ML20207K873

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Forwards Proposed Tech Spec 4.8.1.1.2.f Re Diesel Fuel Oil Surveillance Requirements,Per 861231 Discussions. Justification & Explanation of Why Proposed Approach Preferable for Controlling Diesel Fuel Oil Chemistry Encl
ML20207K873
Person / Time
Site: Vogtle  
Issue date: 01/02/1987
From: Bailey J
GEORGIA POWER CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
GN-1280, NUDOCS 8701090549
Download: ML20207K873 (3)


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Georga Power Company Pbst Off,c] Bcx 282 Wayn storo, George 30830 Telephone 404 554 9%1 404 724-8114 Southern Company Services, Inc.

Post Office Box 2625 b

Birmingham. Alabama 35202 Telephone 205 870 6011 VOgtie Project January 2,1987 Director of Nuclear Reactor Regulation File:

X7N16 Attention:

Mr. B. J. Youngblood Log:

GN-1280 PWR Project Directorate #4 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C.

20555 NRC DOCKET NUMBER 50-424 CONSTRUCTION PERMIT NUMBER CPPR-108 V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 TECHNICAL SPECIFICATIONS

Dear Mr. Denton:

During our discussions on December 31, 1986 with your NRC staff, we proposed an approach to assuring adequate control of diesel fuel oil chemistry which, at the same time. could be reasonably implemented.

Specifically, chemistry control of the fuel oil is done in the most reasonably effective manner by sampling of the fuel oil in the storage tanks.

By having a limit on neutralization number and mercaptan content in the tank at less than the acceptable limits for those parameters, it is permissible to add a limited amount of unanalyzed diesel fuel to the storage tank with reasonshic assurance that the technical specification limits are not exceeded.

Attached is our proposed wording of the technical specification and an explanation and justification that this is a much preferred approach to controlling diesel fuel oil chemistry. We shall appreciate confirmation of the acceptability of this proposed technical specification as soon,as possible.

If your staf f requires any additional information, please do not hesitate to contact me.

Sincerely, J. A. Bailey Project Licenning Manager JAB /caa xet R. E. Conway NRC Regional Administrator R. A. Thomas NRC Resident Inspector J. E. Joine r, Esquire D. Feig 0

B. W. Churchill, Esquire R. W. McManus (w/o att.)

9, M. A. Miller (2)

L. T. Cucwa

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g\\g B. Jones, Esqui re Vogtle Project File G. Dockhold, Jr.

G701090549 070102 PDR ADOCK 05000424 h

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-s Proposed Diesel Fuel Oil Surveillance Requirement 4.8.1.1.2.f At least once per 92 days, obtain a sample and verify that the neutralization numbar is less than 0.4 and the mercaptan is less than 0.01%.*

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  • New fuel oil that has not been tested for neutralization number and mercaptan content may be added to the storage tank if the previous value for the neutralization number was found to be less than or equal to 0.25 and the mercaptan content was less than or equal to 0.007%.

The quantity of new fuel j

oil added to the storage tank will not exceed 15,000 gallons until a new sample is taken from that storage tank, i

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e Justification for Proposed Surveillance Requirement 4.8.1.1.2.f The tests for neutralization number and mercaptan content are intended to ensure that these parameters are within permissible limits for the fuel oil in the storage tanks. However, these tests are not common in the industry and the capability to perform these tests onsite does not exist. Therefore, samples must be shipped offsite for testin8 The specifications for commercial diesel fuel do not include limits in neutralization number and mercaptan content. However, it is expected that commercial diesel fuel will be well within the limits. Testing of new fuel oil prior to addition to the storage tanks would be impractical since the tank trucks would have to wait until the results of the confirmatory test results were available. Our proposed footnote to 4.8.1.1.2.f would allow the addition of new fuel as long as the neutralization number and mercaptan content from the most recent storage tank oil sample are less than or equal to 0.25 and 0.007%, respectively. For example, if a tank contained 64,000 gallons of fuel oil (tech spec limit is 68,000 gallons but this is an " indicated" value to ensure at least 64,000 gallons) with a neutralization number of 0.25 and mercaptan content of 0.007%, at least 15,000 gallons of fuel oil with a neutralization number as high as 1.0 and mercaptan content as high as 0.022%

could be added without exceeding the limits of 0.4 and 0.01%, respectively.

It is unlikely that values for these parameters as high as the above will be delivered to the site.

In addition, the potential contamination of fuel oil by the zine in the tank coating is a very slow process and the addition of fuel oil in limited quantities (even in the unlikely event of exceeding the specified limits) will not endanger operability of the diesel engines.

Therefore, our proposed specification will provide adequate margin to ensure that the limits for neutralization number and mercaptan content will not be exceeded as the result of the addition of new fuel oil to the storage tanks.

o 0971V

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