NOC-AE-20003762, Supplement to 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 Improvemen

Supplement to 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 Improvemen

ML20266H819
Person / Time
Site:	South Texas
Issue date:	09/22/2020
From:	Connolly J South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-20003762, STI: 35070184
Download: ML20266H819 (2)

Text

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Nuclear Operating Company South "fiXls Profecl Ekc/rlc Genera/Ins Station P.Q &JK 289 W.ukworth, Texas 77483 ~~~~~~~~~~~~'VVV\,--------

September 22, 2020 NOC-AE-20003762 10 CFR 50.90 STI: 35070184 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 Supplement to 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

Reference:

1. Letter; from J. Connolly to U.S. NRC Document Control Desk; "South Texas Project Units 1 & 2 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"; July 30, 2020; (NOC-AE-20003742) (ML20212L521).

In Reference 1, STP Nuclear Operating Company (STPNOC) submitted 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 supplemental information to further explain the Bases mark-up provided in Reference 1 to facilitate NRC review of the License Amendment Request.

There are no 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.

~n~

t~~~cutive VP and CNO cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington , TX 76011-4511

Enclosure:

Supplemental Information

Enclosure NOC-AE-20003762 Page 1 of 1 ENCLOSURE Supplemental Information The South Texas Project (STP) Technical Specifications and bases are custom technical specifications which differ from the Standard Technical Specifications (STS). Technical Specification Task Force (TSTF) Travelers are written generically based on STS and bases.

The NRC provided guidance in Reference 1 that requires a licensee requesting to adopt TSTF-374 to provide bases changes that would make the licensees bases consistent with the bases in TSTF-374. The STP custom technical specification bases were not consistent with the initial state of the STS bases or the markup provided in the traveler. STP provided a bases markup in Reference 2 that incorporated the initial state of the STS bases in TSTF-374 and the mark-up of the STS bases as provided in TSTF-374 to comply with the guidance specified in Reference 1.

The TSTF-374 was approved by the NRC in 2005. Since that time, American Society for Testing and Materials (ASTM) standards have changed as has the quality of Diesel Fuels delivered to Licensees. To address these changes, STP replaced ASTM D5452, which is intended for use with aviation fuels, with ASTM D6217-18, a newer standard that allows the use of less hazardous filter flushing fluids. In addition to this standard, an additional allowance for the use of ASTM D7321-18a was made for accepting biodiesel fuels up to 5% to accommodate the potential for ASTM D6217-18 filter material to partially dissolve with biodiesel containing fuels.

To accommodate higher American Petroleum Institute (API) gravity fuels that STP may receive from fuel vendors, STP performed an engineering evaluation and determined a new acceptable limit of 42° API gravity. STP applied the 50.59 process to this change, documented in CR 20-6185-8, and determined NRC prior approval was not required. The change was incorporated into the STP Diesel Fuel Oil Program. STP added an allowance for the use of ASTM D287-12b which STP currently uses to perform API gravity testing.

REFERENCES 1 Notice of Availability of Model Application Concerning Technical Specification Improvement to Revise Diesel Fuel Oil Testing Program Using Consolidated Line Improvement Process, per TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel; (ML061040356).

2 Letter; from J. Connolly to U.S. NRC Document Control Desk; South Texas Project Units 1

& 2 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; July 30, 2020; (NOC-AE-20003742)

(ML20212L521).