ML20045H838
| ML20045H838 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/15/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20045H836 | List: |
| References | |
| NUDOCS 9307210353 | |
| Download: ML20045H838 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION k.i
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u WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 80 TO FACILITY OPERATING LICENSE NO. NPF-62 ILLIN0IS POWER COMPANY. ET AL.
CLINTON POWER STATION. UNIT NO. 1 DOCKET NO. 50-461
1.0 INTRODUCTION
By letter dated August 17, 1992, the Illinois Power Company (IP, the licensee), requested an amendment to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS). The proposed amendment would modify Clinton Power Station Technical Specification (TS) 3/4.8.1.1, "AC Sources -
Operating," to update the testing requirements for the fuel oil used by the standby diesel generators.
The licensee submitted this amendment request as part of their corrective actions after identifying that the fuel oil testing requirements were not being met due to the offsite laboratory that performed the testing using a later revision of American Society for Testing and Materials (ASTM) Standard ASTM-D975, " Standard Specification for Diesel Fuel Oils," than was specified in the CPS TS.
Specifically, the laboratory used ASTM-D4294 (X-ray fluorescence spectrometry method) to determine sulfur content of the fuel oil sample. While this method is considered acceptable in the 1988 and later revisions of ASTM-D975, prior revisions (including the 1977 revision currently identified in the CPS TS) require that ASTM-D129, general bomb method, be used to determine sulfur content.
(See CPS Licensee Event Report (LER)-92-009.)
2.0 EVALUATION The licensee is proposing the following changes to CPS TS 3.8.1.1 and associated Surveillance Requirement (SR) 4.8.1.1.2.d for testing of the diesel generator fuel oil:
(1)
IP proposes to change TS SR 4.8.1.1.2.d to specify the use of the more current 1989 version of ASTM-D975 for testing fuel oil rather than the 1977 version.
The fuel oil properties to be determined and the limits on those properties required by ASTM-0975-89 are identical to those required by ASTM-0975-77. The primary advantage that the licensee gains by using ASTM-0975-89 is the l
incorporation of alternative test methods for determining sulfur content.
I ASTM-0975-77 requires testing for sulfur content in accordance with ASTM-D129, general bomb method, whereas ASTM-D975-89 allows the use of alternate test i
9307210353 930715 PDR ADOCK 05000461 P
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1 methods ASTM-D1552, high temperature method, ASTM-D2622, X-ray spectrographic method, and ASTM-D4294, non-dispersive X-ray fluorescence spectrometry method, 3
in addition to ASTM-D129. The proposed change will allow the use of the most up-to-date test methods for determining sulfur content.
These additional methods have also been approved for use in Federal Specification VV-F-800D (July 29, 1988).
The staff considers these alternative methods for testing sulfur content to be acceptable because they produce results equivalent to the results-obtained in ASTM-D129. The staff, therefore, finds this proposed change acceptable.
(2)
IP proposes adding the performance of a visual appearance test (" Clear and Bright" appearance per ASTM-04176-82) as an alternative to the water and sediment test (centrifuge method per ASTM-D1796) currently required by SR 4.8.1.1.2.d.l.
The " Clear and Bright" appearance test is more sensitive for detecting water and sediment in fuel oil than the centrifuge method currently specified.
According to ASTM-D4176-82, an experienced tester can visually detect as little as 40 ppm of free water in fuel by use of the proposed " Clear and Bright" appearance test. The lower limit of water detectable by the centrifuge method is 250 ppm based on the smallest readable division on the centrifuge tube.
The staff has reviewed these methods for determining water and sediment content and concluded that the " Clear and Bright" test is more sensitive and that its inclusion as an alternative testing method is acceptable.
(3)
IP proposes adding the determination of specific gravity as an alternative to the determination of API gravity currently required by SR 4.8.1.1.2.d.
This proposed change is consistent with the requirements of Regulatory Guide 1.137, Revision 1, which require testing of new fuel for either specific or API gravity prior to addition to the storage tankt The primary purpose of testing for specific or API gravity is to detect grs.
contamination of the fuel oil during transport. Determination of either sp.cific or API gravity will fulfill this purpose.
The staff has reviewed this proposed change and finds it acceptable because it is consistent with the requirements of Regulatory Guide 1.137.
l (4)
IP proposes revising the time limit for obtaining ASTM-0975 test results for the "other properties" (i.e., those properties other than water and sediment and kinematic viscosity) from two weeks to 31 days.
i SR 4.8.1.1.2.d currently requires new fuel and the fuel contained in the storage tanks to be tested for conformance to the limits of the "other" fuel oil properties listed in Table 1 of ASTM-0975. The "other properties" are in addition to those verified prior'to the addition of the fuel to the storage
tanks.
These test results are currently required to be obtained within two weeks of taking the sample.
IP is proposing increasing the time limit for obtaining these test results to 31 days.
The fuel oil properties which could result in detrimental and immediate impact on the diesel generator if n'ot within specification (water _and sediment, viscosity, and gravity) are checked for conformance to applicable limits prior to acceptance of the new fuel or adding new fuel to the storage tanks. The remaining fuel oil. properties are those which might impact diesel generator performance only on a long term basis.
Because of the effective screening done to verify that acceptable. fuel is being received before unloading, the proposal to extend the time for obtaining test results for the remaining fuel oil properties from two weeks to 31 days will not adversely affect diesel generator reliability.
The staff concurs with the licensee's justification and, therefore, finds this proposed change acceptable.
(5)
IP proposes changing SR 4.8.1.1.2.d to delete the requirement for testing the fuel oil contained in the storage tanks in accordance with ASTM-D975 on a 92 day basis.
The rationale for this deletion is that the majority of fuel oil properties determined in accordance with ASTM-D975 do not change during storage.
If these properties are within specification when the fuel oil is placed in storage, they will remain within specification during storage unless I
unacceptable petroleum products are added to the storage tanks.
The addition of unacceptable petroleum products is precluded by the proposed surveillance i
program for new fuel as detailed above. Although the majority of fuel oil properties do not change during storage, over prolonged periods of time, j
stored fuel oil can oxidize and form particulates.
These particulates, in i
significant concentrations, can impair diesel generator performance.
Particulate concentrations and bacteria concentrations are the only l
characteristics that will change significantly in stored fuel.
Particulate concentrations, will be monitored every 31 days as detailed in Item 6 below.
Bacteria growth is currently prevented and will continue to be prevented by removal of water from the storage tanks every 92 days in accordance with SR 4.8.1.1.2.c.
Considering that the fuel oil properties will not change significantly during storage and that fuel oil conditions which could adversely affect diesel generator operation will be closely monitored, further testing of stored fuel in accordance with ASTM-D975 every 92 days would not provide any additional, worthwhile data nor improve diesel generator reliability.
The staff concurs with the licensee's justification and, therefore, finds this proposed change acceptable.
(6)
IP proposes replacing the requirement to perform an accelerated oxidation stability test in accordance with ASTM-D2274-70 on stored fuel every 92 days and on new fuel per current SR 4.8.1.1.2.d.2 with a requirement to perform a particulate concentration test in accordance
1 with ASTM-D2276-88 on the stored fuel only every 31 days per proposed SR
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4.8.1.1.2.d.3.
The rationale for this change is that the proposed test addresses the actual
-l condition of the fuel that will be pumped to the diesel generators in terms of particulate matter which could impair diesel generator. operation or result in diesel generator unavailability.
The current surveillance requirements, stated in ASTM-D2274-70, are oriented to predicting the tendency of fuel to.
oxidize and form particulates during 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 more frequent testing for. actual particulates in the stored fuel oil would provide better data on fuel condition at the time of the test, as well as the tendency for formation of particulates under site storage conditions.
This test need not be a requirement for new fuel because the current water and sediment test, ASTM-D1796 per ASTM-0975-89, or the proposed " Clear and Bright" appearance test, ASTM-D4176-82, described earlier is sufficient to detect unacceptable particulate concentrations in new fuel prior to adding it to the storage tanks.
The staff has reviewed the proposed change and concluded that the proposed i
test is more conservative in establishing _the adequacy of stored fuel than the present requirements and it is, therefore, acceptable.
(7)
IP proposes to revise TS 3.8.1.1 by adding Action Statement "j" to clarify the requirements to be met when the properties of the fuel oil contained in the storage tanks do not meet the limits of proposed SR 4.8.1.1.2.d. 2 or 4.8.1.1.d.3.
These surveillances verify, on a periodic basis, the quality of new fuel oil added to the storage tanks, 4.8.1.1.2.d.2, and the quality of fuel oil in the i
storage' tanks, 4.8.1.1.2.d.3.
The intent of these surveillance requirements is to ensure the fuel oil satisfies the quality specifications.
In accordance with Regulatory Guide 1.137, Revision 1, Regulatory Position C.2.a, the fuel oil may be replaced in a short period of time (about a week) when the fuel oil does not meet the specified requirements.
Proposed Action Statement "j" has been added to allow up to seven days to correct the out-of-specification condition by replacing the fuel oil or taking other necessary actions.
The staff has reviewed this proposed change and finds it acceptable because it is consistent with the requirements of Regulatory Guide 1.137.
3.0 STATE CONSVLTATION In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment.
The State official had no comments.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as' defined in 10 CFR Part 20 and changes surveillance requirements. The NRC 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 the amendment involves no significant hazards consideration and there has been no public comment on such finding (57 FR 48820).
Accordingly, the amendment meets the eligibility criteria for-categorical exclusion set forth in 10 CFR 51.22(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 the amendment.
5.0 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,.(2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will:not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
R. Laufer K. Parczewski l
Date:
July 15,1993