Text

Issuance of Amendment on Changes to Technical Specifications Section 3.8, Electrical Power Systems and Section 6.8. Procedures and Programs
	ML17048A184
Person / Time
Site:	Harris
Issue date:	05/24/2017
From:	Martha Barillas; Plant Licensing Branch II
To:	Hamilton T; Duke Energy Progress
	Barillas M, NRR/DORL/LPL2-2, 415-2760
References
	CAC MF7775
	Download: ML17048A184 (13)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 24, 2017 Ms. Tanya M. Hamilton Site Vice President Shearon Harris Nuclear Power Plant Duke Energy 5413 Shearon Harris Road M/C HNP01 New Hill, NC 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: CHANGES TO TECHNICAL SPECIFICATIONS SECTION 3.8, ELECTRICAL POWER SYSTEMS AND SECTION 6.8, PROCEDURES AND PROGRAMS (CAC NO. MF7775)

Dear Ms. Hamilton:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 158 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1. This amendment changes the Technical Specifications in response to your application dated May 26, 2016, as supplemented by letter dated December 19, 2016.

The amendment revises the Technical Specifications (TS) by adding a new Administrative Controls TS Section 6.8.4.q to establish, implement, and maintain a Diesel Fuel Oil Testing Program for the testing of both new and stored fuel oil, moving Surveillance Requirement 4.8.1.1.2.h.1 to perform a sediment cleaning of the fuel oil storage tank to licensee control, and taking an exception to Regulatory Guide 1.137, Revision 1, to allow for the ability to perform new fuel oil sampling offsite prior to its addition to the storage tanks.

T. Hamilton A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosures:

1. Amendment No. 158 to NPF-63

2. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 158 Renewed License No. NPF-63

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

1. The application for amendment by Duke Energy Progress, LLC (the licensee),

dated May 26, 2016, as supplemented by letter dated December 19, 2016, 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 Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-63 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 158, are hereby incorporated into this license.

Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION 137::.__,-d Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed License and the Technical Specifications Date of Issuance: May 24, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 158 SHEARON HARRIS NUCLEAR POWER PLANT. UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 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 line in the margin indicating the area of change.

Remove Insert Page4 Page4 Replace the following pages of the 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 3/4 8-5 3/4 8-5 3/4 8-9 3/4 8-9 6-19j 6-19j

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and 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 Duke Energy Progress, LLC, is authorized to operate the facility at reactor Core power levels not in excess of 2948 megawatts thermal (100 percent rated core power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 158, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions Duke Energy Progress, LLC. shall comply with the antitrust conditions delineated in Appendix C to this license.

(4) Initial Startup Test Program (Section 14) 1 Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) Steam Generator Tube Rupture (Section 15.6.3)

Prior to startup following the first refueling outage, Carolina Power & Light Company* shall submit for NRC review and receive approval if a steam generator tube rupture analysis, including the assumed operator actions, which demonstrates that the consequences of the design basis steam generator tube rupture event for the Shearon Harris Nuclear Power Plant are less than the acceptance criteria specified in the Standard Review Plan, NUREG-0800, at 15.6.3 Subparts II (1) and (2) for calculated doses from radiological releases. In preparing their analysis Carolina Power &

Light Company* will not assume that operators will complete corrective actions within the first thirty minutes after a steam generator tube rupture 1

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

On April 29, 2013, the name "Carolina Power & Light Company" (CP&L) was changed to "Duke Energy Progress, Inc." On August 1, 2015, the name "Duke Energy Progress, Inc." was changed to "Duke Energy Progress, LLC."

Renewed License No. NPF-63 Amendment No. 158

ELECTRICAL POWER SYSTEMS A.C. SOURCES OPERATING SURVEILLANCE REQUIREMENTS (CONTINUED) 4.8.1.1.2 (Continued)

b. Check for and remove accumulated water:

1. From the day tank, at the frequency specified in the Surveillance Frequency Control Program and after each operation of the diesel where the period of operation was greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and

2. From the main fuel oil storage tank, at the frequency specified in the Surveillance Frequency Control Program .

c. By verifying 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, at frequencies in accordance with the Diesel Fuel Oil Testing Program.

d. DELETED.

e. At the frequency specified in the Surveillance Frequency Control Program, the diesel generators shall be started** and accelerated to at least 450 rpm in less than or equal to 10 seconds. The generator voltage and frequency shall be 6900

+/- 690 volts and 60 +/- 1.2 Hz in less than or equal to 10 seconds after the start signal.

- This test shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations.

SHEARON HARRIS - UNIT 1 314 8-5 Amendment No.1 58

ELECTRICAL POWER SYSTEMS A.C. SOURCES OPERATING SURVEILLANCE REQUIREMENTS (CONTINUED) 4.8.1.1.2 (Continued)

13. During shutdown, verifying that all diesel generator trips, except engine overspeed, loss of generator potential transformer circuits, generator differential, and emergency bus differential are automatically bypassed on a simulated or actual loss of offsite power signal in conjunction with a safety injection signal.

14. During shutdown, verifying that within 5 minutes of shutting down the EOG, after the EOG has operated for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at an indicated load of 6200-6400 kw, the EOG starts and accelerates to 6900 +/- 690 volts and 60 +/- 1.2 hz in 10 seconds or less.

g. At the frequency specified in the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence by starting** both diesel generators simultaneously, during shutdown, and verifying that both diesel generators accelerate to at least 450 rpm in less than or equal to 10 seconds.

h. At the frequency specified in the Surveillance Frequency Control Program by:

1) DELETED.

2) Performing a pressure test, of those isolable portions of the diesel fuel oil piping system designed to Section 111, subsection ND of the ASME Code, at a test pressure equal to 110% of the system design pressure.

- This test shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations.

SHEARON HARRIS - UNIT 1 314 8-9 Amendment No.1 58

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

p. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

q. Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil 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:

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

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

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

c. A clear and bright appearance with proper color or a water and sediment content within limits.

2. 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 1., above, are within limits for ASTM 2D fuel oil, and

3. Total particulate concentration of the fuel oil is::::; 10 mg/I when tested every 31 days.

The provisions of Surveillance Requirement 4.0.2 and Surveillance Requirement 4.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

SHEARON HARRIS - UNIT 1 6-19j Amendment No.1 58

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 158 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DUKE ENERGY PROGRESS, LLC SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

By application dated May 26, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16151A001), as supplemented by letter dated December 19, 2016 (ADAMS Accession No. ML16354B553), Duke Energy Progress, LLC (the licensee) submitted a license amendment request (LAR) for changes to the Shearon Harris Nuclear Power Plant (Harris), Unit 1, Technical Specifications (TSs).

The requested changes would revise the TSs by adding a new Administrative Controls TS Section 6.8.4.q to establish, implement, and maintain a Diesel Fuel Oil Testing Program for the testing of both new and stored fuel oil. The LAR would also move Surveillance Requirement (SR) 4.8.1.1.2.h.1, to perform a sediment cleaning of the fuel oil storage tank, to licensee control. The LAR was submitted consistent with the guidance contained in the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-2, "Relocate the 1O Year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control," Revision 1 (ADAMS Accession No. ML040360147), and TSTF-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," Revision 2 (ADAMS Accession No. ML011340449). The LAR would also take an exception to Regulatory Guide (RG) 1.137, Revision 1, Regulatory Position 2.b, to allow for the ability to perform new fuel oil sampling offsite prior to its addition to the storage tanks.

The supplement dated December 19, 2016, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on October 11, 2016 (81 FR 70178).

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 System Description The operability of the Alternating Current (AC) power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety-related equipment required for: (1) the safe shutdown of the facility, and (2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant AC power sources and distribution systems satisfy the requirements of General Design Criterion (GDC) 17 of Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50.

The function of the Diesel Generator (DG) Fuel Oil Storage and Transfer System is to store, maintain, and supply fuel oil to the standby emergency diesel generators (EDGs) as required for all modes of DG operation during normal and abnormal site and plant conditions. The system consists of two separate, independent fuel oil supply subsystems, each serving one of the two standby DG engines. Each of these redundant subsystems consists of one fuel oil storage tank, one transfer pump, one day tank, interconnecting piping valves, and associated instruments and controls. Each fuel oil storage tank is a reinforced concrete tank that has a capacity of 175,000 gallons and is located in the Diesel Fuel Oil Storage Tank Building that consists of a below grade reinforced concrete structure.

Proper operation of the standby EDGs is reliant upon proper quality of the fuel oil. Surveillance of the quality of the fuel oil is accomplished by periodic sampling for water and other contaminants in the storage system and sampling of new fuel oil prior to transfer to the storage system. Sampling procedures are in accordance with the American Society for Testing and Materials (ASTM) Standards. Fuel oil samples are tested per ASTM Standards as described in the Harris TSs.

2.2 Regulatory Requirements The NRC staff reviewed the licensee's application, as supplemented, against the following regulatory requirements and regulatory guidance documents.

Section 182a of the Atomic Energy Act of 1954, as amended, requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses.

In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.36(c)(2)(i), LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility. 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 technical specifications until the condition can be met." The remedial actions in the TSs are specified in terms of LCO conditions, required actions, and completion times, or allowed outage times, to complete the required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being

met, and the completion time must be a reasonable time for completing the required actions while maintaining the safe operation of the plant.

As required by 10 CFR 50.36(c)(3), SRs are the requirements related 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 LCOs will be met. The NRC staff reviewed the proposed changes for compliance with 10 CFR 50.36.

In general, licensees cannot justify TS changes solely on the basis of adopting the model Standard Technical Specifications. Instead, the NRC staff must make a determination that any proposed changes maintain adequate safety. Changes that result in a relaxation (i.e., less restrictive condition) of current TS requirements require detailed justification. Licensees may revise the TSs to adopt improved standard TS format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative, or provides clarification (i.e., no requirements are materially altered); (2) the change is more restrictive than the licensee's current requirement; or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework is discussed in Section 3.0 in the context of specific proposed changes.

Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, establishes the minimum necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety; that is, structures, systems, and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.

GDC 17, "Electric power systems," requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety. The onsite system shall have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. Electric power from the offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this GDC requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of the loss of power from the unit, the offsite transmission network, or the onsite power supplies.

2.3 Regulatory Guidance NUREG-1431, Revision 4.0, "Standard Technical Specifications, Westinghouse Plants,"

Volume 1, "Specifications" (ADAMS Accession No. ML 121 OOA222).

RG 1.137, "Fuel-Oil Systems for Standby Diesel Generators," Revision 1 (ADAMS Accession No. ML003740180).

TSTF-374, "Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil," Revision 2.

TSTF-2, "Relocate the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control," Revision 1.

3.0 TECHNICAL EVALUATION

3.1 Ten Year Sediment Cleaning of the Fuel Oil Storage Tank (TSTF-2)

In its application, the licensee proposed to relocate the SR 4.8.1.1.2.h, Item 1, for cleaning both main diesel fuel oil storage tanks to the Diesel Fuel Oil Testing Program in the Plant Program Procedure PLP-106, a licensee-controlled document.

The SR is considered a preventative maintenance activity that encompasses the draining, sediment removal, and cleaning of each main fuel oil storage tank at least once per 1O years.

The licensee stated that it is not related to the testing, calibration, or inspection of the DG fuel oil storage tanks to assure that necessary quality is maintained as required by 10 CFR 50.36(c)(3) for SRs. This SR is based on Regulatory Position 2.f of RG 1.137, Rev. 1, which states that, as a minimum, the fuel oil stored in the tanks should be removed, the accumulated sediment removed, and the tanks cleaned at 10-year intervals. The relocation of this cleaning requirement to a licensee-controlled document was previously approved by the NRC for the Standard Technical Specifications by TSTF-2, Rev. 1.

The NRC staff finds that the proposed amendment to relocate the Fuel Oil Storage Tank cleaning requirements of SR 4.8.1.1.2.h, Item 1, from the Harris TSs to the Harris Final Safety Analysis Report (FSAR) is acceptable because this SR is not required to be in the TSs under any of the criteria of 10 CFR 50.36, and changes to it will be controlled under 10 CFR 50.59, "Changes, Tests, and Experiments." The staff also finds that the relocation of the SR to a licensee-controlled document is acceptable because the SR is a preventative maintenance activity.

3.2 Relocation of TS SRs to the Diesel Fuel Oil Testing Program (TSTF-374)

The licensee proposed to add new Administrative Controls TS 6.8.4 subsection 'q,' which would establish, implement, and maintain a Diesel Fuel Oil Testing Program. The program would include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The licensee proposed to relocate sampling requirements for new fuel oil, including American Petroleum Institute (API) gravity, kinematic viscosity, flash point, and color in accordance with applicable ASTM Standards, from TS 4.8.1.1.2 to the proposed Diesel Fuel Oil Testing Program. The licensee stated that this would move prescriptive details of the program to the licensee-controlled Plant Program Procedure PLP-106, "Technical Specification Equipment List Program and Core Operating Limits Report," which will contain the specifics of the program. In addition, sampling frequency for new fuel oil and fuel oil that is located on site in the EOG storage tank would be moved to the Diesel Fuel Oil Testing Program.

In the proposed amendment, the licensee would establish a diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil. The program would include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. This change would retain the original intent of the TSs that are proposed to be relocated, but would allow the licensee to update the ASTM fuel oil testing standard to newer versions without having to amend the plant's TSs. The licensee stated that this proposed change would provide the flexibility to maintain the capability to conduct fuel oil sampling and analysis using methodologies in accordance with the ASTM Standards whenever there are changes in Environmental Protection Agency regulations for fuel oil or newer editions of the ASTM Standards. The licensee stated that the Diesel Fuel Oil Testing Program prescriptive requirements would become technical requirements to which changes would be evaluated in

accordance with the provisions of 10 CFR 50.59 and the ability to demonstrate DG operability would be maintained. The NRC staff finds that adequate controls exist to allow the relocation of the requirements discussed above, including specific ASTM Standard references, to a licensee-controlled document. Therefore, the staff finds the change acceptable.

The licensee proposed to modify the existing requirement of SR 4.8.1.1.2.c.2 by increasing the time required for verification of fuel oil quality, after a sample of new fuel oil is taken, from 30 days to 31 days. This new frequency is reflected in the proposed Diesel Fuel Oil Testing Program in TS 6.8.4. The NRC staff finds that this is a negligible change and that a 1-day difference in sampling time will not affect test results in a significant way. Therefore, the staff finds this change to be acceptable.

The licensee stated that the Harris plant-specific adoption of TSTF-374 would also include an alternative to the "clear and bright" test currently required for new fuel oil acceptability. The revised TSs would allow either the "clear and bright" test or a test confirming that the fuel oil has "water and sediment content within limits." 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. The water and sediment alternative test is better suited for darker colored fuels and is recognized as an acceptable method in the ASTM Standards that have been referenced in previous NRG-approved amendments. The NRC staff finds that the alternative for testing the water and sediment content will maintain or improve the inspection of new fuel oil and, therefore, finds the change to be acceptable.

The NRC staff has evaluated the licensee's proposed TS changes regarding DG fuel oil used in the EDGs. The licensee proposed to include a new program to TS 6.8.4, which would establish, implement, and maintain a Diesel Fuel Oil Testing Program, the details of which would be located in the licensee-controlled Plant Program Procedure PLP-106. Based on its evaluation, as set forth in Section 3.2 above, the staff concludes that the licensee's proposed changes will simplify the existing Harris TSs without relaxing any of the current requirements since they are relocated from the TSs to the licensee-controlled Plant Program Procedure PLP-106.

3.3 Exceptions to Regulatory Guide 1.137 for Onsite Testing GDC 17 states the requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability for onsite and offsite electric power systems.

The RG 1.137, "Fuel-Oil Systems for Standby Diesel Generators," describes methods that the NRC staff considers acceptable for use in complying with the NRC requirements regarding fuel oil systems for safety-related diesel powered generators, including assurance of adequate fuel oil quality. The RG 1.137 states at Regulatory Position 2.b that, prior to adding new fuel oil to the supply tanks, onsite samples should be taken.

In its LAR, the licensee is requesting an exception to RG 1.137, Regulatory Position 2.b, to allow for the sampling of the new fuel oil offsite. Specifically, the licensee stated that sampling of the new fuel oil would occur following its loading into the tanker truck and prior to its offloading at Harris. Once the sample is taken, the truck would be sealed and the new fuel oil would be delivered to the site. The seals on the truck would be inspected against a Certificate of Analysis from an approved testing laboratory and the fuel oil properties would be verified to meet the required specifications. Upon verification, the new fuel oil would then be added to the fuel oil storage tanks. Controls on truck cleanliness and contamination would provide assurance that the chemical compositions of the fuel oil would remain valid over the period of time that the fuel oil is in transit to Harris.

In its request for additional information (RAI) dated December 6, 2016 (ADAMS Accession No. ML16335A046), the NRC staff requested that the licensee clarify how the testing will be adequately controlled at a fuel oil supplier location to continue to meet RG 1.137 and assure that adequate fuel oil quality will be maintained. The staff requested that the licensee describe the controls that are in place to prevent thermal cycling of the fuel oil in the tanker during the time interval between leaving the supplier and arriving at Harris that may accelerate biological growth, fuel degradation, and/or condensation of water inside the tanker. Regarding connection points to the tanker truck, the staff also requested that the licensee describe the controls that are in place to prevent contamination of the fuel oil occurring in the tanker due to aging, sediment, condensation of water, and to assure that GDC 17 will continue to be met and that the EDGs will continue to meet their mission time.

In its RAI response dated December 19, 2016 (ADAMS Accession No. ML163548553), the licensee stated that the testing itself would not be conducted at the fuel supplier location, but rather at a contracted laboratory on the Approved Suppliers List. The current practice of taking the sample from the loaded tanker truck would remain the same. The only difference would be that the sample would be taken at a contracted laboratory rather than onsite. In doing so, the time interval between the proposed sampling and offloading of the fuel would be less than or equal to the current process since the tanker would be in route to Harris while the testing of the fuel oil sample was being conducted at the lab. In addition, the licensee stated that there have not been any instances of the fuel oil being rejected due to not meeting the pre-offload quality requirements within at least the past 3 years. Therefore, the licensee states that no additional procedures or controls are required outside of those under the current process. The proposed process is described further in the RAI response letter.

The licensee would require receipt inspection of the tanker truck to verify that all connections are sealed and that tampering has not taken place. The trucking company would apply seals to all tanker ports upon loading and would fax a trucking seal sheet to the licensee. The licensee would validate the traceability of the fuel oil by comparing the trucking seals versus the trucking seal sheet. The seal broken by the contracted laboratory to take the fuel oil sample for analysis would be replaced at the time of sampling by the laboratory. This seal would also be verified by licensee personnel to be intact and performing its intended function prior to the licensee accepting the fuel oil.

As per the proposed Administrative Controls Technical Specification for the Diesel Fuel Oil Testing Program, acceptability of new fuel oil for use prior to addition to storage tanks would be established by determining that the fuel oil has: (a) an API gravity or an absolute specific gravity within limits, (b) a flash point and kinematic viscosity within limits for ASTM 20 fuel oil, and (c) a clear and bright appearance with proper color or a water and sediment content within limits. In its RAI response, the licensee stated that the fuel oil would continue to be tested in accordance with the appropriate testing methods and intervals. The combined verification of the tanker seals and the fuel oil quality would assure that GDC 17 will continue to be met and that the EDGs will continue to meet their mission time.

The NRC staff reviewed the licensee's responses and finds them to be acceptable since adequate controls will be in place to ensure that the new fuel oil tanker has sealed connections at the supplier location and then once samples are taken at the contracted laboratory. If the fuel oil did not pass the three tests in the proposed Diesel Fuel Oil Testing Program, then there is reasonable assurance that the EOG fuel oil truck would not be accepted for fuel offload to the EOG storage tanks.

The specific details of the Diesel Fuel Oil Testing Program will exist within the Harris procedure PLP-106, a licensee-controlled document. This procedure is incorporated by reference into the Harris FSAR and is therefore made a part of the FSAR, which, in turn, is a part of the Harris Current Licensing Basis. Therefore, this procedure is subject to the update and reporting requirements of 10 CFR 50.71(e) and the change requirements of 10 CFR 50.59. The NRC staff finds that there is reasonable assurance that the proposed changes to the TSs, as discussed above, are in accordance with the Commission's regulations. In addition, the NRC staff finds that the proposed changes to the new fuel oil sampling methodology are acceptable since adequate controls are in place to prevent tampering and contamination once the sample is taken to maintain adequate fuel oil quality. Therefore, the new fuel oil sampling methodology, as proposed to be changed, continues to meet GDC 17 requirements and is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment on February 21, 2017. 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 and changes the SRs. 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 published in the Federal Register on October 11, 2016 (81 FR 70178). 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: T. Sweat L. Wheeler Date: May 24, 2017

ML17048A184 *via e-mail OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DSS/STSB* DSS/SBPB*

NAME MBarillas BClayton AKlein RDennig DATE 5/1/2017 4/28/2017 2/21/2017 2/21/2017 OFFICE DE/ESGB* OGC-NLO DORL/LPL2-2/BC DORL/LPL2-2/PM NAME EWong JWachutka BBeasley MBarillas (AJohnson for)

DATE 2/21/2017 5/11/2017 5/23/2017 5/24/2017

v t e Letter Sequence Approval
CAC:MF7775, TSTF-2, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers 19 December 2016 Results Approval Other:
MONTHYEAR2016-05-26 [Table View]

ML17048A184