NL-15-082, Withdrawal of License Amendment Request Regarding Emergency Diesel Generator Fuel Oil Storage Supplies

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Withdrawal of License Amendment Request Regarding Emergency Diesel Generator Fuel Oil Storage Supplies
ML15187A072
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 06/25/2015
From: Coyle L
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-082, TAC ME9264
Download: ML15187A072 (3)


Text

Enterqay Nuclear Northeast Indian Point Energy Center

%Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President June 25, 2015 NL-15-082 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Withdrawal of License Amendment Request Regarding Emergency Diesel Generator Fuel Oil Storage Supplies (TAC No. ME9264)

Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64

REFERENCES:

1. Entergy Letter NL-12-097 to NRC Regarding License Amendment Request for Emergency Diesel Generator Fuel Oil System, dated August 14, 2012 (Accession No. ML12234A250)
2. Entergy Letter NL-13-057 to NRC Regarding Response to Request For Additional Information Regarding Emergency Diesel Generator Fuel Oil System (TAC No. ME9264), dated April 15, 2013
3. Entergy Letter NL-13-102 to NRC Regarding Response to Request For Additional Information Regarding Emergency Diesel Generator Fuel Oil Supplies (TAC No. ME9264), dated July 23, 2013
4. Entergy Letter NL-14-053 to NRC Regarding Request For Additional Information Regarding Emergency Diesel Generator Fuel Oil Supplies (TAC No. ME9264), dated July 23, 2013

Dear Sir or Madam:

The purpose of this letter is to withdraw a License Amendment request. Entergy Nuclear Operations, Inc, (Entergy) requested, Reference 1, a License Amendment to Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). This was supplemented in three responses (Reference 2, 3, and 4) to requests for additional information.

The proposed changes would have revised Technical Specification (TS) Limiting Condition for Operation (LCO) 3.8.3, "Diesel Fuel Oil, and Starting Air," to relocate specific numerical values for fuel oil storage volumes from the TSs to the TS Bases in accordance with Technical Specification Task Force (TSTF) 501 Revision 1.

NL-15-082 Docket No. 50-286 Page 2 of 3 The amendment proposed by Entergy was based on TSTF-51 0-A Rev 1. The TSTF removes the fuel oil requirements from the Technical Specifications to the Bases. It requires that the fuel oil consumption be determined using specific methodology. The TSTF states "the fuel oil storage requirements should either be based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity or calculations based on the time-dependent loads of the diesel generator." Entergy used the rated capacity to calculate fuel oil requirements. However, this approach reduced the amount of time each individual storage tank would supply the associated Emergency Diesel Generator (EDG) before being refilled to less than the existing 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

This proposed Technical Specification is being withdrawn because Entergy is unable to meet the Staff position that each EDG must be capable of operation using just the associated fuel oil storage tank for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. While this might be feasible using the time dependent load approach, there are no current calculations to support this or to show the load management required to do this would be an acceptable operational practice. Entergy will continue discussions with NRC staff on the feasibility of resubmitting a new amendment that will meet NRC Staff requirements.

In the meantime, the current licensing basis for the three EDG fuel oil storage tanks associated with the Emergency Diesel Generators (EDGs) will remain as described in the TS bases and FSAR section 8.2. Entergy plans to maintain a reserve margin of 6921 gallons of fuel oil in the fuel oil storage tanks (operations standing order 11-10) to account for any additional issues that may arise regarding fuel oil requirements (e.g., low sulfur). The FSAR says:

"The minimum required usable inventory for each of the three storage tanks is specified in the Technical Specifications. The safety design criteria are based on the need to provide adequate fuel to support forty-eight (48) hour operation of minimum safeguards equipment following a design basis accident. The minimum required inventory (gallons) for fulfillment of the safety design criterion is based on the following:

31 Tank 32 Tank 33 Tanks Calculated consumption (TS Required Usable) 5,365 5,365 5,365 Margin reduction due to re-coating 20 20 20 Level indication uncertainty 50 50 50 Unusable (pump cutoff worst case drift) 915 915 956 Total minimum required Inventory 6,350 6,350 6,391" "A usable amount of 37556 gallons of fuel oil is required to operate two emergency diesels at minimum safeguards load continuously for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />.... There are two 30,000 gallon seismic Class III tanks located in the Indian Point 1 Superheater Building and a 200,000 gallon seismic Class III tank in the Buchanan Substation located immediately across Broadway. These tanks contain fuel oil for operation of the IP2 SBO / Appendix R diesel."

"The following "minimum safeguards" equipment is required and assumed to be operating for a design basis event at Indian Point Unit 3:

2 of 3 Safety Injection (SI) Pumps 1 of 2 Residual Heat Removal (RHR) Pumps 1 of 2 Motor Driven Auxiliary Feedwater (AFW) Pumps 1 of 2 Recirculation Pumps

NL-15-082 Docket No. 50-286 Page 3 of 3 3 of 5 Containment Recirculation (CR) Fans 1 of 2 Containment Spray (CS) Pumps 1 of 3 Nonessential Service Water (NE SW) Pumps 2 of 3 Essential Service Water (ESW) Pumps 1 of 3 Component Cooling Water (CCW) Pumps" There are no new commitments being made in this submittal.

If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Affairs at (914) 254-6710.

Sincerely, LC/sp cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. John B. Rhodes, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service