ML20248C738
| ML20248C738 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/22/1998 |
| From: | Berger C, Siefert G, Spivak A Public Service Enterprise Group |
| To: | |
| Shared Package | |
| ML20248C737 | List: |
| References | |
| 98-015, 98-015-R00, 98-15, 98-15-R, NUDOCS 9806020241 | |
| Download: ML20248C738 (13) | |
Text
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s J FORM NC.NA-AP.ZZ-0059-3
, 10 CFR 50.59 SAFETY EVALUATION Page 1 of 13 Revision 0 l 1.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for tne "B" Emergency Diesel Generator Applicability:
Salem 1 Salem 3 (Gas Turbine)
Salem 2 x Hope Creek Common to Salem 1 & 2 Common to Hope Creek & Salem COMPLETION AND APPROVAL Prsparer: fjkhu W))-/hd f Date W22/98 Peer Reviewer: C//n m h-
/., - $El/lT-
/.
Date [/22/4 e Approval: %c.Faec,a ss
/ f_ F~ Date 5/zz,/9 s Safety Evaluation No. 70-O/f SORC Review: K) Mtg. No. 3-634 Date E/24/ff Ap oval: [ j! _ 1 99
/ / /
Safety Evaluation and associated documepfation sent to Nuclear Review Board (NRB):
[UFSAR 17.2.1.1.2.1) SORC Presenter: Date:
1.0 10 CFR 50.59 Applicability Review - 10 CFR 50.59 applies because:
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FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Page 2 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator 1.1 The proposal changes the facility as described in the SAR.
YES NO x Explain:
The proposed change will temporarily extend the Allowed Out of Service Time (AOT) for the "B" Emergency Diesel Generator. The current AOT is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as detailed in TS 3.8.1.1. This change will extend the AOT an additional 7 days.
1.2 The proposal changes procedures as described in the SAR.
YES NO x l Explain:
The current procedures do not ds.>cribe the AOT for the EDG. The procedures describe the operability requirements and the transfer of fuel oil from the various tanks; however, this change does not change these procedures. The operating procedures are not specifically described in the
- SAR; however, general steps on the transfer and acceptance testing of oil are described in the SAR. The proposed change will not change these steps because the same transfer process and acceptance testing for the fuel oil will be followed.
1.3 The proposal involves a test or experiment not described in the SAR.
YES NO x Explain:
i The AOT for a EDG does not involve a test or an experiment. The tests I
which describe the testing of the EDG are not impacted by this change.
This change merely extends the time the station is allowed to continued to operate with an inoperable EDG.
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- FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION of 13 Page 3 Revision 0 I
l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015 i
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator 2.0 LICENSING BASIS DOCUMENTATION .
2.1 ' UFSAR REVISION DETERMINATION - Does the proposal require a UFSAR change?
YES NO x The SAR describes the plant condition where a EDG has less then its required capacity of EDG fuel oil.
UFSAR Change Notice No. dA 2.2 - TECHNICAL SPECIFICATION REVISION DETERMINATION - Docs the proposal require a Technical Specification change?
YES NO x.
The current TS allow the "B" EDG to be inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This change will extend the AOT an additional 7 days. However, because this change will be for a limited duration a permanent change to the TS is not being requested. In accordance with NRC Administrative Letter 95-05, a Notice of Enforcement Discretion (NOED) will be requested. A NOED requires a determination that the request does not constitute an Unreviewed Safety Question.
If a change is required, STOP. Contact Nuclear Licensing for assistance in preparation of a License Change Request.
Identify the pertinent Technical Specification sections that were reviewed to
' make the determination:
TS 3.8.1.1 Electrical Power Systems TS 4.8.1.1.2.f Electrical Power Systems - Surveillance Requirements TS 6.8.4.e Diesel Generator Fuel Testing Program Nuclear Common Rev.6
FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION of 13 Page 4 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator
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3.0. DESCRIPTION f I
3.1' Describe the modification or activity being evaluated and its expected I effects.
4 The proposed activity will temporarily extend the AOT for the "B" EDG.
This change is being requested because of corrective actions being taken by PSE&G h ensure fuel oil storage tank clean (ness. The fuel oil requirements are detailed in Section 6.8.4.e, " Diesel Generator Fuel Oil Testing Program."
Specifically, the "B" EDG was removed from service prior to its normally scheduled mainter;ance because of high particulate in the fuel oil. In accordance with the Diesel Generator Fuel Oil Testing Program, the fuel oil in the "D" fuel oil storage tank (FOST) was tested and did not satisfy the requirements of TS 6.8.4.e. The "D" tank was filled on May 21 and 22, 1998; however, after allowing for sufficient settling the oil in the "D" tank did not satisfy the critoria detailed in Section 6.8.4.e. This criteria . .; quires that 4 the particulate concentrate of the stored fuel be less than or equal to 10 mg/l after the fuel oil has tested through a filter with a 3 micron membrane.
1 The "C" and "D" FOSTs supply the "B" EDG. After the condition of the "D" FOST was discovered, the companion "C" FOST was sampled, and that tank did not satisfy the same criteria. The six FOSTs which supply the
, remaining 3 EDG's were sampled on May 21, and May 22,1998 and were ;
found in specification. Therefore, PSE&G believes this condition is limited ;
L to the "B" EDG.
L . The plan for cleaning the tanks will be to drain the "C" FOST, and clean and re-fill the "C" tank with oil meeting the TS requirements. During this iteration, the "D" FOST will be available. The oil in the "D" FOST did not L pass the criteria; however, further testing was performed on the oil in the L "D" tank. A test sample of the oil in the "D" tank was passed through a 5 micron filter, and analyzed. After filtering the sample, a test in accordance l with TS 6.8.4.e was conducted. The levels of particulate concentrate were found to be less than 3 mg/l. A 5 micron filter was selected because the EDG have an installed duplex 5 micron filter, and are designed to handle fuel particulate less than 5 micron.
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FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Page 5 of 13 Revision 0 1.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator The EDG vendor has confirmed that particulate'less than 5 microns will not impact EDG operation. Further, Amendment 100 to the Hope Creek Technical Specifications, states that particulate sizes less than 5 microns are not an issue.
After the "C" tank is cleaned, oil which has passed the test criteria detailed in TS 6.8.4.e, will be put in the "C" tank. The "C" tank will be returned to service, and the "D" tank will be drained. The "D" tank will then be cleaned ari re-filled with fuel oil that has passed the test criteria of TS 6.8.4.e.
To address this concern, PSE&G has elected to fully drain and clean the "C" and "D" FOSTs. This process will require 7 days. The AOT is scheduled to expire at 2020 on May 22,1998; therefore, a request for NOED is being pursued.
Despite not havir.g all 44,800 gallons of EDG fuel oil, fuel oil which will support operation of the EDG engine will be available on site, and one of the FOSTs will be available. The "B" EDG was run on May 22,1998 and the surveillance requirements (TS 4.8.1.1.2.a) were satisfied, except for quantity of fuel oil. The fuel oil which did not satisfy the TS 6.8.4.e criteria did not effect the operation of the "B" EDG during this run. This run was completed with fuel oil from the "D" FOST, and validates the assumption that the quality of the fuel will support operation of the EDG. The 5 micron installed fuel filters were monitored during the run and the differential pressure (dP) across these filters was acceptable.
In the event of a LOP during this extended AOT, the dP across the fuel filter will be monitored, and PSE&G will be prepared to swap filters and replace the fuel filter. The fuel filter high dP alarm annuciates locally, and has a common EDG trouble alarm in the main Control Room. The filter design is a duplex type which allows for quick realignment of the fuel supply to a new filter without interrupting flow. Filter change out after swap over is simple, I and spare filters are on site to address contingencies.
The remaining quantity of oil necessary to achieve 44,800 gallons will be delivered, transferred to the FOST and accepted during the additional 7 days.
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l FORM NC.NA-AP.ZZ-0059-3 i
. . 10 CFR 50.59 SAFETY EVALUATION Page 6 of 13 Revision 0 I
1.D. Numbers / Reference / Revision: Safety Evaluation # 98-015 1
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator 3.2 Identify the parameters and systems affected by the change.
The Emergency Diesel Generators, and its support systems, and the 4kV Emergency AC System are affected by this change.
3.3 Identify the credible failure modes associated with the change.
The credible failure modes associated with this change are a loss of off site power (LOP).
3.4 Provide references to location of information used for the Safety Evaluation.
TS 3.8.1.1 Electrical Power Systems TS 4.8.1.1.2.f Electrical Power Systems - Surveillance Requirements
' TS 6.8.4.e Diesel Generator Fuel testing Program Amendment 100 UFSAR Sections:
9.5.4 Standby Diesel Fuel Oil Storage and Transfer 1.2.1.2.17, Power Supplies 1.2.4.6.12 DG Fuel Oil Storage 1.8.1.137 Fuel Oil Systems 1.14.1.43_ DG Reliability 3.1.2.28 GDC 17 Electrical Power System.
Vendor Letter dated May 22,1998 3.5 Other Discussion if applicable.
None 4.0 USQ DETERMINATION -Is an Unreviewed Safety Question (USQ)
-involved?
'4.1 - - Which anticipated operational transients or postulated design basis accidents previously evaluated in the SAR are considered applicable to the proposal?
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FORM NC.NA-AP.ZZ.0059-3 t
10 CFR 50.59 SAFETY EVALUATION Page _,7 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator l
A Loss of Off Site Power is the anticipated operational translent which is assumed to occur either alone or concurrent with'a design bases accident.
4.2 May the proposal:
- a. Increase the probability of an accident previously evaluated in the SAR?
YES NO X DISCUSSION:
No, the EDG's are not accident initiators. The EDGs are used for I accident mitigation. The probability of a LOP is independent of the quantity of available fuel oil, and the AOT of a EDG.
- b. Increase the consequences of an accident previously evaluated in the SAR7 YES NO x DISCUSSION:
The consequences of an accident are unchanged by this proposal.
The "B" EDG would be available and have sufficient quantity of fuel oil to satisfy its load requirements for approximately 3 days. Either the "D" or "C" FOST will have at least 23,000 gallons of fuel oil. At the expected consumption rate, and with available quantity of fuel oil, the ,
diesel will run for approximately 3 days. Therefore, if a design bases accident with a concurrent LOP were to occur, the "B" EDG would start and accept load. The quantity of oil necessary to achieve the TS required 44,800 gallons could be provided to the engine before the i fuel oil currently available to the "B" EDG was exhausted. Sufficient fuel that has been sampled and in specification is available on site. ;
Plans are in place to have additional fuel delivered if required. Thus, i there would be no interruption of power to the Emergency 4kV busses, the design function of the EDG is satisfied, and the l
consequences of an LOP would be mitigated.
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4 FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Page 8 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel
- Generator Ac stated above, the oil for the "D" FOST ha,s been sampled and although it does not satisfy its sample requirements for particulate concentrate (<10mg/I, per TS 8.6.4.e) additional size sampling has determined that the majority of the particies were less than 5 micronc, which will not impact EDG operation.The proposed change will not:
- 1) Alter any assumptions previously made in evaluating the radiological consequences of any accident previously evaluated in the SAR.
- 2) Affect a fission product barrier.
- 3) Restrict access to vital areas.or otherwise impede actions tc mitigate the consequences of plant accidents.
Therefore, this proposal does not increase the consequences of an accident previously evaluated in the SAR.
4.3 What malfunctions of equipment important to safety that were previously evaluated in the SAR are considered applicable to the proposal?
The failure of EDG is considered applicable to this proposal.
~4.4 May the proposal:
- a. Increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR?
YES NO X DISCUSSION:
. The remaining three EDGs are unaffected by this change.
The probability of a malfunction of the EDG because of reduced fuel oil capacity is unchanged. The "B" EDG is available, and has sufficient fuel oil to run for approximately 3 days if required. In that period, additional fuel oil will be made availa' ole to support the "B" EDG. Thus, the probability of a malfunction of the EDG because of
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FORM NC.NA-AP.ZZ-0059-3 1 10 CFR 50.59 SAFETY EVALUATION Page 9 of 13 Revision 0 )
l.D. Numbers / Reference /Re/sion: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator the reduced capacity in the FOST fuel remains unchanged. Moreover, the extensive sampling of new fuel oil being' delivered as a result of this condition, elevates the confidence that the EDG will be supplied with fuel that meet Technical Specification Requirements.
In completing this analysis, manual actions (i.e., the delivery, transfer and acceptance of oil, monitoring dP across the fuel filter, transferring between fuel filters, and replacing fuel filters) are credited. As detailed in NRC Information Notice 97-78 the following issues must be oiscussed:
a) The specific operator actior.s required: The delivery of oil is being p' > formed by a qualified supplier and is therefore outside of the direct c atrol of PSE&G. The transfer and acceptance of the oil is within PSE&G control, and requires a series of steps. These steps are detailed in approved procedures and do not require heroic or extraordinary effort by the operators.
The monitoring, swapping and replacing of fuel filters are detailed in existing procedures and do not require heroic or extraordinary efforts by the operators.
b) The potentially harsh or inhospitable environmental conditions expected: There are no inhospitable conditions expected. These actions will be conducted in the outside environment, within the EDG
' bay, and under laboratory conditions. The weather conditions are not expected to impact the delivery and transfer of oil. The EDG bay is indoors, and there is no concern over inhospitable conditions. The L testing and acceptance of the oil is being completed under controlled L
laboratory conditions. A barge connection is available for filling the l FOSTs in extremely inclement (i.e., hurricane) weather.
l The monitoring, swapping and replacing of the fuel filters will be completed in the EDG bay. The fuel filter and housing will be hot because'of the heat of the operating engine. The operators will be prepared with appropriate personnel safety apparatus.
c) A General discussion of the ingress / egress paths taken by the operators to accomplish the functions: The operators are stationed Nuclear Common Rev.6
FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Page 10 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel 1 Generator at the EDG bay to complete the transfer of EDG oil, and filter activities.
Therefore, there is no concern over access 'or egress.
d) The procedural guidance for required actions: As discussed )
above, there are approved procedures to control the transfer and acceptance of the fuel oil and the fuel filter activities. These procedures do not require heroic actions by the operators.
e) The specific operator training necessary to carry out actions, including any operator qualifications required to carry out actions: There are no special operator training requirements to transfer fuel, and to complete the filter activities. The acceptance testing of the oil will be completed by qualified technicians. The technicians have completed training as part of their normal qualifications.
f) Any additional support personnel and/or equipment required by the operator to carry out action: No special equipment is required to transfer the oil. The acceptance test requires standard laboratory equipment. As stated above, the operators may require personnel safety apparatus to replace the filter. This apparatus will be available.
g) A description of information required by the control room to determine whether such operator action is required, including qualified instrumentation used to diagnose the situation, and to ;
verify the required action has been successfully taken: These actions are on going and the control room is being kept informed of the status of the EDG fuel oil supply.
h) The ability to recover from credible errors in performance of manual actions, and the expected time required to make such a recovery: A spill of oil during the transfer is not likely however it is considered a credible accident. There are spill recovery procedures, and spill mitigation devices (i.e., dikes and booms) available. The l' recovery time for a spill is based on the quantity of oil; however, if a spill did occur additional replacement oil could be delivered, transferred and accepted.
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FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Page 11 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator in addition, in the event of a LOP, there will,be approximately three days before actions are required to fill the tank. This is sufficient time to address any credible errors that may occur.
l) consideration of the risk significance of the proposed operator actions: These actions are normal activities for the operators and do not represent en undue risk to plant personnel, or the public.
- b. Increase the consequences of a malfunction of equipment important to safety previously evaluated in the SAR7 YES NO x DISCUSSION:
The consequences of a EDG failure remain unchanged. The "B" EDG will start as required in response to a LOP. The "B" EDG is considered available; however, it is not operable because of the reduced quantity and quality of fuel oil. The fuel oil level and quality will be restored to its TS limits within the requested extended AOT.
The SAR has evaluated the consequences of a loss of a EDG and found it to be acceptable. The change in the AOT for the "B" EDG does not impact this analysis.
The proposed change will not:
- 1) Alter any assumptions previously made in evaluating the radiological consequences of any a malfunction of equipment important to safety previously evaluated in the SAR
- 2) Affect a fission product barrier.
- 3) Restrict access to vital areas or otherwise impede actions to mitigate the consequences of plant accidents.
Therefore, this proposal does not increase the consequences of any a malfunction of equipment important to safety previously evaluated in the SAR.
Nuclear Common Rev.6
FORM NC.NA-AP ZZ-0059-3
, 10 CFR 50.59 SAFETY EVALUATION
. Page 12 of 13 Revision 0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator 4.5 May the proposal:
- a. Create the possibility of an accident of a different tvoe from any previously evaluated in the SAR7 YES NO x DISCUSSION:
The possibility of an accident of a different type is unaffected by the extension of the AOT of the "B" EDG due to reduced fuel oil capacity, because no accident precursors are affected.
- b. Create the possibility of a malfunction of a different tvoe from any previously evaluated in the SAR?
YES NO x DISCUSSION:
The AOT for the "B" EDG does not affect the possibility of a malfunction of a different typa. A EDG failure is analyzed in the SAR.
4.6 Qogg the proposal reduce the margin of safety as defined in the basis for any Technical Specifications?
YES- NO x The margin of safety as defined in the TS Bases is unaffected by the AOT for the "B" EDG.
The requirement for a 7 day supply of oil is based on the availability of replacement fuel oil, and the ability to deliver the oil to the site. The availability and deliverability of the oil does not impact any safety limit i
During the AOT extension, even though the fuel oil specification may not comply with the technical specification recommended values, it has been
. demonstrated by sampling and through diesel generator runs that there is no detrimental impact on diesel generator operation. The intent of the Nuclear Common Rev.6 L_______m._____.-_..-____m_ _ _ _ _
FORM NC.NA-AP.ZZ-0059-3
~ ~ 10 CFR 50.59 SAFETY EVALUATION
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Page 13 of 13 Revision 0 I
l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel f Generator
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bases of the technical specification has been satisfied, and hence there is ~
no reduction in any margin of safety. -
Therefore, the margin of safety remains unchanged.
5.0 10 CFR 50.59(b)(2) Report The proposed activity will temporarily extend the AOT for the "B" EDG.
This change is being requested because of corrective actions being taken by PSE&G to ensure fuel oil storage tank cleanliness. The fuel oil requirements are detailed in Section 6.8.4.e, " Diesel Generator Fuel Oil Testing Program.'
Specifically, the "B" EDG was removed from service prior to its normally scheduled maintenance because of high particulate in the fuel oil. In acccrdance with the Diesel Generator Fuel Oil Testing Program, the fuel oil in the "D" fuel oil storage tank (FOST) was tested and did not satisfy the requirements of TS 6.8.4.e. The "D" tank was filled on May 21 and 22, 1998; however, after allowing for sufficient settling the nil in the "D" tank did not satisfy the criteria detailed in Section 6.8.4.e. This criteria requires that the particulate concentrate of the stored fuel be less than or equal to 10 mg/l after the fusi oil has tested through a filter with a 3 micron membrane.
6.0 CONCLUSION
If ALL answers in Section 4 are "N_Q," the proposal does NOT involve a USQ.
If ANY answer in Section 4 is "YES," the proposal involves a USQ.
Is a USQ involved?
l YES NO x Nuclear Common Rev.6
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