ML20212L521
| ML20212L521 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/30/2020 |
| From: | Connolly J South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-200037 42, STI: 35028049 | |
| Download: ML20212L521 (12) | |
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Nuclear Operating Company South TtX1.S Project Ekcbic Generatif18 Station P.Q Bak' 287 ~. Tex:as 77483 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 July 30, 2020 NOC-AE-200037 42 10 CFR 50.90 STI: 35028049 License Amendment Request to Revise Technical Specifications to Adopt TSTF-374, Revision 0, "Revision to TS 5.5.13 and associated TS Bases for Diesel Fuel Oil" Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) is submitting a request for an amendment to the Technical Specifications for South Texas Project (STP), Units 1 and 2.
The proposed amendment would modify Technical Specifications by relocating references to specific American Society for Testing and Materials (ASTM) standards for fuel oil testing to licensee-controlled Technical Specification Bases and adding alternate criteria to the "clear and bright" acceptance test for new fuel oil.
The Enclosure to this letter provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Marked-up and re-typed (clean)
Technical Specification pages are provided in Enclosure Attachments 1 and 2, respectively. A marked-up copy of the Technical Specification Bases is provided for information only in Enclosure Attachment 3.
STPNOC requests approval of the proposed license amendment by July 29, 2021. STPNOC will implement the amendment within 90 days of the NRC approval date.
In accordance with 10 CFR 50.91(b), "State Consultation," STPNOC is notifying the State of Texas of this license amendment request by transmitting a copy of this letter and Enclosure to the designated State Official. The proposed amendment has been reviewed and approved by the STPNOC Plant Operations Review Committee and has undergone an independent organizational unit review.
There are no regulatory commitments in this amendment request.
If there are any questions or if additional information is needed, please contact Nie Boehmisch at (361) 972-8172 or me at (361) 972-7344.
I declare under penalty of perjury that the foregoing is true and correct.
Enclosure:
Evaluation of the Proposed Change James Connolly Executive VP and CNO
NOC-AE-20003742 Page 2 of 2 cc:
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511
Enclosure NOC-AE-20003742 Page 1 of 3 ENCLOSURE Evaluation of the Proposed Change
Subject:
License Amendment Request to Revise Technical Specifications to Adopt TSTF-374, Revision 0, Revision to TS 5.5.13 and associated TS Bases for Diesel Fuel Oil Using the Consolidated Line Item Improvement Process 1
SUMMARY
DESCRIPTION 2
ASSESSMENT 3
REGULATORY ANALYSIS 4
ENVIRONMENTAL EVALUATION 5
REFERENCES ATTACHMENTS:
- 1.
Technical Specification Pages Markup
- 2.
Retyped Technical Specification Pages
- 3.
Technical Specification Bases Pages Markup (Information Only)
Enclosure NOC-AE-20003742 Page 2 of 3 1
SUMMARY
DESCRIPTION The proposed amendment would modify Technical Specifications by relocating references to specific American Society for Testing and Materials (ASTM) standards for fuel oil testing to the Technical Specification Bases and adding alternate criteria to the "clear and bright" acceptance test for new fuel oil.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-374 Revision 0. The availability of this Technical Specification improvement was published in the Federal Register on April 21, 2006 (71 FR 20735), as part of the consolidated line item improvement process (CLIIP).
2 ASSESSMENT 2.1 Applicability of TSTF-374, and Published Safety Evaluation STP Nuclear Operating Company (STPNOC) has reviewed TSTF-374 (Reference 5.1), and the NRC model safety evaluation (SE) in Reference 2 as part of the CLIIP. STPNOC has concluded that the information in TSTF-374, as well as the SE prepared by the NRC staff are applicable to STP Units 1 and 2, and justify this amendment for the incorporation of the changes to the STP Units 1 and 2 Technical Specifications.
2.2 Optional Changes and Variations.
STPNOC is not proposing any variations or deviations from the Technical Specification changes described in TSTF-374, Revision 0, or the NRC staff's model safety evaluation published in the Federal Register on February 22, 2006 (71 FR 9179).
STP Unit 1 and 2 Technical Specification numbering is different than Standard Technical Specifications. This is an administrative difference only. The STP Unit 1 and 2 Technical Specification for the Diesel Fuel Oil Testing Program is 6.8.3.i compared to Standard Technical Specification 5.5.13.
3 REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination STP Nuclear Operating Company (STPNOC) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.
STPNOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to STP Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Verification As discussed in the notice of availability published in the Federal Register on April 21, 2006 (71 FR 20735) for this Technical Specification improvement, plant-specific verifications were performed as follows:
STPNOC has proposed Technical Specification Bases consistent with TSTF-374, which provide guidance and details on how to implement the new requirements. In addition, STPNOC has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.
Enclosure NOC-AE-20003742 Page 3 of 3 4
ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-374, Revision 0, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-374, Revision 0, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 9179, February 22, 2006. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5 REFERENCES 5.1 TSTF-374, Revision 0, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil.
5.2 NRC Model Safety Evaluation (71 FR 9179).
5.3 NUREG-1431, Volume 2, Revision 4.0, Standard Technical Specifications Westinghouse Plants Revision 4.0 Volume 2, Bases
Enclosure NOC-AE-20003742 Technical Specification Pages Markup
6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.g (continued)
- h.
- 10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR 190. or a water and sediment Not Used content within limits Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of bo h new fuel oil and stored fuel oil shall be established. The program shall include ampling and testing requirements, and acceptance criteria, all based on applic le ASTM Standards. The purpose of the program is to establish the followi
- 1)
Acceptability of new fuel oil prior to addition to the diesel enerator fuel oil storage tanks by determining that the fuel oil has:
- a.
an API gravity or absolute specific gravity within I mits.
- b.
a flash point and kinematic viscosity within limits for ASTM 20 fuel oil, and
- c.
a clear and bright appearance with proper colo ;
- 2)
Within 31 days following addition of new fuel oil to the diesel generator fuel oil storage tanks, verify that the properties of the new fuel oil, other than those addressed in 6.8.3.i.1 above, are within limits for ASTM 20 fuel oil; and
- 3)
Total articulate concentration of fuel oil is~ 10 mg/I when tested every 31 day!U;lSiAQ::P test ffietfieel eased eA /\\STM D 2276, The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.
- j.
Containment Leakage Rate Testing Program A program shall be established to implement leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NE! 94-01 Revision 2-A, dated October 2008.
SOUTH TEXAS - UNITS 1 & 2 6-9 (contjnued)
Unit 1 - Amendment No. 47,57,68,151 Unit 2 -Amendment No. J6,46,57,13Q
Enclosure NOC-AE-20003742 Retyped Technical Specification Pages
6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.g (continued)
- 10)
Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR 190.
- h.
Not Used
- i.
Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all based on applicable ASTM Standards. The purpose of the program is to establish the following:
- 1)
Acceptability of new fuel oil prior to addition to the diesel generator fuel oil storage tanks by determining that the fuel oil has:
- a.
an API gravity or absolute specific gravity within limits,
- b.
a flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and
- c.
a clear and bright appearance with proper color or a water and sediment content within limits; 2 )
Within 31 days following addition of new fuel oil to the diesel generator fuel oil storage tanks, verify that the properties of the new fuel oil, other than those addressed in 6.8.3.i.1 above, are within limits for ASTM 2D fuel oil; and
- 3)
Total particulate concentration of fuel oil is 10 mg/l when tested every 31 days.
The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.
- j.
Containment Leakage Rate Testing Program A program shall be established to implement leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01 Revision 2-A, dated October 2008.
(continued)
SOUTH TEXAS - UNITS 1 & 2 6-9 Unit 1 - Amendment No. 47,57,68,151,210 Unit 2 - Amendment No. 36,46,57,139,197
Enclosure NOC-AE-20003742 Technical Specification Bases Pages Markup (Information Only)
ELECTRICAL POWER SYSTEMS BASES A.C. SOURCES, D. C. SOURCES, AND ONSITE POWER DISTRIBUTION (Continued)
This SR is modified by two Notes. Note 4 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 6 states that momentary transients, because of changing bus loads, do not invalidate this test.
A successful DG start under SR 4.8.1.1.2.a.2 must precede this test to credit satisfactory performance.
SR 4.8.1.1.2.b Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil tanks at a frequency found in the Surveillance Frequency Control Program eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137. This SR is for preventative maintenance. The presence of water does not necessarily represent failure of the SR, provided the accumulated water is removed during the performance of this Surveillance.
SR 4.8.1.1.2.c The requirements will be controlled and administered by the Diesel Fuel Oil Testing Program located in section 6.8.3 of Administrative Controls.
SR 4.8.1.1.2.e.1 NOT USED SR 4.8.1.1.2.e.2 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load (785.3 kW) without exceeding predetermined voltage and frequency. The frequency specified in the Surveillance Frequency Control Program is consistent with the recommendation of Regulatory Guide 1.108.
This SR is modified by two Notes. Note 4 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 5 allows the diesel start for this surveillance to be a modified start as stated in SR 4.8.1.1.2.a.2.
SOUTH TEXAS - UNITS 1 & 2 B 3/4 8-8 Unit 1 - Amendment No. 16-2176-36 Unit 2 - Amendment No. 16-2176-36 Insert 1
Insert 1 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:
- a. Sample the new fuel oil in accordance with ASTM D4057-19,
- b. Verify the sample has a specific gravity at 60/60°F of 0.815 and 0.89 or an API gravity at 60°F of 27° and 42° when tested in accordance with ASTM D287-12b or D1298-12b, a kinematic viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a flash point of 125°F in accordance with the tests specified in ASTM D975-10, and
- c. Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176-04 or a water and sediment content within limits when tested in accordance with ASTM D2709-16.
Failure to meet any of the above limits is cause for rejecting the new fuel oil but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.
Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-10 are met for new fuel oil when tested in accordance with ASTM D975-10, except that the analysis for sulfur may be performed in accordance with ASTM D1552-16, ASTM D2622-16, or ASTM D4294-16. The 31-day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high-quality fuel oil for the DGs.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.
Particulate concentrations should be determined in accordance with ASTM D6217-18. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. If B5 biodiesel fuel oil is used, particulate concentrations should be determined in accordance with ASTM D7321-18a, biodiesel may degrade the filter paper used in ASTM D6217-18.
The frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between frequency intervals.