ML23019A003
| ML23019A003 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/16/2023 |
| From: | Ballard B Plant Licensing Branch 1 |
| To: | Blair B Energy Harbor Nuclear Corp |
| Goetz S | |
| References | |
| EPID L-2022-LLA-0048 | |
| Download: ML23019A003 (23) | |
Text
March 16, 2023 Mr. Barry N. Blair Site Vice President Energy Harbor Nuclear Corp.
Beaver Valley Power Station Mail Stop P-BV-SSEB P.O. Box 4, Route 168 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 320 AND 210 RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL (EPID L-2022-LLA-0048)
Dear Mr. Blair:
The U.S. Nuclear Regulatory Commission (NRC, or the Commission) has issued the enclosed Amendment No. 320 to Renewed Facility Operating License No. DPR-66 for the Beaver Valley Power Station (Beaver Valley), Unit 1, and Amendment No. 210 to Renewed Facility Operating License No. NPF-73 for the Beaver Valley, Unit 2. These amendments consist of changes to the technical specifications (TS) in response to your application dated March 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22090A093).
The amendments 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 TS and placing them in the TS Bases so that they may be modified under licensee control. The TS are modified so that the stored diesel fuel oil inventory will require that a 3 1/2 day supply for Unit 1 or 7 day supply for Unit 2 be available for each diesel generator and that the stored lube oil inventory of a 7 day supply be available for each diesel generator. Condition A and Condition B in the Action table are revised and Surveillance Requirements 3.8.3.1 and 3.8.3.2 are revised to reflect the above change. Additionally, TS 3.8.1, AC Sources - Operating, is revised to remove the specific numerical value for the fuel oil volume and replace it with the time requirement of greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> supply of fuel oil in each day and engine mounted tank (Unit 1) and each day tank (Unit 2).
B. Blair A copy of the related safety evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Brent Ballard, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosures:
- 1. Amendment No. 320 to DPR-66
- 2. Amendment No. 210 to NPF-73
- 3. Safety Evaluation cc: Listserv
ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION LLC DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 320 Renewed License No. DPR-66
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Energy Harbor Nuclear Corp., acting on its own behalf and as agent for Energy Harbor Nuclear Generation LLC* (the licensees),
dated March 30, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- Energy Harbor Nuclear Corp. is authorized to act as agent for Energy Harbor Nuclear Generation LLC and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.
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. DPR-66 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 320, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Hipolito J. Hipolito J. Gonzalez Date: 2023.03.16 Gonzalez 09:41:36 -04'00' Hipólito J. González, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: March 16, 2023
ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION LLC DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 Renewed License No. NPF-73
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Energy Harbor Nuclear Corp., acting on its own behalf and as agent for Energy Harbor Nuclear Generation LLC* (the licensees), March 30, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- Energy Harbor Nuclear Corp. is authorized to act as agent for Energy Harbor Nuclear Generation LLC and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.
Enclosure 2
- 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-73 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto and hereby incorporated in the license. Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Hipolito Hipolito J. J. Gonzalez Date: 2023.03.16 09:41:57 Gonzalez -04'00' Hipólito J. González, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: March 16, 2023
ATTACHMENT TO LICENSE AMENDMENT NOS. 320 AND 210 BEAVER VALLEY POWER STATION, UNITS 1 AND 2 RENEWED FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 DOCKET NO. 50-334 and 50-412 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.
Renewed Facility Operating License No. DPR-66 Remove Insert Page 3 Page 3 Renewed Facility Operating License No. NPF-73 Remove Insert Page 4 Page 4 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.
Appendix A, Technical Specifications Remove Insert 3.8.1 - 6 3.8.1 - 6 3.8.3 - 1 3.8.3 - 1 3.8.3 - 2 3.8.3 - 2
3.8.3 - 3
(3) Energy Harbor Nuclear Corp., 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) Energy Harbor Nuclear Corp., 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 instrument calibration or associated with radioactive apparatus or components; (5) Energy Harbor Nuclear Corp., pursuant to the Act and 10 CFR Parts 30, 40, 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 1:
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; 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 Energy Harbor Nuclear Corp. is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 320, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Auxiliary River Water System (Deleted by Amendment No. 8)
Amendment No. 320 Beaver Valley Unit 1 Renewed Operating License DPR-66
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations set forth in 10 CFR Chapter 1 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 Energy Harbor Nuclear Corp. is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 210, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Amendment No. 210 Beaver Valley Unit 2 Renewed Operating License NPF-73
AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.4.1 ------------------------------------------------------------------------
- NOTE -
Only applicable to Unit 1.
Verify each DG's day and engine mounted tanks In accordance contain a combined total of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> supply of fuel oil. with the Surveillance Frequency Control Program SR 3.8.1.4.2 ------------------------------------------------------------------------
- NOTE -
Only applicable to Unit 2.
Verify each DG's day tank contains 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> supply of In accordance fuel oil. with the Surveillance Frequency Control Program SR 3.8.1.5.1 ------------------------------------------------------------------------
- NOTE -
Only applicable to Unit 1.
Check and remove accumulated water from each day In accordance tank and engine mounted tank. with the Surveillance Frequency Control Program SR 3.8.1.5.2 ------------------------------------------------------------------------
- NOTE -
Only applicable to Unit 2.
Check and remove accumulated water from each day In accordance tank. with the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer In accordance fuel oil from storage tank to the day tank. with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.8.1 - 6 Amendments 320 / 210
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 fuel A.1 Restore fuel oil inventory to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> inventory less than a within limits.
3 1/2 day supply (Unit 1) 7 day supply (Unit 2) and greater than or equal to a 3 day supply (Unit 1) 6 day supply (Unit 2) in storage tank.
B. One or more DGs with lube 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 /> oil inventory less than a 7 to within limits.
day supply and greater than or equal to 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 limits.
particulates not within limit.
D. One or more DGs with new D.1 Restore stored fuel oil 30 days fuel oil properties not within properties to within limits.
limits.
Beaver Valley Units 1 and 2 3.8.3 - 1 Amendments 320 / 210
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. One or more DGs with E.1 Restore starting air 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> starting air receiver receiver pressure to pressure 165 psig (Unit 1)
< 165 psig and 125 psig 380 psig (Unit 2).
(Unit 1)
< 380 psig and 285 psig (Unit 2).
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 not within limits for reasons other than Condition A, B, C, D, or E.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains In accordance a 3 1/2 day supply of fuel oil (Unit 1) with the a 7 day supply of fuel oil (Unit 2). Surveillance Frequency Control Program SR 3.8.3.2 Verify lubricating oil inventory is a 7 day supply. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil are In accordance tested in accordance with, and maintained within the with the Diesel limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program Beaver Valley Units 1 and 2 3.8.3 - 2 Amendments 320 / 210
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.3.4 Verify DG air start receiver pressure is In accordance 165 psig (Unit 1) with the 380 psig (Unit 2). Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from each In accordance fuel oil storage tank. with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.8.3 - 3 Amendments 320 / 210
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 320 AND 210 TO RENEWED FACILITY OPERATING LICENSES NOS. DPR-66 AND NPF-73 ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By application dated March 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22090A093), Energy Harbor Nuclear Corp. (the licensee),
requested changes to the technical specifications (TS) for Beaver Valley Power Station (Beaver Valley), Units 1 and 2.
The proposed changes would revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, Surveillance Requirement (SR) 3.8.3.1 (verification of fuel oil storage tank volume), and SR 3.8.3.2 (verification of lube oil inventory volume), by removing the current stored diesel fuel oil and lube oil numerical volume requirements and replacing them with duration-based diesel operating time requirements, consistent with TS Task Force (TSTF) Standard TS traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (ML090510686). The availability of this TS improvement was published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the consolidated line item improvement process (CLIIP). The licensee also proposed changes that would revise TS 3.8.1, AC Sources
- Operating, SR 3.8.1.4.1 and SR 3.8.1.4.2 (verification of diesel generator (DG) day tank fuel oil volumes for each unit) to replace the specific day tank numerical volume requirements with a duration-based diesel operating time requirement. The licensee also proposed associated changes to the TS Bases.
Any change to the numerical volume requirements in the TS requires prior approval by the U.S.
Nuclear Regulatory Commission (NRC or the Commission). Licensees may need to modify diesel fuel oil numerical volumes to account for changes to the energy content (British Thermal Units (BTU)/gallon) of available fuel oils in the market. Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements. The proposed changes would remove the numerical volume requirements for stored diesel fuel oil and lube oil from the TS and would replace them with duration-based diesel operating time requirements.
This amendment would permit the numerical volume requirements for stored diesel fuel oil and lube oil to be modified under licensee control pursuant to Title 10 of the Code of Federal Enclosure 3
Regulations (10 CFR) Section 50.59, Changes, tests, and experiments, and, therefore, would not require a license amendment pursuant to 10 CFR 50.90.
2.0 REGULATORY EVALUATION
2.1 System Description 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 requirements are retained in the TS as a limiting condition for operation (LCO) under 10 CFR 50.36(c)(2)(i) because they support the operation of the standby AC power sources.
Each Beaver Valley Units standby AC power system is powered by two independent DGs capable of an automatic start at any time and capable of continued operation at rated load, voltage, and frequency until manually stopped. Each DG is provided with a storage tank having a diesel fuel oil capacity sufficient to operate that DG for a period of 3 1/2 days (Unit 1) or 7 days (Unit 2) while the DG is supplying maximum post loss-of-coolant accident load demand. The maximum load demand is calculated assuming that one DG is operated at full load for 7 days.
This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources. Diesel fuel oil is transferred from each storage tank to its respective day tank by either of two transfer pumps associated with each storage tank.
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 DGs diesel engine working surfaces and to remove excess heat generated by friction during operation. Each DG has an inventory of lube oil 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.
2.2 Description of the Proposed Changes The proposed changes in the license amendment request (LAR) would revise conditions and SRs in TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air and SRs in TS 3.8.1, AC
[alternating current] Sources - Operating, by removing the current stored diesel fuel oil volume and lube oil inventory numerical requirements and replacing them with duration-based DG operating time requirements. The proposed changes would mean that the volume necessary to meet the TS duration requirements may be modified under licensee control. The specific TS changes are described in the following sections.
Consistent with TSTF-501, the licensee proposes replacing the volumetric requirements with the duration-based DG operating times required by the current licensing basis for Beaver Valley, Units 1 and 2.
2.2.1 Proposed Changes to TS 3.8.3 Actions Table Conditions A and B Conditions A and B of TS LCO 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, would be revised in the Actions table. Currently, Conditions A and B apply when the stored diesel fuel oil and lube oil numerical volume requirements are not met. As discussed in the TS Bases, the numerical diesel fuel oil volume requirement for Unit 2s DGs in Condition A is based on volumes of less than a 7-day supply, but greater than or equal to a 6-day supply. Similarly, for
Unit 1, Condition A would apply for a less than 3 1/2-day supply, but greater than or equal to a 3-day supply of diesel fuel oil. For both Unit 1 and Unit 2, the numerical DG lube oil inventory requirement in Condition B would apply for a volume of less than a 7-day supply, but greater than or equal to a 6-day supply. The proposed amendment would remove the numerical volumetric requirements from the TS and replace them with duration-based requirements.
2.2.2 Proposed Changes to SR 3.8.3.1, SR 3.8.3.2, SR 3.8.1.4.1, and SR 3.8.1.4.2 Currently, SR 3.8.3.1 requires the licensee to verify that fuel oil storage tanks contain a volume greater than or equal to 17,500 gallons of fuel oil for each Unit 1 tank and 53,225 gallons of fuel oil for each Unit 2 tank. SR 3.8.3.2 requires the licensee to verify that the lube oil inventory volume is greater than or equal to 330 gallons for each DG. SR 3.8.1.4.1, which applies only to Unit 1, requires the licensee to verify that each DGs day and engine-mounted tanks contain a combined volume of greater than or equal to 900 gallons of fuel oil. SR 3.8.1.4.2 is applicable only to Unit 2 and requires the licensee to verify that each DGs day tank contains greater than or equal to 350 gallons of fuel oil. The proposed amendment would remove the numerical volume requirements from these SRs. SR 3.8.3.1 would be revised to require verification that the stored diesel fuel oil inventory is greater than or equal to a 3 1/2-day supply (Unit 1) or a 7-day supply (Unit 2). For SR 3.8.3.2, it would require verification that the lube oil inventory is greater than or equal to a 7-day supply. SRs 3.8.1.4.1 and 3.8.1.4.2 would be revised to require the licensee verify that each day and engine mounted tank (Unit 1) and each day tank (Unit 2) contain a minimum one-hour supply of fuel oil.
2.2.3 Licensee-Identified Variations from TSTF-501, Revision 1 In the LAR, the licensee proposed four variations from TSTF-501, Revision 1, as described below:
Variation 1: The LAR includes a proposed change to remove the fuel oil volume requirements and replace them with durational requirements for SR 3.8.1.4.1 (Unit 1 DGs day and engine-mounted tanks) and SR 3.8.1.4.2 (Unit 2 DGs day tanks).
Variation 2: Standard TS 3.8.3, Conditions A and B in TSTF-501 uses the phrase greater than a 6 day supply. For Condition A, the licensee proposed using greater than or equal to a 3-day supply (Unit 1) or a 6-day supply (Unit 2). For Condition B, the licensee proposed to use greater than or equal to a 6-day supply.
Variation 3: In the Beaver Valley TS Bases for SR 3.8.3.1, the current references include Regulatory Guide (RG) 1.137, Fuel-Oil Systems for Standby Diesel Generators and the Updated Final Safety Analysis Report (UFSAR), while the TSTF-501 standard TS Bases for SR 3.8.3.1 reference American National Standards Institute (ANSI) standard N195. The licensee stated in the LAR that the Unit 2 UFSAR includes ANSI N195 as a design basis reference and ANSI N195 will be added to the Unit 1 UFSAR design basis.
Variation 4: The Beaver Valley Unit 1 calculations that determine fuel oil volumes do not include the fuel oil volume required to support periodic testing. Instead, the licensee administratively controls fuel oil in support of periodic testing to meet TS requirements.
2.2.4 Proposed Changes to TS Bases Consistent with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1), the licensee submitted corresponding changes to the TS Bases that provide the reasons for the proposed TS changes. The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TS. The licensee shall make changes to the Beaver Valley TS Bases in accordance with TS 5.5.10, TS Bases Control Program. This applies to both proposed bases consistent with TSTF-501 and those in Variation 3, as described in Section 2.2.3 of this safety evaluation (SE).
2.3 Regulatory Requirements and Guidance Used in the Evaluation of the Changes 2.3.1 Regulatory Requirements The regulation in 10 CFR 50.36, Technical specifications, provides the regulatory requirements for the content of the TS. It requires, in part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a production or utilization facility. Specifically, 10 CFR 50.36(c) requires that TS include items in five specific categories related to station operation. These categories are (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls.
The regulation in 10 CFR 50.36(c)(2)(i), Limiting conditions for operation, states, in part, that TS will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Section 50.36(c)(2)(i) further states that
[w]hen 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 regulation in 10 CFR 50.36(c)(3), Surveillance requirements, states that [s]urveillance requirements are 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 limiting conditions for operation will be met.
2.4.2 Guidance Regulatory Guide 1.137, Revision 1, Fuel-Oil Systems for Standby Diesel Generators (ML003740180), provides guidance that describes a method acceptable to the NRC staff for complying with the Commissions regulations regarding fuel oil systems for standby DGs and endorses ANSI N195-1976, Fuel Oil Systems for Standby Diesel Generators, with certain limitations. RG 1.137, Section C.1.c sets forth two methods for the calculation of fuel oil storage requirements as described in ANSI N195-1976, Section 5.4 Calculation of Fuel Oil Storage Requirements. These methods are: (1) calculations based on the assumption that the DG operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the DG. If the time-dependent load method is used, the minimum required capacity should include the capacity to power engineered safety features.
The NRC-approved Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (ML090510686), provides an acceptable method of modifying the stored fuel oil and lube oil requirements contained in the STS. Though the
TSTF-501 traveler was developed based on changes to Revision 3 of NUREG-1431, the NRC staffs review of this LAR includes consideration of whether the proposed changes are consistent with the latest revision. NUREG-1431, Revision 5, Standard Technical Specifications for Westinghouse Plants (ML21259A155), provides example TS LCOs and acceptable remedial actions that meet the requirements in 10 CFR 50.36(c)(2)(i) for a standard plant design.
3.0 TECHNICAL EVALUATION
The licensee assessed the model SE (ML100850069), which was published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the CLIIP notice of availability. The licensee concluded, as stated in Attachment 1 of the LAR, that the justifications presented in the model SE are applicable to Beaver Valley Units 1 and 2, and therefore justify this amendment.
Each Unit 1 DG is provided with a fuel oil capacity sufficient to operate that DG for a period of 3 1/2 days (7 days for Unit 2). This onsite fuel oil capacity is sufficient to operate the DG long enough to place Beaver Valley in a shutdown condition and to bring in replenishment fuel oil from offsite sources.
The standby AC power sources (i.e., the DGs), 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. Requirements for diesel fuel oil and lube oil supplies are retained in the TS under 10 CFR 50.36(c)(2)(i) because they support the operation of the standby AC power sources.
The proposed changes would revise TS 3.8.3 and SRs 3.8.3.1, 3.8.3.2, 3.8.1.4.1, and 3.8.1.4.2 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS and replacing them with the associated duration-based diesel operating times. These changes would permit the fuel oil and lube oil volumes necessary to support a duration-based DG operating time to be modified under licensee control pursuant to 10 CFR 50.59. The NRC staffs evaluation of the proposed TS changes is provided in the following sections.
3.1 NRC Staff Evaluation of Proposed Changes to TS 3.8.3 Actions Table Conditions A and B The NRC staff reviewed the proposed changes described in Section 2.2.1 of this SE. The changes would modify TS 3.8.3 Conditions A and B by removing the numerical volumetric requirements and replacing them with duration-based diesel operating time requirements. The following are applicable to the inventories of one or more DGs:
for Unit 1, Condition A is entered when the stored fuel oil inventory is less than a 3 1/2-day supply, but greater than or equal to a 3-day supply for Unit 2, Condition A is entered when the stored fuel oil inventory is less than a 7-day supply, but greater than or equal to a 6-day supply for both units, Condition B is entered when the lube oil inventory is less than a 7-day supply, but greater than or equal to a 6-day supply No other parts of Condition A or B are proposed to be modified.
In section 2.2.3 of this SE, Variation 2 describes phrasing in Beaver Valleys TS 3.8.3 Conditions A and B that differs from the equivalent in TSTF-501 (i.e., Beaver Valleys greater than or equal to versus standard TSs greater than). The NRC staff determined that this difference does not conflict with the intent of TSTF-501 to permit the numerical volume requirements for stored diesel fuel oil and lube oil to be modified under licensee control, and therefore finds Variation 2 acceptable.
The licensee stated that methodology described in RG 1.137 and ANSI N195-1976, Fuel Oil Systems for Standby Diesel Generators, will be used to calculate the stored diesel fuel oil numerical volumes sufficient to meet the duration-based operating time requirements, and that these volumes are based on applying the conservative assumption that the DG is operated continuously for 3 1/2 days (Unit 1) or 7 days (Unit 2) at its rated capacity. The use of this methodology will ensure that the supplies of stored diesel fuel oil for each DG that dictate Condition A entry will continue to be calculated in accordance with NRC-approved methods.
Regarding lube oil, the volumes equivalent to a 7-day and a 6-day supply that dictate Condition B entry are based on the DG manufacturers consumption values for the run time of the DG.
Based on the above evaluation, the NRC staff finds that the changes to the TS 3.8.3 Actions table are acceptable because they remain consistent with the requirements in 10 CFR 50.36(c)(2)(i) by providing the conditions and remedial actions for when LCO 3.8.3 is not met that support DG operational analysis.
3.2 NRC Staff Evaluation of Proposed Changes to SRs 3.8.3.1, 3.8.3.2, 3.8.1.4.1, and 3.8.1.4.2 The NRC staff reviewed the proposed changes described in Section 2.2.2 of this SE that revise SRs 3.8.3.1, 3.8.3.2, 3.8.1.4.1, and 3.8.1.4.2. The proposed changes to SRs 3.8.3.1 and 3.8.1.2 would reflect the change from numerical volume requirements to durational requirements made in the TS 3.8.3 Actions table. Specifically, SR 3.8.3.1 would be revised to require, for each DG, verification of at least a 3 1/2-day supply of fuel oil for Unit 1, and at least a 7-day supply of fuel oil for Unit 2, rather than a specified numerical volume. Likewise, SR 3.8.3.2 would be revised to require availability of at least a 7-day supply of lube oil for each DG.
The licensee also proposed to revise SRs 3.8.1.4.1 and 3.8.1.4.2. The proposed change to these SRs is similar to the proposed change for SR 3.8.3.1 in that the numerical volume requirements would be replaced with durational requirements. SR 3.8.1.4.1 (applicable to Unit 1s day and engine-mounted tanks) and SR 3.8.1.4.2 (applicable to Unit 2s day tanks) would require the licensee to verify that the diesel fuel oil volume for each DG is greater than or equal to a one-hour supply of fuel oil. The licensees proposed inclusion of these changes to the day and engine-mounted tank requirements in the LAR is identified as Variation 1 in section 2.2.3 of this SE.
In Attachment 1 of the LAR, the licensee describes how the volume of fuel oil necessary to support operation of the standby DGs is managed at the site, as follows:
the Unit 2 calculation determines the fuel oil volume required to support 7 day operation of each diesel generator and does explicitly include analysis that shows adequate capacity for testing purposes is available. The Unit 1 calculation determines the fuel oil volume required to support 3 1/2 day operation of each diesel generator but does not include an explicit allowance for fuel oil
consumption due to periodic testing. Instead, Unit 1 administratively controls fuel oil volumes in support of required periodic testing, such that the TS required volumes are maintained above the requirement for a 3 1/2 day supply for each storage tank.
The proposed changes to SR 3.8.1.4.1 and SR 3.8.1.4.2 are identified as Variation 4 in Section 2.2.3 of this SE.
The methodology in ANSI N195-1976 discusses how the stored diesel fuel oil requirement should 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 in ANSI N195-1976 considers the time dependence of DG loads. That is, if DG loads increase or decrease during the event, the load changes should be included in the required fuel oil 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 should be included in the calculation of required fuel oil storage capacity. Revision 1 of RG 1.137 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 shall 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 engine operates continuously for 7 days at its rated capacity.
Since both methods described in ANSI N195-1976 are approved for use by the NRC staff in RG 1.137, Revision 1, and the licensee calculates the volume of fuel oil in accordance with RG 1.137, Revision 1, the staff has reasonable assurance that the volume of fuel oil calculated by the licensee will meet the new duration-based limits specified in SR 3.8.3.1, SR 3.8.1.4.1, and SR 3.8.1.4.2. Additionally, the licensee will administratively control the amount of fuel oil required to support periodic testing of Unit 1 DGs. As stated in the LAR, the licensee will control the volume of fuel oil required for testing in addition to the TS required 3 1/2-day supply.
One variable used in both stored diesel fuel oil calculation methods is the fuel oil consumption rate. The property of diesel fuel oil having the most significant effect on the fuel oil consumption rate is the energy content (heating value) of the fuel oil. Standards exist that correlate the energy content to the fuel oils American Petroleum Institute (API) gravity or absolute specific gravity. At a minimum, licensees calculate the required fuel oil storage values for their plants assuming the most limiting API gravity or absolute specific gravity, and therefore, the most limiting fuel oil 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 licensee, the calculations of fuel oil consumption and required stored volume remain valid. Current SR 3.8.3.3 requires new fuel oil to be tested in accordance with, and maintained within the limits of current TS 5.5.9, Diesel Fuel Oil Testing Program to verify that the fuel oils 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 TS 3.8.3 Condition B, is based on the DG manufacturer consumption values for the run time of the DG.
The above methods continue to provide assurance that the necessary quantity and quality of diesel fuel oil and lube oil will continue to be maintained and calculated in accordance with
NRC-approved methods. Variation 1 is acceptable because revising the day and engine-mounted tank supply for Unit 1 (day tank supply for Unit 2) to a duration-based amount continues to provide assurance that the necessary quality of systems and components is maintained, and that facility operation will be within safety limits, and that the LCOs will be met, consistent with 10 CFR 50.36(C)(3). The method used to calculate the day tank oil volumes is one of the acceptable methods provided in RG 1.137. Variation 4 is acceptable because the calculation method used to determine the volume of oil required to be controlled is one of the acceptable methods provided in RG 1.137 and continues to provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within the safety limits, and that the LCOs will be met because only the calculated volume of oil, less testing volume, is necessary if the DG was used in an accident, consistent with 10 CFR 50.36(c)(3). Therefore, the NRC staff finds the duration-based changes to SRs 3.8.3.1, 3.8.3.2, 3.8.1.4.1, and 3.8.1.4.2 acceptable.
3.3 Technical Conclusion The proposed changes will continue to require that the appropriate volumes of stored diesel fuel oil and lube oil are maintained. The proposed changes to TS 3.8.3 Actions table continue to provide assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility will continue to be met. Conditions A and B of the TS 3.8.3 Actions table continue to provide acceptable remedial actions to follow until LCO 3.8.3 can be met. The NRC staff concludes that replacement of the TS numerical value volume requirements with durational requirements does not change the current plant configuration, the current volume requirements, or the current basis for fuel oil and lube oil volume requirements.
Therefore, the changes to TS 3.8.3 Actions table will continue to meet 10 CFR 50.36(c)(2)(i) and are acceptable.
In addition, the proposed changes to SRs 3.8.3.1, 3.8.3.2, 3.8.1.4.1, and 3.8.1.4.2 continue to provide assurance that the necessary quality of systems and components is maintained, the facility will be within safety limits, and that the LCO will be met. The revised SRs will continue to meet 10 CFR 50.36(c)(3) and are therefore acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments on January 6, 2022. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change 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 surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (87 FR 36008; June 14, 2022). Accordingly, the amendments meet 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 amendments.
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: K. West, NRR Date: March 16, 2023
ML23019A003 *by memorandum OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NAME BBallard KZeleznock VCusumano BWittick DATE 01/18/2023 01/25/2023 12/19/2022 01/28/2023 OFFICE OGC - NLO* NRR/DORL/LPL1/BC NRR/DORL/LPL3/PM NAME ELicon HGonzález BBallard DATE 03/13/2023 3/16/2023 3/16/2023