ML20116N485
| ML20116N485 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/19/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92153, NUDOCS 9211240029 | |
| Download: ML20116N485 (9) | |
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e Public Service Electric and Gas Company Sitniey LaBruna Pubhc Service Electnc and Gas Company P.O. Box 236. Hancocks Bridgu, NJ 08038 609-339-1200 v+enev>m-%ca owam NOV 191992 NLh-N92153
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United Stater Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
)
EMERGENCY DIESEL GENERATOn FUEL OIL STORAGE TANKS AND DAY TANKS b
HOPE CREEK GENFRATING STATION DOCKET NO. 50-334 Public Service Electric and Gas (PSE&G) is revising our response to Notice of Deviations 50-354/92-80-05 and 50-354/92-80-06, involving the emergency diesel generator fuel oil storage tank capacity and fuel oil transfer pump start level, transmitted as Appendix A of the " Electrical Distribution System Functional Inspection of Hope Creek Generating Station," (Inspection Report No. 50-354/92-80).
As discussed with Mr. J. Stone of NRR and Mr.
L.
Cheung of Region I, PSE&G has further. evaluated our response to the above deviations and believes that revising our commitments as described in the following attachment will provide a greatur margin of safety than complying with our initial response transmitted in our letter dated July 10, 1992 (NLR-N92094).
In order to revise our response to these deviations, PSE&G is requesting relief from the requirements of Standard Review Plan Section 9.5.4 paragraph I.1.d and Pegulatory Guide 1.137 Revision 1 (ANSI N195-1975 Sectica 6.1) as committed to in the Hope Creek ?Ipdated Final Safety Analysis Report.
PS3&G has completed a no significant hazards consideration evaluation in accordance with 10 CFR 50.92 for these commitment changes.
If you have any questions regarding this submittal, please contact us.
Sin erely, h30133
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Attachment (1) t 9211240029 921119
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{DR ADOCK 05000354 Ik j
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- NOV191992 l
-Vocument Control Desk 2
NLR-N92153 i
C Mr. T. T. Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission j
475 Allendale Road j
King-of Prussia, PA 19406 1
4 Ms. A.
Keller U.
S.
Nuclear Regulatory Commission-MS~14~E-21 i-Washington, DC 20555 Mr. T. P. Johnson (SOS)
USNRC Senior Resident Inspecto" i.
l Mr. W.
Ruland l
Region I l
U.
S.
Nuclear' Regulatory Commission i
475 Allendale Rd.
King of Prussia, PA 19406 Mr.
K. Tosch, Chief i
NJ Depart ent-of Environmental Protection
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Divisior, of Environmental-Quality Bureau of Nuclear Engineering j
CN 415 l
Trenton, NJ 08625 I
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ATTACHMENT NLR-N92153 Hope Creek Generating Station Docket No. 50-354 On May 28, 1993, the NRC issued Inspection Report No.
50-354/92-80, " Electrical Distribution System Punctional Inspection of Hope Creek Generating Station."
Appendix A of this report transmitted, in part, the following Notice of Deviations as stated below:
Dev+gt. ion 1
" Hope Creek UFSAR, paragraphs 9.5.4.2 and 1.8.1.137 indicate that the Emergency Diesel Generator (EDG) fuel oil storage system is sized in accordance with the requirements of Regulatory Guide 1.137, Revision 1, which in turn refers to ANSI Standard N195-1976.
This standard requires the day tank capacity for each EDG to be sufficient to maintain at least 60 minutes of EDG operation at the level where fuel oil is automatically added.
This capacity is to be based on the fuel consumpt?.on at a load of 100% of the continuous rating of the diesel plus a minimum margin of 10%.
Contrary to the above, on February 14, 1992, there was no evidence that the EDG day tank capacities meet the above commitment.
The license estimated the day tank capacities to be about 47 minutes."
Deviation 2
" Hope Creek UFSAR, paragraph 9.5.4, states that each set of storage tanks can store a quantity of diesel fuel oil that is sufff.cient for 7 days of continuous operation of one EDG l
unit under rated full operating loads as described in EDG loading tables 8.3-2 through 8.3-6.
Contrary to the above, calculation JE-0014 dated January 27, 1992, indicates insufficient fuel oil reserves for 7 days (a combined shortage of 5579 gallons) of continuous worst case EDG loading based on the basis of segregated channel storage "
on July 10, 1992, PSE&G responded to thess above deviations es follows:
Deviation 1 PSE&G will revise the start setpoint of the EDG fuel oil transfer pumps to meet the requirement of ANSI N195-1976 1
section 6.1.
This setpoint change will be implemented via a design change package no later than the end of the fourth refueling outage.- PSE&G will also submit a change to the Technical Specifications to revise the minimum EDG _ fuel oil day tank level to correspond with the revised setpoint.
Deviation 2 4
PSE&G is currently reviewing the load tables (8.3-2-to 8.3-6) in the Hope Creek UFSAR against Emergency Operating Procedures to determine the actual loads required in the one hour to seven day time period following a design basis accident.
Upon completion of this review, the load tables in the UFSAR will be revised and the required diesel fuel i
oil storage capacity will be recalculated using the new load tables.
Revision of the UFSAR load tables will be completed by October 1, 1992.
PSE&G believes that recalculating the required fuel oil storage capacity based on the revised load i
tables should demonstrate that there is suffi-lent fuel oil to power engineered safety feature loads
'er seven days following a loss of offsite power concurreu. with a design basis accident.
I PSE&G proposes the following corrective actions in lieu of our-previous response:
Deviation 1 The Hope Creek Generating Station (HUGS) SDG fuel oil storage and transfer system-is designed as Class 1E and seismic category I.
HCGS has 4 EDGs with'two separate fuel oilistorage tanks supplying fuel oil for each individual-E DG.
There are-two fuel oil transfer pumps to supply the single day tank for each EDG.
The fuel cil transfer pump logic _is designed to alternate _the starting of'the transfer pumps when~ filling the EDG day tanks.
This~ logic also provides a start signal to the alternate transfer pump upon receipt of the EDG day tank low level alarm in the event that the designated transfer pump fails to start.
The Hope Creek UFSAR states that HCGS complies with Regulatory Guide 1.137, Rev.
1.
Regulatory Position C.1 of Regulatory Guide 1.137, Rev.
1, endorses ANSI N195-1976 as "an acceptable method for complying with the pertinent -
requirements.of General Dasign Criteria 17 of Appendix:A to 10 CFR 50...",
' ANSI: Standard N195-1976,- Section 6.1' states that, "cach diesel shall~be equipped with day or integral tank or tanks-whosefcapacity is sufficient to maintain at least 60 minutes of operation at the level where oil is automatically added to the day or integral tank...".
2 L
The Hope Creek EDG fuel oil day tanks have a total capacity of 550 gallons.
In order to meet the requirements of ANSI Standard N195-1976, section 6.1, the transfer pump start level would have to be raised from itc current level of 248 gallons to a new level of 422 gallons.
Increasing the transfer pump start level to this point would increase the cycling of the pump by over seven times and increase the probabi]ity of pump motor failure.
PSE&G believes that the increased cycling of the pump would significantly increase tue component degradation of the switches and cabling (i.e.,
increased maintenance, early component replacement) beyond the benefit gained from raising the transfer pump start level.
Instead of raising the fuel oil transfer pump start level to this 422 gallon level, PSEIG proposes to revise the HCGS UFSAR to take exception to Regr 1 tory Guide 3.137, Rev. 1 as follows:
Administrative controls will be established to ensure that the EDG day tanks are filled to at least 422 gallons of fuel oil following operation of an EDG.
This level of fuel oil will be reverified during daily operator rounds.
PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed licensir.g commitment changes to deterrine whether our request involves a significant hazards consideration.
We have determined that operation of the Hope Creek Generating Station in accordanca with the proposed changes:
- 1. Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
Having the fuel oil transfer pump start level set below 66 minutes does not increase the probability of an accident since the fuel oil transfer pumps have the ability to increase the day tank 'evel while the EDGs are running.
Loss of a EDG fuel oil day tank or loss of inventory in the day tank is bounded by the analysis for the loss of an EDG during a design basis accident.
PSE&G has demonstrated that the Hope Creek Generating Station has the ability to shut the plant down and maintain the plant in safe shutdown in the event of a Loss of Offsite Power concurrent witi: a design base accident i
with the loss cf one EDG (refer to UFSAR Section 8.3.1.1.3).
- 2. Will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3 1
Loss of level in the EDG fuel oil day tank is bounded by a loss of the EDG.
PSE&G has previously demonstrated that the Hope Creek Generating Statlon has the ability to shut the plant down and maintain the plant in safe shutdown in the event of a Loss of offsite Power concurrent with a design base accident with the loss of one EDG (refer to UFSAR Section 8.3.1.1.3).
- 3. Will not involve a significant reduction in a margin of safety.
Having the EDG fuel oil transfer pump start level set below the ANSI N195-1976 level of 66 minutes will not reduce the margin of safety sjnce the fuel oil transfer pumps have the ability to increase the EDG day tank level while the EDG is running.
The EDG fuel oil transfer pump logic le designed to start the alternate transfer pump upon receipt of a low level alarm in the day tank if the designated transfer pump does not start.
This design precludes the locs of one transfer pump from causing the loss of fuel oil inventory to the EDG.
PSE&G has also demonstrated the ability to shutdown and maintain HCGS in safe shutdown with the loss of one EDG during a design basis accident concurrent with a loss of offsite power (refer to UFSAR Section 8.3.1.1.3).
Levs of a EDG bounds the complete loss l
of fuel oil inventory in the EDG day tanks.
l PSE&G believes th ' these administrative controls meat the intent of Regulatory Guide 1.137, Revision 1 and therefore Hope Creek Generating Station complies with 10 CFR 50 Appendix A General Design Criteria 17.
Deviation 2 PSE&G committed in the Hope Creek UFSAR to size the EDG fuel oil storage system in accordance with the Standard Review Plan (SRP) section 9.5.4, and Regulatory Guide 1.137.
The SRP states that "a minimum of seven days' supply of fuel i
oil, for each redundant diesel generator syste7, has been provided onsite to meet the engineered safety featuro load requirements following a loss of offsite power and a design basis accident."
Regulatory Guide 1.137 states that "the design of fuel-oil systems for diesel generators that i
provide standby electrical power for a nuclear power plant that are included in ANSI N195-1976 provide a method acceptable to the NRC staff for complying with the pertinent I
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9 requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50."
ANSI N195-1976 section 5.2 states, "the on-site oil storage shall be sufficient to operate the minimum number of diesel-generators following the limiting design basis accident (DBA) for either seven days, or the time required to replenish the oil-from sources outside the plant site following any limiting design-basis event w;thout 4
interrupting tha operation of the diesel, whichever is longer."
Calculation JE-0015 was performed by PSE&G to determine-the
- uel oil storage capacity for the Hope Creek EDGs.
This calculation was based on the time dependent loads listed in Tables 8.3-2 to 8.3-6 of the Hopc-Creek UFSAR.
It was determined that the worst case consumption of fuel oil would occur in the case of a loss of offsite power with a DBA_and the loss of the D EDG.
PSE&G calculated the onsite storsqe capacity would be capable of providing 6 days 16.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of operation, including the 10% rargin required by the ANSI standard, if no credit is taken_for the fuel oil of the idle diesel generator.
If credit.is'taken for transferring fuel oil from the idle EDG, PSE&G has cL1culat=a that there is sufficient fuel oil on-site for 7 days.
l PSE&G committed to review the EDG load tables in the Hope
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Creek UFSAR against the Emergency Operating Procedures (EOPs) to determine the actual leads on-the EDGs for the 60 minute to 7 dey time period.
In the process of reviewing the EOPs, PSE&G has determined that there are more safety benefits for loaving the operations personnel with the ability to load non-safety related loads on the EDGs in l
accordance with the current EOPs than to limit:the i
operators' flexjbility.
In order to provide the operators the flexibility taa lond non-class 1E loads during post accident conditions, PSE&G requests that the NRC provide relief from the following HCGS UFSAR commitment.
i HCGS UFSAR Section 9.5.4.2 states that the "SDG fuel l
oil storage system is sized in accordance with the requirements of Standard Review Plan Section 9.L.4...".
PSE&G proposes to revise the HCGS UFSAR to state that the fuel oil storage system'is designed in accordance with kegulatory Guide 1.137, Revision 1 which refers to ANGI i
N195-1976.
Procedures will be revised to. initiate actions necessary'to transfer _ fuel oil from the idle EDG storage tanks to the operating EDGs to ensure for a continuous 7-day l
supply in'the event of an extended loss of offsite power-event.
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e PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed licensing commitment changes 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 changen
- 1. Will not involve a significant increasu in.he probability or consequences of an accident previously evaluated.
Since the EDGs are used to mitigate the con-rquences of an accident, transferring tuel oil from
..e tank to another will not increase the probability of an accident.
With the ability to transfer fuel oil from the idle EDG, Hope Creek Generating Station has sufficient EDG fuel oil capacity in seismic category I tanks to operate the EDGs for seven days in the event of a DBA concurrent with the loss of offsite power in accordance with Regulatory Guide 1.137, Revision 1.
- 2. Will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The transfer of EDG fuel oil from one tank to another will only occur during.long term accident mitightion and therefore does not create the possibility of a new or different kind of accident.
3.
Will not involve a significant reduction in a margin of safety.
i The EDG onsite fuel oil storage tanks are seismic category I.
The eight EDG fuel oil storage tanks at HCGS hold a supply of fuel oil that is sufficient to supply the EDGs for 7 days of operation following a loss of offsite power event concurrent with a design l
basis accident.
In response to NRC rCAR Question 430.88, PSE&G evaluated the ability to refuel the EDG fuel oil storage tanks within-the seven day time period under severc weather conditions.
This ovaluation states that while extremely adverse wind, weather and tidal conditions at the Hope Creek Site could interfere with diesel oil delivery for approximately 24-36 hours, it would be a very improbable situation that would preclude delivery by truck or barge for as long as 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.
Dur ag normal weather conditions the delivery of foot oil takes approximately 1 - 2 days from placing an 6
t i
j order to receiving the oil onsite.- Since Hope Creek has the ability to refuel the EDG within the seven day fuel supply, there is no reduction-in.the-margin of safety.
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l With the ability to transfer fuel oil from one seismic category I EDG fuel oil storage tank to another, PSE&G has sufficient capacity onsite to' provide for seven days of continuous operation i
of the EDGs during-the.uorst case-design basis accident concurrent with a loss.of offsite power.
Having'seven days of.
fuel oil onsite rests toe requirements of Regulatory Guide 1.137, i
Revision 1, and therefore Hope. Creek Generating Station complies l
with 10 CFR 50 Appendix A, General Design Criteria 17.
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