View source for HL-5770, Application for Amends to Licenses DPR-57 & NPF-5,revising Acceptance Criteria for Diesel Fuel Oil Storage as Surveillance Requirement 3.8.1.3 Min Fuel Oil Level for DG Day Tanks Will Be Changed to Greater than 500 Gallons

{{Adams
| number = ML20212J251
| issue date = 10/01/1999
| title = Application for Amends to Licenses DPR-57 & NPF-5,revising Acceptance Criteria for Diesel Fuel Oil Storage as Surveillance Requirement 3.8.1.3 Min Fuel Oil Level for DG Day Tanks Will Be Changed to Greater than 500 Gallons
| author name = Sumner H
| author affiliation = SOUTHERN NUCLEAR OPERATING CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000321, 05000366
| license number = 
| contact person = 
| document report number = HL-5770, NUDOCS 9910050088
| package number = ML20212J258
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 7
| project = 
| stage = Request
}}

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       .g 4 Lewis Sumner                Sevehern helear                                                  -
Vee President               Operating Compsey, lac.
Hatch Project Support       40 inverness Parkway Post Office Box 1295 Birrningham Alabama 352D1 Tel 205.992.7279 Fax 205.992.0341 SOUTHERN L COMPANY Energy to Serve YourWorld" October.1, 1999 Docket Nos. 50-321                                                                              HL-5770 50-366 U.S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, D.C. 20555 Edwin 1. Hatch Nuclear Plant Request to Revisc Technical Specifications to Modify the Diesel Generator Fuel Oil Storane Reauiremeng ladies and Gentlemen:
In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Southern Nuclear Operating Compa..y hereby proposes changes to the Plant Hatch Units I and 2 Technical Specifications, Appendix A to operating licenses DPR-57 and NPF-5, respectively.
He proposed changes revise the acceptance criteria for diesel fuel oil storage as follows:
                  . Surveillance requirement 3.8.1.3's minimum fuel oil level for diesel generator day tanks will be changed from "2 900 gallons" to "2 500 ga!!ons" s
                  . The acceptable fuel oil level storage band in Required Action Statement B of Limiting Condition for Operation 3.8.3 will be changed from "< 33,000 and > 29,200" to "< 33,320 and > 29,520", SR 3.8.3.1 is also being changed to reflect the new 33,320 requirement.
Encicsure I provides a description of the proposed changes and an explanation of the basis for the
                ; changes. Enclosure 2 details the basis for SNC's determination that the proposed changes do not involve a significant hazards consideration. Enclosure 3 provides page change instructions for incorporating the revised TS changes. The revised pages and the corresponding markups follow the page change instructions. In accordance with the requirements of 10 CFR 50.91, the designated state official will be sent a copy of this letter and all applicaole enclosures.
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                                                        -n 9910050088 991001                                                                                        /\
PDR p
ADOCK 05000321 PDR-
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U.S. Nuclear Regulatory Commission Page 2 October 1, 1999 l
l Mr. H. L Sumner, Jr. states he is Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southem Nuclear Operating Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.
Respec ully submitted,
                                            )
h@                   W H. L. Sumner, Jr.                                                                               1 Sworn to and subscribed before me this         / {$ day of_              !' Y l_ _ 1999         i d
Notcry Public                                                              j i
Commission Expiration Date: M4tt&?6 2003 OCV/BJB/eb                                                                                       i

==Enclosures:==
I
: 1. Basis for Change Request                                                                     I
               - 2. 10 CFR 50.92 Evaluation
: 3. Page Change Instructions                                                                     !
: 4. Iland-Marked Pages cc: Southern Nuclear Operatina Company Mr. P.11. Wells, Nuclear Plant General Manager SNC Document Management (R-Type A02.001)
U.S. Nuclear Regulatory Commission. Washincton. D1                                        ;
Mr. L. N. Olshan, Project Manager - Ilatch                                                l l                      ES. Nuclear Regulatory Commission. Reaion 11 Mr, L. A. Reyes, Regional Administrator Mr. J. T. Munday, Senior Resident inspector - Hatch i                      State ofGeoraia Mr. L C. Barrett, Commissioner - Department of Natural Resources HL-5770 l
l L                                                                                                                ;

1 e o i
l Enclosure !
Edwin I.11atch Nuclear Plant Request to Revise Technical Specifications to Modify the Diesel Generator Fuel Oil Storage Requirements lla. sis for Change Reqqqs Description of Proposed Changn The proposed changes revise the acceptance criteria for two Technical Specifications (TS) as           q follows:                                                                                              '
     . Surveillance requirement 3.8.1.3's minimum fuel oil level for diesel generator day tanks will be changed from "> 900 gallons" to "> $00 gallons".
j
    . The acceptable fuel oil level storage band in Required Action Statement B of Limiting Condition for Operation 3.8.3 will be changed from "< 33,000 and > 29,200" to "< 33,320 and > 29,520" SR 3.8.3.1 is also being changed to reflect the new 33,320 requirement.
The changes apply to TS 3.8.1 ("AC Sources-Operating") and 3.8.3 (" Diesel Fuel Oil and Transfer, Lube Oil, and Starting Air"), and their associated Bases. No structural design modifications are necessary under this proposed change.                                                1 Ilarkeround and Justification In the event of offsite power supply loss, liNP-l and HNP-2 employ 5 diesel generators used to         ]
supply emergency AC power. Five underground supply storage tanks each with a capacity of 40,000 gallons provide fuct oil to the diesel generators. Each tank is required to maintain a level of 33,000 gallons of fuel oil.
Located in the diesel generator building and housed separately, five 1,000-gallon day tanks provide each diesel generator with a fuel capacity of approximately 4 hours of 100% kad operations. Fuel oil is transferred from the storage tanks to the day tanks via one of two pumps located on each        j storage tank. Fuel oil level switches, located in the day tank, automatically engage these pumps based on designated setpoints. Pumps driven by the diesel engines transfer fuel oil from the day tank to the dicsci engine fuel m mifolds.
Alarms located in the diesel generator building and in the control room are provided to notify the operator when the day tank fuel oil level is high and low. However, because the capacity of an individual day tank is 1,000 gallons (only 100 gallons from the 900 gallon requirement) it is necessary to locate the low level setpoint below the point at which 900 gallons remains in the day tank. Ifit were located above the acceptance criterion for TS SR 3.8.1.3, the instrument tolerances for the high and low level alarms would overlap. As a result, once the low level alarm is received, the fuel oil in the tank is already below the TS SR 3.8.1.3 requirement. Generally, an alarm is received prior to exceeding a TS or other type of administrative requirement.
HL-5770                                              El-1

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Enclosure 1 Basis for Chan8e Request Having the low level alann below the TS requirement a:so causes a problem with the fuel oil transfer pump surveillance.
During scheduled testing of transfer pump operability, the transfer pump is taken off-line by -
placing it in the off position and the diesel generator is operated for a period of time until the fuel oil level in the day tank falls below the low foci oil level annunciator setpoint. The pump is subsequently brought back on-line by placing it in the auto position to determine if the automatic transfer from the fuel oil supply tank, initiated by the level switches, occurs as anticipated.         ;
Performing this test requires the tank level to fall beneath TS SR 3.8.1.3's acceptance < trrion of     j
          .2 900 gallons.
l TS SR 3.8.1.3 requires verification every 31 days that the fuel oil level of the day tank is 2 900 gallons to ensure that this minimum level is maintained. Since the low-level annunciator is located below the 900-8allon requirement, the plant staff adjusted the inspection frequency from 31 days to once per day < %c increased inspection frequency is an unnecessary burden that would be eliminated by the proposed changes to the TS.
         > Rere are two primary design criteria for onsite dicsci fuel oil storage: 1)There must be sufficient
         ' fuel oil stored onsite to permit four of the five diesel generators to run continuously at 3250 kW for a period of seven days, and 2) Here must be enough fuel in each day tank to operate the appropriate diesel generator for one hour at 100% load plus a 10% margin.
i For conservative purposes, TS SR 3.8.1.3 requires that the fuel oil level be 2 900 gallons, equating -  l to an approximate runtime of 3.5 hours at the required load.                                            i The proposed 2 500-gallon day tank fuel oil level allows for an adequate margin above the minimum diesel generator operation requirement of 60 minutes at i10% load. In order for the             j diesel generator to operate for 60 minutes at 100% load,240 gallons of fuel oil is required.            !
Derefore,264 gallons of fuel oil is necessary to satisfy the 110% load TS requirement. The proposed change to 2 500-gallon day tank fuel oil level accounts for an operating time of 1.89          i hours or 113 minutes.-
Additionally, it is proposed that the acceptance criterion for TS SR 3.8.3.1 be increased from "2       )
33,000 gallons" to "2 33,320 gallons." This change is being made such that it, in conjunction with      i the reduction for TS SR 3.8.1.3 level requirement, does not affect the ability of four of the five      ;
diesel generators to run continuously for seven days supplying accident loads. With 500 gallons in each of the four operating diescl's day tanks and 33,320 gallons in each of the five storage tanks,     i four of five diesels will be able to run continuously for seven days at a load of 3250 kW.              l The basis for seven days of continuous operation is that a sufficient supply of fuel is maintained onsite to insure that diesel generator operation can be maintained for a period longer than that required to replenish the supply from off site sources.
In addition to the above proposed changes to TS SRs 3.8.1.3 and 3.8.3.1 and their corresponding Bases, TS LCO 3.8.3 CONDITION B is being changed to reflect the new level requirements for the fuel oil storage tanks. The lower limit on CONDITION 3.8.3.B is being changed for consistency, i.e.,320 gallons is being added. Additionally, the Background and LCO portions of          I HL-5770                                            El-2

e a1 Enclosure i Basis for Change Roquest
       't he TS BASES for 3.8.3 are being changed to reflect the actual design basis for the plant concerning onsite fuel storage. Plant Hatch design basis calculations show that, to operate four of the five dicscis continuously for seven days, credit is taken for the fuel oil stored in the five main storage tanks and each of the four diesel's day tanks. 'Ihis is done to account for the unusable fuel in the main storage tanks.
Presently. the Bases state that the fuci in the storage tanks (33,000 gallons) alone is sufficient to account for seven days of continuous operation. This is true for 33,000 gallons of usable fuel.
However, each storage tank contains approximately 1,438 gallons of unusable fuel. Accounting for this, four of five dicscis are capable of running continuously for about 164.4 hours,3.6 hours under seven days. The seven day continuous operation criteria was established to insure that the diesel could run continuously for a longer period of time than that required to replenish the onsite storage from offsite sources.- A 164.4 hour continuous run time does not seriously degrade this capability, however, the Bases should reflect the actual design calculations. (With the new proposed requirement of 33,320 gallons for the main storage tanks, these tanks alone will provide the capability to run four of the five dicscis for about 166 hours,2 hours under seven days.)           l I
Summarizing, following incorporation of this change, the 500 gallon day tank volume requirement alone will allow operation of the appropriate dicsci generator for 1.89 hours at i 10% load.
Additionally, the total onsite storage (main stcrage tanks and each of the respective diesel's day
                                                                                                               )
tanks) will allow for 7 days of continuous operation for four of the five diesel generators at         '
3250 kW.
l HL-5770                                             El-3

                                                   . Enclosure 2 Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications to Modify the Diesel Generator Fuel Oil Storage Requirements                        j 10 CFR 50.92 Evaluation In 10 CFR 50.92, the Nuclear Regulatory Commission (NRC) provides the following standards to be used in determining the existence of a significant hazards consideration:
              ...a proposed amendment to an operating license for a facility licensed under 650.21(b) or 650.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: (1) Involve a significant increase in the probability or                ,
consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.
i Basis for no sientlicant hazards consideration determination:
i Southern Nuclear Operating Company reviewed the proposed license amendment request and                 !
determined its adoption does not involve a significant hazards consideration based upon the following discussion:
: 1. Do the proposed changes involve a sigmficant increase in the probability or consequences of an accidentpreviously evaluated?
The diesel generators are designed to supply power to the emergency systems needed to             :
mitigate the consequences of design basis accidents such as LOCA/LOSP. They (the diesel           4 generators) do not function to prevent accidents. Reducing the level requirement in the day tanks and raising the level requirement in the fuel oil storage tanks will therefore not increase the probability of occurrence of a LOCA/LOSP event. Furthermore, this proposed change does not affect any other system or piece ofcquipment designed to prevent the occurrence of any othei design basis accident or transient. Therefore, reducing the required level in the day tanks anc r.dsing the level in the fuel oil storage tanks will not increase the probability of occurrwx of any previously evaluated accident or transient.
The consequences of previously evaluated events will not be significantly increased because, with the 500-gallon day tank requirement and the increased storage tank supply, ample fuel will be available to supply the diesel generators for the duration of a LOCA/LOSP event or a station blackout event. Therefore, the consequences of an accident previously evaluated are not increased by this modification.
HL-5770                                              E2-1

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Enclosure 2 10 CFR 50.92 Evaluation
     ' 2. Do the proposed changes create the possibility ofa new or diferent kind ofaccidentfrom anyaccidentpreviously evaluated?
Lowering TS SR 3.8.1.3 from E 900 gallons to E 500 gallons and raising TS SR 3.8.3.1 from 2 33,000 gallons to 2 33,320 gallons will have no impact on the normal or emergency operation of the diesel generator and its support systems. For example, diesel generator transfer pumps and supply tank transfer pumps will continue to perform as necessary to insure      i an adequate supply in the respective tanks for accident mitigation.
As a result, since no new unanalyzed modes of operation are introduced, the possibility of a new or different type of accident, from any previously evaluated is not introduced.
: 3. Do theproposed changes involve a significant reduction in a margin ofsafety?
The Bases for TS SR 3.8.1.3 states that the day tank must carry enough fuel oil to provide for one hour of operation, plus a 10 percent margin. This requirement is based on ANSI N195-1976 (Section 6.1).
1 The present 900-gallon requirement in the present Technical Specifications provides for 3.5 hours of continuous operation. Reducing the volume requirement to 500 gallons will continue to provide ample margin above the 1-hour requirement. In fact,500 gallons in the day tank provides for 1,89 hours ofcontinuous operation.
The Bases for TS SR 3.8.3.1 states that the fuel in the storage tanks (33,000 gallons) alone is
: sufficient to account for seven days of continuous operation. This is true for 33,000 gallons of usable fuel. However, each storage tank contains approximately 1,438 gallons of unusable fuel. Additionally, part of the current design bases for the cracrgency diesel generators is the ability to run four of the five dicscis continuously for seven days at a load of 3250 kW. With 500 gallons in each of the four diesci's day tanks and 33,320 gallons in each of the five storage tanks, the system is capable of runt.ing continuously for 7 days. Ample onsite fuel capacity remains to operate the diesels continuously for a longer period than required to replenish the supply from outside sources. For the above reasons, the margin of safety is not significantly reduced.
HL-5770                                             E2-2}}