ML20238C846

Application for Amends to Licenses DPR-44 & DPR-56,providing New Limited Condition for Operation Specifying Actions to Be Taken When Fuel Oil Particulate Level in One Main Storage Tank Exceeds Tech Spec Limit of 10 Mg/Liter

ML20238C846
Person / Time
Site:	Peach Bottom
Issue date:	08/28/1987
From:	Bauer E, Bradley E, Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20238C802	List: ML20238C801 ML20238C846 ML20238C868
References
NUDOCS 8709100410
Download: ML20238C846 (14)

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'BEFORE THE UNITED-STATES NUCLEAR REGULATORY COMMISSION

-In them Matter of  :

Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY  : 50-278

'l AMENDMENT TO NOVEMBER 24, 1986 APPLICATION FOR AMENDMENT i 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 i

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@709100410870902.ADOCK DR 05000277; P , .. PDR

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of  :

Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY  : 50-278 AMENDMENT TO NOVEMBER 24, 1986 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On November 24, 1986, 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 Technical Specifications 1 contained in Appendix A of the Operating Licenses involving diesel generator fuel oil be amended. The changes were proposed ]

to bring the Peach Bottom fuel oil program into conformance with the sampling and analysis requirements of Regulatory Guide 1.137, Revision 1 (October, 1979) " Fuel Oil Systems for Standby Diesel Generators".

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As a result of discussions with the NRC staff, the Application is being revised.to: (1) Provide a new' Limiting Condition for Operation specifying actions to be taken when'the

'fuelLoil part!culate level in one of the main storage tanks exceeds the Technical Specification limit of 10 mg/ liter; (2) r Increase the allowable pore size of the filters specified in ASTM-D2276-78. Sections 5.1'.6 and 5.1.7, which are used to trap the particulate; and (3) Centralize commitments related to

. Regulatory Guide 1.137 Position C.2 involving Peach Bottom Atomic Power Station.

Accordingly, Philadelphia Electric Company, Licensee i

.under Facility Operating Licenses DPR-44 and DPR-56 for Peach j Bottom Atomic Power Station Units 2 and 3, respectively, hereby amends its Application-of November 24, 1986, by deleting the proposed. Technical Specification page 218, 218a and 218b referred to in the November 24, 1986 Application and substituting therefor.

updated pages 218, 218a, 218b, 218c, 220a and 224 which are attached hereto and incorporated herein by reference. Pages 218a, 218b,.218c and 220a are being added to accommodate the distribution of new material. Additionally, Licensee requests that the effectiveness of the License Amendment requested herein 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.  ;

i In October, 1979, NRC issued Regulatory Guide 1.137 (Revision 1) which describes a method acceptable to NRC staff for

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lcomplying with the commission's regulations regarding fuel oil

. systems for standby diesel generators to assure adequate fuel oil quality. Currently, Peach Bottom Technical Specification surveillance requirement 4.9.A.1.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 Application revises the diesel fuel oil surveillance program to conform with the

' requirements of Regulatory Guide 1.137 (with one exception which is discussed later:in this Application) and is consistent with an NRC-approved fuelioil program which is currently in use at'other nuclear power plants. The program proposed herein requires

' checking for (and removing, if necessary) accumulated water in the day. tanks and main storage tanks on a monthly basis; sampling' I

and testing new fuel oil prior to~its' addition to the main tanks; sampling and testing. fuel oil from the main tanks on a monthly basis; draining and cleaning the main storage tanks at least once every. ten years; and-periodically checking the main storage tank cathodic. protection system. In order to incorporate this-program into the Peach Bottom Technical Specifications, the requirement to remove accumulated water will replace the current Technical Specification 4.9.A.l.d; requirements for sampling and testing new fuel oil will become 4.9.A.l.e; main tank sampling and testing will become 4.9.A.1.f; main tank draining and cleaning will become 4.9.A.l.g; and periodically checking the main tank cathodic protection system will become 4.9.A.l.h. To accommodate these additions, the current Technical Specification 4.9.A.1.e t will be renumbered as 4.9.A.l.j.. Lastly, a new Limiting

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. Condition.for Operation'_is proposed-(3.9.B.6) which_ specifies the L actions to be taken when.the fuel oil' particulate level'in one of-l:

the main storage tanks exceeds the Technical Specification limit of 10 mg/ liter. The changes requested in this application are intended to centralize commitments related to Regulatory Guide ~

1.137 Position C.2 involving Peach Bottom Atomic-Power Station.

The attached Technical. Specification pages.218, 218a, 218b, 218c, 220a, and 224 contain the proposed changes.

l The three revisions'to the November 24, 1986 application i

are as follows:

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I. Regulatory Guide 1.137 requires that a diesel generator be

-1 declared inoperable if the fuel oil in its main tank is  ;

determined to be contaminated. In lieu.of this requirement, the proposed Technical Specification 3.9.B.6 provides the j option of.either declaring the diesel inoperable, or, replacing the-contaminated fuel oil within seven days and j allowing the affected diesel generator to remain operable during that period by isolating the diesel from its main tank and aligning it to an uncontaminated tank. Precautionary I i

measures have been added to the proposed amendment which J require establishing and maintaining a minimum of 104,000

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gallons of fuel oil in the three uncontaminated main storage tanks within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (total capacity of three tanks is f i

112,500 gallons), and, sampling the fuel oil in the other three main storage tanks and confirming acceptable j i

particulate levels within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The associated diesel generator would remain operable for the following reasons: l

a. Each of the four diesel generators is provided with a separate fuel oil storage tank, fuel oil day tank, and fuel oil transfer pump. Each fuel oil day tank can be filled from any of the four storage tanks using'any of the four 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.

b. 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.

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c. If a diesel generator is declared inoperable because of utocceptable fuel oil in its associated storage tank, then the plant would be required to operate under the existing Technical Specifications which require daily

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. surveillance testing of the remaining diesel generators.

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This daily testing is not consistent with the intent of L '

NRC Generic Letter 84-15, in which the' reduction of 1

extraneous diesel generator surveillance testing is one I of the recurring themes for increasing diesel generator reliability.

d.- All low pressure core and containment cooling subsystems are required to be tested daily when a diesel. generator is declared inoperable. This imposes increased testing _ j burdens on station personnel, increases equipment wear,.

and increases the potential for. future emergency Technical Specification relief.

It has been determined that seven days is an adequate time period to drain a contaminated storage tank, clean the 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 per.iod is

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consistent'with Regulatory Guide 1.137.

c l II. The November 24, 1986 Application proposed that fuel oil particulate levels be checked in accordance with ASTM-D2276-

78. The filter pore size specified in Sections 5.1.6 and 5.1.7 of this standard is 0.8 microns. However, the diesel  !

vendor has confirmed that filter pore sizes of up to 3.0 microns are acceptable. In-line filters on the diesels are not designed to trap particulate less than 3.0 microns in 1

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size, since particle sizes below 3.0 microns will pass through the fuel injectors and therefore not cause any l degradation of engine performance. For this reason, particle sizes below 3.0 microns need not be considered in the acceptance criteria for engine operability.

III. Two additional surveillance provisions are proposed for incorporation into the Technical Specifications as a means of centralizing commitments related to Regulatory Guide 1.137 Position C2. These are periodic draining and cleaning of the main fuel oil storage tanks, and periodic inspection and testing of the main fuel oil storage tank cathodic protection system. These proposed surveillance provisions are identified as 4.9.A.l.g and 4.9.A.l.h respectively, on page l 218b attached.

l Safety Assessment:

For proper operation of the standby diesel generators, it is necessary to ensure the proper quality of the fuel oil.

Regulatory Guide 1.137 describes a method acceptable to the NRC i

staff for complying with the Commission's regulations regarding j fuel oil systems for standby diesel generators and assurance of adequate fuel oil quality. With one exception (which is l

discussed in the next paragraph), the proposed changes conform to j an NRC approved diesel fuel oil program currently in use at other nuclear plants, which meets the requirements of Regulatory Guide l

1.137 (reference NRC approval of License Amendment No. 33 for McGuire Nuclear Station, issued June 30, 1984). The proposed j j

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. changes would increase the_ scope of the Peach Bottom Diesel Puel .

I Oil. Program in accordance with this NRC approved program, thereby I enhancing,the present Peach Bottom program. Enhancement of the.

diesel fuel. oil program will provide added assurance that the 'l diesel-generators are available when called upon to perform their design functions.

During a March 5, 1987 telecon, the NRC review team noted that our November 24, 1986 proposal to re-align a diesel to

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an uncontaminated main storage tank could create a situation in which a certain single failure could render two diesels inoperable simultaneously. The single failure involves failure of one of the two fuel-oil transfer pumps which are taking suction from the uncontaminated main storage tank. The failure could cause-air to be entrained in the piping which is common to i

the two fuel oil systems (common due to the proposed temporary )

re-alignment) thereby causing the other transfer pump to become l air bound and therefore incapable of providing fuel oil to'its diesel. This would leave two operable diesels. Although this scenario is possible, it is believed that declaring a diesel with a contaminated main storage tank inoperable is less conservative than re-aligning that diesel to an uncontaminated tank, for the following reason. Declaring a diesel inoperable and not re-aligning it to an uncontaminated tank removes that diesel from service. Should any single failure occur on any of the remaining three diesels, another diesel would be inoperable thereby leaving two operable diesels. During an emergency situation, it would be better to have four diesels available and being supplied by three

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. main storage tanks, than to have .three diesels M/ailable and- 1 being supplied by the.same number of tanks. Based on this, the most prudent course of action is to re-align the diesel with the

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contaminated tank to an uncontaminated tank, as.we have proposed in the attached-Technical Specification 3.9.B.6. The proposed specification would limit plant power operations in this condition-to seven days, and require conformance with appropriate

' surveillance and operability provisions for the diesel generators as specified in 3.9.B.6.

Lastly, in correspondence from the diesel vendor (Colt Industries-Fairbanks Morse) dated March 17, 1987, the vendor stated that "The fuel injection system of the Fairbanks Morse Model 3800TD8-1/8 diesel engine will tolerate particles under 3-5

-microns.as long as proper maintenance practices are maintained, such as changing the filter cartridge in use during annual '

inspections or whenever.the pressure differential across the filter exceeds 10 PSI". For this reason, particle sizes below 3.0 microns need not be considered in the acceptance criteria for engine operability.

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

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1. Involve a significant increase in the probability'or f/ 4 1

consequences of an accident previously evaluated; jTbe' l requested change will improve the fuel oil surveillance j program to ensure that an adequate supply of quality 1

fuel oil is maintained on-site in accordance with Regulatory Guide 1.137. Consequently, on-site emergency power reliability is improved, thereby reducing the probability and consequences of an accident. )

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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 of diesel fuel oil and fuel oil tanks. These tasks,  ;

performed in accordance with NRC guidance, will have no adverse effects on the station or any safety-related equipment, and consequently cannot initiate a new or ,;

different kind of accident.

3. Involve a significant reduccion in a margin of safety. 3 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

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the effect of enhancing the safety margin.

>z The Plant Operational Review Committee and the Nuclear Review Board have reviewed these proposed changes to the j

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, n Technic'al Specifications arad have concluded that they do not ,,

involve an.unreviewed safety question or a significant hazards consideration and will not elidanger the health and safety of the i n ,.

public. ,

/ ll Respectfully submitted, 'i PlfILADELPHIA ELECTRIC COMPANY f

e' By %p./ h_%J2bd O Vice President 4 '

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'y COMMONWEALTH OF PENNSYLVANIA.  :

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. COUNTY OF PHILADELPHIA  :

J. W. Gallagher,'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. Amendment to the November 24, 1986 Application for Amendment of Facility Operating Licenses DPR-44 and DPR-56 and knows the contents

- thereof ; . and .. tha t the' statements and matters set-forth therein are true and correct to the best of his knowledge, information and belief.

h b&M C.Vice Presid'ent s.

Subscribed and sworn to bef ore me t.his day .2 8*

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of Ouc . 1987 m d E U '})I b 1 n d $s:

Notaty Public JUDn~H Y. FRANKLIN Notsfy PubHc, Phila., Phila. C6.

My Commesion Empires July 26, W4 '

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-'- CERTIFICATE OF SERVIC24 j ',

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I hereby eqrtify that copies of the foregoing Amendment ,to November 24, 1986 Application were servedion the following by, deposit in tue United; states mail, fi;si.Mlass postage prep. aid, on this day of 1987 ,

Regional AdmirIistrator ' '

U.S. Nuclear Hegulatory Ccamission ' l Region 1 631 Park Avenue King of Prussia, PA 19406 T. P. Johnsc,nj Resident Inspector U. S. Nuclear Regulatory Commission Peach Bottom' Atomic Power Station P. O. Box ~>99 Delta, PA 17314 Mr. Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Fulton Bank Duilding,' 5tt) Floor Third fi Locu'sts Streets .'

Harrisburg, PA 17120 t

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IIugenff 3 ,p'radley

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Attorney for ,

' Philadelphia. Electric Company i

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