ML15274A110

Response to NRC Request for Additional Information (RAI) Regarding License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil And..

ML15274A110
Person / Time
Site:	Browns Ferry
Issue date:	09/30/2015
From:	Shea J W Tennessee Valley Authority
To:	Document Control Desk
References
CNL-15-194, TAC MF5417, TAC MF5418, TAC MF5419
Download: ML15274A110 (10)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-194

September 30, 2015 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Response to NRC Request for Additional Information (RAI) Regarding

License Amendment Request for the Adoption of Technical Specifications

Task Force (TSTF) Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (BFN TS-493)

(TAC Nos. MF5417, MF5418, MF5419)

References:

1. Letter from TVA to NRC, CNL-14-059, "License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control' (BFN TS-493)," dated December 11, 2014 (ML14349A694)

2. Electronic Mail from NRC to TVA, "RAI for Browns Ferry Units 1, 2, and 3 Adoption of TSTF-501 (MF5417, MF5418, MF5419)," dated September 2, 2015 (ML15245A598)

By letter dated December 11, 2014 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to modify Technical Specification (TS) 3.8.3, "Diesel Fuel Oil , Lube Oil, and Starting Air," to replace the volume requirements with the number of continuous days the diesel generators are required to run. The request was consistent with U.S. Nuclear Regulatory Commission (NRC) approved Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications (STS) Change Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." The LAR also proposed changes to TS 5.5.9, "Diesel Fuel Oil Testing Program," to be consistent with NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, Revision 4.

By electronic mail dated September 2, 2015 (Reference 2), the NRC transmitted a request for additional information (RAI). The due date for the response is October 2, 2015. The enclosure to this letter provides the TVA response to the RAI.

U.S. Nuclear Regulatory Commission CNL-15-194 Page 2 September 30, 2015

Consistent with the standards set forth in Title 10 of the Code of Federal Regulations (10 CFR), Part 50.92(c), TVA has determined that the additional information, as provided in this letter, does not affect the no significant hazards consideration determination associated with the request provided in Reference 1.

There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 30th day of September 2015.

Respectfully,

J. W. Shea Vice President, Nuclear Licensing

Enclosure:

Response to NRC Request for Additional Information (RAI) Regarding License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1

cc (Enclosure): NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Branch Chief - Region II State Health Officer, Alabama State Department of Health

J. W. Shea Digitally signed by J. W. Shea DN: cn=J. W. Shea, o=Tennessee Valley

Authority, ou=Nuclear Licensing, email=jwshea@tva.gov, c=US

Date: 2015.09.30 20:51:35 -04'00'

CNL-15-194 E - 1 of 4 ENCLOSURE Response to NRC Request for Additional Information (RAI) Regarding License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-501, Revision 1

Attachment:

Excerpts Related to the Diesel Fuel Oil Testing Program from the BFN Improved Standard Technical Specifications (ISTS) Conversion Application

CNL-15-194 E - 2 of 4 Basis for the Request Enclosure 1 of the licensee's submittal, page 3 of 9 states:

A change to TS 5.5.9 "Diesel Fuel Oil Testing Program" is proposed to adopt the testing of new fuel oil consistent with NUREG-1433, Revision 4. This change adds a requirement to test new fuel oil to a set of standards and limits and is a more restrictive change to support the adoption of TSTF-501, Revision 1. The periodicity of testing the 7-day storage tank fuel oil particulate concentration has been retained from the BFN Current Licensing Basis as every 92 days, consistent with ASTM D-2276, Method A-2 or A-3.

In addition, the licensee's proposed TS change to TS 5.5.9 states the following:

c. Total particulate concentration of the fuel oil in the 7-day storage tank is 10 mg/l when tested every 92 days.

Technical Specification (TS) 5.5.10, "Diesel Fuel Oil Testing Program," of NUREG-1433, Revision 4, "Standard Technical Specifications (STS) BWR/4 Plants" establishes the following acceptance criteria for the total particulate concentration of the fuel oil:

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

In addition, the licensee's proposed TS Bases change to SR 3.8.3.3 proposes the following:

Particulate concentrations should be determined in accordance with ASTM D6217-11 (Ref. 7). This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l.

The equivalent NUREG-1433, Revision 4, "Standard Technical Specifications (STS) BWR/4 Plants" Bases to SR 3.8.3.3 states the following:

Particulate concentrations should be determined in accordance with ASTM D5452-[ ]

(Ref. 6). This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l.

TVA Response - Clarification The statement provided in Enclosure 1 of the application and quoted above, "The periodicity of testing the 7-day storage tank fuel oil particulate concentration has been retained from the BFN Current Licensing Basis as every 92 days, consistent with ASTM D2276, Method A-2 or A-3." requires clarification. ASTM D2276 is a test method describing procedures for the evaluation of particulate contaminant in aviation turbine fuels. ASTM D2276 does not specify periodicity of testing. Therefore, the phrase "every 92 days, consistent with ASTM D2276" could be misleading. TVA is retaining the 92 day periodicity requirement from the current licensing basis as discussed in the response to RAI-1 in this enclosure. However, after NRC approval of the LAR, ASTM D2276 will no longer be used as the test method for determining particulate concentration. Testing for particulate concentration will instead be performed with the more recent standard ASTM D6217, as specified in the proposed TS Bases changes previously provided in Enclosures 2 and 4 of the application. Further discussion on the use of ASTM D6217 is provided in the response to RAI-2 in this enclosure.

CNL-15-194 E - 3 of 4 RAI-1 Provide the documentation that establishes the current licensing basis for the periodicity of testing the 7-day storage tank fuel oil particulate concentration as every 92 days versus 31 days as suggested in STS.

TVA Response In current BFN TS 5.5.9, Diesel Fuel Oil Testing Program, Specification 5.5.9.b requires particulate testing of the fuel oil in each 7-day fuel oil tank every 92 days. This requirement has existed in TS 5.5.9 since the BFN conversion to Improved Standard Technical Specifications (ISTS) (Reference). Prior to ISTS Conversion, the BFN Custom Technical Specifications (CTS) 4.9.A.1.e required a quarterly check of the quality of each diesel generator's 7-day fuel supply. This quarterly, or 92 day, periodicity requirement was maintained in the BFN conversion to ISTS. Excerpts from the BFN application for ISTS conversion are included as an attachment to this enclosure. The excerpt includes markups of the NUREG-1433, Revision 1, Diesel Fuel Oil Testing Program Specification 5.5.10, and the justification for changes to NUREG-1433, Revision 1, for the BFN ISTS.

Reference:

Letter from NRC to TVA, "Amendment Nos. 234, 253, and 212 to Facility Operating License Nos. DPR-33, DPR-52, and DPR-68: Regarding Conversion to Improved Standard Technical Specifications for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. M96431, M96432, and M96433)," dated July 14, 1998 (ML020040291)

RAI-2 Provide a justification for deviation for determining particulate concentrations of the fuel oil in accordance with ASTM D6217-11 versus ASTM D5452-[ ] as suggested in STS.

TVA Response

ASTM D975, "Standard Specification for Diesel Fuel Oils," establishes detailed requirements for diesel fuels. Current BFN TS 5.5.9 requires diesel fuel oil to meet limits specified in Table 1 of ASTM D975-1989. In nonmandatory Appendix X3 of the 1989 revision of the standard, Section X3.6.3 states the "quantity of insoluble fuel contaminants present in fuel can be determined using Test Method D2276, Procedure A." Although ASTM D2276 was developed for aviation turbine fuels, revisions of ASTM D975 through the year 2000 included reference to D2276.

Early revisions of D2276 included both a field method and a laboratory method for determining particulate concentration in aviation turbine fuel. The laboratory method was separated from D2276 and established as ASTM D5452. Therefore, ASTM D5452 is based on a method developed for aviation turbine fuel.

CNL-15-194 E - 4 of 4 ASTM D6217 was developed as the first ASTM standard test method for assessing the mass quantity of particulates in middle distillate fuels, specifically including the D975 No. 2 grade type diesel fuel, which is used at BFN. Revisions of D975 since 2001 have replaced the reference to D2276 with a reference to D6217. As shown in the proposed TS Bases changes included in Enclosures 2 and 4 of the application, TVA will use the tests specified in ASTM D975-14a to test fuel oil properties.

ASTM D6217 is the appropriate standard for determining particulate concentrations in diesel fuel oil at BFN for the following reasons: ASTM D6217 is recommended by the revision of ASTM D975 proposed for BFN, ASTM D6217 was developed for diesel fuel rather than aviation fuel, and the ASTM D975 No. 2 grade fuel type used at BFN is specifically included within the scope of ASTM D6217.

3 pages follow Attachment to Enclosure Excerpts Related to the Diesel Fuel Oil Testing Program from the BFN Improved Standard Technical Specifications (ISTS) Conversion Application