RS-08-111, Supplemental Information Related to Application for Technical Specification Change TSTF-374, Revision to TS 5.5.9 for Diesel Fuel Oil Using Consolidated Line Item Improvement Process

Supplemental Information Related to Application for Technical Specification Change TSTF-374, Revision to TS 5.5.9 for Diesel Fuel Oil Using Consolidated Line Item Improvement Process

ML082520209
Person / Time
Site:	Clinton
Issue date:	09/05/2008
From:	Benyak D AmerGen Energy Co, Exelon Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-08-111
Download: ML082520209 (15)

Text

{{#Wiki_filter:AmerGen Energy Company, LLC www .exeloncorp_com erG An Exelon Company 4300 Winfield Road Warrenville, IL 60555 10 CFR 50.90 RS-08-111 September 5, 2008 U .S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Supplemental Information Related to Application for Technical Specification Change TSTF-374, Revision to TS 5.5 .9 for Diesel Fuel Oil Using Consolidated Line Item Improvement Process

Reference:

Letter from Darin M . Benyak (AmerGen Energy Company, LLC) to U . S . Nuclear Regulatory Commission, "Application for Technical Specification Change TSTF-374, Revision to TS 5 .5.9 for Diesel Fuel Oil Using Consolidated Line Item Improvement Process," dated September 27, 2007 In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," AmerGen Energy Company, LLC (AmerGen) is providing additional information in support of its request for an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1 . In the referenced letter, AmerGen proposed a modification to the TS that relocates references to specific American Society for Testing and Materials (ASTM) standards for fuel oil testing to licensee-controlled documents . During a phone call on August 26, 2008, the NRC technical reviewer requested that AmerGen provide additional information in support of his review of the referenced letter . Specifically, the reviewer requested that AmerGen provide supplemental information to address why the CPS TS Bases were not revised to reflect the proposed Bases changes documented in Technical Specification Task Force (TSTF) Traveler No. 374 (i .e., TSTF-374). In the referenced letter, AmerGen did not include any changes to the CPS Bases, as AmerGen had previously revised the CPS Bases to address diesel fuel oil testing through the CPS TS Bases Control Program. Therefore, AmerGen did not propose to make the TSTF-374 identified Bases changes. To support the NRC review of the referenced letter, AmerGen is providing the following information as attachments to this letter . Attachment 1 provides a marked-up version of NUREG-1434, "Standard Technical Specifications General Electric Plants, BWR/6," Revision 3 .1, to document the differences between the TSTF-374 version and CPS version of the TS Bases sections . Revision 3 .1 of NUREG-1434 was used for this comparison since it includes

September 5, 2008 U . S. Nuclear Regulatory Commission Page 2 the changes to the TS Bases associated with TSTF-374. Where differences were noted, item numbers were assigned . These item numbers are displayed in dashed text boxes in the left margin of the document, and the associated justifications for the differences are provided in Table 1 . These justifications describe why the CPS version is acceptable . Attachment 2 to this letter provides Table 1 . As shown in Attachment 1 and documented in Table 1, CPS is proposing to perform particulate contamination testing in accordance with ASTM D6217-98, "Standard Test Method for Particulate Contamination in Middle Distillate Fuels by Laboratory Filtration ." Therefore, a markup of the CPS TS Bases is provided in Attachment 3 to this letter to document this proposed change. The TS Bases pages are provided for information only, and do not require NRC approval . The information provided in this letter does not affect the No Significant Hazards Consideration, or the Environmental Consideration provided in Attachment 1 of the original license amendment request as described in the referenced submittal . There are no regulatory commitments associated with the changes proposed by this request. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819 . I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of September 2008 . Darin Benyak Director - Licensing and Regulatory Affairs AmerGen Energy Company Attachments :  : Markup of NUREG-1434, Revision 3.1, TS Bases Section SR 3.8.3.3 : Table 1 : Comparison Between NUREG-1434, Revision 3 .1, and CPS TS Bases : Mark-up of CPS Technical Specifications Bases Pages (For Information Only)

ATTACHMENT 1 Markup of NUREG-1434, Revision 3.1, Technical Specifications Bases SR 3.8.3.3 Pages 3 .8 .3-6 3 .8 .3-7 3 .8.3-8

Diesel Fuel Oil, Lube Oil, and Starting Air B 3 .8.3 BASES SURVEILLANCE REQUIREMENTS (continued) 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 D40574951

                 ? 30° and          (Ref . 6);
                 <_ 38°, and Verify in accordance with the tests specified in AST                           D1298-99 (Ref. 6) that the sample has the tests specified in                       and 5 0-.83-of an API gravity at 60°F of ASTIVI D975-06b                              in accordance wi                                    a kinematic (Ref. 6) that the                    viscosity at 40°C of z 1 . centistokes and s 41     . centistokes ; and a sample has                                                                                                        93 (Ref. 6)

These additional c. Verify that the new fuel oil has a clear and bright appearanc ith analyses are proper color when tested in accordance with ASTM D4176 i .or a < 0 05 v/o required by en tested in accordance)=-- wlthHnQ iw (Mci~m Isc--- .___ A TMa6b Specification 5 .5 .9, - D975-I v4 A UU-n ii Diesel Fuel Oil Failure to meet any of the above limits is cause for rejecting the new fuel Testing Program, oil, but does not represent a failure to meet the LCO since the fuel oil is to be performed not added to the storage tanks . within 31 days Y following sampling i ' 1 Ia Ilowing the initial new fuel oil sample, the fuel oil is and addition, This analyzed to establish that the other properties specified in Table 1 of ASTM D975-{06b} (Ref . 6) are met for new fuel oil when tested in 31 days is intended accordance with ASTM D975-[06b} (Ref . 6Y, to assure: 1) that IIthe sample taken is 9 The 31 day period is not more than 31 acceptable because the fuel oil properties of interest, even if not within 'days old at the time stated limits, would not have an immediate effect on DG operation. This of adding the fuel Surveillance ensures the availability of high quality fuel oil for the DGs. oil to the storage Fuel oil degradation during long term storage shows up as an increase in tank, and 2) that particulate, mostly due to oxidation . The presence of particulate does not the results of a new mean that the fuel oil will not burn properly in a diesel engine . However, fuel oil sample the particulate can cause fouling of filters and fuel oil injection equipment, (sample obtained which can cause engine failure . prior to addition but not more than 31 days prior to) are obtained within 31 days after addition . BWR/6 STS B 3 .8.3-6 Rev. 3 .0, 03/31/04

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8 .3 BASES SURVEILLANCE REQUIREMENTS (continued) Particulate concentrations should be determined in accordance with 4; ASTI ~Ref. 6). This method involves a gravimetric D6217-98 ination of total particulate concentration in the fuel oil and has a limit of 10 mg/I. It is acceptable to obtain a field sample for subsequent With regard to fuel oil laboratory testing in lieu of field testing. property values obtained pursuant to this SR, as read from plant indication The Frequency of this Surveillance takes into consideration fuel oil instrumentation, the degradation trends indicating that particulate concentration is unlikely to specified limit is change between Frequency intervals . considered to be a nominal value and therefore does not SR 3 .8.3.4 require compensation for instrument This Surveillance ensures that, without the aid of the refill compressor, indication sufficient air start capacity for each DG is available . The system design uncertainties (Ref . 9). requirements provide for a minimum of five engine start cycles without recharging. [A start cycle is defined by the DG vendor, but usually is measured in terms of time (seconds of cranking) or engine cranking speed.] The pressure specified in this SR is intended to reflect the lowest value at which the [five] starts can be accomplished . The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure . SR 3.8.3 .5 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 storage tanks once every 31 days 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 from breakdown of the fuel oil by bacteria . BWR/6 STS B 3 .8.3-7 Rev . 3.0, 03/31/04

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) 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 (Ref . 2). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of the Surveillance . REFERENCES Section {9.5.4}.

2. Regulatory Guide 1 .137 .

3. ANSI N195, Appendix B, 1976.

AR 0 4. Chapter {6}. USAR D6217-98 . 5:~ Chapter {15} .

6. ASTM Standards : D4057495};`D975-{06b}; D4176493};

7. ASME, Boiler and Pressure Vessel Code, Section XI .

8 . Calculation IP-0-0120 . 9 . Calculation IP-0-0121 . 10 . Calculation IP-0-0122 . 11 . Calculation IP-C-0111 . BWR/6 STS B 3.8.3-8 Rev. 3 .0, 03/31/04

ATTACHMENT 2 Table 1 : Comparison Between NUREG-1434, Revision 3.1, and CPS TS Bases

Table 1 : Comparison of TSTF-374 Technical Specifications (TS) 3.8.3 Bases Wording to the Clinton Power Station Wording and Justification of Differences Item Section NUREG-1434 Version CPS Version Differences Justification The CPS version contains no CPS fuel consumption and stored discussion of sampling for volume calculations are based on absolute specific gravity. API gravity, so this option is Additionally, the order that the Verify in accordance with the specified for Surveillance ASTM Standards are discussed tests specified in ASTM D975-[ ] Verify in accordance with the Requirement (SR) 3.8 .3 .b is reversed in CPS version . The (Ref. 6) that the sample has an tests specified in ASTM D1298- monitoring rather than the absolute discussion of the use of ASTM absolute specific gravity at 99 (Ref. 6) that the sample has specific gravity option . Compliance D1298-99 for determining API 60/60°F of z 0 .83 and 5 0.89 or an API gravity at 60°F of z 30° is assured by the current CPS SR gravity precedes the discussion an API gravity at 60° F of a 27° and :5 38°, and in accordance version through testing of API

            .3.b.                                                                         of the tests specified by ASTM and :5 39° when tested in           with the tests specified in ASTM D975[                               gravity in accordance with ASTM BBases                                                                                      - ]. The CPS version accordance with ASTM D1298-[ ]      D975-06b (Ref . 6) that the                                          D1298-99 within a more restrictive contains a more-restrictive (Ref . 6), a kinematic viscosity at sample has a kinematic viscosity acceptable API Gravity band         range than the TSTF version 40°C of a 1 .9 centistokes and 5    at 40°C of >_ 1 .9 centistokes and                                   specifies . The acceptance criteria than the specifications listed in 4.1 centistokes, and a flash point  5 4.1 centistokes ; and                                              for flash point is contained within the TSTF-374 version of this of z 125°F, and                                                                                          Table 1 of ASTM D975-06b, and section . Lastly, the CPS version was therefore, not included in the does not contain a discussion of CPS TS Bases. Consequently, the the acceptance criteria for flash CPS version is acceptable.

point. Verify that the new fuel oil has a Verify that the new fuel oil has ASTM D975-06b, "Standard clear and bright appearance with clear and bright appearance with Specification for Diesel Fuel Oils," is proper color when tested in proper color when tested in The CPS version references the a parent document that specifies a SR accordance with ASTM D4176-[ ] accordance with ASTM D4176- use of ASTM D975-06b versus test methods and acceptable limits

       .8 . .3 .c.

or a water and sediment content 93 (Ref. 6), or a water and ASTM D2709-[ ] as shown in for diesel fuel oil. As ASTM D2709

   '  B ase s Bases within limits when tested in        sediment content <_ 0.05 v/o       Insert 3 of TSTF-374 .            is the approved referee method accordance with [ASTM D2709-[       when tested in accordance with                                       specified in ASTM D975-06b, the
                   )) (Ref. 6).                        ASTM-D975-06b .                                                      current CPS version is acceptable.

Item Section NUREG-1434 Version CPS Version Differences Justification Following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-06b (Ref. 6) are met for Within 31 days following the new fuel oil when tested in initial new fuel oil sample, the accordance with ASTM D975-fuel oil is analyzed to establish ASTM D975-06b is a parent p6b (Ref. 6). These additional that the other properties document that specifies test analyses are required by specified in Table 1 of ASTM methods and acceptable limits for Specification 5 .5.9, Diesel Fuel D975-[ ] (Ref. 6) are met for new diesel fuel oil. Note B at the top of Oil Testing Program, to be fuel oil when tested in Table 1 in ASTM D975-06b states, performed within 31 days accordance with ASTM D975-[] "The test methods indicated are the following sampling and addition . The CPS version contains no (Ref. 6), except that the analysis approved referee methods . Other This 31 days is intended to discussion of Sulfur analysis ,~ . . ; for sulfur may be performed in acceptable methods are indicated in assure : 1) that the sample taken according to ASTM D1522-[ ], 3* SR 3.8.3.3 accordance with ASTM D1522-[ 4.1 ." Section 4 .1 .8 includes is not more than 31 days old at ASTM D2622-[ ], or ASTM-

""               J, ASTM D2622-[ J, or ASTM                                                                                acceptable methods for testing for the time of adding the fuel oil to  D4294-[ ], as shown in Insert 4 D4294-[ ] (Ref. 6). The 31 day                                                                            sulfur, depending on fuel grade .

the storage tank, and 2) that the of TSTF-374. period is acceptable because the ASTM D1552, ASTM D2622, and results of a new fuel oil sample fuel oil properties of interest, ASTM D4294 are included in the list (sample obtained prior to addition even if not within stated limits, of methods that may be used. As but not more than 31 days prior would not have an immediate these methods are already included to) are obtained within 31 days effect on DG operation . This in ASTM D975-06b, no change is after addition . The 31 day period Surveillance ensures the necessary for compliance . is acceptable because the fuel oil availability of high quality fuel oil properties of interest, even if not for the DGs. 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. Page 2 of 4

Item Section NUREG-1434 Version CPS Version Differences Justification ASTM D5452 (as referenced in the TSTF-374 Bases markup) and its predecessor D2276 were developed for aviation fuel testing. ASTM D975-06b, Section 2 .1, references Particulate concentrations should ASTM D6217, Standard Test be determined in accordance Method for Particulate with ASTM D5452-[ ] (Ref. 6). Contamination in Middle Distillate Particulate concentrations should This method involves a Fuels by Laboratory Filtration . The gravimetric determination of total be determined in accordance diesel fuel oil utilized by CPS is a with ASTM D6217-98. This particulate concentration in the middle-distillate-type fuel . method involves a gravimetric The CPS version contains no fuel oil and has a limit of 10 mg/l

                                              .                                                                       Accordingly,    and as shown in the determination of total particulate mention of ASTM D5452-[ ] .

SR 3.8.3.3 It is acceptable to obtain a field attached markup of the CPS TS " 4- concentration in the fuel oil and CPS proposes the use of ASTM Bases sample for subsequent Bases, CPS is proposing the use of has a limit of 10 mg/l . It is D6217-98 for the determination laboratory testing in lieu of field ASTM D6217-98 as a current and acceptable to obtain a field of particulate concentration . testing. [For those designs in appropriate method of testing for sample for subsequent which the total volume of stored particulate contamination in Diesel laboratory testing in lieu of field fuel oil is contained in two or Fuel Oil, and in lieu of ASTM testing . more interconnected tanks, each D5452 . As discussed in Paragraph tank must be considered and 1 .1 of ASTM D6217-98, the test tested separately.] methodology covers the determination of the mass of particulate contamination in middle distillate fuels by filtration, and is suitable for all No. 1 and No. 2 fuel oil grades described in ASTM D975. Page 3 of 4

Item Section NUREG-1434 Version CPS Version Differences Justification 1 . USAR, Section 9 .5 .4 . The referenced methods : ASTM

2. Regulatory Guide 1 .137. D1552, D2622, D2709, and D4294

3. ANSI N195, Appendix B, 1976 .

1 . FSAR, Section [9.5.4] . are included in ASTM D975-06b,

4. USAR, Chapter 6.

2 . Regulatory Guide 1 .137. The CPS version lists ASTM which is the parent document for

5. USAR, Chapter 15 .

3 . ANSI N195, Appendix B, 1976. D6217-98 and the NUREG- diesel fuel oil referenced in the Bases 6. ASTM Standards : D4057-95 ; 4 . FSAR, Chapter [6] . 1434 version does not . The current CPS version . As noted Section D1298-99 ; D975-06b ; D4176-93 ; pnw ., 5 . FSAR, Chapter [15]. NUREG-1434 version lists above, and in the provided markup 3.8.3 D6217-98 . References 6 . ASTM Standards : D4057-[ ]; ASTM D1552, D2622, D2709, of the CPS TS Bases, ASTM D6217

7. ASME, Boiler and Pressure D975-[ ]; D1298-[ ]; D4176-[ ] ; D4294, and D5452, while the 98 is the appropriate test Vessel Code, Section XI . CPS version does not .

[D2709-[ ] ;] D1552-[ ] ; D2622-[ ]; methodology for particulate 8 . Calculation IP-0-0120 . D4294-[ ] ; D5452-[ ]. contamination, and an acceptable

9. Calculation IP-0-0121 . equivalent of ASTM D2276 and

10. Calculation IP-0-0122 . D5452 .

11 . Calculation IP-C-0111 . Page 4 of 4

ATTACHMENT 3 Markup of CPS Technical Specifications Bases Pages (For Information Only) 3.8-46 3 .8-47 3 .8-48a

This page provided for information only and contains no markups . Diesel Fuel Oil, Lube Oil, and Starting Air B 3 .8 .3 BASES SURVEILLANCE SR 3 .8 .3 .3 (continued) REQUIREMENTS tests listed in the Diesel Fuel Oil Testing Program of Specification 5 .5 .9 are as follows :

a. Sample the new fuel oil in accordance with ASTM D4057-95 (Ref . 6) ;

b. Verify in accordance with the tests specified in ASTM D1298-99 (Ref . 6) that the sample has an API gravity at 60 °F of >_ 30 ° and <_ 38 ° , and in accordance with the tests specified in ASTM D975-06b (Ref . 6) that the sample has a kinematic viscosity at 40 °C of ? 1 .9 centistokes and S 4 .1 centistokes ; and

c. Verify that the new fuel oil has clear and bright appearance with proper color when tested in accordance with ASTM D4176-93 (Ref . 6), or a water and sediment content <_ 0 .05 v/o when tested in accordance with ASTM-D975-06b .

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 since the fuel oil is not added to the storage tanks . Following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-06b (Ref . 6) are met for new fuel oil when tested in accordance with ASTM D975-06b (Ref . 6) . These additional analyses are required by Specification 5 .5 .9, Diesel Fuel Oil Testing Program, to be performed within 31 days following sampling and addition . This 31 days is intended to assure : 1) that the sample taken is not more than 31 days old at the time of adding the fuel oil to the storage tank, and 2) that the results of a new fuel oil sample (sample obtained prior to addition but not more than 31 days prior to) are obtained within 31 days after addition . The 31 day period is acceptable because the fuel oil properties of interest, even if 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 . (continued) CLINTON B 3 .8-46 Revision No . 11-5 This page provided for information only and contains no markups,

Diesel Fuel Oil, Lube Oil, and Starting Air B 3 .8 .3 BASES SURVEILLANCE SR 3 .8 .3 .3 (continued) REQUIREMENTS 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 . However, the particulate can cause fouling of filters and fuel oil injection equipment, which can cause engine failure .

                           -             lit:~v     "es          av method involves a .-                 determination
                                    - ntration 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 .

The Frequency of this Surveillance takes into consideration fuel oil degradation trends indicating that particulate concentration is unlikely to change between Frequency intervals . With regard to fuel oil property values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref . 9) . SR 3 .8 .3 .4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available . The system design provides for multiple start attempts without recharging when pressurized above the low pressure alarm setpoint . The pressure specified in this SR reflects a value at which multiple starts can be accomplished, but is not so high as to result in failing the limit due to normal cycling of the recharge compressor . The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure . (continued) CLINTON B 3 .8- 4 7 Revision No .

Diesel Fuel Oil, Lube Oil, and Starting Air B 3 .8 .3 BASES SURVEILLANCE SR 3 .8 .3 .6 REQUIREMENTS Draining of the fuel oil stored in the supply tanks, removal of accumulated sediment, and tank cleaning are required at 10 year intervals by Regulatory Guide 1 .137 (Ref . 2), paragraph 2 .f . This SR is typically performed in conjunction with the ASME Boiler and Pressure Vessel Code, Section XI (Ref . 7), examinations of the tanks . To preclude the introduction of surfactants in the fuel oil system, the cleaning should be accomplished using sodium hypochlorite solutions, or their equivalent, rather than soap or detergents . This SR is for preventive maintenance . The presence of sediment does not necessarily represent a failure of this SR provided that accumulated sediment is removed during performance of the Surveillance . REFERENCES l. USAR, Section 9 .5 .4 .

2. Regulatory Guide 1 .137 .

3. ANSI N195, Appendix B, 1976 .

4. USAR, Chapter 6 .

5 . USAR, Chapter 15 . 6 . ASTM Standards : D4057-95 ; D1298-99 ; D975-06b ; D4176-93 ;

                              @S~~`C---- ....,._ D6217-98

7. ASME, Boiler and Pressure Vessel Code, Section XI .

8. Calculation IP-0-0120 .

9. Calculation IP-0-0121 .

10 . Calculation IP-0-0122 . 11 . Calculation IP-C-0111 . CLINTON B 3 .8- 4 8a Revision No .}}