BSEP 06-0067, Request for License Amendment, Technical Specification 3.8.3, Diesel Fuel Oil, Provisions for Main Fuel Oil Storage Tank Inspection, Cleaning, or Repair

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Request for License Amendment, Technical Specification 3.8.3, Diesel Fuel Oil, Provisions for Main Fuel Oil Storage Tank Inspection, Cleaning, or Repair
ML062830043
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 09/28/2006
From: Scarola J
Progress Energy Carolinas, Progress Energy Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 06-0067, TSC-2006-03
Download: ML062830043 (27)
v • d • e


Text

SProgress Energy James Scarola Vice President Brunswick Nut lear Plant Progress Eneriy Carolinas. Inc.

September 28, 2006 SERIAL: BSEP 06-0067 10 CFR 50.90 TSC-2006-03 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Request for License Amendment Technical Specification 3.8.3, "Diesel Fuel Oil" Provisions for Main Fuel Oil Storage Tank Inspection, Cleaning, or Repair Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

is requesting a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendment revises Technical Specification 3.8.3, "Diesel Fuel Oil," to include a new Condition A.,with associated Required Action and Completion Time. The proposed Condition A.allows the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, or repair activities. An evaluation of the proposed license amendment is provided in Enclosure 1.

CP&L has evaluated the proposed change in accordance with 10 CFR 50.9 1(a)(1), using the criteria in 10 CFR 50.92(c), and determined that this change involves no significant hazards considerations.

CP&L is providing, in accordance with 10 CFR 50.9 1(b), a copy of the proposed license amendment to the designated representative for the State of North Carolina.

CP&L requests approval of the proposed amendment by September 15, 2007 and that once approved, the amendment shall be implemented within 90 days.

Regulatory commitments contained in this letter are identified in Enclosure 6. Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager - Support Services, at (910) 457-2447.

PO. Box 10429 Southport, NC 28461 A C-I T> 910.457.3698 F> 910.457.2803

Document Control Desk BSEP 06-0067 / Page 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 28, 2006.

Sincerely, James Scarolaat1 MAT/mat

Enclosures:

1. Evaluation of License Amendment Request
2. Marked-up Technical Specification Page - Unit 1
3. Typed Technical Specification Page - Unit 1
4. Typed Technical Specification Page - Unit 2
5. Marked-up Technical Specification Bases Page - Unit 1 (For Information Only)
6. List of Regulatory Commitments

Document Control Desk BSEP 06-0067 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

ESEP 06-0067 Enclosure 1 Page 1 of 9 Evaluation of Proposed License Amendment Request

Subject:

Technical Specification 3.8.3, "Diesel Fuel Oil" Provisions for Main Fuel Oil Storage Tank Inspection, Cleaning, or Repair 1.0 Description This letter is a request to amend Renewed Operating Licenses DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2.

The proposed change revises Technical Specification (TS) 3.8.3, "Diesel Fuel Oil," to permit internal inspection and cleaning of the main fuel oil storage tank. Currently, TS 3.8.3 requires diesel fuel oil level, within the main fuel oil storage tank, to be greater than or equal to 20,850 gallons per required emergency diesel generator (EDG). When diesel fuel oil level is less than 20,850 gallons and greater than 13,900 gallons per required EDG Required Action B.1 allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore level. If this is not accomplished or if the diesel fuel oil level is less than 13,900 gallons, the associated EDGs must be immediately declared inoperable per Required Action D.1. These requirements do not provide sufficient time to perform inspection, cleaning, or repair of the main fuel oil storage tank. Additionally, operability of the main fuel oil storage tank affects all four EDGs; thereby, presenting the potential of a dual unit outage to accomplish the required inspections. Therefore, a new Condition A, with associated Required Action and Completion Time is proposed. The new Condition A allows the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, or repair activities.

2.0 Proposed Change The proposed change revises TS 3.8.3, to include a new Condition A with associated Required Action and Completion Time. The proposed Condition A allows the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, or repair activities. As a result of the new Condition A, three subsequent changes are made. First, the statement "for reasons other than Condition A" is added to existing Condition B (i.e., re-lettered as Condition C). Second, existing Conditions A, B, C, and D are re-lettered as B, C, D, and E, respectively. Third, Condition D (i.e., re-lettered as Condition E) is revised to reflect the addition of a new Condition. The specific wording of the proposed changes follows;; changes made to existing conditions are bolded.

B'SEP 06-0067 Enclosure 1 Page 2 of 9 CONDITION REQUIRED ACTION COMPLETION TIME A. The main fuel oil storage tank A.1 Confirm fuel oil level in day fuel Prior to removing tank from inoperable for tank inspection, oil storage tank(s) >Ž22,650 gal service cleaning, or repair activities, per required DG.

AND PROPOSED NEW CONDITION A Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND A.2 Restore main fuel oil storage tank 14 days level to within limits.

B. One or more required DGs with B.1 Restore required day fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level in the associated day storage tank level to within limit.

fuel oil storage tank(s) < 22, 650 gal per required DG and > 17,000 gal per required DG AND Fuel oil level in the main fuel oil storage tank(s) >Ž20, 850 gal per required DG C. One or more required DGs with C.I Restore main fuel oil storage tank 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level in the main fuel oil level to within limit.

storage tank < 20, 850 gal per required DG and > 13,900 gal per required DG for reasons other than Condition A.

AND Fuel oil level in the required day fuel oil storage tank(s) > 22,650 gal per required DG D. One or more DGs with stored fuel D.1 Restore stored fuel oil total 7 days oil total particulates not within particulates to within limit.

limit.

E. Required Actions and associated E.1 Declare associated DG Immediately Completion Time of Condition A, inoperable.

B, C, or D not met.

OR One or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, C, orD.

In summary, the overall affect of the proposed amendment is to allow the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, or

B SEP 06-0067 Enclosure 1 Page 3 of 9 repair activities. Other Conditions, Required Actions, and Completion Times of the existing TS 3.8.3 are not substantially changed but rather reflect changes resulting for inclusion of a new Condition A.

3.0 Background

System Description

The EDGs comprise a major part of emergency power supply when off-site power is lost or a major accident occurs. There are four EDGs which supply power to 4160, 480, and 120 VAC loads. EDG 1 and EDG 2 supply emergency buses El and E2, respectively, and are assigned to BSEP Unit 1. EDG 3 and EDG 4 supply emergency buses E3 and E4, respectively, and are assigned to BSEP Unit 2. However, certain Unit 1 loads are supplied by emergency buses E3 and E4 and certain Unit 2 loads are supplied by emergency buses El and E2. As such, operability of a single EDG affects both Units I and 2.

The Diesel Fuel Oil System supplies each EDG with fuel oil capacity sufficient to operate that EDG for a period of approximately seven days while the EDG is operating at rated load with an approximate fuel consumption rate of 4.0 gallons per minute per EDG. The Diesel Fuel Oil System consists, in part, of:

" One main fuel oil storage tank, which contains sufficient capacity (i.e., 225,000 gallons) to provide for approximately three days of operation for each of four EDGs at rated load.

The main fuel oil storage tank is seismically designed but not seismically qualified.

" Four Seismic Class I day fuel oil storage tanks (i.e., 23,300 gallons per tank), one per EDG each located in its own vault. The day fuel oil storage tanks, in combination with the engine mounted fuel tanks, provide approximately four days of diesel generator operation at rated load. The day fuel oil storage tanks are known as the 4-day tanks.

" Four Seismic Class I engine mounted fuel tanks (i.e., 550 gallons per tank), one attached to each EDG..

Gravity fill is used to maintain fuel oil level in the 4-day tanks. Two redundant transfer pumps between each 4-day and engine mounted fuel tanks maintain fuel oil level in the engine mounted fuel tanks. Automatic makeup to the engine mounted fuel tanks occurs upon low level.

A more complete description of the Diesel Fuel Oil System can be found in Section 8.3.1.1.6.2.8 of the BSEP Updated Safety Analysis Report (UFSAR).

Needfor Change As a result of robotic tank inspections, performed in July 2005, it was determined that periodic draining of the main fuel oil storage tank would be a preferable method for performing inspection, cleaning, or repair activities. Internal tank inspection and cleaning is planned to be

E-SEP 06-0067 Enclosure 1 Page 4 of 9 performed on a 10 year frequency. It is estimated that the required draining, inspecting/cleaning, and re-filling the main fuel oil storage tank will take 7 to 10 days. The requested 14 day allowed out-of-service time provides margin should the evolution take longer than expected and eliminates the burden of a dual unit outage to accomplish the required inspections. Repair activities may be associated with the main fuel oil storage tank or components associated with the supply of fuel oil from the main fuel oil storage tank to the 4-day tanks (e.g., buied piping).

In such cases, draining of the main fuel oil tank may not be necessary; however, the new Condition A would still be entered to allow adequate time for repairs.

Carolina Power & Light Company (CP&L) plans to perform main fuel oil tank cleaning in October 2007. CP&L requests issuance of the proposed amendment by September 15, 2007, to support the planned inspection of the main fuel oil storage tank in October 2007.

4.0 Technical Analysis DetermzinisticEvaluation Currently, TS 3.8.3 requires each EDG which is required to be operable, have a minimum of 43,500 gallons of fuel oil (i.e., 20,850 gallons per EDG in the main fuel oil storage tank and 22,650 gallons in the associated 4-day tank) available for use. This provides in excess of seven days of operation at rated load with an approximate fuel consumption rate of 4.0 gallons per minute. Should less than 43,500 gallons of fuel oil be available to a required EDG the required fuel oil level must be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; otherwise, the associated EDG must be declared inoperable. If fuel oil levels drop below 13,900 gallons per EDG in the main fuel oil storage tank or 17,000 gallons in the 4-day tank, the associated EDG must immediately be declared inoperable.

The proposed change will allow the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, or repair activities. During this time period, fuel oil levels in the 4-day fuel oil storage tank, for each required EDG must be greater than 22,650 gallons. This provides approximately four days of operation at rated load with an approximate fuel consumption rate of 4.0 gallons per minute. Should less than 22,650 gallons of fuel oil be available to a required EDG, Condition E would be entered and the associated EDG must immediately be declared inoperable.

To accomplish the internal inspection, cleaning or repair affecting the main fuel oil storage tank, fuel oil in the tank will be maintained in temporary, on-site storage. Provision will be made, such that this fuel can be used to replenish the 4-day fuel oil storage tanks should the need arise.

This will ensure that a seven day fuel oil supply for each required diesel is available on-site. In the event of an emergency requiring operation of the EDGs while the main fuel oil storage tank is out-of-service, actions will be taken to return the out-of-service tank to service in an expeditious manner.

B SEP 06-0067 Enclosure 1 Page 5 of 9 As discussed in Section 8.3.1.1.6.2.8 of the BSEP UFSAR, the main fuel oil storage tank was seismically designed but not seismically qualified. To ensure supply to the 4-day tanks following damage to the main fuel oil storage tank, fuel oil can be readily obtained by truck or rail directly to BSEP, or by barge on the Cape Fear River or Intercoastal Waterway to local docks and off loaded into trucks for delivery to the site. Thus, operation in accordance with the proposed change is consistent with the existing design and evaluation of the Diesel Fuel Oil System and the proposed change will not impact the availability of the EDGs to perform their required design function of auto-starting and load sequencing during an emergency EDG dermand event.

Risk Insights A qualitative risk assessment was performed to determine whether the proposed change could cause a significant increase in Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) risks that would necessitate a quantitative risk assessment in accordance with Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Tec*hnical Specifications," dated August 1998.

The first step of the assessment was to identify any equipment or structures, modeled in the Probabilistic Safety Assessment (PSA), which could be impacted by the activities associated with inspection and cleaning of the main fuel oil storage tank. It was determined that only the EDGs and the diesel driven fire pump could potentially be impacted by the activities.

Next, an assessment of the impact of the proposed change on the availability of the EDGs and the diesel driven fire pump was performed to determine whether the activities would cause a significant increase in CDF or LERF.

Based on the design of the Diesel Fuel Oil System, the proposed change does not have a significant impact on the availability of the EDGs or the ability of the EDGs to perform their required safety function. The main fuel oil tank provides, via gravity feed, make-up to each of the four 4-day tanks. This make-up path is normally isolated, and operator action is procedurally required to refill the 4-day diesel fuel oil tanks. Each of the 4-day tanks supplies fuel oil to its corresponding EDG via one of two fuel oil transfer pumps (i.e., eight in total) to the engine mounted fuel tanks. No cross-tie exits between the 4-day tanks, and each 4-day tank, along with its associated engine mounted fuel tank, has an inventory that allows nominally four days of operation. Thus, the supply of diesel fuel oil stored in each of the 4-day tanks far exceeds the exposure window of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i.e., the exposure window of interest analyzed for mitigation systems in typical PSAs for nuclear reactors). Based upon a review of past industry loss of off-site power events since 1990, there was only one where off-site power was not available within 4 days. This LOOP event was associated with a hurricane which would provide some warning in advance of its occurrence. Thus even though there is some uncertainty associated with LOOP durations due to events such a severe weather event, the delta CDF and delta LERF are still small.

ESEP 06-0067 Enclosure 1 Page 6 of 9 Likewise, the impact of the proposed change on the availability of diesel driven fire pump is not significant and does not impact CDF or LERF. The primary differences between the current plant configuration and the configuration during inspection and repair activities are the location of the make-up diesel fuel oil supply and actions required to refill the diesel driven fire pump fuel supply storage tank. Both configurations require manual operator actions to maintain adequate fuel supply and operator action to re-fuel the diesel driven fire pump fuel tank is modeled in the existing PSA. The existing operator actions require unlocking and opening two manual isolation valves. With the main fuel oil storage tank out of service, re-supply fuel for the fire pump will require use of temporary hoses from the temporary on-site storage lo.zation.

Appropriate procedural controls and training will be developed to ensure adequate fuel oil inventory to the diesel driven fire pump from alternate supplies. As such, this difference is considered insignificant. Additionally, the critical action in the PSA is operator recognition of the need to maintain an adequate supply of diesel fuel oil to the diesel-driven fire pump. Timing is not an issue since a minimum diesel fuel oil inventory of 500 gallons is currently maintained in the diesel driven fire pump fuel tank to meet fire protection requirements, and the pump is only credited as a late injection source in a limited number of scenarios.

Additionally, the main fuel oil storage tank inspection and repair activities will be performed on-line, in accordance with the provision of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." Performing the required inspection while on-line minimizes the potential that these activities would be performed concurrent with outage configurations where electrical power defense in depth may be more limiting. Plant procedure OAP-025, "BNP Integrated Scheduling," provides the administrative controls for scheduling and managing risk associated with performing on-line work activities and implements the requirements of 10 CFR 50.65(a)(4). To limit the risk impact of on-line activities, CAP-025 requires consideration of many factors (e.g., potential weather impacts, coincident work activities, etc.) when scheduling work to ensure that risk is properly maintained. Additionally, to manage the risk impact of unforeseen events, emergent failures, or changing plant conditions, OAP-025 directs operations shift management to: (1) ensure applicable TS requirements are met, (2) ensure the plant is maintained in a safe and stable condition, (3) return the component or system to service as soon as possible, (4) minimize routine maintenance on the system during repair activities, and (5) be aware of the risk significance of an emergent failure or change in plant conditions, including severe weather conditions, and the impact on the operator's ability to control the plant, mitigate events, or place and maintain the unit in a shutdown condition.

Based on the above, it is concluded that the risk associated with shutting down either or both units, and outage risk associated with an extended shutdown, outweigh any risk associated with allowing the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing internal tank inspections and cleaning. Extending the existing allowed out-of-service time to 14 days is acceptable and is not considered to cause an increase in CDF or LERF.

B.SEP 06-0067 Enclosure I Page 7 of 9 Implementing ProcedureControls In support of the main fuel oil storage tank inspection and cleaning activities, CP&L will establish an implementing procedure to assure that the EDGs will be able to perform their intended safety function when the main fuel oil storage tank is removed from service. This procedure will include the following provisions.

  • Fuel oil removed from the main fuel oil storage tank will be readily available to replenish the 4-day tanks or supply the diesel driven fire pump should the need arise.

" Elective maintenance and testing (i.e., including performance of routine surveillances), that affects EDG operability, will not be permitted when the main fuel oil storage tank is out-of-service for inspection, cleaning, or repairs.

  • Switchyard activities and other on-site electrical maintenance that could cause any unstable offsite or on-site power conditions will not be scheduled while the main fuel oil storage tank is removed from service.

" Removal of the main fuel oil storage tank from service will not be permitted when severe weather is forecast for the area or if there is a foreseen need for EDG operation.

" Restoration of the main fuel oil storage tank will be pursued in an expeditious manner in the event that long-term EDG operation is required.

The proposed Technical Specification requirements and procedural controls will maintain necessary defense-in-depth throughout implementation of the main fuel oil storage lank inspection and cleaning activities.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration CP&L has evaluated whether or not a significant hazards consideration is involved -with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change does not alter the assumption of the accident analyses or the Technical Specification Bases. The inclusion of provisions to permit internal inspection of the main fuel oil storage tank during plant operation does not impact the availability of the EDGs to perform their intended safety function. Furthermore, while the main fuel oil storage tank is out of service, the availability of on-site and off-site fuel oil sources ensures

BSEP 06-0067 Enclosure 1 Page 8 of 9 that an adequate supply of fuel oil remains available. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not involve a physical change to the design of the Diesel Fuel Oil System, nor does it alter the assumptions of the accident analyses. The inclusion of provisions to permit internal inspection and cleaning of the main fuel oil storage tank during plant operation does not introduce any new failure modes. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change alters the method of operation of the Diesel Fuel Oil System.

However, the availability of the EDGs to perform their intended safety function is not impacted and the assumptions of the accident analyses are not altered. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, CP&L concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The BSEP design was reviewed for construction under the "General Design Criteria for Nuclear Power Plant Construction" issued for comment by the AEC in July 1967 and is cormrnitted to meet the intent of the GDC, published in the Federal Register on May 21, 1971, as Appendix A to 10 CFR Part 50.

The proposed change does not involve a physical change to the Diesel Fuel Oil System.

Therefore, conformance with the intent of General Design Criteria 2, 4, 5, and 17 is not impacted. Likewise, compliance with Regulatory Guide 1.9 "Fuel Oil Systems for Standby Diesel Generators," and Regulatory Guide 1.137 "Fuel Oil Systems for Standby Diesel Generators," as they apply to the design of diesel engine fuel oil systems, is not impacted.

B SEP 06-0067 Enclosure I Page 9 of 9 6.0 Environmental Considerations A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does 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 proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 References Precedents

1. ML032540402: Letter from US NRC to Virginia Electric and Power Company, "Surry Units 1 and 2 - Issuance of Amendments RE: Proposed Changes to the Technical Specifications for the Emergency Diesel Generator Buried Fuel Oil Storage Tanks (TAC NOS. MB6291 and MB6292)," dated September 10, 2003.

BSEP 06-0067 Enclosure 2 Marked-up Technical Specification Page - Unit 1

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE ---------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME One or more required DGs Restore required day fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the oil storage tank level to associated day fuel oil within limit.

storage tank(s) < 22,650 gal per required DG and

> 17,000 gal per required DG.

AND Fuel oil level in the main fuel oil storage tank > 20,850 gal per required DG.

(continued)

A. The main fuel oil storage tank A.1 Confirm fuel oil level in day fuel oil Prior to removing tank inoperable for tank inspection, storage tank(s) > 22,650 gal per from service cleaning, or repair activities, required DG.

AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND A.2 Restore main fuel oil storage tank 14 days level to within limits.

Brunswick Unit 1 3.8-20 Amendment No. 41

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION J REQUIRED ACTION COMPLETION TIME One or more required DGs Restore main fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the main storage tank level to within fuel oil storage tank limit.

< 20,850 gal per required DG and _>13,900 gal per required DG.

fov. YecusotA-z dte AND Fuel oil level in the required day fuel oil storage tank(s) a 22,650 gal per required DG.

+ 4 One or more DGs with Restore stored fuel oil total 7 days z9 stored fuel oil total particulates to within limit.

particulates not within limit.

(* Required Action and Declare associated DG Immediately associated Completion Time inoperable.

Condition A-B&,-er-e'ot met.

OR One or more DGs with diesel fuel oil not within limits for reasons other than Condition ,-__.

4.

I I

Brunswick Unit 1 3.8-21 Amendment No. a,

B SEP 06-0067 Enclosure 3 Typed Technical Specification Page - Unit 1

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE--------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. The main fuel oil storage A.1 Confirm fuel oil level in day Prior to removing tanks inoperable for tank fuel oil storage tank(s) tank from service inspections, cleaning, or > 22,650 gal per required repair activities. DG. AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND thereafter A.2 Restore main fuel oil 14 (days storage tank level to within limits.

B. One or more required DGs B.1 Restore required day fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> I with fuel oil level in the oil storage tank level to associated day fuel oil within limit.

storage tank(s) < 22,650 gal per required DG and

> 17,000 gal per required DG.

AND Fuel oil level in the main fuel oil storage tank > 20,850 gal per required DG.

(continued)

Brunswick Unit 1 3.8-20 Amendment No. I

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required DGs C.1 Restore main fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the main storage tank level to within fuel oil storage tank limit.

< 20,850 gal per required DG and >_13,900 gal per required DG for reasons other than Condition A.

AND Fuel oil level in the required day fuel oil storage tank(s)

> 22,650 gal per required DG.

D. One or more DGs with D.1 Restore stored fuel oil total 7 days stored fuel oil total particulates to within limit.

particulates not within limit.

E. Required Action and E.1 Declare associated DG Immediately associated Completion Time inoperable.

of Condition A, B, C, or D not met.

OR One or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, C, or D.

Brunswick Unit 1 3.8-21 Amendment No. I

BSEP 06-0067 Enclosure 4 Typed Technical Specification Page - Unit 2

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE ---------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. The main fuel oil storage A.1 Confirm fuel oil level in day Prior to removing tanks inoperable for tank fuel oil storage tank(s) tank from service inspection, cleaning, or > 22,650 gal per required repair activities. DG. AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND thereafter A.2 Restore main fuel oil 14 days storage tank level to within limits.

B. One or more required DGs B.1 Restore required day fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> I with fuel oil level in the oil storage tank level to associated day fuel oil within limit.

storage tank(s) < 22,650 gal per required DG and

> 17,000 gal per required DG.

AND Fuel oil level in the main fuel oil storage tank Ž 20,850 gal per required DG.

(continued)

Brunswick Unit 2 3.8-20 Amendment No. I

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required DGs C.1 Restore main fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the main storage tank level to within fuel oil storage tank limit.

< 20,850 gal per required DG and > 13,900 gal per required DG for reasons other than Condition A.

AND Fuel oil level in the required day fuel oil storage tank(s)

>_22,650 gal per required DG.

D. One or more DGs with D.1 Restore stored fuel oil total 7 days stored fuel oil total particulates to within limit.

particulates not within limit.

E. Required Action and E.1 Declare associated DG Immediately associated Completion Time inoperable.

of Condition A, B, C, or D not met.

OR One or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, C, or D.

Brunswick Unit 2 3.8-21 Amendment No. I

BSEP 06-0067 Enclosure 5 Marked-up Technical Specification Bases Page - Unit 1 (For Information Only)

Diesel Fuel Oil B 3.8.3 BASES (continued)

APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor arid maintain it in a safe shutdown condition after an AOO or a postulated DBA.

Because stored diesel fuel oil supports LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, is required to be within limits when the associated DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) governed by separate Condition entry and application of associated Required Actions.

etsýc Met 1e With one or more required DGs with fuel oil level in the associated day fuel oil storage tanks < 22,650 gallons per required DG and > 17,000 gallons per required DG and the fuel oil level in the main fuel oil storage tank Ž_20,850 gallons per required DG, the approximate 7 day fuel oil supply for a required DG is not available. However, Conditionis¶ restricted to fuel oil level reductions that maintain at least an approximate 6 day supply (at least an approximate 3 day supply is available in the required day fuel oil storage tanks and an approximate 3 day supply is available in the main fuel oil storage tank).

With one or more required DGs with fuel oil level in the main fuel oil storage tank < 20,850 gallons per required DG and > 13,900 gallons per required DG and the fuel oil level in the required day fuel oil storage tank(s) > 22,650 gallons per required DG, the approximate ,7 da foel' supply for a required DG is not available. However, ConditiIn restricted to fuel oil level reductions that maintain at least an approximate 6 day supply (at least an approximate 2 day supply is available in the main fuel oil storage tank and an approximate 4 day supply is available in the required day fuel oil storage tanks(s)).

(continued)

Brunswick Unit 1 B 3.8.3-3 Revision No./,

Insert for new Action A.1 A.1 The main fuel oil storage tank may be inoperable, for up to 14 days, for the purpose of performing required tank inspection, cleaning, or repair activities. Repair activities may be associated with the main fuel oil storage tank or components associated with the supply of fuel oil from the main fuel oil storage tank to the 4-day tanks (e.g., buried piping). Prior to removal of the main fuel oil storage tank from service and during this time period, fuel oil levels in the 4-day fuel oil storage tank, for each required DG, must be > 22,650 gallons. This provides approximately 4 days of operation at rated load. Should less than 22,650 gallons of fuel oil be available to a required DG, Condition E would be entered and the associated DG must immediately be declared inoperable.

A period of 14 days is considered sufficient to perform the required tank inspection activities and complete restoration of the required fuel oil level in the main fuel oil storage tank prior to declaring the associated DG inoperable. This period is acceptable based on (1) the remaining fuel oil capacity (> approximately 4 days per required DG), (2) control of the maintenance activity in accordance with 10 CFR 50.65(a)(4), thereby limiting the risk impact of on-line activities through consideration of factors such as potential weather impacts, coincide:nt work activities, etc., and (3) a qualitative risk assessment which demonstrated that this activity has an insignificant impact on Core Damage Frequency (CDF) and Large Early Release Frequency (LERF). Additionally, when Condition A is entered, the following controls will be established consistent with the assumptions of the qualitative risk assessment.

" Fuel oil removed from the main fuel oil storage tank will be readily available to replenish the 4-day tanks or supply the diesel driven fire pump should the need arise.

  • Elective maintenance and testing (i.e., including performance of routine surveillances), that affects EDG operability, will not be permitted when the main fuel oil storage tank is out-of-service for inspection, cleaning or repairs.

" Switchyard activities and other on-site electrical maintenance that could cause any unstable offsite or on-site power conditions will not be scheduled while the main fuel oil storage tank is removed from service.

" Removal of the main fuel oil storage tank from service will not be permitted when severe weather is forecast for the area or if there is a foreseen need for EDG operation.

" Restoration of the main fuel oil storage tank will be pursued in an expeditious manner in the event that long-term EDG operation is required.

Diesel Fuel Oil B 3.8.3 BASES ACTIONS A.*, s4-4.-. (continued)

These circumstances may be caused by events such as:

a. Full load operation required for an inadvertent start while at minimum required level; or
b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of otheroil quality degradations. , . ,

These restrictions (Required Actions A-4-and-8.') allow sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> approximately 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

This Condition is entered as a result of a failure to meet the acceptance criterion for particulates. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since 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.

(continued)

Brunswick Unit I B 3.8.3-4 Revision No./ I

Diesel Fuel Oil B 3.8.3 BASES ACTIONS __Do-'

(continued)

With a Required Action and associate dCompletion Time of Condition-A-,

, not met, or the stored diesel f oil not within limits for reasons other than addressed by Conditions AB, t e, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for approximately 7 days at rated load. The approximate 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location. For the purposes of this SR, the verification of the main fuel oil storage tank fuel oil volume is performed on a per DG basis. This per DG volume is obtained using the following equation:

MvOU - Uvo, UVOL NDo

where MVOL = measured fuel oil volume of the main fuel oil storage tank, UvoL unusable fuel oil volume of the main fuel oil storage tank, and NDG number of DGs required to be OPERABLE.

The results from this equation must be > 20,850 gallons in order to satisfy the acceptance criteria of SR 3.8.3.1.b.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

(continued)

Brunswick Unit 1 B 3.8.3-5 Revision No./

BSEP 06-0067 Enclosure 6 Page 1 of 1 List Of Regulatory Commitments The following table identifies those actions committed to by Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc. in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to the Manager - Support Services at the Brunswick Steam Electric Plant (BSEP).

Commitment I Schedule In support of the main fuel oil storage tank inspection and Prior to removing the cleaning activities, CP&L will establish an implementing main fuel oil storage procedure to assure that the EDGs will be able to perform their tank from service in intended safety function when the main fuel oil storage tank is accordance with the removed from service. This procedure will include the proposed Condition A of following provisions. Technical Specification

" Fuel oil removed from the main fuel oil storage tank will be (TS) 3.8.3.

readily available to replenish the 4-day tanks or supply the diesel driven fire pump should the need arise.

" Elective maintenance and testing (i.e., including performance of routine surveillances), that affects EDG operability, will not be permitted when the main fuel oil storage tank is out-of-service for inspection, cleaning or repairs.

" Switchyard activities and other on-site electrical maintenance that could cause any unstable offsite or on-site power conditions will not be scheduled while the main fuel oil storage tank is removed from service.

" Removal of the main fuel oil storage tank from service will not be permitted when severe weather is forecast for the area or if there is a foreseen need for EDG operation.

" Restoration of the main fuel oil storage tank will be pursued in an expeditious manner in the event that long-term EDG operation is required.

With the main fuel oil storage tank out-of-service, re-supply fuel Prior to removing the for the fire pump will require use of temporary hoses from the main fuel oil storage temporary on-site storage location. Appropriate procedural tank from service in controls and training will be developed to ensure adequate fuel accordance with the oil inventory to the diesel driven fire pump from alternate proposed Condition A of supplies. TS 3.8.3.

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