ML091400199
| ML091400199 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/19/2009 |
| From: | Brandon M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML091400199 (6) | |
Text
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
In the Matter of the
)
Docket No. 50-390 Tennessee Valley Authority
)
50-391 WATTS BAR NUCLEAR PLANT (WBN) - EMERGENCY DIESEL GENERATOR (EDG) FUEL OIL - SAMPLING OF STORAGE TANKS The fuel oil for WBNs EDGs is tested in accordance with Technical Specification (TS) 5.7.2.16, Diesel Fuel Oil Testing Program. The sampling of new fuel oil prior to transferring fuel oil to the 7 day fuel oil storage tank for each EDG is performed in accordance with Section 8 of ASTM D4057-1988 to satisfy TS 5.7.2.16. This specific test also fulfills the following Surveillance Requirement for TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air:
SURVEILLANCE FREQUENCY 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 ASTM D4057-1988 requires the fuel oil sample be obtained by utilizing an all levels sample (Reference Section 8.2.3.1 of ASTM D4057-1988). This method entails lowering a special sampling container to the bottom of the main fuel oil storage tank at which point the container opens and is then pulled up collecting a sample at all levels of the tank.
May 19, 2009
U.S. Nuclear Regulatory Commission Page 2 To obtain this sample in accordance with ASTM D4057-1988 Section 8, a chemistry technician must climb a ladder approximately 25 feet to the top of the storage tank. As a minimum, the technician must bring a special sample container, two 25 foot cables, wipe cloths, two one liter bottles, a funnel, a bucket, and a safety belt with a ladder climbing device. Once on top of the domed tank, the technician must secure him/herself and open the manway to the tank. After a sample is collected, the manway is secured and the sample and equipment are lowered to the ground in a bucket. The technician then returns to the ladder and descends 25 feet.
This sampling method poses a safety risk to the technician obtaining the sample. In addition, this method puts the fuel oil supply at risk because during the sampling collection with the manway open, the possibility exists to drop tools, a sample container, flashlight, or other material into the tank. Should this happen, the status of the fuel oil would be indeterminate until the item(s) are recovered. These risks can be reduced by making a minor change to the sampling method.
Section 8.1 of ASTM D4057-1988 states: Alternative sampling procedures may be used if a mutually satisfactory agreement has been reached by the parties involved. Such agreement shall be put in writing and signed by authorized officials. In an effort to reduce the safety risk to personnel and to eliminate the possibility of dropping objects into the fuel oil storage tanks, WBN is proposing an alternative to the sampling method of ASTM D4057-1988.
WBN proposes to take samples from the fuel oil transfer pump discharge lines of each storage tank. The transfer pumps take suction near the bottom of their respective storage tanks through a five inch diameter line. There is a one inch diameter line and valve off each discharge line that will be used as the sample point. To obtain a fuel oil sample, the fuel oil transfer pump for the tank to be sampled will be placed in the recirculation mode for a period of time based on the volume of diesel fuel in the tank. This is done to ensure the contents of the tank are adequately mixed. After the tank has been recirculated for the appropriate time, the sample line will be flushed and a sample obtained. The sample line and transfer pump will then be secured and the fuel oil sample will be analyzed in accordance with existing TS requirements.
Provided in the Enclosure are the results of the sampling of Main Fuel Oil Storage Tank Number 1. The sampling was performed over a two month period (three samples) and compares the results of samples taken from the top of the tank and samples which were taken using the proposed method. Based on this comparison, the sampling results are essentially equivalent and this supports TVAs position that the proposed sampling method is acceptable.
This requested change in sampling procedures is being made in accordance with the provisions of ASTM D4057-1988. There will be no change to the wording or intent of the TS or Bases as a result of this action. Therefore, no change to the TS will be required.
WBN requests the staffs review of the proposed alternate sampling method. If the request is determined to be acceptable, please return a written confirmation of the acceptance of the sampling process to satisfy the requirements of Section 8.1 of ASTM D4057-1988. There is no May 19, 2009
U.S. Nuclear Regulatory Commission Page 3 specific time or milestone by which NRCs approval of this request is required. However, since TVA considers this change to be a safety enhancement, a timely response will be appreciated.
A request similar to that being proposed by WBN was submitted to NRC on March 27, 1990, by Louisiana Power and Light Company for the Waterford 3 Plant. That request was approved by NRC in a letter dated April 12, 1990.
There are no regulatory commitments in this letter and should there be any questions regarding this letter, please contact me at (423) 365-1824.
Sincerely, Michael K. Brandon Manager, Site Licensing and Industry Affairs Enclosure cc: See page 4 May 19, 2009 Original signed by
U.S. Nuclear Regulatory Commission Page 4 Enclosure cc (Enclosure):
NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 May 19, 2009
Enclosure Comparison of Fuel Oil Sampling Results from Fuel Oil Storage Tank (FOST) Number 1 E-1 of 2 Sample Date 07/23/2008 FOST Number 1 Sample Method Sample Analysis Units Top of Tank Recirculation Pump Sample Acceptance Criteria Clear and Bright Pass Pass Pass No water drops or particulate matter and free of haze Kinematic viscosity cSt 2.70 2.72 1.9 to 4.1 cSt at 40 Degrees C Flashpoint Degree F 153 155 125 Degrees F Specific Gravity N/A 0.849 0.849 0.83 to 0.89 (60/60 Degrees F)
Water and Sediment Percent
<0.05
<0.05 0.05 percent by volume Ash Percent
<0.001
<0.001 0.01 weight percent Ramsbottom Carbon residue on 10 percent distillation residue Percent 0.145 0.155 0.35 weight percent Cetane Number Index (calculated) 45.9 47.0 40 Cloud Point Degree F
<18.0
<18.0 23 Degrees F Copper Strip Corrosion
<3.0
<3.0 Number 3 Distillation Temperature Degree F 611 611 540 Degrees F to 640 Degrees F
Sulfur Percent 0.05 0.05 0.50 weight percent Sample Date 08/19/2008 FOST Number 1 Sample Method Sample Analysis Units Top of Tank Recirculation Pump Sample Acceptance Criteria Clear and Bright Pass Pass Pass No water drops or particulate matter and free of haze Kinematic viscosity cSt 2.78 2.77 1.9 to 4.1 cSt at 40 Degrees C Flashpoint Degree F 153 149 125 Degrees F Specific Gravity N/A 0.839 0.839 0.83 to 0.89 (60/60 Degrees F)
Water and Sediment Percent
<0.05
<0.05 0.05 percent by volume Ash Percent
<0.001
<0.001 0.01 weight percent Ramsbottom Carbon residue on 10 percent distillation residue Percent 0.123 0.128 0.35 weight percent Cetane Number Index (calculated) 46.1 46.1 40 Cloud Point Degree F
<18.0
<18.0 23 Degrees F Copper Strip Corrosion
<3.0
<3.0 Number 3 Distillation Temperature Degree F 613 613 540 Degrees F to 640 Degree F Sulfur Percent 0.05 0.05 0.50 weight percent
Enclosure Comparison of Fuel Oil Sampling Results from Fuel Oil Storage Tank (FOST) Number 1 E-2 of 2 Sample Date 08/21/2008 FOST Number 1 Sample Method Sample Analysis Units Top of Tank Recirculation Pump Sample Acceptance Criteria Clear and Bright Pass Pass Pass No water drops or particulate matter and free of haze Kinematic viscosity cSt 2.88 3.03 1.9 to 4.1 cSt at 40 Degrees C Flashpoint Degree F 155 153 125 Degrees F Specific Gravity N/A 0.851 0.839 0.83 to 0.89 (60/60 Degrees F)
Water and Sediment Percent
<0.05
<0.05 0.05 percent by volume Ash Percent
<0.001
<0.001 0.01 weight percent Ramsbottom Carbon residue on 10 percent distillation residue Percent 0.146 0.138 0.35 weight percent Cetane Number Index (calculated) 46.3 45.8 40 Cloud Point Degree F
<18.0
<18.0 23 Degrees F Copper Strip Corrosion
<3.0
<3.0 Number 3 Distillation Temperature Degree F 616 611 540 Degrees F to 640 Degrees F
Sulfur Percent 0.05 0.05 0.50 weight percent