L-PI-13-039, Supplement to License Amendment Request (LAR) to Add Diesel Fuel Oil License Bases and Revise Technical Specifications (TS) 3.7.8, Cooling Water (Cl) System and 3.8.3, Diesel Fuel Oil.
| ML13121A092 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/30/2013 |
| From: | Jeffery Lynch Northern States Power Co, Xcel Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TAC ME6849, TAC ME6850, L-PI-13-039 | |
| Download: ML13121A092 (12) | |
Text
tl Xcel Energy L-PI-13-039 APR 3 0 2013 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 Supplement to License Amendment Request (LAR) to Add Diesel Fuel Oil License Bases and Revise Technical Specifications (TS) 3.7.8, "Cooling Water (CLl System" and 3.8.3, "Diesel Fuel Oil" (TAC Nos. ME6849 AND ME6850)
By letter dated August 11, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML112240140), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requested NRC review and approval of additional diesel fuel oil (DFO) license bases and amendments to TS 3.7.8, "Cooling Water (CL) System" and 3.8.3, "Diesel Fuel Oil" for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. NSPM supplemented this LAR by letters dated February 21,2012 (ML12054A057) and July 9, 2012 (ML12192A213), October 4,2012 (ML12279A116) and February 8,2013 (ML13039A332).
NSPM has further evaluated the capability to transfer DFO during a maximum probable flood and concluded that acceptable paths differ from those described in the supplement dated February 8, 2013 (ML13039A332). Page 2 of the Enclosure to the letter dated February 8, 2013 (ML13039A332) implies fuel oil will be transferred from "storage tank to storage tank" within the Unit 1 DFO system. During flood conditions, the system is capable of sharing DFO between the trains by transferring DFO from storage tank to day tank. This page was revised and is provided in Enclosure 1 to this letter with the revised line indicated by a right margin sidebar. Also the Unit 1 DFO fill connection described in the Updated Safety Analysis Report (USAR) page markup in the supplement dated February 8, 2013 (ML13039A332), Enclosure Attachment 3, page
. 2, as the "emergency safeguards fill connection" is more appropriately described as an "alternate fill connection" and this connection is not accessible during site flooding conditions. The USAR markup pages have been updated to include the revised DFO transfer paths and the revised fill connection designation. Although only two USAR markup pages are affected, for clarity, all seven USAR markup pages are provided in 1717 Wakonade Drive East
- Welch, Minnesota 55089-9642 Telephone: 651.388.1121
Document Control Desk Page 2 Enclosure 2 to this letter. The revised lines are indicated by the unnumbered right margin sidebars. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.90.
The supplemental information provided in this letter and enclosure does not impact the conclusions of the Determination of No Significant Hazards Consideration or Environmental Assessment presented in the August 11,2011 (ML112240140) submittal as supplemented February 21,2012 (ML12054A057), July 9,2012 (ML12192A213),
October 4, 2012 (ML12279A116) and February 8, 2013 (ML13039A332).
In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR supplement by transmitting a copy of this letter and enclosure to the designated State Official.
If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 'l/3</;3 i.:~
Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (2) cc: Administrator, Region III, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota
ENCLOSURE 1 Revised Enclosure Page 2 of 11 from letter dated February 8,2013 (ML13039A332)
One page follows
Diesel Fuel Oil RAls requirements will maintain a safer fuel oil storage configuration to protect the plant during a DBA [design basis accident].
Maintaining the cross tie between the EDG and DDCLP fuel oil supplies as part of the TS compliance will require additional sUNeillance testing. The limited tank volume flexibility does not offset the additional testing requirements, therefore the cross tie ability will no longer be credited for meeting the 7-day TS supply requirement.
Other than the cross tie capability, the Unit 1 7-day requirement and basis has not changed from the original August 11, 2011 submittal (ML112240140). The TS requirement will still maintain the 7 -day fuel oil supply for each train of EDGs and DDCLPs. Therefore, the ability to mitigate an accident has not been reduced by this proposed change. The only function that has been affected is the potential ability to operate with reduced volume in one or two of the tanks while crediting fuel oil in the other same train tank(s).
The 14-day fuel oil supply requirement for a maximum probable flood will be retained in the Updated Safety Analysis Report (USAR) for Unit 1. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to day tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.)
Unit 2 has dedicated fuel oil storage tanks for each EDG so there are no changes to the crediting of the 7-day supply. In addition, the 14-day fuel oil supply requirement for a maximum probable flood will be retained in the USAR for Unit 2. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.)
This proposed license basis change necessitates additional changes to the TS 3.7.8 Bases and TS 3.8.3 Bases which are provided in marked up format as Attachment 1 to this Enclosure. These marked up Bases supersede in their entirety the marked up Bases provided in the original submittal dated August 11,2011 (ML112240140),
Enclosure Attachment 2. Pages B 3.7.8-16, B 3.8.3-5 and B 3.8.3-6 have been revised.
NRC Request for Additional Information (RAJ) EEEB-13 The license amendment request (LAR) states that six Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) supply fuel oil to the two emergency diesel generators (EDGs) D1/D2 and the two diesel-driven cooling water pumps (DDCLPs). These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any diesel day tank. Therefore, any combination of the six tanks can be used to meet the 14-day storage capacity requirement for a probable maximum flood. This licensing basis will be maintained.
Page 2 of 11
ENCLOSURE 2 Revised Draft Updated Safety Analysis Report Section 10.3.13 Seven pages follow
PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT
. . USAR Section 10 1rl~ () 15 ~ 1 fj "HI) 5 A<<MfA IklAf r~{ ellit sJoJC(J~~I.::i~;'~~~
y IJ The Control Rooms and 480V switchgear areas are provided with a direct expansion type mechanical cooling system for non-safety related auxiliary cooling. Each cooling system consists of an outdoor compressor/condenser unit, a room-mounted evaporator/fan unit, interconnecting tubing, control equipment, and power supply.
The safety-related building ventilation system includes two 100% capacity vane axial type supply fans and two 100% capacity exhaust fans per train. The fans have direct-drive totally enclosed, air over (TEAO) motors. One supply and one exhaust fan per train are normally operating, with the other fan in standby: All safety-related eqUipment is powered from safeguards buses.
The Lube Oil and Fuel Oil Tank Rooms are provided with exhaust fans to prevent the buildup of fumes.
The 05/06 Diesel Generator Room Ventilation system includes the non-safety related normal mode ventilation fans, provided for human comfort; the safety-related cooling fans (one PC3r train) which operate upon receipt of a diesel generator start,signal; and the associated ductwork and controls. The diesel generator room cooling fans will function to limit the maximum ambient temperature to 120°F in conformance with equipment operating temperat!lre ratings, and supply the volumetric flow of air necessary to cool the generator bearings. The outside air is modulated with return air to maintain a minimum temperature of 50°F in the Diesel Generator Engine Room. The diesel generator room cooling fans are vane axial type with direct-drive TEAO motors, and are supplied from safeguards buses. The ventilating equipment is accessible for periodic testing and inspection during normal operation.
10.3.13 Fuel Oil System 10.3.13.1 Design Basis 10.3.13.1.1 Function The fuel oil system receives and stores diesel fuel oil and delivers it to the fuel oil systems of both safety and non-safety related components consisting of six diesel generators, two diesel driven cooling water pumps, one heating boiler, and a diesel driven fire pump. Since four of the' diesel generators, 01/02 and 05106, and the cooling water pumps are safety related components, provisions are made in the design and installation to ensure that these components will operate in the event of an abnormal or emergency condition. The fuel oil system for Unit 1 provides fuel oil for the operation of all but two safety related emergency diesel generators, 05/06; the fuel oil system for Unit 2 provides fuel oil solely for the operational needs of emergency diesel generators 05/06.
The fuel oil system also provides a means of transferring fuel oil between fuel oil storage tanks and a means of filtering new and transferred oil.
PRAIRIE ISLAND UPDATED SAFETY ANAL YSIS REPORT USAR Section 10 Revision 32 Page 10.3*33 10.3.13.1.2 Design Minimum Storage Capacity 10.3.13.1.2.1 Unit 1 The Unit 1 design minimum storage Gapaoity of diesel fuel oil is based on one emergenoy diesel generator (EOG), 01 or 02, operating at the loads stated in Table 8.4 1 plus one diesel driven Gooling !Nater pump for 14 days. Under those ~
Gonditions one EOG 'Nould require 42, 14 6 gallons of fuel oil and tho diesol drivon , 1.- i Gaoling '.vater pump viould require 19,428 gallons. (Reference 7 2 ) , f \?5,c J h.>~' ()
10.3.13.1.2.2 Unit2 )
Tho Unit 2 design minimum storage Gapaoity of diesel fuel oil is based on (1) two EDGs, 05/06, operating at the loads stated in Table 8.4 2 for 7 days or (2) one EOG, 05 OF 06, I operating at the loads stated in Table 8,4 2 fer 14 days. For condition (1) tho two EOGe would require 70,595 gallons of fuel oil and for sondition (2) one EDG would require 70,496 gallons. (Reforence73) 10.3.13.2 Description 10.3.13.2.1 Unit 1 Four Design Class I fuel oil storage tanks supply fuel oil to the two emergency diesel generators (EDGs) 01102. Each tank is equipped with a transfer pump to pump fuel from the tank to the nominal capacity 500 gallon day tank of either EDG. for the two diesel driven cooling water pumps, fuel oil supply is from two Design Class I fuel oil storage tanks. Similarly each tank is provided with a transfer pump to transfer fuel to either diesel driven cooling water pump nominal capacity 500 gallon day tank. Two non-Design Class I fuel oil storage tanks supply fuel oil to the heating boiler booster pumps and/or the D3/D4 fuel oil day tanks supply pumps. A small 4,000 gallon non-Design Class I fuel oil storage tank supplies the day tank for the diesel fire pump.
Interconnecting piping, valves, and instrumentation are shown in Figure 10.3-18.
The fuel oil storage tanks are normally filled from the fuel oil transfer house through a filter. The safety related diesel generator fuel oil storage tanks are filled either from the normal fill connection or from an '11 connection. The diesel cooling water and diesel fire pump fuel oil storage tanks r so filled from either the normal fill connection or emergenoy safeguards . i connection. Iternate fill connection is provided for each of the heating bOiler 0 e tanks.
Piping and valving is provided to transfer fuel oil from anyone fuel oil storage an alternate any other fuel oil storage tank by using the proper valve lineup. A submersible pump associated with each fuel oil storage tank pumps the fuel oil to the transfer house where the oil is then routed to the desired fuel oil storage tank. The boundary between safety and non-safety related components is provided by normally closed isolation valves. In addition, any fuel storage tank can be pumped to any diesel's day tank by performing a special valve lineup.
(6) lJ J;>
10.3.13.1.2.1 Unit 1 The Unit 1 design minimum storage capacity of diesel fuel oil is based on one emergency diesel generator (EDG), D 1 or D2, operating at the loads stated in Table 8.4-1 plus one diesel driven cooling water pump (DDCLP), 12 or 22, for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 1 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EDG and DDCLP in accordance with Technical Specifications. The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained. The onsite Unit 1 fuel oil supply is sufficient to operate one EDG and one DDCLP for longer than the time to replenish the onsite supply from outside sources. (Reference 72) 10.3.13.1.2.2 Unit 2 The Unit 2 design minimum storage capacity of diesel fuel oil is based on one EDG, D5 or D6, operating at the loads stated in Table 8.4-2 for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 2 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EDG in accordance with Technical Specifications. The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained. The onsite Unit 2 fuel oil supply is sufficient to operate one EDG for longer than the time to replenish the onsite supply from outside sources. (Reference 73)
ell)
PRAIRIE ISLAND UPDA TED SAFETY ANALYSIS REPORT USAR Section 10 Revision 32P Page 10.3-34 10.3.13.2.2 Unit 2 The Unit 2 fuel oil system consists of a noo-Design Class I fuel oil receivin'g tank, four Design Class I fuel oil storage tanks, fo.ur fuel oil transfer pumps, two fuel oil day tanks, one fuel oil recirculating pump, four fuel oil trahsfer recirculation filters, a receiving tank recirculating filter, and associated piping, valving and instrumentation. The basic drawing of the Unit 2 fuel oil system is shown in Figure 10.3-19.
The fuel oil receiving tank supplies fuel oil to the fuel oil storage tank~ and the fuel oil recirculation pump. The four fuel oil storage tanks supply fuel oil to the fuel oil day tanks via the fuel oil transfer pumps. The two fuel oil day tanks each have a nomihal capacity of 600 gallons.
The fuel oil receiving tank is filled from a truck fill connection. The fuel oil storatle tanks are filled from the fuel oil receiving tank by gravity feed. Also, there is an emergenCY fuel oil storage tank fill connection located in the 05/06 building. The emergency fill connection cEm be utilized in the event of flooding which could render the receiving tank fill connection inaccessible. The fuel oil day tanks can only be filled from the fuel oil storage tanks.
Piping is provided to permit the transfer of fuel oil from one storage tank to another storage tank or to the receiving tank by using the appropriate valve lineup. The transfer can be accomplished by performing a tank recirculation lineup through the fuel oil transfer recirculation filters and pumping the tank contents through the recirculation header to another lank.
The fuel oil storage tanks of each diesel generator building are looated in $ Seismic Category I reinforced concrete fUel oil storage vault. The fuel oil storage vaults are
- Iocateel below gro.und level. The vaults provide the required three-hour rated fire protection barrier and are designed to withstand the effects of tornado generated missiles, site flo()d and buoyancy force considerations. The storage vaults are provided with leak detection sumps. If a sump fill~ with water and/or fuel oil, an alarm will activate on the main diesel generator loc'al control panel.
The b~se of the fuel oil receiving tank is located helow ground level and the tank is in a concrete lined retention basin. The basin is sized to contain the tank volumetric contents, should a leak occur.
Ktor",~e Co.", ks- I The fuel oil eay-taRk associated with one EOG can be filled directly from the fuel oil storage tanks of the other EDG by petiorming a valve lineup through the receiving tank return line. However, each fuel oil day tank is dedicated to its respective EDG and oannot supply fuel oil to the other EDG directly.
(9 PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT USAR Section 10 Revision 32 Page 10.3-35 10.3.13.3 Performance Analysis 10.3.13.3.1 Unit 1
=there are four Design Class I fuel oil storage tanks (19,500 nominal, 17,500 availaele gallons each) for the Unit 1 EDGs and two Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons eaGR) for tRe diesel driven Gooling \VateJ:
f}umps. The six Design Class I tanks are interoonnected such that any tank can be manually aligned to supply any diesel day tonic Therefore any comeination of four tanks will meet tRe storage capaoity requirements. TRe Unit 1 Design Class I fuel oil storage tanl<s can also be refilled from either of the t'...,o nOR-Design Glass I heating eoiler fuel oil storage tanl<s (35,000 nominal gallons each).
10.3.13.3.2 Unit 2 Thero are four Unit 2 Dosign Class I fuel oil storage tanks (32,800 nOAlinal, )
30,800 available gallons each). The four tanks are intoroonneoted such that any tank can be manually aligned to supply either diesel day tank. Thorefore, any oombinatien of throe tonl<6 'Nill meet tho storage capaoity requirements.
4-0.3.13.4 Tasting and InspeotioR puel oil sampling is done in accordanoe 'Nith tho Diesel Fuel Oil Testing Pregram for each Diesel Glass I fuel oil storage tanl< and verified by analysis that the samples are
"'/ithin acceptaBle limits. In addition, operability of the fuel oil transfer pumps and fuel )
flow to the days tanks are verified in aooordanoe '.vith the Technical Speoifioations.
(0 The Diose! Fuel Gil Testing Program is credited as part of tho Lieense Renmval Fl:lel Oil I~
GAemistry Aging Management Program as desoribed in Appendix b. ,~
o 10.3.13.5 Instrumentation and Control 10.3.13.5.1 Unit 1 The fuel oil storage tanks are provided with level instrumentation to indicate tank liquid level at the control room (except for the heating boilerfuel oil storage tank) and filter house. High level will actuate an alarm in the control room except for the heating boiler fuel oil storage tank.
Level switches are provided in the fuel oil day tanks for automatic makeup.
10.3.13.3.1 Unit 1 There are four Design Class I fuel oil storage tanks (19,500 nominal, 17,500availab1e gallons each) for the Unit 1 EDGs and two Design Class Ifuel oil storage tanks (19,500 nominal, 17,500 available gallons each) for the diesel driven cooling water pumps. The six Design Class I tanks are interconnected such that any storage tank can be manually aligned to supply any diesel day tank. Therefore any combination of the tanks will meet the 14 day fuel oil supply requirements. The 7 day fuel oil supply configuration requirements will be maintained in accordance with Technical Specifications. The Unit 1 Design Class 1 fuel oil storage tanks can also be refilled from either of the two non-Design Class I heating boiler fuel oil storage tanks (35,000 nominal gallons each).
10.3.13.3.2 Unit 2 There are four Unit 2 Design Class I fuel oil storage tanks (32,800 nominal, 30,800 available gallons each). The four tanks are interconnected such that any storage tank can be manually aligned to supply any diesel storage tank. Therefore, any combination of the tanks will meet the storage capacity requirements for the 14 day fuel oil supply requirements. The 7 day fuel oil supply configuration requirements will be maintained in accordance with Technical Specifications.
10.3.13.4 Testing and Inspection Fuel oil sanlpling is done in accordance with the Diesel Fuel Oil Testing Program for each Diesel Class I fuc;l oil storage tank and verified by analysis that the samples are within acceptable limits. In addition, the operability of the fuel oil transfer pumps and fuel flow paths from associated storage tanks to associated days tanks are verified in accordance with the Technical Specifications.
The interconnecting capability for the 14 day fuel oil supply requirement will be tested every refueling cycle for the associated Unit. The testing will verify flow path integlity for all the various storage tank to d~y tank configurations.
The Diesel Fuel Oil Testing Program is credited as palt of the License Renewal FuelOil Chemistry Aging Management Program as described in Appendix L.
(J)
PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT USAR Section 10 Revision 32 Page 10.3-36 10.3.13.5.2 Unit 2 The fuel oil storage tanks are provided with level instrumentation, mounted on the diesel generator benchboard control panel and monitored by a computer. Tank high and low levels annunciate in the diesel generator control room. A separate leak detection monitoring instrument system is provided for each pair of tanks serving a single diesel generator set.
Level instrumentation is provided with each fuel oil day tank for automatic makeup.