ML070650096
| ML070650096 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/19/2007 |
| From: | Pearce L FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| PY-CEI/NRR-2991L | |
| Download: ML070650096 (11) | |
Text
FENOC Perry Nuclear Power Station 10 Center Road FirstEnergy NuclearOperating Company Perry Ohio 44081 L. William Pearce 440-280-5382 Vice President Fax: 440-280-8029 10 CFR 50.90 January 19, 2007 PY-CEI/NRR-2991L Perry Nuclear Power Plant Docket No. 50-440 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
License Amendment Request to Revise Diesel Fuel Oil Requirements Using the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, a license amendment is requested for the Perry Nuclear Power Plant (PNPP). The amendment would modify Technical Specification (TS) 5.5.9, "Diesel Fuel Oil Testing Program," by relocating a reference to a specific ASTM International standard for fuel oil testing to licensee-controlled documents, and adding alternate criteria to the "clear and bright' acceptance test for new fuel oil, per the Consolidated Line Item Improvement Process (CLIIP).. The enclosure provides the evaluation of the proposed changes.
Approval. of the proposed license amendment is requested by. September, 2007. Once approved, the amendment will be implemented within 120 days.
There are no new regulatory commitments in this letter or the Enclosure. If there are any questions or if additional information is required, please contact Mr. Henry L. Hegrat, Supervisor- FENOC Fleet Licensing, at (330) 315-6944.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January /_?_, 2007.
L. William Pearce
Enclosure:
Evaluation of the Proposed License Amendment cc: NRC Project Manager
- NRC Resident Inspector, NRC*Region III -
State of Ohio
- i- : ' ':, . . . 4D..I 4°0) / I~C
Enclosure PY-CEI/NRR-2991 L Page 1 of 3 EVALUATION OF THE PROPOSED LICENSE AMENDMENT
Subject:
Perry Nuclear Power Plant License Amendment Request - Revise Diesel Fuel Oil Requirements Using the Consolidated Line Item Improvement Process
1.0 DESCRIPTION
2.0 ASSESSMENT 2.1 Applicability of TSTF-374, and Published Safety Evaluation 2.2 Optional Changes and Variations
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration 3.2 Verification
4.0 ENVIRONMENTAL CONSIDERATION
5.0 REFERENCES
ATTACHMENTS:
- 1. Proposed Changes to the PNPP Technical Specification Page (mark-up)
- 2. Associated Bases Changes (mark-up) For Information
Enclosure PY-CEI/NRR-2991 L Page 2 of 3 EVALUATION OF THE PROPOSED LICENSE AMENDMENT
1.0 DESCRIPTION
The proposed license amendment would modify Perry Nuclear Power Plant (PNPP) Technical Specification (TS) 5.5.9, "Diesel Fuel Oil Testing Program," by relocating a reference to a specific ASTM International standard for fuel oil testing to licensee-controlled documents, and adding alternate criteria to the "clear and bright" acceptance test for new fuel oil.
The TS changes are consistent with a Nuclear Regulatory Commission (NRC) approved document produced by the Technical Specification Task Force (TSTF), TSTF-374, Revision 0 (Reference 1). The availability of this TS improvement was published in the FederalRegister on April 21, 2006 (Reference 2), as part of the Consolidated Line Item Improvement Process (CLIIP). The Notice of Availability incorporates by reference a model Safety Evaluation (SE),
model No Significant Hazards Consideration (NSHC), and model Environmental Consideration that were published in a Federal Register Notice dated February 22, 2006 (Reference 3).
2.0 ASSESSMENT 2.1 Applicability of TSTF-374 and Published Safety Evaluation A review of TSTF-374 and the NRC model safety evaluation (SE) performed as part of the CLIIP was performed. The conclusion of the review was that the information in TSTF-374, as well as the SE prepared by the NRC staff, are applicable to PNPP, and justify this amendment to the PNPP TS. The NRC SE is hereby incorporated by reference.
2.2 Optional Changes and Variations The proposed changes to PNPP TS 5.5.9 shown in Attachment 1 to this Enclosure do not vary or deviate from the changes described in TSTF-374 or the NRC staffs SE dated February 22, 2006, except for the addition of a comma to better define that the test described in the new insert is separate/distinct from the currently required 'clear and bright with proper color' test.
Proposed changes to the TS Bases are included in Attachment 2 to this Enclosure. They are not a part of the requested license amendment, but are provided for information. The Bases markups are different in some instances from the example markups provided in TSTF-374, but each difference is intended to be consistent with the intent of TSTF-374 to allow use of current ASTM standards. For example, references are included to ASTM D975-06, "Standard Specifications for Diesel Fuel Oils." ASTM D975-06 is the most current standard available, and includes endorsements of ASTM D2709 and D4294, which TSTF-374 Inserts 3 and 4 would have added.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration The proposed NSHC determination published in the Federal Register as part of the CLIIP has been reviewed. The conclusion of the review was that the proposed NSHC presented in the Federal Register Notice is applicable to PNPP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
Enclosure PY-CEI/NRR-2991 L Page 3 of 3 3.2 Verification A Bases Control Program is already included in the PNPP Technical Specifications, as required by the NRC for adoption of this proposed TS change.
As discussed above, proposed Bases changes are included for information in Attachment 2 to this Enclosure. In accordance with the PNPP Bases Control Program, appropriate Bases changes will be incorporated as part of the implementation of the license amendment.
Also as part of the implementation of this license amendment, associated changes to the PNPP Updated Safety Analysis Report (USAR) will be processed. The entry in Table 1.8-1, "Conformance to NRC Regulatory Guides," for Regulatory Guide 1.137, "Fuel-Oil Systems for Standby Diesel Generators," will be revised to be consistent with the intent of TSTF-374, by identifying the TS Bases as the licensee-controlled document that details the industry standards utilized for PNPP fuel oil testing.
4.0 ENVIRONMENTAL CONSIDERATION
The proposed Environmental Consideration published in the Federal Register as part of the CLIIP has been reviewed. The NRC staff determined, and the PNPP review confirmed, that the proposed amendment adopting TSTF-374, Revision 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. As discussed above in Section 3.1, the NRC issued a proposed finding that TSTF-374, Revision 0, involves no significant hazards considerations, and there has been no public comment on the finding in the February 22, 2006 Federal Register Notice (71 FR 9179). 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
- 1. Traveler TSTF-374, Revision 0, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," http://w-w, excelservices.com
- 2. Federal Register Notice dated April 21, 2006 (71 FR 20735), "Technical Specification Improvement to Revise Diesel Fuel Oil Testing Program Using the Consolidated Line Item Improvement Process," htt:I//www..pooaccess.povifriadvanced. html
- 3. Federal Register Notice dated February 22, 2006 (71 FR 9179), "Notice for Opportunity to Comment on Model Safety Evaluation on Technical Specification Improvement to Revise Diesel Fuel Oil Testing Program Using the Consolidated Line Item Improvement Process,"
http.://www._qoaccess.qovifr/advanced.html
Enclosure, Attachment 1 PY-CEI/NRR-2991 L Page 1 of 2 Proposed Changes to the PNPP Technical Specification Page (mark-up)
Enclosure, Attachment 1 PY-CEI/NRR-2991 L Page 2 of 2 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program (continued)
- b. A surveillance program to ensure that the quantity of radioactivity contained in any temporary outdoor tanks not including liners for shipping radwaste 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.
5.5.9 Diesel Fuel Oil Testinq Proqram 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 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. l and bright appearance with -color-)o
- b. Within 31-days Tol owing addition oT the nto 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 in the storage tanks is
- 10 mg/l when tested every 31 dayV4-The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing frequencies.
(continuedT PERRY - UNIT 1 5.0-13 Amendment No. 120
Enclosure, Attachment 2 PY-CEI/NRR-2991 L Page 1 of 5 Associated Bases Changes (mark-up)
For Information
ý '. 1 Enclosure, Attachment 2 PY-CEI/NRR-2991 L Page 2 of 5 Diesel Fuel Oil. Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.2 REQUIREMENTS (continued) This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of maximum expected post LOCA load operation for each DG. This requirement is ased on the DG manufacturer's consumption values for the run time of the DG. The 7 day lube oil inventory for the Division 1 and 2 diesel engines represents the minimum volume of lube oil required to safely sustain engine operation (sump tank oil level above the lube oil pump suction foot valve) plus the volume of lube oil that would be consumed during 7 days of continuous operation. The 7 day lube oil inventory limit for the Division 3 diesel engine represents the minimum volume of lube oil required to safely sustain engine operation (sump tank oil level at dipstick low level) plus the volume of lube oil that would be consumed during 7 days of continuous operation.
The lube oil sump inventories identified herein correspond to the following lube oil sump tank dipstick readings:
Division 1 and 2 374 Gallons - 3 1/2" above the dipstick LOW mark 350 Gallons - 11/2" above the dipstick LOW mark Division 3 260 Gallons - 4 3/8" below dipstick HIGH mark 236 Gallons - 5 1/2" below dipstick HIGH mark A 31 day Frequency is adequate to ensure that a sufficient lube oil supply i-s onsite, since DG starts and run times are closely monitored by the plant staff.
SR 3.8.3.3 The tests of fuel oil prior to addition to the storage tanks 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 and operation. 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.
(continued)
INFORM A IIN ONLY' PERRY - UNIT 1 B 3.8-46 Revision No. 3
Enclosure, Attachment 2 PY-CEI/NRR-2991 L Diesel Fuel Oil, Lube Oil, and Starting Air Page 3 of 5 B 3.8.3 EASES SURVEILLANCE SR 3.8.3.3 (continued)
REQUIREMENTS 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 the sample (and corresponding results) of new fuel, and addition of new fuel oil to the storage tanks to exceed 31 days. The limits and applicable ASTM Standards for the tests listed in the Diesel Fuel Oil Testing Program of Specification 5.5.9 are as follows:
- a. Sample the new fuel oil in accordance with ASTM D4057-95 (Reapproved 2000)(Ref. 6):
- b. Verify in accordance with the tests specified in ASTM D1298-85 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of Ž 0.83 and
- 0.89; an ION
.*A ONLY API gravity at 60°F of t 260 and
- 390: or an API I O gravity of within 0.30 at 60 0 F, or a specific gravity within 0.0016 at 60/60°F when compared to the supplier's certificate:
- c. Verif 'n accordance with the tests specified in ASTM D975. Ref. 6), a flash point of Ž 125 0 F;
- d. Veri in accordance with the tests specified in ASTM
_7 (Ref. 6), if gravity was not determined by comparison with the supplier's certification, a gkinematic viscosity at 400C of Ž 1.9 centistokes and
- 4.1 centistokes; and
- e. Verify that the new fuel oil has no visible free water or particulate contamination when tested in accordance wi ASTM D4176-86 (Ref. 6).
o0 - Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure eA to meet the LCO since the fuel oil is not added to the 1 .. Afeokstorage tanks. e 06
, Following the initial ne fuel oil sample, t e fuel oil is analyzed to establish t t the other proper ies specified in Table 1 of ASTM D975 (Ref. 6) are met f new fuel oil when tested in accordance with ASTM D975- (Ref. 6). These w 4'.e..4k . additional analyses are required by Speci ication 5.5.9, Diesel Fuel Oil Testing Program, to be performed within 31 days following sampling and addition. This 31 days is
- (continued)
PERRY - UNIT 1 B 3.8-47 Revision No. 5
Enclosure, Attachment 2 PY-CEI/NRR-2991L Diesel Fuel Oil, Lube Oil, and Starting Air Page 4 of 5 B 3.8.3 BASES SURVEILLANCE SR 3.8.3.3 (continued)
REQUIREMENTS 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 not within stated limits, would not have an immediate effect on DG operation.
This Surveillance ensures the availability of high quality fuel oil for the DGs.
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. However, the particulate can cause fouling of filters and fuel oil injection equipment, whicgcan cause engine failure. .
Particulate concentr soula e edermine in accor ance 0(.
with ASTM D2276-88, e1 (Ref. 6). This method involves a gravimetric determina ion 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 Surveillance takes into consideration fuel oil degradation trends indicating that particulate concentration is unlikely to change between Frequency intervals.
SR 3.8.3.4 INFORMATIO ONLY This Surveillance ensures that, without the aid of the air compressor, sufficient air start capacity for each DG is available. The system design provides for a minimum of five engine starts without recharging. The pressure specified in this SR reflects the value at which the five starts can be accomplished, but is not so high as to result in failing the limit due to normal cycling of the air compressor. Division 1, 2, and 3 DGs have two independent air start subsystems per DG. For Division 1 and 2 DGs, this Surveillance is met provided one air start receiver for an engine is pressurized (continued)
PERRY - UNIT 1. B 3.8-48 Revision No. 3
Enclosure, Attachment 2 Diesel Fuel Oil, Lube Oil, and Starting Air PY-CEI/NRR-2991 L B 3.8.3 Page 5 of 5 BASES SURVEILLANCE SR 3.8.3.6 (continued)
REQUIREMENTS preventive maintenance. The presence of sediment does not necessarily represent a failure of this SR provided that accumulated sediment is removed during performance of the Surveillance.
REFERENCES 1. USAR, Section 9.5.4.
- 3. ANSI N195, Appendix B. 1976.
- 4. USAR, Chapter 6.
- 5. USAR, Chapter 15.
- 6. ASTM Standards: D4057-95 (Reapproved 2000); D1298-85:
D975A D4176-86; D2276-88.
- 7. ASME, 16iler and Pressure Vessel Code,Section XI.
INFO ATIO u0 PERRY - UNIT 1 B 3.8-50 Revision NoA