ML18010A370

Application for Amend to License NPF-63,revising Tech Specs 3.8.1.1.b.1 & 3.8.1.2.b.1 Re Emergency Diesel Generator Fuel Oil Day Tank Min Level,Per Insp Rept 50-400/90-200

ML18010A370
Person / Time
Site:	Harris
Issue date:	08/26/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18010A371	List: IR 05000400/1990200 ML18010A370 ML18010A372
References
NLS-91-197, NUDOCS 9109030236
Download: ML18010A370 (12)

Text

, A,CCELERATED D+RIBUTION DEMONSTION SYSTEM

~

'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9109030236 DOC.DATE: 91/08/26 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION VAUGHN,G.E. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-63,revise.ng Tech Specs 3.8.1.1.b.1 & 3.8.1.2.b.l emergency diesel generator fuel oil day tank min level,per reInsp Rept 50-400/90.-200. D DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution I ENCL 3 SIZE: 7 NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-1 LA ' 1 1 PD2-1 PD 1 1 MOZAFARI,B,. 2 2 D ACRS 6 6 NRR/DET/ECMB 7D 1 1 'NTERNAL:

NRR/DET/ESGB 1 1 NRR/DOEA/OTSB11 1 1 NRR/DST 8E2 1 1 NRR/DST/SELB 7E 1 1 NRR/DST/SICB8H7 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 O~C~F4IB 1 0 OGC/HDS1 1 0 G~EIZi~E- 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 22

t Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602 SERIAL: NLS-91-197

'AUG 38 i991 10CFR50.90 G. E. VAUGHN Vice President Nuclear Senices Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR DAY TANK LEVEL Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power 6r Light Company (CPGL) hereby requests a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).

The proposed amendment revises Technical Specifications 3.8.1.1.b.l and 3.8.1.2.b.l concerning the emergency diesel generator (EDG) fuel oil day tank minimum level. Specifically, the change revises the minimum required level from 2670 gallons to 1457 gallons and adds a footnote which clarifies the differences in assumed fuel oil specific gravities'his change is being proposed in response to an NRC inspection item (50-400/90-200-05) which dealt with the day tank level dropping below the required minimum during engine operation prior to automatic refill.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 is an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9); therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides the proposed Technical Specification pages.

In order to allow time for procedure revisions and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued such that implementation will occur within 60 days of issuance of the amendment.

9l09030236 910826 PDR ADOCK 05000400 P PDR

'I

,Document Control De~

(NLS-91-197) / Page+

In accordance with 10CFR50.91(b), CP&L is providing the, State of North Carolina with a copy of this letter.

Please refer any questions regarding this submittal to Mr. R. W. Prunty at (919) 546-7318.

Yours very truly, LSR/lsr (1249AHNP)

Enclosures:

1. Basis for Change Request

2. 10CFR50.92 Evaluation

3. Environmental Evaluation

4. Technical Specification Pages CC; Mr. Dayne H. Brown Mr. S. D. Ebneter Ms. B. L. Mozafari Mr. J. E. Tedrow (NRC-SHNPP)

G. E. Vaughn, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

Notary ( eal), "'

My commission expires: D/&(Cyp +" ~HARV r:. PUBS<

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~ ~

ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR DAY TANK LEVEL BASIS FOR CHANGE RE VEST Back round The proposed Technical Specification revision is being requested in response to an NRC inspection item (50-400/90-200-05) which dealt with the emergency diesel generator day tank level dropping below the required minimum during engine operation prior to automatic refill. The present Technical Specification for the minimum volume contained in the fuel oil day tank provides no provision for usage during performance of periodic testing of the EDG. During routine EDG testing, the fuel oil level in the day tank falls below the minimum Technical Specification value while the engine is running, but does automatically refill when the engine is stopped.

During operation of the Emergency Diesel Generator, fuel oil is supplied to the engine-driven fuel oil pump from the day tank by the static head of fuel oil.

Automatic makeup to the fuel oil day tank is commenced when the engine is shutdown and the day tank level is below the full level (90 inches or 2790 gallons), or when the fuel oil day tank level decreases to 20.25 +/- 0.5 inches (approximately 627 +/- 15 gallons) while the diesel engine is running. The transfer pump runs until the full level control switch is actuated at a level of 90 inches above tank bottom.

The applicable system requirements of Regulatory Guide 1.137 and ANSI Standard N195-1976 specify that the stored fuel oil volume provides a seven-day operating time for the Emergency Diesel Generator (EDG), and at the commencement of makeup to the fuel oil day tank that the oil volume will provide for operating the EDG at load for a minimum of 60 minutes, plus an additional 10 percent of fuel (a minimum operating time of 1.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

Pro osed Chan e The proposed amendment revises Technical Specifications 3.8.1.1.b.l and 3.8.1.2.b.l concerning the emergency diesel generator (EDG) fuel oil day tank minimum level. Specifically, the change revises the minimum required level from 2670 gallons to 1457 gallons and adds a footnote which clarifies the differences in assumed fuel oil specific gravities.

Safet Evaluation The present Technical Specifications (TS) 3 '.1.1 and 3.8.1.2 require a total minimum quantity of stored fuel oil of 102,670 gallons with 2670 gallons in the fuel oil day tank and the remainder in the fuel oil storage tank for each EDG.

The conservative operating time for each emergency diesel at 100 percent continuous load is approximately 230.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> (9 days, 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />). ANSI N195-1976, Section 6.1 sets the design standard of the day tank by requiring a minimum of 1.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of diesel engine operating time at 100 percent continuous load when fuel oil is automatically added to the tank. The SHNPP fuel oil day tanks (one (1249HHP)

ENCLOSURE 1 (continued) per engine) exceed this minimum level requirement, and in addition, have a low level alarm that will annunciate prior to the day tank inventory decreasing below the 1.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limit. This design allows for corrective action to be initiated to refill the tank. The minimum volume required in the fuel oil day tank to meet the 1.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> criteria is 490 gallons (15.8 inches above the tank outlet).

Present design setpoints of the day tank level control and alarm would allow a minimum inventory of 519 gallons (16.75 inches, setpoint minus tolerance, above the tank outlet) at the low level alarm and a minimum inventory of 612 gallons (19.75 inches above the tank outlet) at commencement of automatic makeup to the tank. At the low level alarm, the percent volume of fuel oil is approximately 16.5 percent, which is equivalent to a minimum indicated level of 11 percent with a minimum specific gravity of 0.83 and the level detector calibrated to a reference specific gravity of 0.876.

Thus, the present design provides for a response time of greater than 1.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore the fill rate of the day tank to a flow of 7 ' gpm (the nominal engine consumption rate at 100 percent continuous load) or greater. With the level restored to 90 inches (equivalent to a percent volume of 88.6 percent and a minimum indicated level of 80.6 percent), an operating time of approximately 6.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 100 percent load is provided to allow for permanent repair or corrective action. Since the minimum seven-day supply for the EDG is contained in the associated storage tank, the only requirement that applies to the minimum day tank volume is a volume that provides an operating time greater than the expected time to restore makeup flow above engine operating requirements. The day tank design exceeds the requirements of ANSI N195-1976. Thus, the minimum required volume in the day tank could be reduced from 2670 gallons to 519 gallons.

The proposed change will only reduce the TS minimum inventory in the fuel oil day tank from 2670 gallons to 1457 gallons. The new minimum level of 1457 gallons continues to provide significant margin above the equivalent ANSI N195-1976 required 519 gallons. An inventory of 1457 gallons would increase the response time available to restore a makeup rate of 7.4 gpm of fuel oil to the engine day tank. In addition, since the normal, controlled level remains unchanged, a test volume of approximately 1200 gallons of fuel oil is obtained. This volume reduction could reduce the overall operating time of the EDG by approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (from 9 days, 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> to 9 days, 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />); however, significant margin above the seven-day minimum required operating time continues to exist.

(1249HNP)

ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR DAY TANK LEVEL 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a 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, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power 6 Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:

Pro osed Chan e The proposed amendment revises Technical Specifications 3.8.1.1.b.l and 3.8.1.2.b.l concerning the emergency diesel generator (EDG) fuel oil day tank minimum level. Specifically, the change revises the minimum required level from 2670 gallons to 1457 gallons and adds a footnote which clarifies the differences in assumed fuel oil specific gravities.

Basis This change,does not involve a significant hazards consideration for the following reasons:

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change only revises the minimum Technical Specification day tank fuel oil level from 2670 gallons to 1457 gallons. It does not change any existing EDG system components or the control/alarm logic. The normal, controlled amount of fuel in the day tank is unchanged.

Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change only revises the minimum Technical Specification day tank fuel oil level from 2670 gallons to 1457 gallons. It does not change any existing EDG system components or the control/alarm logic. In addition, the proposed change does not introduce any new components or system control/alarm logic, nor does it change the normal, controlled amount of fuel in the day tank. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(1249HHP)

ENCLOSURE 2 (continued)

The proposed amendment does not involve a significant reduction in the margin of safety.

The present design for automatic makeup and level alarm of the fuel oil day tank for each EDG is unchanged and exceeds the performance requirements of ANSI N195-1976, Section 6.1. The proposed change only reduces the volume of fuel oil in the day tank that places the system in a Technical Specification action statement. This change does not reduce the present setpoints for commencement of fuel oil makeup nor does it reduce the normal, controlled amount of fuel in the day tank. This volume reduction could reduce the overall operating time of the EDG by approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (from 9 days, 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> to 9 days, ll hours);

however, significant margin above the seven-day minimum required operating time continues to exist. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

(1249HHP)

ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR DAY TANK LEVEL ENVIRONMENTAL CONSIDERATIONS 10CFR51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site; (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power & Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9). Pursuant to 10CFR51.22(b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e The proposed amendment revises Technical Specifications 3.8.1.1.b.l and 3.8.1.2.b.l concerning the emergency diesel generator (EDG) fuel oil day tank minimum level. Specifically, the change revises the minimum required level from 2670 gallons to 1457 gallons and adds a footnote which clarifies the differences in assumed fuel oil specific gravities.

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9) for the following reasons:

As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site.

The propose amendment does not introduce any new equipment nor does it require existing equipment or systems to perform a different type of function than they are currently designed to perform. As such, the change can not affect the types or amounts of any effluents that may be released off-site.

(1249HHP)

ENCLOSURE 3 (continued)

The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not change the way existing surveillances or testing requirements are performed nor does it add any additional surveillances or testing requirements. Therefore, the amendment has no effect on either individual or cumulative occupational radiation exposure.

(1249HNP)