ML12110A088

License Amendment Request Regarding the Diesel Fuel Oil Test Program Technical Specification

ML12110A088
Person / Time
Site:	Millstone
Issue date:	04/13/2012
From:	Price J Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
11-669
Download: ML12110A088 (18)

Text

/

e Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 ~Domini N W Web Address: www.dom.com April 13, 2012 U.S. Nuclear Regulatory Commission Serial No.11-669 Attention: Document Control Desk NSS&L/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 LICENSE AMENDMENT REQUEST REGARDING THE DIESEL FUEL OIL TEST PROGRAM TECHNICAL SPECIFICATION Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests to amend Operating License DPR-65 for Millstone Power Station Unit 2 (MPS2). The proposed amendment would modify technical specification (TS) requirements related to diesel fuel oil testing consistent with NUREG-1432, Rev. 3.1, "Standard Technical Specifications, Combustion Engineering Plants", December 1, 1995, and NRC approved Technical Specification Task Force (TSTF) TSTF-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," Revision 0. A description of the proposed changes is provided in Attachment 1. The marked up TS page is provided in Attachment 2. The associated bases changes are provided in Attachment 3 for information only and will be implemented in accordance with the Technical Specification Bases Control Program.

The proposed amendment does not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92. The Facility Safety Review Committee (FSRC) has reviewed and concurred with this determination.

DNC requests approval of the proposed amendment by May 1, 2013. Once approved, the amendment will be implemented within 120 days.

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.

4o01

Serial No.11-669 Docket No. 50-336 Page 2 of 3 If you have any questions regarding this submittal, please contact Ms. Wanda Craft at (804) 273-4687.

Sincerely, A nrice J.

Vic P sident - Nuclear Engineering COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this day of___ ___

My Commission Expires: 7 D Notary KC.MARSHALL Public Commonwealth of Virginia Commitments made in this letter: None jMy Commialon J

FWANIDA 7173087 rs 31, 2012 Attachments:

1. Evaluation of Proposed License Amendment

2. MPS2 Marked-up Page

3. Marked-up MPS2 Bases Pages, For Information Only

Serial No.11-669 Docket No. 50-336 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 J. S. Kim Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.11-669 Docket No. 50-336 ATTACHMENT I LICENSE AMENDMENT REQUEST REGARDING THE DIESEL FUEL OIL TEST PROGRAM TECHNICAL SPECIFICATION EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 1 of 9 EVALUATION OF PROPOSED LICENSE AMENDMENT

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests to amend the Operating License DPR-65 for Millstone Power Station Unit 2 (MPS2).

The proposed amendment would modify technical specification (TS) requirements related to diesel fuel oil testing consistent with NUREG-1432, Rev. 3.1, "Standard Technical Specifications, Combustion Engineering Plants", December 1, 1995, and NRC approved Technical Specification Task Force (TSTF) TSTF-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," Revision 0. These changes also remove from the TS specific testing methodologies which are already described in the MPS2 TS Bases. To adopt proposed changes that are consistent with the content of NUREG-1432, Rev. 3.1 and TSTF-374 for use in the custom TS of MPS2, the existing MPS2 diesel fuel oil testing program of TS 6.24 will require modification.

2.0 PROPOSED CHANGE

S The following paragraph describes the proposed changes to the MPS2 TS. The marked up page of these current TS are provided in Attachment 2.

2.1 MPS2 TECHNICAL SPECIFICATIONS Change Page Description of Proposed Change(s) 1 6-29 Administrative Control TS 6.24,'DIESEL FUEL OIL TEST PROGRAM TS 6.24.a.3, regarding the acceptability of new fuel oil, is changed to replace the criteria of "Water and sediment < 0.05%" with the criteria of "A clear and bright appearance with proper color or a water and sediment content within limits."

TS 6.24.c is revised to remove the applicable American Society for Testing and Materials ASTM D 2276-78, Method A from the TS.

ASTM D 2276-78, Method A is already described in the MPS2 TS Bases.

These changes to TS 6.24 are based upon TSTF-374, but modified to be consistent with MPS2 custom TS.

Section 4 provides analysis regarding the proposed changes shown on the marked-up TS page in Attachment 2.

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 2 of 9 2.2 BASES The TS Bases will be revised to reflect the proposed specification changes.

Because the TS Bases are a licensee-controlled document, these changes have been provided for information only in Attachment 3. Changes to the Bases are controlled in accordance with the Technical Specification Bases Control Program (MPS2 TS 6.23) and the Bases are considered a licensee-controlled document.

Thus, adequate controls exist to allow removal of the reference to a specific ASTM method from TS 6.24.c as the TS Bases already contains this information.

3.0 BACKGROUND

3.1 REASON FOR PROPOSED AMENDMENT This proposed amendment is needed to allow MPS2 to be responsive to the changing nature of testing methodologies associated with fuel oil, and industry standards (e.g., EPRI Guidelines). MPS2 custom TS have already included the requirement of a diesel fuel oil testing program, however the TS continue to specify the details of a specific fuel oil testing methodology. The proposed changes will remove such procedural information since this information is already specified in the TS Bases.

3.2 MPS2 FUEL OIL DESCRIPTION Section 8.3, "Emergency Generators," in the MPS2 Final Safety Analysis Report (FSAR) provides a detailed description of the diesel fuel oil system. Diesel fuel oil for the Diesel Generators (DGs) is stored in a 25,000-gallon (approximate capacity) above ground diesel fuel oil storage tank (T - 148). The diesel fuel oil is transferred from the storage tank by two 25-gpm diesel fuel oil transfer pumps to the two 13,500-gallon (approximate capacity), Class I, diesel fuel oil supply tanks (T - 48A and T - 48B) that are located in the structure that houses the associated DG. A minimum of 12,000 gallons of diesel fuel oil is stored in each above ground diesel fuel oil supply tank. The piping is arranged such that normally one diesel fuel oil transfer pump supplies diesel fuel oil to one diesel fuel oil supply tank.

However, there is an interconnection in the supply piping so that each transfer pump can supply diesel fuel oil to either supply tank. Diesel fuel oil is transferred by gravity from the supply tank to the engine-driven diesel fuel oil pump that supplies diesel fuel oil to the diesel engine. The piping is arranged such that normally one supply tank provides diesel fuel oil to one DG. However, there is an interconnection in the piping so that one DG can be provided with diesel fuel oil from either or both supply tanks.

The required 12,000 gallon volume in the diesel fuel oil supply tanks (T - 48A and T - 48B) will provide sufficient diesel fuel oil for two DGs to operate at 2750 KW for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and then one DG to continue operation at 2750 KW for a total of

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 3 of 9 approximately 3.5 days, assuming the two tanks are cross-connected after securing one DG. A DG run time of approximately 3.5 days provides a significant margin of time for replenishment of DG fuel oil. Replenishment can be accomplished from the nonsafety-related above ground diesel fuel oil storage tank or offsite sources. The nonseismic above ground diesel fuel oil storage tank provides the normal make-up path for diesel fuel oil to the diesel fuel oil supply tanks. It contains diesel fuel oil that is fully qualified and tested regularly.

If the volume of fuel oil in the above ground diesel fuel oil storage tank is taken into consideration, the one remaining DG will be able to continue operation at 2750 KW for an additional 3.5 days. This increases the total time one DG will be able to operate to approximately 7 days.

4.0 TECHNICAL ANALYSIS

The proposed change to TS 6.24.a.3, regarding the acceptability of new fuel oil, replaces the existing specific criteria of "Water and sediment < 0.05%" with the criteria of "A clear and bright appearance with proper color or a water and sediment content within limits." The change will also revise 6.24.c to remove the reference to a specific American Society for Testing and Materials (ASTM) method (ASTM D 2276-78, Method A) from the Administrative Control section of the TS.

MPS2 TS Bases already states "Particulate concentrations should be determined in accordance with ASTM D2276-78, Method A, every 92 days." The MPS2 TS Bases is a licensee-controlled document. Changes to TS Bases that correspond to future changes in requirements can be made in accordance with 10 CFR 50.59, "Changes tests, and experiments," as described in TS 6.23, "Technical Specifications (TS) Bases Control Program.".

The diesel fuel oil testing program was added to the MPS2 TS by Amendment No.

277, dated July 25, 2003. The current TS for Electrical Power Systems, A.C.

Sources Surveillance Requirement (SR) 4.8.1.1.2.b requires fuel oil testing to be performed in accordance with the Diesel Fuel Oil Test Program, and TS 6.24 provides the programmatic requirements for fuel oil testing. The applicable ASTM Standards applicable to the Diesel Fuel Oil Test Program may be modified following this change as related information is updated. However, the frequency and purpose of SR 4.8.1.1.2.b was not altered.

In TS 6.24.a.3, the criteria of "Water and sediment < 0.05%" is replaced with the criteria of "A clear and bright appearance with proper color or a water and sediment content within limits." This change to the administrative section of the MPS2 TS meets the intent of the TS changes described in TSTF-374, and results in wording that is consistent with NUREG-1432, Rev. 3.1. The part stating "or a water and sediment content within limit" allow a water and sediment content test to be performed to establish the acceptability of new fuel oil. The water and sediment content test is a quantitative test using centrifuge methods. As discussed in ASTM D975-98 and ASTM D975-81, ASTM D2709, "Test Method for Water and

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 4 of 9 Sediment in Distillate Fuels by Centrifuge," or ASTM D1796, "Standard Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)," are acceptable standards for the water and sediment content test.

The use of ASTM D1796-83 was previously approved by the NRC in Amendment No. 101, dated August 9, 1996 (ML022040294) for the Wolf Creek Generating Station. The proposed wording provides the same level of assurance of acceptability of water and sediment content as the existing wording.

TS 6.24.c is revised to remove reference to a specific American Society for Testing and Materials (ASTM) method (ASTM D 2276-78, Method A) from the Administrative Control section of the TS. The MPS2 TS Bases already states, on page B 3/4 8-7, "Particulate concentrations should be determined in accordance with ASTM D2276-78, Method A, every 92 days." The MPS2 TS Bases is a licensee-controlled document. Changes to the TS Bases that correspond to future changes in requirements can be made in accordance with 10 CFR 50.59, "Changes tests, and experiments," as described in TS 6.23, "Technical Specifications (TS) Bases Control Program." This proposed change meets the intent of the TS changes described in TSTF-374, and results in wording that is consistent with NUREG-1432. The testing programs for diesel fuel oil are also governed by other regulatory requirements, including 10 CFR 50, Appendix B, "Quality Assurance Criteria". While the removal of selected program details provides some flexibility to adopt practices defined in future ASTM standards, the remaining TS, and TS Bases Control Program, provide appropriate regulatory controls to ensure diesel fuel oil quality will be maintained. Should it be determined that future changes involve a potential reduction in a margin of safety, NRC review and approval would be necessary prior to the implementation of the changes. The proposed approach provides effective regulatory control and an appropriate change control process.

The proposed change removes the design detail to provide the flexibility to address future changes in Environmental Protection Agency (EPA) regulations for diesel fuel oil or revisions to the ASTM standards. The detail that is removed from the TS (and which is already specified in the TS Bases) is not required to be in the TS to provide adequate protection of the public health and safety since the TS still retains the requirement for compliance with the applicable ASTM standard.

Requirements for testing the diesel fuel oil are maintained, but reference to specific criteria from ASTM standards is specified in the TS Bases.

Maintaining the programmatic requirement but removing the specific ASTM criteria from TS 6.24, as it is already specified in a licensee-controlled document, will not affect the diesel fuel oil properties. Therefore, the operability of the DGs will not be affected. The specification of test method or dated specification will be contained in the diesel fuel oil test program which provides flexibility for MPS2 to be responsive to the changing nature of diesel fuel oil regulations and associated industry standards (e.g., EPRI Guidelines). Future changes in reference or specific criteria for the diesel fuel oil test program will be performed in accordance

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 5 of 9 with 10 CFR 50.59. This change will not impact plant safety. NUREG-1432 does not reference an ASTM method or date of specification, providing that level of detail under licensee-control in the Standard TS Bases.

In summary, the removal of this information from the TS and its placement into the TS Bases is considered to be less restrictive because it will no longer be controlled by the TS change process. However, the information is descriptive in nature and its removal conforms with NUREG-1432 for format and content. Information placed into the TS Bases remains under regulatory control. The proposed TS and associated Bases changes will continue to ensure the quality of both new fuel oil and stored fuel oil designated for use in the DGs. Therefore, the operability of the DGs is unaffected.

5.0 REGULATORY ANALYSIS

The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

General Design Criterion (GDC) 17, "Electrical Power Systems," of Appendix A, "General Design Criterion for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," requires, in part, that an onsite electrical power system be provided to permit functioning of structures, systems, and components (SSC) important to safety. In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability. Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 establishes overall quality assurance requirements for the design, construction, and operation of SSCs important to safety. In support of these requirements, Regulatory Guide (RG) 1.137 was developed to provide generic industry guidance for fuel oil system maintenance.

The information residing in the MPS2 TS Bases must be reviewed under the TS Bases Control Program, located in the Administrative Controls chapter of the TS, which requires changes to be evaluated under 10 CFR 50.59. Future changes to this information that do not meet the criteria in 10 CFR 50.59 are required to be submitted to the NRC for prior review under 10 CFR 50.90.

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 6 of 9 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION Dominion Nuclear Connecticut, Inc. (DNC) reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the Consolidated Line Item Improvement Process for Industry/Technical Specification Task Force (TSTF) traveler TSTF-374. DNC concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Millstone Power Station Units 2 (MPS2) and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

As discussed in the notice of availability published in the Federal Register on February 22, 2006 for TSTF-374, plant-specific verifications were performed. DNC has concldded the proposed Technical Specification (TS) Bases for MPS2 are consistent with TSTF-374, which provide guidance and details on how to implement the new requirements. In addition, DNC has a Bases Control Program consistent with Section 5.5 of NUREG- 1432.

DNC has evaluated whether or not a Significant Hazards Consideration (SHC) is involved with the proposed changes to MPS2 TS by addressing the three standards set forth in 10 CFR 50.92(c) as discussed below.

Criterion 1:

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes modify the TS requirements related to diesel fuel oil testing consistent with NRC approved TSTF-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," Revision 0. To adopt changes consistent with the content of TSTF-374 for use in the custom TS of MPS2, the existing MPS2 diesel fuel oil testing program will be modified. These changes replace the criteria of "Water and sediment < 0.05%" with the criteria of "A clear and bright appearance with proper color or a water and sediment content within limits" and remove specific American Society for Testing and Materials (ASTM) standard references from TS.

The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems, and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 7 of 9 consequences of any accident previously evaluated. Further, the proposed changes do not increase the types and amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures.

Therefore, the changes do not involve a significant increase in the probability or consequences or any accident previously evaluated.

Criterion 2:

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes are used to provide operational flexibility regarding evolving industry standards while maintaining operational conditions which are consistent with the design basis. Removing of specific details from TS, since the details are already specified in licensee-controlled documents, provides the flexibility needed to maintain state-of-the-art technology in fuel oil sampling and analysis methodology. The procedural details associated with the involved specifications that are removed from TS and residing in licensee-controlled documents are not required to be in the TS to provide adequate protection of the public health and safety, since the TS still retains the requirement for compliance with applicable standards. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation in the provision, maintaining, or use of diesel fuel oil. The requirements retained in the TS continue to require testing of the diesel fuel oil to ensure the proper functioning of the DGs.

Therefore, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes are consistent with the content of TSTF-374 for use in the custom TS of MPS2. These changes remove specific ASTM standard references and a preventive maintenance cleaning requirement from TS since the references and requirements are already specified in licensee-controlled documents. The proposed changes provide the flexibility needed to improve

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 8 of 9 fuel oil sampling and analysis methodologies while maintaining sufficient controls to ensure continued quality of the fuel oil. The margin of safety provided to the DGs by these detailed fuel specifications is unaffected by the proposed changes since there continue to be TS requirements to ensure fuel oil is of the appropriate quality for emergency DG use and DG operability is unaffected.

In summary, DNC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of no significant hazards consideration is justified.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA General Design Criterion (GDC) 17, "Electric Power Systems," of 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," 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.

Regulatory Guide 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators" dated October 1979, describes a method acceptable to the NRC staff for complying with the Commission's regulations regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality.

Regulatory Guide 1.137 states that Appendix B to ANSI N195-1976 should be used as a basis for a program to ensure the initial and continuing quality of diesel fuel oil as supplemented by eight additional provisions described in the Regulatory Guide for maintaining the properties and quality of diesel fuel oil.

The proposed changes do not involve a physical change to the Diesel Fuel Oil, Lube Oil and Air Start systems. Therefore, conformance with the intent of General Design Criteria 2, 4, 5 and 17 is not impacted. Likewise, compliance with Regulatory Guide 1.9 "Fuel Oil Systems for Standby Diesel Generators," and Regulatory Guide 1.137 as they apply to the design of diesel engine fuel oil systems, is not impacted.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance 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.

Serial No.11-669 Docket No. 50-336 Diesel Fuel Oil Test Program Attachment 1, Page 9 of 9

6.0 ENVIRONMENTAL CONSIDERATION

DNC has determined that the proposed amendment would change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR Part 20, or an inspection or surveillance requirement. DNC has evaluated the proposed change and has determined that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 PRECEDENTS

1. These proposed changes would modify the TS requirements related to diesel fuel oil testing consistent with NRC approved TSTF-374. The proposed changes would revise TSs by relocating references to specific ASTM standards for fuel oil testing to licensee-controlled documents and adding alternate criteria of "or a water and sediment content within limits" to the "clear and bright with proper color" acceptance test for new fuel oil. These changes were described in a Notice of Availability for Consolidated Line Item Improvement Process TSTF-374 published in the Federal Register on April 21, 2006 (71 FR 20735).

2. MPS2 diesel fuel oil testing program was previously implemented with Amendment No. 277, "Emergency Diesel Generator Testing Requirements," July 25, 2003 (ADAMS Accession No. ML031640541).

3. Waterford Unit 3, Amendment No. 216 to Modify Diesel Generator Fuel Oil Testing Surveillance Requirements (TAC MD5966), July 30, 2008 (ADAMS Accession No. ML081990457), regarding the description of the diesel fuel oil testing program.

4. Wolf Greek Generating Station, Amendment No. 101 to revise Technical Specification 3/4.8.1, "Electrical Power Systems - A.C. Sources," and associated Bases, dated August 9, 1996 (ADAMS Accession No. ML022040294), regarding the use of ASTM D1796-83.

Serial No.11-669 Docket No. 50-336 ATTACHMENT 2 LICENSE AMENDMENT REQUESTS REGARDING THE DIESEL FUEL OIL TEST PROGRAM TECHNICAL SPECIFICATION CURRENT TECHNICAL SPECIFICATIONS MPS2 MARKED-UP PAGE DOMINION NUCLEAR CONNECTICUT, INC.

• MILLSTONE POWER STATION UNIT 2

Serial No.11-669 Docket No. 50-336 Attachment 2, Page 1 of 2 CURRENT TECHNICAL SPECIFICATIONS MPS2 MARKED-UP PAGE The attached markups reflect the currently issued revision of the Technical Specifications (TS) listed below. Pending TS or TS changes issued subsequent to this submittal are not reflected in the enclosed markup.

The following TS are included in the attached marked-up page:

TS Title Page(s) 6-24 DIESEL FUEL OIL TEST PROGRAM ....................... 6-29

ADMINISTRATIVE CONTROLS 6.24 DIESEL FUEL OIL TEST PROGRAM 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 3k _, ..

,A clear and bright appearance with proper

3. ....... ............ . 6. color or a water and sediment content within limits.

b. Within 31 days following addition of the new fuel oil to 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 is _<10 mg/l when tested every 92 days in a...r.dan.. wih ASTM B 2276 78, Moth* d A.

The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Diesel Fuel Oil Test Program test frequencies.

6.25 PRE-STRESSED CONCRETE CONTAINMENT TENDON SURVEILLANCE PROGRAM This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measurements prior to initial operations.

The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 3, 1989.

The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Tendon Surveillance Program inspection frequencies.

Any abnormal degradation of the containment structure detected during the tests required by the Pre-stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken. This Tendon Surveillance Report is an administrative requirement listed in Technical Specifications 6.9.2, "Special Reports."

MILLSTONE - UNIT 2 6-29 Amendment No.2-7-7, 2- [7-

Serial No.11-669 Docket No. 50-336 ATTACHMENT 3 LICENSE AMENDMENT REQUESTS REGARDING THE DIESEL FUEL OIL TEST PROGRAM TECHNICAL SPECIFICATION MARKED-UP MPS2 BASES PAGES FOR INFORMATION ONLY DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

LBDCR 07-NtF2-009 March 29, 200-7 3/4.8 ELECTRICAL POWER SYSTEMS BASES Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176 or a water and sediment content within -

Slimits when tested in accordance with ASTM D2709 or R 4.8.1.1.2.b.2 ID1796.

This surveillance requires testing of the new and stored fuel oil in accordance with the Diesel Fuel Oil Testing Program, as defined in Section 6 of the Technical Specifications.

The tests listed below 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. 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. 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 receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows (more restrictive State of Connecticut and/or equipment limits may apply):

a. Sample the new fuel oil in accordance with ASTM D4057,

b. Verify in accordance with the tests specified in ASTM D975-81 that the sample has an absolute specific gravity at 60/60'F of > 0.83 and < 0.89, or an API gravity at 60'F of> 270 and < 390, a kinematic viscosity at 40'C of_> 1.9 centistokes and <

4.1 centistokes (alternatively, Saybolt viscosity, SUS at 100°F of_> 32.6 but *40.1) and a flash point > 125°F, and C. Vrif.. that the n. w fu..l oil has w.t. r an.d s.dim-ent

• 0.05%; when tested in. <

a...r.dane with ASTM D1796 83.

Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-81 are met for new fuel oil when tested in accordance with ASTM D975-81, except that the analysis for sulfur may be performed in accordance with ASTM D1552 or ASTM D2622. The 31 day period is acceptable because the fuel oil properties of interest, even if they were 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 diesel generators.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure. Particulate concentrations should be determined in accordance with ASTM D2276-78, Method A, every 92 days. This method involves a gravimetric MILLSTONE - UNIT 2 B 3/4 8-7 Amendment No. 2-7-7-