ML20077N159

Proposed Tech Specs Re Min Gallons of Fuel Oil Required in Day Tanks & Storage Tanks

ML20077N159
Person / Time
Site:	Nine Mile Point
Issue date:	01/06/1995
From:	NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML20077N137	List: ML20077N133 ML20077N159
References
NUDOCS 9501170088
Download: ML20077N159 (18)

Text

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ATTACHMENT A NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 Proposed Channes to the Technical Soecifications Replace pages 3/4 8-1,3/4 8 4 through 3/4 8-6,3/4 8-13, and B3/4 8-2 through B3/4 8-4 with the attached revised pages. Additior' ally, new pages 3/4 813a and 6-17a have been added. These pages have been typed e resi;ed in their entisoty with rnarginal markings to indicate the changes to the text.

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9501170088 950106 PDR ADDCK 05000410 P PDR

. 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 AC SOURCES AC SOURCES - OPERATILig LIMITING CONDITIONS FOR OPERATION 3.8.1.1 As a minimum, the following AC electrical power sources shall be OPERABLE:

a. Two physically independent Orcuits between the offsite transmission network and the onsite Class 1E distribution sys:sm, and

b. Three separate and independent diesel geerators, each with:

1. Separate day fuel tanks containing a minimum of 403 gallons of fuel for EDG*1 l (Division I) and EDG*3 (Division ll), and 282 gallons for EDG*2 (HPCS-Division lil)

2. A separate fuel storage system containing a minimum of 47,547 gallons of fuel for EDG*1 (Division I) and EDG*3 (Division 11), and 35,342 gallons for EDG*2 (HPCS-Division Ill), and

3. Two fuel oil transfer pumps.

APPLICABILITY: OPERATIONAL CONDITIONS 1,2, and 3.

ACTION:

a. With one offsite circuit of the above required AC electrical power sources inoperable, demonstrate the OPERABILITY of the remaining AC sources by performing Surveillance Requirements 4.8.1.1.1 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 overy 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. With either diesel generator EDG*1 or EDG*3 inoperable, demonstrate the OPERABILITY of the above required / C offsite sources by performing Surveillance Requirement 4.8.1.1.1 within 1 hout and at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If the diesel generater became inoperable from any cause other than preplanned maintenance or testing, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, for each OPERABLE diesel generator separately, either verify that the cause of the diesel generator being inoperable does not impact the OPERABILITY of the OPERABLE diesel generator or perform Surveillance Requirement 4.8.1.1.2.a.4*. Restore the inoperable diesel generator '.o CPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• This is required to be completed regardless of when the inoperable diesel generator is restored to OPERABLE status. The provisions of Specification 3.0.2 are not applicable.

NINE MILE POINT - UNIT 2 3/4 8-1 Amendment No. dd

. ELECTRICAL POWER SYSTEMS AC SOURCES AC SOURCES - OPERATING LIMITING CONDITIONS FOR OP2 RATION 3.8.1.1 (Continued)

ACTION:

h. With one offsite circuit of the above-required AC electrical power sources inoperable and diesel generator EDG*2 inoperable, apply the requirements of ACTIONS a and d specified above.

i. With either diesel generator EDG*1 or EDG*3 inoperable and diesel generator EDG*2 inoperable, apply the requirements of ACTIONS b, d, and e specified above.

j. With one or more diesel fuel storage tank (s) containing less than the minimum quantity of fuel cil but greater than or equal to 40,755 gallons of fuel for EDG*1 and EDG*3, or greater than or equal to 30,293 gallons for EDG*2, restore fuel oil to required levels within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the affected diesel generator (s) inoperable.

k. With one or more diesel generator (s) with new diesel fuel oil properties not within limits, restore stored fuel oil properties to required limits within 30 days or declare the affected diesel generator (s) inoperable.

l. With one or more diesel generator (s) with stored fuel total particulates not within limits, restore stored fuel total particulates to required limits within 7 days or declare the affected diesel generator (s) inoperable.

SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be determined OPERABLE at least once every 7 days by verifying correct breaker alignments and indicated power availability.

4.8.1.1.2 Each of the above reouired diesel generators shall be demonstrated OPERABLE:

a. In accordance with the frequency specified in Table 4.8.1.1.2-1 on a STAGGERED TEST BASIS by:

1. Verifying the fuellevelin the day fuel tank

2. Verifying the fuellevelin the fuel storage tank.

NINE MILE POINT - UNIT 2 3/4 8-4 Amendment No.

. ELECTRICAL POWER SYSTEMS AC SOURCES AC SOURCES - OPERATING SURVEILLANCE REQUIREMENTS 4.8.1.1.2.a (Continued) l

3. Verifying each fuel transfer pump starts and transfers fuel from the storage system to the day fuel tank.

4. Verifying that on a start from ambient conditions:

a) That diesel engines EDG*1 and EDG*3 accelerate to at least 600 rpm in less than or equal to 10 seconds.* The generator voltage and frequency shall be 4160 416 volts and 60 i 3.0 Hz within 10 seconds and 41601416 volts and 60 1.2 Hz within 13 seconds after the start signal.

b) That diesel engine EDG*2 accelerates to at least 870 rpm and at least 3750 volts in less than or equal to 10 seconds.* The generator voltage and frequency shall be 4160 i 416 volts and 60 1.2 Hz within 15 seconds after the start signal.

c) Each diesel generator shall be started for this test by using one of the following signals:

1) Manual.

2) Simulated loss of offsite power by itself.

3) Simulated loss of offsite power in conjunction with an ESF actuation test signal.

4) An ESF actuation test signal by itself.

5. Verifying that after the diesel generator is synchronized, it is loaded to greater than or equal to 4400 KW for diesel generators EDG*1 and EDG*3 and greater than or equal to 2600 KW for diesel generator EDG*2 in less than or equal to 90 seconds

• and operates with these loads for at least 60 minutes.

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

• All diesel generator starts for the purpose of this surveillance test may be preceded by an engine prelube period. Further, all surveillance tests, with the exception of once per 184 d-ys, may also be preceded by warmup procedures and may also include gradual loading c recommended by the manufacturer so that the mechanical stress and wear on the dss .' engine is minimized.

NE Mid PO,sT - UNIT 2 3/4 8-5 Amendment No. [d

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. ELECTRICAL POWER SYSTEMS AC SOURCES AC SOURCES - OPERATING SURVEILLANCE REQUIREMENTS 4.8.1.1.2.a - (Continued) l ,

7. Verifying the pressure in diesel generator air start receivers for EDG*1 and EDG*3  !

to be greater than or equal to 225 psig.  !

8. Verifying the pressure in diesel generator air start receivers for EDG*2 to be greater ,

than or equal to 190 psig.

b. By removing accumulated water:

1. From the day tank at least once per 31 days and after each occasion when the  :

dieselis operated for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and i

2. From the storage tank at least once per 31 days.  !

c. By verifying fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program, i

d. Deleted. l l

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i NINE MILE POINT - UNIT 2 3/4 8-6 Amendment No.

. ELECTRICAL POWER SYSTEMS AC SOURCES AC SOURCES - SHUTDOWN LIMITING CONDITIONS FOR OPERATION 5

3.8.1.2 As a minimum, the following AC electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and '

b. Diesel generator EDG*1 or EDG*3, and diesel generator EDG*2 when the HPCS system is required to be OPERABLE, with usch diesel generator having:

1. Separate day fuel tank.s containing a minimum of 403 gallons of fuel for EDG*1 l (Division 1) and EDG*3 (Division ll) and 282 gallons for EDG*2 (HPCS-Division Ill).

2. A separate fuel storage system containing a minimum of 47,547 gallons of fuel for r EDG*1 (Division 1) and EDG*3 (Division 11) and 35,342 gallons of fuel for EDG*2 (HPCS-Division Ill). i l

3. Two fuel oil transfer pumps.

l APPLICABILITY: OPERATIONAL CONDITIONS 4,5, and *.

ACTION:

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a. With less than the the above required AC electrical power sources OPERABLE, suspend CORE ALTERATIONS, handling of irradiated fuelin the secondary containment, operations  ;

with a potential for draining the reactor vessel and crane operations over the spent fuel '

storage pool when fuel assemblies are stored therein. In addition, in OPERATIONAL CONDITION 5, with the water level less than 22 feet 3 inches above the reactor pressure vessel flange, immediately initiate corrective action to restore the required power sources to OPERABLE status as soon as practical.

b. With diesel generator EDG*2 of the above required AC electrical power sources inoperable, restore the inoperable diesel generator to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or declare the HPCS system inoperable and take the ACTION required by Specification 3.5.2 and 3.5.3

c. The provisions of Specification 3.0.3 are not applicable.

d. With one or more diesel fuel storage tank (s) containing less than the minimum quantity of fuel oil but greater than or equal to 40,755 gallons of fuel for EDG*1 and EDG*3, or greater than or equal to 30,293 gallons for EDG*2, restore fuel oil to required levels within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the affected diesel generator (s) inoperable.

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• When handling irradiated fuel in the secondary containment.

I NINE MILE POINT - UNIT 2 3/4 8-13 Amendment No.

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. ELECTRICAL POWER SYSTEMS l AC SOURCES l

AC SOURCES - SHUTDOWN LIMITING CONDITIONS FOR OPERATION 3.8.1.2 (Continued)

e. With one or more diesel generator (s) with new diesel fuel oil properties not within limits, I restore stored fuel oil properties to required limits within 30 days or declare the affected diesel generator (s) inoperable,

f. With one or more diesel generator (s) with stored fuel total particulates not within limits, restore stored fuel total particulates to required limits within 7 days or declare the affected die:,el generator (s) inoperable.

SURVEILLANCE REQUIREMENTS 4.8.1.2 At least the above required AC electrical power sources shall be demonstrated OPERABLE per Surveillance Requirements 4.8.1.1.1, 4.8.1.1.2, and 4.8.1.1.3, except for the requirement of 4.8.1.1.2.a.5.

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NINE MILE POINT - UNIT 2 3/4 8-13a Amendment No.

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. ELECTRICAL POWER SYSTEMS BASES AC SOURCES. DC SOURCES. AND ONSITE POWER DISTRIBUTION SYSTEMS 3/4.8.1-3 (Continued) list. Continued plant operation is limited to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with diesel generator EDG*1 or EDG*3 inoperable. The term " verify" as used in this context means to administratively check by examining logs or other information to determine if certain 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.

When a diesel generator becomes inoperable due to any cause other than proplanned maintenance or testing, there is a requirement in the ACTION to, for each OPERABLE diesel generator separately, either verify that the'cause of the diesel generator being inoperable does not impact the OPERABILITY of the OPERABLE diesel generator or perform Surveillance Requirement 4.8.1.1.2.a.4. The term verify in this context means to determine by visual inspection, functional test or other means that the subsystem will perform its function. For diesel generators made by different manufacturers, this verification may consist of a determination that the cause cannot exist if the comparable subsystem is of a different design.

The OPERABILITY of the minimum specified AC and DC power sources and associated distri-bution systems during shutdown and refueling ensures that (1) the facility can be maintained in the shutdown or refueling condition for extended time periods and (2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

1 The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of RG 1.9, " Selection of Diesel Generator Set Capacity for i Standby Power Supplies," December 1979; RG 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977; and RG 1.137, " Fuel-Oil Systems for Standby Diesel Generato:s," Revision 1, October 1979.

The Diesel Fuel Oil Testing Program describes the sampling and test methods for assuring that l new and stored fuel are of the appropriate grade and not contaminated with substances that i would be detrimental to the operation of the diesel generators. The test, limits, and applicable l ASTM Standards for fuel are as follows-  !

1. New Fuel

a. Sample the new fuel oil in accordance with ASTM D4057-81 before addition to the storage tanks;

b. Verify in accordance with the tests specified in ASTM D975-81, before adidition to the storage tanks, that the sample has an API gravity of within 0.3 degrees at 60oF !

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 60/600F of 20.83 and so.'89 (or an API specific gravity at 600F of 227 and s39), a kinematic viscosity at 40*C of 21.9 centistokes and 54.1 centistokes, and a flash point of 2125'F; and

c. Verify before addition to the storage tanks that the new fuel oil has a clear and bright appearance when tested in accordance with ASTM D4176-82.

NINE MILE POINT - UNIT 2 B3/4 8-2 Amendment No. IN

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. ELECTRICAL POWER SYSTEMS  !

BASES l AC SOURCES. DC SOURCES. AND ONSITE POWER DISTRIBUTION SYSTEMS 1 l

3/4.8.1-3 (Continued) '

d. Verify within 31 days after addition to the storage tanks that the other properties specified in Table 1 of ASTM D975-81 are met for new fuel 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.

2. Stored Fuel 1

a. At least once every 31 days sample fuel oil in the storage tanks in accordance with l ASTM D2276-78, and verify in accordance with ASTM D2276-78, Method A, that total particulate concentration is less than 10 mg/l.

The Surveillance Requirements for demonstrating the OPERABILITY of the unit batteries are in accordance with the recommendations of RG 1.129, " Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Standard 450-1980, "lEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage on float charge, connection resistance values, and the performance of battery service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates, and compares the battery capacity at that time with the rated capacity.

Table 4.8.2.1-1 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage, and specific gravity. The limits for the designated pilot cells float voltage and specific gravity, greater than 2.13 volts and 0.015 below the manufacturer's full-charge specific gravity or a battery charger current that had stabilized at a low value,is characteristic of a charged cell with adequate capacity. The normal limits for each connected cell for float voltage and specific gravity, greater than 2.13 volts and not more than 0.020 below the l manufacturer's full-charge specific gravity with an average specific gravity of all the connected cells not more than 0.010 below the manufacturer's full-charge specific gravity, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8.2.1-1 is permitted for up to 7 days. During this 7-day period: (1) the l allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than 0.020 below the manufacturer's recommended full-charge specific gravity ensures that the decrease in rating will be less than the safety margin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than 0.040 below the manufacturer's full-charge specific gravity and that the overall I capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability to l perform its design function. l NINE MILE POINT - UNIT 2 B3/4 8-3 Amendment No. $/, dd, dd

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. ELECTRICAL POWER SYSTEMS BASES 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES Primary containment electrical penetrations and penetration conductors are protected by either de-energizing circuits not required during reactor operation or demonstrating the OPERABILITY of primary and backup overcurrent protection circuit breakers by periodic surveillance. The list of primary containment AC circuits required to be doenergized is contained in administrative  !

procedure NIP DES-04 and revisions will be processed in accordance with Section 6.0, i Administrative Controls. l l

The Surveillance Requirements applicable to lower voltage circuit breakers provides assurance of breaker reliability by testing at least one representative sample of each manufacturer's brand of circuit breaker. Each manufacturer's molded case and metal case circuit breakers are grouped l into representative samples which are then tested on a rotating basis to ensure that all breakers j are tested. If a wide variety exists within any manufacturer's brand of circuit breakers,it is  ;

necessary to divide that manufacturer's breakers into groups and treat each group as a separate I type of breaker for surveillance purposes.

The emergency lighting system overcurrent protective devices ensure that a failure of the non- l Class 1E portion of the circuit will not affect the operation of the remaining portions of the Class  :

1E circuits that are necessary for safe shutdown. The list of these overcurrent protective devices ]

is contained in administrative procedure NIP-DES-04 and revisions will be processed in ,

accordance with Section 6.0, Administrative Controls. l The EPAs provide Class 1E isolation capabilities for the RPS power supplies and the scram power supplies. This is required because the power supplies are not Class 1E power supplies.

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NINE MILE POINT - UNIT 2 B3/4 8-4 Amendment No. dd

. ADMINISTRATIVE CONTROLS PROCEDURE AND PROGRAMS PROGRAMS 6.8.4 (Continued) l

e. Diesel Fuel Oil Testina Proaram t

! A diesel fuel oil testing program to implement required testing of both new fuel oil and f stored fuel oil shall be established. The program shallinclude sampling and testing

! requirements, and acceptance criteria, all in accordance with applicable ASTM Standards.

l The purpose of the program is to establish the following:

1. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

a. an API gravity or an absolute specific gravity within limits,

o. a flash point and kinematic viscosity within limits, and

c. a clear and bright appearance;

2. Other properties for ASTM fuel oil are within limits within 31 days following addition to storage tanks; and

3. Total particulate concentration of the fuel oil is < 10 mg/l when tested every 31 days in accordance with ASTM D-2276, Method A.

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NINE MILE POINT - UNIT 2 6-17a Amendment No.

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l ATTACHMENT B NIAGARA MOHAWK POWER CORPORATION l LICENSE NO. NPF-69 l DOCKET NO. 50-410 j i

Sucoortina information and No Slanificant Hazards Consideration Analysis l l

Introduction i The present NMP2 Technical Specifications regarding diesel generator fuel oil result in the diesel I generator (s) being declared inoperable if fuel oil supplies fall below specified minimums for any reason. Similarly, the diesels must be declared inoperable if the fuel oil sample test results fall )

outside the limits specified in the Surveillance Requirements. The improved Standard Technical I Specifications (NUREG-1434) allow time to restore the fuel levels to required minimums without I declaring the diesel generator (s) inoperable. They also provide sufficient time for further i evaluation, resampling and re-analysis of the fuel oil, and restoration of stored fuel oil properties j to within specified limits.

Niagara Mohawk proposes to change the minimum quantity of fuelin the day tanks and in the fuel storage tanks to reflect updated calculations of fuel consumption rates and amend the  !

wording of the existing Technical Specifications to adopt the wording of the improved Standard i Technical Specifications. The fuel oil properties specified in the Surveillance Requirement section will be relocated to the Technical Specification Bases and the Diesel Fuel Oil Testing '

Program will be described in the Administrative Controls section of the Technical Specifications.

This relocation will permit the sampling and testing program to be revised as necessary to incorporate revisions to the applicable ASTM standards and to address the requirements of the .

Environmental Protection Agency, specifically 40CFR80.29, regarding diesel fuel oil. Changes to the Technical Specification Bases will be controlled in accordance with 10CFR50.59 l requirements. l Descriotion of Chanaes Current version of 3.8.1.1.b.1., 2., and 3. and 3.8.1.2.b.1., 2., and 3.:

1. Separate day fuel tanks containing a minimum of 409 gallons of fuel for EDG*1 (Division I

1) and EDG"3 (Division 11), and 282 gallons for EDG'2 (HPCS-Division Ill),

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2. A separate fuel storage system containing a minimum of 52,664 gallons of fuel for EDG"1 (Division 1) and EDG"3 (Division ll), and 36,173 gallons for EDG'2 (HPCS-Division Ill), and

3. Two fuel oil transfer pumps.

Proposed version of 3.8.1.1.b.1., 2., and 3. and 3.8.1.2.b.1., 2., and 3.:

1. Separate day fuel tanks containing a minimum of 403 gallons of fuel for EDG*1 (Division

1) and EDG'3 (Division ll), and 282 gallons for EDG'2 (HPCS-Division lil),

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2. A separate fuel storage system containing a minimum of 47,547 gallons of fuel for EDG'1 (Division 1) and EDG'3 (Division 11), and 35,342 gallons for EDG'2 (HPCS-Division lil), and i l

3. Two fael oil transfer pumps. i Proposed additions to 3.8.1.1 (3.8.1.2) ACTION:

j(d). With one or more diesel fuel storage tank (s) containing less than the minimum quantity of fuel oil but greater than or equal to 40,755 gallons of fuel for EDG'1 and EDG'3, or '

greater than or equal to 30,293 gallons for EDG'2, restore fuel oil to required levels within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the affected diesel generator (s) inoperable.

k(e). With one or more diesel generator (s) with new diesel fuel oil properties not within limits, restore stored fuel oil properties to required firnits within 30 days or declare the affected diesel generator (s) inoperable.

l(f). With one or more diesel generator (s) with stored fuel total particulates not within limits, restore stored fuel total particulates to required limits within 7 days or declare the affected diesel generator (s) inoperable.

Current version of 4.8.1.1.2.c

c. By sampling new fuel oil in accordance with ASTM D4057-81 before addition to the storage tanks and:

1. By verifying in accordance with the tests specified in ASTM D975-81 before addition to the 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 60/600F, 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 or equal to 0.89 or an API gravity 60 F of greater than or equal to 27 degrees but less than or equal to 39 degrees, b) A kinematic viscosity at 40 C of greater than or equal to 1.9 centistokes, but less than er equal to 4.1 centistokes,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.

2. By verifying within 31 days of obtaining the sample that the other propertios 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.

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l Proposed version of 4.8.1.1.2.c

c. By verifying fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

Current version of 4.8.1.1.2.d l

d. At least once per 31 days by obtaining a sample of fuel oil from the storage tanks in accordance with ASTM D2276-78, and verifying that total particulate contamination is less than 10 mg/ liter when checked in accordance with ASTM D2276-78, Method A.

Proposed version of 4.8.1.1.2.d

d. Deleted. (The current Surveillance Requirement of 4.8.1.1.2.d will be performed as indicated in Surveillance Requirement 4.8.1.1.2.c through the Diesel Fuel Oil Testing Program as detailed in Bases 3/4.8.1-3.)

Proposed addition to Bases 3/4.8.1-3 The Diesel Fuel Oil Testing Program describes the sampling and test methods for assuring that new and stored fuel are of the appropriate grade and not contaminated with substances that would be detrimental to the operation of the diesel generators. The test, limits, and applicable ASTM Standards for fuel are as follows:

1. New Fuel

a. Sample the new fuel oil in accordance with ASTM D4057-81 before addition to the storage tanks;

b. Verify in accordance with the tests specified in ASTM D975-81, before addition to the storage tanks, that the sample has an API gravity of within 0.3 degrees at 60*F or a specific gravity of within 0.0016 at 60/60oF, when compared to the suppliers certificate or an absolute specific gravity at 60/60 F of 20.83 and s0.89 (or an API specific gravity at 60 F of 2 27 and s39), a kinematic viscosity at 40 C of 21.9 centistokes and $4.1 contistckes, and a flash po;nt of 21250F; and

c. Verify before addition to the storage tanks that the new fuel oil has a cleat and bright appearance when tested in accordance with ASTM D4176-82.

d. Verify within 31 days after addition to the storage tanks that the other properties specified in Table 1 of ASTM D975-81 are met for new fuel when tes'.ed in accordance with ASTM D975-81, except that the analysis for sulfur snay be performed in accordance with ASTM D1552,79 or ASTM D2622 82.

2. Stered Fuel

a. At least once every 31 days sample fuel oil in t'ne storage tanks in accordance with ASTM D2276-78, and verify in accordance with ASTM D2276-78, Method A, that total particulate concentration is less than 10 mg/l.

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l Proposed addition to Administrative Controls Section 6.8.4

e. Diesel Fuel Oil Testina Procram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shallinclude sampling and testing requirements, and acceptance criteria, allin accordance with applicable ASTM Standards.

The 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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1. an API gravity or an absolute specific gravity within limits, l

2. a flash point and kinematic viscosity within limits, and  !

3. a clear and bright appearance:  !

b. Other properties for ASTM fuel oil are within limits withm 31 days following addition to storage tanks; and

c. Total particulate concentration of the fuel oil is < 10 mg/l when tested every 31 l days in accordance with ASTM D 2276, Method A.

Evaluation  !

l The' diesel generators are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to emergency safety feature systems in design basis accidents and analyzed transients. A sufficient supply of fual oil is required for seven days of operation for each diesel generator. This requirement,in conjunction with the ability to obtain replacement supplies within seven days, supports the availability of the diesel generators. The minimum quantities of fuel have been revised to reflect updated calculations of  ;

fuel consumption rates. Existing storage requirements were based on the diesel generators running for seven days at their rated capacity. The calculations which determined the proposed -

storage requirements are based on the time-dependent loads of the diesel generators during design basis events. Regulatory Guide 1.137, Fuel Oil Systems for Standby Diesel Generators, accepts the use of calculations based on time-dependent loads to determine fuel oil storage  ;

requirements. Certain circumstances may cause the fuel oil levels to drop below the seven-day limit. These circumstances may be caused by events such as: full load operation required after i an inadvertent start while at the minimum required level; or feed and bleed operations that may ['

be necessary to correct particulate levels or other oit quality degradations. This proposed change allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is sufficient to complete restoration of the required level prior to declaring the diesel generator inoperable, ,

This period is acceptable based on the remaining fuel oil capacity (> 6 days), initiating the process for procuring additional fuel, and the low probability of an event occurring during this i brief period.  !

The fuel oil is required to meet specific standards for quality. New fuelis tested for water and  !

sediment content, kinematic viscosity, specific gravity (or API gravity) and impurities prior to l

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adding the fuel to the storage tank . Failure to meet any of these requirements is cause for rejecting the fuel, but does not represent a failure to meet the Limiting Condition for Operation since the fuel has not been added to the storage tank. Within 31 days after addition to the storage tanks (versus 31 days after the initial sample as required by the ITS), the fuelis tested for the other properties specified by ASTM D975-81. The 31-day period is acceptable because the fuel oil properties of interest, even if not within stated limits, would not have an immediate effect on diesel operation. If the balance of these tests are not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to re-test the stored fuel oil to determine that the new fuel oil, when mixed with the previously stored fuel oil, remains acceptable or to restore the stored fuel oil properties.

This restoration may involve feed and bleed procedures, filtering, or a combination of these procedures. Even if a diesel generator start and load was required during this time interval and the fuel oil properties (i.e., those properties not required to be checked prior to adding fuel to the ,

storage tank) were outside limits, there is a high likelihood that the diesel generator would still be capable of performing its intended function.

The test for clear and bright appearance has been revised to delete the test for proper color.

The color is not an indicator of fuel quality. It may, however, be an indicator of fuel type. The EPA has recently required the use of a red dye to indicate non-highway high sulfur diesel fuel oil.

Nuclear industry consultants have requested that the EPA exempt diesel fuel used for emergency generators at nuclear power stations from this requirement. Deleting the "with proper color" from the surveillance requirement will allow the plant to respond to the final rule issued by the EPA without a subsequent revision to the Bases.

Fuct oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. Poor sample techniques (bottom sampling), contaminated sampling equipment, and errors in laboratory analysis can produce errors. The presence of particulate does not result in the failure of the fuel oil to burn properly in the engine, but it does cause an increase in wear.

This will result in increased maintenance and will eventually affect the availability of the diesel.

Particulate concentration is unlikely to change significantly between surveillance tests. There is no mechanism that would cause a sudden change in the quality of stored fuel oil such that engine performance would be affected. Since proper engine performance has been recently demonstrated (within 31 days), it is reasonable to allow a brief period prior to declaring the associated diesel generator inoperable. The seven-day period allows sufficient time for further evaluation, (esampling, and re-analysis of the fuel oil. It also allows time for corrective action if required.

The current Nine Mile Point Unit 2 surveillance requirements for diesel fuel oil are based upon GE-Standard Technical Specifications (NUREG-0123, Revision 3) as modified based on a report prepared for the Standardized Nuclear Power Plant System, " Surveillance Requirements for Emergency Diese! Fuel Oil Systems in Nuclear Power Plants," dated September 23,1983. This report made specific recommendations for surveillance testing based on petroleum industry practices and available test methods. Since that time new ASTM standards have been developed and there have been some revisions to the old standards. Most significant, however, is the Environmental Protection Agency's (EPA) amendment of 40CFR80.29, " Fuels and Fuel Additives." This amendment requires the addition of a dye to high sulfur diesel fuels. The addition of the dye affects the " clear and bright" test in the current Technical Specifications Surveillance Requirement. By relocating the details of the fuel oil test program to the Bases, as suggested by the improved Standard Technical Specifications (NUREG-1434), Niagara Mohawk will be able to revise the test program to incorporate improvements in technology and to address Page 5 of 7

. l l

l EPA requirements without the burden of a Technical Specification amendment. Revisions to the l Technical Specification Bases will be performed in accordance with 10CFR50.59 and applicable plant procedures. This relocation does not reduce the testing requirements necessary to ensure fuel oil quality. The process for evaluating changes from the ASTM testing methods currently specified to newer ASTM test methods will ensure that the new methods have sufficient j accuracy to assure that the fuelis acceptable for use in emergency diesel generators.

A description of the Diesel Fuel Oil Testing Program will be added to Administrative Controls  !

Section 6.8.4. Adding a description of the Program to the Technical Specifications will assure l adequate program control. This change is administrative in nature and is consistent with the  ;

other proposed changes. I Conclusion The revised minimum quantities of fuelin the day tanks and storage tanks are justified by revised calculations for fuel oil consumption. The allowance of a limited time to restore the diesel fuel oil levels is justified since the 48-hour limit does not affect the short-term operability '

of the dien,! 9enerators. The allowance of a limited time to restore diesel fuel oil properties to acceptable limits is justified since these limits do not affect the short-term operability of the diesel genarators. These limits, if exceeded, may have an impact on the wear and maintenance of the diesels. The 30-day limit on new fuelis justified because the long-term storage of the fuel oil will not be significantly affected during this period. Relocation of the testing requirements to the Bases is justified since this is essentially an administrative change and does not result in the use of lower quality diesel fuel. Adding a description of the Program to the Technical Specifications will assure adequate program control. Therefore, thcre is reasonable assurance that the operation of Nine Mile Point Unit 2 in the proposed manner will not endanger the public health and safety.

10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10CFR50.92 concerning the issue of no significant hazards consideration. Therefore,in accordance with 10CFR50.91, the following analysis has been performed:

The operation of Nine Mile Point Unit 2. In accordance with the proposed amendment, will not involve a sianificant increase in the orobability or consecuences of an accident oreviousiv gyaluated.

The diesel generators are not initiators or precursors to an accident previously evaluated. The  ;

diesel generators are required to provide onsite power to safe shutdown loads as assumed in the accident analysis. Therefore, the proposed changes to the diesel generator fuel oil specifications cannot significantly affect the probability of a previously evaluated accident. i The proposed change to the minimum required diesel generator fuel oil levels is based on updated calculations of fuel consumption rates. Because the updated calculations assume a lower consumption rate, the nc: minimum fuel oil levels are lower but still assure that a seven-day fuel oil capacity i: avnable. Accordingly, the proposed change has no effect on the operation of the diesel generator. The proposed change to allow 48-hours to restore diesel generator fuel oil to the minimum required level does not affect short-term diesel generator operability and is acceptable based on the remaining fuel oil capacity (> 6 days), initiating the process for procuring additional fuel and the low probability of an event requiring a diesel Page 6 of 7 l___

generator during this interval. Also, the proposed allowance of a limited time to restore diesel fuel oil properties to required limits will not affect the short-term operability of the diesel generator. Even with minor degradation of the fuel oil properties, the diesels will start and perform their intended function. Relocation of the testing requirements to the bases and adding a description of the Diesel Fuel Oil Testing Program to the Administrative Control section are administrative changes. The diesel fuel oil will continue to be sampled and tested in a manner to assure its quality. In summary, the changes will not adversely affect the performance or the ability of the diesel generators to perform their intended function. Therefore, the proposed changes will not significantly increase the consequences of an accident previously evaluated.

The operation of Nine Mile Point Unit 2. In accordance with the oronosed amendment, will not create the nossibility of a new or different kind of accident from any accident oreviously evaluated.

The proposed changes will revise the minimum required diesel generator fuel oil levels and l requirements associated with diesel generator fuel oil properties. The changes do not introduce any new accident precursors and do not involve any alterations to plant configurations which could initiate a new or different kind of accident. The proposed changes do not affect the short-term operability of the diesel generator. In addition, the operability ref the diesel generators is assured by periodic testing and preventive maintenance. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The operation of Nine Mile Point Unit 2. In accordance with the cronosed amendment, will not involve a sinnificant reduction in a marain of safety.

Safety margins are established through safety analyses. These analyses assume that at least one diesel generator will start and load whenever offsite power is lost. The proposed change to the minimum required diesel generator fuel oil levels is based on updated calculations of fuel consumption rates. The updated calculations use the guidance delineated in Regulatory Guide 1.137 which is based on time-dependant loads of the diesel-generators during design basis events. Calculations based on time dependent loads result in new minimum fuel oil levels which are lower. This change has no effect on the operation of the diesel generator or on a margin of safety. The allowance of a limited time to restore the fuel oil levels, or to analyze and restore fuel oil properties to required limits, is justified since the short term operability of the diesel generators is not affected. Relocation of the fuel oil testing requirements to the Bases does not affect the quality of the fuel oil. The 10CFR50.59 process will assure that future changes to the Bases will maintain the current margins of safety, and that the diesel fuel oil will continue to be sampled and tested in such a manner as to assure its quality. Adding a description of the Diesel Fuel Oil Testing Program to the Administrative Control section of Technical Specifications are administrative. Therefore, the diesel generator will continue to operate as analyzed and there will not be a significant reduction in a margin of safety.

The proposed changes are further justified in that they are consistent with the requirements of the improved Standard Technical Specifications (NUREG-1434).

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