ML101160349
| ML101160349 | |
| Person / Time | |
|---|---|
| Site: | Columbia  (NPF-021) |
| Issue date: | 05/27/2010 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Parrish J Energy Northwest |
| Lyon C Fred, NRR/DORL/LPL4, 301-415-2296 | |
| References | |
| TAC ME2121 | |
| Download: ML101160349 (20) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 27, 2010 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT RE:
CHANGES TO TECHNICAL SPECIFICATIONS RELATING TO DIESEL GENERATOR FUEL OIL STORAGE AND TESTING (TAC NO. I\\I1E2121)
Dear Mr. Parrish:
The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 215 to Facility Operating License No. NPF-21 for the Columbia Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated August 17, 2009, as supplemented by letter dated January 21, 2010.
The amendment will modify (1) TS LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," to relocate specific numerical values for fuel oil and lube oil storage volumes from the TSs to the TS Bases, (2) TS SR 3.8.1, "AC [Alternating Current] Sources - Operating," to relocate specific values for the day tank fuel oil volumes from the TSs to the TS Bases, and (3) TS 5.5.9, "Diesel Fuel Oil Testing Program," to relocate the specific standard for particulate concentration testing of fuel oil from the TSs to the TS Bases.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosures:
- 1. Amendment No. 215 to NPF-21
- 2. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 215 License No. NPF-21
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Energy Northwest (licensee), dated August 17, 2009, as supplemented by letter dated January 21,2010, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-21 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 215 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance. Implementation of the amendment shall include updating the Final Safety Analysis Report to reflect the exception to American National Standards Institute (ANSI) N195-1976 regarding the explicit allowance for fuel oil for periodic testing in the calculation of emergency diesel generator fuel oil storage requirements.
FOR THE NUCLEAR REGULATORY COMMISSION
>>0J<U l7~ ~
~hael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License No. NPF-21 and Technical Specifications Date of Issuance:
May 27. 2010
ATIACHMENT TO LICENSE AMENDMENT NO. 215 FACILITY OPERATING LICENSE NO. NPF-21 DOCKET NO. 50-397 Replace the following pages of the Facility Operating License No. NPF-21 and Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
Facility Operating License REMOVE INSERT -3 Technical Specification REMOVE INSERT 3.8.1-7 3.8.1-7 3.8.3-1 3.8.3-1 3.8.3-3 3.8.3-3 5.5-9 5.5-9
- 3 (3)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
(6)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to store byproduct, source and special nuclear materials not intended for use at Columbia Generating Station. The materials shall be no more than 9 sealed neutron radiation sources designed for insertion into pressurized water reactors and no more than 40 sealed beta radiation sources designed for use in area radiation monitors. The total inventory shall not exceed 24 microcuries of strontium-90, 20 microcuries of uranium-235, 30 curies of plutonium-238, and 3 curies of americium-241.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3486 megawatts thermal). Items in shall be completed as specified. Attachment 1 is hereby incorporated into this license.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 215 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(a)
For Surveillance Requirements (SRs) not previously performed by existing SRs or other plant tests, the requirement will be considered met on the implementation date and the next required test will be at the interval specified in the Technical Specifications as revised in Amendment No. 149.
Amendment No. 215
AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS SR 3.8.1.3 SURV EI LLANCE
- - - - - - - - - - - - - - - - - - -NOTES - - - - -- - - - - - - - - - - - -
- 1.
DG loadings may include gradual loading as recommended by the manufacturer.
- 2.
Momentary transients outside the load range do not invalidate this test.
- 3.
This Surveillance shall be conducted on only one DG at a time.
- 4.
This SR shall be preceded by. and immediately follow. without shutdown.
a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
- 5.
The endurance test of SR 3.8.1.14 may be performed in lieu of the load-run test in SR 3.8.1.3 provided the requirements. except the upper load limits. of SR 3.8.1.3 are met.
Verify each required OG is synchronized and loaded and operates for 2 60 minutes at a load 2 4000 kW and ~ 4400 kW for OG-1 and DG-2. and 2 2340 kW and ~ 2600 kW for OG-3.
31 FREOUENCY days SR 3.8.1.4 Verify each required day tank contains fuel oi 1 to support greater than or equal to one hour of operation at full load plus 10%.
31 days SR 3.8.1.5 Check for and remove accumulated each required day tank.
water from 31 days (continued)
Columbia Generating Station 3.8.1-7 Amendment No. 149,169.173 215
D{esel Fuel Oil. Lube Oil. and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil. Lube Oil. and Starting Air LCO 3.8.3 The stored diesel fuel oil. lube oil. and starting air subsystem shall be within limits for each required diesel genera tor (DG).
"APPLICABI LITY:
When associated DG is required to'be OPERABLE.
ACTIONS 0"
0 0
- NOT E Separate Condition entry
~ is allowed for each DG.
~
CONDITWN REQUIRED ACTION COMPLETION TIME A.
One or more DGs with fuel oil 1eve1 1es s than a 7 day supply and greater thana 6 day supply.
A.1 Restore stored fuel oil 1eve1 to withi n 1i mi t.
'48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> B.
One or more DGs with lube oil inventory less than a 7 day supply and greater than a 6 day supply.
B.l Restore lube oil inventory to withi n 1i mit.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (continued)
Columbia Generating Station 3.8.3-1 Amendment No. 149.169 215
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREOUENCY SR 3.8.3.1 Verify each fuel oil storage subsystem contains L a 7 day supply of fuel.
31 days SR 3.8.3.2 Verify lube oil inventory is ) a 7 day supply.
31 days' SR 3.8.3.3 Veri fy fuel oi 1 properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Di esel Fuel Oi 1 Testing Program.
In accordance
. wi th the Oi esel Fuel Oil Testing Program SR 3.8.3.4 Verify each required OG air sta rt receiver pressure is:
- a.
L 230 psig for DG-1 and DG-2; and
- b.
L 223 psig fo r OG-3.
31 days SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.
92 days Columbia Generating Station 3.8.3-3 Amendment No. 149.169 215
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.9 Diesel Fuel Oil Testing Program A di esel fuel oil testing program shall establ ish the requi red testing of both new fuel oil and stored fuel oil.
The program shall include sampling and testing requirements. and acceptance criteria. all in accordance with applicable ASTM Standards.
The purp~se of the program is to establish the following:
- a.
Acceptability of new fuel.oil for use prior to addition to storage tanks by determi ni ng that the fuel oi 1 has:
- 1.
An API gravity, a specific gravity, or an absolute specific gravity within limits.
- 2.
A kinematic viscosity, if gravity was not determined by comparison with the supplier's certificate, and a flash point within limits for ASTM 2-D fuel oil.
3.* A water and sediment content within limits or a clear and bright appearance with proper color;
- b.
Other properties for ASTM 2-D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and
- c.
Total particulate concentration of the fuel oil in the storage tanks 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 Diesel Fuel Oil Testing Program test Frequencies.
5.5.10 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases to these Technical Specifications.
- a.
Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
(continued)
Columbia Generating Station 5.5-9 Amendment No. 149,169 215
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 215 TO FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 INTRODUCTION
By application dated August 17, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092380153), as supplemented by letter dated January 21, 2010 (ADAMS Accession No. ML100330287), Energy Northwest (the licensee) requested changes to the Technical Specifications (TSs) for the Columbia Generating Station (Columbia).
The requested change would modify (1) TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," to relocate specific numerical values for fuel oil and lube oil storage volumes from the TSs to the TS Bases, (2) TS 3.8.1, "AC [Alternating Current] Sources - Operating," to relocate specific values for the day tank fuel oil volumes from the TSs to the TS Bases, and (3) TS 5.5.9, "Diesel Fuel Oil Testing Program," to relocate the specific standard for particulate concentration testing of fuel oil from the TSs to the TS Bases.
In addition, the proposed change for Limiting Condition for Operation (LCO) 3.8.3 also addresses a non-conservative TS value for the Division 2 emergency diesel generator (EDG) by imposing a more restrictive value for the required volume of diesel fuel oil to support 7 days of continuous operation.
The supplemental letter dated January 21, 2010, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on November 3, 2009 (74 FR 56884).
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses.
- 2 In Section 50.36, Technical specifications," of Title 10 of the Code of Federal Regulations (10 CFR), the NRC established its regulatory requirements related to the content of TSs.
Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plant's TSs.
The TSs include requirements for testing diesel fuel oil to ensure it is of the appropriate grade and that it has not been contaminated (Le., proper fuel oil quality). The Diesel Fuel Oil Testing Program defined in the TSs includes tests for (1) the acceptability of new fuel oil for use prior to addition to storage tanks; (2) other properties of new fuel oil within limits within 31 days following sampling and addition to storage tanks; and (3) total particulate concentration of the fuel oil every 31 days. The current TSs identify the particular American Society for Testing and Materials (ASTM) standards and methods of performing these tests. The industry submitted Technical Specification Task Force (TSTF)-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," proposing changes to the Standard TS (STS) (NUREG-1430 to NUREG-1434) to provide the flexibility to address future changes in the U.S. Environmental Protection Agency (EPA) regulations for fuel oil or revisions to ASTM standards. TSTF-374 was reviewed and accepted by the NRC staff and has been incorporated into each of the STS NUREGs. Requirements for testing the diesel fuel oil are maintained, but references to specific ASTM standards are relocated to licensee-controlled documents and an alternative to the "clear and bright" acceptance test for new fuel is added to address changes in EPA requirements.
In its letter dated August 17, 2009, the licensee identified 10 CFR Part 50, Appendix A, General Design Criterion (GOG) 17 as applicable to this review:
General Design Criterion (GDC) 17, "Electric Power Systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability.
In Sections 1.8 and 9.5.4.1.b of the Columbia Final Safety Analysis Report (FSAR), the licensee stated that the design of the Diesel Generator Fuel Oil Storage and Transfer System conforms to NRC Regulatory Guide (RG) 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators," dated October 1979. RG 1.137, Regulatory Position 1, states that American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel Generators," provides a method acceptable to the staff for complying with the pertinent requirements of GDC 17 of Appendix A to 10 CFR Part 50. RG 1.137, Regulatory Position 1.c states that Section 5.4 of ANSI N195-1976, "Calculation of Fuel Oil Storage Requirements," sets forth two methods for the calculation of fuel oil storage requirements:
These two methods are (1) calculations based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. For
- 3 the time-dependent load method, the minimum required capacity should include the capacity to power the engineered safety features.
Both methods shall include an explicit allowance for fuel consumption required by periodic testing. NUREG-0800, "Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 9.5.4, "Emergency Diesel Engine Fuel Oil Storage and Transfer System," paragraph 1.1.H states that the emergency diesel engine fuel oil storage and transfer system is reviewed to verify whether "[a] minimum of seven days supply of fuel oil for each diesel generator system is onsite to meet the engineered safety feature load requirements following a loss of offsite power and a design-basis accident (DBA)." The licensee used TSTF 501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," which was approved by the NRC staff subsequent to the licensee's submittal, as the basis for the proposed change.
3.0 TECHNICAL EVALUATION
3.1
System Description
The onsite electrical power system includes standby power sources, distribution systems, and vital auxiliary supporting systems to supply power to safety-related equipment. Most commercial nuclear power plants use EDGs as standby emergency alternating current (AC) power source for the safety-related electrical buses. The importance of the diesel generators (or other standby power sources) is reflected in their incorporation into NRC regulations, TSs, and other regulatory programs, including GDC 17 and Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50.
3.2 Proposed TS Changes
It its letter dated August 17, 2009, the licensee requested the following TS changes:
TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" - The proposed changes would relocate specific values for fuel oil and lube oil storage volumes from the TS to the TS Bases consistent with the approach specified by [TSTF-501], which is currently under review by the Nuclear Regulatory Commission (NRC).
TS 3.8.1, "AC Sources - Operating" - This proposed change would relocate the specific value for day tank fuel oil volume from the TS to the TS Bases.
TS 5.5.9, "Diesel Fuel Oil Testing Program" - This proposed change would relocate the specific standard for particulate concentration testing of diesel fuel oil from the TS to the TS Bases consistent with [TSTF-374-A Rev. 0, "Revision to TS 5.5.13 and associated TS Bases for Diesel Fuel Oil"].
3.2.1 Proposed Changes to TS 3.8.3 Currently, LCO 3.8.3 Conditions A and B state:
A.
One or more DGs with stored fuel oil level:
- 4
- 1.
For DG-1 or DG-2, < 55,500 gal and ~ 47,520 gal; and
- 2.
For DG-3, < 33,000 gal and ~ 28,340 gal.
B.
One or more DGs with lube oil inventory:
- 1.
For DG-1 or DG-2, < 330 gal and ~ 283 gal; and
- 2.
For DG-3, < 165 gal and ~ 142 gal.
Revised LCO 3.8.3 Conditions A and B would state, A.
One or more DGs with fuel oil level less than a 7 day supply and greater than a 6 day supply.
B.
One or more DGs with lube oil inventory less than a 7 day supply and greater than a 6 day supply.
Currently, SR 3.8.3.1 states, Verify each fuel oil storage tank contains:
- a.
~ 55,500 gal of fuel for DG-1 and DG-2; and
- b.
~ 33,000 gal of fuel for DG-3.
Revised SR 3.8.3.1 would state, Verify each fuel oil storage subsystem contains ~ a 7 day supply of fuel.
Currently, SR 3.8.3.2 states, Verify lube oil inventory is:
- a.
~ 330 gal for DG-1 and DG-2; and
- b.
~ 165 gal for DG-3.
Revised SR 3.8.3.2 would state, Verify lube oil inventory is ~ a 7 day supply.
3.2.2 Proposed Change to TS SR 3.8.1 Currently, SR 3.8.1.4 states, Verify each required day tank contains ~ 1400 gal of fuel oil.
Revised SR 3.8.1.4 would state, Verify each required day tank contains fuel oil to support greater than or equal to one hour of operation at full load plus 10%.
- 5 3.2.3 Proposed Change to TS 5.5.9 Currently, TS 5.5.9.c states, Total particulate concentration of the fuel oil in the storage tanks is =: 10 mgtl when tested every 31 days in accordance with ASTM D-2276, Method A-2 or A-3.
Revised TS 5.5.9.c would state, Total particulate concentration of the fuel oil in the storage tanks is =: 10 mgtl when tested every 31 days.
3.3
NRC Staff Evaluation
3.3.1 TS 3.8.3 The licensee proposes to modify TS 3.8.3, "Diesel Fuel Oil and Starting Air," by replacing the specific fuel oil and lube oil storage volumetric requirements (in gallons) with a requirement to maintain less than a 7-day supply and greater than or equal to a 6-day supply for the diesel fuel oil and lube oil while retaining the specific tank volumetric requirements (in gallons) needed to meet the 7-and 6-day requirements in the TS Bases.
The licensee's TS currently have the specific amounts (in gallons) of fuel oil and lube oil necessary for each EDG for 7 days and 6 days of continuous operation. These specific amounts are located in both the LCOs and the SRs for fuel oil and lube oil. The licensee proposes to replace these specific amounts of fuel oil and lube oil with the required amount of time (7 days and 6 days). The specific amounts of fuel oil and lube oil would be relocated to the TS Bases. The specific amounts of fuel oil are based on the properties of Ultra Low Sulfur Diesel (ULSD) fuel, and the specific amounts of lube oil are based upon the EDG manufacturer's lube oil consumption values with the EDGs operating at full load and operating with ULSD fuel.
In reviewing the calculation method utilizing the minimum quality of fuel oil acceptable at Columbia, the licensee stated that it has determined that the fuel oil volume required for the Division 2 EDG was non-conservative. The same review process by the licensee confirmed that the required fuel oil volumes for the Division 1 and 3 EDGs remain bounded by the current TS-required storage volumes. As such, the licensee implemented administrative controls to ensure that the higher volume of fuel oil is maintained for the Division 2 EDG, consistent with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Legacy Library Accession No. 9812280273). Replacing the specific fuel oil storc:lge volumetric requirements (in gallons) with a requirement to maintain less than a 7-day supply and greater than or equal to a 6-day supply for the diesel fuel oil in TS 3.8.3 will remove the non-conservative volumetric value.
- 6 In its letter dated January 21, 2010, the licensee proposed to use the term "fuel oil storage subsystem" in SR 3.8.3.1 rather than the term "fuel oil storage tank" used in TSTF-501, which it specifically defines as the fuel oil storage tank and the available volume in the day tank (the differential between the low level alarm set point and the volume for EDG operation for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at full load plus 10 percent) for greater than or equal to a 7-day fuel oil supply. ANSI N195-1976 does not prohibit the use of the excess fuel oil in the day tank when calculating the required amount of fuel oil for 7 days of continuous EDG operation.
As identified in NRC Information Notice 2006-22, "New Ultra-low-sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," dated October 12, 2006 (ADAMS Accession No. ML062710079), the EPA finalized the Clean Diesel Trucks and Buses Rule and the Clean Nonroad Diesel Rule (71 FR 25706-25726; May 1, 2006). In its letter dated August 17, 2009, the licensee stated that these rules require sulfur reductions for land-based nonroad diesel fuel to be accomplished in two steps, with an interim step from currently uncontrolled sulfur content levels to a 500 parts per million (ppm) cap starting in June 2007 and the final step to 15 ppm sulfur content in June 2010. This 15 ppm sulfur content fuel is known as ULSD. The processing required to reduce the sulfur content to 15 ppm also reduces the aromatic content and the density of diesel fuel, which results in a reduction in volumetric energy content (British Thermal Unit per gallon). This reduction in energy content will require the licensee to store more fuel in order to maintain an amount sufficient for 7 days of EDG operation.
As stated in RG 1.137, Regulatory Position 1, AI\\ISI 1\\1195-1976 provides a method acceptable to the NRC staff for complying with the pertinent requirements of GDC 17 of Appendix A to 10 CFR Part 50. Regulatory Position 1.c states that Section 5.4 of ANSI N195-1976 sets forth two methods for the calculation of fuel oil storage requirements. The licensee has stated that its calculation follows the conservative method for determining the fuel oil storage requirements, with the exception that it did not include an explicit allowance for fuel consumption required by periodic testing. This method is not consistent with ANSI N195-1976. The licensee stated that there are two periodic SRs for EDGs that could impact its fuel oil storage volumes related to not including an explicit allowance for fuel consumption required by periodic testing in its fuel oil storage calculation. SR 3.8.1.3, performed on a 31-day frequency interval, requires the EDG to be operated for greater than or equal to 60 minutes at or near rated load. SR 3.8.1.14, which is performed on a 24-month frequency, requires an extended run time of the EDG for greater than or equal to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee's surveillance procedures that satisfy SR 3.8.1.3 ensure that the 7-day fuel oil storage requirement is verified immediately upon completion of the 31-day surveillance test. The 24-hour surveillance procedure requires that fuel oil volume be closely monitored and that fuel oil be added to the storage tank to ensure that the 7-day storage requirement is maintained during this surveillance test. As such, the licensee meets the intent of ANSI N195-1976 for a 7-day fuel oil storage requirement.
In its letter dated August 17, 2009, the licensee currently allows a range of American Petroleum Institute (API) Gravity values at 60 degrees Fahrenheit CF) of greater than 27 degrees but less than or equal to 38 degrees for its fuel oil. The licensee stated that it has calculated the required amount of stored fuel for 7 days and 6 days of EDG operation considering all ULSD fuel at an API Gravity at 60°F of 38 degrees, which is at the conservative end of its allowable range. The correlation between API Gravity and energy content is well known. This correlation is documented by the National Bureau of Standards (now National Institute of Standards and Technology) in its Miscellaneous Publication No. 97, "Thermal Properties of Petroleum
- 7 Products," dated April 28, 1933. The licensee stated that if a shipment of fuel is received and it has an API Gravity outside of the current allowable range, the fuel shipment will be rejected.
ASTM D975-08a, "Standard Specification for Diesel Fuel Oils" (and subsequent revisions),
permits number 2 diesel fuel to contain up to a B5 blend (5 percent biodiesel) and still be considered the same without labeling the blend. The licensee's fuel oil storage calculation does not accommodate the use of fuel oil that contains biodiesel. The licensee has stated that its purchase contract for fuel oil specifies that fuel oil containing biodiesel will not be accepted. The licensee screens new shipments of fuel oil for biodiesel content prior to offloading the fuel.
Shipments that fail the screening for biodiesel are rejected.
The requested changes to the Diesel Fuel Oil and Starting Air TS (3.8.3) ensure that the information required by 10 CFR 50.36 is maintained in the TS and that the specific design value for volume that needs to be maintained in the fuel oil storage tanks, and lube oil tanks (in gallons) are located in a licensee-controlled document (i.e., the TS Bases). The licensee's TS Bases are controlled in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Based on the above, the NRC staff concludes these changes are acceptable.
3.3.2 TS SR 3.8.1 The licensee proposes to modify TS 3.8.1, "AC Sources - Operating," by replacing the specific day tank volumetric requirements (in gallons) with a requirement to maintain a volume of fuel oil to support greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of operation at full load plus 10 percent.
Relocating the specific values of fuel oil in the day tanks equivalent to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of EDG operation at 100 percent load plus 10 percent to the TS Bases does not alter the licensing basis of the plant. The licensee is still required by TSs to maintain the 1-hour supply. In addition, the proposed amendment will allow the licensee to adjust the specific value based on the properties of the fuel oil received without the need to submit a license amendment request. The requested changes to TS SR 3.8.1 ensure that the specific design value for volume that needs to be maintained in the day tanks (in gallons) are located in the TS Bases which are controlled in accordance with TS 5.5.10. Based on the above, the NRC staff concludes this change is acceptable.
3.3.3 TS LCO 5.5.9 The licensee proposes to modify TS 5.5.9, "Diesel Fuel Oil and Testing Program," by relocating the specific standard for particulate concentration testing of diesel fuel oil from the TS to the TS Bases, consistent with TSTF-374, Revision O.
In adopting TSTF-374, the licensee proposes to relocate the reference to ASTM D2276, "Standard Test Method for Particulate Contaminant in Aviation Fuel by Line Sampling," from the TS Administrative Controls Section 5.5.9, "Diesel Fuel Oil Testing Program," to a Iicensee controlled document. Although the reference to ASTM D2276 is relocated, TS 5.5.9 retains acceptance criteria for new and stored diesel fuel oil and refers to "applicable ASTM standards" for sampling and testing requirements.
- 8 In addition, in its letter dated August 17, 2009, the licensee proposes the following changes to the TS Bases SR 3.8.3.3 that are consistent with the recommendations of TSTF-374:
Updates to the versions of the ASTM standards employed, or proposed to be employed (i.e., newer versions), at Columbia as delineated by the brackets [ ] in the TSTF; The addition of ASTM D1298 ["Standard Test Method for Density, Relative Density (Specific Gravity), or API Gravity of Crude Petroleum and Liquid Petroleum Products by Hydrometer Method"] which will be used to test for API Gravity; ASTM D5452 ["Standard Test Method for Particulate Contamination in Aviation Fuels by Laboratory Filtration"] will replace ASTM D2276 as the standard for determination of particulate concentrations; and The addition of sulfur testing standard ASTM D4294 ["Standard Test Method for Sulfur in Petroleum and Petroleum Products by Energy Dispersive X-ray Fluorescence Spectrometry"].
TSTF-374 added ASTM D2709 ["Standard Test Method for Water and Sediment in Middle Distillate Fuels by Centrifuge"] as the standard for testing water and sediment content consistent with the proposed addition of this test to the TS. As discussed above, Columbia's TS already included this required testing, but [the licensee] was testing to the ASTM D1796 standard ["Standard Test Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)"]. Columbia is proposing to align with the recommendation of the TSTF by replacing ASTM D1796 with ASTM D2709.
In its letter dated August 17, 2009, the licensee also proposes the following deviations to TSTF-374 in its TS Bases 3.8.3 section:
As discussed above, the TSTF modifies a portion of SR 3.8.3.3.b. A requirement of SR 3.8.3.3.b that the TSTF does not modify [is] the range for allowed API Gravity at 60°F as being ~ 27 degrees and.::: 39 degrees.
Based on current fuel oil volume calculations, Columbia has restricted the upper limit of allowed API gravity to 38 degrees, which is more conservative than the allowed value listed in the TSTF/STS.
Columbia proposes to add standards ASTM D3120 ["Standard Test Method for Trace Quantities of Sulfur in Light Liquid Petroleum Hydrocarbons by Oxidative Microcoulometry"] and ASTM D5453
["Standard Test Method for Determination of Total Sulfur in Light Hydrocarbons, Spark Ignition Engine Fuel, Diesel Engine Fuel, and Engine Oil by Ultraviolet Fluorescence"] to provide for additional referee test methods or alternative methods for sulfur testing as recognized in
- 9 ASTM 0975 (Ref. 7 [of the licensee's submittal]). These ASTMs were not discussed in the TSTF.
A correction to the TS Bases Background to more accurately reflect that the original guidance provided in Regulatory Guide (RG) 1.137 and ANSI N195 have since been modified with regards to fuel oil practices via the existent TS Actions and Surveillance Requirements. This issue was not addressed in the TSTF.
These deviations were reviewed by the NRC staff. The upper limit of allowed API Gravity at 60 of has been restricted to 38 degrees, which is at the conservative end of the range listed in the TSTF/STS and, therefore, is acceptable. The range for allowed API Gravity at 60 of used by the licensee (greater than or equal to 27 degrees and less than or equal to 39 degrees) is consistent with the range used in the industry. In TSTF-374, ASTM 02709 was accepted for use. ASTM 02709 endorses the use of ASTM 0975, which endorses ASTM 03120 and ASTM 05453. Therefore, ASTM 02709, by inference, endorses the use of ASTM 03120 and ASTM 05453. The staff concludes that ASTM 03120 and ASTM 05453 are acceptable for use.
As discussed above, because the fuel would be tested to ASTM 0975, the NRC has no objection to the conforming changes being made to the TS Bases.
Based on the above, the licensee's proposed changes in this license amendment request are acceptable, since the changes to Columbia TS requirements do not result in any substantive change in operating requirements, are consistent with the Commission's regulations, and conform to the requirements of 10 CFR 50.36. On this basis, the NRC staff concludes that the proposed TS changes are acceptable.
3.4 Conclusion Since the licensee committed in its FSAR to RG 1.137, Revision 1, dated October 1979, which endorsed ANSI N195-1976, it should update the FSAR to reflect the exception to ANSI N195-1976 regarding the explicit allowance for fuel oil for periodic testing in the calculation of EOG fuel oil storage requirements.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Washington State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIOERATION The amendment changes a requirement 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 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 the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on November 3,2009 (74 FR 56884). Accordingly, the
- 10 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.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: P. Sahay R. Wolfgang Date: May 27, 2010.
- bJY memo d t d ae OFFICE NAME NRRlLPL4/PM LWllkins NRR/LPL4/PM FLyon NRR/LPL4/LA JBurkhardt NRR/DE/EEEB/BC GWilson*
NRRIDCI/CSGB/BC RTaylor*
NRRIDCI/CPTB/BC AMcMurtray*
DATE OFFICE NAME DATE 5/3/10 NRR/DSS/SBPB/BC GCasto 5/11/10 5/5/2010 DIRS/ITSB/BC REIliott 5/14/10 4/30/10 OGC MSpencer 5/20/10 3/31/10 NRR/LPL4/BC MMarkley JRHall for 5/26/10 3/31/10 NRR/LPL4/PM FLyon 5/27/10 3/31/10 I