaAA report specifies l

• • Transmitted to H. R. Denton, NRC from C. L. Ray, Jr., TDI Owners Group, i by letter dated December 11, 1984.

I

' ~

.. 3-additional inspections to be performed for blocks with "known" .

or " assumed" ligament cracks). The inspection intervals i frequency) shall not exceed the intervals calculated gusin/1.e., the '

cumulative damage index model in the subject FaAA repo t. In addition, inspection method shall be consistent with r equivalent to those identified in the subject FaAA port.  ;

b. In addition to inspections specified in the afor entioned FaAA report, blocks with "known" or " assumed" ligame cracks (as i defined in the FaAA report) shall be inspected t each refueling outage to determine whether or not cracks hav initiated on the  !

top surface exposed by the removal of two or more cylinder heads. This process shall be repeated over several refueling outages until the entire block top has be inspected. Liquid-penetrant testing or a similarly sensiti e nondestructive testing technique shall be used to det t cracking, and eddy current shall be'used as appropriate detemine the depth of ,

any cracks discovered.

c. If inspection reveals cracks in t cylinder blocks between E stud holes of adjacent cylinders " stud-to-stud" cracks) or 4  ;

" stud-to-end" cracks, this cond tion shall be reported promptly 9 to the NRC staff and the aff ed engine shall be considered inoperable. The engine shal not be restored to " operable" { l status until the proposed d sposition and/or corrective actions  ; j have been approved by the RC sta, f.

}  !

3.3 Cylinder Heads I

Qg { f The following air roll te shall be' performed as specified below, except when the plant is Iready in an Action Statement of Technical  :

Specification 3/4.8.1 - lectric Power Systems, A.C. Sources": '

The engines shall be olled over with the airstart system and with the cylinder stopco s open prior to each planned start, unless that start occurs withi 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a shutdown. The engines shall also be rolled over w h the airstart system and with the cylinder stopcocks open ter 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 t en 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 j each shutdow . (In the event an engine is removed from service for i any reason her than the rolling over procedure prior to expiration of the 8-h r or 24-hour periods noted above, that engine need not be roll over while it is out of service. The licensee shall air roll th engine over wtr.h the stopcocks open at the time it is return to service.) The origin of any water detected in the cylin er must be detemined and any cylinder head which leaks due to a cr ek shall be replaced. The'above air. roll test may be discon-ti ed following the first refueling outage subject to the following j

-c nditions: 1

F )

i....-

l l

I

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

F

') . Quality revalidation inspections, as identifie in the GGNS ,

Design Review / Quality Revalidation Report, Re sion 2, have been completed for all cylinder heads.

/

c. Group III heads continue to demonstrate f orable leakace performance. This should be confimed 'with TDI prior to deleting air roll tests. /

I l f

l7 t 3.4 Turbocharcers 'O Periodic inspections of the turbocharge shall include the following: r,i i

a. The turbocharger thrust bearingI shall be visually in:pected for $

excessive wear after 40 non-pr ubed starts since the previous .

visual inspection. ," 3

b. Turbocharger rotor axial cl arance shall be measured at each

• 8 refueling outage to verif compliance with TDI/Elliott l specifications. In addi' on, thrust bearing measurements shall ,

be compared with measur ents taken previously to detemine a need for further inspe ion'or corrective action.  ;

l c. Spectrographic and rrographic engine oil analysis shall be i Q performed quarterl to provide early evidence of bearing degradation. Par cular attention shall be paid to copper level and parti ate size which could signify thrust bearing dearadation. l

d. The nozzle r g components and inlet guide vanes shall be visually in ected at each refueling outage for missing parts  !

or parts owing distress. If such are noted, the entire ring i assembly hall be replaced. )

l l

l i

i