ML20079B153
| ML20079B153 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/10/1991 |
| From: | Wallace E TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-76130, TAC-76131, TAC-76132, NUDOCS 9106140024 | |
| Download: ML20079B153 (6) | |
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'JUN 10 7991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Centlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - REQUEST FOR ADDITIONAL INFORMATION ON BFN'S DIESEL GENERATOR FUEL OIL (DFO) SAMPLING REQUIREMENTS
Reference:
NRC letter to TVA dated February 12, 1991, 1) Issuance of Amendments Concerning Diesel Generator Technical Specifications (TAC NOS. 76130, 76131, and 76132) (TS 277) -
BFN, Units 1, 2, and 3; 2) Request For Additional Information The purpose of this letter is to respond to the request for additional information contained in the referenced NRC letter.
Specifically, NRC requested TVA to review Section 4.9 of BFN's Technical Specifications (TS) against the NRC Standard Technical Specifications (STS) for Boiling Water Reactors in the area of requirements on sampling DFO, to determine if additional TS requirements are needed to assure the high quality of the fuel oil and the operation of the diesel generators.
Additionally, NRC stated, in the Safety Evaluation transmitted by the referenced letter, that BFN TS did not address the following requirements prescribed in the STS:
- 1) removing water periodically from the tanks, 2) testing new fuel oil prior to its addition to the 7-day fuel storage tanks, and
- 3) sampling the fuel oil from the 7-day fuel storage tanks in accordance with ASTM-D270-1975.
The enclosure provides the results of a comparison study which responds to NRC's questions regarding TVA's methodology for sampling of DF0 at BFN.
Raced en this study, TVA has concluded that the DF0 program assures the integrity of the fue' oil and the operation of the diesel generators. Although BFN's TS do not explicitly provide DF0 sampling requirements equivalent to the STS, existing BFN practices and procedures implement DFO sampling, which provide the same high level of assurance.
Accordingly, revising the existing BFN TS to explicitly piovide an additional level of detail for DF0 sampling would have no safety benefit.
0 9106140024 910610 D
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2 U.S. Nuclear Regulatory Commission JiUN 101991 There are no commitmento contained in this submittal. Copies of the TVA procedures referenced in the enclosure ars available at the TVA office in Rockville, Maryland, for NRC's review.
If you have any questions, pleaso telephone Patrick P. Carler at (205) 729-3566.
Very truly yours.
TENNESSEE VALLEY AUTHORITY
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Nucleat icensing and Regulatory Affairs Enclosure cc (Enclosure ):
Ms. S. C. Black, Deputy Director Project Dlrectorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager l
U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockvillo Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Coorgia 30?'.3 l
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ENCLOSURE BFN DIESEL CENERATOR FUEL OIL SAMPLING COMPARISON STUDY page 1 of 4 Referenco:
NHC letter to TVA dated February 12, 1991, 1) Issuance of Amendments Concerning Diesel Generator Technical Specifications (TAC NOS. 76130, 16131, and 76132) (TS 277) - BFN, Units 1, 2, and 3; 2) Request For Additional Information The following is a comparison study between the NRC's Standard Technical Specifications (STS) for Bolling Water Feactors and Browns Ferry Nuclear plant (DFN) diesol generator fuel oil (DFO) sampling program. The specific items (Items 1 thru 3) that were questioned by NRC in the reference lotter and other BFN program information pertaining to BFN DF0 sampling methods (Item 4) are addressed as follows:
Item 1.0:
NRC's Area of Concern:
Removal of evater periodically from diesel tanks.
TVA's Response: This requirement is stated in the following STS sections:
STS 4.8.1.1.2.b -
requires in part that the day tank be checked for and remove accumulated water when the engine is operrted for one hour or more.
a STS 4.8.1.1.2.c -
requires in part that the water be removed from the fuel oil storage tanks every 31 days.
These STS requirements are implemented at BFN by C1-130 (Monitoring Schedule and Documentation of Diesel Fuel Oil and Specific Lubricating 0118) and 0-TI-158 ( Alternate Method for Representativo Sampling of the Diesel Conerator 7-Day Tank Fuel 011) procedures.
CI-130 requires that the day tank be checked monthly for water after the diesel generator has been operating for one hour. CI-130 requires that the outside DF0 storage tank be checked monthly for water and removed if found, and CI-130 in conjunction with 0-TI-158, requires that the 7-day storage tanks be checked for water once a month and removed if found.
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Itfm 2.0:
NHC's Area of Concern:
Testing now fuel oil prior to addition to the 7-day fuel oil storage tanks.
TVA's Response:
This requirement is stated in the following STS section:
STS-4.8.1.1.2.d - requires in part that prior to addition of new fuel to the storage tanks a sample must be taken and meet the minimum requirements and is tested within the specified time:
- 1) as soon as sample is taken, or from new fuel prior to addition to the storage tank, as applicable, verify per ASTM-D975-77 that the sample has:
a) water / sediment content 5 0.5 volume b) kinematic viscosity 9 40*C 2 1.9 s 4.1 centistokes c) specific gravity
- 2) within one week after obtaini.ig sample, verify an impurity level of less than 2mg of insolubles per 100ml when tested by ASTM-D2274 latest revision.
- 3) within two weeks verify the other properties specified in Table 1 of ASTM-D975-77 and Regulatory Guide 1.137.
BFN procedures CI-643 (specific gravity), C1-626 (flash point) and SDSp 16.11 (Bulk Chemical control) prescribe the requirements that implement the above listed STS minimum requirements. These procedures ensure that the new DFO is qualified prior to transfer to the 7-day fuel oil storage tank from the No. 1 outside receipt storage tank.
Specifically, a sample is taken from each shipment (each truck load) and analyzed for specific gravity, flash point, and water / sediment (visually), prior to transferring the DFO from the truck to the No. I storage tank. The water / sediment content is analyzed per ASTM-D1796 (Test for Water and Sediment in Crude Oils and Fuel Oils by Centrifuge) as prescribed in SDSp 16.11.
After this sample is verified to be within the limits required by these tests, the DF0 shipment is transferred to the No. I storage tank and held until the DFO quality is verified by TVA's central laboratory to be within the specification requirements in SDSP 16.11 ( ASTM-D975-1989).
In accordance with SDSP 16.11, TVA's central laboratory analyzes the DF0 for:
- 1. Kinematic viscosity per ASTM-D445 (Test for Kinematic Viscosity of Transparent and Opaque Liquids);
- 2. Impurity level per ASTM-D2274 (Test for Oxidation Stability of Distillate Fuel 011); and
- 3. Other properties specified in Table 1 of ASTM-D975-89.
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page 3 of 4 These tests are performed at TVA's central laboratory within thirty calendar days of BFN's receipt of the new fuel oil. Upon completion of this testing, an official data report is sent to BFN for documentation of the fuel quality.
After the fuel quality has been verified in the No. I storage tank, it is then transferred to No. 2 outside DFO storage tank to be utilized specifically for the etacrgency diesel generator 7-day storage tanks. This transfer of fuel oil is covered by SDSp 16.11.
Item 3.0:
NRC's Area of Concern:
Sampling fuel oil from the 7-day fuel storage tanks in accordance with ASTH-D270-1975.
TVA's Hosponse:
This requirement is stated in the following STS section:
STS 4.8.1.1.2.d - requires in part that at least once per 92 days obtain a sample per ASTH-D270-1975 of the storage tanks, and verify that the sample meets the minimum requirements.
The STS requirements are implemented by C1-130,1-SI-4.9. A.1.0 (Quarterly Fuel Oil Quality Determination of Unit 1 Diesel Generator 7-day Storage Tank Supply) and 3-SI-4.9. A.1.e (Quarterly Fuel Oil Quality Determination of Unit 3 Diesel Generator 7-day Storage Tank Supply).
C1-1J0 - requires that the outside storage tanks No. 1 and No. 2 be analyzed every three months in accordance with ASTM-D975-1989.
1-SI-4.9.A.1.e and 3-SI-4.9.a.1.e prescribe requirements for obtaining a DFO sample from the 7-day storage tanks. These two sis also require that the 7-day storage tanks be analyzed every three months in accordance with ASTM-D975-1989.
It should be noted that ASTM-D270-1975, which prescribes DF0 sampling methods, was superceded by ASTM D4057-1981 (Manual Sampling of Petroleum and Petroleum products). The sampling methods contained in 1-SI-4.9.A.1.0 and 3-SI-4.9.c.1.e meet the requirements contained in ASTM D4057-1981.
The sampling methods used at BFN for the 7-day tanks involves taki.ng a sample from the lower level of the middle assembly (each 7-day tank consists of 3 tank assemblies) at approximately two inches from the bottom of the tank. This sample is taken after the DFO has boon recirculated approximately five pipe volumes through the transfer pump system. The sample is then analyzed in accordance with ASTM-D975-1989.
Item 4.0:
Other BFN program information:
A.
STS-4.8.1.1.2.g - requires in part that at least every ten years:
- 1) Drain each fuel oil tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution.
Page 4 of 4 The DFO storage tanks No. 1, No. 2, and the 7-day tanks are scheduled to be cleaned every ten years and is implemented by the BFN preventive maintenanco program, TI-94 (Requirements and procedures for Cleaning the 7-day Diesel Fuel Oil Storage Tanks), and MMG-004 (Cleaning of Yard Fuel Oil Storage Tanks).
The DF0 storage tanks no. I and 2 were last cleaned in September 1984, and will be cleaned again in September 1994. The 7-day storage tanks were last cleaned in September 1986, and will be cleaned again in September 1996.
B.
DF0 Quality Program:
Fuel oil quality is ensured by the following:
CI-636 (BRIGHT AND CLEAR)
CI-643 (SPECIFIC CRAVITY)
CI-626 (FLASH POINT)
C1-800 (BULK CHEMICAL CONTROL, SAMPLINC, AND PREPARATION)
DF0 quality data is verified by the Chemical Technical Support chemist.
In addition, BFN is currently in the process of qualifying an independent laboratory to provide backup and periodic crosschecks as needed.
SUMMARY
Based on this study. TVA has concluded that the DF0 program assures the integrity of the fuel oil and the operation of the diesel generators.
Although BFN's TS do not explicitly irovide DF0 sampling requirements equivalent to the STS, existing BFN practices and procedures implement DFO sampling, which provide the same high level of assurance. Accordingly, revisin; the existing BFN TS to explicitly provide an additional level of detail :.or DFO sampling would have no safety benefit.
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