L-94-224, Forwards Revs to 940719 Proposed License Amends to Licenses DPR-31 & DPR-41,revising TS 4.8.1.1.2e & 4.8.1.1.2f,which Address EDG Fuel Oil Testing & Adding Action Statements G & H to TS 3.8.1.1,per Recent Conversation W/Nrc
| ML17352A826 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/20/1994 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17352A827 | List: |
| References | |
| L-94-224, TAC-M89936, TAC-M89937, NUDOCS 9410260298 | |
| Download: ML17352A826 (28) | |
Text
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I P'R.IC3H.I EV I
'ACCELERATED RIDS PROCESSING'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9410260298 DOC.DATE: 94/10/20 NOTARIZED: YES FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F.
Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000250 05000251
SUBJECT:
Application for amends to licenses DPR-31
& DPR-41,revising TS 4.8.1.1.2e 6 4.8.1.1.2f,addressing EDG fuel oil testing 6
adding action statements g
6 h to TS 3.8.1.1.
DISTRIBUTION CODE:
AOOID COPIES RECEIVED:LTR g ENCL $
SIZE: l 7~~
TITLE: OR Submittal:
General Distribution NOTES INTERNAL:
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/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 NRR/DE/EELB NRR/DRPW NRR/DSSA/SRXB OGC/HDS3 1
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1 1
0 RECIPIENT COPIES ID CODE/NAME LTTR ENCL PD2-2 PD 1
1 EXTERNAL: NOAC 1
1 NRC PDR 1
1 YOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO RFDUCE iVKSTE!COYTACT'I'IIEDOCUiIEYTCONTROL DESK, ROONI P I -37 (EXT. 504-o083 ) TO EL I XII.'PATE YOI'R i'Ai!LTFROi!
DISTRIBU'I'IOYLIS'I'S FOR DOCL'MEY,'I'SYO!:!MY."I'L'E~D!
TOTAL NUMBER OF COPIES REQUIRED:
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OCT 20 >Bgq L-94-224 10 CFR 550.36 10 CFR 550.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Gentlemen:
Re:
Turkey Point Units, 3 and 4
Docket Nos.
50-250 and 50-251 Proposed License Amendments Diesel Fuel Oil Testin Pro ram TAC No.
M89937 M89936 By letter L-94-144, dated July 19, 1994, Florida Power and Light (FPL)
Company requested that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to revise Turkey Point Units 3 and 4
Technical Specifications (TS) 4.8.1.1.2e.
and 4.8.1.1.2f.,
which address Emergency Diesel Generator (EDG) fuel oil testing.
In
- addition, FPL proposed the addition of ACTION statements g.
and h., to TS 3.8.1.1.,
to address the required action in the event the diesel fuel oil does'not meet the Diesel Fuel Oil Testing Program limits.
In response to a recent conversation with the staff, the proposed license amendment (PLA) is revised to include a description of the Diesel Fuel Oil Testing Program in TS 6.8.4, Procedures and Program.
In addition, FPL proposes a revision to TS Section 6.0 to include the programmatic responsibilities of the Plant Nuclear Safety Committee (PNSC) and Company Nuclear Review Board (CNRB) to review the Diesel Fuel Oil Testing Program and implementing procedures, as well as the requirement that written procedures be established, implemented and maintained for implementation of the Diesel Fuel Oil Testing Program.
The proposed ACTION statement
- g. to TS 3.8.1.1 is also revised to include the word "stored" in describing the fuel oil properties to be restored to within the required limits.
FPL has concluded that the proposed changes to the Technical Specifications do not alter the original conclusion rendered in L 144 that no significant hazards consideration exists pursuant to 10 CFR 550.92.
In order to support the staff' review, the original PLA is re-submitted in its entirety, with the proposed revisions.
A description of the amendment request is provided in Attachment 1.
The no significant hazards determination in support of the proposed Technical Specifications changes is provided in Attachment 2.
Attachment 3 provides the proposed revised Technical Specifications changes.
In accordance with 10 CFR 550.91(b)(1),
a copy of these proposed license amendments is being forwarded to the State Designee for the state of Florida.
The proposed amendments have been approved by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.
250"rg6 94102b0298 9'41020 an FPL GrouP comPanY PDR ADQCK 05000250 PDR LI
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L-94;224 Page 2
Should there be any questions on this request, please contact us.
Very truly yours, T.F. Plunkett Vice President Turkey Point Plant "TFP/EJW/RJT Attachments CC:
S.
D. Ebneter, Regional Administrator, Region II, USNRC T. P.
- Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services P
STATE OF FLORIDA COUNTY OF DADE
)
) ss.
)
T. F. Plunkett being first duly sworn, deposes and says:
That he is Vice President Turke Point Nuclear Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
, T. F. Plunkett Subscribed and sworn to before me this AO day of C ~7
- 1994, Name of Notary Public (Type or Print)
NOTARY PUBLIC, in and for the County of
- Dade, State of Florida My Commission expires Commission No.
CHEAYLA. KELLY MYCOWSSIN S CCnisi EXPQES: Sophebet 27. 189S "d~ p';+'ondedlhm Notary PuNc ~md~
T. F. Plunkett is personally known to me.
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ATTACHMENT 1 DESCRIPTION OF AMENDMENTS REQUEST
L-94-224 Attachment 1
Page 1 of 7
DESCRIPTION OF AMENDMENTS RE VEST Introducti.on Florida Power and Light Company (FPL) proposes to amend Turkey Point Units 3 and 4 Technical Specifications (TS) 4.8.1.1.2e.
and 4.8.1.1.2f.,
which address Emergency Diesel Generator (EDG) fuel oil
- testing, by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to verify new and stored EDG fuel oil in accordance with the Diesel Fuel Oil Testing Program.
In
- addition, FPL proposes the addition of ACTION statements
- g. and h., to TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits.
The Diesel Fuel Oil Testing Program will be described in both TS 6.8.4 and the BASES Section to the Technical Specifications.
In addition, FPL proposes the revision to TS Section 6 '
to include the programmatic responsibilities of the Plant Nuclear Safety Committee (PNSC) and Company Nuclear Review Board (CNRB) to review the Diesel Fuel Oil Testing Program and implementing procedures, as well as the requirement that written procedures shall be established, implemented and maintained for implementation of the Diesel Fuel Oil Testing Program.
The proposed amendments will improve flexibilityin accomplishing the Surveillance Requirements.
This flexibilityis required, for example, as a result of recent difficulties encountered in obtaining laboratory analyses as required by the TS, in that the specific testing standards have become out-dated and generally fallen into disuse.
While these difficulties can, and have been, overcome in the short term, the continued requirement to meet out-dated standards is economically expensive and provides no safety benefit.
Discussion American Society for Testing and Materials (ASTM) standards represent a
common viewpoint of parties concerned with the provisions of the particular testing standard.
A new volume of the Annual Book oof ASTH Standards is published annually because of additions of new standards and revisions in existing standards.
Certain ASTM standards are listed in the Turkey Point Units 3 and 4
Technical Specifications as the specific tests required to be performed on Emergency Diesel Generator (EDG) fuel oil.
The ASTM standards specified in the TS are:
ASTM-D4057: defines method foz obtaining a composite sample of new fuel oil prior to addition of new fuel oil to the diesel oil storage tanks.
ASTM-D975-81: defines and identifies testing to be performed on the new fuel oil.
L-94-224 Attachment 1
Page 2 of 7
ASTM-D1298-80: defines the testing methodology to be used on the new fuel oil prior to addition of the new fuel oil to the diesel fuel oil storage tanks to determine the acceptability of the fuel oil's specific gravity.
ASTM-D4176-82: defines the testing methodology to be used on the new fuel oil prior to addition of the new fuel oil to the diesel fuel oil storage tanks to determine the new fuel oil' clear and bright appearance with proper color.
ASTM-D1552-79: identifies one of two acceptable methods to be performed to analyze for sulfur in the fuel oil.
ASTM-D2622-82: identifies one of two acceptable methods to be performed to analyze for sulfur in the fuel oil.
ASTM-D2276-78: defines the method to be used in obtaining a fuel oil sample at least once every 31 days from the diesel fuel oil storage tanks and analyzing for total particulate contamination.
FPL proposes to change Turkey Point Units 3 and 4
TS Surveillance Requirements 4.8.1.1.2e.
and 4.8.1.1.2f.,
which address the EDG fuel oil testing requirements.
FPL proposes to revise the Turkey Point Units 3 and 4
TS by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to vezify new and stored EDG fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
The Diesel Fuel Oil Testing Program will be described in both TS 6.0 and the TS BASES Section.
The Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria will be listed in the BASES for the TS, as well as in the plant procedures used to test the EDG fuel oil on initial receipt and periodically, as currently required.
FPL proposes the addition of ACTION statement
- g. of TS 3.8.1.1 to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits.
A failure to meet the American Petroleum Institute (API) gravity, kinematic viscosity, flash point or clarity limits is cause foz rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage
- Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks.
Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage
- tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement
- g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits.
This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operation.
The diesel fuel oil surveillance in accordance with the Diesel Fuel Oil Testing Program will ensure the availability of high quality fuel oil
L-94-224 Attachment 1
Page 3 of 7 for the EDGs.
FPL proposes the addition of ACTION statement
- h. to TS 3.8.1.1, to address the required action in the event the stored fuel oil total particulates do not meet the Diesel Fuel Oil Testing Program limits.
At least once every 31 days, a sample of fuel oil is obtained from the storage tanks in accordance with ASTM-D2276-78.
The particulate contamination is verified to be less than 10 mg/liter when checked in accordance with ASTM-D2276-78, Method A. It is acceptable to obtain a
field sample for subsequent laboratory testing in lieu of field testing.
Fuel oil degradation during long term storage shows up as an inczease in particulate, due mostly to oxidation.
The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine.
The particulate can cause fouling of filters and fuel oil injection equipment,
- however, which can cause engine failure.
The fzequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Proposed ACTION statements g.
and h. of TS 3.8.1.1, are identical in intent to the statements specified in TS 3.8.3 of NUREG-1431, "Standard Technical Specifications Westinghouse Plants."
Changes to the Diesel Fuel Oil Testing Program will be accomplished pursuant to 10 CFR 550.59, "Changes,
- tests, and experiments."
Title 10 CFR 550.59 permits a licensee, among other things, (i) to make changes to the facility as described in the safety analysis report, or (ii) to make changes in the procedures as described in the safety analysis report, without prior NRC approval, unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question.
By deleting the specific reference in the
.TS of the testing standards being used to meet TS testing requirements, FPL could change an ASTM standard, or standard edition, without prior NRC approval, provided an unreviewed safety question did not exist.
An unreviewed safety question exists (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report may be created; or (iii) if the margin of safety as defined in the basis foz any technical specification is reduced.
FPL is required by 10 CFR 550.59(b)(1) to maintain records of any changes made pursuant to 10 CFR 550.59 and that these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Additionally, FPL is required to submit to the NRC periodically a report containing a brief description of any changes made pursuant to 10 CFR 550.59, as well as a summary of the safety evaluation of each change.
As a result, the NRC will periodically be informed of changes
L-94-224 Attachment 1
Page 4 of 7 that FPL may make to the Diesel Fuel Oil Testing Program.
Proposed Technical Specifications Changes FPL proposes to add TS 3.8.1.1 ACTION statements g.
and h., to read as follows (with the proposed new requirements in bold):
g, h.
Following the addition of the new fuel oil to the Diesel Fuel Oil Storage Tanks, with one or more diesel generators with new fuel oil properties outside the required Diesel Fuel Oil Testing Program limits, restore the stored fuel oil propezties to within the required limits within 30 days.
With one or more diesel generators with stored fuel oil total particulates outside the required Diesel Fuel Oil Testing Program limits, restore the fuel oil total particulates to within the required limits within 7 days.
2.
FPL proposes to revise TS SURVEILLANCE REQUIREMENTS 4.8.1.1.2e.
and 4.8.1.1.2f.,
to read as follows (with the proposed new requirements in bold):
4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE e.
By verifying fuel oil properties of new fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
By verifying fuel oil properties of stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
3.
FPL proposes to revise TS 6.5.1.6, to read as follows (with the proposed new requirements in bold):
6.5 '.6 The PNSC shall be responsible for:
m.
Review of the Diesel Fuel Oil Testing Program and implementing procedures.
4, FPL proposes to revise TS 6.5.2.8, to read as follows (with the proposed new requirements in bold):
6.5.2.8 n.
Audits of unit activities shall be performed under the cognizance of the CNRB.
These audits shall encompass:
The Diesel Fuel Oil Testing Program and implementing procedures.
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L-94-224 Attachment 1
Page 5 of 7 5.
FPL proposes to revise TS 6.8.1, to read as follows (with the proposed new requirements in bold):
6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
Diesel Fuel Oil Testing Program implementation.
FPL proposes to revise TS 6.8.4, to include a description of the Diesel Fuel Oil Testing Program (with the proposed new requirements in bold):
e.
Diesel Fuel Oil Testin Pzo ram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall 'be established.
The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards.
The purpose of the program is to establish the following:
a.
Acceptability of new fuel oil for use prior to addition to stoxage tanks by determining that the fuel oil has:
1.
an API Gravity or an absolute specific gravity within limits, 2.
a flash point and kinematic viscosity within limits fox Grade No. 2-D fuel oil per ASTM D975, and 3.
a clear and bright appearance with proper color; b.
Other px'operties for Grade No. 2-D fuel oil per ASTM D975 are within limits within 30 days following sampling and addition to storage tanks; and c ~
Total particulate concentration of the fuel oil is
< 10 mg/liter when tested every 31 days in accordance with either ASTM D-2276 or ASTM D-5452.
Additionally, FPL proposes to revise the BASES for TS 3/4.8.1 to address the Diesel Fuel Oil Testing Program's Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria for new and stored EDG fuel oil.
L-94-224 Attachment 1
Page 6 of 7
Bases of Pxoposed Changes ASTM standards represent a
common viewpoint of parties concerned with the provisions of the particular testing standard.
A new volume of the Annual Book of'STM Standards is published once a yeaz because of additions of new standards and revisions in existing standards.
An ASTM standard is subject to revision at any time by the technical committee and must be reviewed every five years and, if not revised, either re-approved oz withdrawn.
As a result, the most current version of a particular standard represents a consensus opinion with respect to the sufficiency of endorsed testing techniques.
A number of licensees, including Turkey Point Units 3 and 4, have submitted, in the recent past, Licensee Event Reports (LERs) to report situations in which the TS-identified fuel oil testing requirements were not being met because the offsite laboratory that performed the testing used a later revision of ASTM standards than were specified in the TS.
While these methods are considered acceptable, from an industrial perspective, they do not meet the legal requirements of the TS.
The proposed changes are consistent with the programmatic controls present in NUREG-1431, Surveillance Requirement (SR) 3.8.3.3 which states:
SURVEILLANCE FRE UENCY SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
In accordance with the Diesel Fuel Oil Testing Program In NUREG-1431,'he tests, limits, and applicable ASTM standaxds are listed in the TS BASES Section.
As a result, a licensee that has implemented NUREG-1431 can make changes to the ASTM standards or editions of the Diesel Fuel Oil Testing Pxogram, pursuant to 10 CFR 550.59.
FPL proposes the addition of ACTION statements
- g. and h. of TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits.
These proposed action statements axe identical in intent to the statements specified in TS 3.8.3 of NUREG-1431.
The Diesel Fuel"Oil Testing Pxogram will be described in both TS 6.8.4 and the BASES Section to the Technical Specifications.
In addition, FPL proposes the revision to TS Section 6.0 to include the programmatic responsibilities of the Plant Nuclear Safety Committee (PNSC) and Company Nuclear Review Board (CNRB) to review the Diesel Fuel Oil Testing Program and implementing pzocedures, as well as the requirement that written procedures shall be established, implemented and maintained for implementation of the Diesel Fuel Oil Testing
L-94-224 Attachment 1
Page 7 of 7
Program.
These requirements are identical in intent to the statements specified in NUREG-1431.
The proposed amendments will improve flexibilityin accomplishing the required Surveillance Requirements.
This flexibilityis required as a
result of recent difficulties encountered in obtaining laboratory analyses as required by the TS, in that the specific testing standards had become out-dated and generally fallen into disuse.
While these difficulties can, and have been, overcome in the short term, the continued requirement to meet out-dated standards is economically expensive and provides no safety benefit.
Changes to the Diesel Fuel Oil Testing Program will be accomplished pursuant to 10 CFR 550.59, "Changes,
- tests, and experiments."
Title 10 CFR 550.59 permits a licensee, among other things, to make changes in the facility described in the safety analysis report or to make changes in procedures as described in the safety analysis report, without prior NRC approval, unless the proposed change involves a
change in the Technical Specifications or an unreviewed safety question.
By deleting the specific reference in the TS of the testing standard being used to meet TS testing requirements, FPL could change an ASTM standard, oz standard edition, without prior NRC approval, provided an unreviewed safety question did not exist.
The TS BASES will address the Diesel Fuel Oil Testing Program's Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria for new and stored EDG fuel oil.
ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION
L-94-224 Attachment 2
Page 1 of 5 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of Proposed License Amendments Florida Power and Light Company (FPL) proposes to amend Turkey Point Units 3 and 4 Technical Specifications (TS) 4 '.1.1.2e.
and 4.8.1.1.2f
~, which address Emergency Diesel Generator (EDG) fuel oil
- testing, by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to verify new and stored EDG fuel oil in accordance with the Diesel Fuel Oil Testing Program.
In
- addition, FPL proposes the addition of ACTION statements g.
and h., to TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits.
The Diesel Fuel Oil Testing Pzogram will be described in both TS 6.8.4 and the BASES Section to the Technical Specifications.
In addition, FPL proposes revising TS 6.8.1 to include the requirement that written procedures shall be established, implemented and maintained for implementation of the Diesel Fuel Oil Testing Program.
Introduction The Nuclear Regulatory Commission has provided Standards for determining whether a significant hazards consideration exists (10 CFR 550.92 (c)).
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; or (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.
Each standard is discussed below for the proposed amendment.
Discussion (1)
Operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generatoz (EDG) fuel oil in accordance with the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program.
The proposed change will permit FPL to use more recent editions of the American Society for Testing and Materials (ASTM) standards currently listed in Technical Specification Surveillance Requirements 4.8.1
~ 1.2e.
and 4.8.1.1.2f.
Prior to changing the Diesel Fuel Oil Testing Program, the proposed change will be evaluated pursuant to Title 10 Code of Federal Regulations 550.59 (10 CFR 550.59),
"Changes,
- tests, and experiments."
Title 10 CFR 550.59 permits a licensee to make changes in the procedures as described in the safety analysis report without prior Commission
- approval, provided that the proposed changes does not involve an unreviewed safety question.
L-94-224 Attachment 2
Page 2 of 5 Title 10 CFR 550.59(a)(2) states that a proposed change involves an unreviewed safety question (i) if the probability of occurrence oz the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased.
Consequently, since any change to the Diesel Fuel Oil Testing Program, including the ASTM standard or ASTM edition standard to be used to evaluate EDG fuel oil acceptability, the change must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The EDG fuel oil TS Surveillance Requirements will be replaced with a requirement to test the EDG fuel oil in accordance with the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program.
ACTION statement
- g. of TS 3.8.1.1 is added to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits.
A failure to meet the American Petroleum Institute (API) gravity, kinematic viscosity,. flash point or clarity limits is cause for rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage
- Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks.
Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage
- tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement
- g. of TS 3.8.F 1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits.
This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operations ACTION statement
- h. of TS 3.8.1.1 is added to address the required action in the event the stored fuel oil total particulates do not meet the Diesel Fuel Oil Testing Program limits.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation.
The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine.
The frequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program, FPL will need to determine if the proposed program change is at least as, if not more, effective, in detecting unsatisfactory fuel oil.
The EDGs will thus continue to function as designed and the probability or consequences of previously evaluated accidents will be unaffected.
L-94-224 Attachment 2
Page 3 of 5
(2)
Operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generator fuel oil using moze recent editions of the American Society for Testing and Materials (ASTM) standards currently listed in Technical Specification Surveillance Requirements 4.8.1.1.2e.
and 4.8.1.1.2f.
Prior to changing the edition of the previously approved ASTM standard being used to evaluate the EDG fuel oil, the proposed edition standard will be evaluated pursuant to 10 CFR 550.59, "Changes,
- tests, and experiments."
Title 10 CFR 550.59 permits a licensee to make changes in the procedures as described in the safety analysis report without prior Commission approval, provided that the proposed changes does not involve an unzeviewed safety question.
Title 10 CFR 550.59(a)(2) states that a proposed change involves an unzeviewed safety question (ii) if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.
Consequently, since any change to the edition of the ASTM standard to be used to evaluate EDG fuel oil acceptability must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.
ACTION statement
- g. of TS 3,8.1.1 is added to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits.
A failure to meet the API gravity, kinematic viscosity, flash point or clarity limits is cause foz rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage
- Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks.
Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage
- tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement g, of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits'his additional 30 day period is acceptable because the fuel oil properties of
- interest, even if they are not within limits, would not have an immediate effect on EDG operation.
ACTION statement
- h. of TS 3.8.1.1 is added to address the required action in the event the stored fuel oil total particulates does not meet the Diesel Fuel Oil Testing Program limits.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation.
The
L-94-224 Attachment 2
Page 4 of 5
presence of particulate does not mean the fuel oil will not burn properly in a diesel engine.
The frequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program, FPL will need to determine if the proposed program change is at least as, if not more, effective, in detecting unsatisfactory fuel oil ~
Since the proposed changes do not involve a change in the design of any plant system or component, and since the proposed changes will need to evaluate the effect of any ASTM standard edition change on the level of EDG reliability, the change proposed will not create the possibility of a new or different kind of accident from any accident previously evaluated.
(3)
Operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generator (EDG) fuel oil using more recent editions of the American Society for Testing and Materials (ASTM) standards currently listed in Technical Specification Surveillance Requirements 4.8.1.1.2e.
and 4.8.1.1.2f.
Prior to changing the edition of the previously approved ASTM standard being used to evaluate the EDG fuel oil, the proposed edition standard will be evaluated pursuant to 10 CFR 550.59, "Changes,
- tests, and experiments."
Title 10 CFR 550.59 permits a licensee to make changes in the procedures as described in the safety analysis report without prior NRC approval, provided that the proposed changes does not involve an unreviewed safety question.
Title 10 CFR 550.59(a)(2) states that a proposed change involves an unreviewed safety question (iii) if the margin of safety as defined in the basis for any technical specification is reduced.
Consequently, since any change to the edition of the ASTM standard to be used to evaluate EDG fuel oil acceptability must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
ACTION statement
- g. of TS 3.8.1.1 is added to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits.
A failure to meet the API gravity, kinematic viscosity, flash point or clarity limits is cause for rejecting, the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks.
Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage
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- tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement
- g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits.
This additional 30 day period is acceptable because the fuel oil properties of
- interest, even if they are not within limits, would not have an immediate effect on EDG operation.
ACTION statement
- h. of TS 3.8.1.1 is added to address the required action in the event the stored fuel oil total particulates does not meet the Diesel Fuel Oil Testing Program limits.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation.
The presence of particulate does not mean the fuel oil will not burn pzoperly in a diesel engine.
The frequency for performing surveillance on. stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Pxogram, FPL will need to determine if the proposed program change is at least as, if not more, effective, in detecting unsatisfactory fuel oil.
Since the proposed changes will require a safety evaluation to assure that the reliability of the EDGs using fuel oil tested in accordance with the different ASTM standard edition maintains the current margin of
- safety, the proposed changes do not involve a reduction in a margin of safety.
Summary Based on the above discussion, FPL has determined that the proposed amendment request does 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 a'ccident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety; therefore, the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 550.92.