ML20248F251
| ML20248F251 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/27/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H Public Service Enterprise Group |
| References | |
| NOED-98-1-004, NOED-98-1-4, NUDOCS 9806040170 | |
| Download: ML20248F251 (12) | |
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May 27,1998 Mr. Harold W. Keiser Executive Vice President l Nuclear Business Unit -
Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION FOR PUBLIC SERVICE ELECTRIC AND GAS COMPANY REGARDING HOPE CREEK NUCLEAR GENERATING STATION (NOED No. 98-1-004)
Dear Mr. Keiser:
By letter dated May 22,1998 (Enclosure 1), you requested that the NRC exercise discretion by not enforcing compliance with the actions required in Hope Creek Technical Specification Action Statement (TSAS) 3.8.1.1. That letter documented information -
i previously discussed with the NRC in a telephone conversation held at approximately 2:30 p.m., on May 22,1998. During the teleconference you stated that on May 19,1998, at '
8:20 p.m., Public Service Electric and Gas (PSE&G) Company discovered that Technical Specification (TS) 6.8.4.e regarding the Diesel Fuel Oil Testing Program had not been met.
This TS specified requirements for particulate concentration within diesel fuel oil (FO) and required that particulate concentration not exceed 10 mg/L when filtered by'a 3.0 micron filter (maximum size) per ASTM D-2276. Since the diesel FO did not meet specification in both of the storage tanks for the 'B' emergency diesel generator (EDG), the EDG was declared inoperable and actions were initiated to return the FO to specification. TS 3.8.1.1 required the affected EDG to be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In order to preclude the plant shutdown required by the TSAS, you requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC'.s policy regarding Exercise -
of Discretion for an operating facility, set out in Section Vll.c, of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period beginning at 8:20 p.m., on May 22,1998, and ending not later than 8:20 p.m., May 29,1998. PSE&G determined that the 'B' EDG was capable of '
l performing its intended function, despite the non-conforming fuel oil, and that the enforcement discretion would not be inconsistent with protecting public health and safety.
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-The_NRC's basis for the discretion considered many factors, primarily, the availability of the required volume of FO on-site (in-situ storage and tanker. trucks) to meet the TS minimum required volume of 44,800 gallons; the availability of new, clean 5 micron filters that could be used to replace clogged filters while operating the EDG with elevated particulate levels; vendor confirmation that particulate of up to 5 microns in size would not adversely affect EDG operation,~and the elimination of any planned maintenance that t
could directly or indirectly impact the electrical distribution system.
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Mr. Harold W. Keiser -
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Additionally, PSE&G determined, based on analysis of the plant's Probabilistic Risk l
Assessment, that risk of extending the allowed outage time by seven days (even assuming the EDG to be unavailable) was comparable to the risk in shutting down the plant. PSE&G
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considered the possibility of significant hazards associated with this period of noncompliance with TS and determined that there were no significant hazards.
l PSE&G agreed to the following compensatory measures during the period of l
noncompliance: the 'B' EDG will remain avaiiable with additional supplies of FO on-site to i
support continuous operation, if adverse weather conditions are likely (though not currently predicted by the National Weather Service) additional FO shipments will be ordered to top i
off all FO storage tanks, procedures and equipment are in place to transfer FO between storage tanks to support continuous EDG operation, no elective work will be performed l
that could adversely impact the electrical distribution system, new FO supplies will be l
sampled before addition to EDG storage tanks, and four spare oil filters are on-site to l
support 'B' EDG availability with additional filters expected on-site by May 24,1998.
On the basis of the staff's evaluation of your request, the staff concluded that an NOED was warranted because we are clearly satisfied that this action involved minimal or no L
safety impact and had no adverse radiologicalimpact to the public's health and safety.
Therefore, we have exercised discretion not to enforce compliance with TSAS 3.8.1.1 for the period from 8:20 p.m. on May 22,1998 to 8:20 p.m. on May 29,1998. This letter documents our telephone conversation on May 22,1998, when we verbally issued this notice of enforcement discretion at 3:45 p.m.
As stated in the Enforcement Policy, the NRC will normally take action, to the extent that l
violations were involved, for the root cause that led to the noncompliance for which this l
NOED was necessary.'
Sincerely, Original Signed By:
Charles W. Hehl, Director l
Division of Reactor Projects Docket No. 50-354 i
NOED No. 98-01-004
Enclosure:
Enclosure 1 t
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Mr. Harold W. Keiser -
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' cc w/ encl:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
- J. A. Isabella, Manager, Joint Generation Atlantic Electric.
M. Bezilla, General Manager - Hope Creek Operations J. McMahon, Director - Quality Assurance & Nuclear Safety Review l
D. Powell, Director - Licensing, Regulation and Fuels R. Kankus, Joint Owner Affairs A. C. Tepert, Program Administrator Jeffrey J. Keenan, Esquire Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township State of New Jersey State of Delaware 1
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s Mr. Harold W. Keiser 4
Distribution w/ encl:
Region 1 Docket Room (with concurrences)
Nuclear Safety Ir: formation Center (NSIC)
NRC Resident inspector PUBLIC
- H. Miller, RA/W. Axelson, DRA (irs)-
B. Boger, NRR J. Goldberg, OGC J. Lieberman, OE D. Holody, EO, RI j
J. Linville, DRP S. Barber, DRP L. Harrison, DRP C. O'Daniell, DRP Distribution w/ encl: (Via E-Mail)
B. McCabe, OEDO R. Capra, PDI-2, NRR R. Ennis, Acting PM, NRR i-Inspection Program Branch, NRR (IPAS)
R. Correia, NRR F. Talbot, NRR DOCDESK
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DOCUMENT NAME: G:\\ BRANCH 3\\NOED.HC T3 receiwo e copy of this document. Indicate in the box: "C" = Copy without ttachment/en losure
'E" = Copy with attachment / enclosure
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DATE 05/26/98 05fD98 J 05/1',198 05/f198 05/ /98 OFFICIAL RECORD COPY k
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"v i e i + 3 3' u DPSEG emsm Pubile Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit May 22,1998 h
LR-N98272 f d @4R United States Nuclear Regulatory Commission Document Control Desk 4 Q Washington, DC 20555
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Gentlemen:
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REQUEST FOR ENFORCEMENT DISCRETION TECHNICAL SPECIFICATION 3.8.1.1 DIESEL GENERATOR ALLOWED OUTAGE TIME I
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HOPE CREEK GENERATING STATION y 3 FACTUTY OPERATING LICENSES NPF-57 2 :-- 't o DOCKET NO. S0-354 I @ [ j Ea 6
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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 Sources - Operating."
As discussed in Attachment 1 to this letter, PS'E&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 discretica 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.
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 exercise of enforcement discretion, TS 3.8.1.1 requires the station to be in HOT 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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Document Control Desk May 22,1998 LR-N98272 PSE&G understands that, if granted, the requested enforcement discretion is for the 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, M. B. Bezill i
General Manager-Hope Creek Operations Attachments (2) f i
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i Document Control Desk LR-N98272 May 22,1998 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 O. 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 l
Mr. K. Tosch, Manager IV Sureau of Nuc, lear Engineering P.O. Box 415 Trenton, NJ 08625 6
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I Document Control Desk 4-LR-N98272 May 22,1998 PRD
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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)
Manager - System Engineering - Hope Creek (H18)
Manager - Nuclear Review Board (N38)
Director - Licensing / Regulation & Fuels (N21)
I Hope Creek Licen. Mag Manager (N21)
J. J. Keenan, Esq. (N21)
Records Management (N21)
NBS Room (N64) l Microfilm Copy Files Nos.1.2.1 (Hope Creek) l l
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ATTACHMENT 1 REQUEST FOR ENFORCEMENT DISCRETION FACILITY OPERATING LICENSE NPF-67 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.
I
- 1. THE TECHNICAL SPECIFICATION OR OTHER LICENSE CONDITIONS T WILL BE 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 than 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:
l 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
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6.8.4.e, " Diesel Fuel Oil Testing Program," the particulate concentration linlit for t
ctored 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 particle 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" wers drained and FOST "D* was refilled. The particulate concentration in FOST "D" remains greater than u m... -.,, -
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the 10 mg/l limit. However, additional testing has shown that the concentration of
. particulate g'reater 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 rneet 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 intervai 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 particulate concentration found in FOSTs "C" and "D" j
is a tank truck of fuel oil received in January 1998 which was added principally to i
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 doeis not exceed 10 mg/1. However, receipt testing for particulate concentration in new fuel oil was not performed.
Sufficient time is not available to clean and refill the FOST s for EDG "B" 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 SAFE 1Y SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF PROPOSED COURSE OF ACTION. THIS EVALUATION SHOULD INCLU LEAST A QUALITATIVE RISK ASSESSMENT DERIVED FROM THE L PRA:
The diesel generator fuel oil storwge and transfer syctem provides sufficient onsite 1
i 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).
Du$N the 7 day period of enforcement discretion, the EDG "B" will remain capable of peiforming its function. The current level of fuel oil for EDG *B" will support approximately 3 days of full load 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 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 expect,ed to be significantly different than after 7 daysi and will not affect operator actions.
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 cdended 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 HEALTH AND SAFETY AND THAT NEITHER AN UNREVIEWED SA QUESTION NOR A SIGNIFICANT HAZARD CONSIDERATION IS IN 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 SHUTDOWN would not significantly increase the probability or consequences o 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 81 1 will not significantly increase the probability or consequences of any accident prev evaluated. - _ - _ _
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LR-N98272 Does not create the possibility of a new or different kind of accident from any previously evaluated.
EDG "B" will remain capable of performing its required safety functions. An 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 ir; 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 particulate 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 Specifications.
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 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 support -___-
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LR-N98272 continuous operation of EDG "B" if required. Extremely adverse wind, weather and tidal condillons 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 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 Specification,ns 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 DURATION OF THE NONCOMPLIAN 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.
B. 'A STATEMENT THAT THE REQUEST HAS BEEN APPROVED ORGANIZATION THAT NORMALLY REVIEWS SAFE'iY ISSUES 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. - _ -
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' IS SATISFIED: CRITERIA FOR APPROPRIATE PLANT CON Enforcement discretion is being requested to avoid an undesirable transient (
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 w 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 REQU MUST INCLUDE MARKED-UP TS PAGES SHOWING THE PROPO CHANGES. THE ACTUAL LICENSE AMENDMENT REQUEST MU
. WITHIN 48 HOURS:
This request is for a noncompliance of short duration. A TS change is impracti because Hope Creek will return to compliance with the existing license require before a license amendment could be issued.
11.A STATEMENT THAT PRIOR ADOPTION OF APPROVED LINE-ITE
- IMPROVEMENTS TO THE TS OR THE ITS WOULD NOT HAV NEED FOR THE NOED REQUEST:
l Prior adoption of the improved Technical Specifications (ITS) would not have obylated the need for this request. The Hope Creek EDG fuel oil testing requirements are consistent with those contal'ned in Specification 5.5.10 of NUREG l
1433, " Standard Technical Specifications General Electric Plants, BWR/4 (
Testing for particulate is performed once per 92 days instead of once per 3 specified in the STS.
12.ANY OTHER INFORMATION THE NRC STAFF DEEMS NEC MAKING A DECISION TO EXERCISE ENFORCEMENT DISCRET None at this time.
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ATTACHMENT 2 DNREVIEWED SAFETY QUESTION EVALUATI 4
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1.D. Numbers / Reference / Revision:
Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator j
Applicability:
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Salem 1 Salem 3 (Gas Turbine) l I
Salem 2 x
Hope Creek Common to Salem 1 & 2 Common to Hope Creek & Salem COMPLETION AND APPROVAL
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Preparer. f uj J.-hdf Date W22/98 PeerReviewer 0;ct m og
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Approval:
W Fhso m se f_ r Date _ S/m/9e Safety Evaluation No.
78-0/6~
SORC Review R)
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9f-438 Date E/M/M royal:
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Safety Evaluation and associated docum tion sent to Nuclear Review Board (NRB):
[UFSAR 17.2.1.1.2.1]
SORC l
Presenter:
Date:
1.0 10 CFR 50.59 Applimbility Review - 10 CFR 50.59 applies because:
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Nuclear Common Rev.6
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I l.D. Numbers / Reference / Revision:
Safety Evaluation # 98-015 l
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel l
Generator 1.1 The proposal changes the facility as described in the SAR.
1 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 i
additional 7 days.'
I 1.2 The proposal changes procedures as described in the SAR.
YES NO x
Explain:
i i
The current procedures do not describe 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 seceptance, testing of oil are described in the SAR. The proposed change will rat change these steps because the same tra'nsfer 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:
The AOT for a EDG does not involve a test or an experiment. The tests which describe the testing of the EDG are not impacted by this change.
I This change merely ?xtends the time the station is allowed to continued to operate with an inoperable EDG.
Nuclear Common Rev.6
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- eseum FORM NC.NA-AP,ZZ-0069-3 10 CFR 50,59 SAFETY EVALUATION Page 3
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1.0, Numbers / Reference / Revision:
Safety Evaluation # 98415 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, i
UFSAR Change Notice No. 6fA 2.2 TECHNICAL SPECIFICATION REVISION DETERMINATION - Does 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 9545, 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.8
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FORM NC.NA-AP.ZZ 0059-3 10 CFR 50.59 SAFETY EVALUATION PAtga 4
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___0 l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "B" Ernergency Diesel Generator
3.0 DESCRIPTION
~
l 3.1 Describe the modification or activity being evaluated and its expected i
effects.
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 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 criteria detailed in Section 8.8.4.e. This criteria requires that the particulate concentrate of the stored fuel be less than or equal to 10 mg/l after the fuel oil has tested through a filter with a 3 micron membrane.
The "C" and "D" FOSTs supply the "B" ED.G. 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 to the "B" EDG.
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 oli in the "D" FOST did not pass the criteria; however, further testing was performed on the oil in the "D" tank. A test sample of the oil in the "D" tank was passed through a S micron filter, and analyzed. After filtering the sample, a test in accordance 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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lW FORM NC.NA-AP.ZZ 0059-3 10 CFR 60.69 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" E
_ Generator sel The EDG vendor has confirmed that particulate less than 5
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not impact EDG operation. Further, Amendment 100 to th ns will Technical Specifications, states that particulate sizes less th are not an issue.
microns After the "C* tank is cleaned, oil which has passed the test crit in TS 6.8.4.e. will be put in the "C" tank. The *C" tank will be eria detailed service, and the "D" tank will be drained. The "O" tank will th retumed to and re-filled with fuel oil that has passed the test criteria of eaned
'C' and "p" FOSTs, This process will requ c ean the scheduled to expire at 2020 on May 22,1998; therefore a re s
NOED is being pursued.
Despite not having all 44,800 gallons of EDG fuel oil fuel oil the FOSTs will be available. The "B" EDG was which will one of the surveillance requirements (TS 4.8.1.1.2.a) were satisfied ay 22,1998 and did not effect the operation of the "B" EDG d
, except for ra that the qual.ity of the fuel will support oper s run was installed fuel filters were monitored during the run a'nd the dif e 5 micron pressure (dP) across these filters was acceptable.erential In the event of a LOP during this extended AOT the dP acro will be monitored, and PSE&G will be prepared to swap e uelfilter the fuel filter. The fuel filter high dP alarm annuciates lo ace common EDG trouble alarm in the main Control cally, and has a a duplex type which allows for quick realignment of the fue gn is filter without interrupting flow. Filter change out after swap ov new and spare filters are on site to address contingencies.
r s simple, The remaining quantity of oil necessary to achieve 44 800 g delivered, transferred to the FOST and accepted during the d a ons will be days.
a onal 7 Nuclear Common Rev.6
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,,,_s FORM NC.NA-AP.ZZ 0059-3 10 CFR 50.59 SAFETY EVALUATION PIga
_6 of 13 Revision 0
f.D. Numbers / Reference / Revision:
Safety Evaluation # 98-015
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).
s 3.4 Provide references to location of information used for the Safety Evaluation.
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.
l i
Vendor Letter dated May 22,1998 3.5 Other Discussion, if applicable.
None L
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 10 CFR 50,59 SAFETY EVALUATION Pcge 7
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 A Loss of Off Site Powe'r is the anticipated operational transient which is assumed to occur either alone or concurrent witif a design bases accident.
l 4.2 May the proposal:
l Increase the probability of an accident previously evaluated in the a.
SAR7 YES NO _ X DISCUSSION:
No, the EDG's are not accident initiators. The EDGs are used for 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 SAR?
YES NO x
DISCUSSION:
The consequences of an accident are unchanged by this proposal.
De "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 gallohs 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 fuel oil currently available to the "B" EDG was exhausted. Sufficient fuel that has been sampled and in specification is available on site.
I Plans are in place to have additional fuel delivered if required. Thus, there would be no interruption of power to the Emergency 4kV busses, the design function of the EDG is satisfied, and the consequences of an LOP would be mitigated.
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10 CFR 50.59 SAFETY EVALUATION l*
PJge 8
of 13 Revision 0
l.D. Numbers / Reference / Revision: Safety Evaluation # 98-01$
i
Title:
Extension of Allowed Out of Service Time for the "B" Emergency Diesel Generator i
As stated above, the oil for the "D" FOST has been sampled and i
although it does not satisfy its samp!e requir'ements for particulate concentrate (510mg/l, per TS 8.6.4.e) additional size sampling has determined that the majority of the particles were less than 5 microns, which will not impact EDG operation.The proposed change will not:
- 1) Alter any assumptions previously made in evaluating the radiologicatconsequences of any accident previously evaluated in the SAR.
.1
- 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 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?
1 The failure of EDG is considered applicable to this proposal.
4.4 May the proposal:
1 Increase the probability of occurrence of a malfunction of equipment e.
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 available to support the "B" EDG. Thus, the probability of a malfunction of the EDG because of Nuclear Cornmon Rev.6
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FORM NC.NA-AP.ZZ 0059-3 10 CFR 50.59 SAFETY EVALUATION Pzg3 9
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 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 discussed:
a) The specific operator actions required: The delivery of oil is being performed by a qualified supplier and is therefore outside of the direct control 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 i
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 There are no inhospitable conditions expected. These expected:
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 concem over Inhospitable conditions. The testing and acceptance of the oilis being completed under controlled laboratory conditions. A barge connection is available for filling the FOSTs in extremely inclement (i.e., hurricane) weather.
The monitoring, swapping and replacing of the fuel filters will be completed in the EDG bay. The fuel filter and housing will be hot l
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
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FORM NC.NA-AP22 0059-3 10 CFR 50,5'9 SAFETY EVALUATION Page _10 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 at the EDG bay to complete the transfer of EDG oil a Therefore, there is no concem over access "or egre,ss.nd filter activities.
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. Theta procedures do not require heroic actions by the operators.
e) Tne 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 ofInformation required by the control room to determine whether such operator action is required, including quallfled 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 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 at.mpted.
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,w, FORM NC.NA-AP.ZZ-0059-3 10 CFR 50.59 CAFETY EVALUATION Page 11 of 13 Revision 0
l.D. Numbers / Reference / Revision: Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Ti.me 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.
- 1) consideration of the risk significance of the proposed operator actions: These actions are normal activities for the operators and do not represent an undue risk to plant personnel, or the public.
b.
Increase the consequences of a malfunction of equipment imoortant to as.fek previously evaluated in the SAR7
- ES _
NO x
DISCUSSION:
i 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 j
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 imoortant 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
u m m. u a si. m oa.ii.ain m aavim*s m r ca/ce FORM NC NA-AP.ZZ-0059-3 10 CFR 50.59 SAFETY EVALUATION Pcg3 12 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 4.5 May the proposal:
\\
Create the possibility of an accident of a different tvoe from any a.
previously evaluated in the SAR?
YES NO x
DISCUSSION:
I 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 SAR7 YES NO x
DISCUSSION:
The AOT for the "B" EDG does not affect the possibility of a malfunction of a different type. A EDG failure is analyzed in the SAR.
4.6 Qggs 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 Ba'ses 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 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
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10 CFR 50,59 SAFETY EVALUATION Prga _13 of' 13 Revision 0
1.D. Numbers / Reference / Revision:
Safety Evaluation # 98-015
Title:
Extension of Allowed Out of Service Time for the "S" Emerg Generator bases of the technical specification has been satisfied, and he i
no reduction in any margin of safety.
Therefore, the margin of safety remains unchanged.
i 5.0 10 CFR 50.59fbif2) Report The proposed activity will temporarily extend the AOT for the "B" E This change is being requested because of corrective actions by PSE&G to ensure fuel oil storage tank cleanliness. The fuel oil Testing Program." requirements are detailed in Section 6.8.4.e " D scheduled maintenance because of high par accordance with the Diesel Generator Fuel Oil Testing Program, the f i
in the "D" fuel oil storage tank (FOST) was tested and did not s requirements of TS 6.8.4.e. The "D" tank was filled on May 21 an not satisfy the criteria detailed in Section 6.8 t
the particulate concentrate of the stored fuel be less than or equa mg/l after the fuel oil has tested through a filter with a 3 micron m
6.0 CONCLUSION
If ALL answers in Section 4 are "JiQ," the proposal does NOT invo USQ.
if ANY answer in Section 4 is "EY" the proposal involves a USQ.
i Is a USQ involved?
YES _
NO x
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