RA-19-0157, Supplement to Request for License Amendment Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time

Supplement to Request for License Amendment Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time

ML19085A340
Person / Time
Site:	Brunswick
Issue date:	03/26/2019
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0157
Download: ML19085A340 (12)

Text

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 March 26, 2019 Serial: RA-19-0157 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Supplement to Request for License Amendment Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time

Reference:

Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Request for License Amendment Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time, dated April 25, 2018, ADAMS Accession Number ML18121A366 Ladies and Gentlemen:

On April 25, 2018 (i.e., Reference), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed change revises an existing Note to allow, on a one-time basis, the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing required inspection, cleaning, and any necessary repair activities.

In support of the LAR, Duke Energy commits to the compensatory actions contained in of this submittal. Additionally, the proposed Note is revised to reference this submittal and indicate that use of the Note is contingent upon meeting these compensatory actions. Enclosures 2 and 3 provide the existing TS pages, for Units 1 and 2, marked-up to show the proposed change. Enclosures 4 and 5 provide revised (i.e., typed) TS pages for Units 1 and 2. There are no TS Bases revisions necessary to support the proposed changes.

Duke Energy has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared for the proposed amendment.

Please refer any questions regarding this submittal to Mr. Art Zaremba, Director - Nuclear Fleet Licensing, at (980) 373-2062.

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on March 26, 2019.

Sincerely, l429 William R. Gideon MAT/mat

Enclosures:

1. Regulatory Commitments

2. Proposed Technical Specification Changes (Mark-Up) - Unit 1

3. Proposed Technical Specification Changes (Mark-Up) - Unit 2

4. Revised (Typed) Technical Specification Pages - Unit 1

5. Revised (Typed) Technical Specification Pages - Unit 2 cc:

U. S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Dennis J. Galvin 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

RA-19-0157 Enclosure 1 Page 1 of 2 Regulatory Commitments Commitment Description Due Date / Event

1. Fuel oil removed from the main fuel oil During application of the one-time Completion storage tank will be maintained in Time extension to support main fuel oil storage temporary, onsite storage. This will ensure tank inspection, cleaning, and repair activities.

that a full seven-day fuel oil supply for each required diesel is available onsite.

2. Plant procedures will be developed to Prior to application of the one-time Completion transfer fuel oil from the temporary, onsite Time extension to support main fuel oil storage storage to the 4-day fuel oil storage tanks tank inspection, cleaning, and repair activities.

should the need arise.

3. If electric transfer pumps are used, they During application of the one-time Completion will be powered by an EDG supplied Time extension to support main fuel oil storage electrical bus or a separate generator tank inspection, cleaning, and repair activities.

versus the plant electrical system.

4. BSEP will maintain on-site adequate During application of the one-time Completion inventory of diesel fuel oil to refill the Time extension to support main fuel oil storage diesel-driven fire pump fuel oil supply tank tank inspection, cleaning, and repair activities.

to meet a minimum time exposure window of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

5. Plant procedures will be developed to Prior to application of the one-time Completion transfer fuel oil from the temporary, onsite Time extension to support main fuel oil storage storage to the diesel-driven fire pump fuel tank inspection, cleaning, and repair activities.

supply storage tank should the need arise.

6. Adequate barriers to prevent any fire During application of the one-time Completion associated with the repair (i.e., welding, Time extension to support main fuel oil storage hot surfaces, and volatile gases) from tank inspection, cleaning, and repair activities.

propagating to the diesel fuel oil 4-day tank or headers will be provided.

7. Elective maintenance and testing, that During application of the one-time Completion affects Emergency Diesel Generator Time extension to support main fuel oil storage operability, will not be permitted. tank inspection, cleaning, and repair activities.

8. Elective switchyard activities and other During application of the one-time Completion elective on-site electrical maintenance that Time extension to support main fuel oil storage could cause any unstable offsite or on-site tank inspection, cleaning, and repair activities.

power conditions will not be scheduled.

9. Removal of the main fuel oil storage tank Prior to application of the one-time Completion from service will not be permitted when Time extension to support main fuel oil storage severe weather is forecast for the area or if tank inspection, cleaning, and repair activities.

there is a foreseen need for EDG operation.

RA-19-0157 Enclosure 1 Page 2 of 2

10. Restoration of the main fuel oil storage During application of the one-time Completion tank will be pursued in an expeditious Time extension to support main fuel oil storage manner if long-term Emergency Diesel tank inspection, cleaning, and repair activities.

Generator operation is required.

RA-19-0157 Enclosure 2 Proposed Technical Specification Changes (Mark-Up)

Unit 1

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

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES ----------------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than December 31, 2008 June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

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

storage tank(s) < 22,650 gal per required DG and 17,000 gal per required DG.

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

(continued)

Brunswick Unit 1 3.8-20 Amendment No. 242

RA-19-0157 Enclosure 3 Proposed Technical Specification Changes (Mark-Up)

Unit 2

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

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES ----------------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than December 31, 2008 June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

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

storage tank(s) < 22,650 gal per required DG and 17,000 gal per required DG.

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

(continued)

Brunswick Unit 2 3.8-20 Amendment No. 270

RA-19-0157 Enclosure 4 Revised (Typed) Technical Specification Pages Unit 1

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

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES ----------------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

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

storage tank(s) < 22,650 gal per required DG and 17,000 gal per required DG.

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

(continued)

Brunswick Unit 1 3.8-20 Amendment No. 242

RA-19-0157 Enclosure 5 Revised (Typed) Technical Specification Pages Unit 2

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

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES ----------------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

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

storage tank(s) < 22,650 gal per required DG and 17,000 gal per required DG.

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

(continued)

Brunswick Unit 2 3.8-20 Amendment No. 270