ML20065B954

LAR 94-007 to Licenses NPF-87 & NPF-89,revising TS to Allow Use of ASTM-D1796-1968 as Alternative Method for Determining Acceptability of Water & Sediment in New DG Fuel Oil Receipts

ML20065B954
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1994
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20065B957	List: ML20065B954 ML20065B960
References
TXX-94099, NUDOCS 9404040220
Download: ML20065B954 (8)

Text

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Log # TXX-94099 '

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File # 916 (3/4.8) 10010 EEE 335 Ref. # 10CFR50.90 10CFR50.36 TUELECTRIC gocyago,29

"*""'J- '" l' March 30, 1994 Gwup Vu e Prrsudest 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 94-007 EMERGENCY DIESEL GENERATOR FUEL OIL SURVEILLANCE TESTING Gentlemen:

Pursuant to 10CFR50.90, TV Electric hereby requests an amendment to the CPSES Unit 1 Facility Operating Licensing (NPF-87) and CPSES Unit 2 Facility Operating License (NPF-89) by incorporating the attached change into the CPSES Units 1 and 2 Technical Specifications.

Technical Sepcification Surveillance Requirement 4.8.1.1.2d requires that prior to addition to the storage tanks, new fuel oil shall be tested in accordance with ASTM-D975-1981. It also requires verification that the sample has "a clear and bright appearance with proper color" when tested in accordance with ASTM-D4176-1982. The requested change modifies the CPSES Technical Specifications to provide an alternate test method for assessing the acceptability of the new fuel oil. The alternate method requires verification that the new fuel oil sample contains less than or equal to 0.05% volume water and sediment, when tested in accordance with ASTM-01796-1968.

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 propose change does not involve a significant hazard consideration. Attachment 3 provides the affected Technical Specification pages, marked up to reflect the proposed change.

Also enclosed are copies of 40CFR80.29, " Fuels and Fuel Additives";

58FR68304-26CFR Parts-47 and 48. " Amendments to the Temporary Fuel Floor Stocks Taxes Regulations"; and Internal Revene Service Notice 94-21.

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

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TXX-94099 Page 2 of 2

, 'TU Electric requests approval as quickly as reasonably possible to avoid I impact on plant operations and potential technical specification compliance l p robl ems . Upon NRC approval of the requested changes, .TV Electric requests a 30 day implementation period following the date of license amendment issuance. )

i Should you have any questions regarding the requested amendment, please  ;

contact Mr. Manu Patel at (214) 812-8298. l Sincerely, f . ) ~

William J. Cahill, Jr.

By: Yf O_

Roger li. Walker Regulatory Affairs Manager MCP/grp Attachments: 1. Affidavit

2. Description and Assessment l 3. Affected Technical Specification pages (NUREG-1468) as revised

Enclosures:

1. 40CFR80.29, Fuel and Fuel Additives

2. 26 CFR Parts 47 and 48, Regulations on Diesel Fuel Oil

! 3. Internal Revenue Service Notice 94-21 of February 18, 1994 c- Mr. L. J. Callan, Region IV Mr. L. A. Yandell, Region IV Mr. T. A. Bergman, NRR Resident inspectors, CPSES (2)

Mr. D. K. Lacker Bureau of Radiation Control Texas Department of Public Health 1110 West 49th Street Austin, Texas 78704 l

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Attachment 1 to TXX-94099 l Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

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) .I Texas Utilities Electric Comoany ) Docket Nos. 50-445

) 50-446 (Comanche Peak Steam Electric )

Station. Units 1 & 2) )

AFFIDAVIT Roger D. Walker being duly swcrn, hereby deposes and says that he is Regulatory Affairs Manager of TV Electric, that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 94-007; that he is familiar with the content thereof; and that the- I matters set forth therein are true and correct to the best of his knowledge, information and belief.

Roger D YWalker Regulatory Affairs Manager STATE OF TEXAS )

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COUNTY OF DALLAS)

Subscribed and sworn to before me, a Notary Public, on this 28th day of March , 1994.

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-2 ATTACHMENT 2 TO TXX-94099 DESCRIPTION AND ASSESSMENT i

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Attachment 2 to TXX-94099 Page 2 of 5 DESCRIPTION AND ASSESSMENT I. BACKGROUER ,

1 The Comanche Peak Steam Electric Station *s (CPSES) Diesel Generators operate using high sulf ur, non-highway diesel fuel oil . Effective October 1, 1993, l the Environmental Protection Agency (EPA), in accordance with 40 CFR 80.29,  ;

requires that high sulfur, non-highway diesel fuel oil be dyed blue with 1.4 )

dialkylamino anthraquinone. The concentrat.on of the dye in the fuel oil is l not specified by the EPA. Effective January 1,1994, the Internal Revenue Service (IRS) in accordance with 26 CFR 48.4082-1T as amended by IRS Notice I 94-21 requires high sulfur diesel fuel oil to be dyed blue with the same dye '

specified by the EPA, but in a concentration of at least 1.2 pounds of active ingredient (exclusive of the solvent) per thousand barrels of diesel fuel. 1 The present dye concentration has not posed a problem with Technical Specification compliance: however, the amended IRS regulations also require the use of increased amounts of the blue dye (specified as color index solvent l blue 98) in concentrations of at least 4 pounds after March 31, 1994, and of  !

at least 10 pounds after June 30. 1994, of active ingredient (exclusive of the j solvent) per thousand barrels of diesel fuel. The IRS requirement to dye high sulfur diesel fuel oil facilitates the detection of tax evasion.

1 Texas Utilities (TV) Electric recently obtained a sample of the dye and l prepared mixtures of dyed diesel fuel oil at different concentrations. The acceptability of the mixture at approximately the concentration of dye required by the amended IRS regulations from~ March 31, 1994, through June 30, 1994, as new fuel oil at CPSES would have been in doubt for two reasons. (1) The CPSES Technical Specification's specify the use of ASTM-D4176-1982., which requires that the fuel oil possess a color of ASTM 5 or less. The dyed fuel oil was darker than ASTM 5. (2) The color of the dyed fuel oil was too dark to detect water and sediment via visual observation.

The ability to detect water and sediment visually is inherent in performing a

" clear and bright" test in accordance with the Technical Specifications.

TU Electric is thereby requesting a change to the CPSES Technical Specifications allowing the use of ASTH-01796-1968 as an alternate method for determining the acceptability of water and sediment in new Diesel Generator fuel oil receipts. Implementation of the requested change will allow CPSES to continue to receive Diesel Generator fuel oil that meets the detailed

- requirements of ASTM-D975-1981.

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Attachment 2 to TXX-94099 l Page 3 of 5 j i

II. DESCRIPTION OF TECHNICAL SPECIFICATION CHANGE REQUEST )

l The following specific change is proposed for Technical Specification 3/4.8,1, "A.C. Sources":

Surveillance Requirement 4.8.1.1.2d.1) states, in part, the following regarding the acceptability of new fuel oil, "By verifying in accordance with the tests specified in l ASTM-D975-1981 ... that the sample has ... a clear and bright appearance with proper color when tested in accordance with ASTM-04176-1982." 4 The requested change revises section 4.8.1.1.2d.1)d) to allow an alternative test to the ' clear and bright" test of ASTM-04176-1982 The alternate test would verify that the new fuel oil sample "has a water and sediment content of less than or equal to 0.05% volume".

In summation, the change does not delete any of the present .

surveillance requirements, but provides an alternative test method for determining the acceptability of new fuel oil. In accordance with ASTM-0975-1981, the new method utilizes ASTM-D1796-1968, with an acceptance limit of 0.05% water and sediment Lby volume.

i III. ANALYSIS i

The change to surveillance requirement 4.8.1.1.2d.1)d), described above continues to provide an adequate level of safety. The amended IRS regulations

• which are required to be implemented as of April 1,1994, may prevent the acceptability determination of new Diesel Generator fuel oil in accordance with ASTM-D4176-1982. TV Electric has researched the bases .for the acceptance criterion of fuel oil testing performed in accordance with ASTM-D4176-1982, '

and concluded that the quantitative acceptance criterion for water and sediment in No. 2 Diesel Generator fuel oil is presented in ASTM-D975-1981.

The acceptance criterion as presented in ASTM-D975-1981, is less than or equal to 0.05% volume water and sediment. TV Electric's conclusion is supported by the CPSES Unit 1 and 2 Technical Specifications which bases overall acceptance -

of new fuel on ASTM-D975-1981. In addition, the version of the Westinghouse Standard Technical Specifications which was provided by the NRC-(Reference 1) for use in developing the CPSES Technical Specifications, contains this same criterion.

ASTM-D4176-1982, provides a pass /f ail test' which confirms that the fuel oil is

• clear and bright." ASTM-D1796-1968 provides test methodology that allows confirmation that the percent volume of water and sediment 'is less than or  ;

equal to 0.05%. These test methods provide an essentially equivalent level of ,

assurance that the level of water and sediment in new fuel oil is low enough to allow its use at CPSES.

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I Attachment 2 to TXX-94099 Page'4 of 5  :

IV. ElGHIFICANT HAZARDS CONSIDERATION DETERMINATION As required by 10 CFR 50.91(a)(1), an analysis is provided below-to demonstrate that the requested license amendment involves no significant hazards considerations.

1. Operation of the CPSES in accordance with the requested license amendment does not involve a significant increase in the probability or ,

consequences of an accident previously evaluated.

Either the current testing option, which remains valid for fuel oil with  !

ASTM Color 5 or less, or the alternative testing method, provide the ,

necessary assurance that the water and sediment quantity in the new fuel oil is acceptable. As the performance of the quantitative water and -

sediment test of ASTM-D1796-1968, maintains essentially the same ,

attribute qualities of the new fuel oil, there should not be any  ;

undetected degradation in the Diesel Generator fuel oil supply. t Therefore, since the fuel oil supply will be maintained at its. present quality level, there should be no increase in the probability or consequences of an accident previously evaluated.

2. The requested license amendment does not create the possibility.of a new- l or different kind of accident from any accident previously evaluated.

As stated in 1) above, the proposed amendment only provides a quantitative method for the acceptability determination'of new' Diesel' Generator fuel oil. The proposed testing will continue to verify the high quality and acceptability of the fuel oil supply. There should not be any possibility that a new or different kind of accident from those previously evaluated is created.

3. The requested license amendment does not involve a significant reduction in a margin of safety.

The only margin associated with this amendment is the margin between the acceptance limit on water and sediment in the fuel oil supply and the quantity of water and sediment that could impact Diesel Generator operation. The " clear aad bright" testing per ASTM-D4176-1982 and the proposed quantitative testing per ASTH-D1796-1968 are both written to detect and reject fuel oil containing water or sediment at essentially. ')

the same level . The margin of safety to Diesel Generator impairment is l therefore not reduced. This amendment request does not involve a l significant reduction in a margin of safety. j i

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T Attachment'2 to TXX 94099 2

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Conclusion:

On the basis of the above evaluations, TU Electric concludes that the -l activities associated with the requested changes satisfy the no significant ~j hazards consideration standards of 10 CFR 50.92(c).and, accordingly, a no ..

significant hazards consideration finding is justified.

V. ENVIRONMENTAL EVALUATION TU 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'ofLany 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.

VI. REFERENCES

1) NRC letter dated August 14, 1987, transmitting " Standard Technical Specifications for Westinghouse Pressurf zed Water Reactors," applicable to CPSES.

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