ML20045D896
| ML20045D896 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/23/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20045D897 | List: |
| References | |
| RTR-NUREG-1433 NSD930537, NUDOCS 9306300183 | |
| Download: ML20045D896 (10) | |
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GENERAL OFFICE
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NSD930537 June 23, 1993 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
Revision to Proposed Change No. 84 to Technical Specifications
" Diesel Generator Fuel Oil Storage Capacity and Fuel Quality Testing" Cooper Nuclear Station NRC Docket No. 50-298, DPR-46
Reference:
Letter G. R. Horn to USNRC dated September 2,1992, " Proposed Change No. 84 to the CNS Technical Specifications - Diesel Generator Fuel Oil Storage Capacity and Fuel Quality Testing" Gentlemen:
In the above Reference, the Nebraska Public Power District (the District) submitted a proposed change to the Cooper Nuclear Station (CNS) Technical Specif.' cations that would increase the minimum amount of Diesel Fuel Oil capacity required to be available in the on-site Diesel Fuel Oil Storage Tanks, and updates the standard to which the fuel oil quality is tested to a more recent edition of the same standard.
As a result of recent discussions between the District and the NRC concerning this subject anc* subsequent District review of this proposed change, the District has decided to revise proposed change No. 84 by including additional diesel fuel oil testing requirements to the CNS Technical Specifications. The proposed revisions to change No. 84 are modeled after the BWR/4 Standard Technical Specifications (STS), NUREG 1433, concerning Diesel Fuel Oil Testing Requirements. This revision to proposed change No. 84 updates Section 3/4.9,
" Auxiliary Electrical System - Diesel Generators," and its associated Bases sections in the CNS Technical Specifications, by including Limiting Conditions for Operation and Surveillance Requirements for testing of particulate concentration levels, and Surveillance Requirements to check for the presense of water in the diesel fuel oil storage tanks. These added restrictions and surveillance requirements will continue to ensure that the diesel fuel oil used at CNS in support of Diesel Generator operation will continue to be of high quality.
The District considers that the no significant hazards determination contained in the reference to still be valid in regard to the increase in on-site fuel oil storage capacity, and the updated edition to the fuel oil quality standard used for testing the diesel fuel oil. However, the District has included in the attachments an additional no significant hazards determination in support of the revision to proposed change No. 84 dealing with particulate concentration testing, and water testing requirements of the diesel fuel oil.
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.+ U.' S.~ Nuclear-Regulatory Commission June 23, 1993 ,
Page 2 of 3' '
Therefore, the attached contains a description of the proposed changes,. the attendant 10CFR50.92 evaluation (concerning particulate concentration, and water testing), a mark-up showing the proposed changes to the CNS Technical Specification pages, and the new revised Technical Specification pages as
. proposed. This. revision to proposed change No. 84 has been reviewed by the- :
necessary Safety Review Committees and incorporates all amendments to the CNS L:
Facility Operating License through Amendment 163 issued May 19, 1993. In order to facilitate the orderly revision of affected plant procedures, the District also requests that the amendment associated with this proposed change including .
the revision, becomo effective 30 days after date of issuance.
By copy of this letter and attachment, the appropriate State'of Nebraska official -
is being notified in accordance with 10'CFR 50.91(b)(1) . Copies to the NRC Region IV Office and CNS NRC Resident Inspector are also being sent in accordance with 10 CFR 50.4(b)(2).
Should you have any questions or require additional information, please contact me. ,
Si cere y, (lh[ibb7I'~
Nuclear Power Group Manager GRH/tj a : PC- 84rev. ltr Attachment cc: H. R. Borchert ;
Department of Health .;
State of Nebraska -
NRC Regional Office Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station t
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. U,' S. Nuclear Regulatory Commission
-June 23, 1993 Page 3 of 3 STATE OF NEBRASKA )
)ss PIATTE COUNTY )
G. R. Horn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation'and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the-statementy contained herein are true to the best of his knowledge and belief.
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{]~G.'R'. Horn .
Subscribed in my presence and sworn to before me this M day of bHY, , 1993.
U 0Ma-(d4WA- GEMMI NOTAR$ tate of Ndruta NOTARY PUBY.fC'. RITA L GOFF d My Comm bp. Dec. 19.1995 1
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NSD930537 Attachment 1
. Page 1 of 6 REVISED TECHNICAL SPECIFICATION PAGES FOR DIESEL FUEL OIL QUALITY TESTING Revised Pages 194 194a 196 198 199 200
- 1. INTRODUCTION The Nebraska Public Power District (District) requests that the NRC approve the proposed changes to. the Cooper Nuclear Station (CNS) Technical Specifications. The proposed changes described below are revisions to proposed change No. 84 to the CNS Technical Specifications,ril and include additional testing requirements of diesel fuel oil to be stored at CNS for-use in the Emergency Diesel Generators. These proposed revisions to change No. 84 are modeled after the BWR/4 Standard Technical Specifications (STS), '
NUREG 1433, concerning diesel fuel oil testing requirements.
This revision to proposed change No. 84 updates section 3/4.9 " Auxiliary Electrical System - Diesel Generators," and its associated Bases sections in the CNS Technical Specifications, ~ by including Limiting Conditions for Operation (LCO) and . Surveillance Requirements - (SR) for the . testing of particulate concentrations levels, and checking for the presence of water in the standby emergency diesel fuel oil storage tanks.- ' These added restrictions and surveillance requirements will' continue to ensure that the diesel fuel oil used at CNS in support of Emergency Diesel Generator operation will continue to be of high quality. Revising the CNS Technical.
Specifications as described herein will make the CNS Technical Specifications more-consistent with the BWR/4 STS _in this regard.
The District considers that the no significant hazards ' determination contained in proposed change No. 84.to the CNS Technical Specificationst21 .
to still be valid for the fuel oil storage capacity, and the updated edition '
to the fuel oil quality standard. However, . the District has ' included in this revision to proposed change No. 84 administrative type changes concerning the ASTM-D975-1989a standard. These -' administrative changes include specifying certain tests that will be performed-on. new diesel fuel -i oil prior to mixing the new fuel oil into the storage tanks. These tests have always been performed in meeting the requirements of ASTM-D975, however, as stated earlier, they' are now specified in the CNS Technical Specifications in order to model the CNS Technical Specifications after the BWR/4 STS. Therefore, for this reason the District considers that the no significant hazards determination submittedt21 in support of updating to a newer edition to the same standard to still be valid.
{l) Letter G. R. Horn to USNRC dated September 2, 1992, " Proposed Change No. 84 to the CNS Technical Specifications - Diesel Generator. Fuel' Oil Storage Capacity and Fuel Quality Testing"
NSD930537 Attachment 1 Page 2 of 6 The remaining revisions to proposed change No. 84 add new LCOs, SRs, and associated Bases changes in support of -adding particulate concentration 1evel testing, and checking for the presence of water in the emergency diesel fuel oil storage tanks to the CNS Technical Specifications. These proposed revisions follow the format for LCO durations, SR frequency, and Bases discussions found in the BWR/4 STS. Due to the nature of the new requirements, a new "no significant hazards determination" is. submitted in support of this revision to proposed change No. 84. This new no significant '
hazards determination addresses only the particulate concentration level testing, and the checking for the presence of water, as .the previous no significant hazards determination is considered to still be valid but did not address either added requirement of particulate and water testing of the diesel fuel oil.
II. DESCRIPTION OF CHANGES The changes to the CNS Technical Specifications consist of: 1) Adding a LCO, and delineating both the immediate, and the delayed testing requirements of ASTM-0975-1989a into the CNS Technical Specifications; 2) Adding a LCO, and associated SR for particulate concentration level; 3) Adding SRs checking for the presence, and removal of water in.the diesel fuel oil storage tanks; and, 4) Updating the associated Bases sections concerning the additions described above. A mark-up of the affected CNS Technical Specification pages are provided in Appendix A, and the new affected CNS Technical Specification pages are provided in Appendix B. The specific changes proposed to the CNS Technical Specifications are detailed below.
Page 194 - Surveillance Requirement (SR) 4.9.A.2.c, is now used for the SR of logging the quantity of available diesel fuel oil.
SR 4.9.A.2.d, is now used for the new additional SR of testing for particulate concentration in the diesel fuel oil per ASTM-D2276-1991, Method A. This SR is modeled after the BWR/4 STS.
SR 4.9.A.2.e, is used for sampling the quality of diesel fuel oil per ASTM-D975-1989a, however, as stated earlier this SR has now delineated between the immediate testing, and the delayed testing of diesel fuel oil. This SR is also modeled after the.
BWR/4 STS.
Page 194a - This is a new page. SR 4.9.A.2.e is continued on this page.
Due to the additional SRs this new page -is required.
SR 4.9. A.2.f, is now used for the new additional SR, checking for the presence, and removal of water in the diesel fuel oil day tanks. This SR is also modeled after the BWR/4 STS.
SR 4.9. A.2.g, is now used for the new additional SR, checking for the presence, and removal of water in the diesel fuel oil storage tanks. This SR is also modeled after the BWR/4 STS.
NSD930537
. Attachment 1 Page 3 of 6 Page 194a - SR 4.9.A.2.h, is now used for the Diesel Generator 18 month inspection. This SR was previously SR 4.9.A.2.f, (page 194).
SRs 4.9. A.3.a 4.9. A.3.a.1, and 4.9. A.3.a.2 are now re-located to this new page. These SRs used to be located on page 194.
Page 196 - LCO 3.9.B.I.b.4, this is a new LC0 in conjunction with the new SR for particulate concentration testing. This LC0 allows a 7 day period to restore the diesel fuel oil to acceptable limits if particulate concentration levels tested per the SR determine the diesel fuel oil to be outside the specified limit of 10 mg/ liter. This LC0 is modeled after the BWR/4 STS.
LC0 3.9.B.1.b.5, this is a new LC0 in conjunction with the -
expanded SR for new diesel fuel oil testing. This LC0 allows a 30 day period to restore the diesel fuel oil in the storage tanks to acceptable limits when those parameters tested per SR 4.9.A.2.e.2, are found to be outside the specified limits per ASTM-D975-1989a. This LC0 is modeled after the BWR/4 STS.
Page 198 - Add new information to the 3.9 Bases section. This information discusses the new LC0 (3.9.B.1.b.4) added to section 3.9.- This discussion follows the BWR/4 STS concerning the allowable LCO duration and why it is acceptable.
Page 199 - Add new information to the 3.9 Bases section. This information discusses the new LC0 (3.9.8.1.b.5) added to section 3.9. This discussion follows the BWR/4 STS concerning the allowable LC0 duration and why it is acceptable.
Add new information to the 4.9 Bases section. This information discusses the SRs added to section 4.9. These discussions follow the BWR/4 STS and staff recommendations concerning the SR frequency intervals and why they are acceptable.
Page 200 - Add new information to the 4.9 Bases section. This information ,
discusses the SRs added to section 4.9. These discussions follow the BWR/4 STS and staff recommendations concerning the SR frequency intervals and why they are acceptable.
Information that was located on previous page 199 has now been re-located to this page due to the volume of the additional Bases discussions for the additional LCOs and SRs.
Deleted third to last paragraph which discussed diesel fuel oil quality, and how water could damage engine. These statements were replaced by discussions on diesel fuel oil quality and water testing discussions listed above.
NSD930537
. Attachment 1 Page 4 of 6 III. SIGNIFICANT HAZARDS DETERMINATION 10 CFR 50.91(a)(1), requires that licensee requests for operating license amendments be accompanied by an evaluation of significant hazards posed by d the issuance of the amendment. This evaluation is to be performed with 4 respect to the criteria given in 10 CFR 50.92(c). The following analysis meets these requirements.
Evaluation of this Amendment with Resnect to 10 CFR 50.92 The enclosed revision to proposed Technical Specification change No. 84 is judged to involve no significant hazards based on the following:
- 1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?.
Evaluation This proposed change does not involve a significant increase in the probability or consequences of a; accident previously evaluated. The proposed change reformats the existing and includes additional diesel fuel oil Limiting Conditions for Operation (LCO) and accompanying Surveillance Requirements (SRs) into a format consistent with the BWR/4 Standard Technical Specifications (STS), and NUREG 1433.
The Cooper Nuclear Station (CNS) Technical Specifications, like the BWR/4 STS, currently provide a set of surveillance requirement acceptability criteria associated with the diesel fuel oil. However, the STS identify additional surveillance requirements-for determining diesel fuel oil acceptability and associated Diesel Generator operability. Presently, the CNS Technical Specifications do not include any requirements for particulate concentration level testing, and checking for the presence of water in the diesel fuel oil, as ,
with the STS.
This proposed change adds additional diesel fuel oil LCOs, and SRs, not currently in the CNS Technical Specifications, in accordance with the guidance provided in the BWR/4 STS. These new surveillance requirements include particulate concentration level testing, with a specified limit as to what the particulate concentration level can be, and establishes a LC0 of 7 days in conjunction with the new SR if the specified limit cannot be. attained. This change also includes new surveillance requirements to check for the presence of water in both the diesel fuel oil day tanks and storage tanks. These additional surveillances provide further assurance that the diesel fuel oil stored, at CNS in support of Emergency Diesel Generator operation will continue to be of high quality, and accordingly do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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NSD930537 i
. Attachment 1 Page 5 of 6 Operation of the Diesel Generators and its auto-start signals are not altered with this proposed change. The ability of the Diesel Generators to meet their Safety Design Basis as- contained in the Updated Safety Analysis Report (USAR) is not affected by this change. i The Diesels will remain able to perform their accident mitigative er.tions as described in the USAR so that the consequences of a previously evaluated accidents remain bounding. Therefore, the probability or consequences of previously evaluated accidents has not significantly increased.
Based on the above discussions, the changes proposed in this revised amendment request do not represent a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed License Amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Evaluation This proposed change will add LCO action statements and associated SRs for the CNS emergency diesel fuel oil system to conform to the BWR/4 STS and assist in ensuring the diesel fuel oil is of sufficient
, quality for maintaining diesel generator operability. This proposed change will not involve any plant design change, affect any plant design criteria, or change the operation or the function of the diesel fuel oil system as described in the USAR. This proposed change also does not allow any new mode of plant operation. This proposed revision will not change the operation or function of the Diesel Generators or any accident analyses that involve the diesel generators as described in the USAR. This proposed change is adding new and more restrictive testing requirements for the quality of diesel fuel oil, thus ensuring that the diesel fuel oil used for Diesel Generator operation is free from excessive levels of particulate concentration, or n-icrobiological fouling. Therefore, -
the proposed Technical Specification revision does not create the possibility of a new or different kind of accident. )
- 3. Does the proposed change create a significant reduction in the margin of safety?
Evaluatio.n l l
This proposed change does not change existing facility equipment or represent any new mode of plant operation. This proposed change incorporates additional limiting conditions for operation, surveillance requirements, and reformats the existing surveillance requirements of the diesel fuel oil system, making them more-stringent than previously required. The additional limiting conditions of operation, surveillance requirements, and reformat style is consistent with the existing BWR/4 STS requirements, and use NRC endorsed criteria and standards for _ nuclear facility diesel fuel l
. i NSD930537 Attachment 1 Page 6 of 6 j i
i oil systems. Additionally, this proposed change will not reduce the capability of the Diesel Generators or their support systems to perform their intended function, therefore maintaining the margin of I safety. :
All safety functions and safety analyses concerning the diesel generators are not altered in any way. The proposed change does not ;
allow any new change to plant operating parameters, nor does it affect any plant setpoints. Therefore, the proposed change does not result in a significant reduction in the margin of safety. -
IV. ADDITIONAL BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION The Commission has provided guidance concerning the application of standards ,
for determining whether a significant hazards consideration exists by providing certain examples (51FR7744). The examples include: (ii)Achange that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications, e.g. a more stringent '
surveillance requirement. The additional surveillance requirements for testing particulate concentration level, and checking for the presence of .
water in the diesel fuel oil are within the scope of this example.
V. CONCLUSION The District has evaluated the proposed changes described above against the, ;
criteria of 10CFR50.92(c) in accordance with the requirements of 10CFR50.91(a)(1). This evaluation has determined that the revision to Proposed Change No. 84 to the CNS Technical Specifications will nal.;.1)- ,
involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility for a new or different kind of accident from any accident. previously evaluated; or 3) create a significant reduction in the margin of safety. Therefore, the ,
District requests NRC approval of this revision to proposed change No. 84 to the CNS Technical Specifications. ,
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APPENDIX "A"
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