ML20126H415

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Safety Evaluation Supporting Amends 177 & 154 to Licenses DPR-53 & DPR-69,respectively
ML20126H415
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 12/29/1992
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20126H414 List:
References
NUDOCS 9301050188
Download: ML20126H415 (6)


Text

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SAFETY EVALVATION BY THE OFFICE OF f41) CLEAR REACTOR REGt)1A_LLQH RELATED TO AHLUQMENT NO.177 TO FAClllTY OPERATING LICENSE N0. DPR-53 AND AMENDMENT NO. 154 TO FACILITY OPERATING _ LICENSE NQ. OPR-62 MLTIMORE GAS AND ELECTRIC COMPANY

[ALVERT CLIFFS NUCLEAR POWER PLANTm IJRILJ.fqS.1 AND 2 EQCKET NQS. 50-317 ANQ_5.Q-110 1.0 INTRODUC1'QH By letter dated October 9, 1992, the Baltimore Gas and Electric Company (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2, Technical Specifications (TS).

The requested changes would revise TS regarding the diesel fuel oil requirements.

The requested changes are divided into three specific areas.

Change No. I would revise TS 3.8.1.1 to:

increase the required volume of fuel maintained in each fuel oil storage tank (f0ST), clarify the TOST requirements during periods of high tornado probability, and would remove the requirement to maintain an 8,000-gallon alternate source of fuel onsite whenever a FOST is inoperable.

This change would also revise TS 3.8.1.2 to more clearly specify the action requirements for an inoperable F0ST in MODES 5 and 6.

Change No. 2 would revise TSs 3.8.1.1.b.1 and 3.8.1.2.b.2 to change the required minimum volume of fuel oil maintained in the day tanks from 375 to 275 gallons.

Change No. 3 wculd revise TS 4.7.ll.l.2.b surveillance requirements for the diesel-driven fire pump fuel oil chemistry requiring it to be within the acceptable limits specified in American Society for Testing and Materials (ASTM) D975-81.

2.0 EVALUATIDH The design of the Emergency Diesel Generator (EOG) fuel oil system is based on a fuel oil capacity of 7 days.

Specifically, Institute of Electrical and Electronics Engineers (IEEE)-308 recommends that sufficient fuel oil be available to run on EDG for 7 days (or the time needed to replenish fuel oil from an offsite source following a design basis event, whichever is longer),

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-, The two FOSTs (No. 11 and No. 21) contain a volume of fuel oil well in excess of that needed to satisfy this requirement.

Each tank is sized to hold approximately 107,000 gallons of usable fuel oil.

Normally, the volume of fuel maintained in each tank is between 90,000 and 107,000 gallons.

Currently, the TS require 18,250 gallons of fuel oil to be maintained in each FOST, for a total of 36.500 gallons.

During a review of the custom TS issued with the original license, the licensee was able to clarify that this requirement applies to each unit, such that 73,000 gallons is the minimum onsite volume that should be maintained to support two-unit operation.

The licensee is requesting that the allowable out-of-service time for No. 11 FOST be increased from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

This will permit the tank to be drained, inspected and repaired as necessary.

In order to compensats for this increase, the licensee proposes that the minimum-required volume for No. 21 FOST, which is bunkered to protect it against tornadoes, be increased to 74,000 gallons. This will ensure that sufficient fuel will be available in No. 21 TOST alone to satisfy the site's fuel demands for both design basis events or tornadoes.

The staff has determined that these proposed changes.are acceptable.

This determination is based on the fact that the minimum onsite fuel oil volume is being increased from 36,500 gallons to 106,000 gallons (74,000 gallons in No. 21 FOST and 32,000 gallons in No. 11 FOST), which is sufficient to adequately supply the diesels for 7 days following both design basis events and tornadoes, and to compensate for the increased allowable out-of-service time for No. 11 F0ST.

As a part of the requested change, the licensee is proposing to delete the present requirement to provide an 8,000 gallon fuel oil source whenever a FOST is out-of-service.

The licensee states that this is not a significant change because its inclusion in the TS has been determined to be inappropriate based upon a review of the licensing basis.. This review indicates that the requirement was only appropriate as a temporary compensatory measure for planned maintenance involving out-of-service times longer than those allowed by the TS in 1984.

However, this requirement was inappropriately incorporated into a subsequent TS amendment.

The staff finds this change acceptable based on the fact that the requirement' for an 8,000 gallon alternate source is unnecessary, except under circumstances requiring extensive out-of-service times in excess of the proposed TS.

While in Modes 5 and 6, each unit is required to have at least one diesel l

generator operable and capable of providing power for normal shutdown loads..

E The licensee has decided that the Modes 5 and 6 TS should be revised-to reflect tornado protection requirements as well.

Limiting Condition for Operation 3.8.1.2 would be revised to require that both FOSTs meet the same L

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' volume requirements as in Modes 1-4.

Action Statements have also been added to clarify the requirements for inoperable F0STs.

The staff finds this change acceptabic based on the fact that it will increase the required volume of fuel, and ensure consistency between the Modes 1-4 and the Modes 5 and 6 TS.

With regard to change No. 2, each EDG is equipped with a fuel oil transfer pump and a fuel oil day tank having a maximum capacity of approximately 485 gallons.

The fuel oil day tank level is normally maintained by automatic cycling of the fuel oil transfer pump. Operation of the transfer pump in automatic is controlled by start and stop level switches connected to the day tank.

h and low day tank level alar.ns are also provided to warn operators of abnormal conditions.

The fuel oil contained in the day tank allows sufficient operating time to correct most problems that may develop with the fuel oil transfer system, such as valve mis-alignments or level switch adjustments, before the EDG trips due to low fuel oil.

Current guidance (Regulatory Guide 1.137 and American National Standards Institute (ANSI) N195-1976) recommend a fuel oil volume equivalent to at least one hour of operation be maintained in the day tank.

Change No. 2 would revise TS 3.8.1.1.b.1 and 3.8.1.2.b.1 to reduce the minimum volume of fuel i

required to be maintained in the day tanks from 375 to 275 gallons.

The requested 275 gallons of fuel oil would provide approximately 65 minutes of operation based on the 7-day maximum rated load of 3,250 Kw. The basis for the requested change is that lowering the required TS volume in the day tank would permit the pump start level switch to be lowered, resulting in reduced cycling of the pumps and level switches.

The licensee believes that this should result in reduced component wear and improved system reliability.

Based on the most recent fuel oil consumption rate calculation, the time between each cycle of the fuel oil transfer pump could be doubled to approximately 30 minutes by adopting the proposed minimum TS volume of 275 gallons.

The staff agrees that the revised volume requirements for minimum day tank level are in accordance with the applicable guidance and, therefore, finds the requested change acceptable.

A minor change is requested to TS 4.7.ll.1.2.b to correct an inconsistency between surveillance requiremer.ts concerning the diesel-driven fire pump fuel oil chemistry and the EDG fuel oil chemistry. Amendment No.111 for Unit I and Amendment No. 94 for Unit 2, authorized use of ASTM 0975-81, in place of ASTM D975-74, for determining acceptance of diesel fuel oil chemistry.- This change should have been implemented for the diesel fire pump-fuel oil chemistry surveillance as well, since the EDGs and the diesel-driven fire pump are supplied from a common source of fuel oil. Although the F0STs provide a common source of fuel for-the EDGs and the diesel fire pump, minimum volume requirements for the EDGs are maintained through the use of standpipes and administrative controls.

In addition, the diesel-driven fire pump demands are small in comparison, so that the proposed minimum volume requirements for the EDGs (106,000 gallons tota.) are more than sufficient to accommodate any such demands.

This proposed change to the TS reflects no actual change in the

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fuel, as the fuel currently being used meets the 1981 standard.

Therefore, the licensee is requesting that TS 4.7.ll.l.2.b be revised to require fuel oil to meet the applicable limits of AS1H 0975-81.

The staff finds this revision acceptable.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments.

The State official had no comments.

4.0 [NVIRONMENTAL CONSIM RATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is-no significant increase in individual or cumulative occupational radiation i

exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant' hazards consideration, and there has been no i

public comment on such finding (57 FR 53783). Accordingly, the amendments i

meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR St.22(b) no environmental impact statement or environmental assessment need be prepared in conne-tion with the issuance of.

the amendments.

5.0 CONCLUSION

1he Commission has concluded, based on the considerations din.ussed above, that:

(1) there is reasonable assurance that the health and safety of the i

public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will; not be inimical to the common defense and. security or to the' health and safety of the public.

Principal Contributor:

C. Orsini.

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Date: December 29, 1992 e

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Mr. Robert E. Denton December 29, 1992 A copy of the related Safety Evaluation is enclosed.

A Notice of Issuance will be included in the Commission's next regular biweekly frdttal llegister notice.

Sincerely, Original $>gned Dy: Chrisptopher Orsini for Daniel G. Mcdonald, Senior Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosures:

1.

Amendment No.177to DPR-53 2.

Amendment No.154 to DPR-69 3.

Safety Evaluation cc w/ enclosures:

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DATED: December 29, 1992 AMENDMENT NO.17710 FACILITY OPERATING LICENSE NO. DPR-53-CALVERT Cliffs UNIT 1 Ad[NDMENT NO.15410 FACILITY OPERATING LICENSE f40. DPR-69-CALVERT Clif f s UNIT 2 Docket file NRC & Local PDRs PDI-l Reading S. Varga, 14/E/4 J. Calvo, 14/A/4 R. Capra C. Vogan D. Mcdonald C. Orsini OGC D. llagan, 3302 MNBB C. Liang, 8/E/23 G. 11111 (8), Pl-22 Wanda Jones, P-370 C. Grimes, ll/f/23 C. Berlinger, 8/0/22 C. McCracken, 8/D/1 J. Strosnider, 7/D/4 ACRS (10)

OPA OC/LfMB Plant file C, Cowgill, Region I cc:

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