ML20043C500

Forwards marked-up Pages to Util 900410 Tech Spec Change Request Indicating Location of Incorrect Std Refs,Per 900419 Telcon W/Jj Hayes

ML20043C500
Person / Time
Site:	Summer
Issue date:	05/29/1990
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-74823, NUDOCS 9006050259
Download: ML20043C500 (5)

Text

-

.* gs. eredham gtge.rguna

, a.ciric a c . c:mp;ny

' Nuclear Operations gnl;ngge SC 29065

. SCE&G

1. SCANA :.s r .avn May 29, 1990  ;

Document Control Desk U. S. Nuclear Regulatory Commission l Washington, DC 20555

Subject:

Virgil C. Summer Nuclear Station I Docket No. 50/395 '

Operating License No. NPF-12 Diesel Fuel Oil Monitoring -

Technical Specifications Change l Request Clarification l 1

Gentlemen:  !

This letter is in regard to an April 19, 1990, conversation with Mr. J. J.

Hayes, of the Nuclear Regulatory Commission, concerning an administrative r error in the Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications Change. Request for..D.iesel . Fuel Oil Monitoring (TAC NO. 74823). l In a letter dated April 10, 1990, South Carolina Electric & Gas Company (SCE&G) submitted a reformatted version of a Technical Specifications Change Request to revise Surveillance Requirement 4.8.1.1.2 of Technical l Specification 3/4.8.1, "A. C. Sources." Specifically, the proposed amendment L replaces the diesel fuel oil storage, monitoring. sampling, and analysis  ;

requirements currently in the Specification with the corresponding  !

requirement in-NUREG-0452, " Standard Technical Specifications-for  !

Mestinghouse Pressurized Water Reactors."

l The proposed marked-up Technical Specifications pages in the April 10, 1990, ,

submittal reflect SCE&G's intent to check for total particulate contamination 1 in accordance with ASTM-02276-88, which is an update to the Standard '

,. specified in NUREG-0452, ASTM-D2276-78. However, in the " Description of l Amendment Request" sections, which compare the current Virgil C. Summer Nuclear Station Technical Specifications with the proposed revision, the submittal incorrectly indicates that SCE&G intends to obtain and check samples'for total particulate contamination in accordance with ASTM-D2276-78.

The referenced standard should be ASTM-D2276-88.

As previously mentioned. ASTM-02276-88 is simply an update to ASTM-D2276-78.

There are no differences in the requirements of the two editions. For your reference. Attachment 1 contains marked-up pages of the April 10, 1990, submittal indicating the locations where the incorrect standard was referenced.

[O b $bbk b f ,()O P

i

a im j c; ,

O

. t Document Control Desk j May 29. 1990 Page 2 of 2 4

Should you have any questions, please call at your convenience.-

Very truly yours, ffhe r

0. S. Bradham '

EWR/OSB: led Attachment c: 0. W. Dixon, Jr./T. C. Nichols, Jr.  !

E. C. Roberts R. V. Tanner S. D. Ebneter J. J. Hayes, Jr.

General Managers C. A. Price R. B. Clary K. E. Nodland J. C. Snelson R. L. Prevatte H. G. Shealy J. B. Knotts, Jr.

W. R. Baehr W..F.' Bacon H. R. Goff E. W. Rumfelt

1. NSRC 1 l- NPCF i RTS (TSP 890003)

~ File (813.20) l I

l L

1 I

l l

p, ' m'rygg.. ' mt 3

i c

<. .. t

-1 Mg, 4

s --. ,

$[ - '

t o

ATTACHMENT 1 f,

'y

((

- w

!t a

i s

e r

e p

c.s i

t g,

r iip-r.

i.

N'

?-

r,'

i a[-..

L:

l.:

f Y

i.

L

[. -

l-y I

r be ruW.  ;..-s & < r

Attachment 2~ t@ Document Control Desk letter ATTACHMENT 1 1 April 10,: 1990 ,

Page 3 of 4

.f' Current VCSNS Proposed Revision Technical Specifications (NUREG-0452)

• Requires that, within

• Requires that, within 30 days of 2 weeks of obtaining the obtaining the sample, the sample, the properties properties specified in Table 1 specified in Table 1 of of ASTM-0975-81 are verified when -

ASTM-0975-77 and Regulatory tested in accordance with Guide 1.137 Position 2.a are ASTM-0975-81, WITH THE EXCEPTION verified when tested in that the analysis for sulfur may accordance with ASTM-0975-77 be performed in accordance with '

ASTM-01552-79 or ASTM-02622-82

' Requires that, within one

• Requires that at least once-week of obtaining the sample, every 31 days a sample of fuel an impurity level of less than oil be obta ed ar -

Nl 2 mg of insoluble per 100 ml ASTM-02276 d the total be verified when tested per particulate contamination be ASTM-02274-70 verified less than 10mg/ liter en checked per ASTM-02276 l Additionally, the proposed revision re-letters sections 4.8.1.1.2 (d),(e),(f), and (g) to make the VCSNS Technical Specifications consistent with the changes mentioned above.

South Carolina Electric and Gas Company is proposing this change to update the VCSNS Technical Specification on testing methodology and acceptability of emergency diesel generator fuel oil to comply with the latest ASTM test standards and to concur with the Standard Technical Specifications. The most beneficial aspect of this change will be the replacement of the Oxidation Stability analysis (4.8.1.1.2.(c)2. in the VCSNS Technical Specifications) with the Total Particulate Contamination analysis as found in the Standard Technical Specifications. The Oxidation Stability test is hazardous to perform and is very time consuming. Additionally, the results from the stability test are not indicative of the actual conditions in the tanks.

Chemistry personnel at VCSNS have performed a trial run on the Total Particulate Contamination Test and are satisfied with the results and the methodology for performing the analysis.

South Carolina Electric and Gas Company (SCE&G) intends for this revision to be a permanent change in the VCSNS Technical Specifications. The change in diesel fuel oil monitoring and analyses does not affect the purpose of the Technical Specification. With the methods proposed in NUREG-0452 implemented at VCSNS, the diesel generator fuel oil will continue to meet the NRC guidelines for kinematic viscosity, water and sediment content, and specific gravity, and will, therefore, ensure the proper quality fuel oil for operation of the diesel generators.

Attachment-3 of Document Control Desk Letter ATTACHMENT 1 April 10, 1990 Page 3 of 5 l 4

i' Current VCSNS Proposed Revision ,

Technical Specifications (NUREG-0452)

' Requires that, within

• Requires that, within 30 days of 2 weeks of obtaining the obtaining the sample, the sample, the properties properties specified in Table 1 specified in Table 1 of of ASTM-0975-81 are verified when ASTM-0975-77 and Regulatory tested in accordance with Guide l.137 Position 2.a are ASTM-0975-81, WITH THE EXCEPTION verified when tested in that the analysis for sulfur may l accordance with ASTM-0975-77 be performed in accordance with  !

ASTM-01552-79 or ASTM-02622-82 b

• Requires that, within one ' Requires that at least once week of obtaining the sample, every 31 days a sample of fuel an impurity level of less than oil be obtaine pe 2 mg of insoluble per 100 ml ASTM-02276 and the total particulate contamination be

%l be verified when tested per ASTM-D2274-70 verified less than 10mg/ lit when j checked per ASTM-02276- l 1

Additionally, the proposed revision re-letters sections 4.8.1.1.2 l (d),(e),(f), and (g) to make the VCSNS Technical Specifications consistent with the changes mentioned above.

South Carolina Electric and Gas Company is proposing this change to update the VCSNS Technical' Specification on testing methodology and acceptability of

-emergency d'.asel generator fuel oil to comply with the latest ASTM test standards A.d to concur with the Standard Technical Specifications. The most beneficial aspect of this change will be the replacement of the Oxidation Stability analysis (4.8.1.1.2.(c)2. in the VCSNS Technical Specifications) with the Total-Particulate Contamination analysis as found in the Standard Technical Specifications. The Oxidation Stability test is hazardous to 4 perform and is very time consuming. Additionally, the results from the stability test are not indicative of the actual conditions in the tanks.

Chemistry personnel at VCSNS have performed a trial run on the Total Particulate Contamination Test and are satisfied with the results and the methodology for performing the analysis.

South Carolina Electric and Gas Company (SCE&G) intends for this revision to be a permanent change in the VCSNS Technical Specifications. The change in diesel fuel oil monitoring and analyses does not affect the purpose of the Technical Specification. With the methods proposed in NUREG-0452 implemented at VCSNS, the diesel generator fuel oil will continue to meet the NRC-guidelines for kinematic viscosity, water and sediment content, and specific gravity, and will, therefore, ensure the proper quality fuel oil for operation of the diesel generators.

l