ML20086A618

License Amend Request 91-008 to License NPF-87,correcting DG Fuel Oil Surveillance Requirements in TS 4.8.1.1.2d.1(b) to Verify That Kinematic Viscosity for New Fuel Oil Samples Be Conducted at 40 C

ML20086A618
Person / Time
Site:	Comanche Peak
Issue date:	11/11/1991
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086A620	List: ML20086A618 ML20086A625
References
TXX-91411, NUDOCS 9111190264
Download: ML20086A618 (7)

Text

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Log # TXX-91411 File # 916 (3/4.8) a== h Ref. # 10CFR50.90

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10CFR50.91 3:_ _:3 10CFR50.92 TUELECTRIC November 11, 1991 Wilitam J. Cahill, Jr.

Gunp % rrentew U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHr PEAK STEAH ELECTRIC STATION (CPSES) - UNIT 1 DOCKET NO. 50-445 LICENSE AMENDHENT REQUEST (LAR)91-008 REVISED DIESEL FUEL OIL KINEMATIC VISCOSITY TEST TEMPERATURE Gentlemen:

Pursuant to 10CFR50.90. Texas Utilities Electric Company (TV Electric) hereby requests an amendment to its Operating License 8. s. NPF-87 by incorporating the attached proposed change to the Technical Spect.ication for Comanche Peak Steam Electric Station (CPSES) Unit 1.

The proposed change corrects the diesel generator fuel oil surveillance requirements specified in the Technical Specification 4.8.1.1.2d.1)b) to verify that the kinematic viscosity for the new fuel oil samples be conducted at 400C (in lieu of 400F) in accordance with ASTH-0975-1981 prior to addition to the storage tanks.

TU Electrir. nas reviewed the attached proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazards consideration. The basis for this determination is provided in Attachment 2.

For administrative purposes, it is requested that the approval transmittal for this proposed amendment include a seven day implementation period following the date of issuance.

In accordance with 10CFR50.91(b). TV Electric is providing the State of Texas a copy of this proposed amendment.

Sincerely, William J. C iill. Jr.

MCP/gj

• O 91111tNQ64 911111 PDR f4 DOCK 05000443 fAI P PDR 400 N. Ouve Street LB. 81 Dallas, Texas 75201 q

l, TXX-91401 Page 2 of 2 Attachments: 1. Affidavit

2. Significant Hazards Consideration Evaluation (10CFR50.92)

3. Proposed Technical Specification 1

c - Mr. R. D. Hartin, Region IV Resident inspectors, CPSES (2)

Mr. T. A. Bergman, NRR Hr. D. K. Lacker Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin Texas 78704 l

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Attachment 1 to TXX-91411 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Texas Utilities Electric Company ) Docket No. 50 445

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(Comanche Peak Steam Electric )

Station, Unit 1) )

AFFIDAVil William J. Cahill, Jr. being duly sworn, hereby deposes and says that he is Group Vice President, Nuclear of TV Electric, that he is duly authorized to sign and file witn the Nuclear Regulatory Commission this transmittal of License Amendment Request 91-008: that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

I William J. Cahil1[/Jr. Group Vice President, Nucl STATE OF TEXAS )

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COUNTY OF DALLAS }

Subscribed and sworn to before me, a Notary Public, on this 8th day of November , 1991.

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/t tary Public (V

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Attach:ent 2 to TXX 91411 Page 1 of 4 l

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l ATTACHMENT 2 TO TXX 91411 SIGNIFICANT HAZARDS CONSIDERATION REVISED DIESEL FUEL OIL KINEMATIC VISCOSITY TEST TEMPERATURE i

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Attachment 2 to TXX-91411 Page 2 of 4

! SIGNIFICANT HAZARDS CONSIDERATION PROPOSED CPSES UNIT 1 TECHNICAL SPECIFICATION CHANGES l

REVISED DIESEL FUEL OIL KINEMATIC VISCOSITY TEST TEMPERATURE

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Pursuant to 10CFR50.92. TV Electric has evaluated the proposed amendment to the CPSES Unit 1 Technical Specifications and has determined that operation of the facility in acordance with the proposed amendment would not involve significant hazards considerations. In accordance with the three factor test I

of 10CFR50.92(c), implementation of the proposed change would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility of a new or ditferent kind of I

accident from any accident previously evalutated, or; 3) involve a significant reduction in the margin of safety.

DESCRIPTION OF PROPOSED CHANGE:

The proposed change will correct the typographical error in the surveillance requirement for the kinematic viscosity testing of Emergency Diesel Generator fuel oil samples. This test is performed before adding the new fuel to the storage tanks. The kinematic viscosity test should be conducted at 400C in lieu of 40uf as stated in the present CPSES Technical Specification. The

! value in the present Technical Specifications (400F) does not meet the l requirements of ASTM D975-1981.

The specific surveillance of concern is 4.8.1.1.2d.1)b). Except for changing I the units of measurement, the surveillance remains unchanged. l DETAILED DISCUSSION OF THE PROPOSED CHANGE.;.

TU Electric is required by the Technical Specification 4.8.1.1.2d.1) to test the diesel fuel cil in accordnace with ASTM D975-1981 prior to tne addition of the diesel fuel oil to the storage tank. As part of this testing, the viscosity of the fuel oil is determined as either kinematic viscosity at 400C or saybolt viscosity at 1000F, These viscosities are comparable per ASTM D2161. All of the Diesel Generator fuel oil currently in the fuel

• l storage tank has been tested at 4000. The chemistry procedures and the

! Technical Specification, describing the fuel testing were written to be in acordance with the ASTM guidelines. The Technical Specification, which should have been written to be in accordance with the ASTM, has a typographical error l in that it requires the kinematic viscosity test at 40 degree F in lieu of 40 l degree C.

All of the diesel generator fuel oil on site has been tested in accordance with the ASTM guidelines because it was tested per site chemistry procedures.

The fact that the Technical Specification description of this tsst is not in

-accordance with the ASTM does not render the testing invalid. Since the saybolt viscosity acceptance criteria is also provided and the test data is directly convertable to the saybolt scale, Technical Specification compliance l has been maintained. This change (from 400F to 400C) will make the l Technical Specification consistent with the ASTM 0975-1981 as required by 4.8.1 1.2d.1).

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Attachment 2 to TXX-91411 Page 3 of 4 SIGNITICANT HAZARDS CONSIDERATION FVALUATION PER 10CFR50.92 TV Electric has evaluated the no significant hazards considerations involved with the proposed change by focusing on the three standards set forth in 10CFR50.92(c) as discussed below:

Does the proposed cnange:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change corrects the typographical error for the kinematic viscosity test temperature from 400F to 4000. This change will not increase the probability of an accident previously evaluated. In addition, no design, material or construction changes are included in this activity. Thus, no changes have been proposed which affect the probability or consequences of an accident.

(2) Create the possibility of a new or different kind of accident from any accident previously ealuated?

The proposed change does not alter any hardware, material or construction.

Although the temperature of the kinematic viscosity test for the diesel fuel oil is revised, no new failure modes are created for any components, systems or structures. As such, no new accidents are created from any accident previously evaluated.

(3) Involve a significant reduction in the margin of safety?

The proposed change do not impact the margin of safety. In fact, the proposed change makes Technical Specification consistent with the standard Technical Specification, site chemistry procedures, and ASTM D975-1981 guidelines. The fact that all the diesel fuel oil stored at site was tested as pe' site chemistry procedures and ASTM 0975-1981 guidelines leads TU Electric to the conclusion that this proposed change does not involve a significant reduction to the margin of safety.

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The commission has provided some guidance concerning the application of the

. standards for determining whether a significant hazards consideration exists, l by providing certain examples (48 FR 14370) of amendments that are considered not likely to involve a significant hazards consideration. Example (vii) relates to a change that constitutes a minor change to the facility operations clearly in keeping with tha regulations.

, Attachment 2 to TXX-91411'  !

Page 4 of 4 l 1

I In this case, the proposed change described above is similer to example (vii) in that changing kinematic viscosity test temperature from 400F to 4000 for the diesel fuel oil constitutes a minor change to the facility and l maintains consistency with the regulations. The change is considered minor in nature because the change corrects a typographical error and that makes the Technical Specification consistent with ASTM 0975-1981 which is a basis for the existing CPSES design, testing, operation and licensing.

l Based on the above evaluations, TU Electric concludes that the activities I associated with the above described change satisfies the no significant hazards consideration standards of 10CFR50.92(c) and, accordingly, a no significant hazards consideration finding is justified.

ENVIRONMENTAL EVALUATION TU Electric has evaluated the proposed change and has determined that the t

change does not involve (1) a significant hazards consideration, (ii) a -  ;

significant changes in the types or significant increase in the amounts of any  ;

effluents that may be released offsite, or (iii) a significant increase in i individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categnrical exclusion set l forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), an  ;

environmental assessment of the proposed change is not required.

REFERENCES

1. ASTM-0975-1981

2. ASTH-D2161-1987 i

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