ML061860225
| ML061860225 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/30/2006 |
| From: | Matthews W Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML061860225 (12) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY
- RICHMOND, VIRGINIA 2326 1 June 30, 2006 U.S. Nuclear Regulatory Commission Serial No.
06-3208 Attention: Document Control Desk NL&OS/ETS RO Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 NORTH ANNA POWER STATION UNITS 1 AND 2 TECHNICAL SPECIFICATIONS BASES CHANGE FOR DIESEL FUEL OIL TESTING PROGRAM TECHNICAL SPECIFICATION CHANGE 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.
This change is 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."
In the May 8, 2006 submittal, Dominion1 stated that the testing standard would be incorporated into the TS Bases upon NRC's approval of the proposed amendment.
In a June 12, 2006 conference call, the NRC staff requested that Dominion provide the marked-up and typed Bases pages for their review. Accordingly, attached for your information are the associated Bases changes for the proposed Technical Specification change. In addition to relocating the testing standard for total particulate concentration to the Bases, Dominion intends to also update the testing standard, as recommended by the ASTM Technical Committee D02, to ASTM D6217-98.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Very truly yours,
&&d&
William R. Matthews Senior Vice President - Nuclear Operations Attachments
- 1. Mark-up of Unit 1 and Unit 2 Technical Specifications Bases Changes
- 2. Typed Unit 1 and Unit 2 Technical Specifications Bases Changes Commitrr~ents made in this letter: None
06-3208 Docket Nos. 50-3381339 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 U. S. Nuclear Regulatory Commission One White Flint North 1 1 555 Rockville Pike Rackville, Maryland 20852 Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative lnrlsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, Virginia 23060 Calmmissioner Bureau of Radiological Health 15100 East Main Street Suite 240 Richmond, Virginia 2321 8
06-3208 Docket Nos. 50-3381339 Page 3 of 3 COMMONWEALTH OF VIRGINIA
)
1 COUNTY OF HENRICO 1
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by William R. Matthews, who is Senior Vice President
- Nuclear Operations, 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 30" day of 9-,2006.
My Commission Expires:
3!, 2008.
(SEAL)
06-3208 Docket Nos. 50-3381339 Mark-up of Unit 1 and Unit 2 Technical Specifications Bases Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)
Diesel Fuel Oil and Starting Air B 3.8.3 SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides veri fi cation that there i s an adequate inventory of fuel oil i n the storage tanks to support two EDGs ' operation for 7 days a t full load. The 7 day period i s sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsi t e location.
The 31 day Frequency i s adequate to ensure that a sufficient supply o f fuel oil i s available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oi 1 during this period.
The tests 1 i sted below are a means of determining whether new fuel oi 1 i s of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are w i t h i n acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), b u t in no case i s the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, 1 imi ts, and applicable ASTM Standards are as follows:
- a. Sample the new fuel oil i n accordance with ASTM D4057-88 (Ref. 6);
- b. Verify in accordance with the tests specified i n ASTM D975-89 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 2 0.83 and 5 0.89 or an API gravity a t 60°F of 2 27" and I 39" a kinematic viscosity a t 40°C of Z 1.9 centistokes and 5 4.1 centistokes, and a flash point of 2 125°F; and C
~ U ~ E R T 2
5
- c. Verify that the new fuel oil i s checked for water and i r L l I (cont i nued)
North Anna Units 1 and 2 B 3.8.3-6 Revi si on $'
Diesel Fuel Oi 1 and Starting Air B 3.8.3 SURVEILLANCE SR 3.8.3.2 (continued)
REOU I REMENTS Failure to meet any of the above limits i s cause for rejecting the new fuel oil, b u t does not represent a fai 1 ure to meet the LC0 concern since the fuel oil is not added to the storage tanks.
Within 31 days following the initial new fuel oil sample, the fuel oil i s analyzed to establish that the other properties speci f i ed in Tab1 e 1 of ASTM D975-89 (Ref. 7) are met for new fuel oi 1 when tested in accordance w i t h ASTM D975-89 (Ref. 6), except that the analysis for su1 fur may be performed i n accordance with ASTM D4294-98 (Ref. 6),
ASTM D1552-88 (Ref. 6) or ASTM D2622-82 (Ref. 6). The 31 day period i s acceptable because the fuel oil properties of interest, even i f they were not w i t h i n stated limits, would not have an immediate effect on EDG operation. This Survei 11 ance ensures the avai 1 abi 1 i ty of high qua1 i ty fuel oil for the EDGs.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly t o 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 fai 1 ure.
B62t7 -98 Parti cul ate concentrations should be determi ned i n accordance w i t h ASTM -BE!%% 93, -~=6s method involves a gravimetri c determination of total I
particulate concentration i n the fuel oil and has a limit of 10 mg/l. I t i s acceptable to obtain a fie1 d sample for subsequent laboratory testing i n lieu of field testing. Each tank i s considered and tested separately.
The Frequency of this test takes into consideration fuel oil degradation trends that indicate that parti cul ate concentration i s unlikely t o change significantly between Frequency interval s.
Thi s Survei 1 lance ensures that, without the aid of the refi 11 compressor, sufficient a i r s t a r t capacity for each EDG is available. The system design requirements were verified for a minimum of five engine s t a r t cycles without recharging. A start cycle is measured i n terms of time (cont i nued)
North Anna Units 1 and 2 B 3.8.3-7 Revision
Diesel Fuel O i 1 and Starting Air B 3.8.3 BASES REFERENCES 1
(continued) w s ( i R 1 5
- 7. ASTM Standards, D975, Table 1, 1989.
North Anna Units 1 and 2 Revi s i on 7
Inserts EDG Fuel Oil Bases Changes per TSTF-374-A Rev 0 lnsert 'I or a water and sediment content within limits Not used - previously incorporated lnsert 2
... whein tested in accordance with ASTM D287-82 (Ref. 6) lnsert 3
... content within limits when tested in accordance with ASTM D1796-83 (Ref. 6) lnsert 4
, or ASTM D4294-98 Not used - previously incorporated lnsert 5 ASTM Standards: D4057-88; D975-89; D l 522-88; D2622-82; D2276-82; D4292-98; D6217-98; D287-82; Dl 796-83.
These isre the inserts recommended in TSTF-374-A Rev 0 as modified to include the current testing standards used at North Anna.
Inserts 1 and 4 are not used since both the water and sediment test method and ASTM D4294-98 have been previously included in the EDG Fuel Oil Testing Program and associated TS Bases.
06-3208 Docket Nos. 50-3381339
'Typed Unit 1 and Unit 2 Technical Specifications Bases Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)
Diesel Fuel O i l and Starting A i r B 3.8.3 BASES SURVE l LLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there i s an adequate inventory o f fuel oi l in the storage tanks t o support two EDGs' operation f o r 7 days a t f u l l load. The 7 day period i s sufficient time t o place the u n i t i n a safe shutdown condition and t o br i ng i n rep1 eni shment fuel from an o f f s i t e l ocat i on.
The 31 day Frequency i s adequate t o ensure that a sufficient supply o f fuel oi l i s avai lable, since low level alarms are provided and u n i t operators would be aware o f any large uses o f fuel o i l during t h i s period.
The tests I i sted be1 ow are a means o f determi n i ng whether new fuel oi l i s o f the appropriate grade and has not been contam i nated w i t h substances that wou l d have an i mmed i ate, detr i menta l i mpact on d i ese l eng i ne combust i on. I f resu l t s from these tests are within acceptable limits, the fuel o i l may be added t o the storage tanks without concern f o r contaminating the entire volume o f fuel o i l i n the storage tanks. These tests are t o be conducted prior t o adding the new fuel t o the storage tank(s), but i n no case i s the time between receipt o f new fuel and conducting the tests t o exceed 31 days. The tests, l i m i t s, and app l i cab l e ASTM Standards are as f o l lows:
- a. Samp l e the new fuel o i l i n accordance w i t h ASTM D4057-88 (Ref. 6) ;
- b. Verify i n accordance with the tests specified i n ASTM D975-89 (Ref. 6) that the sample has an absolute speci f i c gravi t y a t 60/60°F o f 2 0.83 and 5 0.89 or an AP I gravi t y a t 60°F o f 2 27" and I 39" when tested i n accordance with ASTM D287-82 (Ref. 6), a k i nemat i c v i scos i t y a t 40°C o f 2 1.9 centistokes and 5 4. 1 centistokes, and a flash point o f 2 125°F; and
- c. Verify that the new fuel oi l i s checked f o r water and sediment content within limits when tested i n accordance w i t h ASTM D l 796-83 (Ref. 6).
(cont i nued)
North Anna Units I and 2 B 3.8.3-6
Diesel Fuel O i l and Starting A i r B 3.8.3 BASES SURVE l LLANCE SR 3.8.3.2 (cont i nued)
REQU l REMENTS Fa i l ure t o meet any o f the above l i m i t s i s cause f o r rej ect i ng the new fuel o i l, but does not represent a f a i l ure t o meet the LC0 concern since the fuel oi l i s not added t o the storage tanks.
Within 31 days f o l lowing the i n i t i a l new fuel o i l sample, the fuel o i l i s analyzed t o establish that the other properties specified i n Table 1 o f ASTM D975-89 (Ref. 7) are met f o r new fuel o i l when tested i n accordance with ASTM D975-89 (Ref. 6), except that the anal ys i s f o r su l f u r may be performed i n accordance with ASTM D4294-98 (Ref. 6),
ASTM D1552-88 (Ref. 6) or ASTM D2622-82 (Ref. 6). The 31 day period i s acceptable because the fuel o i l properties o f i nterest, even i f they were not with i n stated l i m i t s, would not have an i mmed i ate effect on EDG operat i on. Th i s Survei l l ance ensures the ava i l ab i l i t y o f hi gh qua l i t y fuel oi l f o r the EDGs.
Fuel oi l degradat i on dur i ng l ong term storage shows up as an i ncrease i n part i cu l ate, due most l y t o ox i dat i on. The presence o f particulate does not mean the fuel o i l w i l l not burn proper1 y i n a diesel engine. The particulate can cause fouling o f f i l t e r s and fuel o i l injection equipment, however, wh i ch can cause eng i ne f a i l ure.
Part i cu l ate concentrat i ons shou l d be determ i ned i n accordance with ASTM D6217-98 (Ref. 6). Th i s method i nvo l ves I a gravimetric determination o f total particulate concentration i n the fuel o i l and has a l i m i t o f 10 mg/l. I t i s acceptabl e t o obta i n a f i el d samp l e f o r subsequent laboratory testing i n lieu o f f i e l d testing. Each tank i s considered and tested separately.
The Frequency o f t h i s t e s t takes into consideration fuel oi l degradation trends that indicate that particulate concentration i s unlikely t o change significantly between Frequency i nterva l s.
This Surveillance ensures that, without the aid o f the r e f i l l compressor, s u f f i ci ent a i r s t a r t capacity f o r each EDG i s available. The system design requirements were verified f o r a minimum o f f i v e engine s t a r t cycles without recharging. A s t a r t cycle i s measured i n terms o f time (cont i nued)
North Anna Units 1 and 2 B 3.8.3-7
Diesel Fuel O i l and Starting A i r B 3.8.3 BASES REFERENCES
- 6. ASTM Standards: D4057-88; D975-89 ; D1522-88; D2622-82; (cont i nued)
D2276-82; D4292-98; D6217-98; D287-82; D l 796-83.
I 7. ASTM Standards, D975, Table 1, 1989.
North Anna Units 1 and 2 B 3.8.3-9