ML17352A727
| ML17352A727 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/19/1994 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17352A728 | List: |
| References | |
| L-94-144, NUDOCS 9407210328 | |
| Download: ML17352A727 (24) | |
Text
'
P'R.ICBM.I JL Y (ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9407210328 DOC.DATE: 94/07/19 NOTARIZED: YES DOCKET g FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to Licenses DPR-31 & DPR-4l,revising DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR TITLE: OR Submittal: General Distribution NOTES:
l TS 4.8.1.1.2e 6 4.8.1.1.2f re EDG fuel oil testing program.
ENCL I SIZE: l +F RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 CROTEAU,R 2 2 INTERNAL: NRR/DE/EELB 1 1 NRR/DORS/ONDD 1 . 1 NRR/DRCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 0 OGC/HDS3 1
1 0 0 -8 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS I OR DOCUMENTS YOU DON "I'EED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 14
JUL 19 1994 L-94-144 10 CFR 550.36 10 CFR 550.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments, Diesel Fuel Oil Testin Pro ram In accordance with Title 10 Code of Federal Regulations 550.90 (10 CFR 550.90), Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to revise Turkey Point Units 3 and 4 Technical Specifications (TS) 4 '.1.1.2e. and 4.8.1.1.2f., which address Emergency Diesel Generator (EDG) fuel oil testing. In addition, FPL proposes the addition of ACTION statements g. and h., to TS 3.8.1.1., to address the requized action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits. FPL proposes to amend the EDG fuel oil Surveillance Requirements by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to verify new and stored EDG fuel oil in accordance with the Diesel Fuel Oil Testing Program. The Diesel Fuel Oil Testing Program will be described in the BASES to the Technical Specifications.
FPL believes that this proposed amendment is consistent with the Executive Order to reduce regulatory burden.
FPL has determined that the proposed license amendments do not involve a significant hazards consideration pursuant to 10 CFR 550.92. A description of the amendment request is provided in Attachment 1. The no significant hazards determination in support of the proposed Technical Specifications changes is provided in Attachment 2. provides the proposed revised Technical Specifications changes.
In accordance with 10 CFR 550.91(b)(1), a copy of these proposed license amendments is being forwarded to the State Designee foz the state of Florida.
The proposed amendments have been approved by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.
Should there be any questions on this request, please contact us.
Very truly yours, T.F. Plunkett Vice Pzesident Turkey Point Plant r'"<
r,-i. ~'.I'%
9407210328 940719 PDR ADOCK 05000250 PDR an FPL Group company
L-94-144 Page 2 TFP/EJW/RJT Attachments CC: S. D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services
STATE OF FLORIDA )
) ss.
COUNTY OF DADE )
T. F. Plunkett being first duly sworn, deposes and says:
That he is Vice President, Turkey Point Nuclear Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
T. F. Plunkett Subscribed and sworn to before me this 5 day of 1994.
Name of Notary Public (Type or Print)
NOTARY PUBLIC, in and for the Count of Da e ate of Florida CNERYL A. KELLY My Commission expires /4 %.'Y I COMMISQOII CC 223781 Commission No. EXPIRES: September 27, 1998 8;t~ikns&lw Notery pubao Urdastbere T. F. Plunkett is personal y known to me.
1 C A 8 V ~
> W, +
ATTACHMENT 1 DESCRIPTION OF AMENDMENTS REQUEST
L-94-144 Page 1 of 5 DESCRIPTION OF AMENDMENTS RE VEST Introduction Florida Power and Light Company (FPL) proposes to amend Turkey Point Units 3 and 4 Technical Specifications (TS) 4.8.1.1.2e. and 4.8.1.1.2f., which address Emergency Diesel Generator (EDG) fuel oil testing, by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to verify new and stored EDG fuel oil in accordance with the Diesel Fuel Oil Testing Program. In addition, FPL proposes the addition of ACTION statements g. and h., to TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits.
The Diesel Fuel Oil Testing Program will be described in the BASES to the Technical Specifications.
The proposed amendments will improve flexibility in accomplishing the Surveillance Requirements, This flexibility is required, for example, as a result of recent difficulties encountered in obtaining laboratory analyses as required by the TS, in that the specific testing standard has become out-dated and generally fallen into disuse. While these difficulties can, and have been, overcome in the short tezm, the continued requirement to meet out-dated standards is economically expensive and provides no safety benefit in the case of contemporary testing methods.
Discussion American Society for Testing and Materials (ASTM) standards represent a common viewpoint of parties concerned with the provisions of the particular testing standard. A new volume of the Annual Book of ASTM Standards is published annually because of additions of new standards and revisions in existing standards.
Certain ASTM standards are listed in the Turkey Point Units 3 and 4 Technical Specifications as the specific tests required to be performed on Emergency Diesel Generator fuel oil. The ASTM standards specified in the TS are:
ASTM-D4057: defines method for obtaining a composite sample of new fuel oil prior to addition of new fuel oil to the diesel oil storage tanks.
ASTM-D975-81: defines and identifies testing to be performed on the new fuel oil.
ASTM-D1298-80: defines the testing methodology to be used on the new fuel oil prior to addition of the new fuel oil to the diesel fuel oil storage tanks to determine the acceptability of the fuel oil's specific gravity.
ASTM-D4176-82: defines the testing methodology to be used on the
L-94-144 Page 2 of 5 new fuel oil prior to addition of the new fuel oil to the diesel fuel oil storage tanks to determine the new fuel oil' clear and bright appearance with proper color.
ASTM-D1552-79: identifies one of two acceptable methods to be performed to analyze for sulfur in the fuel oil.
ASTM-D2622-82: identifies one of two acceptable methods to be performed to analyze for sulfur in the fuel oil.
ASTM-D2276-78: defines the method to be used in obtaining a fuel oil sample at least once every 31 days from the diesel fuel oil storage tanks and analyzing for total particulate contamination.
FPL proposes to change Turkey Point Units 3 and 4 TS Surveillance Requirements 4.8.1.1.2e. and 4.8.1.1.2f., which address the EDG fuel oil testing requirements. FPL proposes to revise the Turkey Point Units 3 and 4 TS by replacing the specific EDG fuel oil Surveillance Requirements with the requirement to verify new and stored EDG fuel oil in accordance with the Diesel Fuel Oil Testing Program. The Diesel Fuel Oil Testing Program will be described in the BASES to the Technical Specifications. The Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria will be listed in the BASES for the TS, as well as in the plant procedures used to test the EDG fuel oil on initial receipt and periodically, as currently required.
FPL proposes the addition of ACTION statement g. of TS 3.8.1.1 to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits. A failure to meet the API gravity, kinematic viscosity, flash point or clarity limits is cause for rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks.
Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits. This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operation. The diesel fuel oil surveillance in accordance with the Diesel Fuel Oil Testing Program will ensure the availability of high quality fuel oil for the EDGs.
FPL proposes the addition of ACTION statement h. to TS 3.8.1.1, to address the required action in the event the stored fuel oil total particulates do not meet the Diesel Fuel Oil Testing Program limits.
At least once every 31 days, a sample of fuel oil is obtained from the storage tanks in accordance with ASTM-D2276-78. The particulate
L-94-144 Page 3 of 5 contamination is verified to be less than 10 mg/liter when checked in accordance with ASTM-D2276-78, Method A. It is acceptable to obtain a field sample foz subsequent laboratory testing in lieu of field testing. 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. The frequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Proposed ACTION statements g. and h. of TS 3.8.1.1, are identical in intent to the statements specified in TS 3.8.3 of NUREG-1431, Standard Technical Specifications Westinghouse Plants.
Changes to the Diesel Fuel Oil Testing Program will be accomplished pursuant to 10 CFR 550.59, "Changes, tests, and experiments." Title 10 CFR 550.59 permits a licensee, among other things, to make changes to the facility described in the safety analysis report or to make changes in procedures as described in the safety analysis report, without prior NRC approval, unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question. By deleting the specific reference in the TS of the testing standards being used to meet TS testing requirements, FPL could change an ASTM standard, or standard edition, without prior NRC approval, provided an unreviewed safety question did not exist.
An unreviewed safety question exists (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report may be created; or (iii) the margin of safety as defined in the basis for any technical if specification is reduced. FPL is required by 10 CFR 550.59(b)(1) to maintain records of any changes made pursuant to 10 CFR 550.59 and that the records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unzeviewed safety question.
Additionally, FPL is zequired to submit to the NRC periodically a report containing a brief description of any changes made pursuant to 10 CFR 550.59 as well as a summary of the safety evaluation of each change. As a result, the NRC will periodically be informed of changes that FPL may make to the Diesel Fuel Oil Testing Program.
Proposed Technical Specifications FPL proposes to add TS 3.8.1.1 ACTION statements g. and h., to read as follows (with the proposed new requirements in bold):
- g. With one or more diesel generators with new fuel oil
1 L-94-144 Page 4 of 5 properties outside the required Diesel Fuel Oil Testing Program limits, restoze the fuel oil properties to within the required limits within 30 days.
- h. With one or more diesel generators with stored fuel oil total particulates outside the required Diesel Fuel Oil Testing Program limits, restore the fuel oil total particulates to within the required limits within 7 days.
FPL proposes to revise TS Surveillance Requirements 4.8.1.1.2e. and 4.8.1.1 bold):
'f., to read as follows (with the proposed new requirements in 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE
- e. By verifying fuel oil properties of new fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
By verifying fuel oil properties of stored fuel oil aze tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
Additionally, FPL proposes to revise the BASES for Technical Specification 3/4.8.1 to address the Diesel Fuel Oil Testing Program's Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria for new and stored EDG fuel oil.
Bases of Proposed Changes ASTM standards represent a common viewpoint of parties concerned with the provisions of the particular testing standard. A new volume of the Annual Book of ASTM Standards is published once a year because of additions of new standards and revisions in existing standards. An ASTM standard is subject to revision at any time by the technical committee and must be reviewed every five years and, if either xe-approved or withdrawn. As a result, the most current not revised, version of a particular standard represents a consensus opinion with respect to the sufficiency of endorsed testing techniques.
A number of licensees, including Turkey Point Units 3 and 4, have submitted, in the recent past, Licensee Event Reports (LERs) to report situations in which the TS-identified fuel oil testing requirements were not being met because the offsite laboratory that performed the testing used a later revision of ASTM standards than were specified in the TS. While these methods are considered acceptable, from an industrial perspective, they do not meet the legal requirements of the TS.
The proposed changes are consistent with the programmatic controls present in NUREG-1431, Surveillance Requirement (SR) 3.8.3.3 which states:
L-94-144 Page 5 of 5 SURVEILLANCE FRE UENCY SR 3.8.3.3 Verify fuel oil properties of new In accordance and stored fuel oil are tested in with the Diesel accordance with, and maintained Fuel Oil Testing within the limits of, the Diesel Program Fuel Oil Testing Program.
In NUREG-1431, the tests, limits, and applicable ASTM standards are listed in the BASES. As a result, a licensee that has implemented NUREG-1431 can make changes to the ASTM standards or editions of the Diesel Fuel Oil Testing Program, pursuant to 10 CFR 550.59.
FPL proposes the addition of ACTION statements g. and h. of TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits. These proposed action statements are identical in intent to the statements specified in TS 3.8.3 of NUREG-1431, Standard Technical Specifications Westinghouse Plants.
The proposed amendments will impiove flexibility in accomplishing the required Surveillance Requirements. This flexibility is required as a result of recent difficulties encountered in obtaining laboratory analyses as required by the TS, in that the specific testing standard had become out-dated and generally falle'n into disuse. While these difficulties can, and have been, overcome in the short term, the continued requirement to meet out-dated standards is economically expensive and provides no safety benefit in the case of contemporary testing requirements.
Changes to the Diesel Fuel Oil Testing Program will be accomplished pursuant to 10 CFR 550.59, "Changes, tests, and experiments." Title 10 CFR 550.59 permits a licensee, among other things, to make changes in the facility described in the safety analysis report or to make changes in procedures as described in the safety analysis report, without prior NRC approval, unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question. By deleting the specific reference in the TS of the testing standard being used to meet TS testing requirements, FPL could change an ASTM standard, or standard edition, without prior NRC approval, provided an unreviewed safety question did not exist. The TS BASES will address the Diesel Fuel Oil Testing Program's Surveillance Requirements'eriodicity, ASTM testing standards, and acceptance criteria for new and stored EDG fuel oil.
ATTACHMENT 2 DETERMZNATZON OF NO SZGNZFZCANT HAZARDS CONSZDERATZON
L-94-144 Page 1 of 5 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of Proposed License Amendments Florida Power and Light Company (FPL) proposes to change Turkey Point Units 3 and 4 Technical Specification (TS) by revising Surveillance Requirements 4.8.1.1 2e. and 4.8.1.1.2f., to delete the specific
~
reference in the TS of the American Society for Testing and Materials (ASTM) testing standard being used to meet TS testing requirements.
FPL proposes to amend the Emergency Diesel Generator (EDG) fuel oil Surveillance Requirements by deleting the specific reference in the TS of the ASTM testing standards being used to meet TS testing requirements. The EDG fuel oil TS Surveillance Requirements will be replaced with a requirement to test the EDG fuel oil in accordance with the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program.
FPL pzoposes the addition of ACTION statements g. and h. of TS 3.8.1.1, to address the required action in the event the diesel fuel oil does not meet the Diesel Fuel Oil Testing Program limits.
Introduction The Nuclear Regulatory Commission has provided Standards for determining whether a significant hazards consideration exists (10 CFR 550.92 (c)). A proposed amendment to an operating license for a facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility 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 below for the proposed amendment.
Discussion (1) Operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generator (EDG) fuel oil in accordance with the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program. The proposed change will permit FPL to use more recent editions of the American Society for Testing and Materials (ASTM) standards currently listed in Technical Specification Surveillance Requirements 4.8.1.1.2e. and 4.8.1.1.2f. Prior to changing the Diesel Fuel Oil Testing Program, the proposed change will be evaluated pursuant to Title 10 Code of Federal Regulations 550.59 (10 CFR 550.59), "Changes, tests, and experiments." Title 10 CFR 550.59 permits a licensee to make changes in the procedures as
L-94-144 Page 2 of 5 described in the safety analysis report without prior Commission approval, provided that the proposed changes does not involve an unreviewed safety question.
Title 10 CFR 550.59(a)(2) states that a proposed change involves an unzeviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased. Consequently, since any change to the Diesel Fuel Oil Testing Program, including the ASTM standard or ASTM edition standard to be used to evaluate EDG fuel oil acceptability, the change must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then opezation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The EDG fuel oil TS Surveillance Requirements will be replaced with a requirement to test the EDG fuel oil in accordance with the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program.
ACTION statement g. of TS 3.8.1.1 is added to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits. A failure to meet the API gravity, kinematic viscosity, flash point or clarity limits is cause for rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not
'represent a failure to meet the Limiting Condition foz Operation (LCO) of TS 3.8 '.1, since the new fuel oil has not been added to the storage tanks. Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits. This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operation.
ACTION statement h. of TS 3.8.1.1 is added to address the required action in the event the stored fuel oil total particulates does not meet the Diesel Fuel Oil Testing Program limits. 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 frequency for performing surveillance on stored fuel oil is. based on stored fuel oil degradation trends which indicate that pazticulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program, FPL will need to determine if the proposed
4 E 1 L-94-144 Page 3 of 5 program change is at least as, if not more, effective, in detecting unsatisfactory fuel oil. The EDGs will thus continue to function as designed and the probability or consequences of previously evaluated accidents will be unaffected.
(2) Operation of the facility in accordance with the proposed amendments would not create, the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generator fuel oil using more recent editions of the American Society for Testing and Materials standards listed in Technical Specification Surveillance Requirements 4.8.1.1.2e. and 4 '.1 1.2f. Prior to changing the edition of the previously approved ASTM standard being used to evaluate the EDG fuel oil,
~
the proposed edition standard will be evaluated pursuant to 10 CFR 550.59, "Changes, tests, and experiments." Title 10 CFR 550.59 permits a licensee to make changes in the procedures as described in the safety analysis report without prior Commission approval, provided that the proposed changes does not involve an unreviewed safety question. Title 10 CFR 550.59(a)(2) states that a proposed change involves an unreviewed safety question if (ii) a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created. Consequently, since any change to the edition of the ASTM standard to be used to evaluate EDG fuel oil acceptability must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previousl'y evaluated.
ACTION statement g. of TS 3.8.1.1 is added to address the required action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits. A failure to meet the API gravity, kinematic viscosity, flash point or clarity limits is cause foz rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not represent a failure to meet the Limiting Condition for Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks. Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits. This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operation.
ll
~ IP g
L-94-144 Page 4 of C 5
ACTION statement h. of TS 3.8.1.1 is added to address the required action in the event the stored fuel oil total particulates does not meet the Diesel Fuel Oil Testing Program limits. 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 frequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program, FPL will need to determine program change is at least as, if if the proposed not more, effective, in detecting unsatisfactory fuel oil. Since the proposed changes do not involve a change in the design of any plant system or component, and since the proposed changes will need to evaluate the effect of any ASTM standard edition change on the level of EDG reliability, the change proposed will not create the possibility of a new or diffezent kind of accident from any accident previously evaluated.
(3) Operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
The proposed changes to the Technical Specifications will permit the Technical Specification required testing of Emergency Diesel Generator (EDG) fuel oil using more recent editions of the American Society for Testing and Materials (ASTM) standards listed in Technical Specification Surveillance Requirements 4.8.1.1.2e. and 4.8.1.1.2f. Prior to changing the edition of the previously approved ASTM standard being used to evaluate the EDG fuel oil, the proposed edition standard will be evaluated pursuant to 10 CFR 550.59, "Changes, tests, and experiments."
Title 10 CFR 550.59 permits a licensee to make changes in the procedures as described in the safety analysis report without prior Commission approval, provided that the proposed changes does not involve an unreviewed safety question. Title 10 CFR 550.59(a)(2) states that a proposed change involves an unzeviewed safety question (iii) if the margin of safety as defined in the basis for any technical specification is reduced. Consequently, since any change to the edition of the ASTM standard to be used to evaluate EDG fuel oil acceptability must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
ACTION statement g. of TS 3.8.1.1 is added to address the zequired action in the event the new fuel oil properties do not meet the Diesel Fuel Oil Testing Program limits. A failure to meet the API gravity, kinematic viscosity, flash point or clarity
L-94-144 Page 5 of 5 limits is cause foz rejecting the new fuel oil prior to the addition to the Diesel Fuel Oil Storage Tanks, but does not represent a failure to meet the Limiting Condition foz Operation (LCO) of TS 3.8.1.1, since the new fuel oil has not been added to the storage tanks. Provided these new fuel oil properties are met subsequent to the addition of the new fuel oil to the storage tanks, 30 days is provided to complete the analyses of the other fuel oil properties specified in Table 1 of ASTM-D975-81, except sulfur which may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. In the event the other new fuel oil properties specified in Table 1 of ASTM-D975-81 are not met, ACTION statement g. of TS 3.8.1.1 provides an additional 30 days to meet the Diesel Fuel Oil Testing Program limits. This additional 30 day period is acceptable because the fuel oil properties of interest, even if they are not within limits, would not have an immediate effect on EDG operation.
ACTION statement h. of TS 3.8 1.1 is added to address the required action in the event the stored fuel oil total
~
particulates does not meet the Diesel Fuel Oil Testing Program limits. 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 frequency for performing surveillance on stored fuel oil is based on stored fuel oil degradation trends which indicate that particulate concentration is unlikely to change significantly between surveillances.
Prior to changing the Turkey Point Units 3 and 4 Diesel Fuel Oil Testing Program, FPL will need to determine if the proposed program change is at least as, if not more, effective, in detecting unsatisfactory fuel oil. Since the proposed changes will require a safety evaluation to assure that the reliability of the EDGs using fuel oil tested in accordance with the different ASTM standard edition maintains the current margin of safety, the proposed changes do not involve a reduction in a margin of safety.
Summary Based on the above discussion, FPL has determined that the proposed amendment request does not (1) involve a significant increase in the probability or consequences of an accident'reviously evaluated; (2) create the possibility 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 the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 550.92.