ML091670518

Emergency Diesel Generator (EDG) Fuel Oil - Sampling of Storage Tanks - Supplemental Information

ML091670518
Person / Time
Site:	Watts Bar
Issue date:	06/16/2009
From:	Brandon M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML091670518 (3)

Text

June 16, 2009 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 - SUPPLEMENTAL INFORMATION

Reference:

TVAs letter to NRC dated May 19, 2009, Watts Bar Nuclear Plant (WBN) -

Emergency Diesel Generator (EDG) Fuel Oil - Sampling of Storage Tanks The referenced letter outlined a request for NRC to approve an alternate method for the sampling of fuel oil stored in the main fuel oil storage tanks. In summary, WBN currently fulfills Surveillance Requirement (SR) for Technical Specification (TS) 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by sampling the tanks in accordance with ASTM D4057-1988. This standard requires that 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. In lieu of sampling in this manner, WBN proposed an alternate process that will provide a well mixed sample from the fuel oil transfer pump discharge lines of each storage tank. The change in sampling process was proposed to address certain safety concerns associated with the current sampling process.

Representatives of TVA discussed the change in the sampling process proposed in TVAs May 19, 2009 letter with the NRC staff on June 3, 2009. The purpose of this discussion was to clarify the regulatory process being utilized by TVA in the subject request. From this discussion, it was established that TVA should perform a review of the proposed process change in accordance with 10 CFR 50.59, Changes, Tests and Experiments. The intent of this action was to determine if an Operating License amendment request was required for the proposed process change.

U.S. Nuclear Regulatory Commission Page 2 June 16, 2009 TVA implements its process for performing evaluations under 10 CFR 50.59 in TVAs procedure, Standard Programs and Processes (SPP) 9.4, 10 CFR 50.59, Evaluations of Changes, Tests and Experiments. This procedure is based on Revision 1 of Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation. In accordance with Section 3.1, Preparation of Screening Reviews and 50.59 Evaluations, of SPP-9.4, Screening Review 0-SI-18-2 Revision 8 was prepared to determine if the proposed fuel oil sampling process required a license amendment. The Screening Review was approved on June 12, 2009, with the conclusion that a license amendment was not required.

Independent of the results of TVAs screening review, Section 8.1 of the ASTM standard states the following:

The standard sampling procedures described in this method are summarized in Table 1. 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. (emphasis added)

TVA believes the referenced letter provides the justification needed for the NRC staff to conclude the proposed sampling change is acceptable and based on this, requests the staffs review of the sampling method described in the May 19, 2009 letter. 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 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.

There are no regulatory commitments associated with this submittal. Should you require additional information regarding this matter, please contact me at (423) 365-1824.

Sincerely, Original signed by M. K. Brandon Manager, Site Licensing and Industry Affairs cc: See page 3

U.S. Nuclear Regulatory Commission Page 3 June 16, 2009 cc: 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