ML23088A120
| ML23088A120 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/29/2023 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23088A118 | List: |
| References | |
| ULNRC-06751 | |
| Download: ML23088A120 (1) | |
Text
Enclosure to ULNRC-0675 1 Page 1 of9 ENCLOSURE Evaluation of the Proposed Change
Subject:
Application to Revise Technical Specifications to Adopt TSTF-501-A Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control
1.0 DESCRIPTION
2.0 PROPOSED CHANGE
3.0 BACKGROUND
4.0 TECHNICAL ANALYSIS
5.0 REGULATORY ANALYSIS
5.1 No Significant Hazards Consideration Analysis 5.2 Applicable Regulatory Requirements / Criteria 6.0 ENVIRONMENTAL EVALUATION
7.0 REFERENCES
ATTACHMENTS 1.
Marked-up TS Pages 2.
Revised (Clean) TS Pages 3.
Marked-up TS Bases Pages (provided for information only) 4.
List of Commitments
Enclosure to ULNRC-0675 1 Page 2 of 9 1.0 DESCRIPTION The changes proposed in this license amendment request (LAR) for the Callaway Technical Specifications are based on TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control, as applicable to the stored fuel oil and lube oil volumes needed to support the standby/emergency diesel generators (DGs). This Traveler revises Technical Specification (TS) 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, to replace the numerical volume requirements for stored diesel fuel oil and lube oil inventory with the requirement that a 7-day supply be available. The diesel fuel oil and lube oil numerical volumes equivalent to a 6-day supply, used in the Actions, are replaced with a statement that there is a 6-day supply. The diesel fuel oil and lube oil numerical volumes equivalent to a 7-day and 6-day supply are stated in the Bases and will be controlled under the TS Bases Control Program.
2.0 PROPOSED CHANGE
The TSTF-501 based changes proposed for the Callaway Technical Specifications are as follows; Surveillance Requirement (SR) 3.8.3.1 states, Verify each fuel oil storage tank contains
? 80,900 gal offuel. The proposed change revises SR 3.8.3.1 to state, Verify each fuel oil storage tank contains ? a 7-day supply offuel. The Bases ofSR 3.8.3.1 are revised to state, The fuel oil inventory equivalent to a 7-day supply is 80,900 gallons when calculated in accordance with References 2 and 3, and to provide additional detail on the calculation ofthe required volume. References 2 and 3 are Regulatory Guide 1.137 and ANSI N195-1976, respectively. The Bases note that these calculations use the most limiting energy content allowed for the stored fuel.
SR 3.8.3.2 states, Verify lubricating oil inventory is ? 750 gal. The proposed change revises SR 3.8.3.2 to state, Verify lubricating oil inventory is ? a 7-day supply. The Bases of SR 3.8.3.2 are revised to state, The lube oil level equivalent to a 7-day supply is 750 gallons.
Condition A states, One or more DGs with fuel level < 80,900 gal and > 69,800 gal in storage tank. The proposed change revises Condition A to state, One or more DGs with fuel level less than a 7-day supply and greater than a 6-day supply in storage tank.
The Bases of Required Action A. 1 are revised to state, The fuel oil level equivalent to a 6-day supply is 69,800 gallons.
Condition B states, One or more DGs with lube oil inventory < 750 gal and> 686 gal.
The proposed change revises Condition B to state, One or more DGs with lube oil inventory less than a 7-day supply and greater than a 6-day supply. The Bases of Required Action B.1 are revised to state, The lube oil inventory equivalent to a 7-day supply is 750 gallons, and a 6-day supply is 686 gallons.
Enclosure to ULNRC-0675 1 Page 3 of 9 The Background section ofthe Bases for TS 3.8.3 is revised to reference Regulatory Guide (RG) 1
. 1 37 in discussing fuel oil capacity. The Bases currently reference RG 1. I 37 in the discussion offuel oil quality, but not in reference to fuel oil volume.
Although they are not explicitly part ofthis LAR, changes to the Callaway FSAR are also intended to be made in support ofthe proposed TS changes. The changes involve revising FSAR Chapter 3A to revise Callaways commitment to RG 1. 1 37 from Revision 0 to Revision 1, specifically (and only) in regard to the calculation methodology used for determining the required diesel fuel oil storage volumes. This proposed FSAR change is consistent with NRC guidance contained in correspondence between the NRC and the Technical Specifications Task Force, in connection with TSTF-501. Specifically, in the NRCs letter dated April 3, 2014 (Reference 4 in Section 7.0 ofthis LAR attachment), the NRC emphasized the importance of utilizing an NRC-approved EDG fuel oil calculation methodology to determine run-duration equivalent diesel fuel oil volumes, and based on that, licensees should identify the NRC-approved calculation methodology in their FSARs. On that basis, as stated in the NRCs letter, current and future license amendments requesting adoption ofTSTF-501 need to provide a regulatory commitment consistent with the one provided as a model within the NRCs letter.
Since RG 1.137, Revision 1, specifies the methodology discussed in the NRCs letter, the FSAR changes proposed for Callaway will include adoption ofthat revision ofthe Regulatory Guide specifically for the diesel fuel oil volume calculation methodology (as Callaway generally remains committed to Revision 0). This commitment is thus being made in connection with the proposed adoption ofTSTF-501. The commitment is documented in Attachment 4, and the content ofthe commitment is consistent with NRCs guidance contained in the noted letter (Reference 4).
3.0 BACKGROUND
In January 2001 and in June 2004, the U.S. Environmental Protection Agency (EPA) finalized the Clean Diesel Trucks and Buses Rule and the Clean Nonroad Diesel Rule, respectively, with more stringent standards for new diesel engines and fuels. (See NRC Information Notice 2006-22, New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance, October 12, 2006.) The EPA rules require a reduction in the sulfur content of highway diesel fuel from its current level of 500 parts per million (ppm) (low sulfur diesel, or LSD) to 1 5 ppm (Ultra Low Sulfur Diesel or ULSD). Refiners were required to start producing the cleaner-burning ULSD fuel, for use in highway vehicles beginning June 1, 2006. The EPA requires sulfur reductions for land-based nonroad diesel fuel to be accomplished in two steps, with the test step from uncontrolled levels to a 500 ppm cap starting in June 2007 and the final step to 1 5 ppm in June 20 1 0. Although the EPA requirements for the 1 5 ppm ULSD did not take effect until 2010 for nonroad diesel fuel, several nuclear power plant licensees began receiving shipments of ULSD. The California Air Resources Board regulations required that all California users of diesel fuel oil transition to ULSD fuel oil by June 1, 2006.
In general, the processing required to reduce sulfur in ULSD also reduces the aromatics content and density of diesel fuel, resulting in a reduction in volumetric energy content (BTU/gallon).
The reduced energy capacity of the ULSD may result in increased fuel consumption such that
Enclosure to ULNRC-0675 1 Page 4 of 9 the TS limit on diesel fuel oil storage level in TS 3.8.3 would be insufficient to ensure that the diesel generator can operate for at least 7 days, as described in the Bases for the LCO.
Therefore, it was anticipated that many nuclear plant licensees would submit a license amendment request to increase the required amount ofstored diesel fuel oil ifthe current required volume would no longer be equivalent to a 7-day supply ofULSD. Some plants have already submitted such amendments. (See, for example, ADAMS accession number MLO6 1590319.)
The requirements on diesel fuel oil may continue to change in the future, and the addition of additives to compensate for the issues associated with ULSD discussed in Information Notice 2006-022 may further affect the volumetric energy content (and, as a result, the stored diesel fuel oil volume requirements). These changes would result in future license amendments to revise the stored fuel oil volume in order to ensure that the volume provides for at least 7 days ofdiesel generator operation. In order to facilitate the expeditious revision ofthe fuel oil volume requirement when needed and to avoid the unnecessary expenditure of licensee and NRC resources to prepare and review future license amendment requests that simply revise the volume equivalent to a 7-day supply, the proposed change places the requirement to have stored fuel oil sufficient to support 7 days of diesel generator operation in the Technical Specifications with the equivalent numerical volume under licensee control in the TS Bases (or the volume equivalent to the number ofdays supply required by the licensees licensing basis).
The TS requirements on lube oil are also based on maintaining a 7-day supply. To maintain consistency within the Specification and to avoid future amendments to the lube oil inventory numerical value equivalent to a 7-day supply, the proposed change places the requirement to have lube oil inventory sufficient to support 7 days ofdiesel generator operation in the Technical Specifications with the equivalent numerical volume in the TS Bases.
4.0 TECHNICAL ANALYSIS
Regulatory Position 1 ofRegulatory Guide 1.137 states that ANSI N195-1976 provides a method acceptable to the NRC staff for complying with the pertinent requirements of General Design Criterion 17 ofAppendix A to 10 CFR Part 50. Regulatory Position 1.c states that the fuel oil storage requirements should either be based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity or calculations based on the time-dependent loads ofthe diesel generator. The NRCs Standard Review Plan, NUREG-0800, Section 9.5.4, paragraph I.d, states that one ofthe areas ofreview by the NRC is to ensure that A minimum ofseven days supply offuel oil, for each redundant diesel generator system, has been provided onsite to meet the engineered safety feature load requirements following a loss of offsite power and a design basis accident. The TS 3.8.3 LCO Bases state, Stored diesel fuel oil is required to have sufficient supply for 7 days of full load operation. From these sources, it is clear that the principal safety concern with the volume of the stored diesel fuel oil is that there is a 7-day supply. Some licensees are required to maintain a stored diesel fuel oil volume equivalent to a different number of days. The proposed change does not alter the licensing basis of the plant, but only revises the presentation ofthe licensing basis assumption (days versus gallons).
Enclosure to ULNRC-0675 1 Page 5 of 9 Historically, the specific volume offuel oil required to provide a 7-day supply was specified in the Technical Specifications to facilitate the comparison by the operator ofthe indicated tank level to the volume limit. However, recent state and federal regulatory changes that affect diesel fuel oil energy content, as well as the anticipation of future changes, support the relocation ofthe specific volume limit to licensee control and placing the basis ofthe limit in the Technical Specifications. There is ample precedent for this type of relocation of specific limits to licensee control while retaining the requirement in the Technical Specifications, such as Generic Letter 88-1 6, Removal of Cycle-Specific Parameter Limits from Technical Specifications, Generic Letter 96-03, Relocation ofthe Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits, and TSTF-2-A, Relocate the 10 year sediment cleaning ofthe fuel oil storage tank to licensee control.
The methodology for calculating the fuel oil storage volume equivalent to a 7-day supply is well established. The Bases will state that the fuel oil level equivalent to a 7-day supply is calculated in accordance with Regulatory Guide 1.137 and ANSI N195-1976. The volume will be stated in the TS Bases, and changes to the volume must be reviewed under the TS Bases Control Program described located in the Administrative Controls chapter ofthe Technical Specifications, which requires changes to be evaluated under 10 CFR 50.59. Future changes to the fuel oil volume or method ofcalculation that do not meet the criteria in 10 CFR 50.59 (for being able to be implemented by the licensee without NRC approval) will be submitted to the NRC for prior review under 10 CFR 50.90.
The 7-day diesel fuel oil inventory requirement is based on the concept ofsupporting diesel generator operation for 7 days without requiring resupply. To support that goal, a 7-day supply of lube oil for the diesel generators must also be available. The volume equivalent to a 7-day supply is based on supporting at least 7 days of full load operation for each DG at the diesel generator manufacturers lube oil consumption values for the diesel generator under those conditions. It is proposed to relocate the specific value for the lube oil equivalent to a 7-day supply to the Bases, in order to be consistent with the diesel fuel oil requirements. In addition, NRC Information Notice 96-67, Vulnerability of Emergency Diesel Generators to Fuel Oil/Lubricating Oil Incompatibility, noted that the reduced amount of sulfur in ULSD will result in more unreacted additive in the lubricating oil. This may result in the formation of deposits when some ofthe oil is burned, which may affect the volume oflube oil required to support 7-day operation. Relocating the specific volume of lube oil equivalent to a 7-day supply to licensee control will allow licensees to adjust the required volume without submitting a license amendment request to the NRC.
The Technical Specifications provide a limited Completion Time to continue to operate with available diesel fuel oil or lube oil inventory less than the 7-day supply, but greater than a 6-day supply. These circumstances may be caused by events such as full load operation required for an inadvertent start while at minimum required level, or feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
This restriction allows sufficient time to obtain the requisite replacement volume and to perform the analyses required prior to addition of the fuel oil to the tank. The calculation of the volume equivalent to a 6-day supply is performed in the same manner as the calculation of the 7-day
Enclosure to ULNRC-0675 1 Page 6 of 9 supply. Relocating the specific volume in the Technical Specifications with the condition that a 6-day supply is available, along with placing the numerical value in the Bases is acceptable for the same reasons provided above for relocating the 7-day limit.
5.0 REGULATORY ANALYSIS
5.1 No Significant Hazards Consideration Analysis Ameren Missouri has evaluated the proposed changes to the Callaway Plant Technical Specifications using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
The proposed changes revise the affected Technical Specifications by removing the current stored diesel fuel oil and lubricating (lube) oil numerical volume requirements from the Technical Specifications and replacing them with equivalent diesel generator operating time requirements. The numerical values will be placed in the (TS) Bases so that they may be modified under licensee control. The current stored diesel fuel oil and lube oil numerical volume requirements are based on a 7-day supply. The Technical Specifications are modified so that the stored diesel fuel oil inventory will require that a 7-day supply be available for each diesel generator.
Ameren Missouri has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, Issuance ofamendment, as discussed below:
1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change relocates the volume ofdiesel fuel oil and lube oil required to support 7-day operation ofthe onsite diesel generators, as well as the volume equivalent to a 6-day supply, to licensee control. The specific volumes of fuel oil equivalent to a 7-and 6-day supply are calculated using the NRC approved methodology described in Regulatory Guide 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators and ANSI N195-1976, Fuel Oil Systems for Standby Diesel Generators. The specific volumes of lube oil equivalent to a 7-and 6-day supply are based on the DG manufacturers consumption values for the run time of the DG. Because the requirement to maintain a 7-day supply of diesel fuel oil and lube oil is not changed and is consistent with the assumptions in the accident analyses, and since the actions required to be taken when the volume of fuel oil and lube oil are less than a 6-day supply have not changed, neither the probability nor the consequences of any accident previously evaluated will be affected.
Enclosure to ULNRC-06751 Page 7 of 9 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed change create the possibility ofa new or different kind of accident from any previously evaluated?
Response: No The change does not involve a physical alteration ofthe plant (i.e., no new or different type ofequipment will be installed) or a change in the methods governing normal plant operation. The change does not alter assumptions made in the safety analysis but ensures that the diesel generator operates as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.
3.
Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change relocates the volume ofdiesel fuel oil and lube oil required to support 7-day operation ofthe onsite diesel generators, as well as the volume equivalent to a 6-day supply, to licensee control. As the bases for the existing limits on diesel fuel oil and lube oil are not changed, no change is made to the accident analysis assumptions and no margin ofsafety is reduced as part ofthis change.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Ameren Missouri concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
5.2 Applicable Regulatory Requirements I Criteria General Design Criterion (GDC) 1 7, Electric Power Systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to Title 10 ofthe Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability.
Enclosure to ULNRC-0675 1 Page 8 of 9 Regulatory Guide 1.1 37, Revision 1, Fuel Oil Systems for Standby Diesel Generators dated October 1979, describes a method acceptable to the NRC stafffor complying with the Commissions regulations regarding diesel fuel oil systems for standby diesel generators and assurance ofadequate diesel fuel oil quality. Regulatory Guide 1.137 states that Appendix B to ANSI N195-1976 should be used as a basis for a program to ensure the initial and continuing quality ofdiesel fuel oil as supplemented by eight additional provisions described in the Regulatory Guide for maintaining the properties and quality ofdiesel fuel oil.
ANSI N195-1976, Fuel Oil Systems for Standby Diesel Generators, requires that onsite fuel oil storage shall be sufficient to operate the minimum number ofdiesel generators following the limiting design basis accident for either seven (7) days, or the time required to replenish the oil from sources outside the plant site following any limiting design basis event without interrupting the operation ofthe diesel, whichever is longer. The ANSI standard also provides guidance for calculating storage requirements.
The proposed change does not affect the design ofthe onsite electric power system, the quality ofthe onsite electric power system, or the method ofdetermining the necessary quantity of onsite diesel fuel oil or lube oil.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety ofthe public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval ofthe proposed change will not be inimical to the common defense and security or to the health and safety ofthe public.
6.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in I 0 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
Enclosure to ULNRC-0675 1 Page 9 of 9
7.0 REFERENCES
1.
Regulatory Guide 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators, dated October 1979 2.
ANSI N 195-1976, Fuel Oil Systems for Standby Diesel Generators 3.
NRC Information Notice 2006-22, New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance, October 12, 2006 4.
NRC letter from Anthony J. Mendiola, Chief-Licensing Process Branch, to Technical Specification task Force (TSTF), Identification and Resolution of Issues Regarding Plant Specific Adoption of Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control, dated April 3, 2014.