ML17326B516
| ML17326B516 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/24/1989 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC-0896I, AEP:NRC-896I, TAC-64515, TAC-64516, NUDOCS 8901310287 | |
| Download: ML17326B516 (13) | |
Text
r ACCELERATED DIS%IBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8901310287 DOC.DATE: 89/01/24 NOTARIZED: NO DOCKET. N FACIL:50-315 Donald C.
Cook Nuclear Power Pla'nt, Unit 1, Indiana 05000315 50-316 Donald C.
Cook Nuclear Power Plant,'Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.ED Office of Nuclear Reactor Regulation, Director (Post 870411
SUBJECT:
Forwards addi info on design of cleaning of diesel generator fuel oil storage tank.
DISTRIBUTION CODE:
AOOID COPIES RECEIVED:LTR+ENCL + SIZE:
TXTLE: OR Submittal:
General Distribution NOTES RECIPIENT ID CODE/NAME PD3-1 LA STANG,J XNTERNAL: ARM/DAF/LFMB NRR/DEST/CEB 8H NRR/DEST/MTB 9H NRR/DEST/SICB QUAHOG~
CT G FXLE EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
0 1
1 1
0 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DEST/ADS 7E NRR/DEST/ESB 8D NRR/DEST/RSB 8E NRR/DOEA/TSB 11 OGC/HDS1 RES/DSIR/EIB NRC PDR COPIES LTTR ENCL 2
2 1
1 1
1 1
1 1
1 1
0
'1 1
1 1
A NOTE IO ALL "RIDS" R1KIPIEGS:
PIZASE HELP US IO RZXRICE WASTF~.
COÃIACT IHE DOCUMEPZ CONTROL DESKS RQCN Pl-37 (EXT. 20079)
IO ELIKCNATE YOUR NAME FROM DISTRZKITIGN IZSTS FOR DOCUKWZS YOU DGN~T NEEDf A
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL 16
Indiana michigan Power Company P.O. Box 16631 Columbus, OH 43216 Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 INFORMATION ON CLEANING THE DIESEL GENERATOR FUEL.OIL STORAGE TANK AEP:NRC:0896I Tac Nos.
64515 and 64516 U.
S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Attn:
T.
E. Murley January 24, 1989
Dear Dr. Murley:
In AEP:NRC:0896H dated November 25,
- 1987, we submitted changes to our Technical Specifications (T/Ss) to address concerns with diesel generator fuel oil chemistry.
Included among the proposed changes was a requirement to clean the fuel oil storage tanks at least once every ten years.
When the proposed changes were submitted, the design of our tank cleaning system had not yet been finalized and we were therefore unable to provide some of the information requested by your staff.
As a result, our submittal included a commitment to submit the requested information once the final design of the cleaning system had been developed.
Attachment 1 to this letter provides the requested information.
Specifically, the attachment includes information on our proposed cleaning methods, the acceptance criteria for determining what constitutes a clean
- tank, a schedule for cleaning the tanks, and details on the leak detection test proposed as an alternative to pressure testing the tanks.
Attachment 2 contains an Edison Electric Institute document that describes one possible leak detection test that may be employed in testing our tanks.
This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M. P. Al xich Vice President ldp Attachments S5'013102S7 S9'0124 PDR AGOCK 05000315 P
PDC O0 i(l
Dr. Murley AEP:NRC:0896I cc:
D. H. Williams, Jr.
W.
G. Smith, Jr.
- Bridgman G. Bruchmann R.
C. Callen A. B. Davis NRC Resident Inspector
- Bridgman
Attachment 1 to AEP:NRC:0896I Information on Design of Cleaning System, Clean Tank Acceptance Criteria, Schedule for Cleaning, and Details of Leak Detection Test
~
~
Attachment 1 to AEP:NRC:08961 Page 1
Introduction This attachment includes a description of our cleaning methods, the acceptance criteria for determining what constitutes a clean
- tank, a schedule for cleaning the tanks, and details of the leak detection test.
Descri tion of Cleanin Methods and Acce tance Criteria Section 4.8.1.1.2.f.l of our proposed Technical Specifications (T/Ss) requires that we either (1) drain each storage
- tank, remove accumulated
- sediment, and clean the tank, or (2) agitate the fuel oil in the tank while pumping the oil from the bottom of the tank through a 5-micron filter and back into the tank.
- 1. Drainin and Cleanin
==
- a. Description:==
The tanks will be emptied of fuel oil and the tank interior will be mechanically cleaned, most likely by hydrolasing (water blasting).
To preclude the introduction of surfactants into the fuel system, no soap or detergent will be used in the cleaning process.
- b. Acceptance Criteria:
Tank cleanliness will be a clean dry interior as determined by visual examination.
2.
A itation - Filtration
==
- a. Description:==
The oil will be agitated by bubbling nitrogen gas into the oil while a minimum of five tank volumes of oil is circulated through a five-micron nominal rated filter.
Circulation of the oil will provide additional agitation.
- b. Acceptance Criteria:
Following the circulation of five tank volumes, three successive samples of fuel from the tank will be analyzed according to ASTM D2276-83.
These samples will be spaced over at least an additional one-half tank volume to ensure that we collect three separate and independent samples.
All samples must indicate a total contaminant level of less than ten mg per liter. If any of the three samples indicate greater than ten mg per liter, the oil will be recirculated through the filter until three successive samples indicate less than ten mg per liter.
Cleanin Schedule We anticipate conducting the first cleaning of our diesel generator fuel storage tanks in the Spring of 1989.
Cleaning of
Attachment 1 to AEP:NRC:0896I Page 2
the tanks will be done at least once per 10 years thereafter.
Details of Leak Detection Test Section 4.8.1.1.2.f.2 of the proposed T/Ss requires that we perform a precision leak detection test to verify that the leakage rate from the fuel oil system is less than or equal to 0.05 gallons per hour.
This procedure may be performed by a vendor and will follow a method giving the required accuracy.
A possible procedure is described in an Edison Electric Institute document entitled "Integrity Tests and Leak Detection for Underground Storage Tanks."
Applicable sections of this document are included as Attachment 2 to this letter.
~ ~
Attachment 2 to AEP:NRC:0896I Edison Electric Institute Document Describing Our Leak Detection Method
EDISON ELECTRIC INSTITUTE NTEGR TY TESTS AND LEAK DETECT ON FOR UNDERIRDUND Submitted by:
Performance Standards/Criteria Task Force of the Underground Storage Tank Committee UtilitySolid Waste Activities Group Prepared by RADIAN CORPORATION
Bo8 ~ (18,31,32)
This method operators on the Archimedes Prlnclple of Buoyancy which states "the apparent loss tn weight of any obJect submerged In a I lquld ls equal to the weight of the dlsp I aced volume of the I IquldP
The Leak Lokator consists of a hol low cyl lnder which ls sealed at the bottom, an anal ytlcal ba I ance (weighing scale),
electronic transmitting circuitry, and a strip chart recorder.
A sensor, suspended from the analy-t tca I ba I ance>
ls placed ln the tank I lqu fd.
The weight of the sensor is equal to its actual weight minus the buoyancy force from the I fquld In the tank.
Any change ln I lquld level wl I I change the buoyancy force on the sensor
- and, hence, the weight of the sensor.
The weight change ls monitored by the analytical balance which electronlcal ly transmits a "signal" to the recorder.
The chart recorder graph.ical ly shows volume changes versus time.
The angle and length of the I Inc drawn by the recorder ls directly correlated to the quantity and rate of leakage.
The chart recorder notes the lapsed time in minutes versus volume change ln cubic centimeters of the product displaced either Into or out of the tank.
A vertical I lne shows no change ln volume, while I ines with posi-tivee or negative slopes indicate decrease and increase, respectively, ln the product volume.
The system Is cal lbrated at least six times during each test.
This fs performed by quickly adding or removing a cal lbratlon rod of precisely known volume to a system being tested.
The typical time for equipment setup and temperature adJustment ls 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
A complete testing on one tank can usual ly be performed ln 3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and on four tanks ln 8 to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
After the equipment fs set up, the test to determine a volume change typical ly takes less than one hour.
This time wl I I increase to at least two hours for fn-tank testing.
The least sen-sltlvlty occurs when the product level Is near the center I ine of the tank.
However, even at this.level, volume changes of 0.05 gal lon per hour reported-ly can be detected by adJustlng test time and the electronic signal
~
The greatest sensitivity for detecting a smal I
leak ls achieved lf the testing ls conducted with the I lquld In a riser above grade.
Hunter Environmental Ser v lees offers nationwide testing serv lees on a one-tIme or retainer contractual basis.
Testers go through an In-house
J
tralnlng program.
The company has tested we I I over 25,000 tanks.
C I lents have Included ten major oil companies and numerous large corporations.
A wide variety of products have been tested, Including chlorinated solvents>
afcohol s, and acetone.
In the Leak Lokator~ testing, the accuracy may be affected due to the fo I lowing reasons (18):
d Ifferences between measured apparent tempera-ture change and actual average temperature change; leak rate change due to the water table effect; tank end deflection, lf ft ls unldentifled; vapor pockets; occurrence of wave due to wind and vlbratlon; differences between theoretical tank volume and actual tank volume; power varlatlons due to the use of 110V AC power source; and In some cases, the f 11 1 pipe ls at such an angle from vertical that the sensor cannot be Installed ln the tank without touching the wal I ~
B-12