ML20115G564

Responds to RAI Re Proposed Change to TS 3/4.8.1, Electrical Power Sys - AC Sources & Associated Bases

ML20115G564
Person / Time
Site:	Waterford
Issue date:	07/17/1996
From:	Sellman M ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G567	List: ML20115G564 ML20115G574
References
W3F1-96-0033, W3F1-96-33, NUDOCS 9607190202
Download: ML20115G564 (11)

Text

_ __ _ __ _.

g yggy Ente y Operations, Inc.

""' ** Kibona. LA 700060751 Tel 504 739 0660

, Mike Sellman ggni.owaims

. I' W3F1-96-0033 A4.05 g PR July 17,1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555  ;

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Request For Additional Information Regarding Technical Specification Change Request NPF-38-172 Gentlemen:  ;

By letter dated November 7,1995, Waterford 3 proposed a change to Technical Specification (TS) 3/4.8.1 " Electrical Power Systems - AC Sources" and the 3 associated TS BASES. The NRC review staff requested additional,'nformation regarding the proposed changes to TS 4.8.1.1.2a.4, TS 4.8.1.1.2c, TS 4.8.1.1.2di, i and TS 4.8.1.1.2d 2. This information is included in the attached report entitled l

" Additional Inforrr.ation Regarding Technical Specification Change Request NPF-38-172" This additional information has no affect on the previously provided no significant hazards determination. However, the attached report also proposes to increase the pore size of the filters (from .8 to 3.0 microns) which are used during the performance of the testing which determines the level of Emergency Diesel Generator (EDG) fuel oil particulate contamination. A significant hazards determination for this change is provided in the attached report.

/kLTl' 9607190202 960717 *-

DR ADOCK0500g2 10007G

Request For Additional Information Regarding Technical Specification Change Request NPF-38-172 W3F1-96-0033 Page 2 July 17,1996 Should you have any questions or comments concerning the additional information, please contact Robert Kullmann at (504) 739-6404.

Very truly yours, M m

k.L<fdL '

M.B. Sellman Vice President, Operations Waterford 3 R

. MBSIRTK/ssf .-

Attachment:

Affidavit Additional Information Regarding NPF-38-172 cc: L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR R.B. McGehee - y N.S. Reynolds NRC Resident' inspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers I

J

' l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  !

In the matter of ) l

)

Entergy Operations, incorporated ) Docket No. 50-382 )

Waterford 3 Steam Electric Station )

AFFIDAVIT i M.B. Sellman, being duly sworn, hereby deposes and says that he is Vice President, Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Additional Information Regarding Technical Specification Change Request NPF-38-172; that he is familiar with the content thereof; and that the matters set -

forth therein are true and correct to the best of his knowledge, information and

)

belief.

j. A i M.B. Sellman Vice President, Operations Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES ) 1 Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 0"' day of J uc1 .1996.

hl&- S .-

Notary Public My Commission expires W ' "' " ' "

1 I

! ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION CHANGE REQUEST NPF-38-172 ,

L l l

1. Item 4.8.1.1.2a.4 ,

The letter requesting additional information states that this proposed change is not consistent with Standard Technical Specifications (TS) which require a fast start test of the Emergency Diesel Generators (EDGs) once every 184 days. Another concern expressed in this letter was that the proposed change would delete the upper voltage and frequency limits of the diesel generator i fast start test acceptance criteria.

1 With regard to the concerns listed above, the NRC staff asked that Waterford l 3 explain: (a) why the proposed change does not contain a requirement to perform a fast start test of the diesel generators at least once every 184 days and why this requirement should not be included in the proposed change; (b) what, if any, trending of generator performance is used to identify or anticipate problems with the diesel generators; and (c) if closure of the '

generator output breakers is to be used to verify voltage and frequency limits, the frequency of calibration for the relays which provide diesel generator output breaker permissives and the calibration tolerances permitted in calibrating these relays. )

Response

(a) Upon further review, Waterford 3 has determined that a fast start test should be performed every 184 days and has modified the proposed amendment to require this testing. Waterford 3's )

original intent was to eliminate the 184 day fast loading  ;

requirement and had interpreted Generic Letter (GL) 93-05 as  ;

allowing both the 184 day fast start requirement and the 184 day fast loading requirement as not being necessary. This interpretation was anived at by comparing the current wording in TS 4.8.1.1.2a.5 and the wording in GL 93-05.

i (b and c) The NRC staff also expressed a concern with what was l perceived by the NRC staff as the elimination of the upper

acceptance limit for the generator output voltage and frequency l during fast start testing in accordance with TS 4.8.1.1.2a.4.

The proposed amendment states that "the generator voltage  :

and frequency shall be at least 3920 volts and 58.8 Hz within 10 seconds after the start signal" The upper voltage and frequency limits were eliminated from this statement. However, 1

this TS has also been revised to require the steady state voltage and frequency to be within the same limits currently in

,. e, this TS. This change was requested solely to clarify when the 10 second start time is satisfied. The values listed in the proposed amendment were conservatively chosen. The EDG l output breaker permissives are satisfied at lower values than l the values listed in the proposed amendment and on detection of a loss of offsite power, the EDG output breakers would close reenergizing the respective safety bus. Waterford 3 does not .

intend to use the closure of the output breakers to verify voltage I and frequency limits. The steaoy state upper limits for voltage and frequency have not been changed and will continue to be I

monitored. Therefore, the original intent of TS 4.8.1.1.2a.4 has not been changed by the proposed amer &ent and additional trending of EDG performance as a result of the proposed amendment is not warranted.

2. Item 4.8.1.1.2c The proposed amendment modified TS 4.8.1.1.2c to state " Maintain properties of new and stored fuel oil in accordance with the Fuel Oil Testing Program" and deletes all previous information and requirements in this section with the exception of the last sentence in subsection three as modified.

With regard to the information listed above, the NRC staff requested that '

Waterford 3 explain: (a) why the standard words " Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within

)

the limits of, the Fuel Oil Testing Program" were not used; (b) why a j requirement to test in accordance with the Fuel Oil Testing Program was not incorporated into the proposed change; and (c) why no completion times 1 were proposed to restore fuel oil total particulates to within limits (i.e., 7 days) 1 or other fuel oil properties to within limits (i.e., 30 days) similar to those contained in Standard Technical Specifications.

Response

(a and b) Waterford 3 believes that the wording in the proposed amendment meets the intent of the wording specified by the NRC staff. However, the proposed amendment has been modified to incorporate the recommended wording. The recommended wording specifically specifies testing in j accordance with the Fuel Oil Testing Program.

i 2

1 (c) TS 4.8.1.1.2c currently does not contain the completion times specified in the Standard Technical Specifications. However,

,. e the proposed amendment has been modified to incorporate three new Action Statements. The first new Action Statement requires that new fuel oil properties found not to be within limits to be restored within limits within 30 days. The secord new i Action Statement requires that stored fuel oil total particulates  !

that are not within limits to be restored within limits within 7 days. The third new Action Statement requires the affected l diesel generators to be immediately declared inoperable if either or both of the completion times of the other two Action Statements cannot be met. In addition, Administrative Controls section 6.8.4.h has been modified to also specify the required completion times listed above. Also, the last sentence of TS 4.8.1.1.2c.3 which states " Failure to meet this requirement shall i not affect diesel generator OPERABILITY; however, corrective action shall be initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to return the fuel oil i supply to within acceptable limits." has been deleted from the '

proposed amendment. These changes are consistent with the I Standard Technical Specifications. The current TS 4.8.1.1.2c requires a sample of fuel oil to be obtained and tested at least once per 92 days. The provisions of section 4 of the TS allows a i 25% deviation from the 92 day requirement. This allowance will also be applied to the once every 31 day testing j requirement for total particulate concentration specified in the proposed amendment.

3. Items 4.8.1.1.2d.1 and 4.8.1.1.2d.2 Technical Specification 4.8.1.1.2d.1 currently states in part "At least once per 18 months during shutdown by verifying the generator capability to reject a load of greater than or equal to 498 kw (HPSI pump).. " The proposed change would delete the reference to the HPSI pump. In addition, the proposed amendment would add "an indicated 4000" to the 18 month full load rejection test criteria in TS 4.8.1.1.2d.2.

The NRC staff expressed a concern that the proposed changes are not I consistent with Standard Technical Specification testing requirements which I

specify a power facter at which the load rejection tests should be performed.

With regard to the information listed above, the NRC staff requested that Waterford 3 provide: (a) a description of how these two load rejection tests will be performed in the future if the requested TS change is granted; (b) the amount of reactive load that will be rejected in order to verify proper 3

r l

operation of the voltage regulator and the bases for the amount chosen; and l

(c) a comparison of these future tests to tests performed in the past so that I

. any changes in the proposed testing method can be readily identified.

Response (a. b. c) '

i The intent of TS 4.8.1.1.2d.1 is to require the EDG to reject the largest single load while maintain:ng specific voltage and frequency constraints. In the past, Waterford 3 satisfied this TS by requiring the EDGs to successfully reject a HPSI pump while maintaining the specified voltage and frequency constraints. During a subsequent review of this TS, Waterford 3 personnel 3 determined that a HPSI pump only represents a load of 415 kw and that this load did not satisfy the requirements of this TS. Licensee Event Report (LER) 94-017-00 addresses this issue and was submitted to the NRC on December 21,1994. As a result, Waterford 3 personnel developed an alternate method of rejecting a load greater than or equal 498 kw. The alternate method of rejecting a load greater than or equal to 498 kw utilizes I an appropriate number of Dry and Wet Cooling Tower Fans. The proposed  !

change would correct this TS by eliminating the reference to the HPSI pump and modify the BASES to clarify the 498 kw load rejection requirement. No '

changes to the actual load rejection requirement or the specified voltage and frequency constraints during the load rejection testing currently in the existing TS are being requested. In addition, the amount of reactive power required by the Dry and Wet Cooling Tower Fans is greater than the reactive power required by a HPSI pump during the performance of the load rejection ,

test specified by TS 4.8.1.1.2d.1. Therefore, the alternste test methodology 1 is more conservative than the previously performed test methodology. j Technical Specification (TS) 4.8.1.1.2d.2 currently requires the verification of the EDGs capability to reject a load of 4400 kw without tripping. This TS d does not currently specify an amount of reactive power to be rejected by the EDGs during the full load rejection test. The proposed change provides for a range (4000 kw to 4400 kw) to conduct this test. This revised loading range is intended to avoid inadvertent overloading of the EDGs. This inadvertent overloading creates unnecessary wear and mechanical stress that adversely affects the reliability and longevity of the diesel generators. Waterford 3 does not intend to change the test methodology for performing the full load rejection test. The current test methodology was developed in response to information Notice 91-13 " Inadequate Testing of Emergency Diesel Generators". Waterford 3 currently loads the EDGs with as much reactive power as is practical without exceeding the EDGs design specifications l during the performance of the full load rejection testing. The only change will be that a range for the real load rejected by the EDGs will be provided to i

i 4

l

improve the EDGs reliability by reducing unnecessary wear and mechanical stress. Providing a range for the real load rejected is in accordance with the

,. S.tandard Technical Specifications.

4. KW Load of a HPSI Pumo and a Essential Chiller

in reviewing the proposed amendment the NRC staff identified an apparent discrepancy in the kw load used to represent a HPSI pump and an Essential Chiller. Table 8.3.1, " Emergency Diesel Generator A Loading Sequence (Steady State)," of the Waterford 3 Final Safety Analysis Report (FSAR) lists the real load of a HPSI pump as 371.5 kw and that of an Essential Chiller as ,

416.37 kw. Page seven of the proposed amendment states these loads are 415 kw and 430 kw respectively.

The NRC staff requested that Waterford 3 explain the reason for the apparent discrepancy.

Response +'

)

The kw values listed in the proposed amendment (415 kw for the HPSI pump and 430 kw for the Essential Chiller) represent maximum values for these two ;1

]

loads. :These maximum load values would be obtained when the HPSI pump l and the Essential Chiller are supplying maximum output. This is not to be 4 confused with the maximum load the HPSI pump and the Essential Chiller >

would represent when supplying output for the specific events listed in FSAR Table 8.3.1 (i.e.,371.5 kw for the HPSI pump and 416.37 for the Essential Chiller operating after a Loss of Offsite Power concurrent with a Loss of Coolant Accident). 1 1

5. Particulate Test Filter Pore Size Increase  !

Testing for particulates in EDG fuel oil will be performed as specified in i Administrative Controls section 6.8.4.h.3. This testing utilizes the process described in ASTM D2276-78, " Standard Test Methods for Particulate Contamination in Aviation Turbine Fuels". The basis of this surveillance process is that when a known amount of fuel oil is passed through a filter of known weight, particulates larger than the filter pore size will not pass l through the filter. The filter is then dried and reweighed to determine the mass of the trapped particulates. The mass of particulates per unit volume of fuel oil is verified to be within the acceptance criteria of 10mg/ liter. This proposed change does not involve a change to this 10mg/ liter limit, it only will ,

change the filter pore size.

1 5

9 Particulate testing as described above does not actually reduce the level of particulate contamination present in the fuel oil because only a small amount

' of the fuel oil is passed through the test filter. The test does, however, provide an indication of fuel oil quality by providing information on the quantity of particulates present in the fuel oil which are larger than the test -

filter pore size.

The current filter pore size specified in ASTM D2276-78 is 0.8 microns. The proposed change would increase the filter pore size used during the testing from 0.8 microns to 3.0 microns. This proposed change would prevent the entrapment of particulates in the size range of 0.8 to 3.0 microns during the testing. Entrapment of particulates in this size range is unnecessary as the in-_line filters,' which are the final step in the fuel oil filtration process prior to the fuel oil entering the EDGs, currently only trap particulates above 15 microns in diameter. Waterford 3 will be replacing these in-line filters with filters that have pore size of 5 microns in the future per a recommendation

- from the vendor.

The proposed change has been previously reviewed and approved by the NRC for Peach Bottom Atomic Power Station Units 2 and 3 and the Limerick Generating Station Unit 1.

Safety Analysis The proposed increase of the filier pore size used during particulate testing of the EDG fuel oil from 0.8 microns to 3.0 microns will not adversely affect EDG

. operability. The use of a filter with a 3.0 micron pore size in lieu of a filter with a 0.8 micron pore size is acceptable since it more closely approximates the fuel oil filtration accomplished by the in-line filters during EDG operation. This increase in filter pore size will not result in harm to the fuel injectors or otherwise degrade diesel engine performance. Therefore, while a population of particulates between 0.8 and 3.0 microns would not be detected in the fuel oil as a consequence of using a larger

, test filter pore size, this is not of consequence because these particulates will pass into the diesel engine fuel injection system and subsequently into the diesel engine without any adverse consequences.

The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No ,

6

4 1 The proposed change will not result in an increase in the quantity of 4

particulates larger than 3.0 microns. The possible consequences of Implementing the proposed change could be an increase in the concentration of particulates in the 0.8 to 3.0 micron size range. Although particulates

smaller than 3.0 microns will pass through the in-line fuel filtering system, i there will be no adverse consequences on the operability of the EDGs.

Accordingly, this change will not result in any increase in the probability of l any accident previously evaluated in Chapter 15, " Accident Analyses" of the Waterford 3 Final Safety Analysis Report. Therefore, the proposed increase in the test filter pore size does not involve a significant increase in the j probability or consequences of an accident previously evaluated.

I

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different type of accident from any accident previously evaluated. 'l I

l Response: No The proposed change is limited to the test filter pore size for determining the level of particulate contamination of the EDG fuel oil. This change will not affect the operability of the EDGs. The presence of particulates below the

size of 3.0 microns are of no consequence in the operation of the EDGs.

l Since the proposed change only affects the concentration of particulates in

! the 0.8 to 3.0 micron size range, the proposed increase in the test filter pore size does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change does not result in an increased concentration of particulates larger than 3.0 microns. The only particulate sizes which can be j affected by this proposed change are those smaller than 3.0 microns. These size particulates will pass through the in-line filters but will not affect EDG operability; therefore, there is no significant reduction in a margin of safety.

7

Safety and Sionificant Hazards Determination Based.on the above safety analysis, it is concluded that: (1) the proposed change d6es not constitute a significant hazards consideration as defined by 10CFR50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC final environmental statement.

1 i

8