ML20090G333
| ML20090G333 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/06/1992 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F191-0456, W3F191-456, NUDOCS 9203120191 | |
| Download: ML20090G333 (4) | |
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Docket No. 50-382 License No. NPi~38 Technical Specification Change llequest NPF-38-111, llequest of Additional Information Gentlemen:
On May 8,1991, Entergy Operations, incorporated submitted W3F1-01-0051 to request several changes to Waterford 3 Technical Speelfications 3/ l.8.1, A.C.
Sources - Operating, and 3/4.8.2, A.C. Sonrees - Shutdown. In recent conversations with We NRC staff, some issues geramne to this change request have been disetu v. This letter serves as documentation of the resolution of these issues.
In one conversation, Entergy Operations, inc learned that although the status of the guidance used from the draft version of Regulatory Guide 1.9 to support the change to Table 4.S-1, Diesel Generator Test Schedule, was i nnfirmed to be final, the staff was not prepared to accept it as justification for this change request until issuance of the guide. Rather than delay the approval of the entire change request until tha, issue is resolved, Entergy Operations, Inc. hereby withdraws the requested changes in the submittal specifically related to that reg guide (i.e., the changes made to Table 4.8-1). This frees the staff to approve the remainder of the submittal regardless of the Reg Guide's status.
Also requested in this submittal is a reduction in the minimum volume required for the diasci generator fuel oil storage tanks. In a phone conversation on August 1, 1991, between Entergy Operations, Inc. and the NRC, ca'culations supporting this request were dicussed. A;tachment A summarizes this discussion. As a result of several recent discussions with the NRC on this issue, Entergy Operations, Inc. is changing the request to reduce the current technical specification volume from 38,700 gallons to 38,000 rather than the 3-1,000 gallons previously submitted. This establishes a conservative minimum volume while allowing suitable margin for operational flexibility.
9203120191 920306
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.e Technical Specification Change Request NPF-38-114,
. Request for Additional Information-
. 3F191-0450 W
Page 2
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March 6, 1992 Questions or comments on any of this information should be directed to T.J. Gaudet at (504) 739-6660.
Very truly yours,
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Attachment NPF-38-114:- Request for Additional lu ormation ec:
R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident inspectors Office Administrato-Radiation Protection Division (State of Louisiana)
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.ttachment-A to 13F191-015G Page 1 of 2 N'P F l l.1 : ltequest for Additional Information in NPF-38-111, several changes to Waterford 3 Technical Specifications (TSs) 3.8.1;1b and 3.8.1.2b, A.C. Sources - Operating and - Shutdown are requested. One of these requested a reduction in the minimum required volume in
- the diesel generator fuel oli storage tanks. These tanks are part of tho Diesel Generator Fuel Oil Storage and 'I runsfer System. This system is desiqued to: (!)
provide oil storage caintelty in each tank for seven days operation of one diesel generator to meet the engineered safety feature load requirements following a loss of offsite power coincident with a des.,.c.. basis accident, and (2) maintain fwl to ai least one diesel engine assuming a single activo or passive failure. The decrease in the minimum required volume represents a reduction in fuel oil supply from a seven day reserve to five (based c*t two different methods of calculation.)
This is requested to accommodate diesel generator testing.
The Diesel Generator Fuel Oil Storage and Transfer System provides gross storage of diesel fuel oil and the means to supply the oil to the two EDGs. Fuel oil storagt for each diesel engine is separate and independent from one another.
Two completely redundant trains are provided, each consistuig of a storage tank, transfer pump and feed tank. Train "A" normally serves EDG "A" and train "15" normally serves EDG "11." The capacity of each storage tank is sufficient for seven days operation of one EDG. Interconnective piping with two normally closed valves is provided between the two storage tanks to enable either EDG to be supplied from either tank should one of the transfer pumps fail. Thus a fourteen day total fuel inventory can be svallable onsite to operate e single EDG, Waterford 3 calculation, EC-E90-000 hG, documents the design basis fuel
- consumption of the EDGs. It ludicates that the TS required fuel volume, 38,700 gallons, is sufficient to operate the emergency diesel generator (EDG) for seven days. This is based on a time dependent load scheme assuming only one EDC. Is operating and only one storage tank available for fuel. (This satisfies the requirements established in ANSI Standard N195, Fuel Oil Systems for Standby Diesel Generators. ) Although this satisfies the design basis, such a loading scenario would restrict operability. During an emergency, operators probably would not restrict EDG loads to c..ly those required by the design basis. To allow i
operators the flexibilitr to pick up additional loads, a more conservative calculation would assume a continuous, full load on the EDG.
Current test procedures require testing the EDGs under full load once a month.
Typleally, run timo for the test is between ono hour fif teen minutes and one hour thirty minutes. Cooper-Bessemer, the diesel generator manufacturer, has issued a technical bulletin that recommends emending this test to four hours. Although beneficial to reliability, a four hour test can consume significantly more fuel.
With the_ tank filled to within the error margin for the high level alarm,_ one foi <
- hour test could potentially reduce the fuel volume to below the low level alarm. if an additional four hour test has to be run before the tank can be refilled, the fuel 1
volume will be reduced to approximately 38,900 gallens, just above the TS limit, Presently, consideration is being given to lowering the high level alarm to prevent overfilling the storage tank. This could eliminate what little inargin remains.
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Attactuaent A to-W3P191-0150 Page 2 of 2-As indicated, a more conservative calculation determines the amount of fuel consumed to run un EDG under a continuous full load. Previous calculations were based on a time dependent-load. Based on the previous (time-varying load) calculations, a value of 3-1,000 gallons was requested for the minimum storage tank volume in TSs 3.8.1.1b and 3.8.1.2b. Itecognizing the limiting nature of a minimum storage tank volumo base-1 on a time dependent load scheme, Entergy Operations, Inc. is changing the request to 38,000 gallons rather than 31,000. A
- five day fullload eniculation indleates that a storage tank volume of approximately 37,690 gallons is required. A TS limit of 38,000 gallonn maintains a five day fuel supply while allowing sufficient margin to support a four hour operability test.
This change does not alter the safety analysis in the original submittal. As discussed in thut submittal, this does not represent a reduction in safety sinco local sujipliers to Waterford 3 enn replenish the fuel oil within twenty-four hours following any limiting design basis event or accident. Several diesel oil suppliers are located in the area. All have more than sufficient quantitles in inventory for Waterford 3 purposes.
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