ML20141L974

Discusses Request for Justification Re Adequacy of TS 3.8.1 on Fuel Oil Vol in Diesel Generator Tanks

ML20141L974
Person / Time
Site:	Callaway
Issue date:	05/28/1997
From:	Naslund C UNION ELECTRIC CO.
To:	NRC
References
ULNRC-3588, NUDOCS 9706030276
Download: ML20141L974 (3)

Text

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, Ca!!away Plant a Post Offn:e Ehu 620  ;

Fulton. Misscari 6E251 '

UMON Etscnuc g

May 28,1997 1

U.S. Nuclear Regulatory Commission ULNRC-3588 ,

Mail Station PI-137 Washington, DC 20555 '

Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT  !

l REQUEST FOR JUSTIFICATION REGARDING ADEQUACY l OF TECHNICAL SPECIFICATION 3 8.1

Reference:

1) NRC Letter dated May 8,1997 l 2) Amendment 100 to Facility Operating License l NPF 30, for Callaway Plant dated July 6,1995

3) ULNRC-2824 dated July 16,1993

4) ULNRC-2042 dated July 21,1989

5) ULNRC-3578 dated May 15,1997 i

l In Reference 1 the NRC Project Manager for Callaway requested that ]

Union Electric provide justification for not pursuing a Technical Specification l

- (TS) a:nendment for the fuel oil volume currently specified in TS 3.8.1.1.b.2),

i or s ubmit an amendment request to reflect a revised volume / level required in th:

j diesel generator (DG) fuel oil day tanks. Reference 2 and 3 revised the same j specification for the DG day tank volume to the currently required value of 510 l gallons. This value is the amount of fuel oil required to allow a DG to operate at its continuous rating for one hour plus a 10% margin.

l The diesel generators have a number of support and auxiliary systems I

w'dch are necessary for operation. These include control, cooling, lubrication, air, and fuel oil systems. The standard TS and Callaway's TS Limiting Conditions for Ormtion (LCO) only specify a day tank volum tank volume, and a ruel oil transfer pump for each DG. There are numerous D other components and parameters that are necessary, but not directly required

. by the LCO to maintain operability of the DGs. These must be considered, regardless of there being an explicit requirement, when determining the operable status of our DGs per Tech Spec 1.0.

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!6 U.S. Nuclear Regulatory Commission May 28,1997-Page 2 l

(. For the Callaway DGs, level in the day tank standpipes is maintained above 88" which ensures both the 510 gallon volume and the injection headers remain full. The level is maintained automatically for each DG by a fuel oil transfer pump taking suction from its associated underground storage tank.

Maintaining the level in the standpipes is a functional requirement for the fuel oil transfer pump subsystem. If the fuel oil level is found to be below the control band or if the transfer subsystem is not capable of automatically maintaining the standpipe level, the associated DG would be declared inoperable and actions taken as required by TS. A plant annunciator alarm is provided for low standpipe level for each DG. An example of this was reported in Reference 4 (Callaway LER 89-001-01). In that case a surveillance test identified that a main control board switch failure had the effect of preventing the transfer pump l l

from automatically supplying fuel to the day tank. The DG was declared inoperable and the switch was replaced prior to returning the DG to service.

The Callaway Technical Specifications are consistent with the STS. The parameters specified, plus other support and auxiliary systems monitored, provide assurance that the diesels will operate when required.

Union Electric submitted a TS conversion amendment request on May 15,1997 (See Reference 5). In Attachment 14, Enclosure 5B, the bases discussion for SR 3.8.1.4 incorrectly states the volume in the day tank is at or  ;

above the level at which fuel oil is automatically added. We will revise that request during the upcoming NRC review period to correct this statement and to -

address the DG day tank level in a manner similar to that done for Wolf Creek. 1 Generating Station. Their request contains a monthly surveillance that verifies the transfer pumps start on a low level associated with the day tank standpipe.

. The actual level is stated in the improved bases.

If you have any further questions please contact us.

Very truly yours,  !

Q.f C. . Naslund Manager, Nuclear Engineering l

I DS/pir i

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O cc: M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive  !

Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Kristine M. Thomas (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 l

Jefferson City, MO 65102 i

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l R. J. Irwin P. M. Barrett J. D. Blosser A. C. Passwater D. E. Shafer l l

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A. J. DiPerna, (Bechtel)

H. D. Bono l NSRB (Patty Reynolds) l A14 0. 0001. 002 (1110) i l

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