NUREG-0123, Safety Evaluation Supporting Amends 173 & 176 to Licenses DPR-44 & DPR-56,respectively
| ML20035C483 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/25/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035C479 | List: |
| References | |
| RTR-NUREG-0123, RTR-NUREG-123 GL-84-15, NUDOCS 9304080021 | |
| Download: ML20035C483 (13) | |
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UNITED STATES 3 i.P '
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NUCLEAR REGULATORY COMMISSION 3 'h [p!
WASHINGTON. D.C. 20555 s....*
l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 173 AND 176 TO FACILITY OPERATING LICENSE NOS. DPR-44 and DPR-56 PHILADELPHIA ELECTRIC COMPANY l
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
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DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT NOS. 2 AND 3 DOCKET NOS. 50-277 AND 50-278
1.0 INTRODUCTION
By letter dated January 31, 1992, as supplemented by letters dated April 28, i
1992, June 22, 1992, November 9,1992, and January 8,1993, the Philadelphia i
Electric Company, Public Service Electric and Gas Company, Delmarva Power and Light and Atlantic City Electric Company (the licensee) proposed various changes to the Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications (TS). Specifically, the licensee proposed changes to Technical j
Specification 3.9/4.9, " Auxiliary Electric Systems," for Units 2 and 3 regarding testing of emergency diesel generators (EDGs) and Offsite AC Sources.
These proposed changes are intended to incorporate enhanced testing i
requirements in the plants' Technical Specifications by implementing the guidance contained in Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite Electrical Power Systems at Nuclear Power Plants;" NUREG-0123, " Standard Technical Specifications for Generat Electric Boiling Water Reactors, Revision 3;" and Generic Letter 84-15, " Proposed Staff Action to Improve and Maintain Diesel Generator Reliability." These changes are intended to improve the availability and reliability of the Emergency Diesel Generator, and Offsite AC Sources for Peach Bottom Units 2 and 3.
The proposed Technical Specification (TS) changes and our evaluation of these changes are described in Section 2.0.
The April 28, 1992, November 9, 1992, and January 8, 1993, letters provided i
clarifying information that did not increase the scope of the original amendment request or change the initial proposed no significant hazards j
i determination which was based on the January 31, 1992, letter. An administrative change to TS 4.9.A.1.2.c.2 was made by the NRC staff, and agreed upon by the licensee, as a result of our telephone discussion on January 12, 1993. The staff corrected typographical errors on page 132 of the 4
TS as agreed to by the licensee in a telephone discussion dated February 10, 1993. These administrative changes were for clarity and also did not change the original proposed no significant hazards determination.
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The supplemental letter of June 22, 1992, requested that the staff review and evaluate a provision of the proposed TS which eliminated immediate and daily I
testing requirements for EDGs when one EDG is out of service for planned
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preventive maintenance. The staff considered that request _and issued l
Amendments 168 and 172 to the TS which incorporated that single change on i
July 6, 1992.
l3 2.0 EVALUATION The licensee has proposed various TS changes for Peach Bottom Units 2 and 3 diesel generator surveillance requirements. The proposed changes constitute a comprehensive and rigorous test program to ensure reliability for the EDGs and I
associated equipment. This test program is modeled on the test program recommended in NUREG-0123, Revision 3 of the Standard Technical Specifications.
(STS) and Generic Letter 84-15. The staff's evaluation of these changes are j
as follows:
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1 2.1 New Surveillances to be added to the current T/S l
i Table 3.2.8 The licensee has proposed the 480 Volt Emergency Load Center Timers to_the list of required operable Core and Containment Cooling System Instrumentation j
and Control equipment in Table 3.2.B.
The Table includes a timer setting of i
3.0 0.5 seconds and requires four channels to be operable.
The surveillance of these timers would be captured under the existing TS Table 4.2.B l
requirement to test Auto Sequencing Timers once per operating cycle (i.e., 18 4
months).
The licensee's proposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
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i T/S Section 4.9.A.1.1.a i
l This surveillance requires that each diesel generator and offsite circuit be l
verified operable at least once per 7 days by verifying correct breaker
'l alignments and indicated power availability, l
The licensee's proposed change is a new requirement which follows the l
guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
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i T/S Section 4.9.A.I.1.b This surveillance pertains to demonstrating'the operability of the diesel generators and offsite circuits at least once per operating cycle (i.e.,:18
.j months) by transferring, manually and automatically, the start-up source from j
the normal circuit to the alternate circuit.
il The licensee's proposed change is a new requirement which follows the i
guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
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1 T/S Section 4.9.A.l.2.a.3 This surveillance requires that each diesel generator be demonstrated operable at least once every 31 days by verifying that the diesel can start and gradually accelerate to synchronous speed with generator voltage and frequency at 4160 410 volts and 60 1.2 Hz, respectively.
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The licensee's proposed change is a new requirement which follows the guidelines contained in Generic Letter 84-15 and is acceptable.
1 T/S Section 4.9.A.l.2.a.4 This surveillance requires verifying that the diesel generator can be synchronized, gradually loaded to an indicated 2400-2600 kW and can operate with this load for at least 60 minutes.
The licensee's proposed change is a new requirement which follows the guidelines contained in Generic Letter 84-15 and is acceptable.
t T/S Section 4.9.A.l.2.a.5 i
This surveillance requires verifying that the diesel generator is aligned to provide standby power to the associated emergency buses.
It_ also requires that each diesel generator shall be demonstrated operable in accordance with the frequency specified in 4.9.A.I 2.K below.
The licensee's proposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9.A.l.2.b This surveillance requires that at least once per 184 days the diesel l
generator shall be started and verified to accelerate to synchronous speed in
'j less than or equal to 10 seconds. The generator voltage and frequency shall l
reach 4160 410 volts and 60 i 1.2 Hz, respectively, within 10 seconds after the start signal. The generator shall be manually synchronized to its appropriate emergency bus, loaded to an indicated 2400-2600 kW in~1ess than or l
equal to 60 seconds, and operated for at least 60 minutes. This test, if.it i
is performed so it coincides with the testing required by Surveillance l
Requirement 4.9.A.I.2.a.3 and 4.9.A.I.2.a.4, may also serve to concurrently meet those requirements as well.
i The licensee's proposed change is a new requirement which follows the
-i guidelines contained in NUREG-0123, Revision 3 of the' STS and'is acceptable.
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-P T/S Section 4.9.A.I.2.f.2 This surveillance requires that each diesel generator be demonstrated operable at least once per operating cycle (i.e.,18 months) by verifying the diesel generator capability to reject a load of greater than or equal to that of the RHR pump motor for each diesel generator while maintaining voltage and frequency at 41f9 410 volts and 60 i 1.2 Hz, respectively.
The licensee's proposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T /S Section 4.9. A.l.2.f.3 This surveillance requires that each diesel generator be demonstrated operable at least once per operating cycle (i.e.,18 months) by verifying the diesel generator capability to reject a load of 2400 to 2600 kW without tripping.
The generater voltage during this test shall not exceed an initial value (4160 410 volts) by more than 660 volts during and following the load rejection test.
The licensee's proposed change is a new requirement which meets the intent of NUREG-0123, Revision 3 of the STS and is acceptable.
l T/S Section 4.9.A.I.2.f.4 This surveillance requires that each diesel generator be demonstrated operable at least once per operating cycle (i.e., 18 months) by verifying that all automatic diesel generator trips except engine overspeed, generator differential over-current, generator ground over-current and manual cardox initiation are automatically bypassed upon an ECCS actuation sigr.al.
l The current staff position stipulated in RG-1.9 for bypassing EDG protective trips during emergency conditions recommends that the diesel generator units be automatically tripped on engine overspeed and generator differential ~
current under accident conditions. Any other automatic protective trips i
should either be bypassed or be_ implemented with two or more measurements for each trip parameter with coincident logic for trip actuation. The licensee's design also allows the EDGs to be automatically tripped on generator ground l
over-current'and manual cardox initiation. The licensee has provided a coincident logic of 2 out of 16 for manual cardox initiation (C02 fire l
extinguishing system discharge). However, no coincident logic is provided for generator ground over-current. The licensee informed the staff that this was the original plant design and that there have been no instances where this over-current trip signal spuriously actuated.
Based on the above, we find the corresponding TS change to be acceptable.
r T/S Section 4.9.A.1.2.f.5 This surveillance requires that each diesel generator be demonstrated operable at least once per operating cycle (i.e., 18 months) by verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this i
test, the diesel _ generator shall be loaded to an indicated 2800-3000 kW and
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during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test the diesel generator shall _be loaded to an indicated 2400-2600 kW.
l The licensee's ;.roposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9 A.1.2.f.6 I
This surveillance requires that each diesel generator be demonstrated operable l
at least once per operating cycle (i.e.,18 months) by verifying diesel i
generator capability at full lead temperature within 5 minutes after completing the 24-hour test by starting and loading the diesel' as described in Surveillance Requirement 4.9.A.l.2.b and operating for greater than 5 minutes.
The licensee's proposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9.A.1.2.f.7 This surveillance requires verification that the fuel transfer pump transfers 5
fuel from each fuel storage tar.k to the day tank of each diesel via the installed cross connection lines.
i The licensee has proposed to add the above surveillance requirement to ensure I
that the transfer pump and crosstie are functioning properly. Because the l
licensee has proposed an action statement (T/S Section 3.9.B.6) to eliminate the requirement to declare an EDG inoperable when the. fuel oil in its associated fuel oil storage tank is not available, the licensee has added the 4
surveillance requirement to ensure that fuel oil can be delivered from one of i
the remaining storage tanks-through the crosstie. This proposed change is a j
new requirement which demonstrates the adequacy of a diverse flow path of fuel 1
oil to the EDGs and is acceptable.
T/S Section 4.9.A.1.2.a.1 This surveillance requires _that each diesel generator be demonstrated operable.-
-i at least once per operating cycle (i.e.,18 months) by simulating a loss-of-l offsite power (LOOP), verifying deenergization of the emergency buses and load l
shedding from the emergency buses and verifying.that the diesel generator starts on the auto-start signal, energizes the emergency buses with the i
permanently connected loads within 10 seconds, energizes the auto-connected i
loads through the individual load timers and operates for greater than or equal to 5 minutes. After energization, the steady-state voltage and
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frequency of the emergency buses shall be maintained at 4160 410 volts and i
60 1.2 Hz, respectively, during this test.
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l The licensee's proposed change is a new requirement which follows the i
guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9.A.l.2.o.2 3
i This surveillance requires that each diesel generator be demonstrated operable at least once per operating cycle (i.e.,18 months) by verifying that on an ECCS actuation test signal, without loss-of-offsite power, the diesel generator starts on the auto-start signal and operates for greater than or equal to 5 minutes. The generator voltage and frequency shall reach 4160 410 volts and 60 1.2 Hz, respectively, within 10 seconds after the auto-start signal; the steady state generator voltage and frequency shall be maintained within these limits during this test.
The licensee's proposed change is a new requirement which follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
I/S Section 4.9.A.l.2.o.3 l
This. surveillance requires that each diesel generator be demonstrated operable j
at least once per operating cycle (i.e., 18 months) by simulating a loss-of-offsite power in conjunction with an ECCS actuation test signal, verifying deenergization of the emergency buses and load shedding from the emergency buses, and verifying that the diesel generator starts on the auto-start signal, energizes the emergency buses with permanently connected loads within 10 seconds, energizes the auto-connected loads through the. individual load s
timers and operates for greater than or equal to 5 minutes. After energization, the steady-state voltage and frequency of the emergency buses shall be maintained at 4160 410 volts and 60 1.2 Hz, respectively, during this test.
l The licensee's proposed revision follows the guidelines contained in NUREG-i 0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9.A.I.2.o.4 This surveillance requires that at least once per operating cycle (i.e., 18 i
months) each diesel generator be demonstrated operable by (1) synchronizing-with the offsite power source while the generator is loaded with its emergency
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loads, (2) transferring this load to the offsite power, and (3) restoring the diesel generator to its standby condition.
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The licensee's proposed change is a new requirement which follows the j
guidelines' contained in NUREG-0123, Revision 3 of the STS and is acceptable.
j T/S Section 4.9.A.l.2.h This surveillance requires that each diesel generator be demonstrated operable at least once per 10 years or after any modifications which could affset diesel generator interdependence by starting all four diesel generators i
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simultaneously and verifying that all four diesel generators accelerate to at least 855 rpm in less than or equal to 10 seconds.
The licensee's proposed change is a new requi ement which follows the i
guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Section 4.9.A.I.2.k This surveillance incorporates requirements-for EDGs which vary the surveillance testing frequency based on the number of failures.
If the number of failures during the last 20 valid demands is less than or equal to one, the test frequency shall be at least once per 31 days. If the number of failures during the last 20 valid demands is greater than or equal to two, the test frequency shall be at least once per 7 days.
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The licensee's proposed change is a new requirement which follows~the guidelines contained in Generic Letter 84-15 and is acceptable.
T /S Section 4.9. A. I.2.1 f
This surveillance requires that all diesel generator failures, valid or non-valid, shall be reported to the Commission in a Special Report,within 30 days.
l Reports of the diesel generator failures shall include the information in i
i Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1, August 1977.
The licensee's above requirement to directly incorporate the. reporting requirements of paragraph C.3.b of Regulatory Guide 1.108, Revision 1, is acceptable.
T/S Section 4.9.B.1 This surveillance requires that when it is determined that one offsite circuit required by Specification 3.9.A.1 is inoperable, verify the operability of the i
remaining AC sources by performing Surveillance Requirement 4.9.A.1.1.a.
within I hour and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
i In addition, it requires that if any diesel generator has not been successfully tested within the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate operability of
-l these diesel generators by performing Surveillance Requirement 4.9.A.I.2.a.3 for one diesel at a time within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.
The licensee's proposed change is a new requirement which follows the i
guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
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T/S Section 4.9.B.3 This surveillance requires that when one diesel generator is inoperable,'the.
l operability of the remaining AC sources shall be verified by performing Surveillance Requirement 4.9. A.I.1.a. within I hour and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, thereafter.
Verification is required within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all' systems, l
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- t subsystems, trains, components, and devices that depend on the remaining diesel generators as a source of emergency power are operable.
l In addition, it requires that if the diesel generator becomes inoperable for any reason other than preplanned preventive maintenance, or testing; demonstrate the operability of the remaining operable diesel generators by performing Surveillance Requirement 4.9.A.I.2.a.3 for one diesel at a time, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.
The licensee's proposed change follows the guidelines contained in Generic l
Letter 84-15 and is acceptable.
T/S Section 4.9.B.4 This surveillance requires that when it is determined that one diesel and one offsite circuit required by Specification 3.9.A.1 are inoperable, verify the operability of the remaining AC sources by performing Surveillance Requirement 4.9.A.l.l.a. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Verification is required within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all required systems, subsystems, trains, components, and devices that depend on the remaining diesel generators as a source of emergency power are operable.
In addition, it requires that if the diesel generator becomes inoperable for any reason other than preplanned preventive maintenance, or testing, demonstrate the operability of the remaining diesel generators by performing Surveillance Requirement 4.9.A.I.2.a.3 for one diesel at a time, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The licensee's proposed change follows the guidelines contained in Generic Letter 84-15 and is acceptable.
2.2 Revisions to Existina T/S Sections T/S Section 3.9.A.2. 3.9.A.2.a. 3.9.A.2.b and 3.9.A.2.c s
t The above action statement establishes a minimum fuel oil availability _
requirement for each operable EDG (28,000 gallons) and increase the existing requirement for the cumulative minimum volume of fuel on site from 104,000 to l
108,000 gallons.
The licensee _has proposed to add the above action statement to increase EDG reliability and availability by establishment of minimum diesel fuel oil availability requirements for each EDG and increasing the existing requirements for_ the cumulative minimum volume of diesel _ fuel oil on site.
t Previously no specific fuel oil inventory requirements were designated for each of the diesel generator fuel oil storage tanks. The only TS requirement was to maintain a specific minimum fuel oil quantity onsite (104,000 gallons) which did not necessarily make available fuel-oil to the operable diesel generators. This proposed change adds conservatism to the TSs and is acceptable.
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f T/S Section 3.9.B.1 This action statement currently states that if one of the two independent-offsite circuits required by Specification 3.9.A.1 is inoperable, continued reactor operation is permissible for 7 days provided the 4 diesel generators and associated emergency buses are demonstrated to be operable. The Licensee has proposed to add the following to this action statement.: " restore at least two offsite circuits to operable status within 7 days or be in at least 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 in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
i The staff finds this proposed revision to be more conservative than the l
current TS and is acceptable.
T/S Sections 3.9.B.3 This action statement currently states that if one diesel generator or I
associated emergency bus is made or found to be inoperable for any reason, continued reactor operation is permissible if other provisions of the existing TS is satisfied.
The licensee has proposed to add the following to this action statement: " restore the inoperable diesel generator and associated emergency bus to operable status within 7 days or be in at least HOT SHUTDOWN
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within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
l The staff finds this proposed revision to be more conservative than the i
current TS and is acceptable.
l T/S Section 3.9.B.4 This action statement currently states that if one of the diesel generators or associated emergency buses and either the emergency or startup transformer power source are made or found to be inoperable for any reason, continued reactor operation is permissible if the existing TS is satisfied, and if the other offsite source, startup transformer and emergency transformer are j
available and capable of automatically supplying power to the 4 kV emergency buses. The licensee has proposed to add the following to this action i
statement: " restore at least two offsite circuits or four diesel generators to l
operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of initial loss or be in at follow r.
The staff finds this proposed revision to i,e more conservative than the current TS and is acceptable.
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T/S Section 3.9.B.6. 3.9.B.6 a. 3.9.B.6.b. 3.9.B.6.c and 3.9.B.6.d I
The above action statement eliminates an option allowing an EDG to be declared inoperable when the fuel oil in one of the diesel fuel storage tanks is not available by requiring that the EDG be supplied from one of the remaining storage tanks but increasing the time from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to establish the required inrentory of 108,000 gallons of fuel in the other three storage tanks.
The licensee has proposed to change the above action statement which increases EDG reliability and availability by elimination of an option allowing an EDG to be declared inoperable when the fuel oil in one of the diesel fuel storage tanks is not available oy requiring the EDG be supplied fuel from one of the remaining storage tanks within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The NP.C evaluated and accepted the operation of an EDG with its associated fuel oil storage tank isolated and the sharing of safety-system components in a safety evaluation report, dated
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May 31, 1988, supporting Amendments Nos. 131 and 134 to Peach Bottom's operating license. The NRC determined in the safety evaluation that there is reasonable assurance that the common mode failure due to the sharing of a crosstie rendering two EDGs inoperable will not occur considering that the crosstie provision will only be utilized during a 7-day period. Amendments Nos. 131 and 134 consisted of changes to the TSs which require the unacceptable fuel oil in _the isolated storage tank to be replaced and returned i
to service within 7 days or place the reactor in COLD SHUTDOWN within 24 i
hours. The proposed action statement also increases the time from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to establish the required inventory of 108,000 gallons of fuel on site which increases the time that the EDGs do not have sufficient fuel to meet the i
design basis requirement of 7 days of post LOOP /LOCA operation.
- However, considering the short duration in which this condition will exist, combined with having a minimum of 84,000 gallons of fuel in the other three tanks provides sufficient time, 5.6 days of operating time with 4 EDGs and 3 fuel oil storage tanks, to obtain additional diesel fuel from offsite sources.
If the licensee does not obtain the minimum 108,000 gallons of fuel oil inventory requirement on site within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> proposed, the TSs require them to place the reactor in COLD SHUTDOWN within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This proposed change ensures that sufficient inventory of fuel oil is available within a specified time and is therefore; acceptable.
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T/S Section 3.9.B.7 This action statement pertains to operation with inoperable equipment and requires that if one of the 4 kV emergency buses or 480 volt emergency load centers required by TS 3.9.A.3 are not energized, declare the associated equipment inoperable and take the appropriate action for that system.
In addition, it requires that the bus be re-energize within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in COLD SHUTDOWN within the following 24' hours.
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G s The licensee's proposed revision follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T/S Sections 4.9.A.l.d and 4.9.A.l.2.c This surveillance deletes the prescriptive corrective maintenance requirements if water is suspected between the day tank and the EDG fuel injectors.
The licensee eliminated these maintenance requirements because they may be counterproductive.
Adherence to the existing TS requirements for operability and testing are sufficient to assure that water in the fuel will be detected and appropriate corrective actions taken in a timely manner. TS 4.9.A.1.d was deleted in part and the remaining requirements were incorporated into proposed TS 4.9.A.l.2.c.
The staff finds these proposed changes acceptable.
T/S Section 4.9.A.l.2.a.6 This surveillance requires that each diesel generator be demonstrated operable by verifying the pressure in all diesel generator air start receivers to be greater than or equal to 225 psig.
The licensee's proposed revision follows the guidelines contained in NUREG-0123, Revision 3 of the STS and is acceptable.
T /S Sections 4.9. A. l. 2. a 3. 4.9. A. l. 2.b. 4. 9. A. l. 2. f. 5. 4.9. A.1. 2. a. l. b.
4.9.A.l.2.o.2 and 4.9.A.1.2.o.3.b.
The licensee has added footnote "a" to the above technical specifications.
This footnote requires explicit recognition that all planned EDG starts shall be performed in accordance with the manufacturer's recommendations for pre-lubrication, warm-up, and, as applicable, loading and shutdown.
The licensee's proposed change is a new requirement which follows the guidelines contained in Generic Letter 84-15 and is acceptable.
T/S Bases Section 4.9.
The bases discussing EDG surveillance requirements have been modified to reflect the review EDG testing program.
2.3 Editorial Channes:
In proposing revised EDG TS requirements, the licensee made numerous editorial and labeling changes to the TSs.
The changes that are strictly editorial are captured below.
1.
Existing TS requirement 4.9.A.I.h on fuel oil storage tank cathodic protection is relabeled as 4.9.A.1.2.j.
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Existing TS requirement 4.9.A.I.g on draining and cleaning fuel oil storage tanks has been slightly reworded with no change in requirements and relabeled as TS 4.9. A.1.2.1.
3.
Existing TS requirement 4.9.A.I.e on sample requirements for new fuel oil have been incorporated with minor editorial revisions into new TS 4.9.A.I.2.d.
4.
Existing TS requirement 4.9. A.l.f on periodic sample requirements for fuel oil in the main storage tanks has been incorporated with minor editorial revisions into new TS 4.9. A.I.2.e.
5.
Existing TS requirement 4.9.A.I.i specified that once per operating cycle (i.e.,18 months) diesel inspection requirements 'in accordance with procedures prepared in conjunction with manufacturer's recommendations was incorporated with minor editorial changes into new TS 4.9.A.I.2.f.l.
6.
Existing TS requirement 4.9. A.I.c on logging quantity of diesel. fuel available has been modified to specify that fuel levels in the fuel storage tank and onsite be verified in accordance with the schedule determined in 4.9.A.I.2.k and has been' incorporated in new TS requirement 4.9.A.1.2..a.l.
7.
Existing TS requirement 4.9.A.I.a specified that, among other things, during the monthly diesel generator test, the operation of the diesel fuel oil transfer pumps shall be demonetrated. This requirement has been moved and clarified to new TS 4.9.A.l.2.a.2.
8.
Revised TS requirement 3.9.B.6 was modified to delete a reference to accelerated testing of ECCS as specified in 4.5.F.1 as not required.
TS 4.5.F.1 was deleted and reference to it is subsequently not required.
2.4 Conclusion We have reviewed the licensee's submittals and have concluded that these changes as described and evaluated individually above are acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change surveillance requirements. The NRC staff has determined-that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released
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- 131-i offsite, and that there is no significant increase in' individual or cumulative' occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards i
consideration, and there has been no public comment on such finding (57 FR.
20515). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need. be prepared in connection with the issuance of the amendments.
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5.0 CONCLUSION
- a The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health' and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's. regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the healtii and safety of the public.
Principal Contributor:
C. Thomas M. Widman t
Date: March 25, 1993 i
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