ML20055C328
| ML20055C328 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/20/1990 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1767, NUDOCS 9003020131 | |
| Download: ML20055C328 (2) | |
Text
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,; w l TOLEDO EDISON AComew Enypc m DONALD C. SHELTON
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we s% sort - Nxer M"9"S*3" Docket Number 50-346 l
License Number NPF-3 Serial Number 1767 February 20, 1990 United States Nuclear Regulatory Commission Document Control Desk Vashington D. C. 20555
Subject:
Alternate Sampling Standards for Diesel Fuel Oil Storage Tanks Gentlement This letter documents a telephone conversation between Toledo Edison (TE) and Nuclear Regulatory Commission Office of Nuclear Reactor Regulation (NRC/NRR) personnel on October 17, 1989 concerning TE's sampling methods for the Diesel Fire Pump Diesel Oil Storage Tank at the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 pursuant to Technical Specification (TS) 4.7.9.1.2.b.
Technical Specification 4.7.9.1.2.b requires that a diesel funi sample be obtained from the Fire Pump Diesel Oil Storage Tank in accordance with~
L ASTH-D270-65, " Standard Method of Sampling Petroleum and Petroleum Products".
This ASTM provides for a multiple level ("all-level") sampling of the storage tank (Section 16.1) to ensure a representative sample is obtained.
- However, DBNPS samples from the Diesel Fire Pump Diesel Oil Storage Tank are obtained downstream of the Diesel 011 Transfer Pumps.
This sample paint != cqi.ivaient to a lover sample point defined in Section 3.8 of ASTH D270-65.
While this type of sampling does not follow the specified standards of ASTH-D270-65, alternate sampling methods are allowed by Section 11.1 of the ASTH.
It should be noted that in 1984, ASTH-D270-65 was replaced by ASTH-D4057, " Standard Practice for Manual Sampling of Petroleum and Petroleum Products", and 1
ASTH-D4177, " Standard Method for Automatic Ssmpling of Petroleum and Petroleum i.
Products." Since manual sampling techniques are used at DBNPS, ASTH D4057-81 applies to the alternative sampling method cited for ASTH-D270-65.
In Section l
6.1.4, ASTH-D4057-81 states that "An all levels [ multiple levels cited abovel is not necessarily a representative sample because the tank volume may not be 9003020131 900220 PDR ADOCK 05000346 p
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,qool THE TOLEDO EDISON COMPANY EDISON PLAZA 300 M/ADISON AVENUE TOLEDO. OHIO 43658 O
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DockOt Number 50-346 j
3 License Number NPF-3
. Serial Number 1767 i
Page 2 proportional to th: depth and because the operator may not be able to raise f'
the sampler at the variable rate required for proportional filling." The lover point / outlet point sample (per ASTM D4057 R1, Section 6.1.10/Section 6.1.14) is deemed acceptable because, per Section 4.1.2 of ASTM D4057-81,
" Tank samples will be representative if the tank contents are homogeneous from top to bottom," and, per Section 8.2 of ASTM D4057-81, " Gasoline and l
Distillate Products usually are homogeneous but they are often shipped from tanks that have clearly separated vater on the bottom. Tank sampling is-acceptable under the conditions covered in 4.1.2".
The conditions of Section 4.1.2 are met by the DBNPS tank de91gn, the sampling procedure and the anticipated contaminants.
1 In accordance with the provisions of both ASTM D270-65 and ASTM D4057-81,' the diesel oil is sampled per DBNPS procedures prior to unloading into the storage tanks by performing visual tests for clarity and brightness and workmanship.
(Further testing per ASTM D4057-81 vill be performed prior to unloading the diesel oil into the storage tanks if the visual tests indicate the sample has l
unacceptable indications of contaminants.) The diesel oil storage tanks at DBNPS are further sampled on a monthly, quarterly and annual basis.
Based on the above, the NRC/NRR personnel concurred that utilizing ASTM
-D4057-81 as the alternate diesel fuel sampling method to the TS 4.7.9.1.2.b cited ASTM D270-65 sampling method was acceptable.
A Technical Specification (TS) change for TS 4.7.9.1.2.b to administratively reflect this updated sampling method was not proposed by TE in that the Fire Protection TSs vill be deleted pursuant to Generic Letter 86-010 in the near future. It was further noted that the Emergency Diesel Generator Diesel Oil Storage Tanks TS 4.8.1.1.1.d is not affected in that an ASTM sampling method is not specified therein. Therefore, the NRC/NRR personnel concurred that a TS change was not required.
In order to comply with the requirements of ASTM D270-65, Section 11.1. TE requests that the NRC's written concurrence with the above be provided by March 30, 1990.
If you have any questions, please contact Mr. R. V. Schrauder, Manager -
Nuclear Licensing, at (419) 249-2366;.
Very truly yours,
'j,,g RMC/ssg cci P. M. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager