JPN-93-083, Proposed Tech Specs,Removing Reference to ASTM Std D 270-65 from Surveillance Requirment 4.12.A.1.i

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Proposed Tech Specs,Removing Reference to ASTM Std D 270-65 from Surveillance Requirment 4.12.A.1.i
ML20062M598
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/22/1993
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20062M520 List:
References
JPN-93-083, JPN-93-83, NUDOCS 9401100105
Download: ML20062M598 (4)
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Attachment I to JPN-93-083 PROPOSED TECHNICAL SPECIFICATION CHANGES DIESEL FUEL OlL SAMPLING CLARIFICATION ,

(JPTS-93-001) 1 J

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New York Power Authority J l

JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9401100105 931222 I

' l PDR ADOCK 05000333 P PDR d 'I a

JAFNPP A. Hioh Pressure Water Fire Protection System (Cont'd) A. Hiah Pressure Water Fire Protection System (Cont'd)

3. If 1. above cannot be fulfilled, place the reactor in Hot item Freauency Standby within six (6) hours and in Cold Shutdown within the following thirty (30) hours. h. Fire pump diesel engine Once/ Month by verifying the fuel storage tank contains at least 172 gallons of fuel.
i. Diesel fuel from each tank is Once/ Quarter l within the acceptable limits for quality as per the following:

Flash Point 'F 125'F min.

Pour Point 'F 10*F max.

Water & Sediment 0.05% max.

Ash 0.01 % max.

Distillation 90% Point 540 min.

Viscosity (SSU) @ 100*F 40 max.

Sulfur 1 % max.

Copper Strip Corrosion No. 3 max.

Cetane # 35 min.

j. Fire pump diesel engine by Once/18 months inspection during shut down in accordance with procedures prepared in conjunction with manufacturers recommendations and verifying the diesel, starts from ambient conditions on the auto start signal and operates for A20 minutes while loaded with the fire pump.

Amendment No. 3474f',1907 244c

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Attachm:nt 11 to JPN-93-083 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES DIESEL FUEL OIL SAMPLING CLARIFICATION UPTS-93-001)

1. DESCRIPTION OF THE PROPOSED CHANGE The proposed change to the James A. FitzPatrick Technical Specifications is addressed below.

Minor changes in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographicalin nature and do not affect the content of the Technical Specifications.

Paae 244c. Soecification 4.12.A.1.i Delete the words "obtained in accordance with ASTM-D270-65."

II. PURPOSE OF THE PROPOSED CHANGE The proposed change to the Technical Specifications removes the reference to American Society for Testing and Materials (ASTM) Standard D 270-65 (Reference 1) from Surveillance Requirement 4.12.A.1.i. ASTM D 270-65, which specifies procedures to draw a representative fuel oil sample, has been superseded and is no I longer in effect. Surveillance Procedure PSP-7 (Reference 2) currently requires sampling in accordance with ASTM D 270-65 but notes that it has been superseded by ASTM D 4057-88 (Reference 3). The proposed change makes Surveillance Requirement 4.12.A.1.i consistent with fuel oil Surveillance Requirement 4.9.C.1, for the emergency diesel generators, by adopting the current industry fuel oil sampling standard (Reference 3). There are no changes to the acceptance criteria for fuel oil quality which are based on ASTM D 975-81 (Reference 4).

Ill. SAFETY IMPLICATIONS OF THE PROPOSED CHANGE Removal of ASTM D 270-65 as the method to sample diesel fuel oil has no adverse affects on plant safety. The proposed change will remove an unnecessary restriction on diesel fuel oil sampling by removing ASTM D 270-65 frorn Surveillance Requirement 4.12.A.1.i. The change is consistent with Surveillance Requirement 4.9.C.1 for the Emergency Diesel Generators (EDG) and the Standard Technical Specifications (STS) (Reference 5).

Improved Fuel Oil Sampling Flexibility Removing reference to ASTM D 270-65 from Surveillance Requirement 4.12.A.1.i will allow ASTM D 4057-88 to be used as the sampling method for the diesel fire pump fuel oil. ASTM D 4057-88, " covers procedures for obtaining representative samples of stocks or shipments of uniform petroleum products ..." The proposed  !

change provides a positive safety benefit by allowing the current industry '

standard for fuel oil sampling to be adopted. The proposed change deletes the referei ..e to an industry standard so that adoption of subsequent industry standards will not require a license amendment.

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Attachm:nt ll to JPN-93-083 SAFETY EVALUATION ,

Page 2 of 4 )

Improved Consistency with the EDG Surveillance Requirement and the STS i

Surveillance Requirement 4.9.C.1 establishes quality requirements for EDG fuel oil that are identical to Surveillance Requirement 4.12.A.1.i. However, Surveillance i Requirement 4.9.C.1 does not require a specific standard for diesel fuel oil sampling. The removal of ASTM D 270-65 makes Surveiliance Requireinent 4.12.A.1.i consistent with Surveillance Requirement 4.9.C.1.

STS Surveillance Requirement 3.8.3.3 specifies fuel oil sampling in accordance with the Diesel Fuel Oil Testing Program. The description of this program in the STS Bases identifies several standards but no specific standard for sampling fuel oil. The STS Bases does reference ASTM D 975-(undated) for fuel oil properties. '

The current standard, ASTM D 975-92 (Reference 6), references ASTM D 4057-(undated) for the sampling method. The proposed change is consistent since it removes ASTM D 270-65 provio.og the flexibility to adopt the applicable industry standard, ASTM D 4057-88. Providing consistency within the Technical Specifications and using the STS to evaluate Technical Specification changes will not decrease plant safety. ,

The changes will not require modification of any plant structures, systems or components and will not alter the conclusions of the plant's accident analyses as  ;

documented in the FSAR or the NRC staff SER.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

Plant accident analyses are not affected by the Technical Specification change.

The change removes reference to ASTM D 270-65 as the method for obtaining  ;

samples of diesel fuel oil from Surveillance Requirement 4.12.A.1.i. The '

American Society for Testing and Materials has superseded ASTM D 270-65 with ASTM D 4057. The proposed change provides improved flexibility to adopt standards as they are issued without requiring a license amendment and makes Surveillance Requirement 4.12.A.1.i consistent with both Surveillance Requirement 4.9.C.1 for the EDG and the STS. The nature of this change will not cause any increase in the probability or consequences of previously evaluated ,

accidents.

2. create the possibility of a new or different kind of accident from those previously evaluated.

The proposed change involves no hardware modifications to any plant structures, systems or components. The change removes reference to ASTM D 270-65 as

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5 14- c Attachmsnt 11 to JPN-93-083. .!

V SAFETY EVALUATION I Page 3 of 4 a .

' the method for obtaining samples of diesel fuel oil from Surveillance Requirement .

4.12.A.1.i. ' The American Society for Testing and Materials has superseded j ASTM D 270-65 with ASTM D 4057. The nature of this change is such that no? ~i new or different kind of accident can be created. ",

I

3. involve's significant reduction in the margin of safety.

The proposed change will not cause a reduction in the margin of safety. The - .l results of the plant accident analyses continue to bound operation under the- l proposed changes so there is no reduction in the margin of safety. The change  ;

removes reference to ASTM D 270-65 to allow the use of ASTM D 4057-88 as - i the method for obtaining samples of diesel fire pump fuel oil. The change will  :

make Survei_Ilance Requirement 4,12.A.1.i consistent with existing Surveillance )

Requirement 4.9.C.1 for the EDG and allow current standards to be used for fuel- .

oil sampling. Revisions of this nature will not cause a reduction in the margin of. j safety.  !

V. IMPLEMENTATION OF THE PROPOSED CHANGES 'i Implementation of the proposed changes removes reference to ASTM D 270-65 a's i the method for obtaining samples of diesel fuel oil from Surveillance Requirement 'l 4.12.A.1.i. This change will not affect the ALARA or Fire Protection Programs at the . 'l FitzPatrick plant, nor will the changes affect the environment. 1 VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as I defined in 10 CFR 50.59. That is, they: Jl

1. will not increase the probability or consequences of an accident or' malfunction of equipment important to safety as previously evaluated in the Safety Analysis j

r Report; i

2. will not create the possibility of an accident or malfunction of a type different l from any previously evaluated in the Safety Analysis Report; and j
3. will not reduce the margin of safety as defined in the basis for any technical  :

specification.

{

The changes involve no significant hazards consideration, as defined in i 10 CFR 50.92. ,

VII. REFERENCES -

1. American Society for Testing and Materials, ASTM D 270-65 " Sampling Pettoleum and Pettoleum Products."
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Attachment il to JPN-93-083 SAFETY EVALUATION Page 4 of 4

2. James A. FitzPatrick Nuclear Power Plant Process Surveillance Procedure PSP-7,

" Diesel Fuel Oil Sampling and Analysis," Revision 8, dated September 5,1991.

3. American Society for Testing and Materials, ASTM D 4057-88 " Manual Sampling of Petroleum and Petroleum Products."
4. American Society for Testing and Materials, ASTM D 975-81 " Standard Specifications for Diesel Fuel Oils."
5. NUREG-1433 " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)," Revision 0, dated September 1992.
6. American Society for Testing and Materials, ASTM D 975-92 " Standard Specifications for Diesel Fuel Oils."
7. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report Section 9.8.4 " Inspection and Testing," through Revision 5, dated January 1993.
8. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.

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Attachment lit to JPN-93-083

' PROPOSED TECHNICAL SPECIFICATION CHANGE - -

DIESEL FUEL OIL SAMPLING CLARIFICATION ,

MARKUP OF TECHNICAL SPECIFICATION PAGE l

(JPTS-93-001) l i

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New York Power Authority 1 JAMES A. FITZPATRICK NUCLEAR POWER PLANT-Docket No. 50-333 -  :

DPR-59  !

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o. ..

JAFNPP t .

l ' A. Hiah Pressure Water Fire Protection System (Cont'd) A. Hiah Pressure Water Fire Protection System (Cont'd)

3. If 1. above cannot be fulfilled, place the reactor in Hot jlam Freauency Standby within six (G) hours and in Cold Stmtdown within the following thirty (30) hours. h. Fire pump diesel engine Once/ Month by verifying the fuel storage tank contains at least 172 gallons of fuel.
i. Diesel fuel from each o Once/Ouarter ta tained in accordance with)

ASTM.n>7n fi5)is within the acceptable limits for quality as per the following:

Flash Point *F 125'F min.

Pour Point 'F 10*F max.

Water & Sediment 0.05% max.

Ash 0.01 % max.

Distillatico 90% Point 540 min.

Viscosity (SSU) @ 100*F 40 max.

Sulfur 1% max.

Copper Strip Corrosion No. 3 max.

Cetane # 35 min.

j. Fire pump diesel engine Once/18 months by inspection during shut down in accordance with procedures prepared in conjunction with manufacturers recommendations and verifying the diesel, starts from ambient conditions on the auto start signal and operates for 2 20 minutes while loaded with the fire pump.-

Amendment No. p. If4,190 244c

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