JAFP-08-0006, Application for Amendment to Technical Specifications Regarding Diesel Fuel Oil, Lube Oil, and Starting Air Consistent with TSTF-501 and Diesel Fuel Oil Testing Program Consistent with TSTF-374

Application for Amendment to Technical Specifications Regarding Diesel Fuel Oil, Lube Oil, and Starting Air Consistent with TSTF-501 and Diesel Fuel Oil Testing Program Consistent with TSTF-374

ML080290664
Person / Time
Site:	FitzPatrick
Issue date:	01/22/2008
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-07-0088
Download: ML080290664 (32)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP

" Entergy P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 Pete Dietrich Site Vice President - JAF January 22, 2008 JAFP-08-0006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Application for Amendment to Technical Specifications Regarding Diesel Fuel Oil. Lube Oil, and Starting Air Consistent with TSTF-501 and Diesel Fuel Oil' Testing Program consistent with TSTF-374

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby requests an amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF);

The proposed amendment would modify TS requirements related to Diesel Fuel Oil, Lube Oil, and Starting Air consistent with TSTF-501, which has been submitted to the NRC, and Diesel Fuel Oil Testing Program consistent with TSTF-374 which has been approved by the NRC.

Attachment I provides a description and evaluation of the proposed TS changes.

Attachment 2 provides the proposed changes to the current TS on marked up pages.

Attachment 3 provides the proposed TS changes in final typed format.

Attachment 4 provides the proposed changes to the current TS Bases on marked up pages. The Bases changes are provided for NRC information only. The final TS Bases pages will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS)

Bases Control Program".

Entergy requests NRC approval of the proposed TS amendment by September 28, 2008, with the amendment being implemented within 60 days from approval.

JAFP-08-0006 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with the associated attachments, is being provided to the designated New York State official.

There are no new commitments made in this letter.

Should you have any questions concerning this submittal, please contact Mr. Jim Costedio at 315-349-6358.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 2 2 nd day of January, 2008.

PD/ed Attachments: 1. Description and evaluation of the proposed TS changes

2. Proposed changes to the current TS on marked up pages

3. Proposed TS changes in final typed format

4. Proposed changes to the current TS Bases on marked up pages cc: next page

cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office U.S. Nuclear Regulatory, Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. John P. Boska, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 1 h Floor Albany, NY 12223 Mr. Paul Tonko, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399

JAFP-08-0006 Attachment 1 Description and Evaluation Application for Amendment to Technical Specifications Regarding Diesel Fuel Oil, Lube Oil, and Starting Air Consistent with TSTF-501 And Diesel Fuel Oil Testing Program Consistent with TSTF-374

JAFP-08-0006 Attachment I 1.0 Description The proposed amendment would modify the Technical Specification (TS) requirements related to Diesel Fuel Oil, Lube Oil, and Starting Air consistent with TSTF-501 (reference 1), including our response to the associated NRC Request for Additional Information (reference 7), by replacing the specific fuel oil and lube oil storage volumes with a requirement to maintain greater than or equal to a seven (7) day supply for both the diesel fuel oil and lube oil while retaining the specific tank volumes needed to meet the 7 day requirement in the TS Bases. This change will also address, through the TS Bases mark-up, a more restrictive change in the required volume of diesel fuel oil to support seven (7) days of continuous operation. The proposed changes will also revise the fuel oil color testing requirement to include water and sediment content within limits consistent with TSTF-374 (reference 2).

The changes to the Diesel Fuel Oil, Lube Oil, and Starting Air Specification (LCO 3.8.3) are intended to ensure that the information required by 10CFR50.36 is maintained in the Technical Specifications and that the specific design value for volume that needs to be maintained in the fuel oil and lube oil storage tanks are located in a licensee controlled document (i.e., the TS Bases). The TS Bases are controlled in accordance with TS 5.5.11, "Technical Specifications (TS) Bases Control Program".

During the FitzPatrick conversion from Custom Technical Specifications (CTS) to the Improved Standard Technical Specifications (ITS), the references to the applicable ASTM Fuel Oil Testing Standards were relocated to the TS Bases as described in TSTF-374. However, the conversion did not include the option to perform the water and sediment test in lieu of the fuel oil "clear and bright" test. The proposed change provides this option.

2.0 Proposed Changes TS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air Condition A states "One or more EDGs with fuel oil level < 32,000 gal and > 28,000 gal in storage tank." The proposed change revises Condition A to state, "One or more EDGs with fuel oil level < a 7 day supply and > a 6 day supply in storage tank." The Bases of Required Action A. 1 is revised to state "With fuel oil level less than the level shown in Table B3.8.3-1 in a storage tank, the 7 day fuel oil supply for an EDG is not available.

However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply as shown in Table B3.8.3-2."

Page 1 of 9

JAFP-08-0006 Attachment 1 Condition B states "One or more EDGs with lube oil inventory < 168 gal and > 144 gal."

The proposed change revises Condition B to state, "One or more EDGs with lube oil inventory < a 7 day supply and > a 6 day supply." The Bases of Required Action B.1 is revised to state "With lube oil inventory < 168 gal, sufficient lube oil to support 7 days of continuous EDG operation at full load conditions may not be available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply (144 gal)."

Surveillance Requirement (SR) 3.8.3.1 states "Verify each fuel oil storage tank contains

> 32,000 gal of fuel." The proposed change revises SR 3.8.3.1 to state, "Verify each fuel oil storage tank contains > a 7 day supply of fuel." The Bases of SR 3.8.3.1 are revised to add a sentence which states "The fuel oil level equivalent to a 7 day supply is shown in Table B3.8.3-1 gallons when calculated in accordance with References 3, 4, and 6."

SR 3.8.3.2 states "Verify lube oil inventory of each EDG is > 168 gal." The proposed change revises SR 3.8.3.2 to state, "Verify lube oil inventory of each EDG is ?: a 7 day supply." The Bases of SR 3.8.3.2 are revised to add a sentence which states "The lube oil level equivalent to a 7 day supply is 168 gallons."

TS 5.5.10 Diesel Fuel Oil Testing Program TS 5.5.10.a.3 states "A clear and bright appearance with proper color;". The proposed change revises TS 5.5.10.a.3 to state, "A clear and bright appearance with proper color or water and sediment content within limits;". SR 3.8.3.3 requires verifying fuel oil properties in accordance with the Fuel Oil Testing Program, the Bases of SR 3.8.3.3, are revised to reference the applicable ASTM testing standard for water and sediment testing.

In summary, consistent with TSTF-501 and TSTF-374, the proposed TS changes revise TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" and TS 5.5.10, "Diesel Fuel Oil Testing Program." Proposed revisions to the TS Bases for TS 3.8.3 are also included in this application. The copies of the TS Bases pages are provided for NRC information only. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

3.0 Background

In January 2001 and in June 2004, the U.S. Environmental Protection Agency (EPA) finalized the Clean Diesel Trucks and Buses Rule and the Clean Nonroad Diesel Rule, respectively, with more stringent standards for new diesel engines and fuels (See NRC Information Notice 2006-22, "New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," October 12, 2006.) The EPA rules require a reduction in the sulfur content of highway diesel fuel from its current level of 500 parts per million (ppm) (low sulfur diesel, or LSD) to 15 ppm (Ultra Low Sulfur Diesel, or ULSD). Refiners were required to start producing the cleaner-burning diesel fuel ULSD, for use in highway vehicles beginning June 1, 2006.

Page 2 of 9

JAFP-08-0006 Attachment I The EPA requires sulfur reductions for land-based nonroad diesel fuel to be accomplished in two steps, with an interim step from currently uncontrolled levels to a 500 ppm cap starting in June 2007 and the final step to 15 ppm in June 2010. Although the EPA requirements for the 15 ppm ULSD do not take effect until 2010 for nonroad diesel fuel, several nuclear power plant licensees have received shipments of ULSD. The California Air Resources Board regulations required that all California users of diesel fuel oil transition to ULSD fuel oil by June 1, 2006.

In reviewing the design calculation establishing the basis for the 7 day volume, Entergy determined that the current 7 day volume specified in TS 3.8.3 is non-conservative. The calculational method outlined in ANSI/ANS 59.51-1997 (reference 4, formerly ANSI N195) requires that the minimum acceptable fuel oil parameters allowed by ASTM D975-1995 (reference 5) be used to assess the volumetric energy content. It was determined that lower density fuels (API gravity at 60'F of greater than 31 0) require volumes in excess of 32,000 gallons to support 7 days of continuous operation. While the process required to reduce sulfur content and lower aromatic content is related to the density of the fuel, the specification of specific sulfur and aromatic content has only a nominal impact on the calculation. The most significant fuel parameter is the API gravity.

By letter to the Technical Specification Task Force dated December 13, 2007, NRC requested additional information related to TSTF-501. Specifically, NRC asked the industry to, "1) [d]iscuss what effects a mixture of ULSD and LSD fuel in the storage tank will have on the fuel consumption rate, in order to ensure that a [7] day supply is maintained, as required by the TS per Criterion 3 of 10 CFR 50.36(d)(2)(ii), 2) [d]iscuss how storage sampling will be performed (including acceptance criteria), in order to verify that any assumptions used in the fuel consumption rate calculation are valid, thereby ensuring that a [7] day supply is maintained, as required by the TS per Criterion 3 of 10 CFR 50.36(d)(2)(ii), and 3) [d]iscuss the effects of deleting the reference to Appendix B in ANSI N 195-1976 on the current acceptable basis for maintaining the quality of fuel oil, as required by the TS per Criterion 3 of 10 CFR 50.36(d)(2)(ii).

1) The mixing of ULSD and LSD fuels will not substantially affect fuel consumption. As noted above during the review and update of the fuel oil consumption calculation it was determined that the most significant fuel oil parameter affecting consumption is the API gravity. The fuel consumption calculation was performed assuming the worst parameter values allowed by the diesel fuel oil sampling program. Mixing of fuel with different parameters values will result in a parameter value somewhere between the value of the stored fuel and that of the added fuel. As long as both values are within specification the resulting value will also remain within the specification, therefore, since the consumption calculation assumed the worst allowable values for the fuel oil quality parameters mixing will not affect the 7-day value shown in the proposed Table B3.8.3-1.

Page 3 of 9

JAFP-08-0006 Attachment 1

2) The proposed change does not affect the stored fuel sampling program. Sampling will continue to be performed in accordance with Technical Specification 5.5.10 and the acceptance criteria will continue to be as specified for ASTM 2D fuel oil.

3) JAF will not delete the reference to Appendix B of ANSI N195 -1976.

The requirements on diesel fuel oil may continue to change in the future and the addition of additives to compensate for the issues associated with ULSD discussed in Information Notice 2006-22 may further affect the volumetric energy content (and, as a result, the stored diesel fuel oil volume requirements). These changes would result in future license amendments to revise the stored fuel oil volume in order to ensure that the volume provides for at least 7 days of diesel generator operation. In order to facilitate the expeditious revision of the fuel oil volume requirement when needed and to avoid the unnecessary expenditure of licensee and NRC resources to prepare and review future license amendment requests that simply revise the volume equivalent to a 7 day supply, the proposed change places the requirement to have stored fuel oil sufficient to support 7 days of diesel generator operation in the TS with the equivalent numerical volume under licensee control in the TS Bases.

The TS requirements on lube oil are also based on maintaining a 7 day supply. To maintain consistency within the Specification and to avoid future amendments to the lube oil inventory numerical value equivalent to a 7 day supply, the proposed change places the requirement to have lube oil inventory sufficient to support 7 days of diesel generator operation in the TS with the equivalent numerical volume in the TS Bases.

The "clear and bright" test, used to establish the acceptability of new fuel oil for use prior to addition to the storage tanks, has been expanded to allow a water and sediment test to be performed to establish the acceptability of new fuel oil. ASTM D4176-93, "Standard Test Method for Free Water and Particulate Contamination in Distillate Fuels (Visual Inspection Procedures)," verifies that new fuel oil has a clear and bright appearance with proper color. The test is only applicable to fuels that meet the ASTM D4176 color rating requirements (i.e., an ASTM D1500, "Test Method for ASTM Color of Petroleum Products (ASTM Color Scale)," color rating of 5 or less). The "clear and bright" test is a qualitative test for determining free water and particulate contamination in distillate fuels and is, therefore, subject to human interpretation. For example, if an attempt is made to use the qualitative "clear and bright" test with darker colored fuels (e.g., for high sulfur fuel oil that has been dyed in accordance with EPA mandated requirements), the presence of free water or particulate could be obscured and missed by the viewer. Expanding the fuel oil testing to allow a water and sediment test will allow the use of a quantitative test method to establish the acceptability of the fuel when the "clear and bright" test is not practical. As discussed in ASTM D975-06 and ASTM D2709, "Test Method for Water and Sediment in Distillate Fuels by Centrifuge," or ASTM D 1796 "Standard Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)," are acceptable standards for the water and sediment content test. The use of ASTM D1796-83 was endorsed by the NRC in Amendment 101 for the Wolf Creek Generating Station.

Page 4 of 9

JAFP-08-0006 Attachment I 4.0 Technical Analysis 4.1 Fuel Oil and Lube Oil Storage Requirements Regulatory Guide 1.137, (Ref. 3), Regulatory Position 1 states that ANSI N195-1976 provides a method acceptable to the NRC staff for complying with the pertinent requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50.

Regulatory Position 1.c states that the fuel oil storage requirements should either be based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity or calculations based on the time-dependent loads of the diesel generator. The NRC's Standard Review Plan, NUREG-0800, Section 9.5.4, paragraph I.d, states that one of the areas of review by the NRC is to ensure "A minimum of seven days' supply of fuel oil, for each redundant diesel generator system, has been provided onsite to meet the engineered safety feature load requirements following a loss of offsite power and a design basis accident." The Specification 3.8.3 LCO Bases states, "Stored diesel fuel oil is required to have sufficient supply for 7 days of full load operation." From these sources, it is clear that the principle safety concern with the volume of the stored diesel fuel oil is that there is a 7 day supply. This proposed change does not alter the licensing basis of the plant.

The methodology for calculating the fuel oil storage volume equivalent to a 7 day supply is well established. The Bases will state that the fuel oil level equivalent to a 7 day supply is calculated in accordance with Regulatory Guide 1.137 (reference 3) and ANSI/ANS 59.51-1997 (reference 4 formerly ANSI N195-1976). The 7 day supply was calculated for API Gravity values over the range allowed by ASTM-D975-95. The volumes will be stated in the TS Bases and changes to the volumes must be reviewed under the TS Bases Control Program, located in the Administrative Controls chapter of the TS, which requires changes to be evaluated under 10 CFR 50.59.

Future changes to the fuel oil volumes or method of calculation that do not meet the criteria in 10 CFR 50.59 will be submitted to the NRC for prior review under 10 CFR 50.90.

The 7 day diesel fuel oil inventory requirement is based on the concept of supporting emergency diesel generator operation for 7 days without requiring resupply. To support that goal, a 7 day supply of lube oil for the emergency diesel generators must also be available. The volume equivalent to a 7 day supply is based on supporting at least 7 days of full load operation for each EDG and the diesel generator manufacturer's lube oil consumption values for the EDG under those conditions. It is proposed to relocate the specific value of lube oil equivalent to a 7 day supply to the TS Bases in order to be consistent with the diesel fuel oil requirements.

Page 5 of 9

JAFP-08-0006 Attachment I The TS provide a limited Completion Time to continue to operate with available diesel fuel oil or lube oil inventory less than the 7 day supply, but greater than a 6 day supply.

These circumstances may be caused by events such as full load operation required for an inadvertent start while at minimum required level, or feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time to obtain the requisite replacement volume and to perform the analyses required prior to addition of the fuel oil to the tank.

The calculation of the volume equivalent to a 6 day supply is performed in the same manner as the calculation of the 7 day supply. The calculation was performed using API Gravity values over the range allowed by ASTM-D975-95. Relocating the specific volume in the TS with the condition that a 6 day supply is available and placing the numerical values in the Bases is acceptable for the same reasons provided above for relocating the 7 day limit.

4.2 Diesel Fuel Oil Testing Program Testing of new fuel per TS Bases paragraph SR 3.8.3.3 b is done per ASTM D975-1995.

As discussed above, ASTM D975 states that the use of ASTM D2709, "Test Method for Water and Sediment in Distillate Fuels by Centrifuge," or ASTM D1796 "Standard Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)," are acceptable standards for the water and sediment content test. Since these methods are already used to establish the acceptability of new fuel, the allowance to use these standards in lieu of ASTM D4176 (i.e., the "clear and bright" test) is acceptable. The TS Bases for SR 3.8.3.3 are revised to include the option of determining water and sediment content.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration

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

Response: No.

The proposed change to the Diesel Fuel Oil, Lube Oil, and Starting Air Specification relocates the volume of diesel fuel oil and lube oil required to support 7 day operation of the onsite diesel generators, and the volume equivalent to a 6 day supply, to licensee control. The specific volume of fuel oil equivalent to a 7 and 6 day supply is calculated using the NRC approved methodology described in Regulatory Guide 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators" and ANSI/ANS 59.51-1997 (formerly ANSI N 195-1976), "Fuel Oil Systems for Safety-Related Emergency Diesel Generators."

The specific volume of lube oil equivalent to a 7 and 6 day supply is based on the Emergency Diesel Generator (EDG) manufacturer's consumption values for the run time of the EDG. Because the requirements to maintain a 7 day supply of diesel fuel oil and lube oil are not changed and are consistent with the assumptions in the accident analyses, Page 6 of 9

JAFP-08-0006 Attachment 1 and the actions taken when the volume of fuel oil and lube oil are less than a 6 day supply have not changed, neither the probability nor the consequences of any accident previously evaluated will be affected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change to the Diesel Fuel Oil Testing Program adds an option to use already approved testing methodology. Since the methodology is already discussed in ASTM D975 as an acceptable standard to determine water and sediment content, neither the probability nor the consequences of any accident previously evaluated will be affected. 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 changes to the Diesel Fuel Oil, Lube Oil and Starting Air Specification and Diesel Fuel Oil Testing Program do not involve physical alterations of the plant (i.e., no new or different type of equipment will be installed) or changes in the methods governing normal plant operation. The changes do not alter assumptions made in the safety analysis but ensure that the diesel generator operates as assumed in the accident analysis. The proposed changes are consistent with the safety analysis assumptions. Therefore, the proposed changes do 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 to the Diesel Fuel Oil, Lube Oil, and Starting Air Specification relocates the volume of diesel fuel oil and lube oil required to support 7 day operation of the onsite diesel generators, and the volume equivalent to a 6 day supply, to licensee control. As the bases for the existing limits on diesel fuel oil and lube oil are not changed and the methods used to determine these limits have been previously approved, no change is made to the accident analysis assumptions and no margin of safety is reduced as part of this change. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

The proposed change to the Diesel Fuel Oil Testing Program provides an option to use a quantitative method of testing for sediment and water content as an alternative to a qualitative method. This option uses an already accepted method for assessing fuel oil quality. Based on this, there are no alterations to any assumptions used in the accident analysis and this change does not reduce any margin of safety. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Page 7 of 9

JAFP-08-0006 Attachment I Based on the above, JAF concludes that the proposed change presents 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 General Design Criterion (GDC) 17, "Electric Power Systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability.

Regulatory Guide 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators" dated October 1979, describes a method acceptable to the NRC staff for complying with the Commission's regulations regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality. Regulatory Guide 1.137 states that Appendix B to ANSI N 195-1976 should be used as a basis for a program to ensure the initial and continuing quality of diesel fuel oil as supplemented by eight additional provisions described in the Regulatory Guide for maintaining the properties and quality of diesel fuel oil.

ANSI/ANS 59.51-1997 (formerly ANSI N195-1976), "Fuel Oil Systems for Safety-Related Emergency Diesel Generators," requires that onsite fuel oil storage shall be sufficient to operate the minimum number of diesel generators following the limiting design basis accident for either seven (7) days, or the time required to replenish the oil from sources outside the plant site following any limiting design basis event without interrupting the operation of the diesel, whichever is longer. The ANSI standard also provides guidance for calculating storage requirements.

The proposed change does not affect the design of the onsite electric power system, the quality of the onsite electric power system, or the method of determining the necessary quantity of onsite diesel fuel oil or lube oil.

ASTM D975, 'Standard Specification for Diesel Fuel Oils", states that the use of ASTM D2709, "Test Method for Water and Sediment in Distillate Fuels by Centrifuge," or ASTM D1796 "Standard Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure)," are acceptable standards for the water and sediment content test.

Page 8 of 9

JAFP-08-0006 Attachment I In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Assessment A review has determined that the proposed changes 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 changes do not involve: (i) a significant hazards consideration; (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed 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), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

7.0 References

1. TSTF-501 Rev. 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control", dated July 2, 2007

2. TSTF-374-A Rev. 0, "Revision to TS 5.5.13 and associated TS Bases for Diesel Fuel Oil", dated January 21, 2005

3. Regulatory Guide 1.137 Rev. 1, "Fuel Oil Systems for Standby Diesel Generators",

dated October 1979

4. ANSI/ANS-59.51-1997, 'Fuel Oil Systems for Safety-Related Emergency Diesel Generators", dated October 23, 1997

5. ASTM D975-1995, "Standard Specification for Diesel Fuel Oils", dated 1995

6. JAF-CALC-07-00020, Revised EDG Fuel Oil Storage Quantities for 7 Day and 6 Day Supplies, dated November 20, 2007

7. NRC letter to the Technical Specification Task Force (TSTF), "Request for Additional Information Regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Values to Licensee Control""', dated December 13, 2007 Page 9 of 9

JAFP-08-0006 Attachment 2 Proposed Technical Specification Changes (Mark up)

Pages 3.8.3-1 3.8.3-2 3.8.3-3 5.5-11

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency diesel generator (EDG).

APPLICABILITY: When associated EDG subsystem is required to be OPERABLE ACTIONS

---

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

Separate Condition entry is allowed for each EDG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more EDGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level < "2,000 within limits.

gal a 7 day supply and

>28,000gal a 6 day suppl in storage tank.

B. One or more EDGs with B.1 Restore lube oil inventory 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory <4-68 to within limits.

gal a 7 day supply and

>144-gal a 6 day suD _ly.

C. One or more EDGs with C.1 Restore stored fuel oil 7 days stored fuel oil total total particulates to particulates not within within limit.

limit.

(continued)

JAFNPP 3.8.3-1 Amendment 2-74

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more EDGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limit.

not within limits.

E. One or more EDGs with E.1 Restore required starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> required starting air air receiver pressure to receiver pressure < 150 within limits.

psig and > 110 psig.

F. Requires Action and F.1 Declare associated EDG Immediately associated Completion inoperable.

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

OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other then condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains> 31 days

,-000- gal a 7 day supply of fuel.

(continued)

JAFNPP 3.8.3-2 Amendment 274

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 Verify lube oil inventory of each EDG is > 31 days 168-gal a 7 day supply.

SR 3.8.3.3 Verify fuel oil properties of new and stored In accordance with the fuel oil are tested in accordance with, and Diesel Fuel Oil Testing maintained within the limits of, the diesel Program Fuel Oil Testing Program.

SR 3.8.3.4 Verify Each EDG required air start receiver 31 days pressure is >_150 psig.

SR 3.8.3.5 Check for and remove accumulated water 31 days from each fuel oil storage tank.

JAFNPP 3.8.3-3 Amendment 2-7-4

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Diesel Fuel Oil Testing Program (continued)

a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and.

3. A clear and bright appearance with proper color or water and sediment content within limits;

b. Within 31 days following addition of the new fuel oil to storage tanks verify that the properties of the new fuel oil, other than those addressed in Specification 5.5.10.a above, are within limits for ASTM 2D fuel oil; and

c. Total particulate concentration of the fuel oil is _ 10 mg/I when tested every 31 days in accordance with the applicable ASTM Standard, except that the specified filters may be replaced with filters up to 3.0 microns.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test Frequencies.

5.5.11 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

(continued)

JAFNPP 5.5-11 Amendment 2-7-4

JAFP-08-0006 Attachment 3 Proposed Technical Specification Changes (Final Typed)

Pages 3.8.3-1 3.8.3-2 3.8.3-3 5.5-11

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency diesel generator (EDG).

APPLICABILITY: When associated EDG subsystem is required to be OPERABLE ACTIONS

---

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

Separate Condition entry is allowed for each EDG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more EDGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level < a 7 day within limits.

supply and > a 6 day supply in storage tank.

B. One or more EDGs with B.1 Restore lube oil inventory 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory < a 7 to within limits.

day supply and > a 6 day supply.

C. One or more EDGs with C.1 Restore stored fuel oil 7 days stored fuel oil total total particulates to particulates not within within limit.

limit.

(continued)

JAFNPP 3.8.3-:1 Amendment

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more EDGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limit.

not within limits.

E. One or more EDGs with E.1 Restore required starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> required starting air air receiver pressure to receiver pressure < 150 within limits.

psig and > 110 psig.

F. Requires Action and F.1 Declare associated EDG Immediately associated Completion inoperable.

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

OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other then condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains > a 31 days 7 day supply of fuel.

(continued)

JAFNPP 3.8.3-2 Amendment

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 Verify lube oil inventory of each EDG is > a 7 31 days day supply.

SR 3.8.3.3 Verify fuel oil properties of new and stored In accordance with the fuel oil are tested in accordance with, and Diesel Fuel Oil Testing maintained within the limits of, the diesel Program Fuel Oil Testing Program.

SR 3.8.3.4 Verify Each EDG required air start receiver 31 days pressure is > 150 psig.

SR 3.8.3.5 Check for and remove accumulated water 31 days from each fuel oil storage tank.

JAFNPP 3.8.3-3 Amendment

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Diesel Fuel Oil Testing Program (continued)

a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. Aflash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color or water and sediment within limits;

b. Within 31 days following addition of the new fuel oil to storage tanks verify that the properties of the new fuel oil, other than those addressed in Specification 5.5.10.a above, are within limits for ASTM 2D fuel oil; and

c. Total particulate concentration of the fuel oil is < 10 mg/I when tested every 31 days in accordance with the applicable ASTM Standard, except that the specified filters may be replaced with filters up to 3.0 microns.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test Frequencies.

5.5.11 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

(continued)

JAFNPP 5.5-11 Amendment

JAFP-08-0006 Attachment 4 Proposed Technical Specification Bases Changes (Mark Up)

(Information Only)

Pazes B 3.8.3-1 B 3.8.3-3 B 3.8.3-4 B 3.8.3-5 B 3.8.3-6 B 3.8.3-7 B 3.7.3-9 B 3.8.3-10 (New Page)

B 3.8.3-11 (New page)

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES BACKGROUND Each emergency diesel generator (EDG) subsystem is provided with two fuel oil storage tanks. Each storage tank has a fuel oil capacity sufficient to operate one EDG for a period of 7 days while the EDG is supplying full load. The maximum post loss of coolant accident (LOCA) load demand discussed in UFSAR, Section 8.6.2 (Ref. 1) is calculated using the assumption that at least two EDGs are operating. This onsite fuel oil capacity is sufficient to operate the EDGs for longer than the time to replenish the onsite supply from outside sources.

Normally fuel oil is transferred from storage tanks to day tanks by either of two transfer pumps associated with each storage tank. In addition the fuel oil transfer pumps can be manually aligned to permit fuel oil transfer, within the EDG subsystem, from either of the two fuel oil storage tanks to either of the two fuel oil day tanks.

Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result in the loss of more than one EDG. All fuel oil storage tanks are located underground.

Fuel oil day tanks and transfer pumps are located in the associated EDG room.

For proper operation of the EDGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) and ANSI N195 (Ref. 3) addressjecomrmended fuel oil practices, as modified . - -j Deleted: es by 1) the ACTIONS and Surveillance Requirements (SRs) of Deleted: the Specification 3.8.3. and 2) the Bases for SR 3.8.3.3. which specifies the current fuel oil testing standards. The fuel oil properties . - Deleted: supplemented by ANSI governed by these SRs are the water and sediment content, the N195 (Ref. 3).

kinematic viscosity, specific gravity (absolute specific gravity or API gravity), and impurity level.

The EDG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated EDG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days' continuous operation. This supply is sufficient to operate the EDGs for longer j Deleted: 0 I JAFNPP B 3.8.3-1 Revision."

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES - Deleted:

APPLICABILITY after an abnormal operational transient or a postulated DBA.

(continued) Because stored diesel fuel oil, lube oil, and starting air subsystems support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated EDG subsystem is required to be OPERABLE.

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

A.1 With fuel oil level less than the level shown in Table B3.8.3-1 in a . - Formatted: Font: Franklin Gothic storage tank, the 7 day fuel oil supply for an EDG is not available. ..... .__ook However, the Condition is restricted to fuel oil level reductions that-Deleted: 32,000 gallons Ina storage tank, maintain at least a 6 day supply as shown in Table B3.8.3-2. These ...

circumstances may be caused by events such as: , Formatted: Font: Franklin Gothic Book

a. Full load operation required for an inadvertent start while at Deleted: (28.000 gallons) minimum required level; or

b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows 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 EDG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that action will be initiated to obtain replenishment, and the low probability of an event during this brief period.

(continued)

Deleted: 5 SDeleted: 0 tF IJAFNPP B 3.8.3-A_3 -- - - - - - - - - - - Revision,,,"

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS B.1 (continued)

With lube oil inventory < 168 gal, sufficient lube oil to support 7 days of continuous EDG operation at full load conditions may not be available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply (144 gal). This restriction allows sufficient time for obtaining the requisite replacement volume. 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 volume prior to declaring the EDG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that action will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 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 EDG inoperable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the EDG fuel oil.

D.1 With the new fuel oil properties defined in the Bases for SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combination of these , Deleted: 5 Deleted: 0 I JAFNPP PB 3.8.3-4 Revision,"

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS DA1 (continued)

EDG start and load was required during this time interval and the fuel oil properties were outside limits, there is high likelihood that the EDG would still be capable of performing its intended function. If the new fuel oil has not yet been added to the fuel oil storage tanks, entry into this condition is not necessary.

E.1 With required starting air receiver pressure < 150 psig, sufficient capacity for five successive EDG starts does not exist. However, as long as the receiver pressure is ;Ž 110 psig, there is adequate capacity for at least one start, and the EDG can be considered OPERABLE while the air receiver pressure is restored to the required limit. 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 to the required pressure prior to declaring the EDG inoperable. This period is acceptable based on the remaining air start capacity, the fact that most EDG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

F.1 With a Required Action and associated Completion Time of Condition A, B, C, D, or E not met, or the stored diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A, B, C, D, or E, the associated EDG 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 EDG's operation for 7 days at full load. The fuel oil level equivalent to a 7 day supply in gallons when calculated in accordance with References 2. 7. and 8 is shown in Table B3.8.3-1. The 7 day period is sufficient time to place the plant in a safe shutdown condition and to bring in replenishment ,=Deleted: 5 Deleted: 0 IJAFNPP B 3.8.3-ný5 _ Revision,

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.2 REQUIREMENTS (continued) This SR ensures that sufficient lubricating oil inventory is available to support at least 7 days of full load operation for each EDG. The lube oil level equivalent to a 7 day suoply is 168 gallons. The 168 gal requirement is based on the EDG manufacturer's consumption values for the run time of the EDG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the EDG, when the EDG lube oil sump does not hold adequate inventory for 7 days of full load Operation without the level reaching the manufacturer's recommended minimum level.

A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since EDG starts and run time are closely monitored by the plant staff.

SR 3.8.3.3 The tests of new fuel oil prior to addition to the storage tanks are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate detrimental impact on diesel engine combustion.

If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks.

These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between the sample (and corresponding test results) of new fuel and addition of new fuel oil to the storage tanks to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

a. Sample the new fuel oil in accordance with ASTM D4057-1995 (Ref. 6);

b. Verify in accordance with the tests specified in ASTM D975"QQ*(Ref. 6) that the sample has an absolute specific... - Deleted: 1995 I gravity at 60/600 F of > 0.83 and < 0.89 or an API gravity at 60OF of > 270 and <390, a kinematic viscosity at 400C of > 1.9 centistokes, and *4.1 centistokes, and a flash point of

> 1250 F; and Deleted: 5

,/1 Deleted: 0 I JAFNPP PB3.8.3-6 Revision,

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES

c. Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176-1993 or verify water and sediment are within ASTM _- . -f Deleted: (Ref. 6)

D975-2006 limits when tested in accordance with, ASTMD2709, or ASTM D1796 (Ref 6).

Failure to meet any of the above limits is cause for rejecting the new " Deleted:

BASES fuel oil, but does not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks. Page Break--------

-P----- -

SURVEILLANCE. 3 (contlnued)¶ Following the initial new fuel oil sample, the fuel oil is analyzed within REQUIREMENTS1 31 days following addition of the new fuel oil to the fuel oil storage tanks to establish that the other properties specified in Table 1 of ASTM D975-O2E6 (Ref. 6) are met for new fuel oil when tested in --4 Deleted: 1995 accordance with ASTM -97526(ef.6), except that the analys-is- . - - - Deleted: 1995 for sulfur may be performed in accordance with ASTM D1552-1995 (Ref. 6) or ASTM D2622-1994 (Ref. 6). The 31 day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on EDG operation. This Surveillance ensures the availability of high quality fuel oil for the EDGs.

Fuel oil degradation during long term storage shows up as an increase in particulate concentration, mostly due to oxidation. The presence of particulates does not mean that the fuel oil will not burn properly in a diesel engine. The particulates can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

Particulate concentrations should be determined in accordance with ASTM D6217-1998 (Ref. 6), except that the specified filters may be replaced with filters up to 3.0 microns. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/I. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing.

The Frequency'of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

Formatted: Underline (continued) ,-rDeleted:5 Deleted: 0 I,

I JAFNPP B 3.8.3.7 Revision;"

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 I BASES (continued) - - Deleted: __

REFERENCES 1. UFSAR, Section 8.6.2.

2. Regulatory Guide 1.137, Revision 1, Fuel-Oil Systems For Standby Diesel Generators, October 1979.

I 3. ANSI N195, Appendix B 1976,, .... - - -( Deleted:.

4. UFSAR, Chapter 14.

5. 10 CFR 50.36(c)(2)(ii).

6. ASTM Standards: D4057-1995, Standard Practice for Manual I Sampling of Petroleum and Petroleum Products; D975-_2Q00,6 - Deleted: 1995 Standard Specification for Diesel Fuel Oils; D4176-1993, Standard Test Method for Free Water and Particulate Contamination in Distillate Fuels (Visual Inspection Procedures); D1552-1995, Standard Test Method for Sulfur in Petroleum Products (High-Temperature Method); D2622-1994, Standard Test Method for Sulfur in Petroleum Products by X-Ray Spectrometry;,D_6217-1998, Standard Test Method for - - - Deleted: and Particulate Contamination ' iddle bistallate Fuels by-Laboratory Filtration: ASTM D2709-1996, Test Method for Water and Sediment in Distillate Fuels by Centrifuge: and ASTM D1796-2004. Standard Method for Water and Sediment in Fuel Oils by the Centrifuge Method (Laboratory Procedure).

7. ANSI/ANS-59.51 1997, Fuel Oil Systems for Safety Related Emergency Diesel Generators.

8. JAF-CALC-07-00020. Revised Emergencv Diesel Generator I Ffl( Fiie~l Oil StnraL0e OiiAntitie.. for 7 day And R flaY Stnnlir*.

(EDG) Fuel Oil Storaoe Ouantities for 7 dav and 6 Day Supplies Deleted: 5 Deleted: 0 I,

JAFNPP B 3.8.3-9 Revision_;"

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 I PA C -+. I "[-Deleted:___________

Table B3.8.3-1 (page I of 1) 7-Day EDG Fuel Oil Supply EDG "A" EDG "B" EDG "C" EDG "D" API Fuel Oil Storage Fuel Oil Storage Fuel Oil Storage Fuel Oil Storage avi Tank Level Tank Level Tank Level Tank Level (in Gallons) (in Gallons) (in Gallons) (in Gallons) 39 33,898 34,226 34,153 34,197 36 33,455 33,783 33,710 33,755 33 33,016 33,344 33.271 33.316 30 32,582 32,910 32,837 32,882 27 32,153 32,481 32,408 32,453 Deleted: 5 Deleted: 0 I JAFNPP B 3.8.3-10 Revision;"

! Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 II RASE5~ (t~ontinued~ - - Deleted: I B.... . i.. . . .

Table B3.8.3-2 (page I of 1) 6-Day EDG Fuel Oil Supply EDG "A" EDG "B" EDG "C" EDG "D" Fuel Oil Storage Fuel Oil Storage Fuel Oil Storag-e Fuel Oil Storage API Tank Level Tank Level Tank Level Tank Level (in Gallons) (in Gallons) (in Gallons) (in Gallons) 39 292560 36 28,881 29209 29136 29181 33 28505 28833 29760 28805 30 28133 28461 28,388 28432 27 27765 28093 28,020 28,064 Deleted:

M 5::

Deleted: 0 I JAFNPP B 3.8.3-11 Revision,"