ML20112E962

Proposed Tech Spec,Deleting Requirement That Fuel Oil Sample Be Taken from Diesel Generator Fuel Storage Tank Drain

ML20112E962
Person / Time
Site:	North Anna
Issue date:	01/08/1985
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20112E949	List: ML20112E945 ML20112E962
References
NUDOCS 8501150327
Download: ML20112E962 (4)

Text

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ELECTRIC POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying the fuel level in the day tank.

2. Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.

4. Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm in less than or equal to 10 seconds. The generator voltage and frequency shall be 4160 ! 420 volts and 60 1 1.2 Hz within 10 seconds after the start signal.

The diesel generator shall be started for this test by using one of the following signals with startup on each signal verified at least once per 124 days.

a) Manual.

b) Simulated loss of offsite power by itself.

c) Simulated loss of offsite power in conjunction with an ESF

. actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized, loaded to greater than or equal to 2750 kw in less than or equal to 60 seconds, and operates for greater than or equal to 60 minutes.

6. Verifying the diesel generator is aligned to prov,ide standby power to the associated emergency busses,

b. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified, in Table 1 of ASTM D975-74 when checked for viscosity, water and sediment.

c. At least once per 18 months during shutdown by:

1. Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its ^ manufacturer's recommendations for this class of standby service,

2. Verifying that, on rejection of a load of greater than or equal to 610 kw the voltage and frequency are maintained within 4100 2 420 volts and 60 1 1.2 Hz.

3. Verifying that the load sequencing timers are OPERABLE with times within the tolerances shown in Table 4.8-1.

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8501150327 850108 PDR ADOCK 05000339 PDR P

NORTH ANNA - UNIT 2 3/4 8-3

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, w i DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE The intent of Specification 4.8.1.1.2.b (either unit) is to require periodic 4

verificatfon that the quality of the fuel available to the emergency diesel engines compliments the operability requirements of the engines. The fuel oil systems of the station were designed and constructed to standards that were acceptable to the Commissicn. Unit I was granted a license for operation on that basis.

The additional phrase was included in the Unit 2 license as a result of a letter written by Mr. D. G. Eisenhut, January of 1980 (copy attached) that cited the failure of one station to bring fuel oil under the Quality Assurance Program. In that letter, Mr. Eisenhut indicated that Regulatory Guide 1.137,

" Fuel Oil Systems for Standby Diesel Generators", described methods acceptable to the commission staff for . complying with the Commission's regulations regarding fuel oil systems and adequacy of fuel oil quality.

Regulatory Guide 1.137 at C.2.c states that "The periodic sampling procedure for the fuel . oil should be t in, accordance with ASTM D-270-1975, " Standard Method of Sam [iling Petroleum anf ?etroleum Products."

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Station practi'ce sis to take Ma%mplas from the discharge of the transfer pumps which transfer fuel oil from thea:torage tanks to the emergency diesel engine day tanks. ., This is a valid sampfe ' point based on the as-built configuration of the station. ' ASTM D-270 defines the DRAIN sample as one which comes from the draw-off or discharge valve. Station practice utilizes the draw-off point

'of the tank with an intervening pump which ASTM D-270 does not appear to permit. .

. . .J , , Stationpracliceis,therefore,inmaterialcompliancewithASTMD-270butnot j " literal" sompliance.

• We submit Nthat the sample point used .by station practice is equally as acceptable is,the sample point identifidd as a DRAIN sample point in ASTM 4, D-270. <

We believeh therefore, that the proposed change to Unit 2 Technical Specifica-tion 4.8.lh4.Qemoves a condition of " literal" noncompliance. The proposed

, change dots *not alter the probability of, dr the consequences of a malfunction-of~ equipment'important to safety as previously evaluated in the UFSAR because it does not affset any operability fdarures of the emergency generator.

9 The proposed change' does not create the possibility of a different type of I' accident f or malfunction charvas prsicusly evaluated in the UFSAR because no physical'or operational f.eldde of tM.,3emergency diesel generator is altered.

s 4 The proposed chanFg does i not reduce the margin ot safety as described in the

' % basis section of 'any psit of the Technical Specification because it does not

.g 4 change any test frequency or quality requirement'o'f the engine or fuel. The

I 3 proposed change, therefore does not reisst an unreviewed safety question.

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