ML20028H080
| ML20028H080 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/27/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20028H077 | List: |
| References | |
| NUDOCS 9010090055 | |
| Download: ML20028H080 (4) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 34 TO FACILITY OPERATING LICENSE NO. NPF-58 THE CLEVELAND ELECTRIC ILLUMINATING COMPANY ET AL.
PERRY NUCLEAR POWER PLANT, UNIT NO.1 DOCKET NO. 50-440
1.0 INTRODUCTION
By letter dated March 21, 1990, The Cleveland Electric Illuminating Company, l
et al. (the licensees), submitted a request for amendment to the Facility L
Operating License to revise the Technical Specifications (TS) for the Perry l
Nuclear Power Plant. The amendment consists of modifying limiting conditions for operation 3.8.1.1 and 3.8.1.2 to accommodate the proposed use of a
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different type of diesel fuel oil and changing surveillance requirement l
4.8.1.1.2 for testing of this oil.
Because of the recurrent fuel oil quality problems, the licensees decided to re) lace the currently used "cata-lytic cracked" distillate oil with a more sta)1e, grade 2-D, " straight run" fuel oil.
Use of this oil requires modification of the relevant technical specifications. The licensees also decided to update diesel fuel oil surveillance methods.
2.0 DISCUSSION AND EVALUATION The major difference between the currently used fuel oil and the new oil is oil density. The minimum allowable density of grade 2-0 oil is lower by about 1.8 percent. The licensees have demonstrated that this difference in 1
density will not have any significant effect on diesel performance. However, 1
the volume of the oil in storage tanks has to be increased to maintain j
adequate fuel supply for emergency diese) generators which, in accordance with Regulatory. Guide 1.137, Rev. I are provided to mitigate a design basis event of 7-day duration.
Thelicenseesproposedtoamendlimitingconditions for operation 3.8.1.1 and-3.8.1.2 to include this change.
In addition, the revised fuel volume limits also included other considerations.
For-the diesel generators in Divisions 1 and 2, an increase in electrical loads and
- a more accurate method for determining unusable fuel volume in the storage tanks were considered.
The fuel consumption was determined using time-
. dependent loads with 15 percent safety margin added.
For the Division 3
- diesel generator, revised fuel oil volume limits were determined using the method provided in ANSI N195-1976 and assuming continuous diesel operation for 7 days at rated capacity. The resulting increases in minimum fuel volumes in the storage tanks were 6.2 percent for Divisions 1 and 2, and 3.7 i
percent for Division 3.
The staff considers that these changes to the 1
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limiting conditions for operation are conservative, ard are, therefore, l
acceptable, l
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l The other proposed change to the Perry Technical Specifications consists of adding a requirement that, if the fuel oil contained in a storage tank does not conform to the survei? lance criteria specified in TS 4.8.1.1.2.d.2 and 4.8.1.1.2.e, it could be broaght within the specification within 7 days before the affected diesel genera?nr is declared inoperable. This change is acceptable because it is consistent with the requirement of Regulatory Guide 1.137.
2 The proposed changes to surveillance rettirement 4.8.1.1.2 consist of replacing
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the fuel oil tests presently required by the technical specifications with r
different tests which will provide an ine.reased and more effective ability to i
detect unsatisfactory fuel oil, could be performed onsite with more innediate results, and are simpler to perform.
The most significant change is a replac(ment of the requirement for testing of stored fuel oil in accordance with AS(M D2274-70 every 92 days (surveil-lance 4.8.1.1.2.d) by the test for determining particulate concentration in the stored fuel oil performed every 31 days in accordance with ASTM D2276-88 t
(surveillance 4.3.1.1.2.e).
The rationale for this change is that the i
proposed test addresses the actual condition of fuel that will be pumped to dieselgeneratorsintermsofparticulate(solid)matterwhichcouldimpair diesel generator operation or result in diesel generator unavailability.
The current surveillance requirements, stated in ASTM D2274-70 are oriented topredictingthetendencyoffueltooxidizeandformparticulatesduring long term storage, but do not address particulates that may already exist.
In addition, the ASTM D2274-70 test results may not accurately correlate with actual fuel condition because they tend to vary depending on factors such as storage conditions. Also, the proposed ASTM D2276-88 test would be performed every 31 days, as opposed to every 92 days for ASTM D2274-70. The t
more frequent testing for actual particulates in the stored fuel oil would provide better data on fuel condition at the time of test, as well as the tendency for formation of particulates under site storage conditions. The t
l proposed test is more conservative in establishing the adequacy of stored fuel l
than the present requirements, and it is, therefore, acceptable.
The licensees modified the surveillance procedure and acceptance criteria for new fuel oil prior to its addition to the storage tanks (surveillance l
4.8.1.1.2.d).
The modification requires sampling to be performed in accordance i
with ASTM D4057-88, which is an acceptable procedure. Water and sediment in the samples will not be determined by the centrifuge method in accordance with ASTM D1796, but by the Clear and Bright test described in ASTM D4176-86. The strff reviewed this method and concluded that the Clear and Bright test is more sensitive and its use is acceptable. This method will also be used in determining water and sediments in the samples taken periodically from ths day and storage tanks, as required by surveillance requirements 4.8.1.1.2.b t.nd l
4.8.1.1.2.c.
The proposed amendment will require a flash point test to be performed on-new fuel oil prior to its addition to the storage tanks.
This would provide an additional indication that new fuel is within specification limits and i
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, will not contaminate the fuel in the storage tanks.
The staff finds this change acceptable.
There will be two options for determining specific gr ity of new oil.
Specific gravity will be determined in accordance wi' ASTM D1298 and its i
absolute value, expressed in specific gravity or API gravity units, will be i
used to determine fuel oil quality by assuring that it is within the pre-scribed limits. If this option is used, additional measurement of kinematic viscosity in accordance with ASTN 0975-89 would be required as a confirma-tory test.
In the second option, measured specific gravity will be directly compared with the supplier's certified value.
Although the first option would give more iirect determination of fuel oil quality, the second option is justifiable because if the supplier provides density certification on i
each load shipped, any contamination occurring during transportation will be detected.
The staff reviewed these two options and finds both of them accept-able.
In addition to the tests performed before its addition to the storage tanks (specific gravity, kinematic viscosity, flar5 point, water and sediment), the new fuel oil will be tested for conformance to the other limits specified in Table 1 of the ASTM 0975-89 standard.. At present, the Technical Specifications require that the results of these tests be available within 14 days following
'uel delivery. Under the licensees' proposed surveillance program, the time for determining the fuel oil properties that may impact diesel generator performance only on a long term basis will be extended from 14 to 31 days.
Because of the effective screening done before unloading of the fuel to Verify that proper fuel is being received, the proposal to extend the time for obtaining test results for the remaining fuel oil properties from 14 days to 31 days would not adversely affect diesel generator reliability. The staff concurs with the licensees' justification and finds this extension acceptable.
The proposed changes to the Technical Specifications include deleting the requirement for testing of fuel oil stored in tanks in accordance with the ASTM 0975-77 standard on a 92-day basis. The licensees' rationale for this deletion is that the fuel oil properties which can affect diesel generator performance do not change during storage.
If these pro)erties are within specification when the fuel oil is placed in storage, tiey will remain within specification un13s other non-specification petroleum products are t
added to the storage tanks. The addition of non-specification petroleum products is precluded by the licensees' proposed new fuel surveillance program, as described above.
Over a prolonged period, stored fuel can oxidize and form products which, in significant concentrations, could impair diesel generator perfornance. However, particulate corcentrations and bacteria concentra-tions are the only things that will change in stored fuel oil.
Particulate concentrations will-be monitored every 31 days, as required by the amended surveillance procedures. Bacteria growth will be prevented by periodic removal of water from the storage tanks.
Considering that the fuel oil properties will not change significantly in storage, and that fuel oil conditions which could affect diesel generator operation will be closely
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monitored (on a 31-day basis), further testing of stored fuel in accordatce with the ASTM D975-77 standard every 92 days will not provide any addition 1 data nor improve diesel generator reliability. This testing can be, theretare, deleted.
The staff concurs with the licensees' justification and concludes that the proposed deletion is acceptable.
The ASTM D975-77 standard requires that the fuel oil testing for sulfur should be performed in accordance with ASTM D129-64.
However, the updated ASTM D975-89 standard includes three additional methods, described in ASTM j
D:552, ASTM D2622 and ASTM D4292, which could be used for testing all grades of diesel fuel oil for sulfur. These methods are also approved in Federal Specification VV-F-800D (July 29, 1988).
The staff considers these methods to be acceptable because they produce results equivalent to the results obtained by ASTM D129.
j In sumary, the staff finds that the proposed change of diesel fuel oil and the resulting changes of limiting conditions for operation 3.8.1.1 and 3.8.1.2 will produce more efficient and safer operation of the emergency diesel generators. The proposed changes to surveillance requirement 4.8.1.1.2 1
will prov Me a more conservative approach to fuel oil surveillance. The added conservatism coupled with the simplified testing procedures, provides prompt assurance of the quality of fuel oil upon de:ivery and maintenance of high quality of stored fuel. We conclude, therefore, that the requested t
amendment for the Perry Nuclear Power Plant, submitted in the letter of March 21, 1990, is acceptable.
l 3.0 ENVIRONMENTA. CONSIDERATION This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted t
area as defined in 10 CFR Part 20 or a change to a surveillance requirement.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no ublic comment on such finding. Accordingly, this amendment meets the eli ibility criteria forcategoricalexclusionsetforthin10CFR51.22(c)(9.
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
4.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the connon defense and security or to the health and safety of the public.
Principal Contributor:
K. Parczewski Dated: September 27, 1990
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