ML101380068

Emergency Diesel Generator Fuel Oil - Sampling of Fuel Oil Storage Tanks - Additional Information

ML101380068
Person / Time
Site:	Sequoyah
Issue date:	05/13/2010
From:	Krich R Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML101380068 (19)

Text

Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing May 13, 2010 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-00001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Emergency Diesel Generator Fuel Oil - Sampling of Fuel Oil Storage Tanks - Additional Information By letter dated February 24, 2010, the Tennessee Valley Authority (TVA) requested NRC approval, pursuant to American Society of testing and Materials (ASTM) Standard D4057-1988, "Standard Practice for Manual Sampling of Petroleum and Petroleum Products," for the Sequoyah Nuclear Plant to use an alternative sampling procedure for the Emergency Diesel Generator Fuel Oil Storage Tanks. Sampling of these tanks is required by Technical Specification Surveillance Requirement 4.8.1.1.2.c.

As agreed by TVA and NRC in a telephone call on April 27, 2010, TVA is providing, in the enclosures, additional information to support the NRC review of this request. This information consists of: 1) general procedural steps with narrative explanation of the proposed sampling process, and 2) work order information that was used in the October to December 2009 period to obtain samples of the Fuel Oil Storage Tanks using the alternative sampling process.

printed on recycled paper

Document Control Desk - NRC Page 2 May 13, 2010 There are no regulatory commitments in this letter. If you have any questions, please contact Rod Cook at (423) 751-2834.

R. M. Krich*

Enclosures:

1. General Procedural Steps for Alternate Testing of Emergency Diesel Generator Fuel Oil Storage Tanks

2. Work Instruction Forms (Step Text 1) for Work Order Numbers 09-779078-003 and 09-779079-003 Used for Alternate Sampling of Fuel Oil Storage Tanks No. 1 and No. 2 cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant

ENCLOSUREI SEQUOYAH NUCLEAR PLANT GENERAL PROCEDURAL STEPS FOR ALTERNATE TESTING OF EMERGENCY DIESEL GENERATOR FUEL OIL STORAGE TANKS

General Procedural Steps for Alternate Testing of Emergency Diesel Generator Fuel Oil Storage Tanks (The procedural steps are general and the values will be provided during formal procedural development. Narrative explanation of general procedural step are provided in italics following the step.)

1. Ensure fuel oil storage tank has been placed on recirculation for a minimum of [ ] hours.

Recirculationof the fuel oil storage tanks is accomplished by the fuel oil transferpump.

Recirculation will ensure that the tank is mixed so that a representative sample can be obtained. Recirculation time is determined based on tank level and tank fuel oil volume to ensure at least a one volume recirculationof the contents.

2. Ensure flexible tube is attached downstream of sample valve to allow sample collection.

This sample valve is the 1- inch valve off of the 4-inch process line downstream of the fuel oil transferpump where the sample will be obtained.

3. Throttle open sample valve Opening this valve will allow for potential stagnantline area flush and subsequent sample collection to take place.

4. Flush for [ minutes then obtain [ _ liter] samples.

The flush will ensure that the sample collected will be representativeof the contents of the tank. Samples will then be taken for analysis.

E1-1

ENCLOSURE 2 WORK INSTRUCTION FORMS (STEP TEXT 1) FOR WORK ORDERS NUMBERS 09-779078-003 AND 09-779079-003 USED FOR ALTERNATE SAMPLING OF EMERGENCY DIESEL GENERATOR FUEL OIL STORAGE TANKS NO. I AND NO. 2

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1 SCOPE:

The scope of this Step Text is to obtain a sample of the fuel oil system.

1.0 EQUIPMENT CATEGORY:

1.1 This equipment is NQR. QA material IS NOT required for this application.

2.0 REOUIREMENTS

2.1 Performance of this WO shall be per MMDP-1.

2.2 Foreign Material Control (SPP-6.5) Level 2 applies if the system is breached.

2.3 "Cleanliness of Fluid Systems" is controlled by 0-MI-MIN-000-070.0. The following cleanliness requirements SHALL apply for the performance of this Work Order if the system is breached and / or new material is installed.

Identify class or mark yes or no External cleanliness: [N ]

Internal cleanliness class [ E ]

2.4 Steps may be "N/A" in accordance with MMDP- 1, section 3.10.5 if the stated condition does not exist or the step is deemed unnecessary by the responsible work supervisor or cognizant engineer.

Document the reason for each step N/A'ed in the actual work performed section of WO.

PMT steps may be marked N/A only if specifically allowed in the PMT.

E2-1

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1 3.0 PRECAUTIONS AND LIMITATIONS:

3.1 If additional steps to support the sampling activity outside the scope of this planning is required, provide detailed description of the required activities in the "Work Performed Section" of this Work Order and return the Work Order Package for additional planning.

3.2 Sections of the work order is to be performed in numerical order while "steps" within a particular section may be worked out of sequence, concurrently, or re-performed as long as operation in work sequence do not affect completion, interfere with required inspections and verifications, or violate prerequisite requirements. Decision to work out of sequence SHALL be made by Cognizant Supervisor / Engineer.

3.3 This sampling activity is to be performed with the fuel oil system placed on recir. per 0-SO-I 8-3.

NO hold order will be in place to support the activity.

3.4 Perform this activity utilizing all human error avoidance techniques to prevent any spillage of oil to the environment.

3.5 DEVELOPMENTAL REFERENCES

1) 0-SI-CEM-018-116.1

2) 1, 2-47W840-1

3) 0-SO-18-3 E2-2

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 'WO NO: 09-779078-003 STEP TEXT 1

4.0 PREREOUISITES

4.1 Coordinate work performance with Operations. []

4.2 Obtain from Power Stores materials necessary to attach down stream of 0- 18-204 that will allow sample collection. []

E2-3

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1

5.0 PERFORMANCE

5.1 A CDR of the following work steps shall be obtained to allow Chemistry to perform sampling activities of the fuel oil system.

CDR Performed by (Ops. /Date)_ Date 5.2 Ensure 0-SI-CEM-0 18-116.1 has been performed. Init./Date /

Chem.

5.3 Ensure #1 fuel oil storage tank has been placed on recirc. for a minimum of 6-1/2 hours. Init./Date /

Chem.

5.4 If #1 fuel oil storage tank has not been on recir. for the required 6-1/2 hours then contact Ops and request system be placed on recir. per 0-SO-18-3. Init./Date /

Chem.

5.5 If requested by Chemistry group to place #1 fuel oil storage tank on recir. then perform per applicable sections of 0-SO- 18-3. Init./Date /

Ops 5.6 Ensure tygon tube is attached down stream of 0-18-204 to allow sample collection if tubing is worn then replace so that no leaks will occur. Init./Date /

Chem.

5.7 Ensure secondary containment measures are in place. Init./D)ate /

Chem.

5.8 Ensure catch container is empty prior to 0-18-204 being opened to support flush. Init./D)ate /

Chem.

5.9 Place [0-I-S-18-9A] in STOP. Init./D )ate /

OPS lnit./Date /

C.V.

E2-4

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1 5.10 Throttle Open valve 0-18-204 on inlet side. Init./Date

/PS 5.11 Flush for 3 minutes then obtain (2) one liter samples.

Init./Date /

Chemistry 5.12 Close valve 0-18-204. Init./Date /

OPS Init./ Date /

I.V.

5.13 Attach App. B from 0-SI-CEM-018-295.0 to the samples then transport to CLS. Init./Date /

Chem.

5.14 Return this completed work order to Cognizant Chemist. (Constance Bryant)

(8225 / Pager 20-295) lnit./ Date /I Chem.

E2-5

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1 6.0 POST MAINTENANCE TESTING:

6.1 Maintenance Testing:

6.1.1 With the fuel oil system in service and 0-018-204 in the closed position, ensure no leakage at connections affected during this WO performance.

Performed by/date /

Chemistry 6.2 Return To Operability Testing; (RECOMMENDED) 6.2.1 None E2-6

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779078-003 STEP TEXT 1 7.0 POST WORK ACTIVITIES:

7.1 Ensure the completed work order has been transported to Cognizant Chemist. (Constance Bryant)

@ 8225 / Pager 20-295)

Performed by/date /

7.2 Ensure work site has been cleaned of materials used to assist in the performance of this work order.

Performed by/date /

7.3 Ensure diesel fuel obtained from flush is properly disposed of or returned to 7day tanks if no FME issues are present.

Performed by/date /

7.4 Notify Operations that work activities are completed and to terminate recirculation of FOST #1 and to place FOST #2 on recirculate for 6 1/2 hours.

Performed by/date /

E2-7

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1 SCOPE:

The scope of this Step Text is to obtain a sample of the fuel oil system.

1.0 EOUIPMENT CATEGORY:

1.1 This equipment is NQR. QA material IS NOT required for this application.

2.0 REQUIREMENTS

2.1 Performance of this WO shall be per MMDP-1.

2.2 Foreign Material Control (SPP-6.5) Level 2 applies if the system is breached.

2.3 "Cleanliness of Fluid Systems" is controlled by 0-MI-MIN-000-070.0. The following cleanliness requirements SHALL apply for the performance of this Work Order if the system is breached and /

or new material is installed.

Identify class or mark yes or no External cleanliness: [N ]

Internal cleanliness class [ E ]

2.4 Steps may be "N/A" in accordance with MMDP-1, section 3.10.5 if the stated condition does not exist or the step is deemed unnecessary by the responsible work supervisor or cognizant engineer.

Document the reason for each step N/A'ed in the actual work performed section of WO.

PMT steps may be marked N/A only if specifically allowed in the PMT.

E2-8

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1 3.0 PRECAUTIONS AND LIMITATIONS:

3.1 If additional steps to support the sampling activity outside the scope of this planning is required, provide detailed description of the required activities in the "Work Performed Section" of this Work Order and return the Work Order Package for additional planning.

3.2 Sections of the work order is to be performed in numerical order while "steps" within a particular section may be worked out of sequence, concurrently, or re-performed as long as operation in work sequence do-not affect completion, interfere with required inspections and verifications, or violate prerequisite requirements. Decision to work out of sequence SHALL be made by Cognizant Supervisor / Engineer.

3.3 This sampling activity is to be performed with the fuel oil system placed on recir. per 0-SO- 18-4.

NO hold order will be in place to support the activity.

3.4 Perform this activity utilizing all human error avoidance techniques to prevent any spillage of oil to the environment.

3.5 DEVELOPMENTAL REFERENCES

1) 0-SI-CEM-018-116.1

2) 1, 2-47W840-1

3) O-SO-18-4 E2-9

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1

4.0 PREREOUISITES

4.1 Coordinate work performance with Operations. []

4.2 Obtain from Power Stores materials necessary to attach down stream of 0-18-204 that will allow sample collection. []

E2-10

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1

5.0 PERFORMANCE

5.1 A CDR of the following work steps shall be obtained to allow Chemistry to perform sampling activities of the fuel oil system.

CDR Performed by (Ops./Date) Date 5.2 Ensure 0-SI-CEM-018-116.1 has been performed. Init./Date /

Chem.

5.3 Ensure #2 fuel oil storage tank has been placed on recirc. for a minimum of 6-1/2 hours. Init./Date /

Chem.

5.4 If #2 fuel oil storage tank has not been on recir. for the required 6-1/2 hours then contact Ops and request system be placed on recir. per 0-SO- 18-4. Init./Date /

Chem.

5.5 If requested by Chemistry group to place #2 fuel oil storage tank on recir. then perform per applicable sections of 0-SO- 18-4. Init./Date /

Ops 5.6 Ensure tygon tube is attached down stream of 0-18-204 to allow sample collection if tubing is worn then replace so that no leaks will occur. Init./Date /

Chem.

5.7 Ensure secondary containment measures are in place. Init./Date /

Chem.

5.8 Ensure catch container is empty prior to 0-18-204 being opened to support flush. Init./Date /

Chem.

5.9 Place [ 0-HS-18-9A] in STOP. Init./Date /

OPS Init./Date /

C.V.

E2-11

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1 5.10 Throttle Open valve 0-18-204 on inlet side Init./Date /

OPS.

5.11 Flush for 3 minutes then obtain (2) one liter samples.

Init./Date /

Chemistry 5.12 Close valve 0-18-204. Init./Date /

OPS Init./ Date /

I.V.

5.13 Attach App. B from 0-SI-CEM-018-295.0 to the samples then transport to CLS. Iriit./Date Chem.

5.14 Return this completed work order to Cognizant Chemist. (Constance Bryant)

@ 8225 / Pager 20-295) Init./ Date /

Chem.

E2-12

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1 6.0 POST MAINTENANCE TESTING:

6.1 Maintenance Testing:

6.1.1 With the fuel oil system in service and 0-018-204 in the closed position, ensure no leakage at connections affected during this WO performance.

Performed by/date /

Chemistry 6.2 Return To Operability Testing; (RECOMMENDED) 6.2.1 None E2-13

WORK INSTRUCTION FORM COMP. ID: SQN-0-MISC-018 WO NO: 09-779079-003 STEP TEXT 1 7.0 POST WORK ACTIVITIES:

7.1 Ensure the completed work order has been transported to Cognizant Chemist. (Constance Bryant)

@ 8225 / Pager 20-295)

Performed by/date 7.2 Ensure work site has been cleaned of materials used to assist in the performance of this work order.

Performed by/date 7.3 Ensure diesel fuel obtained from flush is properly disposed of or returned to 7day tanks if no FME issues are present.

Performed by/date /

7.4 Notify Operations that work activities are completed and the recirculation of the FOST #2 can be terminated.

Performed by/date E2-14