ML17219A265

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Proposed Tech Spec Pages 8-3,8-3a,8-3b,8-4 & 8-6,revising Emergency Diesel Generator Fuel Oil Surveillance Requirements
ML17219A265
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 12/12/1986
From:
FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17219A264 List:
References
NUDOCS 8612160334
Download: ML17219A265 (15)


Text

ATTACHMENT I Marked-up Technical Specification Pages:

3/4 3/4 3/4 3/4 3/4 8-3 8-3a (new) 8-3b (new) 8-4 8-6 p

DR ADCI0g 050003

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EJW2/OQ5/3

ELECTRICAL POWER SYSTEM SURVEILLANCE REOUIREMENTS Continued) 4.8. 1. 1.2 Each diesel generator shall be demonstrated OPERABLE:

a ~

In accordance with the frequency specified in Table 4.8-1 on a STAGGEREO TEST BASIS by:

1.

Verifying the fuel level in the engine-mounted fuel tank, 2.

Verifying the fuel level in the fuel storage

tank, 3.

Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted

tank, 4.

Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm in less than or equal to 10 seconds.

The generator vo1tage and frequency shall be

- 4160

+ 420 volts and 60 ~ 1.2 Hz within 10 seconds after the start signal.

The diesel generator shall be started for this test by using one of the following signals:

a) b)

c)

Manual.

Simulated loss-of-offsite power by itself.

Simulated loss-of"offsite power in conjunction with an ESF actuation test signal.

An ESF actuation test signal by itself.

5.

Verifying the generator is synchronized, loaded to greater than or equal to 3685 kW in less than or equal to 60 seconds, and operates with a load greater than or equal to 3685 kW for at least an additional 60 minutes, and 6.

Verifying the diesel generator is aligned to provide standby power to tne associated emer enc busses.

At least once per 31 days and after each operation of the di ere the period of operation was greater than or equal hour by chec for and removing accumulated water from t ngine-mounted fuel tanks.

At least once per 92 and from uel prior to addition'o the

'torage

tanks, by obtaining e of fuel oil in accordance with ASTM-0270-1975, and by ver 1ng the sample meets the fol'lowing minimum requirements is tested wit 'e specified time limits:

1.

As soo s sample is taken or prior to adding 'uel to the ge.tank verify in accordance with the test'p

'ed in STM-0975-77 that the sample has:

3/4 8-3

ELECTRICALePOWER SYSTEHS C

SURVEILLANCE REOUIREHENTS (Conti nued) b.

By removing accumulated water:

ca ys'ac

~ mou~kd Qc/

1)

From the 4ay~tank at least once per 31 days and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 2)

From the storage tank at least once per 31 days.

c.

By sampling new fuel oil in accordance with ASTI 04057-81 prior to addition to the storage tanks and:

1)

By verifying in accordance with the tests specified in ASTI 0975-81 prior to addition to the storage tanks that the sample has:

a)

An API Gravity of within 0.3 degrees at 60'F or a specific gravity of within 0.0016 at 60/60'F, when compared to the supplier's certificate or an absolute specific gravity at 60/60'F of greater than or equal to P.83 but less than or equal to 0.89 or an API gravity at 60'F of greater than or equal to 27 degrees but less than or equal to 39 degrees.

b)

A kinematic viscosity at 40'C of greater than or equal to 1.9 centistokes.

but less than or equal to 4.1 centistokes, if gravity was not determined by comparison with the supplier's certification, c)'

flash 'point equal to or greater than 125'F, and I

L d)

A clear and bright appearance with proper color when tested in accordance with AS'4176-82.

2)

By verifying within 31 days of obtaining the sample that the other properties specified in Table 1 of AS'975-81 are met when tested in accordance with ASTI 0975-81 except that the analysis

&l~e-b.~~~

3/4 8-3a

ELECTR?CALKPOMER SYSTEMS SURVEILLANCE REQUlREMEHTS (Continued )

for sulfur may be performed in accordance with ASTM 01552-79 or ASTM 02622-82.

d.

At least once every 31 days by obtaining a sample of fuel oil from the storage tanks in accordance with ASTM 02276-78, and verifying that tota'. particulate contamination is less than 10 mg/liter when checked in accordance with ASTM 02276-78, Method A>o> APPA4+ A L 3/4 8-3b

I

ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIR MENTS (Continued) b)

c)

A water and sediment content of less or equal to 0.05 volume percent.

A 'matic viscosity 8 40 C of greate~

than equal to 1.9 ce

'stokes, but less than or equal

4. 1 centistokes.

A specific vity as specified by e manufacturer 9 60/604F of gr er than or e

to 0.8 but less than or equal to 0.99 or API vity 8 60 F of greater than or equal to ll degrees less than or equal to 47 degrees.

2.

Within 1 week after ob

>ning the s

le, verify an impurity level'of less than mg of insolubles p

100 ml when tested in accor dance

'STM-02274-70.

3.

Within eeks of obtaining the sample verify tha he other pro ties specified in Table 1 of ASTM-0975-77 and R

latory

>de 1. 137 Position Z.a are met when tested in accordanc ith ASTN-0975-77.

At least once per 12 months by verifying that the automatic load sequence timers are OPERABLE with the interval between each load block within + 1 second of its design interval.

At least once per 18 months during shutdown by:

A 1.

Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service.

2.

Verifying the generator capability to reject a load of greater than or equal to 453 kW while maintaining voltage at 4160

+

420 vol ts and frequency at 60.+ l. 2 Hz.

3.

Verifying the generator capability to reject a load of 3685 kW without tripping.

The generator voltage shall not exceed 4784 volts during and following the load rejection.

Simulating a loss-of-offsite power, by itself, and:

a)

Verifying deenergization of the emergency busses and load shedding from the emergency busses.

b)

Verifying the diesel star ts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto"connected shut-down loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads.

After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 a 420 volts and 60 + 1.2 Hz

~

during this test.

ST.

LUCIE - UNIT 2 3/4 8-4

ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREMENTS Continued 8.

Verifying that the auto-connected loads to each diesel generator do not exceed the 2000-hour rating of 3985 kW.

9.

b) c)

Verifying the diesel generator's capability to:

a)

Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a

simulated restoration of offsite power, s

Transfer its loads to the offsite power source, and Be restored to its standby status.

10.

Verifying that with the diesel generator operating in a test mode (connected to its bus),

a simulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.

ll.

Verifying that the fuel transfer pump transfers fuel from each fuel storage tank to the engine-mounted tanks of each diesel via the installed cross connection lines.

At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 900 rpm in less than or equal to 10 seconds.

At least once per 10 years by:

l.

Oraining each fuel oil storage

tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite
solution, and 2.

Per'forming a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection NO of the ASME Code at a test pressure equal to 110Ã of the system design pressure.

ST.

LUCIE - UNIT 2 3/4 8-6

c

ATTACHMENT2 SAFETY EVALUATION Introduction The proposed amendment would change the surveillance requirements for emergency diesel generator fuel in the St. Lucie Unit 2 Technical Specifications.

The proposed change involves replacing fuel oil tests currently required by the Technical Specifications with tests which are:

(I) more effective in detecting unsatisfactory fuel oil and (2) simpler and less expensive to perform.

Discussion The intent of the proposed surveillance requirements is discussed below:

(a)

Receipts of new fuel should be tested prior to addition to the storage tanks to detect contamination which could occur after leaving the refinery.

Fuel leaving the refinery is generally good quality and must meet ASTM standards;

however, as a second-check, the proposed Technical Specifications would require verifying ASTM D975-8I is met for new fuel. To ensure that all likely sources of contamination are detected, some different tests are proposed.

(b)

Fuels in storage should be tested periodically to detect degradation..Only those parameters which can change during storage need to be tested.

(c)

Periodic testing for particulates formed in storage should concentrate on the actual particulate contamination.

The accelerated oxidation stability test TASTM D2274-70) is currently required to be'Performed for new fuel and every 92 days for stored fuel.

This test provides a rough prediction of the tendency of the fuel to oxidize and form particulates during storage.

It does not indicate actual particulate contamination.

In addition, ASTM D975-8l states "Correlations (of Method D2274 results) with fuel suitability are tenuous."

Finally, the ASTM D2274-70 test involves significant cost and a significant administrative burden.

The test must be performed by an outside laboratory because facilities are not available to perform the test on site and it is considered a'significant fire hazard to personnel.

(The test involves bubbling pure oxygen for several hours through a filtered fuel oil sample heated to 203 F - significantly greater than the flash point.)

ln lieu of the accelerated oxidation stability test, a test for actual particulate contamination, ASTM D2276-78, is proposed.

This test would be performed every 3I days for fuel in storage - more frequently than the current test frequency for the accelerated oxidation stability test.

Since'formation of particulates during storage at ambient temperatures is a relatively slow

process, the 3 I -day test frequency will ensure early detection of particulates.

This test need not be performed on new fuel receipts because the Clear and Bright test (ASTM D4I76-82) detects particulates in new fuel.

The ASTM D2276-78 test is a relatively simple test which can be performed on site.

(d)

Technical Specification 4.8.I.I.2.b currently requires removing accumulated water periodically from the engine-mounted fuel tanks.

We propose to extend this requirement to include the storage tanks.

EJ W2/005/4

t E

The following is a summary of the specific changes proposed.

(a)

Extend T.S. 4.8.l.l.2.b to require periodic water removal from the storage tanks.

(b)

Replace the Water and Sediment test (by centrifuge) with the Clear and Bright test (ASTM D4 l76-82).

(c)

Add a flash point test for new fuel.

,(d)

Add an option to verify fuel gravity by testing and comparing it with supplier's certification.

The viscosity test would be required only if gravity was determined without"comparison to a supplier s certification.

(e)

Extend the time limit for obtaining ASTM D975-8l test results from l4 days to 3I days.

(f)

Delete the requirement to perform ASTM D975-77 testing every 92 days for fuel in storage.

This includes water and sediment, viscosity, and gravity.

(g)

Substitute ASTM D2276-78 performed every 3l days to detect particulate contamination in lieu of ASTM D2274-70, accelerated oxidation stability test, performed every 92 days and on new fuel.

(h)

Allow sulfur analysis (ASTM D975-8I) to be performed in accordance with ASTM D I 552-79 or ASTM D2622-82.

(i)

Update the Technical Specifications to use current ASTM standards specifically, ASTM D4057-8I instead of ASTM D270-l 975.

Also, reference the l98l version of ASTM D975.

When considering the relative safety impact of these proposed fuel oil surveillance requirements, it should be noted that severe degradation of the fuel which could affect engine performance would be detectable during the periodic tests on the engine which are performed at least once per 3l days.

For example, particulate contamination severe enough to plug the filters in a short time would be detected.

Florida Power and Light believes that the proposed amendments would establish surveillance requirements which are effective in ensuring the quality of the diesel fuel while being less expensive and less burdensome.

EJW2/005/5

ATTACHMENT3 DETERMINATIONOF NO SIGNIFICANTHAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulations, 10 CFR.50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (I) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possiblity of a new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety.

Each standard is discussed as follows:

(I)

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated in that the proposed change involves replacing fuel oil tests currently required by Technical Specifications with Technical Specification Surveillance Requirements which are more effective in detecting unsatisfactory fuel oil and are simpler to perform.

(2)

Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendments would replace fuel oil tests currently required by the Technical Specifications with different tests which are more effective for ensuring quality fuel oil. These changes are:

(a)

The proposed testing requirements would improve the capability to detect delivery of diesel fuel contaminated with gasoline or jet fuel (JP-4) by adding a test for flash point.

(b)

The proposed Clear and Bright test is more sensitive for detecting water and sediment than the test which is currently required.

(c)

The accelerated oxidation stability test which predicts the tendency of the fuel to form particulates during storage would be replaced by a different test performed more frequently which measures actual particulates in the fuel.

(d)

Because proposed tests for incoming fuel shipments will ensure its quality, periodic testing would only be required for the parameters which can change during storage.

Thus, certain test requirements would be deleted.

(e)

Because of the high degree of protection obtained by the tests on incoming fuel prior to addition to the storage

tanks, the proposed relaxation of the time limit for complete fuel specification testing from l4 days to 3I days is insignificant.

EJ W2/005/6

(f)

Since comparative gravity, as proposed, can detect contamination by jet fuel (Jet A) and other types of contamination are detected by tests other than viscosity, viscosity testing is not required if gravity is determined using this method.

(g)

Under the proposed amendments, analysis for sulfur using any one of three generally accepted methods would be allowed.

(h)

Administrative changes would be made to reference up-to-date industry standards.

(i)

The requirement to periodically remove accumulated water from the day tanks would be extended to include the storage tanks.

(3)

Use of the modified specification would not involve a significant reduction in a margin of safety.

With one exception, the changes described involve either adding surveillance tests or replacing tests with others which are at least as effective.

The exception (item (d) above) involves deleting tests which are not meaningful because the parameters tested do not change during storage.

Thus, the net effect of the proposed changes would be to increase safety by establishing surveillance requirements which would be more effective for ensuring quality fuel oil.

Based on the above, we have determined that the amendment request does not (I) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the probability of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

EJW2/005/7

e