ML20248C731

Requests Regional Enforcement Discretion from Provisions of TS 3.8.1.1,for Extension of 7 Days for B EDG Aot.Rev 0 to 10CFR50.59 Safety Evaluation Encl

ML20248C731
Person / Time
Site:	Hope Creek
Issue date:	05/22/1998
From:	Bezilla M Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248C737	List: ML20248C731 ML20248C738
References
LR-N98272, NUDOCS 9806020240
Download: ML20248C731 (11)

Text

I O PSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit May 22,1998 LR-N98272 I

United States Nuclear Regulatory Commission 3

Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR ENFORCEMENT DISCRETION TECHNICAL SPECIFICATION 3.8.1.1 DIESEL GENERATOR ALLOWED OUTAGE TIME HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NO. 50-354 1

I Public Service Electric and Gas Company (PSE&G) hereby requests Regional

~ Enforcement Discretion from the provisions of Technical Specification (TS) 3.8.1.1, "AC l

Sources - Operating."

As discussed in Attachment 1 to this letter, PSE&G concludes that granting this request would not be a potential detriment to the public health and safety and would involve neither an unreviewed safety question, a significant hazards consideration nor any adverse environmental consequences.

PSE&G is requesting enforcement discretion for an extension of 7 days for the "B" Emergency Diesel Generator (EDG) allowed outage time (AOT) specified in TS 3.8.1.1.

In view of the current circumstances, PSE&G has concluded that there would be no safety benefit from a plant shutdown in accordance with Technical Specification 3.8.1.1 Granting this enforcement discretion would allow for the completion of the appropriate restoration of the EDG *B" fuel oil supply while the plant remains on-line and would not jeopardize public health and safety.

l The requested duration of this enforcement discretion is 7 days, beginning at 2020 hours0.0234 days <br />0.561 hours <br />0.00334 weeks <br />7.6861e-4 months <br /> on May 22,1998 and lasting until 2020 hours0.0234 days <br />0.561 hours <br />0.00334 weeks <br />7.6861e-4 months <br /> on May 29,- 1998. Absent the

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exercise of enforcement discretion, TS 3.8.1.1 requires the station to be in HOT

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k SHUTDOWN by 0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />, on May 23,1998.

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9eo6o20240 990522 PDR P

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95-2168 REV 6/94

____._______________._____________._____.___________o

j Document Control Desk May 22,1998 LR-N98272 '

PSE&G understands that, if granted, the requested enforcement discretion is for the

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conditions described in this request. For any other conditions that would cause an Emergency Diesel Generator to become inoperable, the appropriate Technical Specification action statement would apply.

- if you have any questions concerning this request, we will be pleased to discuss them with you.

Sincerely,

,s M. B. Bezill General Manager -

Hope Creek Operations Attachments (2)

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Document Control Desk May 22,1998 LR-N98272' l

C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Pindale (X24)

USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box 415 Trenton, NJ 08625

Document Control Desk May 22,1998 LR-N,98272.

PRD BC Senior Vice President - Nuclear Engineering (N19)

General Manager - Hope Creek Operations (H07)

Director - Quality / Nuclear Training /EP (X01)

Manager - Financial Control & Co-Owner Affairs (N07)

Manager - Hope Creek Operations (H01)

Director-System Engineering (H18)

Director-Design Engineering (N23)

Manager - System Engineering - Hope Creek (H18)

Manager-Nuclear Review Board (N38)

Director - Licensing / Regulation & Fuels (N21)

Hope Creek Licensing Manager (N21)

J. J. Keenan, Esq. (N21)

Records Management (N21)

NBS Room (N64)

Microfilm Copy Files Nos.

1.2.1 (Hope Creek) 2.10

ATTACHMENT 1 REQUEST FOR ENFORCEMENT DISCRETION FACILITY OPERA'a.

lCENSE NPF-57 HOPE CREEK GENERATING STATION This request for enforcement discretion includes the following information pursuant to NRC inspection Manual Part 9900: Operations - Notices of Enforcement Discretion.

1. THE TECHNICAL SPECIFICATION OR OTHER LICENSE CONDITIONS THAT WILL EE VIOLATED Technical Specification (TS) 3.8.1.1.b will be violated during the period of requested enforcement discretion.

TS 3.8.1.1.b requires that the Limiting Condition for Operation (LCO) be met for the Emergency Diesel Generators (EDGs), except as provided in the associated ACTION requirements. Since the EDG "B" Fuel Oil Storage Tanks contain less thar; the required 44,800 gallons of fuel, EDG "B" is inoperable. The ACTION statement associated with this TS requires the plant to be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the inoperable diesel generator cannot be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2. THE CIRCUMSTANCES SURROUNDING THE SITUATION, INCLUDING ROOT CAUSES, THE NEED FOR PROMPT ACTION AND IDENTIFICATION OF ANY RELEVANT HISTORICAL EVENTS:

At 2020 hours0.0234 days <br />0.561 hours <br />0.00334 weeks <br />7.6861e-4 months <br /> on May 19,1998, EDG "B" was declared inoperable due to higher than allowed particulate concentrations in FOSTs "C" and "D". As stated in TS 6.8.4.e, " Diesel Fuel Oil Testing Program," the particulate concentration limit for stored fuel oil is 10 mg/l when tested in accordance with ASTM D-2276. TS 6.8.4.e permits the 0.8 micron membrane filter specified in ASTM D-2276 to be replaced with filters up to 3.0 microns. Each EDG has a set of two storage tanks. The system includes a 40-micron particle retention duplex strainer on the diesel fuel oil pump suction header, and a 5-micron particio retention duplex filter on the pump discharge header.

Testing for particulate concentration was performed for the other FOSTs. All other FOSTs were found to meet the TS requirement for particulate concentration. EDG's "A", "C" and "D" are OPERABLE. The FOSTs for EDG "B" were drained and FOST "D" was refilled. The particulate concent ation in FOST "D" remains greater than _ - _ _ _ _ _ _

f LR-N98272 the 10 mg/l limit. However, additional testing has shown that the concentration of particulate greater than 5 microns is less than 10 mg/l. The smallest filter in the diesel fuel oil system is 5 microns. EDG "B" was tested and operated successfully with fuel oil supplied from FOST "D". Thus, while the fuel supply for EDG "B" does not currently meet the TS requirements for particulate concentration, EDG "B" is available and capable of performing its required functions. In addition, the EDG vendor confirmed that particulate less than 5 microns will not adversely affect EDG operation.

At the surveillance interval specified in the Diesel Fuel Oil Testing Program (92 days), each FOST is sampled and tested for particulate concentration. Prior to May 19,1998 all particulate concentration sample results were acceptable. The suspected cause for the high parti:ulate concentration found in FOSTs "C" and "D" is a tank truck of fuel oil received in January 1998 which was addad principally to FOSTs "C" and "D". PSE&G specifies that fuel oil for the Hope Creek EDGs be supplied by the vendor with a particulate concentration that does not exceed 10 mg/l. However, receipt testing for particulate concentration in new fuel oil was not performed.

Sufficient time is not available to clean and refill the FOSTs for EDG "B" within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TS ACTION Statement allowed outage time. Therefore, the 7 day enforcement discretion is requested.

3. THE SAFETY BASIS FOR THE REQUEST, INCLUDING AN EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE PROPOSED COURSE OF ACTION. THIS EVALUATION SHOULD INCLUDE AT LEAST A QUALITATIVE RISK ASSESSMENT DERIVED FROM THE LICENSEE'S PRA:

The diesel generator fuel oil storage and transfer system provides sufficient onsite storage of fuel oil for the EDGs to support continuous operation under full operating loads such that standby (onsite) electric power supply is available in case of loss of offsite power (LOP) and/or design basis accident (DBA).

During the 7 day period of enforcement discretion, the EDG "B" will remain capable of performing its function. The current level of fuel oil for EDG "B" will support approximately 3 days of fullload operation. In addition, operator actions described in the NRC Safety Evaluation Report (SER) for Hope Creek License Amendment No. 59 can be performed to provide additional fuel oil to EDG "B" under post-transient conditions, if required. Surveillance testing of EDG "B" performed on May _ _ _ _

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LR-N98272 l

22,1998 verified that it is capable of starting and loading in accordance with Surveillance Requirement (SR) 4.8.1.1.2.

Required operator actions to support continued EDG operation are not performed in harsh or inhospitable conditions. The actions required to support continued operation of EDG "B" are the same as those required for the other EDG's. The radiological conditions after 3 days are not expected to be significantly different than after 7 days and will not affect operator actions.

i The increase in risk to core damage and to the public is insignificant. The basis for this judgment is the relatively short duration of the extended AOT and the continued availability of EDG "B" to mitigate design basis events as described in the Hope Creek Updated Final Safety Analysis Report (UFSAR). A qualitative assessment of risk derived from the Hope Creek PRA indicates that the increase in risk due to the requested AOT extension is comparable to the probability of core damage associated with a manual shutdown of the plant.

4. THE BASIS FOR THE LICENSEE'S CONCLUSION THAT THE NONCOMPLIANCE WILL NOT BE OF POTENTIAL DETRIMENT TO THE PUBLIC HEALTH AND SAFETY AND THAT NEITHER AN UNREVIEWED SAFETY QUESTION NOR A SIGNIFICANT HAZARD CONSIDERATION IS INVOLVED:

i Determination of No Significant Hazards Consideration This proposed enforcement discretion:

Does not involve a significant increase in the probability or consequences of any accident or malfunction of equipment important to safety previously.

evaluated.

During the 7 day enforcement discretion period, EDG "B" will remain capable of performing its required safety functions. An additional 7 days to enter HOT

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SHUTDOWN would not significantly increase the probability or consequences of an accident previously evaluated, since the capability of the diesel generator to automatically start, synchronize and load is maintained for the enforcement discretion period. Therefore, the enforcement discretion for TS 3.8.1.1 will not significantly increase the probability or consequences of any accident previously evaluated. -_

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Does not create the possibility of a new or different kind of accident from I

any previously evaluated.

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EDG "B" will remain capable of performing its required safety functions. An

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additional 7 days to enter HOT SHUTDOWN would not create the possibility of a new or different kind of accident from any previously evaluated.

Does not involve a significant reduction in a margin of safety.

For the duration of the requested enforcement discretion, EDG "B" will remain available and functional. Additional supplies of fuel oil are on site and will support continuous EDG "B" operation if required. The EDG vendor has confirmed that pak ticulates less than 5 microns will not impact EDG operation.

Analysis using 5 micron filters showed concentration levels < 10 mg/l. If required, EDG fuel filters and strainers can be replaced while the EDG is operating.

Since EDG "B" operation is not adversely affected by the conditions of the current fuel supply, the requested enforcement discretion involves no significant reduction in the margins of safety as discussed in the bases for the Technical Specif; cations.

An unreviewed safety question (USQ) evaluation has been completed and is appended as Attachment 2. The USQ evaluation determined that there is no USQ involved in the granting of the requested enforcement discretion.

' 5. THE BASIS FOR THE LICENSEE'S CONCLUSION THAT THE NONCOMPLIANCE WILL NOT INVOLVE ADVERSE CONSEQUENCES TO THE ENVIRONMENT:

The requested enforcement discretion does not cause any increase in effluents that may be released offsite, does not involve an increase in radiation exposure to the public, and does not involve a Significant Hazards Consideration. Therefore, the request does not involve any irreversible environmental consequences.

6. ANY PROPOSED COMPENSATORY MEASURES:

EDG "B" will remain available for the duration of the requested enforcement discretion. Additional supplies of fuel oil will be maintained on site to suppod.

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LR-N98272 l

continuous operation of EDG "B"if required. Extremely adverse wind, weather and tidal conditions at the Hope Creek site that could interfere with additional fuel oil deliveries are not expected for the duration of the requested enforcement discretion.

However, in the event of a National Weather Service hurricane, tornado, or tropical storm alert for the Artificial Island area, procedures are in place which require PSE&G to order a fuel shipment to top off all the diesel fuel oil tanks.

Procedures are in place and equipment is pre-staged to permit the transfer among FOSTs if required to support continuous operation in the event of an EDG failure.

The minimum volume of fuel oil required by Technical Specifications will be maintained on site for the duration of the requested enforcement discretion.

New fuel oil supplies will be sampled and tested for particulate concentration before addition to any FOST.

No elective work that has the potential to adversely affect plant electrical systems will be performed during the duration of the requested enforcement discretion.

PSE&G has confirmed that four spare fuel oil filters are on site to support EDG "B" availability. An order for additional filters is being expedited and is expected on site May 24,1998.

7. THE JUSTIFICATION FOR THE OURATION OF THE NONCOMPLIANCE The time necessary to clean and refill the FOSTs for EDG "B"is greater than the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time specified in TS 3.8.1.1 An additional 7 days will provide sufficient time to complete the tank cleaning and refilling. Based upon the continued availability of EDG "B" and the availability of additional supplies of fuel oil, the impact of the requested 7 day extension upon core damage frequency is insignificantly small and the increase in risk to the public is negligible.

8. A STATEMENT THAT THE REQUEST HAS BEEN APPROVED BY THE FACILITY ORGANIZATION THAT NORMALLY REVIEWS SAFETY ISSUES (PLANT ONSITE REVIEW COMMITTEE, OR ITS EQUIVALENT):

This request has been reviewed and approved by the Hope Creek Station Operations Review Committee, which normally reviews safety issues. _ _ _ _ _

LR-N98272

9. THE REQUEST MUST SPECIFICALLY ADDRESS HOW ONE OF THE NOED CRITERIA FOR APPROPRIATE PLANT CONDITIONS SPECIFIED IN SECTION B IS SATISFIED:

Enforcement discretion is being requested to avoid an undesirable transient (p! ant shutdown) as a result of forcing compliance with the license condition (72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for EDG "B"). Continued plant operation for a 7 day period with less than the required 7 day supply of fuel oil results in minimal potential safety consequences and reduces operational risks.

10 lF A FOLLOW UP LICENSE AMENDMENT IS REQUIRED, THE NOED REQUEST MUST INCLUDE MARKED-UP TS PAGES SHOWING THE PROPOSED TS CHANGES. THE ACTUAL LICENSE AMENDMENT REQUEST MUST FOLLOW WITHIN 48 HOURS:

This request is for a noncompliance of short duration. A TS change is impractical because Hope Creek will return to compliance with the existing license requirement before a license amendment could be isaued.

11.A STATEMENT THAT PRIOR ADOPTION OF APPROVED LINE-ITEM IMPROVEMENTS TO THE TS OR THE ITS WOULD NOT HAVE OBVIATED THE NEED FOR THE NOED REQUEST:

Pnor adoption of the Improved Technical Specifications (ITS) would not have obvsted the need for this request. The Hope Creek EDG fuel oil testing requirements are consistent with those contained in Specification 5.5.10 of NUREG-1433, " Standard Technical Specifications General Electric Piants, BWR/4 (STS).

Testing for particulate is performed once per 92 days instead of once per 31 days specified in the STS.

12. ANY OTHER INFORMATION THE NRC STAFF DEEMS NECESSARY BEFORE MAKING A DECISION TO EXERCISE ENFORCEMENT DISCRETION:

None at this time. _ - _ _ _ _

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ATTACHMENT 2 UNREVIEWED SAFETY QUESTION EVALUATION _ _ - _ _ _ _