ML101680207

Emergency Diesel Generator Fuel Oil - Alternate Sampling Procedure of Storage Tanks

ML101680207
Person / Time
Site:	Sequoyah
Issue date:	07/27/2010
From:	Doug Broaddus Plant Licensing Branch II
To:	Krich R Tennessee Valley Authority
Lingam, S NRR/DORL 415-1564
References
TAC ME3439, TAC ME3440
Download: ML101680207 (3)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 JUly 27, 2010 Mr. Rodney M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEOUOYAH NUCLEAR PLANT, UNITS 1 AND 2 -EMERGENCY DIESEL GENERATOR FUEL OIL -ALTERNATE SAMPLING PROCEDURE OF STORAGE TANKS (TAC NOS. ME3439 AND ME3440)

Dear Mr. Krich:

By letter dated February 24, 2010, as supplemented by letter dated May 13, 2010, Tennessee Valley Authority (TVA or the licensee) submitted a request to use an alternative sampling procedure for the emergency diesel generator (EDG) fuel oil storage tanks for Sequoyah Nuclear Plant (SON), Units 1 and 2. The requirement to sample the diesel fuel oil storage tanks comes from Technical Specification (TS) Surveillance Requirement 4.8.1.1.2.c, which states that, "At a frequency in accordance with the Diesel Fuel Oil Testing Program, verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits specified in the Diesel Fuel Oil Testing Program." TS Section 6.16, "Diesel Fuel Oil Testing Program," requires that sampling and testing of new and stored fuel be performed in accordance with applicable American Society for Testing Materials (ASTM) standards.

Historically, TVA has performed a manual "all-levels" sample in accordance with Section 8 of ASTM D4057-1988, "Standard Practice for Manual Sampling of Petroleum and Petroleum Products." However, Section 8.1 of ASTM D4057-1988 specifies that alternate sampling methods may be used with agreement of the parties involved.

TVA determined that U. S. Nuclear Regulatory Commission (NRC) staff approval of the alternative sampling methods was necessary to satisfy the criteria of ASTM D4057-1988; there is no change to the TSs or its bases. The "all-levels" sample from ASTM D4057-1988 draws a sample that is representative of the entire tank, by opening an empty specialized container near the bottom of the fuel oil storage tanks and drawing the container upward to the top of the tank as it fills. Instead of this process, TVA proposed to take samples from the fuel oil transfer pump discharge lines of each fuel oil storage tank. The transfer pumps take suction near the bottom of their respective tanks through a 4-inch diameter line. There is a 1-inch diameter line and valve off each discharge line that will be used as the sample point. To obtain a fuel oil sample, TVA proposed that the fuel oil transfer pump for the tank to be sampled will be placed in the recirculation mode for a period of time necessary to ensure a one-volume recirculation of the contents, based on the volume of diesel fuel in the tank. After the tank has been recirculated for the appropriate time, TVA proposed that the sample line will be flushed and a sample obtained.

The fuel oil sample will be analyzed in accordance with existing TS requirements.

R. Krich -2 To show that the new sampling procedure would provide results that were representative of the fuel oil contained in the tanks and equivalent to the existing procedure, the licensee collected samples using the existing "all-levels" method, and the new proposed method, from Fuel Oil Storage Tanks 1 and 2 for a period of 3 months. The sampies were then tested with the same procedures and the results were provided in the enclosure of TVA letter dated February 24, 2010. The NRC staff reviewed the proposed sampling process and the test results comparison provided in the enclosure of TVA letter dated February 24, 2010. Based on the comparison of the sampling methods and test results, the NRC staff finds that the proposed sampling method provides an equivalent sample of the fuel oil storage tank contents as the "all-levels" sampling method in ASTM 04057-1988.

Based on the NRC staff review of the TVA request, the NRC staff finds the alternative sampling technique for SON, Units 1 and 2 EDG fuel oil storage tanks acceptable.

Pursuant to ASTM 04057-1988, Section 8.1, TVA is authorized to obtain samples from the fuel oil transfer pump discharge lines of each EDG storage tank by the described process in lieu of specific methods described in applicable ASTM standards.

If you have any questions regarding this matter, please contact Siva P. Lingam at 301-415-1564.

Douglas A. Broaddus.

Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328 cc: Distribution via Listserv R. Krich -2 To show that the new sampling procedure would provide results that were representative of the fuel oil contained in the tanks and equivalent to the existing procedure, the licensee collected samples using the existing "all-levels" method, and the new proposed method, from Fuel Oil Storage Tanks 1 and 2 for a period of 3 months. The samples were then tested with the same procedures and the results were provided in the enclosure of TVA letter dated February 24, 2010. The NRC staff reviewed the proposed sampling process and the test results comparison provided in the enclosure of TVA letter dated February 24, 2010. Based on the comparison of the sampling methods and test results, the NRC staff finds that the proposed sampling method provides an equivalent sample of the fuel oil storage tank contents as the "all-levels" sampling method in ASTM D4057-1988.

Based on the NRC staff review of the TVA request, the NRC staff finds the alternative sampling technique for SON, Units 1 and 2 EDG fuel oil storage tanks acceptable.

Pursuant to ASTM D4057-1988, Section 8.1, TVA is authorized to obtain samples from the fuel oil transfer pump discharge lines of each EDG storage tank by the described process in lieu of specific methods described in applicable ASTM standards.

If you have any questions regarding this matter, please contact Siva P. Lingam at 301-415-1564.

Sincerely, IRA BMozafari forI Douglas A. Broaddus, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328 cc: Distribution via Listserv DISTRIBUTION:

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DATE 7/26/10 7/27/10 06/16/10*

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