ML15324A247

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Issuance of Amendment to Adopt TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Valves to Licensee Control
ML15324A247
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 12/14/2015
From: Farideh Saba
Plant Licensing Branch II
To: James Shea
Tennessee Valley Authority
Kuntz R, NRR/DORL, 415-3733
Shared Package
ML15324A214 List:
References
CAC MF5417, CAC MF5418, CAC MF5419
Download: ML15324A247 (44)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 14, 2015 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3R-C Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER-501, REVISION 1 (CAC NOS. MF5417, MF5418, AND MF5419)

Dear Mr. Shea:

The Commission has issued the enclosed Amendment Nos. 292, 317, and 275, to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68, for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively, in response to your application dated December 11, 2014, as supplemented by letter dated September 30, 2015.

The amendments revise Technical Specification (TS) 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the stored diesel fuel oil and lube oil numerical volume requirements and replacing them with diesel operating time requirements consistent with Technical Specification Task Force Traveler-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control."

The related safety evaluation (SE) is enclosed. We have previously sent the SE in draft form to your staff to ascertain that it contains no proprietary information. Your staff confirmed that the SE contains no proprietary information.

J. Shea Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Farideh E. Saba, enior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 292 to DPR-33
2. Amendment No. 317 to DPR-52
3. Amendment No. 275 to DPR-68
4. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 292 Renewed License No. DPR-33

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated December 11, 2014, as supplemented by letter dated September 30, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Renewed Facility Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 292, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. Implementation Requirements A. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

B. Upon implementation of this amendment, Tennessee Valley Authority shall incorporate in the Final Safety Analysis Report the following information as set forth in the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description with the next Final Safety Analysis Report update in accordance with 10 CFR 50.71(e):

The specific Emergency Diesel Generator (EOG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EOG run-duration requirements are met, are calculated using Section 5.4 of American National Standards Institute (ANSI)

N195-1976, "Fuel Oil Systems for Standby Diesel-Generators,"

and are based on applying the conservative assumption that the EOG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators," Regulatory Position C.1.c.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 14, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 292 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.8-19 3.8-19 3.8-20 3.8-20 3.8-21 3.8-21 5.0-17 5.0-17 5.0-17a

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 292, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 292

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 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. One or more DGs 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 less than a within limits.

7-day supply and greater than a 6-day supply in storage tank.

B. One or more DGs 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 less to within limits.

than a 7-day supply and greater than a 6-day supply.

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

particulates not within limits.

(continued)

BFN-UNIT 1 3.8-19 Amendment No. ~. 292

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

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties not properties to within limits.

within limits.

E. One or more DGs with E.1 Declare associated DG Immediately the required starting air inoperable.

receiver unit pressure

< 165 psig.

F. Required Action and F.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem inoperable for reasons other than Condition A, B, C, D, or E.

BFN-UNIT 1 3.8-20 Amendment No. 2-J4, 292

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains :?: a 31 days 7-day supply.

SR 3.8.3.2 Verify lube oil inventory is:?: a 7-day supply. 31 days SR 3.8.3.3 Verify fuel oil properties of new and stored In accordance fuel oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Fuel Oil Testing Oil Testing Program. Program SR 3.8.3.4 Verify each required DG air start receiver unit 31 days pressure is :?: 165 psig.

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

BFN-UNIT 1 3.8-21 Amendment No. ~. 292

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program (continued)

b. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and fuel oil stored in 7-day tanks shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil for use prior to addition of the 7-day 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 20 fuel oil, and
3. A clear and bright appearance with proper color or a water and sediment content within limits,
b. Within 31 days following addition of the new fuel oil to the 7-day storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 20 fuel oil, and (continued)

BFN-UNIT 1 5.0-17 Amendment No. ~. 292

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Diesel Fuel Oil Testing Program (continued)

c. Total particulate concentration of the fuel oil in the 7-day storage tank is~ 10 mg/I when tested every 92 days.

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

(continued)

BFN-UNIT 1 5.0-17a Amendment No. ~. 292

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 317 Renewed License No. DPR-52

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated December 11, 2014, as supplemented by letter dated September 30, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Renewed Facility Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-52 is hereby amended as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 317, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. Implementation Requirements A. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

B. Upon implementation of this amendment, Tennessee Valley Authority shall incorporate in the Final Safety Analysis Report the following information as set forth in the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description with the next Final Safety Analysis Report update in accordance with 10 CFR 50.71(e):

The specific Emergency Diesel Generator (EOG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EOG run-duration requirements are met, are calculated using Section 5.4 of American National Standards Institute (ANSI)

N195-1976, "Fuel Oil Systems for Standby Diesel-Generators,"

and are based on applying the conservative assumption that the EOG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators," Regulatory Position C.1.c.

FOR THE NUCLEAR REGULATORY COMMISSION

~J~.

Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 14, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 317 RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.8-19 3.8-19 3.8-20 3.8-20 3.8-21 3.8-21 5.0-17 5.0-17 5.0-17a

sealed sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 317, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 253. For SRs that existed prior to Amendment 253, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253.

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 317

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 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. One or more DGs 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 less than a within limits.

7-day supply and greater than a 6-day supply in storage tank.

B. One or more DGs 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 less to within limits.

than a 7-day supply and greater than a 6-day supply.

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

particulates not within limits.

(continued)

BFN-UNIT 2 3.8-19 Amendment No.~. 317

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

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties not properties to within limits.

within limits.

E. One or more DGs with E.1 Declare associated DG Immediately the required starting air inoperable.

receiver unit pressure

< 165 psig.

F. Required Action and F.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem inoperable for reasons other than Condition A, B, C, D, or E.

BFN-UNIT 2 3.8-20 Amendment No.~. 317

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains ;?: a 31 days 7-day supply of fuel.

SR 3.8.3.2 Verify lube oil inventory is;?: a 7-day supply. 31 days SR 3.8.3.3 Verify fuel oil properties of new and stored In accordance fuel oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Fuel Oil Testing Oil Testing Program. Program SR 3.8.3.4 Verify each required DG air start receiver unit 31 days pressure is ;?: 165 psig.

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

BFN-UNIT 2 3.8-21 Amendment No.~. 317

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program (continued)

b. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and fuel oil stored in the 7-day tanks shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil for use prior to addition to the 7-day 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 20 fuel oil, and
3. A clear and bright appearance with proper color or a water and sediment content within limits, (continued)

BFN-UNIT 2 5.0-17 Amendment No.~. 317

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Diesel Fuel Oil Testing Program (continued)

b. Within 31 days following addition of the new fuel oil to the 7-day storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 20 fuel oil, and
c. Total particulate concentration of the fuel oil in the 7-day storage tank is s 10 mg/I when tested every 92 days.

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

(continued)

BFN-UNIT 2 5.0-17a Amendment No. ~. 317

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT. UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 275 Renewed License No. DPR-68

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated December 11, 2014, as supplemented by letter dated September 30, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, the license is amended by changes to the Renewed Facility Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-68 is hereby amended as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 275, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. Implementation Requirements A. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

B. Upon implementation of this amendment TVA shall incorporate in the Final Safety Analysis Report the following information as set forth in the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description with the next Final Safety Analysis Report update in accordance with 10 CFR 50.71(e):

The specific Emergency Diesel Generator (EOG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EOG run-duration requirements are met, are calculated using Section 5.4 of American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel-Generators," and are based on applying the conservative assumption that the EOG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators," Regulatory Position C.1.c.

FOR THE NUCLEAR REGULA TORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 14, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 275 RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.8-19 3.8-19 3.8-20 3.8-20 3.8-21 3.8-21 5.0-17 5.0-17 5.0-17a

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 275, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 275

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 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. One or more DGs 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 less than a within limits.

7-day supply and greater than a 6-day supply in storage tank.

  • B. One or more DGs 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 less to within limits.

than a 7-day supply and greater than a 6-day supply.

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

particulates not within limits.

(continued)

BFN-UNIT 3 3.8-19 Amendment No. ~. 275

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

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties not properties to within limits.

within limits.

E. One or more DGs with E.1 Declare associated DG Immediately the required starting air inoperable.

receiver unit pressure

< 165 psig.

F. Required Action and F.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem inoperable for reasons other than Condition A, B, C, D, or E.

BFN-UNIT 3 3.8-20 Amendment No. ~. 275

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains ;::: a 31 days 7-day supply of fuel.

SR 3.8.3.2 Verify lube oil inventory is;::: a 7-day supply. 31 days SR 3.8.3.3 Verify fuel oil properties of new and stored In accordance fuel oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Fuel Oil Testing Oil Testing Program. Program SR 3.8.3.4 Verify each required DG air start receiver unit 31 days pressure is;::: 165 psig.

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

BFN-UNIT 3 3.8-21 Amendment No. ~. 275

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program (continued)

b. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and fuel oil stored in the 7-day tanks shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil for use prior to addition to the 7-day 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 20 fuel oil, and
3. A clear and bright appearance with proper color or a water and sediment content within limits,
b. Within 31 days following addition of the new fuel oil to the 7-day storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 20 fuel oil, and (continued)

BFN-UNIT 3 5.0-17 Amendment No. ~. 275

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Diesel Fuel Oil Testing Program (continued)

c. Total particulate concentration of the fuel oil in the 7-day storage tank is :5 10 mg/I when tested every 92 days.

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

(continued)

BFN-UNIT 3 5.0-17a Amendment No. 2-+2-, 275

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 292 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33.

AMENDMENT NO. 317 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52.

AND AMENDMENT NO. 275 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1. 2. AND 3 DOCKET NOS. 50-259. 50-260. AND 50-296

1.0 INTRODUCTION

By application dated December 11, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14349A694), as supplemented by letter dated September 30, 2015 (ADAMS Accession No. ML15274A110), the Tennessee Valley Authority (TVA, the licensee) requested changes to the Technical Specifications (TSs) for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (BFN).

The supplemental letter dated September 30, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination.

The amendments would revise TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs and replacing them with diesel operating time requirements consistent with Technical Specification Task Force Traveler (TSTF) -501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control."

The licensee requested changes to the BFN TSs to adopt TSTF-501, Revision 1. The licensee's current TSs contain numerical volume requirements for both stored diesel fuel oil and lube oil, and any change to the numerical volume requirements currently requires prior approval from the NRC. As an example, diesel fuel oil numerical volume requirements may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements. By adopting TSTF-501, Revision 1, the numerical volume requirements for both stored diesel fuel oil and lube oil would be removed from the TSs.

Enclosure 4

As a result, the numerical volume requirements for both stored diesel fuel oil and lube oil could be modified under licensee control under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59 and, therefore, would not require prior NRC approval.

Regarding stored diesel fuel oil and lube oil, no changes to the current plant configuration, current numerical volume requirements, or current 7-day basis are proposed in this application. This request replaces the current numerical volume requirements with the associated current 7-day basis of the numerical volume requirements.

The amendments would revise TS 3.8.3 by removing the current stored diesel fuel oil volume and lube oil level numerical requirements from the TSs and replacing them with diesel operating time requirements so that the volume necessary to meet the TS duration requirements may be modified under licensee control. The TSs would also be modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each Diesel Generator (DG). As a result, the licensee proposed the following changes:

  • Revise Condition A and Condition Bin the Action table. Currently, Condition A and Condition B are entered when the stored diesel fuel oil volume and lube oil level numerical requirements are not met. As discussed in the current TS Bases, the numerical diesel fuel oil volume requirement in Condition A is based on a volume of less than a 7-day supply, but greater than a 6-day supply. The numerical diesel lube oil level requirement in Condition Bis a volume of less than a 7-day supply, but greater than a 6-day supply. The proposed revision would remove the numerical requirements from the TSs. The TSs would be modified so that Condition A is entered when the stored diesel fuel oil is less than a 7-day supply, but greater than a 6-day fuel oil for one or more DG. Condition B would be entered when stored diesel lube oil is less than a 7-day supply, but greater than a 6-day lube oil supply for one or more DGs.
  • A new Condition D is added to the Action table and the current Conditions D and E are re-lettered as E and F, respectively. The licensee stated in its submittal that this change is required to provide a condition with required action and completion time for new fuel oil properties not being within limits and as a result of changes to Surveillance Requirement (SR) 3.8.3.3 and TS 5.5.9 discussed in the following sections, consistent with NUREG-1433, Revision 4, "Standard Technical Specifications, General Electric BWR/4 Plants" (hereafter "NUREG-1433") (ADAMS Accession No. ML12104A192).
  • Revise SR 3.8.3.1 and SR 3.8.3.2. Currently, SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil volume and lube oil level numerical requirements are met. As discussed in the current TS Bases, the numerical requirements in SR 3.8.3.1 and SR 3.8.3.2 are based on maintaining at least a 7-day supply. The proposed revision would remove the volume numerical requirements from the TSs. The TSs would be revised so that SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil inventories are greater than or equal to a 7-day supply for each DG.
  • SR 3.8.3.3 is revised to make it consistent with NUREG-1433 and compatible with TSTF-501, Revision 1. The licensee stated this is necessary because currently, the

BFN TSs do not require the level of testing that is contained in NUREG-1433. In addition, the proposed changes to SR 3.8.3.3 provide consistency with changes to TS 5.5.9.

  • A new SR 3.8.3.5 is added to check for and remove accumulated water. This change is consistent with NUREG-1433.
  • TS 5.5.9 is revised to be consistent with NUREG-1433. This proposed change adds requirements and limits for the testing of new fuel oil.
  • The American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems For Standby Diesel Generators," is being added as a reference, and the version of Regulatory Guide (RG) 1.137, "Fuel-Oil Systems for Standby Diesel Generators," is being specified as Revision 1, October 1979, The licensee stated that during its review of the TSTF-501 model safety evaluation (SE) published in the FR on May 26, 2010 (75 FR 29588), it concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to BFN and, therefore, justify this amendment for the incorporation of the proposed changes to the BFN TSs. In addition, the licensee stated that the changes proposed in the license amendment request (LAR) are consistent with the NRG-approved TSTF-501, Revision 1.

In addition to the changes discussed in TSTF-501, the licensee proposed additional changes that are further discussed in Section 3 of this SE.

2.0 REGULATORY EVALUATION

2.1 Proposed Changes to Limiting Conditions for Operation 3.8.3. "Diesel Fuel Oil. Lube Oil, and Starting Air." Requirements The regulation at 10 CFR Section 50.36, "Technical specifications," provides the regulatory requirements for the content required in the TSs. As stated in 10 CFR Section 50.36, the TSs include limiting conditions for operation (LCO) and SRs to assure that the LCOs are met.

The regulation at 10 CFR 50.36(c)(2)(i) states that TSs will include LCOs that are "the lowest functional capability or performance levels of equipment required for safe operation of the facility."

RG 1.137, Revision 1, provides guidance that describes a method acceptable to the NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby DGs.

RG 1.137, Section C.1.c, sets forth two methods for calculation of fuel oil storage requirements as described in Section 5.4 of ANSI N195-1976.

2.2 Proposed Changes to Action Table for TS 3.8.3. "Diesel Fuel Oil. Lube Oil. and Starting Air" The regulation at 10 CFR 50.36(c)(2)(i) states that TSs will include LCOs that are "the lowest functional capability or performance levels of equipment required for safe operation of the

facility." Paragraph 50.36(c)(2)(i) additionally states that, "when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met."

2.3 Proposed Changes to TS SRs 3.8.3.1. 3.8.3.2. 3.8.3.3, and Addition of SR 3.8.3.5 Paragraph 50.36(c)(3) states that TSs will include SRs that are "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met."

2.4 Proposed Changes to TS 5.5.9, "Diesel Fuel Oil Testing Program" The regulation at 10 CFR 50.36(c)(5) states that the TSs will include administrative controls that are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

2.5 Addition of References to RG 1.137 and ANSI N195-1976 RG 1.137, Revision 1, addresses the recommended fuel oil practices as supplemented by ANSI N195-1976, Appendix B. The fuel oil properties that are checked to ensure the proper quality of the fuel oil are sediment content, the kinematic viscosity, specific gravity (or American Petroleum Institute (API) gravity), and impurity level.

Regulatory Position 2 of RG 1.137 states, in part, that, "Appendix B to ANSI N 195-1976 be used as a basis for a program to ensure the initial and continuing quality of fuel oil." As a result, the use of Appendix B of ANSI N 195-1976, as referenced by RG 1.137, Revision 1, provides a basis for ensuring the proper quality of the fuel oil; namely that water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level are within the specified limits.

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to LCO 3.8.3. "Diesel Fuel Oil. Lube Oil. and Starting Air,"

Requirements Each DG is provided with a fuel oil capacity sufficient to operate that diesel for a period of 7 days, while the DG is supplying maximum load demand. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time needed to replenish the onsite fuel oil supply from outside sources.

The standby alternating current (AC) power sources are a part of the primary success path and function or actuate to mitigate a design basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Diesel fuel oil and lube oil are retained in the TSs to satisfy 10 CFR 50.36(c)(2)(i), since they support the operation of the standby AC power sources. The proposed changes would revise TS 3.8.3 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs and replacing them with the required diesel operating time so that the fuel oil and lube oil

volumes necessary to support the required diesel operating time may be modified under licensee control.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG 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. Each DG has a lube oil inventory capable of supporting a minimum of 7 days of operation. This supply is sufficient to allow the operator to replenish lube oil from outside sources.

In order to meet a 7-day supply of stored diesel fuel oil and lube oil for each DG, TS 3.8.3 currently contains numerical volume requirements associated with a 7-day supply for each DG as measured by volume, in gallons. The TS Bases currently state that the numerical volume requirements are based on meeting a 7-day supply. The proposed change would revise TS 3.8.3 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs so that the fuel oil and lube oil volumes necessary to support the required diesel operating time may subsequently be modified under licensee control pursuant to 10 CFR 50.59. The revised TSs continue to require that the stored diesel fuel oil and lube oil inventory have a 7-day supply available for each DG. The removal of the TS numerical value volume requirement does not change the current plant configuration, the current volume requirements, or the current 7-day basis for the fuel oil and lube oil volume requirements.

Finally, the methodology as to how the stored diesel fuel oil and lube oil numerical volume basis may be modified under licensee control is described in Section 3.6 of this SE. The use of this methodology is consistent with RG 1.137 and will ensure that a 7-day supply of stored diesel fuel oil and lube oil for each DG will be met, thereby providing assurance that the lowest functional capability or performance levels of the DG required for safe operation of the facility will continue to be met.

Based on the above evaluation, the NRC staff finds the change to the LCO 3.8.3 requirements to be acceptable.

3.2 Proposed Changes to Action Table for TS 3.8.3. "Diesel Fuel Oil, Lube Oil, and Starting Air" 3.2.1 Changes to Condition A and Condition B Currently, Condition A and Condition B are entered when the stored diesel fuel oil and lube oil numerical volume requirements are not met. The current TS Bases state that the numerical volume requirements in Condition A and Condition B are based on volumes less than a 7-day supply, but greater than a 6-day supply. The proposal would remove the volumetric requirements from the TSs and would modify Condition A and Condition B to maintain a duration-based requirement such that the Conditions are entered when the stored diesel fuel oil and lube oil inventory is less than a 7-day supply, but greater than a 6-day supply, for one or more DGs. No other parts of Condition A and Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application.

Finally, the methodology to be used in modifying the stored diesel fuel oil and lube oil numerical volume basis may be modified under licensee control is described in Section 3.6.

The use of this methodology will ensure that the 7-day and 6-day supply of stored diesel fuel oil and lube oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC-approved methods.

Based on the above evaluation, the NRC staff finds the modification to TS 3.8.3, Condition A and Condition B, to be acceptable.

3.2.2 Addition of Condition D The licensee proposed to add a new condition, Condition D, to TS 3.8.3. The proposed new Condition D states that with one or more DGs with new fuel oil properties not within limits, restore stored fuel oil properties to within limits with a completion time of 30 days. The licensee's proposed new Condition Dis equivalent to that contained in NUREG-1433, Standard Technical Specifications (STS) TS 3.8.3, Condition D.

Currently, if new fuel oil properties are not within limits, BFN TSs do not provide a condition equivalent to this state. The current TS 5.5.9, "Diesel Fuel Oil Testing Program," does not contain a requirement for testing of new fuel oil, and the current SRs of TS LCO 3.8.3, do not require testing of new fuel oil or checking for water in the stored oil. As a result of the proposed changes to SR 3.8.3.3 and TS 5.5.9 discussed below, new Condition D is required, since the addition of a requirement to test new fuel oil must have a required action to follow when new fuel oil limits are not met. This change is consistent with NUREG-1433 and is a more restrictive change to support of the adoption of TSTF-501, Revision 1, since it requires an action when new fuel oil limits are not met.

With the new fuel oil properties 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 a combination of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

The licensee also proposed to re-letter current Condition D and Condition E to Condition E and Condition F, respectively, to insert the new Condition. The staff considers this a non-technical editorial change for clarity.

Based on the above evaluation, the NRC staff finds the addition of new Condition D to TS 3.8.3, as well as the accompanying editorial changes, to be acceptable.

3.3 Proposed Changes to TS SRs 3.8.3.1. 3.8.3.2, 3.8.3.3. and Addition of SR 3.8.3.5 3.3.1 Changes to TS SR 3.8.3.1 and SR 3.8.3.2 Currently, SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. The licensee proposes to revise

SR 3.8.3.1 and SR 3.8.3.2 to reflect the change in LCO requirements, namely, that a 7-day supply (rather than a specified numerical volume) be available for each DG. As a result, SR 3.8.3.1 and SR 3.8.3.2 would require the licensee to verify that the stored diesel fuel oil and lube oil inventory is greater than, or equal to, a 7-day supply for each DG.

No other revision to these SRs is proposed. The licensee proposes to remove the current numerical volume requirement from the TSs and replace it with the associated current 7-day supply for fuel oil and lube oil for each DG.

ANSI N195-1976 discusses how the stored diesel fuel oil requirement is to be calculated based upon the DGs operating at the minimum required capacity for the plant condition that is most limiting for the calculation of such capacity. One method for calculating the stored diesel fuel oil supply takes into account the time dependence of DG loads. That is, if DG loads increase or decrease during the event, the load changes shall be included in the required fuel storage calculation. If the design includes provisions for an operator to supply power to equipment other than the minimum required for the plant condition, such additional loads shall be included in the calculation of required fuel storage capacity. RG 1.137, Revision 1, supplements the above by stating that for the time-dependent load method, the minimum required capacity should include the capacity to power the engineered safety features. A minimum margin of 10 percent will be added to the calculated storage requirement if the alternate conservative calculation discussed next is not used. Another method for calculating the stored diesel fuel oil supply, which is more conservative than the time-dependent load method, is to calculate the storage capacity by assuming that the diesel operates continuously for 7 days at its rated capacity. The licensee uses the more conservative, continuous 7-day operation at rated capacity, methodology. Both calculation methods will include an explicit allowance for fuel consumption required by periodic testing. This includes the fuel required for operation of the engine at the minimum loads specified by the engine manufacturer.

One variable used in both stored diesel fuel oil calculation methods is the fuel consumption rate. The property of diesel fuel oil having the most significant effect on the fuel consumption rate is the energy content (heating value) of the fuel. There are standards which correlate the energy content to the fuel's API gravity, or absolute specific gravity. At a minimum, plants calculate their required fuel storage values assuming the most limiting API gravity or absolute specific gravity and, therefore, the most limiting fuel energy content. As long as the fuel oil placed in the storage tank is within the API gravity range, or absolute specific gravity range specified by the TS Diesel Fuel Oil Testing Program, the calculations of fuel consumption and required stored volume remain valid. Proposed TS SR 3.8.3.3 (discussed next) requires new fuel to be tested in order to verify that the new fuel API gravity, or absolute specific gravity, is within the range assumed in the diesel fuel oil consumption calculations.

The lube oil inventory equivalent to a 7-day supply, as well as the 6-day supply associated with Condition B, is based on the DG manufacturer consumption values for the run time of the DG.

Licensee continued adherence to the methods described above provides assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Based on the above evaluation, the NRC staff finds the duration-based change to SR 3.8.3.1 and SR 3.8.3.2 to be acceptable.

3.3.2 Changes to TS SR 3.8.3.3 The licensee is proposing a change to SR 3.8.3.3 to make it consistent with NUREG-1433 and with the proposed changes to TS 5.5.9.

Currently, TS SR 3.8.3.3 states:

Verify fuel oil total particulate concentration in stored fuel oil is tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

The proposed TS SR 3.8.3.3 states:

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

The current licensing basis of BFN does not require the level of testing that is contained in NUREG-1433. By changing SR 3.8.3.3 to be consistent with NUREG-1433, it is ensured the new and stored fuel oil have a more comprehensive testing than before the change. In addition, since the proposed change adds a requirement to test new fuel oil to SR 3.8.3.3, the proposed SR change is more restrictive and supports the adoption of TSTF-501, Revision 1.

Also, the proposed change to SR 3.8.3.3 reflects proposed changes to TS 5.5.9 as discussed in Section 3.4 below.

The tests referred to in SR 3.8.3.3 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. The proposed SR ensures the availability of high quality fuel oil for the DGs.

Based on the above evaluation, the NRC staff finds the proposed changes to SR 3.8.3.3 acceptable, since they provide a more comprehensive level of testing and add new fuel to the SR.

3.3.3 Addition of TS SR 3.8.3.5 A new SR 3.8.3.5 is proposed to check for and remove accumulated water.

Currently, TS 3.8.3 does not contain a surveillance requirement to check for or remove accumulated water.

The new proposed SR 3.8.3.5 states: "Check for and remove accumulated water from each fuel oil storage tank," with a frequency of every 31 days. This change is consistent with NUREG-1433 and is a more restrictive change to support of the adoption of TSTF-501, Revision 1.

Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to

survive. Periodic removal of water from the fuel storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system.

Based on the above evaluation, the NRC staff finds the new SR 3.8.3.5 to be acceptable, since it will assure that the necessary quality of the DG fuel oil is maintained and that LCO 3.8.3 will be met.

3.4 Proposed Changes to TS 5.5.9, "Diesel Fuel Oil Testing Program" The licensee proposed a change to TS 5.5.9 by revising it to be consistent with NUREG-1433.

This proposed change adds requirements and limits for the testing of new fuel oil to a set of standards and limits and is a more restrictive change to support the adoption of TSTF-501, Revision 1.

Current TS 5.5.9 states, in part:

A diesel fuel oil testing program to implement required testing of the fuel oil in each 7-day fuel oil tank shall be established. The purpose of the program is to establish the following:

a. The quality of the fuel oil in each 7-day fuel oil tank is within the acceptable limits specified in Table 1 of ASTM D-975-1989 when tested every 92 days; and
b. Total particulate concentration of the fuel oil in each 7-day fuel oil tank is s 10 mg/I when tested every 92 days in accordance with ASTM D-2276, Method A-2 or A-3.

The proposed change to TS 5.5.9 will replace the above paragraphs with the following:

A diesel fuel oil testing program to implement required testing of both new fuel oil and fuel oil stored in the 7-day tanks shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil for use prior to addition to the 7-day 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 20 fuel oil, and
3. A clear and bright appearance with proper color or a water and sediment content within limits,
b. Within 31 days following addition of the new fuel oil to the 7-day storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil, and;
c. Total particulate concentration of the fuel oil in the 7-day storage tank is
10 mg/I when tested every 92 days.

The licensee stated in its submittal that the periodicity of testing the 7-day storage tank fuel oil particulate concentration has been retained from the BFN current licensing basis as every 92 days, consistent with American Society for Testing and Materials (ASTM) D-2276, Method A-2 or A-3.

Specifically, the licensee's proposed TS change to TS 5.5.9 states, in part:

c. Total particulate concentration of the fuel oil in the 7-day storage tank is
10 mg/I when tested every 92 days.

In the NRC staff's request for additional information (RAI) dated September 2, 2015 (ADAMS Accession No. ML15245A598), the NRC staff requested from the licensee the documentation that establishes the current licensing basis for the periodicity of testing the 7-day storage tank fuel oil particulate concentration as every 92 days versus 31 days, as suggested in STS 5.5.10, "Diesel Fuel Oil Testing Program," of NUREG-1433.

In its response to the staff's RAI dated September 30, 2015, the licensee stated:

In current BFN TS 5.5.9, Diesel Fuel Oil Testing Program, Specification 5.5.9.b requires particulate testing of the fuel oil in each 7-day fuel oil tank every 92 days. This requirement has existed in TS 5.5.9 since the BFN conversion to Improved Standard Technical Specifications (ISTS) [License Amendment dated July 14, 1998 (ADAMS Accession No. ML020040291)]. Prior to ISTS Conversion, the BFN Custom Technical Specifications (CTS) 4.9.A.1.e required a quarterly check of the quality of each diesel generator's 7-day fuel supply.

This quarterly, or 92 day, periodicity requirement was maintained in the BFN conversion to ISTS. Excerpts from the BFN application for ISTS conversion are included as an attachment to this enclosure. The excerpt includes markups of the NUREG-1433, Revision 1, Diesel Fuel Oil Testing Program Specification 5.5.10, and the justification for changes to NUREG-1433, Revision 1, for the BFN ISTS.

In addition, in its response to the NRC staff's RAI, the licensee clarified its original submittal with the following information:

The statement provided in Enclosure 1 of the application and quoted above, "The periodicity of testing the 7-day storage tank fuel oil particulate

concentration has been retained from the BFN Current Licensing Basis as every 92 days, consistent with ASTM D2276, Method A-2 or A-3." requires clarification. ASTM D2276 is a test method describing procedures for the evaluation of particulate contaminant in aviation turbine fuels. ASTM D2276 does not specify periodicity of testing. Therefore, the phrase "every 92 days, consistent with ASTM D2276" could be misleading. TVA is retaining the 92 day periodicity requirement from the current licensing basis as discussed in the response to RAl-1 in this enclosure. However, after NRC approval of the LAR, ASTM D2276 will no longer be used as the test method for determining particulate concentration. Testing for particulate concentration will instead be performed with the more recent standard ASTM D6217, as specified in the proposed TS Bases changes previously provided in Enclosures 2 and 4 of the application.

The tests required in proposed TS 5.5.9 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. The proposed changes to the Diesel Fuel Oil Testing Program ensure the availability of high quality fuel oil for the DGs.

Based on the above evaluation, the NRC staff finds the proposed changes to TS 5.5.9 acceptable, since it provides a more comprehensive level of testing and adds new fuel to the testing program.

3.5 Addition of References to RG 1.137 and ANSI N195-1976 LCO 3.8.3 requires, in part, that the stored diesel fuel oil and lube oil shall be within limits for each required DG. For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. RG 1.137, Revision 1, addresses the recommended fuel oil practices as supplemented by ANSI N195-1976, Appendix B. The fuel oil properties that are checked to ensure the proper quality of the fuel oil are sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level.

As a result, the use of Appendix B of ANSI N 195-1976, as referenced by RG 1.137, Revision 1, provides a basis for ensuring the proper quality of the fuel oil; namely that water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level are within the specified limits. Proposed TS SR 3.8.3.3 verifies these limits.

3.6 Implementation Requirement to Revise the Final Safety Analysis Report To ensure an acceptable and consistent fuel oil calculation methodology is maintained, TVA provided a commitment in its December 11, 2014, letter, to revise the BFN Final Safety Analysis Report (FSAR) with the following information and to submit the revised description with the next FSAR update:

Tennessee Valley Authority will revise the BFN Units 1, 2, and 3 Final Safety Analysis Report (FSAR) Chapter 8.5.3.4, "Diesel Fuel Oil Storage and Transfer System," with the following information and submit the revised description with

the next FSAR update following issuance of the License Amendment approving the BFN TS-493 request to adopt TSTF-501, Revision 1:

The specific Emergency Diesel Generator (EOG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EOG run-duration requirements are calculated using Section 5.4 of American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel-Generators,"

and are based on applying the conservative assumption that the EOG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators," Regulatory Position C.1.c.

The NRC staff finds that licensee control of the fuel oil calculation methodology in the FSAR will continue to adequately ensure public health and safety, as any deviation from the calculation methodology described above requires the licensee to perform an evaluation pursuant to the provisions of 10 CFR 50.59 to determine whether the change requires prior NRC approval.

3. 7 TS Bases ASTM Standards References In its submittal, the licensee proposed changes to the TS Bases to be implemented with the associated TS changes. The NRC staff found that these changes are consistent with the proposed TS changes.

The staff reviewed the proposed changes to the TS Bases, and the following discussion documents the NRC staff's conclusion on the subject.

The licensee's proposed TS Bases change to SR 3.8.3.3 proposes the following:

Particulate concentrations should be determined in accordance with ASTM 06217-11 (Ref. 7). This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/I.

The equivalent NUREG-1433 Bases to SR 3.8.3.3 states the following:

Particulate concentrations should be determined in accordance with ASTM 05452-[] (Ref. 6). This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 1O mg/I.

In the NRC staff's RAI dated September 2, 2015, the licensee was requested to justify the deviation for determining particulate concentrations of the fuel oil in accordance with ASTM 06217-11 versus ASTM 05452-[] as suggested in STS.

In its response dated September 30, 2015 the licensee stated:

ASTM 0975, "Standard Specification for Diesel Fuel Oils," establishes detailed requirements for diesel fuels. Current BFN TS 5.5.9 requires diesel fuel oil to

meet limits specified in Table 1 of ASTM 0975-1989. In nonmandatory Appendix X3 of the 1989 revision of the standard, Section X3.6.3 states the "quantity of insoluble fuel contaminants present in fuel can be determined using Test Method 02276, Procedure A." Although ASTM 02276 was developed for aviation turbine fuels, revisions of ASTM 0975 through the year 2000 included reference to 02276.

Early revisions of 02276 included both a field method and a laboratory method for determining particulate concentration in aviation turbine fuel. The laboratory method was separated from 02276 and established as ASTM 05452.

Therefore, ASTM 05452 is based on a method developed for aviation turbine fuel.

ASTM 06217 was developed as the first ASTM standard test method for assessing the mass quantity of particulates in middle distillate fuels, specifically including the 0975 No. 2 grade type diesel fuel, which is used at BFN.

Revisions of 0975 since 2001 have replaced the reference to 02276 with a reference to 06217. As shown in the proposed TS Bases changes included in Enclosures 2 and 4 of the application, TVA will use the tests specified in ASTM D975-14a to test fuel oil properties.

ASTM 06217 is the appropriate standard for determining particulate concentrations in diesel fuel oil at BFN for the following reasons: ASTM 06217 is recommended by the revision of ASTM 0975 proposed for BFN, ASTM 06217 was developed for diesel fuel rather than aviation fuel, and the ASTM 0975 No. 2 grade fuel type used at BFN is specifically included within the scope of ASTM 06217.

The NRC staff reviewed the differences between 02276 and 06217 and found that the two standards are similar. Both 02276 and 06217 require similar apparatus and procedures in determining particulate contamination. Therefore, the NRC staff concludes the proposed change is adequate since ASTM 06217 provides an appropriate standard test method.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Alabama State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (March 31, 2015; 80 FR 17104). Accordingly, the amendment meets the eligibility criteria for

categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: C. Tilton Date: December 14, 2015

J. Shea Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA RKuntz for/

Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 292 to DPR-33
2. Amendment No. 317 to DPR-52
3. Amendment No. 275 to DPR-68
4. Safety Evaluation cc w/enclosures: Distribution via Listserv DISTRIBUTION:

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