NLS2023045, Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program

Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program

ML23319A419
Person / Time
Site:	Cooper
Issue date:	11/15/2023
From:	Dia K Nebraska Public Power District (NPPD)
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NLS2023045
Download: ML23319A419 (1)

Text

H Nebraska Public Power District

Always there when you need us" 50.90 NLS2023045 November 15, 2023 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Nebraska Public Power District is submitting a request for an amendment to the Technical Specifications (TS) for Cooper Nuclear Station.

The proposed amendment would modify TS by relocating reference to specific American Society for Testing and Materials standards for fuel oil testing to licensee-controlled documents. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS page marked up to show the proposed change. Attachment 3 provides the revised (clean) TS page. provides proposed TS Bases pages, for information only, that are consistent with TSTF-374 and will be implemented concurrent with the approved TS amendment.

Approval of the proposed amendment is requested by November 15, 2024. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments made in this submittal.

The proposed TS change has been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this application, with attachments, is being provided to the designated State of Nebraska Official.

If you should have any questions regarding this submittal, please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at (402) 825-5416.

COOPER NUCLEAR STATION 72676 648A Ave/ P.O. Box 98 / Brownville, NE 68321 http://www.nppd.com

NLS2023045 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.

ExecutedOn: 10@2,3 Date Site Vice President

/dv Attachments: 1. Description and Assessment

2. Proposed Technical Specifications Change (Mark-up)

3. Revised Technical Specifications Page

4. Technical Specifications Bases Pages - Information Only cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/ attachments USNRC-CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Li censure NPG Distribution w/ attachments CNS Records w/ attachments

NLS2023045 Page 1 of 4 Attachment 1 Description and Assessment Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 1.0 Description 2.0 Assessment 2.1 Applicability of TSTF-374 and Published Safety Evaluation 2.2 Optional Changes and Variations 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 Environmental Evaluation 5.0 References

NLS2023045 Page 2 of 4

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) by relocating reference to specific American Society for Testing Materials standards for fuel oil testing to licensee-controlled documents.

The change is consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-374 Revision 0. The availability of this TS improvement was published in the Federal Register on April 21, 2006 (71 FR 2073 5), as part of the consolidated line-item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability ofTSTF-374 and Published Safety Evaluation Nebraska Public Power District (NPPD) has reviewed TSTF-374 (Reference 1), and the NRC model safety evaluation (SE) (Reference 2) as part of the CLIIP. NPPD has concluded that the information in TSTF-374, as well as the SE prepared by the NRC staff are applicable to Cooper Nuclear Station (CNS) and justify this amendment for the incorporation of the changes to the CNS TS.

2.2 Optional Changes and Variations NPPD is proposing the following variations from the TS changes described in TSTF-374 or the applicable parts of the NRC staffs safety evaluation. These variations do not affect the applicability of TSTF-374 or the NRC staffs safety evaluation to the proposed license amendment.

TSTF-374 makes two changes to the TS. The first change is to add "or a water and sediment content within limits" to the acceptability criterion TS 5.5.9.a.3. This statement was previously included in the CNS TS when CNS converted to the Standard Technical Specifications format in Amendment 178 (Reference 3), therefore, is not necessary to add with this request. The second change is to relocate the reference to AS TM D22 76 which is the purpose of this license amendment request. ASTM D2276 is already referenced in the TS Bases for Surveillance Requirement 3.8.3.3. This difference does not affect the applicability ofTSTF-374 to the CNS TS.

TSTF-374 states, "ASTM D5452 supersedes ASTM D2276" for the determination of particulate concentrations. ASTM D2276-1989, Method A, is still an industry approved appropriate methodology and therefore, the proposed change in TS Bases SR 3.8.3.3 discussion of particulate concentrations will retain ASTM D2276-1989, Method A, and add ASTM 5452-2023 to allow the use of either method. This is consistent with the Comanche Peak license amendment request, dated August 10, 2005 (Reference 4), approved by the NRC on July 28, 2006 (Reference 5). The proposed change will assure that the required quality of Diesel

NLS2023045 Attachment 1 Page 3 of 4 Generator fuel oil is maintained. This does not affect the applicability ofTSTF-374 to the CNS TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Nebraska Public Power District (NPPD) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the consolidated line-item improvement process. NPPD has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Cooper Nuclear Station and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3 .2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 21, 2006 (71 FR 20735) for this TS improvement, plant-specific verifications were performed as follows:

NPPD has proposed TS Bases consistent with TSTF-374, which provide guidance and details on how to implement the new requirements. In addition, NPPD has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.

4.0 ENVIRONMENTALEVA LUATION 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, Rev 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, Rev 0, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FRN 9179, February 22, 2006. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c)(9). Therefore, pursuant to 10 CFR 5 l .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0

• REFERENCES

1. TSTF-374, Revision 0, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil"

2. NRC Model Safety Evaluation (Federal Register 71 FR 9179)

3. Letter to Nebraska Public Power District, from NRC, dated July 31, 1998, "Conversion to Improved Technical Specifications for the Cooper Nuclear Station - Amendment No. 178 to Facility Operating License No. DPR-46 (TAC No. M98317)

NLS2023045 Page 4 of 4

4. Letter to U.S NRC, from TXU Power, dated August 10, 2005, "License Amendment Request (LAR)05-003 Revision to Technical Specification (TS) 5.5.13, "Diesel Fuel Oil Testing Program" (ML052280310)

5. Letter to TXU Power, from NRC, dated July 28, 2006, "Issuance of Amendments RE:

Revision to Technical Specification 5.5.13, "Diesel Fuel Oil Testing Program" (TAC NOS.

MC8161 and MC8162)"

NLS2023045 Page 1 of2 Attachment 2 Proposed Technical Specifications Change (Mark-up)

Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Page 5.0-14

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 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 in 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:

1. An API gravity or an absolute specific gravity within limits,

2. A kinematic viscosity or Saybolt viscosity, when required, and a flash point within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or a water and sediment content within limits;

b. Within 31 days following addition of the new fuel oil to storage tanks verify the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and

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

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing Frequencies.

5.5.10 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

1. A change in the TS incorporated in the license; or (continued)

Cooper 5.0-14 Amendment No.

NLS2023045 Page 1 of2 Attachment 3 Revised Technical Specifications Page Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Page 5.0-14

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 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 in 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:

1. An API gravity or an absolute specific gravity within limits,

2. A kinematic viscosity or Saybolt viscosity, when required, and a flash point within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or a water and sediment content within limits;

b. Within 31 days following addition of the new fuel oil to storage tanks verify the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and

c. Total particulate concentration of the fuel oil is s 10 mg/I when tested every 31 days.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing Frequencies.

5.5.10 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

1. A change in the TS incorporated in the license; or (continued)

Cooper 5.0-14 Amendment No.

NLS2023045 Page 1 of 4 Attachment 4 Technical Specifications Bases Pages - Information Only Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Pages B 3.8-34 B 3.8-35 B 3.8-37

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) inventory equivalent to a 7 day supply is 504 gallons and is based on a 3 gallon per hour consumption value for the run time of the DG. Implicit in this SR is the requirement to verify that adequate DG lube oil is stored onsite to ensure that sump level does not drop below the manufacturer's recommended minimum level.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.3.3 The tests of new fuel oil prior to addition to the storage tanks 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 the sample (and corresponding test results) including receipt of new fuel and addition of new fuel oil to the storage tanks to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

a. Sample the new fuel oil in accordance with ASTM D4057-1988 (Ref. 8);

b. Verify in accordance with the tests specified in ASTM D975-1989a (Ref. 8) that: (1) the sample has an API gravity of within 0.3° at 60°F or a specific gravity of within 0.0016 at 60/60°F, when compared to the supplier's certificate, or the sample has an absolute specific gravity at 60/60°F of~ 0.83 and s 0.89 or an API gravity at 60°F of~ 26° and s 38° when tested in accordance with ASTM D1298-2012b (Reapproved 2017) £ 1 ; (2) a kinematic viscosity at 40°C of~ 1.9 centistokes and s 4.1 centistokes, or a Saybolt viscosity at 100°F of~ 32.6 ands 40.1 if gravity was not determined by comparison with the supplier's certification; and (3) a flash point of~ 125°F; and

c. Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176-1991 (Ref. 8) or a water and sediment content of s 0.05% volume when tested in accordance with ASTM D1796-1983 (Ref. 8).

Cooper B 3.8-34 xx/xx/xx

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

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.

Following the initial new fuel oil sample, the new fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-1989a (Ref. 8) are met for new fuel oil when tested in accordance with ASTM D975-1989a (Ref. 8), except that the analysis for sulfur may be performed in accordance with ASTM D1552-1990 (Ref. 8), GF-ASTM D2622-1992 (Ref. 8), or ASTM D4294-2021 (Ref. 8). These additional analyses are required, by Specification 5.5.9, "Diesel Fuel Oil Testing Program," to be performed within 31 days following addition of new fuel oil. This 31 day requirement is intended to assure that:

a. The new fuel oil sample is taken no more than 31 days old at the time of adding the new fuel oil to the DG storage tank; and

b. The results of the new fuel oil sample are obtained within 31 days after addition of the new fuel oil to the DG storage tank.

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, mostly due to oxidation. The presence of particulate does not mean that 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 D2276-1989 (Ref. 8), Method A or ASTM D5452-2023 (Ref. 8).

+fHS---These methods involves a gravimetric determination of total particulate concentration in the fuel oil and ha-shave a limit of 10 mg/I. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. For the Cooper Nuclear Station design in which the total volume of stored fuel oil is contained in two interconnected tanks, each tank must be considered and tested separately.

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.

Cooper B 3.8-35 xx/xx/xx

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES REFERENCES (continued)

8. ASTM Standards: D4057-1988E1; D975-1989a; D1298-2012b (Reapproved 2017Y:1; D4176-1991; D1796-1983; D1552-1990; D2622-1992; D4294-2021; D2276-1989; and D5452-2023.

9. NEDC 11-072, DGSA Accumulator Sizing Basis Cooper B 3.8-37 xx/xx/xx