ML20101M126
| ML20101M126 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/01/1992 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-92-208R, NUDOCS 9207080073 | |
| Download: ML20101M126 (5) | |
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Omaha Public Power District 444 South 16th Street Mall Omaha. Nebraska 68102-2247 July 1, 1992 LIC-92-208R V. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (A. B. Beach) to OPPD (W. G. Gates) dated November 22, 1991 (NRC Inspection Report No. 50-285/91-23)
Gentlemen:
SUBJECT:
Proposed Permanent SMution and Implementation Schedule Addressing Onsite Emergency Diesel Generator (EDG) Fuel Oil Storage Capacity at Fort Calhoun Station (FCS)
In Reference 2, the NRC identified a violation noting that 0maha Public Power District (OPPD) did not consider the effect on the minimum required onsite EDG fuel oil storage capacity when additional electrical loads were placed on the EDGs as a result of a series of modifications followin ' plant start-up in 1973.
In response, OPPD adopted an interim action plan in November 1991 while long-term solutions addressing onsite EDG fuel oil storage capacity were evaluated. After considering the alternatives, OPPD proposes enhancement of the interim action u
plan as the permanent solution.
As noted in Reference 2, OPPD committed to notify the NRL of the plan and implementation schedule by July 1,1992.
Interim Action Plafli In November 1991, FCS implemented an interim action plan which provides for transfer of fuel cil from auxiliary boiler fuel oil storage tank F0-10 to EDG fuel oil storage tank FO-1. The interim action plan revised an emergency plan implementing procedure (EPIP) to modif third auxiliary feedwater pump (FW-54)y the fuel oil transfer piping for the to allow the transfer of fuel oil from storage tank F0-10 to storage tank F0-1 utilizing the fuel oil transfer purro on FW-54.
An Engineering Analysis (EA-FC-92-04/, Rev. 0) on the storage capacity of EDG fuel oil storage tank F0-1 was recently completed, which takes credit for post accident load reductions. EA-FC-92-047 has determined that storage tank f0-1 and the day and base tanks have a fuel oil capacity sufficient for one EDG to continue operating for approximately 4.9 days (EDG Ho. 2) or 5.2 days (EDG No.
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'U. S. Nuclear Regulatory Commission LIC-92-208R Page 2 Using the criteria of IEEE 308, "IEEE Standard Criteria for Class lE Power Systems fur Nuclear Power Generating Systems," as referenced in the FCS Updated Safety Analysis Repart (USAR), EA-FC-92-047 conservatively determined that 24,500 gallons is the minimum inventory of fuel oil required to meet 7 da operation.
For the additional fuel oil necessary for 7 day operation,y EDG OPPD proposes continued reliance on storage tank FO-10 as a source of fuel oil for replenishing storage tank F0-1 in the event of an accident.
The following enhancements to the interim action plan are proposed to provide sufficient fuel oil storage for the EDGs at FCS.
Permanent Solution:
1.
ToLreduce the time required to connect F0-10 to F0-1, additional valves and piping will be added to the FW-54 fuel oil transfer piping system.
The enclosed ~ drawings (provided for your information only) show the proposed system configuration.
2.
Sufficient hose for the FW-54 fuel oil transfer piping system will be dedicated, tagged, and stored in an appropriate area.
Periodically, the hose will be checked via a preventative maintenance task to ensure it is 4
available for use.
3.
As a backup to the FW-54 fuel oil transfer piping system, a portable pump and sufficient hose will be procured and stored in an appropriate area.
Periodically, :he pump and hose will be checked via a preventative maintenance task to ensure they are available for use.
4.
Appro riate procedure revisions will be completed and new procedures will be im lemented as necessary for use of the transfer systems.
5.
The fuel oil classification for storage tank F0-10 will be upgraded to
" Limited Critical Quality Element (CQE)," with the same quality assurance requirements and inspections currently in effect for fuel oil in storage l
tank F0-1.
Administrative controls for F0-10 fuel oil inventory will be l
revised to clarify minimum reserve requirements.
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6.
System walkdowns and training for appropriate personnel will be performed periodically.
i 7.
Technical Specification and USAR revisions will be submitted to clarify the crediting of storage tank FO-10 as part of the onsite EDG fuel oil storage capacity.
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'U. S. Nuclear Regulatory Commission LIC-92-208R Page 3 Justification:
OPPD's Design Engineering Nuclear Department has reviewed the casign documents for storage tanks F0-1 and F0-10. This review has determined that the two tanks are identical, with the only identified differences being the nameplate and current CQE classification.
The capacity, fcundation, construction materials, construction code, and initial pressurized leak testing are identical for both tanks.
Based on the acceptance of storage tank F0-1 in the original licensing basis for FCS, storage tank F0-10 can be relied on as a source of fuel oil for replenishing storage tank FO-1 in the event of an accident.
Although the transfer pump for FW-54 is a non-CQE component, power can be supplied to the transfer pump from either of the two EDGs or from the generator connected to the diesel driver for FW-54. The transfer piping is non-CQE but is qualified to ANSI B31.1-1986 standards. The level indicator (non-CQE) for FC-10 is located in the Service Building.
The vendor and model number of the level indicators are the same for both F0-1 and F0-10, and they have similar maintenance requirements.
The auxiliary boiler is designed to heat plant work areas and support water treatment plant operation when the plant is shutdown. The 24,500 gallons of fuel oil necessary for 7 day EDG operation is comprised of the Technical Specification minimum of 16,000 gallons of fuel oil in F0-1, less 240 gallons that cannot be utilized from FO-1, plus 1700 gallons of fuel oil in the day / base tanks, plus an additional 7300 gallons from F0-10, less 240 gallons that cannot be utilized from FO-10. Although only 7,300 gallons of fuel oil is required, 8,000 gallons will
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be reserved in auxiliary boiler fuel oil storage tank F9-10 for potential transfer to EDG fuel cil storage tank F0-1.
i Upon reaching the 16,000 gallon level in F0-10, additional fuel oil would be ordered from offsite sources as currently directed by FCS administrative procedures.
At this point, the auxiliary boiler would be able to operate for approximately 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br /> without encroaching on the 8,000 gallons of fuel oil reserved for potential transfer to storage tank F0-1.
Fuel oil is normally available within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from offsite sources, and the Technical Support Center, which would be activated in the event of an emergency, has procedures directing replenishment of the fuel oil supply.
In summary, it is OPPD's position that this solution is justified on a permanent basis for the following reasons:
1.
Storage tank F0-10 is identical to storage tank F0-1.
2.
Re-configuring the FW-54 fuel oil transfer piping system will substantially reduce preparations necessary to initiate fuel oil transfer from F0-10 to F0-1.
Also, preparations to initiate fuel oil transfer from FO-10 to F0-1 would only be necessary if offsite supplies could not be obtained within approximately 5 days, which is considered improbable based on the availability of fuel oil in the immediate area.
3.
In the unlikely event that the FW-54 fuel oil transfer system becomes ino]erable, i t will be backed up by a portable pump to provide fuel oil transfer capability.
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'U. S. Nuclear Regulatory Commission LIC-92-208R Page 4 4.
All equipment necessary to implement the fuel oil transfer will be procured, periodically checked and stored onsite.
5.
Appropriate administrative controls will be taken to govern use of the transfer system in the event of a loss of offsite power. These controls will include procedure revisions clearly specifying the order point for replenishing F0-10/F0-1 as well as clarification of the amount of fuel oil that must be reserved in F0-10 for potential transfer to storage tank F0-1.
Other administrative measures include training, changing the designation of fuel oil contained in F0-10 to " Limited CQE" (same as fuel oil in FO-1), and appropriate FCS Technical Specification and USAR revisions.
In conclusion, this proposed solution meets the 7 day criteria for onsite storage contained in IEEE 308 as referenced in the FCS USAR. With the exception of the USAR update, which will be submitted with the next annual revision (after NRC concurrence), OPPD will complete implementation of the permanent solution described above within 16 weeks of NRC acceptance of this proposal.
In the meantime, OPPD will continue to implement the interim action plan as presented to the NRC in November 1991.
If you should have any questions, please contact me.
Sincerely, AV.h.55 W. G. Gates Division Manager Nuclear Operations WGG/sel Enclosures
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LeBoeuf, Lamb, Leiby & MacRae (w/o Enclosurcs) l J. L. Milhoan, NRC Regional Administrator, Region IV (w/o Enclosures) l R. P. Mullikin, NRC Senior Resident Inspector (w/o Enclosures)
S. D. Bloom, NRC Acting Project Manager
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