ML20079J197
| ML20079J197 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/10/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20079J201 | List: |
| References | |
| LCR-91-14, NLR-N91170, NUDOCS 9110150324 | |
| Download: ML20079J197 (10) | |
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1 Pubhc Tervice Electnc and Gas Company Stanley LaDruna Pubi<c Semce Electnc and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 va meson nww cwws DCT i o iggi NLR-N91170 LCR 91-14 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDnENT APPLICATION DIESEL GENERATOR CATHODIC PROTECTION FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby submits a request for amendment of Facility Operating License NPF-57 for the Hope Creek Generating Station in accordance with 10 CFR 50.90.
A copy of this submittal has been sent to the State of New Jersey as indicated below pursuant to the requirements of 10 CFR 50.91(b) (1).
The proposed change would separate the surveillance requirements associated with the buried fuel oil transfer piping's cathodic protection system from those used to determine diesel generator operability.
It has become necessary to plan corrective maintenance for the buried fuel c'1 transfer piping's carthodic protection system; while the syscem is currently operable, literal interpretation of the present specification could potentially result in an unnecessary shutdown of the station if the system were to become inoperable in the future.
Insofar as the planned maintenance will require outside excavation, prudency dictates that it be completed before the ground freezes in December.
Otherwise, the work will be delayed until Spring of 1992.
PSE&G is, therefore, requesting that the NRC expedite the review of this submittal to the extent possible. includes a description, justification and
-significant hazards analysis'for the proposed change.
Attachment 2 contains marked up Technical Specification (TS) pages which reflect-the proposed change.
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' Document Control Desk 2
NLR-U91170 PSE&G believes that this submittal conta.
aufficient technical justification to conclude that a detaileu specialist review should not be required and that the proposed change can be classified as a Category 2 change.
U on NRC approval, please insuo a License Amendment which will be etfective upon issuance and shall be implemented within 60 days I issuance.
Should you have any questions or comments on thic submittal, please do not hesitato to contact us.
Sincerely, l
fMf" Affidavit Attachments (2) b C
Mr.
S.
Dembek Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering e
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Ref:
NLR-N91170 LCR 91-14 STA.TE OF NEW JERSEY
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SS.
COUNTY OF SALEM
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S. LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters not forth on our letter dated 00T 101991
, concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
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A Q hb k hca u --
Subscribed and Sworn to before me this
/6 day of [M f.
1991 NJ422. 0.. /Ini Notary Pplic offNew ' Jersey My Commission expires on 4/J r/#/J~
ELIZABETH J. KIDD Notary Publicof NewJersey My Commission Expires April 25,1995 1
ATTACHMENT'1 REQUEST FOR LICENSE AMENDMENT DIESEL GENERATOR CATIIODIC PROTECTION FACILITY OPERATING LICENSE NPF-57 IIOPE CREEK GENERATING. STATION DOCKET NO. 50-354 T
g
l NIR-N91170 110PE CREEK IIR 91-14 I.
Descri_ption of the Proposed Chances This amendment request proposes the following:
1.
Delete the requirements of Technical Specification Surveillance 4.8.1.1.2.g and insert the word " DELETED" to preclude the re-numbering of the remaining items.
2.
Create a new Technical Specification Surveillance 4.8.1.1.4 containing the requirements that are currently delineated by 4.8.1.1.2.g.
3.
Create a new Action Statement h to specify actions that are to be taken if the requirements of Surveillance 4.8.1.1.4 cannot be met.
II.
Reason for the Propssed Chances Technical Specification (TS) 3.8.1.1.b identifies the components that are required for the diesel generators to be operable; they consist of the fuel oil day tank, fuel oil storage tanks, and fuel oil transfer pumps.
TS 4.8.1.1.2 delineates surveillance requirements that are to be performed to demonstrate operability cf the Diesel Generators.
With the exception of item g, each specified requirement pertains directly to the operability of the individual Diesel Generators; therefore, failure to meet any of these requirements, with the exception of item g, could adversely affect the ability of the respective Diesel Generator to perform its specified function.
Item g of TS 4.8.1.1.2 pertains to the the buried portion of the fuel oil transfer piping's cathodic protection system.
This.
portion of the system is used to transfer fuel oil from the normal truck-fill connection into the station where it is then distributed to each fuel storage tank.
If this connection becomes unavailable, an emergency fill connection inside the Diesel Building can be used.
Insofar as the fuel storage tanks contain sufficient fuel to allow the Diesel Generators to perform their specified funct ion and that level is maintained in these tanks in accordance with TS 3.8.1.1, the requirements of TS 4.8.1.1.2.g do not directly affect operability of the Diesel Generators.
However, since this surveillance ) 'quirement is currently a sub-item of TS 4.8.1.1.2, literal interpretation of TS could preclude scheduled maintenance on the system and/or potentially result in an unnecessary station shutdown due to failure of the cathodic protection' system.
This change is being submitted to preclude such a situation.
PAGE 1 OF 5 ATIAQIMEtTf 1 I
NIR-N91170 HOPE CREEK ICR 91-14 III. Justification for the Proposed Chances The design bases of the Diesel Generator (DG) fuel oil storage and transfer system require sufficient storage of fuel oil for seven days of continuous operation under design load conditions so that standby (onsite) electrical power is availabla during loss of of fsite power (LOP) and/or design basis accident (DBA) events.
The function of storing and supplying this amount of fuel oil is. accomplished by each DG's respective fuel oil day tank, two fuel oil storage tanks, and two fuel oil transfer pumps.
Operability of these components, including minimum allowable storage tank level, is specifically required by TS
- 3. 8.1.1 and verified by TS Surveillances 4. 8.1.1. 2.a.1-3, b, c,
d, f.1-3, h.12, j.1, and j. 2.
Fuel oil is normally added to the DG fuel oil storage tanks through a truck / barge fill connection located outside the diesel building.
The fuel oil is transferred from this connection through a section of underground piping that is common to all four DGs and then into the plant where it splits into a distribution manifold.
The buried portion of the transfer piping is not considered safety-related since an emergency fill connection is provided inside the diesel building, which can be isolated from the buried portion of the fill piping by an isolation valve located inside the diesel building.
This emergency fill connection provides a protected fill path to the DG fuel oil storage tanks, none of which is buried piping.
The buried portions of the fuel oil transfer piping are cathodically protected from long-term corrosion induced degradation by a non-safety related, impressed current-type, cathodic protection system.
Installation and testing of this system is required by Regulatory Guide 1.137 (Revision 1, October 1979).
Surveillance intervals for the buried fuel-oil transfer piping cathodic protection system are currently specified in TS Surveillance 4. 8.1.1. 2.g.
This is an inappropriate location for these requirements because TS Surveillance 4.R.1.1.2 is used to demonstrate DG operability.
Failure of the (:chodic protection system would not direc.tly impact DG operabile-y for the following reasons:
1.
The ability of the DGs to perform their specified functions
'is dependent upon the amount of fuel oil that is present in the storage tanks and the ability to transfer that oil to the DGs via the fuel oil day tanks.
Conversely, DG operability is independent of the ability to add make up fuel oil to the storage tanks.
PEE 2 OF 5 ATIAGEEN1' 1 J
NIR-N91170 HOPE CREEK LCR 91-14 4
2.
Fuel oil that is used during surveillance testing operation of the DGs is normally made up from a truck / barge fill connection.
If the normal connection is unavailable, an emergency connection is provided.
If both of these connections are unavailable, and make-up fuel oil cannot be added to the storage tanks, DG operability would be determined by fuel oil storage tank level as specified by TS 3.8.1.1.
3.
Inoperability of the cathodic protection system would not have any immediata negative impacts on the affected piping.
Instead, the affects would be cumulative over the lifs of the facility.
Therefore, appropriate actions to be taken in the event that the system becomes inoperable for more than 30 days would consist of the preparation and submittal of a special report to the commission outlining the cause of the malfunction and the plans for restoring the system to operable status.
mased on the preceding discussion, the surveillance requirements of TS 4.8.1.1.2 9 pertaining to the buried fuel oil transfer piping cathodic protection system should be separated from those surveillances that are used to demonstrate DG operability.
A new TS surveillance should be added to delineate the testing requirements of Regulatory Guide 1.137 (Revision 1, October 1979) and a new action statement added to specify actions that are to be taken in the event that the system becomes inoperable.
PAQB 3 OF 5 ATIAGMENT 1 l
NIR-N91170 IOPE CRED( LCR 91-14 IV.
Sinnificant Hazards Consideration Evaluation PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to determine whether our request involves a significant hazards consideration.
We have determined that operation of the Hope Creek Generating Station in accordance with the proposed changes:
1.
Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The design bases of the Diesel Generator (DG) fuel oil storage and transfer system require sufficient storage of fuel oil for seven days of continuous operation under design load conditions so that standby (onsito) electrical power is available during loss of offsite power (LOP) and/or design basis accident (DBA) events.
The function of storing and supplying this amount of fuel oil is accomplished by each DG's respective fuel oil day tank, two fuel oil storage tanks, and two fuel oil transfer pumps.
Operability of these components, including minimum allowable storage tank level, is specifically required by TS 3.8.1.1 and verified by TS Surveillances 4.8.1.1.2.a.1-3, b, c, d, f.1-3, h.12, j.1, and j.2.
2.
Will not create the possibility of a new or different kind of accident from any accident previously evaluated.
Neither the buried portion of the diesel fuel oil transfer piping nor the associated cathodic protection system is safety-related.
Therefore, the proposed change does not adversely affect the design or operation of any system or component important to safety.
No physical plant modifications or new operational configurations result from this change.
3.
Will not involve a significant reduction in a margin of safety.
Credit for the capability to transfer fuel to the storage tanks is not taken in any analyzed event.
Additionally, in the unlikely event that it becomes necessary to transfer oil-to the storage tanks during a design basis event and the normal fill line serviced by the affected cathodic protection systeu is not available, the emergency fill connection located in the diesel building can be used.
PAGE 4 OF 5 ATIAONENI' 1
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1 NIR-N91170 110PE CREEK Im 91-14 V.
Conclusion Based on the preceding discussion, PSE&G has concluded that the proposed change to the Technical Specifications does not involve a significant hazards consideration insofar as the change: (1) does not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) does not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) does not involve a significant reduction in a margin of safety.
-PAGE 5 OF 5 A'ITACHMENI' 1
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f NIR-N91170 llOPE CREEK LCR 91-14 ATTACHMENT 2 REQUEST FOR LICENSE AMENDMENT DIESEL GENERATOR CATIIODIC PROTECTION FACILITY OPERATING LICENSE NPF-57 IIOPE CREEK GENERATING STATION DOCKET NO. 50-354 4
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