ML061510199

Proposed Technical Specifications Change Diesel Fuel Oil Testing Program

ML061510199
Person / Time
Site:	North Anna
Issue date:	05/30/2006
From:	Grecheck E Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
06-320A
Download: ML061510199 (13)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 3 0 , 2006 U.S. Nuclear Regulatory Commission Serial No. 06-320A Attention: Document Control Desk NL&OS/ETS RO Washington] D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE DIESEL FUEL OIL TESTING PROGRAM In a May 8, 2006 letter (Serial No.06-320) Virginia Electric and Power Company (Dominion) requested amendments] in the form of a change to the Technical Specifications (TS) to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed change relocates the ASTM standard being used to test the total particulate concentration of the stored fuel oil to a licensee controlled program consistent with the intent of Technical Specifications Task Force (TSTF) Traveler 374-A, Rev 0, Revision to TS 5.5.13 and Associated Bases for Diesel Fuel Oil. The testing standard will be incorporated into the TS Bases upon NRCs approval of the proposed amendment.

Subsequent to this submittal, it was noted that Attachments 2 and 3 had been inadvertently omitted during transmittal of the May 8, 2006 letter. This letter supercedes the May 8, 2006 letter in its entirety. Please use this letter to complete your review of this proposed Technical Specification change.

If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Very truly yours, Eugene S. Grecheck Vice President - Nuclear Support Services Attachments

1. Discussion of Change

2. Mark-up of Unit 1 and Unit 2 Technical Specifications Change

3. Proposed Unit 1 and Unit 2 Technical Specifications Change Commitments made in this letter: None

06-320A Docket Nos. 50-338/339 Page 2 of 3 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. Stephen R. Monarque NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative lnnsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, VA 23218

06-320A Docket Nos. 50-338/339 Page 3 of 3 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO 1 The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is Vice President -

Nuclear Support Services, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 3 6 ) % a y of ,2006.

My Commission Expires:

I Notary Public (SEAL)

Serial No. 06-320A Docket Nos. 50-3381339 Attachment 1 Discussion of Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No. 06-320A Docket Nos. 50-338/339 DISCUSSION OF CHANGE Introduction Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests a change to Technical Specifications 5.5.1 2, Diesel Fuel Oil Testing Program to relocate the specific American Society for Testing and Materials (ASTM) standard used for particulate contamination testing of the stored fuel oil to a licensee-controlleddocument.

The change is consistent with Technical Specification Task Force Improved Standard Technical Specifications Change Traveler (TSTF-374-A, Rev 0), Revision to TS 5.5.1 3 and associated TS Bases for Diesel Fuel Oil. The testing standard will be incorporated into the TS Bases upon the NRCs approval of the proposed amendment and maintained in accordance with the Bases Control Program.

Desian/Licensina Bases The initial conditions of a Design Basis Accident and transient analysis assume Engineered Safety Function (ESF) systems are operable. The diesel generators are designed to provide capacity, capability] redundancy, and reliability to ensure the availability of necessary power to ESF systems so that nuclear fuel, Reactor Coolant System, and containment design limits are not exceeded. For proper operation of the diesel generators] it is necessary to ensure the proper quality and properties of the fuel oil. The diesel generator fuel oil properties governed by the Diesel Fuel Oil Testing Program (TS 5.5.12) are the water and sediment content, the kinematic viscosity, specific gravity or API gravity, and particulate level.

Discussion Program Section 5.5.12 was added to the Technical Specifications during the conversion to the Improved Technical Specifications. The purpose of Section 5.5.1 2 was to establish a diesel fuel oil testing program that set specific limits and testing requirements for both new and stored diesel fuel oil. The program included sampling and testing requirements with acceptance criteria, in accordance with applicable ASTM Standards that support EDG operability. If these requirements and acceptance criteria are exceeded, they can cause a degradation of the EDGs capability.

The proposed change will adopt the intent of Technical Specification Task Force (TSTF)

Improved Standard Technical Specification Change Traveler (TSTF-374-A, Rev O),

Revision to TS 5.5.1 3 (TS 5.5.12 at North Anna) and Associated Bases for Diesel Fuel Oil. The change will revises TS 5.5.1 2.c to relocate the ASTM Standard reference from the Technical Specification Ad ministrative Section to a licensee-cont rolled document (Technical Specification Bases Section 3.8.3). The test frequency of 92 days will remain the same. This frequency is based upon the ITS submittal] whereby Justification for Deviation (Item 11) modified TS 5.5.12.c to add the word stored fuel oil and maintain the frequency for the EDG fuel oil testing at every 92 days. This frequency was based upon plant operating practice of conducting the surveillance every 92 days, Page 1 of 5

Serial No. 06-320A Docket Nos. 50-338/339 test history indicating that the interval was appropriate, and the fact that there were no Technical Specification requirements to perform this test.

In addition, North Anna elected not to adopt the performance of a clear and bright appearance with proper color test required by TS 5.5.12.a.3. In lieu of the clear and bright test, North Anna elected to require a water and sediment test (50.05%) as part of determining acceptability of new fuel oil prior to its addition to the storage tanks. As stated in our Justification for Deviation (Item lo), the water and sediment test was adopted because the diesel oil used at North Anna is dyed. Therefore, this portion of TSTF-374-A Rev 1 will not be implemented with this change.

The Bases of Technical Specification (SR 3.8.3.2) states that particulate concentration should be determined in accordance with ASTM D2276-83. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. The current frequency for conducting this test is every 92 days, which takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between surveillances. The testing frequency of 92 days will remain the same.

The proposed change to TS 5.5.12.c will provide the flexibility of using 10 CFR 50.59 to implement required testing of both new fuel oil and stored fuel oil, including sampling and testing requirements, in accordance with applicable ASTM standards, whenever there are changes in EPA regulations for fuel oil or newer editions of the ASTM standards. Currently the use of a different ASTM Standard than specified in TS 5.5.1 2.c or a newer edition of the ASTM Standard is not permitted without an Amendment to the TS. NUREG-1431 Rev 1 previously relocated all references to ASTM Standards to licensee controlled documents, with the exception of TS 5.5.1 2.c.

Precedent The proposed change is consistent with those presented and approved by the NRC with the approval of TSTF-374-A, Rev 0 in letter dated January 13, 2005.

ProDosed Chanae The proposed change revises TS 5.5.12 as follows:

TS 5.5.1 2.c currently states, Total particulate concentration of the stored fuel oil is 5 10 mg/l when tested every 92 days in accordance with ASTM D-2276, Method A-2 or A-3; and TS 5.5.1 2.c will be revised to state:

Total particulate concentration of the stored fuel oil is 5 10 mg/l when tested every 92 days; and Page 2 of 5

Serial No. 06-320A Docket Nos. 50-338/339 Environmental Review 10 CFR 51.22(~)(9)provides criteria for the identification of licensing and regulatory action eligible for categorical exclusion for performing an environmental assessment. A proposed amendment to an operating license for a facility does not require an 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 offsite, and (3) result in a significant increase in individual or cumulative occupation radiation exposure.

The proposed change to relocate references to ASTM Standards to a licensee controlled document has been reviewed and determined that it meets the eligibility criteria far categorical exclusion set forth in 10 CFR 51.22(~)(9). Pursuant to 10 CFR 51.22(~)(!3),no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the proposed license amendment. The basis for this determination is as follows:

1. The aimendment involves no significant hazards consideration.

As described in the significant hazards consideration evaluation, the proposed change does not involve a significant hazards consideration.

2. There is no significant change in the type or significant increase in the amounts of any effluents that may be released offsite.

The proposed change does not involve the installation of any new equipment, or the modifilcation of any equipment that may affect the types or amounts of effluents that may b'e released offsite. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

3. There is no significant increase in individual or cumulative occupation radiation expow re.

The proposed change does not involve plant physical changes, or introduce any new mode of operation. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.

Page 3 of 5

Serial No. 06-320A Docket Nos. 50-3381339 Sianificant Hazards Consideration Determination Dominion has reviewed the criteria as set forth in 10 CFR 50.92 as they relate to the proposed change and determined that the change does not represent a significant hazards consideration. This is consistent with the conclusion determined by Technical Specification Task Force Improved Standard Technical Specifications Change Traveler (TSTF)-374-AJRev 0. The proposed change revises the TS 5.5.12, Diesel Fuel Oil Testing Program, to remove the specific reference to ASTM Standards. The following is provided to support this conclusion:

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

The proposed change relocates the specific ASTM reference from the Administrative Controls Section of Technical Specifications (TS) to a licensee-controlled document.

Relocating the specific ASTM Standard reference from the TS to a licensee controlled document will not affect nor degrade the ability of the EDGs to perform their specified safety function. Fuel oil quality will continue to meet the current ASTM requirements for particulate concentration.

The proposed change is administrative in nature and does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configiuration of the facility or the manner in which the plant is operated and maintained. The proposed change does not alter or prevent the ability of structures, systems or components from performing their intended function to mitigate the consequences on an initiating event with the assumed acceptance limits. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types and amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupationaVpublic radiation exposiJre.

Therefore, the change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do changes create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change relocates the specific ASTM reference from the Administrative Controls Section of Technical Specifications to a licensee-controlleddocument.

The change does not involve a physical alteration of the plant or a change in the methods governing normal plant conditions. In addition, the change does not impose any new or different requirements or eliminate any existing requirements.

The change does not alter assumptions made in the safety analysis and licensing Page 4 of 5

Serial No. 06-320A Docket Nos. 50-3381339 basis. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do changes involve a significant reduction in the margin of safety?

The proposed change relocates the specific ASTM reference from the Administrative Controls Section of TS to a licensee-controlled document. The detail associated with thie specific ASTM standard reference is not required to be in the TS to provide adequate protection of the public health and safety, since the TS still retain the requirement for compliance with the applicable ASTM standard.

The level of safety of facility operation is unaffected by the proposed change since there is no change in the intent of the TS requirements of assuring fuel oil is of the appropriate quality for EDG use. The proposed change provides the flexibility needed to maintain state-of-the-art technology in fuel oil sampling and analysis methold0Iogy .

The proposed change does not reduce a margin of safety since it has no impact on any transient or safety.

Conclusion The proposed Technical Specification change will continue to assure that the quality of the diesel fuel will be maintained at standards that provide high reliability of diesel avaiIabiIity.

References The following references support the proposed Technical Specification change and the evaluation of this change.

1. NUREG 1431, Rev 1, Improved Standard Technical Specifications Westinghouse Plants, Improved Technical Specifications 3.8.3, Diesel Fuel Oil and Starting Air with supporting Bases, and 5.5.12, Diesel Fuel Oil Testing Program.

2. Technrical Specification Task Force (TSTF) Improved Standard Technical Specifiication Change Traveler, TSTF-374-A, Rev 0, Revision to TS 5.5.1 3 and Associated TS Bases for Diesel Fuel Oil.

3. NRC Letter dated January 13, 2005 from NRC to the Members of the Technical Specifiication Task Force (NRCs Approval and Safety Evaluation Report for TSTF-374).

4. UFSAR Chapter 9.5.4, EDG Fuel Oil Storage and Transfer System.

Page 5 of 5

Serial No. 06-320A Docket Nos. 50-3381339 Attachment 2 Mark-up of Unit 1 and Unit 2 Technical Specifications Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Programs and Manual s 5.5 5.5 Programs and Manuals 5.5.12 Iliesel Fuel Oil Testing Program R diesel fuel oil testing program t o implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall i ncl ude sampl i ng and testing requi rements , and acceptance c r i t e r i a , a l l in accordance with applicable ASTM Standards. The purpose of the program i s t o establish the following:

ii. Acceptability o f new fuel oil for use prior t o addition t o storage tanks by determining t h a t the fuel o i l has:

1. an API g r a v i t y or an absolute specific g r a v i t y within limits,

2. a flash point and kinematic viscosity w i t h i n limits f o r ASTM 2D fuel oi 1 , and

3. water and sediment 50.05%.

b. Within 31 days following addition of the new fuel oil t o storage tanks verify t h a t the properties of the new fuel o i l , other than those addressed in a . above, are within limits for ASTM 20 fuel oil;

c. Total particulate concentration of the stored fuel o i l i s I 10 mg/l when tested every 92 days A -

L m A-3; and

d. The provisions o f SR 3.0.2 and SR 3.0.3 are applicable t o the Diesel Fuel O i 1 Testing Program testing Frequencies.

5.5.13 jrechnical Specifications (TS) Bases Control Program This program provides a means for processing changes t o the Bases of these Technical Specifications.

ii. Changes t o the Bases o f the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes t o Bases without prior NRC approval provided the changes do not require either of the following:

1. a change in the TS incorporated in the 1 icense; or (continued)

North Anna Units 1 and 2 5.5-16 Amendments 23k+?i+g

Serial No. 06-320A Docket Nos. 50-338/339 Attachment 3 Proposed Unit 1 and Unit 2 Technical Specifications Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Programs and Manua I s 5.5 5.5 Programs and Manuals 5.5.12 Diesel Fuel O i l Testinq Proqram A diesel f u e l o i l t e s t i n g program t o implement required t e s t ng o f both new f u e l o i I and stored f u e l oi I shal I be establ ished. he program s h a l l include sampling and t e s t i n g requirements, and acceptance c r i t e r i a , a l l i n accordance w i t h applicable ASTM Standards. The purpose o f t h e program i s t o e s t a b l i s h t h e f o I owi ng :

a. A c c e p t a b i l i t y o f new f u e l o i l f o r use p r i o r t o a d d i t i o n t o storage tanks by determi ni ng t h a t t h e f u e l o i I has:

1 . an API g r a v i t y o r an absolute s p e c i f i c g r a v i t y w i t h i n I imits,

2. a f l a s h p o i n t and kinematic v i s c o s i t y w i t h i n l i m i t s f o r ASTM 2D f u e l o i I , and

3. water and sediment I 0 . 0 5 % .

b. Within 31 days f o l lowing a d d i t i o n o f t h e new f u e l o i I t o storage tanks v e r i f y t h a t t h e properties o f t h e new f u e l o i I , other than those addressed i n a . above, are w i t h i n l i m i t s f o r ASTM 2D f u e l oi I ;

C. Total p a r t i c u l a t e concentration o f t h e stored f u e l o i l i s I 1 0 mg/l when t e s t e d every 92 days; and

d. The provisions o f SR 3 . 0 . 2 and SR 3 . 0 . 3 are applicable t o t h e Diesel Fuel O i l Testing Program t e s t i n g Frequencies.

5.5.13 Techn i ca I Speci f i c a t i ons (TS) Bases Contro I Proqram This program provides a means f o r processing changes t o the Bases o f these Technical Specifications.

a. Changes t o t h e Bases o f t h e TS s h a l l be made under appropriate a d m i n i s t r a t i v e c o n t r o l s and reviews.

b. Licensees may make changes t o Bases without p r i o r NRC approval provided t h e changes do n o t r e q u i r e e i t h e r o f t h e f o l l o w i n g :

1 . a change i n t h e TS incorporated i n t h e I icense; o r (cont i nued)

North Anna U n i t s 1 and 2 5.5-16