ML20046C388
| ML20046C388 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/16/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20046C387 | List: |
| References | |
| NUDOCS 9308100239 | |
| Download: ML20046C388 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0. 165 TO FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By letter dated September 2,1992, as supplemented by letter dated June 23, 1993, the Nebraska Public Power District (NPPD, or the licensee) submitted a request for changes to the Cooper Nuclear Station (CNS) Technical Specifications (TS). The requested changes modify the TS to (1) increase the minimum total amount of diesel fuel oil required to be available in the two on-site diesel fuel oil storage tanks from 45,000 to 48,000 gallons, (2) update the standard to which the fuel oil quality is tested from ASTM-D975-1968 to ASTM-D975-1989a, and (3) add additional testing requirements for particulates and water in the fuel. Specifically, the amendment makes the following changes in the TS:
Limiting Condition for Operation (LCO) 3.9.A.I.b is modified to change the minimum quantity of diesel fuel in the fuel oil storage tanks from 45,000 gallons to 48,000 gallons.
Old Surveillance Requirement (SR) 4.9.A.2.d, which requires the quantity of available diesel fuel oil to be logged once a month, has been renumbered SR 4.9.A.2.c, but is otherwise unchanged (old SR 4.9.A.2.c was deleted by a previous amendment).
New SR 4.9.A.2.d requires monthly testing of the diesel fuel oil for particulates per ASTM-D2276-1991, Method A, and specifies a limiting particulate concentration of 10 mg/ liter.
Old SR 4.9. A.2.e, which required testing of the fuel oil per ASTH-D975-68, has been deleted. New SR 4.9.A.2.e requires that prior to adding new diesel fuel oil to the storage tar.ks, the oil must be sampled and tested and shown to meet the requirements of ASTM-0975-1989a for specific gravity, kinematic viscosity, flash point, and appearance. New SR 4.9.A.2.e further requires that within 30 days of obtaining the sample, the licensee must verify that the other fuel oil properties specified in Table 1 of ASTM-D975-1989a are met.
9308100239 930716 PDR ADDCK 0500029G P
. _ _ Old SR 4.9.A.2.f has been renumbered SR 4.9.A.2.h.
New SR 4.9.A.2.f requires monthly checking for the presence of water in the diesel fuel oil day tanks, and the removal of any water found.
New SR 4.9.A.2.g requires monthly checking for the presence of water in the diesel fuel oil storage tanks, and the removal of any water found.
New SR 4.9. A.2.h, defines the Diesel Generator 18 month inspection. This SR was previously numbered SR 4.9.A.2.f, but is otherwise unchanged.
New LC0 3.9.B.1.b.4 is associated with SR 4.9.A.2.d, the new SR requiring testing the particulate concentration in the oil.
This LCO allows 7 days to restore the diesel fuel oil to acceptable limits if particulate concentration levels tested per the SR are found to be outside the specified limit of 10 mg/ liter.
New LC0 3.9.B.I.b.5 is associated with SR 4.9.A.2.e.2, the expanded SR for sampling and testing new diesel fuel oil. This LCO allows 30 days to restore the diesel fuel oil in the storage tanks to acceptable limits when the parameters tested per SR 4.9.A.2.e.2, are found to be outside the specified limits of ASTM-D975-1989a.
New information is added to the 3.9 Bases section, discussing the new LCOs 3.9.B.I.b.4 and 3.9.B.1.b.5.
These discussions follow the BWR/4 STS concerning the allowable LC0 duration and why it is acceptable. Also, new information is added to the 4.9 Bases section. This information discusses the SRs added to section 4.9.
These discussions also follow the BWR/4 STS and staff recommendations concerning the SR frequency intervals and why they are acceptable.
2.0 BACKGROUND
NRC Information Notice (IN) 86-70, " Potential Failure of All Emergency Diesel Generators," described design deficiencies that could disable both diesel generators at a nuclear power plant by placing unanalyzed loads on the diesel generator power buses. NRC Information Notice 89-50, " Inadequate Emergency Diesel Generator Fuel Supply," described discrepancies at several nuclear power plants where the plant technical specifications and/or the Final Safety Analysis Report (FSAR) did not correctly determine the amount of on-site fuel required to allow 7-day post-accident operation of the emergency diesel generators (EDG).
In its September 2, 1992, request for TS changes, the licensee stated that in response to these Information Notices, the licensee evaluated the CNS EDG loads to determine if the EDGs had any of the problems identified in the Information Notices. The licensee calculated the EDG fuel oil storage requirements in an EDG loads evaluation, based on the guidance contained in Regulatory Guide 1.137, " Fuel Oil Systems for Standby Diesel Generators," as recommended by Information Notice 89-50. The licensee used a calcuhtional method based on time-dependant EDG loads, including the capacity to power the engineered safety features.
The licensee stated that its EDG loads evaluation concluded that the 45,000 gallon on-site fuel oil storage requirements currently listed in TS 3.9.A.I.b is adequate to supply an EDG with enough fuel to power its essential loads for a 7-day post-accident event, taking into account all the guidance given in Information Notices 86-70 and 89-50. However, the licensee stated that it desires to raise this storage requirement, to provide an expanded reserve margin of available diesel fuel oil, and also to allow for any future loading additions that could be powered by the diesel generator during loss of coolant accident (LOCA)/ loss of offsite power (LOOP) events.
In addition, the licensee has requested that the TS be modified to update the ASTM standard to which the oil is required to be tested. The licensee states that it has found that testing of fuel oil quality to the edition of the standard previously referenced in TS 4.9.A.2.e, ASTM D975-1968, has become increasingly difficult because diesel fuel oil testing facilities have upgraded to the newer version of the standard. Therefore, the licensee requested that the TS be revised to require testing the fuel oil quality to ASTM D975-1989a, the newer edition of the previously required standard.
The NRC staff reviewed the licensee's submittal of September 2,1992, and based on its review, the staff requested that the licensee consider adding requirements to test for particulates and water. The licensee's submittal of June 23, 1993, added these changes to the proposed TS revision.
3.0 EVALUATION The NRC staff has reviewed the licensee's proposed TS changes contained in its letters of September 2, 1992, and June 23, 1993, and finds them to be acceptable. The staff's evaluation of each of the specific changes proposed by the licensee is given below.
With regard to the increase in the required amount of the diesel fuel oil storage from 45,000 to 48,000 gallons, the licensee states that the increase in the on-site diesel fuel oil storage requirements will continue to ensure that sufficient fuel is stored on-site for seven days of operation of one EDG unit under postulated accident conditions. Operation of the EDGs and their auto-start signals are not altered by the increased fuel oil storage requirement. The licensee states that the ability of the EDGs to meet their Safety Design Basis defined in the Updated Safety Analysis Report (USAR) is not affected by the change. The licensee's analysis has shown that the previous storage capacity is sufficient to power the time-dependant EDG loads, including the capacity to power the engineered safety features. The diesels will remain able to perform their accident mitigative actions as described in the USAR, so that the consequences of previously evaluated accidents remain bounding.
Based on the licensee's determination that a 45,000 gallon requirement is adequate, and that a 48,000 gallon requirement will provide i
additional reserve margin, the NRC staff finds the change acceptable.
With regard to the revision of the ASTM standard used for the testing of diesel fuel oil quality to a naver edition of the same standard, the NRC staff finds this acceptable because the updated standard is an improved version of l
r the previous standard, and contains acceptable criteria for assuring fuel oil quality.
With regara to adding requirements for testing the fuel oil for water and particulates, the staff finds that the licensee's proposals are in agreement with the BWR/4 Standard Technical Specifications, and are, therefore, acceptable.
The licensee also proposed to modify the TS Bases to give the basis for each of the proposed changes to the TS, which the staff has reviewed and found acceptable.
In summary, the proposed TS changes increase the quantity of diesel fuel oil required, update the standard for testing the diesel fuel oil, and add testing requirements for water and particulates in conformance to the STS. The NRC staff finds these changes to be acceptable on the bases given above.
4.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comment.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative
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occupational radiation exposure. The Commission has previously issued a pro-posed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (57 FR 61113).
Accordingly, the amendment meets the eligibility criteria for categorical l
exclusion set forth in 10 CFR Section 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental cssessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Comission has concluded, based on the cunsiderations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
E. Tomlinson H. Rood Date: July 16, 1993