ML062970105

Proposed Change Number (Pcn) 567 Emergency Diesel Generator Fuel Oil Volume Requirements Response to NRC Request for Additional Information

ML062970105
Person / Time
Site:	San Onofre
Issue date:	10/19/2006
From:	Katz B Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PCN 567
Download: ML062970105 (37)

Text

r i SOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONALa Company Brian Katz Vice President October 19, 2006 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 Proposed Change Number (PCN) 567 Emergency Diesel Generator Fuel Oil Volume Requirements Response to NRC Request for Additional Information San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Letter from Brian Katz (SCE) to NRC (Document Control Desk) dated June 2, 2006,

Subject:

Docket Nos. 50-361 and 50-362; Proposed Change Number (PCN) 567; Emergency Diesel Generator Fuel Oil Volume Requirements; San Onofre Nuclear Generating Station, Units 2 and 3

Dear Sir or Madam:

Southern California Edison (SCE) submitted the referenced license amendment request to increase the required amount of stored diesel fuel oil to support a change to Ultra Low Sulfur Diesel (ULSD) fuel from the California diesel fuel presently in use. Nuclear Regulatory Commission staff has subsequently requested additional information to facilitate their review of the referenced request.The SCE response to the request for information is enclosed.

This response should be considered as Supplement 1 to our PCN-567 submittal.

The No Significant Hazards Consideration and Environmental Evaluation provided with PCN-567 remain bounding.Should you have any questions or require additional information, please contact Mr. A.E. Scherer at (949) 368-7501.Sincerely, P.O. Box 128 San Clemente, CA 92674-0128 949-368-9275 Fax 949-368-9881 AtDO\

Document Control Desk-2-October 19, 2006

Enclosures:

1. Notarized affidavit 2. Licensee's Response to Request for Additional Information

3. Engineering Change Package (ECP) 040301409-3 (Description of Change)4. EMD Maintenance Instruction (MI) 1760 Rev. G, "Lubricating Oil for EMD Engines" 5. ESI letter dated 12/4101 for low Aromatic Fuels (including 1 P-94 Pointers)cc: B. S. Mallett, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Health Services, Radiologic Health Branch Enclosure I Page 1 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA)

EDISON, ET AL. for a Class 103 License to Acquire, Possess, and Use a )Utilization Facility as Part of Unit No.2 )of the San Onofre Nuclear Generating

)Station )Docket No. 50-361 Amendment Application Number 244 SOUTHERN CALIFORNIA EDISON, ET AL., pursuant to 10 CFR § 50.90, hereby submit Supplement I to Amendment Application Number 244 to Facility Operating License NPF-10.This change is a request to revise the Technical Specification required quantities of emergency diesel generator fuel oil for Ultra Low Sulfur Diesel fuel. Supplement I responds to a request for additional information.

In accordance with 10 CFR § 50.30(b), the following affirmation is provided: Brian Katz states that he is Vice President of Southern California Edison, is authorized to execute this oath on behalf of Southern California Edison and, to the best of his knowledge and belief, the facts set forth in this letter are true.Respectfully submitted, 66uoýýit:zý-Brian Katz Vice President Southern California Edison State of California County of San Diego Subscribed and sworn to (cr-afflmed) before me on this .. iL day of by'ýflo..Ia-I&it personally known to me OF person who appeared before me.Ion the hb.asisf.. ,atifaect.;

e.v.,ene.

to be the (DJ60L .JOArf#Notary Public ImDieg CoWy Enclosure I Page 2 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA)

EDISON, ET AL. fora Class103 )License to Acquire, Possess, and Use a )Utilization Facility as Part of Unit No. 3 )of the San Onofre Nuclear Generating

)Station )Docket No. 50-362 Amendment Application Number 229 SOUTHERN CALIFORNIA EDISON, ET AL., pursuant to 10 CFR § 50.90, hereby submit Supplement I to Amendment Application Number 229 to Facility Operating License NPF-15.This change is a request to revise the Technical Specification required quantities of emergency diesel generator fuel oil for Ultra Low Sulfur Diesel fuel. Supplement I responds to a request for additional information.

In accordance with 10 CFR § 50.30(b), the following affirmation is provided: Brian Katz states that he is Vice President of Southern California Edison, is authorized to execute this oath on behalf of Southern California Edison and, to the best of his knowledge and belief, the facts set forth in this letter are true.Respectfully submitted, Brian Katz Vice President Southern California Edison State of California County of San Diego Subscribed and sworn to We-effisr-4) before me on this Rik day of by 1r4L YN k -personally known to me of preeve person who appeared before me..t .. bao,.s ...........

-.vi.., to be the Notary Public'01W DAM AL FAMI COMAulan

• 1623105 Notwy Public -C011foaft SM DNW cQW0"U*MvCWmEq*wNov20,]

-NWW-W ----ý --W ENCLOSURE 2 SOUTHERN CALIFORNIA EDISON RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION PCN-667 Question 1: The June 2 application states in paragraph 4.0 on page 4 of 9 of Enclosure 2: "Both the day tanks and the storage tanks minimum diesel fuel requirements have been re-calculated with the worst case lower heating value (LHV) of the new ULSD fuel which is lower on a per gallon basis than of the existing diesel fuel. These calculations conservatively assume that the diesel fuel inventory is entirely ULSD fuel with the worst case LHV. " However, the email dated 08/15/06, in paragraph 4.1) ULSD fuel energy content, it says: "Fuel specifications provided by our current fuel vendor, ARCO, indicates that ULSD fuel has the same typical specific gravity (American Petroleum Institute, API 38) as CARB fuel. Per Att 1 in calculation M-0016-008

'DG Onsite Fuel Oil Requirements,'

diesel fuels with the same specific gravity have the same heating values." and also in paragraph 4.8) EDG performance with ULSD fuel, it states: "The EDG performance issues in Ref 2, AR011101320, addressed the change in heating value of CARB diesel fuel.As the heating value is proportional to the API gravity, the ULSD fuel has an equivalent heating value to that of CARB fuel. As a result there will not be any anticipated changes to engine performance from the introduction of ULSD fuel." Is there a contradiction here?Response Yes. There is a contradiction in what Southern California Edison (SCE) sent in the 8/15/06 e-mail, which was an early in-house evaluation.

The updated evaluation is documented in Engineering Change Package (ECP) 040301409-3 (Enclosure

3) which, while still containing the same first sentence quoted above 1 of 7 for paragraph 4.1), goes on to explain that the SCE calculation conservatively assumes that the new Ultra Low Sulfur Diesel (ULSD) fuel will have the worst case API value of 42. It is true that given the same API value, both California Air Resources Board (CARB) and ULSD fuel heating values are the same.Enclosure 3 also contains the same statement quoted above from paragraph 4.8)that "...the ULSD fuel has an equivalent heating value to that of CARB fuel," a statement which is repeated in paragraph 5), "Conclusion:" for ULSD, "...the energy content is the same as the currently used CARB fuel." These statements should be understood in the context of Reference 3 to Enclosure 3, namely, that once ULSD is in full-time refinery production, the API gravity is expected to be comparable to the CARB fuel it is replacing.

API values ranging from 30-42 are acceptable for San Onofre Nuclear Generating Station (SONGS) diesel performance.

Testing at SONGS shows that the CARB fuel API value ranges between 37-39. ARCO has stated that the new ULSD fuel API is currently ranging higher than CARB, but within specification, and is expected to levelize at values comparable to CARB once mass production of ULSD fuel is started. Not knowing for sure what the API values will be for delivered ULSD fuel in future, the SCE calculation conservatively assumes the lowest heating value (LHV) at API 42. An upper limit of API 42 is the industry standard, and is not expected to be exceeded for the ULSD fuel supplied to SONGS. In addition, the SCE calculation assumes that the diesel tanks are full of ULSD fuel, which is very conservative in the beginning.

However, in reality there will be a mixture of CARB and ULSD fuels until the whole inventory is replaced with ULSD fuel over time.As long as the API value is the same, both CARB and ULSD fuel have the same heating value. However, SCE has used API 42 as the worst case for the ULSD fuel in calculating the required inventory of diesel fuel to be conservative.

Question 2: Does the lower heat value affect the rating (4700 kW with a 0.8 pf) of the Diesel Generators (DGs)? If so, will the lower rating be sufficient to supply the peak loading of the DGs during the design basis events?Response No. Peak loading during a design basis event is less than the nominal full load rating of the Emergency Diesel Generator (EDG). See excerpt below from a previous evaluation and vendor input. Note that EDG governor response to load demands is instantaneous.

EDG Performance with CARB Fuel 2 of 7 The ability of the EDGs to control and maintain engine load is primarily a function of the engine governor control system. The heating value of the fuel burned in the engine has only a minor effect on how well the engine control system compensates for major changes in engine load. To date there have been no engine performance issues with the EDGs running on EPA clear which has almost a 3% lower heating value than diesel fuel used for factory testing. The heating value of the low aromatic CARB fuel is approximately 0.5% less than the EPA clear. Engine System Inc. (ESI)has stated (Enclosure

5) that the governor control system will adjust the fuel rack to compensate for any changes in the BTU content of the fuel and has provided a letter (Enclosure

5) endorsing the use of low aromatic fuels in our EDGs.In order to maintain the current level of performance, a very minimal increase in fuel consumption will be required.

The fuel injection system and the engine control system are fully capable of providing additional fuel supply, so that the EDGs can maintain design basis loading.Fuel rack scale ranges from 1.96 (zero fuel) to 0.62 (full fuel). Past data collection on fuel rack position during various loads (2G002 16 cylinder)are: 1.62 900 rpm idle 1.5 180 amps 1.3 320 amps 1.1 470 amps 0.93 705 amps (full EDG rated capacity of 4.7 MWe)As per calculation M-0016-008, the largest EDG load during a small break LOCA used for the determination of fuel consumption is 4.5 MW. The rack positions stated above are typical to within 0.07 of rack position for all the engines. The above data indicates that there is approximately 30% of fuel rack travel still available for increasing fuel delivery to the engine for sustained loads or transient loads. On a load increase, fuel injection will advance and start earlier for a quicker engine response.

The fuel circulating pump (attached at accessory end) provides fuel oil to the fuel injection header for combustion as well as providing excess fuel for cooling to the injectors by circulating the fuel through the injectors and fuel header. The EMD fuel system will always be able to provide enough fuel for intermittent and sustained engine load changes. EDG performance will not be compromised with the use of CARB fuel.The same argument applies for using ULSD fuel and ULSD/CARB fuel mixture, as the largest EDG load during a small break LOCA used for the determination of 3 of 7 diesel fuel consumption is 4.5 MW per Updated Final Safety Analysis Report Table 8.3.1.Question 3: Do you need the concurrence from the DG manufactures (EMD)regarding the sulfur content compatibility with the engine lubricating oil? Will the concurrence from the ULSD supplier (ARCO) suffice?Response SCE has generic concurrence from the manufacturer.

The SONGS EDGs meet engine manufacturer specifications as spelled out in Maintenance Instruction (MI)1760 Rev. G (Enclosure 4). SCE would be unable to obtain any concurrence from the fuel vendor, whoever they may be, when it comes to lube oil compatibility within a certain type of engine. Such recommendations can only be within the purview of the engine vendor, as compatibility is a function of the engine operational characteristics.

SONGS EDGs use Mobilgard 450 NC, which has a Total Base Number (TBN) of approximately 10 and the ULSD has 15 ppm of sulfur. EMD MI 1760 contains a graph, identified as Fig. 1, that indicates the SONGS EDGs are within a safe operating band for lube oil and fuel oil compatibility.

NRC Information Notice (IN) 96-67 was an example of how the interaction of incompatible lube oil and fuel oil can affect an engine. By the use of MI 1760, SCE has addressed this issue prior to adopting the use of ULSD.Below is an excerpt from previous evaluations justifying the use of CARB fuel: CARB Fuel Oil Compatibility with Engine Lubricating Oil.The introduction of low-sulfur EPA clear diesel fuel created the need for changes in some engine lubricants.

Internal combustion byproducts in the form of ash deposits in the combustion chamber area were found in some engine applications due to lower amounts of sulfur in the new diesel fuel and high amounts of alkaline reserve still in the lubricants.

Total Base Number (TBN) is used to measure the amount of alkaline reserve in lubricating oil.With high sulfur diesel fuels, a high TBN number was required to prevent the formation of corrosive acids (sulfuric acid) that could be formed as a combustion byproduct.

With a lower amount of sulfur in the diesel fuel, a corresponding decrease in TBN was needed in some diesel engines to prevent said ash deposits from forming.EMD has provided guidance on the compatibility of lubricating oils and diesel fuel oils with varying amounts of sulfur content (Enslosure 4). Lubricating oil that will be in the engine sumps at the time of converting to the CARB fuel will 4 of 7 be Mobilgard 450 NC which has a stated TBN number of 10. This TBN value meets the manufacture's recommendations for both EPA clear and CARB fuel. The manufacturer has indicated that if an imbalance between sulfur levels in the fuel and TBN in the lubricating oil exists, ash deposits will form only if the engine is run extensively.

Proper maintenance of fuel injection equipment will also reduce the likelihood of ash formation, if such an imbalance were to occur. At SONGS, we typically run the EDGs only for testing purposes and we monitor fuel injector condition under the EDG predictive maintenance program. With SONGS EDGs meeting manufacturer criteria for fuel and lubricating oil compatibility and not operating in a condition that could potentially result in forming combustion chamber ash, the implementation of CARB fuel is acceptable for this aspect of engine operation.

The same argument applies for using ULSD fuel and a ULSD/CARB fuel mixture.Question 4: Finally, the staff would like to have a supplement, under oath and affirmation, the broad contents of the email. You can say in the supplement that the following items were considered and give couple of sentences of explanation for each. These nine have been taken from your email. In addition you need to provide the responses to the above questions.

1) ULSD fuel energy content 2) ULSD fuel chemistry 3) ULSD fuel lubricity and effects on engine components

4) Conductivity of ULSD fuel 5) Compatibility of ULSD fuel with underground storage tank liner 6) Fuel transfer system components

7) ULSD compatibility with engine lubricating oil 8) EDG performance with ULSD fuel 9) Long-term storage of ULSD/CARB fuel Response SCE has considered the following items in determining the suitability of ULSD for the SONGS EDGs.1) ULSD fuel energy content SCE has considered and evaluated ULSD fuel energy content and has used the worst case Low Heating Value (LHV) associated with API 42 (upper limit) in calculating the required fuel oil inventory.

The upper limit of 5 of 7 API 42 is the industry standard and is not expected to be exceeded at SONGS. See technical considerations section 4.1 in ECP 040301409-3 (Enclosure 3).2) ULSD fuel chemistry SCE has considered and evaluated ULSD fuel chemistry and has performed necessary testing to assure SONGS meets the criteria of Technical Specification Surveillance Requirement 3.8.3.3. See technical considerations section 4.2 in ECP 040301409-3 (Enclosure 3).3) ULSD fuel lubricity and effects on engine components SCE has considered and evaluated ULSD fuel lubricity and effects on engine components and has concluded that internal engine components are not adversely affected.

See technical considerations section 4.3 in ECP 040301409-3 (Enclosure 3).4) Conductivity of ULSD fuel SCE has considered and evaluated conductivity of ULSD fuel. The acceptable ULSD fuel chemistry properties that can affect fuel handling and design of the SONGS EDG fuel system makes use of ULSD acceptable for use in the SONGS EDGs. See technical considerations section 4.4 in ECP 040301409-3 (Enclosure 3).5) Compatibility of ULSD fuel with underground storage tank liner SCE has considered and evaluated the compatibility of ULSD fuel with the underground storage tank liner and has concluded that ULSD or a mixture of ULSD and CARB fuel will not have any adverse effect on the liner, and is therefore acceptable for use and storage in the underground fuel oil storage tanks. See technical considerations section 4.5 in ECP 040301409-3 (Enclosure 3).6) Fuel transfer system components SCE has considered and evaluated fuel transfer system components and has concluded that ULSD or a mixture of ULSD and CARB fuel will not hinder the ability of the fuel transfer system components to transfer fuel oil. See technical considerations section 4.6 in ECP 040301409-3 (Enclosure 3).7) ULSD compatibility with engine lubricating oil SCE has considered and evaluated ULSD compatibility with engine lubricating oil and has concluded that the use of ULSD fuel or a mixture of ULSD and CARB fuel with SONGS EDG current lubricating oil Mobilgard 450 NC, meets the compatibility criteria in EMD Maintenance Instruction Mi 1760 (Enclosure 4). See technical considerations section 4.7 in ECP 040301409-3 (Enclosure 3).6 of 7

8) EDG performance with ULSD fuel SCE has considered and evaluated EDG performance with ULSD fuel and has concluded that heating value is proportional to the API value for both CARB and ULSD fuel and as a result there will not be any anticipated changes to engine performance from the introduction of ULSD fuel. See technical considerations section 4.8 in ECP 040301409-3 (Enclosure 3).9) Long-term storage of ULSD/CARB fuel SCE has considered and evaluated long-term storage of ULSD/CARB fuel, and a series of tests was performed, validating the conclusion that the use of ULSD or mixture of ULSD and CARB fuel will not have an impact on fuel storage practices at SONGS and poses no new diesel fuel aging issues that are not monitored in the diesel fuel oil testing program.ULSD or a mixture of ULSD and CARB is acceptable at SONGS. See technical considerations section 4.9 in ECP 040301409-3 (Enclosure 3).7 of 7 ENCLOSURE 3 ENGINEERING CHANGE PACKAGE (ECP) 040301409-3 GEC.P 040o3 014 +o3, Rtov.O0 AR 040301409:

Ultra Low Sulfur Diesel Fuel P jA. O i 4 0+ 1 Description of Change/Engineering Evaluation I I NL.u~g 1) PURPOSE The purpose of this technical evaluation is to justify the acceptability of using Ultra Low Sulfur Diesel (ULSD) fuel oil in the Emergentcy Diesel Generators at SONGS Unit 2 and 3. 'This evaluation also covers all the identified technical issues resulting from the addition (mixing) of ULSD fuel to existing California Air Resources Board (CARB)diese fuel.2) BACKGROUND SONGS converted to CARE fuel in 2002 to meet State of California emissions requirements (ef #2, AR 011101320).

CARB fuel was formulated to have a lower aromatic cotent, which has tIe effect of reducing the sulftr content in the fuel and increasing the API gravity (reducing the specifiegravity).

In June 2006, the State of Califmoia will require all diesel engines operated inihe state to be using ULSD fuel as required by Califoimia Code of Regulation Section 2281-2285.

IJLSD as the name implies is Teduceda suiftur content (nominlly 15Op;m for CARB to < or = 15ppm. for ULSD) so -ia emission particulates canbe reduced.3) PROCESS )BSCRIflON nodeviation from normal diesel fuel filling and storage operations.

State regulators only Teqie that ULSD diesel fue be in use by June 2006 and does not require cdsting inventories to be replaced.

Aa result, t&e ULSD fuel will be added to the storage tanks as needed during normal fuel inventory management activities.

4) TECHnICAL CONSIDETIONS 4.1) ULSD fuel energy contmt The conversion over to CARB fuel required a change to Technical Specification 3.8.3 (PC1-531) for incrtased requirements due to the reduoed Lower Heating Value (LUV) of the CARB fueL Fuel specifications provided by our current fuel vendor, ARCO, idicates that ULSD fae has the same typical specific gravity (Americaf Petroleum Institute, API 38) as CARB fuel However, acceptance of ULSID fuel is based on values of API ranging from 30 to 42. The worst case heating value, based on API 42, is used in Calculation M-0016-008, Rev.3 (CN A41549) and M-0016-006, Rev.1 (ECN A41735). This calculationTesults shows that theinimum storage volume is inc.ased in both the day tank and the storage tank compared to what is in the Technical Specification.

A PCN567 has be=* repared and will be issued to NRC for approval.-

Since we are increasing thie minimum volume on coiservative side, we can implement the increased volume srv'lanee by administrative means until we received NRC appmval.040301409-3 E-CP o4o3oI4ol-3, po.f'z24 Per oir current fuel vendor ARCO, the current che=ical formulation of UILSD and a t .&%16%k(M CARB are identical with the only different property being a reduced level of sulfur " content in ULSD (Ref 1). Variations in specific gravity or variations in fuel quality, thlmally induced volumetric changes, atmospheric conditiomn, engine wear etc. and their efftet on diesel fuel consumption are captured in the 10% additional fuel margin maintain.

in Ihe storage tanks per ANSI N195-1976/ANS 59.5 1.4.2) ULSD fuel chemiitry SONGS is required to meet the criteria of Tech Spec 3.8.3.3 for estab.shing whether diesel fuelto be used in the EDGsi s ofthe appropriate grade and does not contain contammnts fa could be detrimental to engine performance.

Tech Spec Basis 3.9.3.3 basis criteria for fuel chemistry artbased on the fuel properties specfied inTable 1 of ASTM I975-91, API gravity per ASTM D287-92, and particulates per ASTM 2276-83.VLSD fuel, treated (with stabilizer and biocide) and untreated used in the liner soak test (see section 4.5) was tested at Satyolt Las for compliance with s0123-M-6.6, "Diesel Fuel Oil Testing Program".

All of the fuel test results were within the specifications of S0123-fII-6.6, and the results were consistent with new CARB fuel currently delivered to.SONGS. Results also indicate that there is no differncebetween treated and mtreated..ful stabilizer and biocide ad by SONGS). Comprehnve esn ults on BCD fuel (ECD is Emission Control Diesel and is a trademark name for ULSD from ARCO our curremt fuel supplier) as tested at Say1oolt Labs are in AR 030600847-03.

The table below is a comparison of atypical sample of CAR3 fuel (see ref 1) and treated ULSD after being used in the liner soak tests and indicalwlhat no dcanges to the SONGS current diesel fuel oil program are warranted.

Test Limit Metitod CO~B fwl EMD Fuel LUnit water And ASTh(D1796 SUMO5 Sediment.0%

ova __ __Jinematic ASTMD445 1-9 -4.1 Viscoity 2.45E 7-642 ParicualeAS7WD2276, 0.6 ng1 cm~ 1mf Conlamination 93A API Gravit AS7hMD287-2 39539.7 30O-42 Flash Point ASIM D93 1447 .150 F 21 I'Cloud Point AS7h(D2300

+147 20 F DislWion ASIM D)86 WIT .' 624 F 540- 6140*w Ash ASTMD492 -<0.001 wta <D.001% 0.1o.10wW.

Carbon Residue ASTMD524 Mom8 o11%2 040301409-3 EC-P 040301tog-sowtio pcaga 3 4 2 Test Limit M)etod CARB fae BCD Fuel Limit (10% bottoms)Sulfur ASTM D4294 0.017 wt% <0.015% sO.30 wt/O Coppcr Strp ASTM DI30 A IA sNo. 3 Corrosion Ceame Index ASTMD976 52.0 52 z40 OcteF2t-61 1 Stabilty (not TB.S) I____________

____atA$,0r%&Q

.3 f cLy, S 4 %S 4.3) UILSD fuel lubricity and e&cts on engine components Diesel fuel in the fe system of the EDGs is used to lubricate moving parts within the fuel system and provide cooling to the fuel inj ectors. The lubricity of a given diesel fuel is directly related to 1he amount of sulfur contained in the fuel with lubricity decreasing with lower amounts of sulfur. Although sulfir content of ULSD is ten times lowv than CARB fuel, he lubridcity cracteistics of the fuel remains comparable due to a lubricity additive'being added to.the fuel during CaMlin.Code of Regulations Section 2284 Tite 13 gives minmum lubricity requirements for ULSD. In particular, the code specifies a maximum wear scar diameter of520 microns when performing lubricity tests per ASTM D 6079-2 the High Frequecy Reciprocating Rig (BFRR) test. Per ref 2, Southwest Research Institute performed this test with CARB fuel and obtained larger wear scars (.605 and .550 microns) that were evahated'by SONGS and found acceptable for SONGS EDGs. Per ASTM D)975-01 a, wear scan above 600 microns might not prevent excessive wear.ARCO las added a lubzicity specification to their L'LSD fuel. This secfication is provided to assure compIiance with minimum lubricity requirements in 1he Califonia regulations.

ARCO's specification is'a minimum of 3100g, according to ASTM test method D 6078, scufng load balloncylinder lubricity evaluator (SLBOCLE) which also allows their ULSD to meet the state requirements of 520 microns per ASTM D6079-2. The 3 1OOg value is also recognized in ASTM D 975-01a (standard specifications for diesel fuel oils) as providing sufficient lubricity in all cases. All ULSD flth SONGS will purchase is going to provide lubricity that meets or exceeds the lubricity requirements of SONGS EDGs.Nitrile elastomer sals in tb.f.d U .e canbe affected by a reduction in sulfur content in diesel fuel. The associated problems with sulfr reduction in the fuel oil are* hardening and subsequent loss of scaling capability.'This issue was addressed in Ref 2, AR 011101320, and an action to remove niarile seals in the fad system and replace them with 3 040301409-3 cp O l40301,o9-3.,fRe4.

Viton was performed.

Viton is not affecte by changes in fuel sulfur content and all seals in the SONGS EDO fual system are Viton.ULSD fuel will not have a substandard lubricity quality due to theequircments in California state law, nor can it have an adverse affect on engine eastomer seals. As a result, internal engine components in the EDGs will not be adversely affected and no further testing of the fuel is required for use in SONGS EDhs.4.4) Conductivity of ULSD fuel Diesel fuel conductivity as stated in ref 2 is primarily an issue in colder climates where ambient air humidity is lowtypically below 50% relative humidity.

Fuel blends in colder climates tend to be blended with kerosene to improve low-temperatur handling which increases and propensity to form mist or vapor that can be detrimental in a electrostatic discharge.

Such cold weather conditions will not happen here and such fel blends are mot available here at SONGS and are not a concern related to use of ULSD fel. Even though ARCO has a conductivity fuel additive in their ULSD, fuel specifications for ULSD fue on the West Coast do not have conductivity specifications or pour point specifications (temperature at which wax precipitates out of the fuel-typically minus 30F) like ULSD fuel blends have in the Midwest and East Coast (this is a change since the issuance ofref 2). Fuel refiners process ULSD fad to meet hndling requirements in their respective mzrketing areas.Other fuel characteristics thatbave an effect ontthe safelhandling of diesel fuel are cosistent with existing fiue charateristics of CARB furl. Such properties like distillation temperature, which effects volatility, and flash point that can affect safe handling of diesel fuel, are unchanged frm existing SONGS diesel fuel. Furthmmorei SONGS diesel fuel and storage system is designed to ANSI N195 -1976 standard, which is referred to in Reg Guide 1.137. Paragraph (g) section 7.5 ofthReg Guide 1.137 clearly states That the ".. cafhodic protection system should be designed to prvvent the ignition of combustible vapors or fuel oil present in the fuel oil ystems..." Fueltransfer operations at SONGS are pe-formed with the use of grounding cables btwen the fuel tuck and a station ground. The fuel transfer connection point is a metal-to-metal contact, which prevents the possible electrical potential build-up between our equipment and the delivery equipment The acceptable ULSD fuel chemistry properties that can affect fuel handling and design of SONGS fuel system makes the introduction and use of ULSD acceptable for use in SONGS EDGs.4.5) Compatilblity ofULSD fual with underground storage tank liner SONGS underground fuel oil storage tanks have a 125 mil thick interior lining made of Bridgeport Glass Aumor GA 27, two-part epoxy coating. This lining was an environmentally mandated tmk uprade. The compatibility of the tank lining with ULSD fuel was assessed in AR 030600847.

Liner soak testing by the coating test vendor (PO 8D023922) was performed in the same manner as the liner testing in ref 2. This testing 4 040301409-3 Cl P oL.43oI 14oq,-3, te.v,0 was done as specified in American Petroleum Institute (API) Recommended Prmdftoe 3a..Li.1631 which includes: ASTM D790: Standard Test Method for Flxral Properties of Unreinforced and Reinforced Plastics and Insulating Materials ASTM D2794: Standard Test Method for Resistance of Organic Coatings to the Effects of Rapid Deformation (Impact) Testing ASTM D2583: Standard Test Method for Indertation Hardness of Rigid Plastics by Mwns of a BaeoGl Impressor ASTM D543: Standard Test Method for Resistance of Plastics to Chemical Reagents ASTM 1)4541: Standard Test Method for Pull-Off Strength of Coatings using Portable Adhesion Testers The final results of the testing indicates that -the immersed Glass Armor 27 showed no signicant change or degradation following immersion in either treated or umtreated (with stabilizer and biodde) BCD-1". Since the chemical fbrmulation of ULSD and CARB are the same, with the same coating testing results, a mixture of the two fuels will have the same properties of deher fuel individually and will not adversely affect the tank liner.ULSD or a mixture of UL-SD and CARB will tot have and adverse effect on SONGS undagmrnd storage tank liner and is therefore acceptable for use and storage in the underground fuel oil storage tanks.4.6) Fuel transfer system components The fuel oil transfer system is constructed primarily of carbm sted (ASME SA- 106 Grade B) schedule 80 material.

The fuel transfer pu1mps are made ofprimarily the same grade of carbon steel 1 with some of the pump internals constructed ofbronze (ASTM-B-584-937), which is used for pump shaft bushings and cast housings.

The wetted metallic surf*ce areas of the fuel transfer pump and piping are not subject to any type of credible attack from the diesel fuel itsefI Fiul transfer pumps do contain some nitrile seals, at the suction bel housing and in the pump columns (2 jqints). The nitrile seal in thm suction bell housing is weUl below the usable ful level in the storage tank,a so its failure could never affect pump suction. The two "0" rings in the pump column joints are within a machine-fit flange and see very low to no pressre. .Failure ofthese O". rings is unlikely due to low pressure in the Pump column and static nature of the coluhmjoint.

Any leakage at these joints would be captured in the pump performance monitored in the IST program. As a result, these seals were not replaced in preparaion for the introduction of CARB fuel and the introduction of ULSD fuel does not warant their roplacement.

The redundancy of the fuel transfer systemn robust design and individual pump scrutiny provided by the IST monitoring proSren" makes the fuel oil trnnsfer system extremely reliable and fully capable of transferring ULSD fuel or any Wthi nmixture of fuerlil c.onsisting of CARB and ULSD.ULSD fuel will not hinder the ability of the fuel transfer system to transfer fuel onl.4.7) ULSD compatibility with engine lubricating oil 5 040301409-3

=CP o00o3ol014cq-3

,,Ae',vO An importatt function of engine lubricating oil is to provide chemical protection to vital L. E 3 engine components exposed to engine combustion byproduct.

Intenal combustion

&,I' (a '" byproducts in The form of ash deposits in the combustion chamber can be generated by the wse of lubricating oil that is not compatible with the fuel oil. In particular, lubricating oil with large alkaline reserves or Total Base Number (TBN) used in conjunction with low sulfur fuels can form ash deposits in the combustion chambers.The engine manufactrer, Electro Motive Diesel (BMD), has assessed compatibility issues with the wide variety of fuels and lubricants available on the market The results of this compatibility stuy are captured in Naintenance Instuiction 1760 which provides guidance on acceptable fuel sulfur content and TBN levels in lubricating oil when used in the same engine. The use of ULSD fuel, or a mixtire that includes CARB fuel, with our urrenlt lubricating oil Mobilgard 450 NC, meets the compatibility criteria in MI 1760.ULSD fuel is therefore acceptable to use with SONGS urrent lubricating oil.4.8) .EDOperfdormace with ULSD fuel As stated previously in section 4.1 the API specific gravity for ULSD futel has a nominal value of 38-40. This normal API 38-40 (range 30-42 see reference

1. 3) value is typically Ihe same as that of our currently used CARB fuel. The EDO performance issues in Ref2, AR 011101320, addressed the change in heating value of CARB diesel fuel. As the heating value is proportional to tae API gravity, the ULSD f has an equivalent heating value to that of CARB fuel. As a result there will not be any anticipated changes to engine performance from the introduction of ULSD fuel.4.9) .Long-term storage of ULSD/CARB fead Long-term storage properties of ULSD fuel are substantially siiar -to that of CARE fuel. As stated in section 42, ULSD fuel.meft all the reqairp ments in S023-In-6.6

'"Diesel fel oil Testing Program".

The carrent fuel oil testing program includes a test that is an accelerated fuel oil.stability test (Analytical Method F21-61) wbichis used to detemine fuel stability, a critical fuel quality for long-term Storage. Program limits aem to obtain a value less than 7. Testing results per AR 030600847 indicate that treated and untreated ECD (ULSD) fuel testod both to a value of 1. Per ref 2 this is the identical test value obtained for both treated and untreated CARB fuel For the purpose of determining the compatibility of UISD and CARB fuel when mixed together, a series of tests were peformed.

Per AR 050300024-02, Sotthwest Research Institute (SWRP) performed AS.TM Method D6468-Standard Test Method for High Temperature Stability of Distillate Fuels. This test was recommended by SWRI'as the test that would provide the best indication of fuel compatibility.

Samples of ECD WULSD).nd CARE were prepared for testing in the various stated combinations below with the following results: 6 040301409-3 SCPo40o0O40o1-3 R0e .o0 P*AS-c 7 4 i Sample % Reflectance, filter pad rating 3 ECD -Untreated 100 BCD -Treated 99 " 7 c- !CARB -Untreated 99 CARB -Treated 100 50/50 BCD -CARB -Untreated 99 50(50 ECD -CARB -Treated 99 90/10 CARB -ECD- Untreated 99 90/10 CARB -ECD- Treated 100 The fuel samples were aged for 180 minutes at 150 deg C; Samples were then filtered and the average amount of filterable insolubles was estimated by measuring the light reflectance of the filter pads. The results indicate no difference (within the precision of the method) between any. of the results. This would indicate no differees in thermal stability or possible storage stability of the raw fuels vs. a 50M50 mixture or 90/10 mixture of the fueds. This test information supports concurrence by the fuel vendor that CARB and JLSD are filly compatible because &ey ar the same fuel formulations.

This information supercedes information previously on the subject of mixing faels that is contined in AR 040301409.

As a conservative masure, the frst ULSD fuel addition will be into a single fMe storage tank and accelerated testing performed on the fuel to assure their will be no complications with mixing of fuels. The use ofULSD or a mixture of ULSD and CARB will not bave an impact on fuel storage practices here at SONGS and poses no new diesel fuel ageing issues fhat are not monitored in the diesel fuel oil testing program. ULSD or a mixture of ULSD and CARB is acceptable for use at SONGS.5) CONCLUSION This evaluation of ULSD fuel with or with out the presence of CARB fuel and the past evalhaion performed for the use of CARB fueJ indicates that there will be no negative impact on the SONGS EI)s with the introduction of ULSD fueL SONGS EDO w be able to perform their designbasis function using ULSD fuel or a mixture of CARB and ULSD.Critical issues that could have affected SONGS EDG have been analyzed and determined to have no negative impact on the engine or the fuel storage and transfer system& The fuel chemistry meets al fuel oil requirements and in particular the eney content is the same as the currtmly used CARB fuel. The similarities of the ULSD to CARB and preventative measures performed on the engine to allow the use of CARB, apply equally to the use of ULSD. As a reslt, there are no new requhrd actions needed to make the EDG system ready for the introduction and use of ULSD. Based on past experience with CARB fuel, the similarities of ULSD and CARB, and the evaluations performed on ULSD-and various mixtures of CARB and IJLSD, the introduction and use of this fuel has been found acceptable for use at SONGS.7 040301409-3 f- CP o40o301o4q3,AeA.o 1OM..QUh%4t 3 at o- 15 Ref 1; Letter from Ken Kimura (British Petroleum/Global Fuels Tecbnology) to Doug Foote (SCB/SE)dated 9Fcb03, regarding ARCO ECD vs ARCO CARB fuel (induded)Ref 2; ENG]NEBRNG EVALUATION FOR THE USE OF CALIFORNIA AIR.RESOURCES BOARD (CARB)DIESEL FUEL OIL IN THE EMERGENCY DIESEL GENEATORS AT SONGS UNIT 2 AND 3. Dated 12March02.

ECP 011101320 (not included)Re,'3; Series of e-mail exchange between Mr. Ken Kimura (British Petroleum/Global Fuels), Bbara Mehta (SCE/DEO) and Gene Sherman (SCE/Chemislty), dated 11/08/2005, regarding API values expeted and used to accept/reject the fuel (inclided).

8 040301409-3 i I':* .Ai .4UP~I bp G0oba Fuels Techmology 6 Cnlterp.ie Drive, 6-592 La ?alma, Calfornia 90623-1066 United States of Aneics Telephone-:

+1 (714)670-5021 Febrm" 9 1, 2005 CiLA$'4t2 S Mr. Doug Foote SONGS SCE PO Box 128 (D3M)San CA 92672 Via e-mai to footedat(on0s.scM.com-J Re. ARCO ECD vs. ARCO CARB DewaMr. Foote: In repgards to your bquy abot the compatbility OfARCO BCD* and ARCO CARB Diesel, BP inan ctire both produ= using be &ame propretmy fImlation certified by Ihe California Air Resources oard. The only changes in the foraulation are ft Sulfr contewt and the addition of a lubricity specifica.tion with a inatdamm 520Wi result on ItMmethod.

These es meet the 2007 diesel*fgul.i ontfr uh-a low oulfur diesel fuel. A lubricity additive is injected into the fuel to co=pe=ate for tz lubricity degradation associated with a lower sulfur diesel fued. A ionduotivity additive is also umtled to reduce the potental for ttic ignition in a lower gulft diesel fuel. Chmges in the reflnmy operatio were required in order to produce the ultar low sulfur product ruch as changes in Ihe management of feedstocks and more severe process operations to wmne a few. However, the net reult prodnred , diesel fel ta Is more t naftly stable with better storage stabiity.

ECI hPas been available sin 2001 with conversion bing made from -noa lank tuove. The ceticte ofa of een prodoction ofbotz products are included for your information.

• S= differeas edst due to the batch processing of BCI. Process optimization w occur in 2006 when BCD* goes into fall-t=u productio nder ft 2007 diesel rue.If you have any questions or comments, please do not heitate to call me at (714)670-502L Best Regards, ri Krin=a*BP Global Fuels Technology Fuel Product Development 1EC P04R0iiiO 040301409-3 PEFE RENCS .3 I V+ ** -BI{APAT'MEIHrASONGSWSEEI

-111062005 121N PM To "KI(mura, Kerr -cKen.KQmura@bp~corn>w-cc footadaL~r.ngssace~comn, mco~annfl@songs~ce.com, shemiaee@songsxsca.comn bee F~t~-t-.SO*

Subjett RE: EDG/diesel fupl dftnge from CARS fuel to ULSD fuel&Ken, Thanks... .thls Is In line with values we are using In the calculation with API 42 as worst case scenario for fuel rejection by our Ohemistry division.Bharat Mehta 11/8/05'Kimura, Ken' <Ken.Kimura@bp.com,"Klmua, .Ken" cKenlrur&@bp.com:

111061200511:20 AM To -cmehtsbo@songs.sce~comn>

cc 4OOteda@8ongs.sce.cDmo. -qn~cCafnn1ongs.&ce.corn-'..

<rshenr-eeeftangs.sce.womý SubJect AE LEDdiesel fuel change from CAJ9B fuel to ULSD fuel Today, the API Gravity has been between 39 and 40 in the batch process. Once the refinery is eptinized to full time =LSD production, it should be in the 37 -36 API xage. .stimated BTU values are 00-129, 600 Net BTU/Gal. Again, we will know better Come June 2006 when ULSD production is running full-time and optiLized.

I hope this helps-in the mean time.Ken Global fuels Technology (714)670-5021

---

Original Message---

From: mehtaboasongs.

see. com [mailto:mehtabolsongs.

see. com]Sent: Tuesday, November 08, 2005 9:09 AM" To': Kimura, Ken Cc: footedal songs. see. corn; mccarnnlS songs. see. com;shexrmaeelsongs sce.comn; mehtaboesongs .ae. con=

Subject:

IE: EDG/diesel fuel change frx CARB fuel to ULSD fuel Ken, Thanks for your input. We have to take the worst case scenario in Calculation and anything beyond that must be rejected by Chemistry (administaetive controlled)..

At present, chemistry c= accept ULSD fuel up to API 42, and therefore, we must use that as the worst case scenario to figure out what the heating value is and how much storage is required.Can you give me the range of BTU values and API values for ULSD fuel you will be supplying.-

Bharat Mebta 11/8/05 ECO 0o3oL-o04

-3 IR9v'd 040301409-3 PE FEIZENcE-3"Kimura, Ken"<Ken. Kimiaxalbp.

co Pase Io$t In>11/08/2005-07;58

<shermaee@songs .sce. com>,<mehtabo@songs.

sce. cam><footedae songs. sace. corn>,<Mccannll@8ongs.

sce. cbM>cc Subj ect BE: EDG/diesel fuel change from CARE fuel to ULSD fuel Eello 3harat/Gene, it wiln be very -premature to make those changes On the basis of today's VLSD fuel for the simple fact that all ULSD production today is made on a batch basis which makes It difficult to optimize operations.

Some batches may show lower BTU content today but should go back to normal once ULSD operations axe operating full-time..

Ken.GlIbal Ftels Technology (714) 670-5021.--Original Message-----

Irli: shetmaeel songs. sce. corn nailto: shermeee songssee.

c'm]Sent: Friday, kNovember 04, 2005 2:51 PM To: mneht ab6B s :be .cam ... -.... .Cc: Ximura, Ken;* footeda songs.sce.cnom; mccannllfsongs.ste.cc..

Subject:

Re: EDG/diesel fuel change from CAPR fuel to ULSD fuel Bharat, I'm not sure that your statement,' "The main reason appears that ULSD EC-P oL-o3ol oo, .3 E0 0403DI404o 040301409-3 fuel has lower heating value (BTU/ERP compared to the existing CARB fuel" is correct. My understanding.

is that ARCO's UTLSD has about the --same heating value as their CARD. You might.want, to contact Ken Kimura (British t&o-Petroleum Global Fuels) at 714-670-5021.

Gene S. 87429 BHARAT MENTA/ SONGS /SCE/E ix 11/04/2005 12:55 MW~PM mnCOLN cc SBAEMfSDNGS/SCE/EIX@SCE, PAML VAL.APMIz SONGS/SCE/Ezxe CE, JOHNSON/SOzNGS/SCE/EngsýCs, RAINQS8ERY/SONGS/SCE/ErxScE, DOUGLAS T0OTE/Sa+/-NGS/SCEIEIX@9SCE, ART NESZL/SONGS/SCE/XIX@SCE,.SEEMANV/SONGS/8CE/=9XSCE, IAC.GAWJq/SONGS/SCE/EIXI!SCE, ItOBEBR!ZELLER/SONGS/SCZ/=0BGCE CHUCK DtIBEISOlqGS/SCE/EflCSCE, PATRICK XEVIV FLYNN/SO'NGS

/SCE/EIXISCE,.SCRO0IED/S0NGS/6CEIEfl@C6SE, PAUL B1KSLEE/SONGS/8CE/EflXSCE,-MNFER MEHEAD ROJATI /SONGS/SCE/EIK@SCE, NE-AL QTUIGLEY/SONGS/SCE-/E~rX@SCE, BHARATF )rEHAJONGS/StE/EnCSCE, PARVIZ BRUCE. RAtJSCH/SM~GS/tCE/EfltgSCE, JOHN EHISCH/SONGS/SCE/rIXU aCE, JACK ROBERT JECXIER/S0NGS/SCE/EIXO BCE-~P 01+0301409-~3

)40301409-3 RS, Fe P.F.Nce-3 QeW 4 4(&AC..GAJ'VG3 Subject EDG/diesel fuel change from CAhR f 13C. 3I'S -14 fuel to ULSD fuel Review of calculation M-0O16-00B (DG on-site fuel oil requirements) shows that prior to using ULSD fuel, diesel fuel storage volume will have to be increased fro what It is in the Technical specifications 3.8.3 at the 3=eaent time. The main reason appears that DLSD fuel has lower heating value (BTtD/Bx compared to the existing CARS fuel, which will require zore volume to do the same job.Therefore, a PCN against the Tech. Spec. is required and AR051100242 has been generated.

Once the PCN is issued, other affected documents such as TLU Calculations, Operating Procedures changes, Chemistry Procedure changes, DBD/UFSAR changes and other evaluation and impacted documents will be revised as part of the MCP 040301409-3, either as part of the ZCP or as an SPI assignments.

Technical Specification change requires NRC approval prior to using ULSD fuel in Zune 2D06 ox earlier. ECP and other documents changes can proceed in paranlel to Technical Specification changes, to meet June 2006 date.Once the PCN is issued for NRC approval, we will have a 10% ECP meeting to make sure we have captured all other design bases documents including calculations and procedural impacts.Per my discussion with Jack Rainsberry, Malcolm MaGawn is assigned to help process Tech. Spec. changes. l will work with Malcolm and others as required to draft the PCH for this effort.Please let me know if any questions or need more information.

Bharat Mehta 11/4/05 E Cp.4 Ft 6,40. o........................--..-...

040301409-3 ENCLOSURE 4 EMD MAINTENANCE INSTRUCTION (MI) 1760 Rev. G"Lubricating Oil for EMD Engines" (Best available quality)

T 6A 141.1760 *Maintenance.

Instruction x ~rOM Tiv Technical Pubricaidons LUBRICATING OIL FOR EMD'ENGINES MARINE, POWER, AND DRILLING RIG The neceIssty for properly lubricating tfhe dynamic:mpnPDets af any engine is readily, apparent.

The recommends tions. suggestions.

and comments Included in this M antemanc Instruction am offered is a guide in the of at suitable engine lubricating oil, OIL OLUAUTY It must be recognizd that the only ren rmeasure of quality in a lubricating oil Is its saeus p=fformancc S. tIn the diesel engine. This is apparent becamse of the* .impossibity.

of" establishing limts on all physl=i and clenical propefties of oils which can affect their peformance in the engine over a broad mrige of environmental influewnce.

Oil qualiky Is the respoisibiity orthe oil supplier, a tenm applicable to refmm and rebranders of engine lubricant As there are a substantia]

nucrn" of. commercial labricants marketed today.engine mamufacturers and conuur *cannnpt completely evaluate the entire d£ produts availablr-As x result. the selection of x $Uimblc.hcaý'y duty must be rade in cooulhation with a relizble oil 9lupplier capable of making product rmcommendations comtmensrm the engine builders specircations and sp=if= evyron.mental influences is well as furnishins sucb a product on a consastem quality' le-L OIL TYPE An SAE 40. heavy duty additive type engine lubrcant conforming to the following specilications should be; sed in all EMD engine &pplicafions Vlscosist.

.sayboh:uivra S=2ntj. U2.10 F (MEN. CY ..ASTM ITESTI D~ES IGNATION DES or D445 NEW. UNUSED OIL LIMIrTS 7"s5 (124-16A 40)6D-100 I.°Viscosity Index Flash Poit'D567 D92*. 4200 F.Min. (216 fieL Far Point Pour Point Zinc Content D92.D97 4750 F Min- (246- C)" 40c F Maý. (434' C I0 ppM Mam 1. -* Totat Base Number (,k) *.. .D-664" 5-17....D-2996 7-2D$This buDetfin is revised and supers-des prvouds issues of"M.l. 1760. 176:2 end 1763.A.rm of cha. am. indicate by vendcal bars t0fMRu7 E-229 mA M'v M.L 1760 NOTE t Zinc additive compounds, such as 2ine dithio-phosphate, must not be prestntin lubricat for EMrDengics.

Ol t10ppm zinc are cosidered

=.essively contaminated with zbe dithlophosphate or -imifr'addhive compounds which will not sacisfactorily lubrictm the silver bmaigp in EMD engi=..¶ Cettain oils In this TBN rangc will not provide adequate perlormutwe If aetis *with sulfurn ce== of 0.5% st be used For frrrber r~eommnSriors in thia itgard nfer to the serdon o h1ih mulfur fuels.In addi-jon to the Woe propeilms lhe oil Formula-tion should have a high restarmc to oxidation, a.low tendency toward the formation of harmful cmrbonattous ardloradditive ash depoetts.

and must be non-corrosive to silver metal at 29P F (140( C)(EMD LO. 201 tw). Oils with sufficient alkaine rese,,,,e LThN) and dispersm systems should be employed in line With fuel qmual, and: or servi= dermnd..QUALIFICATION TESTS FOR ENGINE LUBRICATING OILS The dim] engine 1uhdcaing Oi must satisractorily lubricate the Anira engine under all conditians expected to be enconunered.

While the conditicn gpd performance of the engine In actmu serne pmoI~dcs the criteria in reachinga finaijudgnent of oil suitbility.

therm air.sev'=1 labctratory ttsm which kic se'ful in making prclimirniry miluations ors product. n=hm..I. Physimcalmd chenical propertire (asprm'iousýy

2. Craroion or n=ie*aL Silver pnd copper -EMD No. LO. 201 method. " b. Lead S.O.D. Method No.5321-l (modifiedt

3. O%=al1 evahuatio), or Dsidztion Stablifty bY th.EMP l-0, 2I mrethod..

inludingi a. Vk .iv inerea= tharatistics

b. Recmion of alkalinity

c.

tof insolubles.

DEVELOPMENT PROGRAM REQUIREMENTS FOR NEW-OIL FORMULATIONS I. Laboratory Evaluaians Thesupplier of the lubrimt base stock and the supplier of the addidve -oneuar t are expecmd to condum complete laboratory and bench =quaJifications by ASTM and EMID =ebotdL EMD will rview and monitor such t= and if afl remults am in good agremn-,t and within acceptable fimits, the oil formulation will be considered worthy of 2-567 engine evalation" to dete mine Is silver lubricit c-,aracte.stis.

2. 2-567 Silver Lubricity Test The purpose of this tet is to detetmin-that the laboratory qualified oil formulation will sa tisfactorily lubrimtte the silver wrist pin b=rinr. This test tnskiation Is lso expected to be conducted and or'conrntmd by the oil or additiv supprirwith review and monoringozf the results by EMD.3. Full Scale Field Test Upon succesful compledon or the laboratory and silver lubricity tes. au oil formulation will be considered worthy of full sc.le field test evaluation.

Field tests shosuld be conducmed in a mi.nimum of tbree (31 EMD en&=nes. pref-erabl in beavy duty for t period or not les.than one '.ear.During the field evaluation and its cortlusloR.

EMD ill reiew the oil an4d enrin prfomxance

• daa b% the After successful completion of the field te=t program the oil uV~ be Considered satisfacor for use. butshould tecloselY monitored' during the following two yeaz df cotmrercial introduction.

Oil fofmulationi established and proven by this development program must MMain 9actly the s .me with no subst.uent chane.S In their meke-up.If ai oil or additive ?provtmett program Is derircable or necessary revised formulation M%%t be evaluated by going through the complete devclopnent program..: .l1*.6 -230

, ..-*1 M.1, 170 I .USE OF ONE OIL The use of a single brand name lubricant is recommended.

This re-ommenda~on of long standing is -bsuanuthlal tupooftr.d by obsmrnous of ptrformance otmany tuits with a single oil copured to performance of units with mixed oil products.MIXING OF LUBRICATING OILS EMD" lu ma'itualky fttt-n*=n tIiat lulir~dhf;

" oils should notibe rmi The combining orlubticants with differenm Rditdve and bast mock ompocnts creates a chemical mixture which cannot be readily evaluawed in the lzboratory.

and its rield performance cannot be relably predicted.

RECLAIMED OILS Considered asaeneral catgory. redaimed oilsaz not recommended for lubric on orEMD engines, HIGH SULFUR FUELS-- EM D strongly recommends the usc of distillate fuels with sulfur content orles than O5r in ordero relbe optimum life urpetncies or both theengine and the lubricating oil It should also be noted. that scheduled programs ane based, on fuel sulfur of .5% or less and other properties as shown in M.I. 1750.In applications where ruel o recommended sulfur level cannot be obtphired m Va" be necessary to make specific engine modifilcaions (contact your locid EMD Sertice Representative) and follow the.lubricating guidelines mentioned In this section. in order to achieve reasonable Perforiance and wear In addihion.

EMD considers the =e of igh.alkallne rmsrve lubricants as mandatory where high sulfur fuels most be employed.

SpecifIcally, the use of lubrijantswith new oiltotal basenummbero lOto 17 by ASTM D-664 (13 to 20 by ASTM D-296)p rc recommended under these conditions.

EMD'guidtlines for lubricant.a.lkalini*

a. a Sfunctiod of fuel silrur consent am rshown in Fr.4 I for Wlues up to and exceedlng 1%. It should be n"noted that extesive operation at low sulfur levcls-. with high baibe cinke'tls Is not recorendedi de-u *) to excessivt formation orf dd itivc ash deposits.---Convers-y, operation with low base number oils and bigh sulfurfucls will not providi: adequate t iotetion.6-0 0.5 1.0 1 z Fuel Sulfur Conmsnt-%Fig.1 -Recornmerdad Alkalinity Level Of New Lube Oil Vs. Fuel Sulfur Content I t Ws rmpWized that the use of high sulfur fuels results In siWnif=ant Teducdons in both enmine wear life and lubricant rilc" R.ecomrmendttions offerd in conjunction

%ith the use of high sulfur fuels are essendal in minimrokng these effects, but ame limited In what thiaccomplish.

As a re=lL, the userofbigh sulfur fuels must znticipate shorter intervals between engine overhbuls as well as more frequent oil changes under sueb condition.

FILTER CHANGES* Repglar monitoring of lube o1 filter tank pressure should be used to determine hter condhion.Replacement of oil filter elen.mvs should bc mindc according to the Scheduled MAaintenaicc " unless piriesre monitoring orlaborttorv unalvvis of the lubricatIng oil dictates earlier repicemcmn.

Replace.m&t element mst be ortbe EMD typ or.eqJuivalent in all respects.

Elenicnts for use with other ityp= or engins am not suitable.Where hlghly dispersant o6Is are cmploved, carbon-menuo matuer- may be Suspended iO finely In th oil that it is esentialy un 'iltemble.

It suich uitunt ions.It ipight appear that a.n extenseion or the filter meplaciment internval may be justif"icd.

Caution should .be-exercised when contemplating.s.ch at=ton since filter materials hav% not yet.beez thit will tolerate prolonopd expoiure (a-ubricants at high tempz mumvwitrho.i dt.inraim

• • and or possible disinegzatlon ot the flter'lrn ia.231* ."i -" 4./ *.1I

" I INTftft'Il~TATloI4 OF LImE Ott. SAMPLE ANALYftift 2 I ~RECOMMEN01DE ACTION Lune DAMIS MI1OIMAL 13011DERINE HIGH Shut Domn Engine. Drain Luba DIL.OIL FOR fin Action Take Ewan Correct Change Fillets.ANALYSIS ANALYSIS Required Oil Samiples Condition Change Filltrs Drily.VlnotS1ty

& 1`1991 Point -2 to 15% Borderline, -find and fin fuel leaI.CheckMfr Miullen If flash* Pool .pohtit low% then 40(' F or .0 to 2% *.High -ullack raffln teatings per vvitel~eionve Leak~ all v~wtyoldrops 115% or .AboveB2%

manlrl fi Rewwuripte vdth'd mm per moe te Water MY__*&___n Lffk Chmyntst Inhibitor 0 to 20 ppm 20 to 40 ppm Above 40 ppm Find and lix water leall. Cheak lube all filter lank prommmr, D orm lnhbf 0e tlo 10ppm iOt*2Oppm Above 20ppm _____________

I Fifiraflon

~~~ Oto 15 ppM 15 to 10 ppin Abe" 103 plimfarlftrnonO~fleriurd I Fn~atio Anilloamagetrt present In new all, TOIN -"64) *Mtn TMI Chan"e 011. Ifsot oil C [its perVSISt, abeek.TONf (0-2896) (0-0041M lube ongtfel sultur content,, all P*1M .0 Cooler 10lency,.

engine eImperature I I Etetw VN01tyRie Me*, 111w. Rnh* In -contraolpoe output (governor aund.1 O~~~Ida ti~~Sseplir P30%M~tlg " 11bi.00htffto lwoverIgw* PH MKl PH SJD CrOOund PISIOSI, POOT uuoii~tisunyoil

~~* ~111]110 ft orln allo p"MP Wmtion leek.-Contemi-Cheek filet cle"Mifles NotIfy fuel liueuf fuel' Aluminum, Stlicon, .*slipplier.

If engine omokes, chiecki nfector (ouManit and/or Magnesium Above 6 pprn co Imitation and t~p ervoelon.

Choult it catalyst) .piston rIngs am excesslv IVon,.Chead It oil 19"l otsollng Matanfredl.o Above 10 jpborie m t -k Orne pointed tnawwas. C"e (I inaketupo Zincre dangrou wioh inelvec (9 whhlbn spettlonricns otf 1111)Inr l Mpla.Check (o eI iof Is j, ms 4 Patton *r.?tube%, 1"meot all cooler, or Imnproperr Silve finI pp ito ppm *,~*toaniprrtute COntro. Feet 8ldog of P146o em"lstioc with it" refflfngAý.

t Off drehllgif rmtmatfloy.Cheek stratnes arnd WoWIm:~jvi; of of part or to Oaadpr turbo bearing 4S I I.F I* I 1 *fi 1-'I--J O~I I* 1.mis.'Q.," "t, (I 1-_________

V IAbnorinal IWear Or.Correelon (ravpid Increases; Within normXFat range Should be eunstdere~

bnmdvrlfhw rtondft"T).

Chromium (Noat Oppflvable 1f shromatly coolant*1inhbitwrl Wsed)0to 10ppm 10 to 20 ppm Above 20 ppm Check for repid Wmar of rings & Tiners.-,, loat ,, ,p~to thrus ,,tit C r 0 to 75 ppm 75 tot 60 ppm Above 150ppm Measuore VpstiI to heod stanrance with lead* -remd~ngg to lovaletornv piston thrust Wathrn.SChte* rod beorhr bfde thrust faee for distress.H" iron and coPer Inmcese ostdallon rates Iron 0to 75 ppm 75to125ppi Abov 125npm Cheekforrapld warofrhings&Alnma

• I* I t t I Load 0 to. 0ppM 150t.76 Vp,', Above 75 ppm Most I1Wely lead flesh Is dissmang off berings.Prmeture tend removal, befom begring we broken In, arn lead to bearing dlitress.

Inwpsat end repfcen uppe edon rod bearIngw In servive Issn then 0 monthm If lead ffes hes been removed from the unlowded area of the flehbnck bearing -urfamc on turbosherged engInes. If cun rod bearings requIre repluesnnt, wrist pin beari"gushould ulm be che 1asd and rplaced if foed flesh hae been mmoved.M.0 CA)In COmbM-nation Copper Iron Lead'In Combi-*n~tio I -Tin.0 to 20 pPM I_________

I ____________

• In ,aplitiatlonn wherefuel mrtfuroontent is0.5 to 1.0%1 the TB Ievel shmtzotdot be afllwedto drmp below 1.0{0084)ur 2.0 (-2556); andwhere fuel aul'ur content In greater then 1-.0M, Tt;shout d not be aOlt-ed t( drop below 3.0 p)-0041 or 4.0 (13-2090e.

Wau ocro tJIdJ nbt h irfco h y~dr head and the crown of the piston duringsesrvice i116, leudwfr reeding shouild not he used* as b bests for power assembly chennlieut.

Lead wire readings may conte, to. be semd to Indite wenr trends. 5fllffcanrt clearence Imersesox.should be behtiga.ed an p rosae comonent failures.IMOU I* I* I I,* I all ljA.I. 176D LUBRICATING OIL CHANGES Oil drjV; in tmis prescribed in the applimable.

Schedttled

)4aimenaneed Program arc based on Inmgie opeling condilioS Vith quality fuels of Ie5 than 0.5% sulfur Conreel When oil cbange intertals are overextended.

serious and costly engine problems may result. This cin occur if ihe additie concentrate is depleted beyond ncatputble limis, and Abe lubricant loses essential.

properties

'ncluding alkalinity.

detergency.

and disp rmzcy.'. In titeabsence of vi II reserves ofthesp properties, the lubricant no longer provides bamisactor' protectiou of the enLni In limiting hbameurl deptsit ronations frmm oxidb.ed D1l and other contamintants, or adequate control or the corrosive products of combustion.

Oils which helve experienced severe addtive depletion will result in acceleramd ngine wear." stuck or broken piston rings. liner scuffing, and corrosivu atack and or frictional failure of vital bearins surfa5cts Replar laboratory analys-is or the lubricant Is a valuable means of judging the condition of the lublriML nd is of equ8d value III MflectMg the condition of the eigine. Boih engine and oil condition must be .ve care'=fl considemaion when planning to extend oil change intervals beyond those recommedcd.

In addition.

EMD s the co.nscientious ise or laiorgtr.y analýsis utere high *ulfur fuels must be used. The degree of satdactory perfornce in such ap-plicauons is hea.l dependent on the ems ishment of proper oil change buet-mms under the actual service condition and high end or the ful sulfur range that can be expecmd. Therefore.

an expeditious well planned program of frequent anazlýsis is most t=sntial in establishing a safe oil change intmrval for a .jven lubricant under the conditions.

Under no drct"nnstains should a set time ineval" for oil changes with high sulfur fuels be arrived a tvhhon tfust establishingsuch an intermalb'l careful laboratory analysis and; or close consulationv with the oil supplier.Among the key parameters for udgingthesieed for in oil change.: total base number (TFN) is oe= cf primary *imponance.

When this or other key indicntors approach or read preTribed minimum.or condemning lirits. appropriatc action must be..taken. To assist maintenance personnel in the.unttrpretafion and recommended actions associated.hitb the regular laboratory analysis of the engi-e lubricating oil. a surnmar of guidelines hab been included in this Maintenance hustruction.

Whilk* some variAtions From guideline

%alus rxaycitdu=

to method or analvsLs techniques employed.sign1nifcin deviations from the normal lubricant history should still be detectable.

and the proper evaluation of such indicators as a means of Implementing preventive lmaintenance:

cai; serve well In avoiding potential engine damage ofa more serious nature.%; I I t k 6- 234 V~4 ENCLOSURE 5 ESI LETTER DATED 12104101 LOW AROMATIC FUELS (including IP-94 Pointers)(Best available quality)

)Engine Systems, Inc.Nuclear Parts & Service Tuesday, December 04, 2001 Southern California Edison Company Attn: Doug Foot P.O. Box 128 San Clemente, CA 92672

Reference:

Low Aromatic Fuels With reference you your question with regards to running Low Aromatic fuels in your EMD 20-645-E4 engines. The engine governor control system will adjust fuel injector rack to compensate for lower BTU rated fuels. The fuel injector will supply additional fuel to each cylinder to carry rated loads. See Pointers 1 P-94 for Low Sulfer & Low Aromatic Fuels.Should you have any questions or need additional information, please don't hesitate to call me @252-407-8520 or Email darryl.hartley@kmtc.com..

Sincerely, Darryl HarUey Customer Service Manager eNCEUW 1IRVICEN.)&WODWRD GPLOWLM'RNMSARruuSYSrB5 In205 Wabbhinto Street /P.O. Box 192S (27362-1923)

IRodcy Mount. KC27511 / Telepheone:

(25) Mf4720 / Tax: (252) d443301 /Web Ai*U1. UvwJ2PwV7L IP-94 POWER POINTERS ELECTRO-MOTIVE Table Of Contents EXHAUST VALVE SEAT SERVICE LIMIT REVISION -.-------------------

LOW SULFERJLOW AROMATIC FUELS --------------------------------

EMD POLICY ON MULTIGRADE ENGINE OILS ..........................

NEW ROCKER ARM SETTING WRENCH ................................

DE-P 7 -339 April 1994 EXHAUST VALVE SEAT SERVICE LIMIT REVISION The service limit for the maximum valve seat mnout. listed in the Service Data at the end of Section 2 in current and previous editions of EMD Engine Maintenance Manuals. is not valid. The old limit may be shown as 0.05mm m '.002") or 0.038mm n.0015O").

The correct current limit should read as 0.064nmm 1.0025").Please mark your copies of Engine Maintenance Manalms to reflect this limit revision.LOW SULFUR/ LOW AROMATIC FUELS Effective in October of 1993.the United States Environmental Protection Agency (EPA)mandated regulation changes in the sulfur and aromatic hydrocarbon content in the Diesel fuel used by trucks on U.S. highways.

Nationwide.

fuel sulfur content was changed to 0.05%maximum from the 0.2% to 0.3%' that had been the norm. Additionally.

in California.

fuel aromatic hydrocarbon content was limited to 10% (with some leeway allowed if a refiner could show equivalent emissions perforrnancei where previous levels had been 35% to 40%.Though the new rules do not extend to fuel used in locomotive or power product applica-tions. refining and distribution considerations dictate that inevitably much of the fuel avail-able to operator's of such equipment will meet the new standards.

The commuter railroad, serving the Sa= Francisco bay area. experienced fuel leaks at the injector nut seals on F40PH locomotives delivered in 1985 and 1987 after changing to the new 'California" fuel. The leaks were caused bv shrinkage of the Nitrile rubber seal (used in injector assemblies at the time of delivery of these locomotives) due to the reduction in the fuel aromatic content. The fuel aromatics act to swell and harden the Nitrile elastomer.

Con-versely, with reduction in aromatic content the seal contracts and because it is no longer pli-able. its sealing function is lost. The resulting fuel dilution of the lubricating oil is the signal that injector seal failure has occurred.Problems with the new fuel have not been limited to locomotives.

Many truck fleets have noted similar fuel system leaks with Nitrile seals: the leaks disappear and do not recur with seal replacement.

even if the new seals are Nitrile rubber. Truck fuel system leakage has been noted nationwide, perhaps as a result of fueling in California or of the effects of the refining and distribution constraints noted above.There are two reasons why EMD does not expect the commuter railroad experience to be repeated nationwide, particularly on railroads or power product operations which have no California contact: ai=t; the California fuel is fl2L..the low-sulfur fuel in use nationwide.

The latter does not have a required aromatic hydrocarbon and, therefore, the swelling-hardening-contraction sequence with Nitrile seals described above is unlikely to occur. We do not expect the fuel sulfur reduction alne to have any adverse effects in the EMD engine.Secnd; the EMD injector nut seal material was changed in March of 1989 from Nitrile rubber to a Fluoroelastomer (of whichr Viton is a trade name), which is unaffected by fuel aromatics.

Most of the other seals in f-,el contact are also Fluoroelastomer material.Customers are cautioned not to use old EMD stock or competitive aftermarket injectors which contain Nitrile rubber seals in this new fuel environment.

7- 340 EMD POLICY ON MULTIGRADE ENGINE OILS.ie of a high quality lubricating oil in EMD engines is required in order to maximize reli-*ility and performance.

Over the years. the most reliable lubricating oil used in our engines.s been SAE 40 weight. EMD continually built knowledge and found success with the-aight weight oil. However. with the introduction of muhtigrade oils. EMD understood the ed for change and recognized the use of multigrade oils for engine operation.

EMD also derstands our customers" needs for lube oil and fuel oil savings, which are being realized h the use of multigrade oils. EMD has accepted the challenge presented to us by the ustry change to multigrade oils and looks forward to a reliable future with these oils.EMD has and will continue to recognize SAE 20W-40 multigrade engine oils that suc-,:essfully complete the required development program. including the field test approval process.lo date. SAE 20W-40 multigrade oil field tests have accumulated a significant number of 3perating hours in EMD engines with satisfactory results. (These hours have been accu-mulated on both 645 and 710 engines)..n addition to field test experience, in use service by major North American owner/opera-

'ors in the last three years has not shown any oil related adverse effects on EMD engines.with the exception of one product.-his product did not provide adequate engine break-in performance.

but EMD believes-is problem is correctable and we are working with the supplier to this end.'he use of SAE 20W-40 multigrade engine oils is directionally consistent with EMD's.3olicy to provide more fuel efficient and lower emission signature engines to the markets we serve.ould be noted, however, that there are EMD service concerns about SAE 20W-40 multi-e oils in high shear applications.

Current lab tests for oils are not able to duplicate all rue shear rates and interface temperatures which would help to predict the safety margin current designs. As a result, field tests and in service use experience are the only mea-to evaluate multigrade oils today.) encourages the oil industry to develop instrumentation to provide a complete map of able shear and temperature characteristics for multigrade oils, so that less emphasis is*ed on field test requirements.

Independently, EMD is also investigating the feasibility of ig a high speed rotating test stand to qualify current and future multigrade oils.nould be noted that, EMD has continually recommended that lubricating oils should not mixed. The combining of lubricants with different additive and base stock components-a=es a chemical mixture which cannot be readily evaluated in the laboratory and its field formance cannot be readily predicted.

Please refer to M.I. 1752 for instructions to mini-ze potential risk if mixing of oils is unavoidable.

7 -341