NRC-06-0063, Application for Technical Specification Change TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for the Diesel Fuel Oil Testing Programs Using the Consolidated Line Item Improvement Process
| ML063420067 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/27/2006 |
| From: | Cobb D DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-06-0063, TSTF-374 | |
| Download: ML063420067 (16) | |
Text
Donald K. Cobb Assistant Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, Ml 48166 Tel: 734.586.5201 Fax 734.586.4172 DTE Energy-10 CFR 50.90 November 27, 2006 NRC-06-0063 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
Reference:
Fermi 2 Docket No. 50-341 License No. NPF-43
Subject:
Application for Technical Specification Change TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for the Diesel Fuel Oil Testing Programs using the Consolidated Line Item Improvement Process In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Detroit Edison is submitting a request for an amendment to the Technical Specifications (TS) for Fermi 2.
The proposed amendment would modify the TS by relocating references to specific American Society for Testing and Materials (ASTM) standards for fuel oil testing to licensee-controlled documents and adding alternate criteria to the "clear and bright" acceptance test for new fuel oil. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the existing Bases pages marked up to show the proposed change for information only.
AO00J
USNRC NRC-06-0063 November 27, 2006 Page 2 Detroit Edison requests approval of the proposed License Amendment by April 20, 2007, with the amendment being implemented within 60 days thereafter.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Michigan State Official.
If you have any questions or require additional information, please contact Mr.
Ronald W. Gaston, Manager, Nuclear Licensing at (734) 586-5197.
Sincerely, Attachments:
- 1. Description and Assessment
- 2. Proposed Technical Specification Changes (Mark-up)
- 3. Revised Technical Specification Pages (Typed)
- 4. Proposed Changes to Technical Specification Bases Pages cc:
David H. Jaffe Christine A. Lipa NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission
USNRC NRC-06-0063 November 27, 2006 Page 3 I, Donald K. Cobb, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
DONALD K. COBB Assistant Vice President, Nuclear Generation On this day of
-2006 before me personally appeared Donald K. Cobb being first duly sworn and says that he executed the foregoing as his free act and deed.
oO,,... Public POSAlIE ARMMlA P1 M pfUYU1G MOINREC00, W yyWAMOM~S¶N EXPIRES OWt11, 2007
ATTACHMENT 1 TO NRC-06-0063 DESCRIPTION AND ASSESSMENT
Attachment I to NRC-06-0063 November 27, 2006 Page 1
1.0 DESCRIPTION
The proposed amendment would modify the Technical Specifications (TS) by relocating references to specific American Society for Testing and Materials (ASTM) standards for fuel oil testing to licensee-controlled documents and adding alternate criteria to the "clear and bright" acceptance test for new fuel oil.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-374 Revision 0. The availability of this TS improvement was published in the Federal Register on April 21, 2006 (71 FR 20735) as part of the Consolidated Line Item Improvement Process (CLIIP).
2.0 ASSESSMENT
2.1 Applicability of TSTF-374 and Published Safety Evaluation Detroit Edison has reviewed TSTF-374 (Reference 1), and the NRC model Safety Evaluation (SE) (Reference 2) as part of the CLIP. Detroit Edison has concluded that the information in TSTF-374, as well as the SE prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of changes to the Fermi 2 TS.
2.2 Optional Changes and Variations Detroit Edison is not proposing any variations or deviations from the TS changes described in the TSTF-374 or the NRC staff s model safety evaluation dated February 22, 2006.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination Detroit Edison has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLIUP. Detroit Edison has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Fermi 2 and hereby is incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).
3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 21, 2006, for this TS improvement, plant-specific verifications were performed as follows:
to NRC-06-0063 November 27, 2006 Page 2 Detroit Edison has proposed TS Bases consistent with TSTF-374, which provide guidance and details on how to implement the new requirements. Detroit Edison has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).
4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-374, Rev 0, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-374, Rev 0, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 9179, February 22, 2006. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 REFERENCES
- 2. 7590-01-P Notice for Opportunity to Comment on Model Safety Evaluation on the Diesel Fuel Oil Testing Program, dated February 22, 2006.
ATTACHMENT 2 TO NRC-06-0063 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas-mixtures contained in the Main Condenser offgas treatment system.
and the quantity of radioactivity contained in temporary outdoor storage tanks.
The program shall include:
- a.
A limit of s 4X by volume for concentration of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limit is maintained.
- b.
A surveillance program to ensure that the quantity of radioactivity contained in any outdoor liquid radwaste tank that is not surrounded byliners, dikes, or walls, capable of holding the tank's contents and that does not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is s 10 curies, excluding tritium and dissolved or entrained noble gases.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.
5.5.9 Emergency Diesel Generator Fuel..Oil TestinaP-ro.ram An emergency diesel generator 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 storage 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 for ASTM 2D fuel oil. and
- 3.
a clear and bright rpernc i
oper color:
01-4 a,4 iM CQ (continued)
FERMI
- UNIT 2 5.0-15 Amendment No. Aw*'
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Emergency Diesel Generator Fuel Oil Testing Program (continued)
- b.
Within 31 days following addition of new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and C.
Total particulate concentration of the fuel oil is
- 10 mq/l when tested every 31 days, 19....
w I
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Emergency Diesel Generator Fuel Oil Testing Program testing frequencies.
5.5.10 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.
- a.
Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
- b.
Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
- 1.
a change in the TS incorporated in the license; or
- 2.
a change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
- c.
The Bases Control Program shall contain provisions to ensure that the-Bases are maintained consistent with the UFSAR.
- d.
Proposed changes that meet the criteria of Specification 5.5.10b above shall be reviewed and approved by the NRC prior to implementation.
Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
(continued)
FERMI - UNIT 2 5.0-16 Amendment No. XA
ATTACHMENT 3 TO NRC-06-0063 PROPOSED TECHNICAL SPECIFICATION PAGES
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Main Condenser offgas treatment system, and the quantity of radioactivity contained in temporary outdoor storage tanks.
The program shall include:
- a.
A limit of
- 4% by volume for concentration of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limit is maintained.
- b.
A surveillance program to ensure that the quantity of radioactivity contained in any outdoor liquid radwaste tank that is not surrounded by liners, dikes, or walls, capable of holding the tank's contents and that does not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is
- 10 curies, excluding tritium and dissolved or entrained noble gases.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.
J 5.5.9 Emergency Diesel Generator Fuel Oil Testing Program An emergency diesel generator 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 storage 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 for ASTM 2D fuel oil, and
- 3.
a clear and bright appearance with proper color or a water and sediment content within limits; (continued)
FERMI - UNIT 2 5.0-15 Amendment No. 04
I Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Emergency Diesel Generator Fuel Oil Testing Program (continued)
- b.
Within 31 days following addition of new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and
- c.
Total particulate concentration of the fuel oil is : 10 mg/l when tested every 31 days.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Emergency Diesel Generator Fuel Oil Testing Program testing frequencies.
5.5.10 Technical Specifications (TS) Bases Control Proqram This program provides a means for processing changes to the Bases of these Technical Specifications.
- a.
Changes to the Bases of the TS'shall-be made under appropriate administrative controls and reviews.
- b.
Licensees may-make changes to Bases without prior NRC approval provided the changes do not require either of the following:
- 1.
a change in the TS incorporated in the license; or
- 2.
a change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
- c.
The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.
- d.
Proposed changes that meet the criteria of Specification 5.5.10b above shall be reviewed and approvedby the NRC prior to implementation.
Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
(continued)
FERMI - UNIT 2 5.0-16 Amendment No./&4, 16b
ATTACHMENT 4 TO NRC-06-0063 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.8.3.2 The tests of fuel oil prior to addition to the storage tank are a means of determining whether new fuel oil is 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 within 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), but in no case is the time between sampling (and associated results) of new fuel and addition of new fuel oil to the storage tank to exceed 31 days.
The tests, limits, and applicable ASTM Standards for the 'new fuel oil tests listed in the Emergency Diesel Generator Fuel Oil Testing Program of Specification 5.5 are as follows:
- a.
Sample the new fuel oil in accordance with ASTM D4057-88 (Ref. 6);
- b.
Verify that the sample has an API Gravity of within 0.3
-degrees at 60°F or a specific gravity of within 0.0016 at 60/600 F, when compared to the suppliers certificate, or an absolute specific gravity at 60/60°F of Ž 0.83 and
- 0.89 or an API gravity at 60°F of Ž 270 and
- 0.
Also, verify in accordance with the tests specified in ASTM D975-91 (Ref. 6) a kinematic viscosity at 400C of ý 1.9 centistokes and
- 4.1 centistokes, and a flash point of Ž 125°F; and CC *Cco rd P C* e c
Verify that the new fuel oil has a clear and bright P
oCICO g
appearance with proper color when tested in accordance 0-4 1Sr J-I#
0' with ASTM D4176-86 4(Ref. 6).
Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks.
Following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in
-r
- Table 1 of ASTM D975-91 (Ref. 6) are met for new fuel oil when tested in accordance with ASTM D975-91 (Ref. 6), with the following two exceptions: 1) the analysis fo ulfur 1Jk J may be performed in accordance with ASIM 01552-901
'iYg b 1, A
A,*
ASTM D2622-8 (Ref. 6), and 2) consistent with Reference
'ii aCCordc"Jc and the EDG nufacturer specification (Ref. 7), which is
- A-oC*o more restric ive than specified in ASTM D975-91 (Ref. 6),
1"-A *the fuel is ested to ensure it meets a minimum cetane index of 45.
FERMI - UNIT 2 3.8.3-5 Revision 20
Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)
These additional analyses are required by Specification 5.5.9, "Emergency Diesel Generator Fuel Oil Testing Program," to be performed within 31 days following sampling and addition.
This 31 days is intended to assure:
- 1) that the sample taken is not more than 31 days old at the time of adding the fuel oil to the storage tank, and 2) that the results of a new fuel oil sample (sample obtained prior to addition but not more than 31 days prior to) are obtained within 31 days after addition.
The 31 day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on EDG. operation.
This Surveillance ensures the availability of high quality fuel oil for the required EDGs.
Fuel oil degradation during long term storage shows up as an increase in particulate, mostly due to oxidation.
The presence of particulate does not mean that 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 fail Particulate concentrations-so-etermined in accordance with ASTM M &
(Ref.
This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l.
It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing.
The Frequency of this test takes into consideration fuel oil.
degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.
SR 3.8.3.3 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each EDG is available.
The system design requirements provide for a minimum of five engine start cycles without recharging.
The pressure specified in this SR is intended to reflect the lowest value at which the five starts can be accomplished.
The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and
- ýTRMI
- UNIT 2 B 3.8.3-6 Revision 0
-S Diesel Fuel Oil and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) other indications available in the control room, including alarms, to alert the operator to below normal air start pressure.
SR 3.8.3.4 Microbiological fouling is a major cause of fuel oil degradation.
There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive.
Removal of water from the required EDG fuel storage tanks once-every 31 days eliminates the necessary environment for bacterial survival.
This is the most effective means of controlling microbiological fouling.
In addition, it eliminates the potential for water entrainment in the fuel oil during EDG operation.
Water may come from any of several sources, including condensation, ground water, rain water, contaminated-fuel oi.I, and from breakdown of:the fuel oil by bacteria.
Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system.
The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 2).
This SR is for preventive maintenance.
The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance.
REFERENCES
- 1.
UFSAR, Section 9.5.4.
- 2.
- 3.
ANSI N195, 1976.
- 4.
UFSAR, Chapter 6.
- 5.
UFSAR, Chapter 15.
US 1, Fairbanks Morse Skidded Heat Exchanger Diesel Generator Sets 7)?S-9 FERMI
- UNIT 2 B 3.8.3-7 Revision 20 FERMI - UNIT 2 B 3.8.3 -7 Revision 20