ML20134M077

Application for Amend to License NPF-57,requesting Rev to 3/4.8 Re Electrical Power Systems for Improvements to EDG

ML20134M077
Person / Time
Site:	Hope Creek
Issue date:	02/11/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20134M080	List: ML20134M077 ML20134M092
References
LCR-H96-05, LCR-H96-5, LR-N96249, NUDOCS 9702200083
Download: ML20134M077 (13)

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Pubhc Serwce Electnc and Gas Company Louis F. Storz Public Service Electric and Gas C P.O. Box 236 Hancocks Bridge. NJ 08038 609-339-5700 sew vce m ni. w ow. m 1 1 l997 LR-N96249 LCR H96-05

l United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i

REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS IMPROVEMENTS TO THE EMERGENCY DIESEL GENERATOR TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:

i In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station (:HC).

In accordance with 10CFR50.91(b) (1), a copy of this submittal has been sent to the State of New Jersey.

The proposed revision represents changes to Technical Specification sections 3/4.8.1 "A.C.

Sources", 6.8 " Procedures e

and Programs", and the Bases for section 3/4.8, " Electrical Power Systems."

Specifically, the changes include:

1) the relocation of existing surveillance requirements related to diesel fuel oil chemistry; 2) the introduction of a new program under TS 6.8.4.e,

" Diesel Fuel Oil Testing Program"; 3) revisions to the TS Bases for section 3/4.8 to incorporate information associated with the TS changes; and 4) editorial changes to implement required corrections.

The proposed TS changes are consistent with the intent of the related specifications in the improved " Standard Technical Specifications General Electric Plants, BWR/4", NUREG-1433 (STS).

i The proposed changes have been evaluated in accordance with 10CFR50. 91 (a) (1), using the criteria in 10CFR50.92 (c), and a f

determination has been made that this request involves no I

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significant hazards considerations.

The basis for the requested change is provided in Attachment 1 to f O!

l this letter.

A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2.

j The marked up TS oages affected by the proposed changes are l

9702200083 970211 ~

DR ADOCK 05000354 PDR

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Document Control Desk LR-N96249 provided in Attachment 3.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely, I

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Affidavit Attachments (3)

C Mr. H. Miller, Administrator - Region I U.

S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.

D.

Jaffe, Licensing Project Manager - HC U.

S. Nuclear Regulatory Commission l

One White Flint North 1

11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr.

R.

Summers (X24)

USNRC Senior Resident Inspector - HC Mr. K.

Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

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Document Control Desk LR-N96249 j

JPP BC Senior Vice President - Nuclear Engineering (N19) j General Manager - Hope Creek Operations (H07) i Director - QA/NSR (X01)

Manager - Nuclear Business Relations (N28)

Manager - Hope Creek Operations (H01) 4 Manager - System Engineering - Hope Creek (H18)

Manag.

- Nuclear Safety Review (N38)

Manager - Licensing & Regulation (X09)

Supervisor - Hope Creek Licensing (X09)

Onsite Safety Review Engineer - Hope Creek (X15)

Station Licensing Engineer - Hope Creek (X09)

General Solicitor, R.

Selover (Newark, SG)

Perry Robinson, Esq.

Records Management (N21)

Microfilm Copy Files Nos. 1.2.1 (Hope Creek), 2.3 (LCR H96-05) i i

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l REF: LR-N96249 l.

LCR H96-05 i

STATE OF NEW JERSEY )

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SS.

COUNTY OF SALEM

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F. Storz, being duly sworn according to law deposes and says:

i 7 am Senior Vice President - Nuclear-Operations of Public Service i

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.:ctric and Gas Company, and as such, I find the matters set

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forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, 1

l information and belief.

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l Subscribed and Sworn to before me l

this //N[

day of d/u;,o x,, 1997

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I Notary!Public of New Jersey DELORIS D. HADDEN NeeeryPulseof NewJersey My Commission expires on WWW i

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i Document Control Desk LR-N96249 Attcchment 1 LCR H96-05

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i HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 i

i IMPROVEMENTS TO THE EMERGENCY DIESEL GENERATOR TECHNICAL SPECIFICATIONS (TS) i BASIS FOR REQUESTED CHANGE:

The changes proposed in this request include:

1) the relocation of existing surveillance requirements related to diesel fuel oil chemistry; 2) the introduction of a new TS section for the EDG fuel oil testing program; 3) revisions to the-EDG TS. Bases to

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incorporate information from the proposed TS changes; and 4) editorial modifications to implement required corrections.

These changes complete the alignment of the HC diesel fuel oil testing a

program to the improved STS initiated with Amendment 74.

The proposed TS are consistent with the intent of the related i

specifications in NUREG-1433, " Standard Technical Specifications General Electric Plants, BWR/4 (STS)", to the extent practical.

i REQUESTED CHANGE AND PURPOSE:

EDG Fuel Oil Chemistry Survei31ances and TS 6.8.4.e As shown in Attachment 3 of this letter, Surveillance

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Requirements 4.8.1.1.2.f will be revised to include a reference to TS 6.8.4.e in the Administrative Controls Section of the TS.

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The proposed requirements contained in TS 6.8.4.e for EDG fuel oil chemistry sampling are consistent with the EDG fuel oil testing requirements contained in STS Specification 5.5.10.

With i

4 the exception of particulate testing (which is being added), no changes are being proposed to any existing fuel oil acceptance I

criteria.

These changes complete the alignment of the HC diesel fuel oil testing program to the improved STS initiated with HC TS Amendment No. 74 and make the HC TS consistent with the requirements contained in the improved STS.

TS Bases Changes As indicated in Attachment 3 of this letter, the HC TS Bases will be revised to include the pertinent information from the improved STS that support the proposed TS revisions.

Additional Changes An editorial carrection is also proposed for LCO 3.8.1.1.

Specifically, the portion of ACTION c. for LCO 3.8.1.1 on TS page l

Page 1 of 5 l

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Document Control'DS3k LR-N96249 Attcchment 1 LCR H96-05 l

3/4 8-1 will be deleted since the entire ACTION Statement already appears on TS page 3/4 8-2.

This change corrects an error that j

was made when HC TS Amendment No. 79 was' issued.

I BACKGROUND:

l The proposed TS revisions will be discussed separately as indicated below:

EDG Fuel Oil Chemistry Surveillances and TS 6.8.4.e l

On July 28, 1994, PSE&G submitted License Change Request (LCR) 94-16.to relocate the details-of the EDG fuel oil testing l

requirements from TS 3/4.8 to a Diesel Fuel Oil Testing Program, i

That LCR was approved in HC TS Amendment No. 74 on June 29, 1995.

L Although the LCR used terminology from the STS, certain elements i

of the STS pertaining to EDG fuel oil testing and the associated l

program were not incorporated.

Specifically, a new EDG fuel oil testing program would need to be established in the i

l Administrative Controls Section of the HC TS (Section 6.0) and additional requirements for particulate testing would need to be L

added to make the HC EDG Fuel Oil Testing Program consistent with l

STS Specification 5.5.10.

Approval of the proposed changes E

contained in this submittal would complete HC's implementation of

-the improved STS requirements for EDG fuel oil testing.

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TS Bases Changes j

l The proposed changes discussed in the previous paragraph also l

include revisions to the Bases of the EDG-related TS to provide l

additional information relative to the requirements being l

implemented by the proposed changes.

The revisions to the TS l

Baaes,.as indicated in Attachment 3 of this submittal, incorporate these changes.

Additional Changes When HC TS Amendment No. 79 was issued, page 3/4 8-1 contained a portion of LCO 3.8.1.1, ACTION Statement c.,

which was previously moved to page 3/4 8-2 via HC TS Amendment No. 75.

This error i

remained uncorrected through the issuance of HC TS Amendment No.

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96.

The changes indicated in Attachment 3 of this letter correct this deficiency and are~ considered to be editorial in nature.

Page 2 of 5

1 Document Control Dack LR-N96249 Attcchment 1 LCR H96-05 I

t JUSTIFICATION OF REQUESTED CHANGES:

The proposed TS revisions will be discussed separately as follows:

EDG Fuel Oil Chemistry Surveillances and TS 6.8.4.e The revision to Surveillance Requirement 4.8.1.1.2.f, which will now include a reference to a new specification 6.8.4.e in the Administrative Controls section of the TS, is consistent with the changes made in the improved STS.

The presentation of the EDG fuel oil surveillance requirements was revised to reflect the latest NRC supported methodologies as. published in the improved STS.

The details of methods for performing these surveillances are not included in the TS and are adequately controlled by procedures, with their revisions controlled by the provisions of 10CFR50.59.

The requirements delineated in Specification 5.5.10 of the j

improved STS have been incorporated into HC TS 6.8.4.e.

However, i

the following exceptions to these requirements are being proposed-1 1.

For testing of new fuel oil prior to introduction to the EDG fuel oil storage tanks, bulk water and sediment testing l

replaces "a clear and bright appearance with proper color" i

in STS Specification 5.5.10.a.3.

The intent of the " clear and bright..." is to provide a rapid, qualitative assessment j

that there is no visible water or other foreign material in the fuel oil.

The bulk water and sediment criteria, specified in ASTM D1796 for fuel oil, provides a quantitative assessment that is more objective over the subjective standard of " clear and bright..." specified in the STS.

HC purchases dyed fuel for the EDGs.

With the dyed fuel, the clear and bright criteria would be dif ficult, if not impossible, to meet.

HC has onsite capability to test for bulk water and sediment.

Tests for water and sediment content are already performed on the EDG fuel oil.

PSE&G believes that the proposed TS criteria satisfies the need for an assessment prior to adding the new fuel to the EDG fuel oil stcrage tanks.

2.

Particulate testing, which is currently not required by the HC TS, of the stored fuel would be done once per 92 days instead of once per 31 days as specified in the imps.oved STS.

The frequency of once per 92 days is acceptable on the Page 3 of 5

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Document Control Dnsk LR-N96249

' Attschment 1 LCR H96-05

- basis of several years (1992-1996) of test data that indicate the HC stored fuel has not exhibited a particulate problem based upon sediment % determined by the bulk water i

and sediment tests.

i In the Safety Evaluation Report for HC TS Amendment No. 74, I

the NRC stated, "The Commission's position on surveillance frequencies, established in the STS, is to take into i

consideration fuel oil degradation trends which indicate

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that particulate concentration is unlikely to change 3

significantly between frequency intervals."

To ensure l

particulate contamination of the fuel does not occur, PSE&G F

proposes that a revision to the station controlled-diesel.

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fuel oil testing program be implemented to monitor particulate analysis results and increase particulate

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sampling, if required, to ensure that limits would not be exceeded prior to the next normal sample period.

The j

increased frequency of testing would be based on identified adverse trends.

This change would represent'an increase in the testing currently required for the EDG fuel oil.

3.

The ASTM D-2276 particulate analysis method has been modified to use a 3.0 micron membrane filter instead of a 1

O.8 micron membrane filter.

This is based on the fact that ASTM D-2276 is intended for aircraft fuel and not EDG fuel j

oil.

As stated in HC UFSAR Section 9.5.4.2.5, the closest tolerance fuel filter in the HC EDGs is a five micron particle retention duplex filter on the engine driven fuel oil pump discharge header.

Based upon past EDG performance, a five micron fuel filter does not have_any adverse impact j

on the operation of the EDGs.

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With the exception of the above, no other EDG fuel oil acceptance i

criteria are being modified.

In addition, the test for flash point will now be conducted prior to the. addition of the new fuel i

to the storage tank.

Therefore, the HC EDG fuel oil testing will l

meet all of the requirements for diesel fuel oil specified in the improved STS.

TS Bases Changes As part of the changes described in the previous section, the HC TS Bases will also be enhanced to provide information consistent I

with that found in the Bases for the improved STS.

The Bases changes essentially include the information contained in the previous section, which justifies the incorporation of those i

proposed changes into the HC TS.

With approval of the proposed Page 4 of 5

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i Document Control Dask LR-N96249 LCR H96-05

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l-changes to the TS, the associated Bases changes would be editorial in nature, requiring no additional justification.

Additional Changes.

When HC TS Amendment No. 79 was issued, page 3/4 8-1 contained a portion of LCO 3.8.1.1, ACTION Statement c.,

which was previously moved to page 3/4 8-2 via HC TS Amendment No. 75.

This error remained uncorrected through the issuance of HC TS Amendment No.

96. The changes indicated in Attachment 3 of this letter correct this deficiency and are considered to be editorial in nature.

CONCLUSIONS:

The changes proposed in this request include revisions to the HC EDG TS and associated Bases to become more consistent with the improved STS.

PSE&G concludes that these proposed changes are adequately justified and result in No Significant Hazards Considerations as described in Attachment 2 of this letter.

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Document Control Dack LR-N96249 Attcchment 2 LCR H96-05 1

HOPE CREEK GENERATING STATION 1

FACILITY OPERATING LICENSE NPF-57 DOCKET No. 50-354 IMPROVEMENTS TO THE EMERGENCY DIESEL GENERATOR TECHNICAL SPECIFICATIONS (TS) i 10CFR50.92 EVALUATION 4

Public Service Electric & Gas (PSE&G) has concluded that the i

proposed changes to the Hope Creek Generating Station (HC) l Technical Specifications do not involve a significant hazards i

consideration.

In support'of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

i REQUESTED CHANGE

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The proposed revisions to TS represent changes to Specifications 3/4.8.1 "A.C.

Sources", and its associated TS Bases as well as to Specification 6.8 " Procedures and Programs."

These changes:

1) revise the HC Emergency Diesel Generator (EDG) TS and associated Bases to become more consistent with the improved " Standard Technical Specifications General Electric Plants", NUREG 1433 (STS); 2) revise the EDG TS Bases to incorporate information from the proposed TS changes; and 3) incorporate editorial modifications to implement required corrections.

BASIS i'

1.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously l

eval ua ted.

The proposed changes involve:

1) no hardware changes; 2) no i

significant changes to the operation of any systems or components in normal or accident operating conditions; and 3) no changes to existing structures, systems or components.

Therefore these changes will not increase the probability of an accident previously evaluated.

Establishment of EDG fuel oil testing requirements in TS 6.8.4.e is a change that is consistent with changes made in the improved STS as contained in Specification 5.5.10 of that document.

These changes establish a new requirement to test for particulates in the EDG fuel oil, but establish a 92 day test frequency (as opposed to 31 days in the improved STS) and a 3.0 micron Page 1 of 3

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___.._4 Document Control Dsak LR-N96249 LCR H96-05 acceptance criteria (as opposed.to 0.8 micron in the improved STS) for particulate testing._ PSE&G concludes that these changes

.are acceptable based upon past EDG fuel oil tests for particulates and acceptable performance of the EDG with 5.0 micron filters.

In addition, PSE&G will utilize more objective test criteria for water and sediment in the EDG fuel oil than established by the " clear and bright" acceptance criteria contained in the improved STS.

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' Since the EDG fuel oil will still:

1) meet all of the requirements established for fuel oil specified in the improved STS; and 2) retain the capability to mitigate'the consequences ~of accidents described in the HC Safety Analysis Report, the proposed changes were determined to be justified.. Based on esta'blished fuel oil quality history, the proposed testing methods and frequencies will not significantly decrease confidence in fuel oil quality and EDG operability, nor will they have any negative effect on established plant practices in regards to the testing of EDG fuel oil.

Therefore, these changes

.will not involve a significant increase in the consequences of an accident previously evaluated.

- The revisions proposed to the TS Bases are being made to provide additional information supporting the proposed EDG TS.

With the approval of the proposed TS changes, the associated Bases changes would be editorial in nature.

Therefore, these changes will not involve a significant increase in the consequences of an accident previously evaluated.

In addition, the proposed change to LCO 3.8.1.1, ACTION c.,

is considered to be editorial in nature and will not result in a significant increase in the consequences of an accident previously evaluated.

1 2.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously evalua ted.

The HC EDGs are designed to mitigate the consequences of accidents by providing electrical power to safety-related equipment.

Failure of the EDGs are not considered to initiate any of the accidents described in the HC Safety Analysis Report.

The proposed changes. concern fuel oil system surveillances and testing frequency.

The proposed changes will not adversely

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impact the operation of any safety related component or j

equipment.

Since the proposed changes involve:

1) no hardware changes; 2) no significant changes to the operation of any systems or components; and 3) no changes to existing structures, Page 2 of 3

Document Control D 2k LR-N96249 LCR H96-05 systems or components, there can be no impact on the occurrence of any accident.

Furthermore, there is no change in plant testing proposed in this change request which could initiate an event.

Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

In addition, the proposed change to LCO 3.8.1.1, ACTION c.,

is considered to be editorial in nature and will not result in a new or different kind of accident from any previously evaluated.

3.

The proposed change does not involve a significant reduction in a margin of safety.

Establishment of EDG fuel oil testing requirements in TS 6.8.4.e is a change that is consistent with changes made in the improved STS.

The proposed changes address:

1) how EDG fuel oil quality is to be determined; 2) how frequently this determination is to be performed; and 3) how to control the process for determining fuel oil acceptability and resultant EDG operability.

With the exception of particulate testing (which is being added) all acceptance criteria for fuel oil testing remain unchanged.

Based on historical data, EDG fuel oil quality will not be adversely affected or impacted by the proposed changes.

Therefore, the proposed amendment does not involve any significant reduction in a safety margin.

The revisions proposed to the TS Bases are being made to provide additional information supporting the proposed EDG TS.

With the approval of the proposed TS changes, the associated Bases changes would be editorial in nature.

Therefore, these changes will not involve a significant reduction in a safety margin.

In addition, the proposed change to LCO 3.8.1.1, ACTION c.,

is considered to be editorial in nature and will not involve a significant reduction in a safety margin.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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Document Control D32k LR-N96249 Attechment 3 LCR H96-05 HOPE CREEK GENERATING STATION EACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 IMPROVEMENTS TO THE EMERGENCY DIESEL GENERATOR TECHNICAL SPECIFICATIONS (TS)

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TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES l

The following Technical Specifications for Facility Operating License No. Nrr-57 are affected by this change request:

Technical Specification Page 3.8.1.1, ACTION c.

3/4 8-1 4.8.1.1.2.f 3/4 8-5 New 6.8.4.e 6-16a Bases 'a/4.8 B 3/4 8-1 1

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