ML17352A828

Proposed Tech Specs 4.8.1.1.2e & 4.8.1.1.2f,addressing EDG Fuel Oil Testing & TS 3.8.1.1,addressing Required Action in Event Diesel Fuel Oil Does Not Meet Diesel Fuel Oil Testing Program Limits

ML17352A828
Person / Time
Site:	Turkey Point
Issue date:	10/20/1994
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17352A827	List: ML17352A826 ML17352A828
References
NUDOCS 9410260300
Download: ML17352A828 (23)

Text

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1 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS Marked-up Technical Specification Pages:

3/4 8-4 3/4 8-5 3/4 8-6 6-7 6-10 6-13 6-15 B 3/4 8-4 Insert "A" and "B" to pg. 3/4 8-4 and 3/4 8-5 Insert to pg. 6-10 Insert to pg. 6-15 Insert to pg. B 3/4 8-4 9410260300 94i020 PDR ADOCK 05000250 PDR

ELECTRICAL POWER SYSTEHS LIMITING CONDITION FOR OPERATION Continued ACTION Continued SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously. With only one startup transformer and associated circuits restored, perform Surveillance Requirement 4.8. 1. l. l.a on the OPERABLE Startup transformer at least once per 8 hours, and restore the other startup transformer and its associated circuits to OPERABLE status or shutdown in accordance with the provisions of Action Statement 3.8. 1. la with time requirements of that Action Statement based on the time of initial loss of a startup transformer.

This ACTION applies to both units simultaneously.

With two of the above required diesel generators inoperable, demon-strate the OPERABILITY of two startup transformers and their associated circuits by performing the requirements of Specifica-tion 4.8. l.l.la. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> there-after; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Restore all req uired diesel generators to OPERABLE status within I W~~F-~ 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from t ime of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hev'4 hours.

SURVEILLANCE RE UIREHENTS 4.8. 1. 1.1 Each of the. above required startup transformers and their associated circuits shall be:

a0 Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability, and

b. Demonstrated OPERABLE at least once per 18 months while shutting down, by transferring manually unit power supply from the auxiliary transformer to the startup transformer.

4.8.1.1.2 Each diesel generator shall be demonstrated'OPERABLE":

In accordance with the frequency specified in Table 4.8-1 with diesel generator surveillances performed nonconcurrently by:

1) Verifying the fuel volume in the day and skid-mounted fuel.

tanks (Unit 4-day tank only),

2) Verifying the fuel volume in the fuel storage tank,

3) Verifying the lubricating oil inventory in storage,

• All diesel generator starts for the purpose of these surveillances may be proceeded by a prelube period as recommended by the manufacturer.

TURKEY POINT - UNITS 3 8L 4 3/4 8-4 AHENDHENT NOS.l 38 AND 133

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ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREMENTS Continued

4) Verifying the diesel starts and accelerates to reach a generator voltage and frequency of 4160 a420 volts and 60 %1. 2 Hz. Once per 184 days, these conditions shall be reached within 15 seconds after the start signal from normal conditions. For all other starts, warmup procedures, such as idling and gradual accelera-tion as recommended by the manufacturer may be used. The diesel generator shall be started for this test by using one of the following signals:

a) Manual, or b) Simulated loss-of-offsite power by itself, or c) Simulated loss-of-offsite power in conjunction with an ESF Actuation test signal, or d) An ESF Actuation test signal by itself.

5) Verifying the generator is synchronized, loaded" to 2300-2500 kW (Unit 3), 2650-2850 kW (Unit 4)"",- operates at this loaded condition for at 1'east 60 minutes and for Unit 3 until automatic transfer of fuel from the day=tank to the skid mounted tank is demonstrated, and the cooling system is demonstrated OPERABLE.

6) Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

b. Demonstrating at least once per 92 days that a fuel transfer pump starts automatically and transfers fuel from the storage system to the day tank, At least once per 31 days and after each operation of the diesel C.'. where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the day and skid-mounted fuel tanks (Unit 4-day tank only);

At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks;

e. aining a composite sample of new fuel oil in accordance with ASTM-D or to addition to storage tanks and:

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1) By verifying sn ASTM-D975-81 prior to sample has:

'n rdance with the tests specified in to the storage tanks that the f

(s) a) An API Gravity of within 0.3 degrees specific gravity of within 0.0016 at 60/60 F, or a kev.a compared to the supplier's certificate, or an abso "May include gradual loading as recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.

""Momentary transients outside these load bands do not invalidate this test.

TURKEY POINT - UNITS 3 5 4 3/4 8"5 AMENDMENT NOS338 AND 133

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L-94-224 Insert A g, Following the addition of the new fuel oil to the Diesel Fuel Oil Storage Tanks, with one or more diesel generators with new fuel oil properties outside the required Diesel Fuel Oil Testing Program limits, restore the stored 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.

Insert B

e. By verifying fuel oil properties of new fuel oil aze 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.

ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREMENTS Continued specific gravity at 60/60 F of greater than or equal to 0.83 but less than or equal to 0.89, or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees, when tested in accordance with ASTM-01298-80; b) kinematic viscosity at 40'C of greater than or equal to

1. centistokes, but less than or equal to 4. 1 centistokes (alte tively, Saybolt viscosity, SUS at 100'F of greater than or al to 32.6, but less than or equal to

40. 1), if g ity was not determined by comparison with the supplier's rtification; c) A flash point equal or greater than 125 F; and d) A clear and bright appea ce with prop'er color when tested in accordance with A "D4176"82.

2) By ver ifying within 30 days of obtain the sample that the other properties specified in Table 1 of TM-0975-81 are met when tested in accordance with ASTM-0975-81 cept that the analysis for sulfur may be performed in accorda e with ASTM-D1552-79 or ASTM-D2622-82.

f. At least once every 31 days by obtaining a sample of fuel os rom the storage tank in accordance with ASTM-02276-78, and verifyin that total particulate contamination is less than 10 mg/liter when checked in accordance with ASTM-D2276-78 Method A.

g. At least once per 18 months, during shutdown (applicable to only the two diesel generators associated with the unit):

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 380 kW while maintaining voltage at 4160 a420 volts and frequency at 60 %1. 2 Hz; 3)" Verifying the generator capability to reject a load of greater than or equal to 2500 kW (Unit 3), 2874 kW (Unit 4) without tripping. The generator voltage shall return to less than or equal to 4784 volts within 2 seconds following the load rejection;

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

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with any permanently "For the purpose of this test, warmup procedures, such as idling, gradual acceleration, and gradual loading as recommended by the manufacturer may be Used, TURKEY POINT " UNITS 3 4 4 3/4 8-6 AMENDMENT NOS. 13BAND 133

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M N STRAT V ONT 0 R SPONSIB T Continued

e. Investigation of all violations of the Technical Specifications, including the preparation and forwarding of reports covering evalua-tion and recommendations to prevent recurrence, to the President-Nuclear Division and to the Chairman of the Company Nuclear Review Board;

f. Review of all REPORTABLE EVENTS;

g. Review of reports of significant operating abnormalities or devia-tions from normal and expected performance of plant equipment or systems that affect nuclear safety.

h. Performance of special reviews, investigations, or analyses and reports thereon as requested by the Plant General Manager or the Chairman of the Company Nuclear Review Board;

i. Review of the Emergency Plan and implementing procedures and submittal of recommended changes to the Chairman of the Company Nuclear Review Board;

j. Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL;

k. Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the President-Nuclear Division and to the Chairman of the Company Nuclear Review Board.

l. Review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Company Nuclear Review Board.

6.5. 1.7 The PNSC shall:

a. Recommend in writing to the Plant General Manager approval or dis-approval of items considered under Specification 6.5. 1.6a. through d.

prior to their implementation and items considered under Specifica-tio'n 6.5. 1.6i through l.

b. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Plant General Manager, President-Nuclear Division and the Company Nuclear Review Board of disagreement between the PNSC and the Plant General Manager; however, the Plant General Manager shall have responsibility for resolution of such disagreements pursuant to Specification 6. 1. 1.

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. AD INISTRATIVE CONTROLS AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the CNRB. These audits shall encompass:

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license condi-tions at least once per 12 months;

b. The performance, training, and qualifications of the entire facility staff at least once per 12 months; C. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety, at least once per 6 months;

d. The performance of activities required by the guality Assurance Program to meet the criteria of Appendix 8, 10 CFR Part 50, at least once per 24 months;

e. The fire protection programmatic controls including the implement-ing procedures at least once per 24 months by qualified licensee gA personnel; The fire protection equipment and program implementation at least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year; The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months; The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months; The PROCESS CONTROL PROGRAM and implementing procedures for proc-essing and packaging of radioactive wastes at least once per 24 months; The performance of activities required by the guality Assurance Program for effluent and environmental monitoring at least once per 12 months;

k. The Emergency Plans and implementing procedures at least once per 12 months; The Security Plans and implementing procedures at least once per 12 months; and Any other area of unit operation considered appropriate by the CNRB or the President-Nuclear Division lrV5FR T (bevy )

TURKEY POINT - UNITS 3 5 4 6" 10 AMENDMENT NOS142 AND 137

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n. The Diesel Fuel Oil Testing Program and implementing procedures.

ADMINISTRATIVE CONTROLS SAFETY LIMIT VIOLATION (Continued)

b. A Licensee Event Report shall be prepared in accordance with 10 CFR 50.73.

c. The License Event Report shall be submitted to the Commission in accordance with 10 CFR 50.73, and to the CNRB, and the President-Nuclear Division within 30 days after discovery of the event.

d. Critical operation of the unit shall not be resumed until authorized by the Nuclear Regulatory Commission.

6.8 PROCEDURES AND PROGRAMS 6.8. 1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Sections 5. 1 and 5.3 of ANSI N18. 7-1972;

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Generic Letter No. 82-33;

c. Security Plan implementation;

d. Emergency Plan implementation;

e. PROCESS CONTROL PROGRAM implementation;

f. OFFSITE DOSE CALCULATION MANUAL implementation;

g. Quality Control Program for effluent monitoring using the guidance in Regulatory Guide 1.21, Revision 1, June 1974;

h. Facility Fire Protection Program; and

i. Guality Control Program for environmental monitoring using the guidance in Regulatory Guide 4.1, Revision 1, April 1976 6.8.2 Each procedure of Specification 6.8. 1 (a through h), and changes thereto,

~ shall be reviewed and approved prior to implementation and reviewed periodically as set forth in Specification 6.5.3 and administrative procedures.

6. 8. 3 Temporary changes to procedures of Specification 6.8.1 (a through i) may be made provided:

a. The intent of the original procedure is not altered; I u.e.l ~s lTe~gi'~~ ~vs sIVsamn.

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TURKEY POIN - UNITS 3 8L 4 6" 13 AMENDMENT NOS.142AND 137

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ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS Continued (3) Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps'or evidence of condenser in-leakage, (4) Procedures for the recording and management of data, (5) Procedures defining corrective actions for all off-control point chemistry conditions, and (6) A procedure identifying: (a) the authority responsible for the interpretation of the data, and (b) the sequence and tim-ing of administrative events required to initiate corrective action.

d. Post-Accident Sam lin A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under acci-dent conditions. The program shall include the following:

(1) Training of personnel, (2) Procedures for sampling and analysis, and (3) Provisions for maintenance of sampling and analysis equipment.

6.9 REPORTING RE UIREMENTS [~$ <R T Ch.eve)

ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the U.S.

Nuclear Regulatory Commission, Document Control Desk, Mashington, DC pursuant to 10 CFR 50.4.

STARTUP REPORT 6.9. 1. I A summary report of plant startup and power escalation testing shall be submitted followinq: (1) receipt of an Operating License, (2) amendment to the license involvsng a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit.

TURKEY POINT - UNITS 3 5 4 6-15 AMENDMENT NOS. 149 AND 144

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e. Diesel Fuel Oil Testin Pro ram 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'he 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:

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an API Gravity or an absolute specific gravity within limits,

2. a flash point and kinematic viscosity within limits for Grade No. 2-D fuel oil per ASTM D975, and

3. a clear and bright appearance with proper color;

b. Other properties for Grade No. 2-D fuel oil per ASTM D975 are within limits within 30 days following sampling and addition to storage tanks; and c ~ Total particulate concentration of the fuel oil is < 10 mg/liter when tested every 31 days in accordance with either ASTM D-2276 or ASTM D-5452.

ELECTRICAL POWER SYSTEMS BASES Continued With both startup transformers inoperable, the unit(s) are required to be shutdown consecutively, after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A consecutive shutdown is used because a unit without its associated transformer must perform a natural circulation cooldown. By placing one unit in COLD SHUTDOWN before starting shutdown of the second unit, a dual unit natural circulation cooldown is avoided.

The term verify means to administratively check by examining logs or other information to determine if required components are out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITY of the component.

The EDG Surveillance testing requires that each EDG be started from normal conditions only once per 184 days with no additional warmup procedures. Normal conditions in this instance are defined as the pre-start temperature and lube oil conditions each EDG normally experiences with the continuous use of prelube systems and immersion heaters.

The fuel supply specified for the Unit 3 EDG's is based on the original criteria and design bases used to license the plant. The specified fuel supply will ensure sufficient fuel for either EDG associated with Unit 3 for at least a week.'he fuel supply specified for the Unit 4 EDG's is based on the criteria provided in ANSI N195-1976 as endorsed by Regulatory Guide l. 137.

The specified fuel supply will ensure sufficient fuel for each EDG associated with Unit 4 for at least a week.

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TURKEY POINT - UNITS 3 8L 4 B 3/4 8-4 AMENDMENT NOS. 138AND133

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L-94-224 Insert for TS BASES P . B 3 4 8-4 DIESEL FUEL OIL TESTING PROGRAM In accordance with TS 6.8.4, a diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. Foz the intent of this specification, new fuel oil shall represent diesel fuel oil that has not been added to the Diesel Fuel Oil Storage Tanks. Once the fuel oil is added to the Diesel Fuel Oil Storage Tanks, the diesel fuel oil is considered stored fuel oil, and shall meet the Technical Specification requirements foz stored diesel fuel oil.

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 new 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 tanks, but in no case is the time between receipt of the new fuel oil and conducting the tests of Suzveillance Requirement 4.8.1.1.2e. to exceed 30 days. The tests, limits, and applicable ASTM standards being used to evaluate the condition of new fuel oil are:

By obtaining a composite sample of new fuel oil in accordance with ASTM-D4057 prior to addition of new fuel oil to the diesel fuel oil storage tanks and:

2. By verifying in accordance with the tests specified in ASTM-D975-81 prior to addition to the diesel fuel oil 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 0.83 but less than oz equal to 0.89, or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees, when tested in accordance with ASTM-D1298-80; 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 (alternatively, Saybolt viscosity, SUS at 100 F of greater than or equal to 32.6, but less than or equal to 40.1), if gravity was not determined by comparison with the supplier's certification; c) A flash point equal to or greater than 125 F; and d) A clear and bright appearance with proper color when tested in accordance with ASTM-D4176-82.

L-94-224 Insert for TS BASES P . B 3 4 8-4 Cont.

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 Limiting Condition for Operation of TS 3.8.1.1, since the new fuel oil has not been added to the diesel fuel oil storage tanks.

Within 30 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 when tested in accordance with ASTM-D975-81 except that the analysis for sulfur may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. The 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 diesel fuel oil for the EDGs.

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 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 for subsequent laboratory testing in lieu of field testing.

Fuel oil degradation during long term storage shows up as an inczease 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.