ML20214L482
| ML20214L482 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/24/1986 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20214L389 | List: |
| References | |
| RTR-REGGD-01.137, RTR-REGGD-1.137 GL-84-15, NUDOCS 8612030087 | |
| Download: ML20214L482 (10) | |
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.r-BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMENT TO OCTOBER 1, 1981 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 8612030087 861124 DR ADOCK 050002 7 i
e BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMENT TO OCTOBER 1, 1981 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On October 1, 1981, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Units 2 and 3, filed an Application for Amendment of the Licenses which requested that several Technical Specifications contained in Appendix A of the Operating Licenses be amended.
Although the Commission has acted in partial response to the Application, there remains pending one of the requested changes, involving diesel fuel oil, which was proposed to bring the Peach Bottom fuel oil program into conformance with the sampling and analysis requirements of Regulatory Guide 1.137 (Fuel Oil Systems for Standby Diesel Generators).
The NRC' staff, in discussions on October 31, 1985 and June 3, 1986, indicated that the proposed October 1, 1981 fuel oil amendment did not satisfy the requirements of Regulatory Guide 1.137 and requested the Licensee to revise its Application.
Accordingly, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station Units 2 and 3, respectively, hereby amends its Application of October 1, 1981, by deleting the proposed Technical Specification page 218 referred to in the October 1, 1981, Application and substituting therefor updated pages 218, 218a, and 218b which are attached hereto and incorporated herein by reference.
Pages 218a and 218b are being added to accommodate the amount of new material.
Additionally, Licensee requests that the effectiveness of the amendment be deferred for six months following issuance to accommodate revisions to plant procedures and procurement of test equipment required to implement the amendment.
A discussion of the proposed revisions to the Technical Specifications follows:
In October, 1979, NRC issued Regulatory Guide 1.137 (Revision 1) which described a method acceptable to NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby diesel generators and assurance of adequate fuel oil quality.
Currently, Peach Bottom Technical Specification surveillance requirement 4.9.A.l.d requires that "once a month a sample of diesel fuel oil shall be checked for quality.
The quality shall be within the acceptable limits specified in Table 1 of ASTM D975-68 and logged".
This -
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r Application revises the diesel fuel oil surveillance program to conform with.the requirements of Regulatory Guide 1.137 (with one exception which is justified later in this Application) and is consistent with an NRC-approved fuel oil program whichiis <
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currently in use at other nuclear power plants.- Th'e program
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proposed herein requires checking for (and removing, 12 '
r necessary) accumulated water in the day tanks a'nd main' storage
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e' tanks on a monthly basis; sampling and testing new fuel oil prior' j
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to its addition to the main tanks; and sampling and testing fue'l oil from the main tanks on a monthly basis.
IrI" order to incorporate this program into the Peach Bottom Technical
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Specifications, the requirement to remove accumulated water will.
replace the current Technical Specification 4.9.A.1.d; new fuel
/ g oil sampling and testing requirements will become 4.9.A.1.e;;and main tank sampling and testing will become 4.9.N.l.f'.
To
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accommodate these additions, the current Technical Specification 4.9.A.l.e will be renumbered as 4.9.A.l.g.
The attached Technical Specification pages 218, 218a, and 218b contain the proposed changes.
Regulatory Guide 1.137 requires that a diosel generator be declared inoperable if the fuel oil in its raain tank is determined to be contaminated.
In lieu of this requirement, the proposed Technical Specification 4.9.A.I.f would require the contaminated fuel oil to be replaced within seven hys and would allow the affected diesel generator to remain operable during that period by isolating the diesel from its main tank and
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f aligning it to an uncontaminated tank.
The associated diesel generator would remain operable for the following reasons:
1.
Each of the four diesel generators is provided with a separate fuel oil storage tank, fuel oil day tank, and fuel oil transfer pump (see attached drawing M-323).
Each fuel oil day tank can be filled from any of the storage tanks using any of the fuel oil transfer pumps.
This provision was included in the design so that in the event of fuel oil contamination, or a fuel oil transfer pump failure, the maximum number of diesel generators will still be available to provide emergency power.
Since the cross ties between the four fuel oil storage tanks are located upstream of the fuel oil transfer pumps, the transfer pump dedicated to the affected diesel generator will still be used to automatically transfer the fuel oil to the associated day tank.
This ensures that electrical independence between the four standby diesel generators is maintained, since there are no electrical components upstream of the transfer pumps which could be intertied to compromise independence.
2.
Declaring a diesel generator inoperable because of an extraneous problem in one of the fuel oil storage tanks is not consistent with the objective of maximizing the availability and reliability of the onsite emergency AC power system.
3.
If a diesel generator is declared inoperable because of unacceptable fuel oil in the associated storage tank, then the plant would be required to operate under the
' existing Technical Specificati~ons which require daily surveillance testing of the remaining diesel generators.
This daily testing is not consistent with the intent of NRC Generic Letter 84-15, in which the reduction of extraneous diesel generator surveillance testing is one
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of the recurring themes for increasing diesel generator reliability.
It has been determined that seven days is an adequate j
time period to drain a contaminated storage tank, obtain' replacement fuel oil, and refill the' storage tank with acceptable fuel oil.
This determination is based.on review of the completed procedures which were used to drain, clean, and refill the main tanks in 1981.
Further, this time perio'd is' consistent with Regulatory Guide l.137.
Safety Assessment:
For proper operation of the standby diesel generators, it is necessary to ensure the proper quality of the fuel oil.
l Regulatory Guide 1.137 describes a method acceptable to the NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby diesel generators and assurance of adequate fuel oil quality.
The proposed changes directly conform to an NRC approved diesel fuel oil program, currently in use at other nuclear plants, which fulfills the requirements of l --.
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1 Regulatory Guide 1.137 (reference NRC approval of License Amendment No. 33 for McGuire Nuclear Station, issued June 30, 1984).
The proposed changes would increase the scope of the L(
Peach Bottom Diesel Fuel Oil Program in accordance with this NRC approved program, thereby enhancing the present Peach Bottom program.
Enhancement of the diesel fuel oil program will provide added assurance that the diesel generators are available when called upon to perform their design functions.
Significant Hazards Consideration:
Upgrading the Peach Bottom Diesel Fuel Oil Technical Specifications to conform with NRC guidance does not involve a Significant' Hazards Consideration because the proposed revision does not:
1.
Involve a'significant increase in the probability or consequences of an accident previously evaluated.
The requested change will improve the fuel oil surveillance program to ensure that an adequate supply of quality fuel oil is maintained on-site in accordance with Regulatory Guide 1.137.
Consequently, on-cite emergency power reliability is improved, thereby reducing the probability and consequences of an accident.
2.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change is limited to the testing and sampling ;r 4
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of diesel fuel oil.
These tasks, performed in accordance with NRC guidance, will have no adverse affects on the station or any safety-related equipment, and consequently cannot initiate a new kind of accident.
3.
Involve a significant reduction in a margin of safety.
Maintaining a high quality fuel oil program will help to ensure that the diesel generators are available when they are required to respond.to mitigate the consequences of an accident.
Therefore, the improved diesel generator fuel oil surveillance program will have the affect of enhancing the safety margin.
The Plant Operational Review Committee and the Nuclear
-Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve an unreviewed safety question or a significant hazards consideration and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY By I
p-Vice Pr'esidenti _
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
'O fueq Subscribed and sworn to
- ay before me thisli d
of Nofj 19 Ob dtW 8 A41 s L' Notary Public JUDITH Y. FRANKLIN Notary Pu'!:c, Phila, Phila Co.
Yf Gomrnission Expires July 28.1987
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I CERTIFICATE OF SERVICE I certify that service of the foregoing Amendment was made upon the i
l Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to Thomas R. Gerusky, Director, Bureau of Radiological Protection, P. O. Box j
2063, Harrisburg, PA 17120; all this 24th day of November,1986.
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Eugene /J. Brad 1ey
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Attorney for
!hiladelphia Electric Company 1
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