ML20077F195

Application for Amends to Licenses NPF-87 & NPF-89, Consisting of LAR 94-021,revising TS to Allow Appropriate Remedial Action for High Particulate Levels in DG Fuel Oil & Other out-of-limit Properties in New DG Fuel Oil

ML20077F195
Person / Time
Site:	Comanche Peak
Issue date:	12/06/1994
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077F197	List: ML20077F195 ML20077F200
References
TXX-94307, NUDOCS 9412130300
Download: ML20077F195 (11)

Text

r

? 'l

.s I F

_g Log # TXX-94307

== -

File # 916 (3/4.8)

, Ref. # 10CFR50.90 C

C __

10CFR50.36 l 1UELECTRIC aM[r','A. December 6. 1994 U. S. Nuclear Regulatory Commission Attn: Document Control Room Washington DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SUBMITTAL OF LICENSE AMENDMENT REQUEST 94-021 DIESEL GENERATOR FUEL OIL PARTICULATES AND OTHER PROPERTIES Gentlemen:

Pursuant to 10CFR50.90. TU Electric hereby requests an amendment to the CPSES Unit 1 facility operating license (NPF-87) and CPSES Unit 2 facility operating license (NPF-89) by incorporating the attached changes into the CPSES Units 1 and 2 Technical Specifications. The purpose of this request is to allow appropriate remedial action for high particulate levels in the diesel generator fuel oil inventory and other out-of-limit properties in new diesel generator fuel oil that has been added to the existing diesel generator fuel oil storage inventory. These changes are equally applicable to CPSES Units 1 and 2.

Attachment 1 is the required affidavit. Attachment 2 provides a detailed description of the proposed change. a safety analysis of the change. and TV Electric's determination that the proposed changes do not involve a significant hazard consideration. Attachment 3 provides the proposed changes to the Technical Speci fications.

In accordance with 10CFR50.91(b). TU Electric is providing the State of Texas with a copy of this proposed amendment.

Upon approval of the proposed changes. TV Electric requests a 30 day implementation period following the date of license amendment issuance.

,q.,rc -

.LUUsVD 9412130300 941206 P.O. Box 1(XT2 Glen Rose. Texas 7243 PDR ADOCK 05000445 P PDR Ill J

4 4

TXX-94307

,Page 2 of'2 Should you have any questions, please contact Mr. Alan Quam at (817) 897-8621.

Sincere .,

i C. L. Terry AD0/tg Attachments: 1. Affidavit

2. Description and Assessment

3. Affected Technical Specification pages (NUREG-1468) as revised by all approved license amendments

Enclosures:

1. Applicable Pages of NUREG-1431

2. ASTM-D975-1981 Table 1

3. Delaval Instruction Manual. Page 8-9

4. NMAC Diesel Fuel Newsletter. 11-16-89 c- Mr. L. J. Callan. Region IV Mr. D. D. Chamberlain. Region IV Resident Inspectors. CPSES Mr. Tim Polich. NRR Mr. D. K. Lacker Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin Texas 78704 i

1 Attachment 1 to TXX-94307 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION In the Matter of )

)

Texas Utilities Electric Company ) Docket Nos. 50-445 ,

) 50-446 (Comanche Peak Steam Electric ) License Nos. NPF-87 Station. Units 1 & 2) ) NPF-89 AFFIDAVIT C L. Terry being duly sworn, hereby deposes and says that he is Group Vice President. Nuclear Production for TU Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 94-021: that he is familiar with the content thereof: and-that the matters set forth therein are true and correct to the best of his '

knowledge, information and belief. ,

/

1f/

< Mu C. L. Terry '

Group Vice Pr t, Nuclear Production STATE OF TEXAS )

)

COUNTY OF Smer re# )  :

Subscribed and sworn to before me, a Notary Public, on this d?7 6f day of  :

A u m/ot. . 1994.

SUSANC.GRAVATT

,d u n t" h( ? u a n -

(&. g &rgy,

[

CW5sion Expires 3-24 97 NotaryPubligy l

l 1

l i

i l

.-- _ _ _. . _. 1

F, '

ie

. ,4 1

I i

[

ATTACHMENT 2 TO TXX-94307 i DESCRIPTION AND ASSESSMENT r

4

-h I

1 t

. .i l

l l

l t

1 I

Attachment 2 to TXX-94307 Page 1 of 7 DESCRIPTION AND ASSESSMENT I. BACKGROUND The Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 Technical Specifications 3.8.1.1 and 3.8.1.2, in part, require declaring the diesel generator (DG) inoperable if the diesel generator fuel storage system fuel oil has a total particulate contamination greater than or equal to 10 mg/ liter or if certain properties for new fuel oil that has been added to the fuel oil storage inventory exceed their acceptance limits.

Since the presence of particulate does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is not expected to rise rapidly between surveillance frequency intervals, ard proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG i perable. In addition, clean up to lower particulate levels can be a time consuming process (removal of missile shield, re-sample, etc.) which, if not completed within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outege time for an inoperable diesel generator, could result in the commencement of a plant shutdown.

With the properties specified in 4.8.1.1.2d.2 for the new fuel oil that has been added to the fuel oil storage inventory not within the required limits, time is needed to evaluate the stored fuel oil to determine that it remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering. or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function. In other words. the EDG's can run at their ,

designed capacity on fuel oil which is of poorer quality than our limits allow. l Reg Guide 1.137 states that fuel oil not meeting applicable requirements should be i replaced "in a short period of time (about a week)." This Reg Guide also states '

that "other properties" should be analyzed (completed) within 2 weeks (this is applicable as CPSES sends samples of the diesel fuel oil off site for analysis).

Currently, a diesel generator is considered " inoperable" if the fuel oil parameters l are above limits even though the likelihood is very high that the diesel generator  ;

will still run and perform its function.

To address this matter, this technical specification change request proposes new l ACTION requirements which allows seven days to restore particulate levels and 30 days to assess the other fuel properties to determine the acceptability of the fuel oil in the storage tanks prior to declaring the associated diesel generator 1

r- ,

Attachment 2 to TXX-94307 Page 2 of 7 inoperable.

This proposed change is a line item improvement which is consistent with the applicable sections of NUREG-1431. the improved Standard Technical Specifications for Westinghouse Plants.

II. QESCRIPTION OF TECHNICAL SPECIFICATION CHANGE REQUEST The following changes are proposed for Technical Specification 3/4.8.1, "A.C.

Sources":

Add ACTIONS g and h (provided below) to Technical Specification 3.8.1.1. Add ACTIONS b and c (provided below) to Technical Specification 3.8.1.2.

Section 3.8.1 1 ACTION

g. With the fuel oil storage system total particulate contamination not within limits, restore total particulate contamination to within limits within 7 days or immediately declare the associated diesel generator inoperable and perform the applicable ACTION for an inoperable diesel generator (s).

h. With the properties specified by Surveillance Requirement 4.8.1.1.2d.2 for new fuel oil that has been added to the fuel oil storage inventory not within limits, confirm that the stored fuel oil properties are within limits or restore the stored fuel oil properties to within limits within 30 days or immediately declare the associated diesel generator inoperable and perform the applicable AC110N for an inoperable diesel generator (s).

Section 3.8.1.2 ACTION

b. With the fuel oil storage system total particulate contamination not within limits, restore the storage system fuel oil particulate contamination level to within limits within seven (7) days or immediately declare the associated diesel generator inoperable and perform ACTION a. if less than the minimum required A.C. electrical power sources are OPERABLE.

c. With the properties specified by Surveillance Requirement 4.8.1.1.2d.2 for new fuel oil that has been added to the fuel oil storage inventory not within limits. confirm that the stored fuel oil properties are within limits or restore the stored fuel oil properties to within limits within thirty (30) days or immediately declare the associated diesel generator inoperable and perform ACTION a. if less than the minimum required A.C. J.ectrical power sources are OPERABLE.

Attachment 2 to TXX-94307 Page 3 of 7 i

The BASES for Specifications 3/4.8.1.1 and 3/4.8.1.2 are revised to reflect and support the new ACTION requirements.

In summary, Technical Specifications 3.8.1.1 and 3.8.1.2 (A.C. SOURCES) are revised from requiring that a diesel generator be considered immediately inoperable when its fuel supply particulate level or new fuel properties are not within limits to allowing seven days to restore particulate levels and thirty days to confirm or restore other fuel properties for the stored fuel oil.

III. ANALYSIS The proposed change is consistent with NURL 1431. " Standard Technical Specifications, Westinghouse Plants."

With fuel oil total particulate contamination not within the required limits, it is being requested that a period of 7 days be allowed for restoring the quality of the fuel oil. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is not expected to rise rapidly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day completion time allows for further evaluation, resampling and re-analysis of the DG ,

fuel oil and more time to get particulate level within limits.

The diesel generator vendor (Cooper) places much more lenient restrictions on particulate contamination levels allowed in the fuel oil supply. This is based, in part. on the fact that there are duplex filters between the diesel fuel oil storage tanks and the diesel generator that filter down to five (5) microns. These filters can be changed out while the diesel generator is in operation which might be required if extremely high particulate contamination fuel oil was used.

The current CPSES Technical Specification requires new diesel fuel that has been added to the fuel oil storage inventory to have less than 0.05% volume of water and sediment in the fuel. The vendor specifies that new fuel oil that has been added to the fuel oil storage inventory should have less than 0.5% volume of water and sediment (Enclosure 3), or rather, ten (10) times more water and sediment than the CPSES Technical Specifications presently allow.

If converted to an equivalent mg/L number, the vendor allows many times more water and sediment in fuel oil than CPSES currently does. Also, the industry recognizes that 10ng/L 1s a very stringent number because it is analyzed for by using an ASTM standard written specifically for aviation fuels used in turbine engines. These aviation fuels are required to be much cleaner than diesel fuels due to the nature of the engines / components they are used in (Enclosure 4). In response to this, I

l 1

+ - - _

, _ . _ _ - 1

E Attachment 2 to TXX-94307 Page 4 of 7 there is an active effort within the industry to create and approve a new standard that is directly applicable to diesel engines and their particular requirements.

The other properties specified in Table 1 of ASTM-D975-1981 (Enclosure 2) are:

- Flash Point, "C

- Cloud Point, *C

- Water and Sediment, volume %

- Carbon Residue, on 10% residuum, %

Ash Weight, %

Distillation Temperatures. 'C Viscosity Sulfur, weight %

Copper Strip Corrosion Cetane Number Based on the testing for gravity, viscosity, flash point and " clear and bright"/" water and sediment", it is highly unlikely that any of these properties will exceed their acceptance value by anything more than a small amount. The impact of the exceedance is minimized as the new fuel that has been added to the '

fuel oil storage inventory is diluted by the existing stored fuel (generally by at '

least a factor of four).

A period of 30 days is allowed by NUREG-1431 for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that it remains acceptable, or to restore the stored fuel oil properties.

This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

In conclusion, extending the required compliance intervals of the fuel oil properties addressed by this request will not adversely affect the ability of the DGs to perform their safety function as the fuel oil properties could exceed the allowable lirits by several factors and still be within acceptable operation limits as specified Dy the manufacturer and industry standards.

IV. SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TU Electric has evaluated whether or not a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92(c) as discussed below:  !

p ,

l y

Attachment 2 to TXX-94307

' Page 5 of 7

1. Do the proposed changes involve a significant increase in the probability or i con!,equences of an accident previously evaluated?

The proposed changes allow 7 days to correct particulate contamination in the stored fuel oil for the diesel generators and 30 days to confirm or restore the I adequacy of the stored fuel oil if certain properties of new fuel that has been added to the fuel oil storage inventory have been discovered to exceed the specified values. These changes do not affect plant operations and the only equipment affected are the diesel generators. The ability of the diesel

+

generators to provide electrical power when needed is directly dependent upon, in part, having fuel oil of adequate quality. The only accident which is potentially initiated by a diesel generator failure is the station blackout event. The mitigation of many accidents is dependent upon the availability of at least one train of electrical power from an emergency diesel generator (EDG). With the proposed changes, the fuel oil should continue to have sufficient quality to assure the operability of the diesel generators until the particulate and other properties are returned to within limits. This is due in part to the existing fuel oil quality requirements that are more stringent than the vendor requires for the EDG to operate and the system of filters installed to insure good quality fuel actually reaches the EDG. Even though the margin provided in the quality of the fuel oil may be affected (see the response to question 3 below), adequate fuel oil quality is being maintained to assure the operability of the diesel generators and therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes: create the possibility of a new or different kind of accident from any accident previously evaluated?

There are no hardware changes and no changes in system operations involved.

These changes only affect the quality of the stored fuel oil for the diesel generators. The availability of a diesel generator has been addressed by the CPSES design and in particular by the analysis of the station blackout event.

These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes: involve a significant reduction in a margin of safety?

The margin of safety of interest for these changes is the quality of the stored fuel oil for the diesel generators as compared to minimum quality which will support the diesel generators ability to supply electrical power when needed.

Particulate contamination increases slowly over a period of time due to the chemical breakdown of the fuel oil (or its additives or the surfaces on the tanks themselves) or due to the introduction of foreign material during

n Attachment 2 to TXX-94307 Page 6 of 7 refueling activities. When considered with the fact that the existing limitation of 10 mg/L was developed for engines which require much cleaner fuel oil (aircraft engines) and that the CPSES diesel engines have in line duplex fuel oil filters which can be switched while the engine is operating, the 7 days which are being provided to restore the particulate levels do not involve a significant reduction in the margin of safety. The levels of particulate are expected to not exceed the specified value by a significant amount and the specified value is already quite conservative. Seven days is a reasonable time period in which to restore the parameter but is short enough to ensure that the contamination values do not exceed the vendors recommended fuel oil tolerances required for the EDGs to run. In a similar manner, the properties of the new fuel oil that has been added to'the fuel oil storage inventory are not expected to deviate significantly from the allowed values. The testing for gravity, viscosity, flash point, clarity, water and sediment prior to adding the new fuel oil provides adequate assurance that the stored fuel oil will be of sufficient quality to support diesel generator operation. The quality of the stored fuel oil is further protected from problems being introduced by new fuel oil that has been added to the fuel oil storage inventory by the fact that the new fuel oil is generally diluted by a factor of four or more when it is added to the storage tanks by the fuel oil that is already in the tanks. Allowing 30 days to confirm or restore the properties of the stored fuel oil when a sample of new fuel that has been added to the fuel oil storage inventory has properties which exceed their specified values does not involve a significant reduction in a margin of safety.

Conclusion:

On the basis of the above evaluations and the fact that the NRC has provided for the same changes in the improved Standard Technical Specifications (NUREG-1431), TU Electric concludes that the proposed change satisfies the no significant hazards consideration standards and does not involve a significant hazards consideration.

V. ENVIRONMENTAL EVALUATION TV Electric has evaluated the requested changes and has determined that the changes do not involve (i) a significant hazards consideration (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the requested changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the requested change is not required.

r; 1 7

Attachment 2 to TXX-94307 Page 7 of 7 VI. REFERENCES NUREG-1431. Revision 0, " Standard Technical Specifications - Westinghouse Plants", 1992 Regulatory Guide 1.137. Revision 1. " Fuel-011 Systems for Star.dby Diesel Generators", 1979

- . . - - __,