ML23293A057
| ML23293A057 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 12/06/2023 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Jim Barstow Tennessee Valley Authority |
| Green K | |
| References | |
| EPID L-2023-LLA-0097 | |
| Download: ML23293A057 (27) | |
Text
December 6, 2023
Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801
SUBJECT:
WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 163 AND 70 REGARDING ADOPTION OF TSTF-501-A, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL (EPID L-2023-LLA-0097)
Dear Mr. Barstow:
The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 163 to Facility Operating License No. NPF-90 and Amendment No. 70 to Facility Operating License No. NPF-96 for the Watts Bar Nuclear Plant, Units 1 and 2, respectively. These amendments are in response to your application dated June 28, 2023.
The amendments revise Watts Bar Nuclear Plant, Units 1 and 2, Technical Specification (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 lubricating 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. The amendments also revise TS 3.8.1, AC Sources - Operating, SR 3.8.1.4 to replace the specific day tank numerical volume requirements with a duration-based diesel operating time requirement.
J. Barstow
A copy of our related safety evaluation is also enclosed. Notice of issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos. 50-390 and 50-391
Enclosures:
- 1. Amendment No. 163 to NPF-90
- 2. Amendment No. 70 to NPF-96
- 3. Safety Evaluation
cc: Listserv TENNESSEE VALLEY AUTHORITY
DOCKET NO. 50-390
WATTS BAR NUCLEAR PLANT, UNIT 1
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No. 163 License No. NPF-90
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated June 28, 2023, 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.
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 Facility Operating License No. NPF-90 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications contained in Appendix A as revised through Amendment No. 163 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Operating License and Technical Specifications
Date of Issuance: December 6, 2023
ATTACHMENT TO AMENDMENT NO. 163
WATTS BAR NUCLEAR PLANT, UNIT 1
FACILITY OPERATING LICENSE NO. NPF-90
DOCKET NO. 50-390
Replace page 3 of Facility Operating License No. NPF-90 with the attached revised page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Replace the following pages of the Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.
Remove Pages Insert Pages
3.8-7 3.8-7 3.8-21 3.8-21 3.8-22 3.8-22 3.8-23 3.8-23
- 3 -
(4) TVA, 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, instrument calibration, or other activity associated with radioactive apparatus or components; and
(5) TVA, 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 license shall be deemed to contain and is subject to the conditions specified in the Commissions 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
TVA is authorized to operate the facility at reactor core power levels not in excess of 3459 megawatts thermal.
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications conta ined in Appendix A as revised through Amendment No. 163 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) Safety Parameter Display System (SPDS) (Section 18.2 of SER Supplements 5 and 15)
Prior to startup following the first refueling outage, TVA shall accomplish the necessary activities, provide acceptable responses, and implement all proposed corrective actions related to having the Watts Bar Unit 1 SPDS operational.
(4) Vehicle Bomb Control Program (Section 13.6.9 of SSER 20 )
During the period of the exemption granted in paragraph 2.D.(3) of this license, in implementing the power ascension phase of the approved initial test program, TVA shall not exceed 50% power until th e requirements of 10 CFR 73.55(c)(7) and (8) are fully implemented. TVA shall submit a letter under oath or affirmation when the require ments of 73.55(c)(7) and (8) have been fully implemented.
Facility License No. NPF-90 Amendment No. 163 AC Sources-Operating 3.8.1
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.8.1.3 ---------------------------------NOTES----------------------------
- 1. DG loadings may include gradual loading as recommended by the manufacturer.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one DG at a time.
- 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
Verify each DG is synchronized and loaded and As specified in operates for t 60 minutes at a load t 3960 kW and Table 3.8.1-1 d 4400 kW.
SR 3.8.1.4 Verify each skid mounted day tank contains t a one In accordance with hour supply of fuel oil. the Surveillance Frequency Control Program
SR 3.8.1.5 Check for and remove accumulated water from each In accordance with skid mounted day tank. the Surveillance Frequency Control Program
SR 3.8.1.6 Verify the fuel oil transfer system operates to In accordance with automatically transfer fuel oil from 7 day storage tank the Surveillance to the skid mounted day tank. Frequency Control Program
(continued)
Watts Bar-Unit 1 3.8-7 Amendment 132,
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 fuelA.1 Restore fuel oil level to within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> level less than a 7 day limits.
supply and greater than a 6 day supply in storage tank.
B. One or more DGs with lubeB.1 Restore lube oil inventory to 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 within limits.
day supply and greater than a 6 day supply.
C. One or more DGs withC.1 Restore fuel oil total 7 days stored fuel oil total particulates within limit.
particulates not within limit.
(continued)
Watts Bar-Unit 1 3.8-21 Amendment
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
D. One or more DGs with newD.1 Restore stored fuel oil 30 days fuel oil properties not within properties to within limits.
limits.
E. One or more DGs withE.1 Restore starting air receiver 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> starting air receiver pressure to t 190 psig.
pressure < 190 psig and t 170 psig.
F. Required Action andF.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
One or more DGs 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 t a 7 day In accordance with supply of fuel. the Surveillance Frequency Control Program
(continued)
Watts Bar-Unit 1 3.8-22 Amendment 132,
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.8.3.2 Verify lubricating oil inventory is t 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 with tested in accordance with, and maintained within the the Diesel Fuel Oil limits of, the Diesel Fuel Oil Testing Program. Testing Program
SR 3.8.3.4 Verify each DG air start receiver pressure is In accordance with t 190 psig. the Surveillance Frequency Control Program
SR 3.8.3.5 Check for and remove accumulated water from each In accordance with of the four interconnected tanks which constitute the 7 the Surveillance day fuel oil storage tank. Frequency Control Program
SR 3.8.3.6 Perform a visual inspection for leaks in the exposed In accordance with fuel oil system piping while the DG is running. the Surveillance Frequency Control Program
SR 3.8.3.7 For each of the four interconnected tanks which In accordance with constitute the 7 day fuel oil storage tank: the Surveillance Frequency Control
- a. Drain the fuel oil; Program
- b. Remove the sediment; and
- c. Clean the tank.
Watts Bar-Unit 1 3.8-23 Amendment 132,
TENNESSEE VALLEY AUTHORITY
DOCKET NO. 50-391
WATTS BAR NUCLEAR PLANT, UNIT 2
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No. 70 License No. NPF-96
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated June 28, 2023, 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.
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 Facility Operating License No. NPF-96 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications contained in Appendix A as revised through Amendment No. 70 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Operating License and Technical Specifications
Date of Issuance: December 6, 2023
ATTACHMENT TO AMENDMENT NO. 70
WATTS BAR NUCLEAR PLANT, UNIT 2
FACILITY OPERATING LICENSE NO. NPF-96
DOCKET NO. 50-391
Replace page 3 of Facility Operating License No. NPF-96 with the attached revised page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Replace the following pages of the Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.
Remove Pages Insert Pages
3.8-6 3.8-6 3.8-18 3.8-18 3.8-19 3.8-19
C. The license shall be deemed to contain and is subject to the conditions specified in the Commissions 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
TVA is authorized to operate the facility at reactor core power levels not in excess of 3459 megawatts thermal.
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications contained in Appendix A as revised through Amendment No. 70 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) TVA shall implement permanent modifications to prevent overtopping of the embankments of the Fort Loudon Dam due to the Probable Maximum Flood by June 30, 2018.
(4) FULL SPECTRUM LOCA Methodology shall be implemented when the WBN Unit 2 steam generators are replaced with steam generators equivalent to the existing steam generators at WBN Unit 1.
(5) By December 31, 2019, the licensee shall report to the NRC that the actions to resolve the issues identified in Bulletin 2012-01, Design Vulnerability in Electrical Power System, have been implemented.
(6) The licensee shall maintain in effect the provisions of the physical security plan, security personnel training and qualification plan, and safeguards contingency plan, and all amendments made pursuant to the authority of 10 CFR 50.90 and 50.54(p).
(7) TVA shall fully implement and maintain in effect all provisions of the Commission approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
The TVA approved CSP was discussed in NUREG-0847, Supplement 28, as amended by changes approved in License Amendment No. 7.
(8) TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as described in NUREG-0847, Supplement 29, subject to the following provision:
Unit 2 Facility Operating License No. NPF-96 Amendment No. 70 AC Sources - Operating 3.8.1
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.8.1.4 Verify each skid mounted day tank contains t a one In accordance with hour supply of fuel oil. the Surveillance Frequency Control Program
SR 3.8.1.5 Check for and remove accumulated water from each skid mounted day tank. In accordance with the Surveillance Frequency Control Program
SR 3.8.1.6 Verify the fuel oil transfer system operates to In accordance with automatically transfer fuel oil from 7 day storage tank the Surveillance to the skid mounted day tank. Frequency Control Program
SR 3.8.1.7 Verify each DG starts from standby condition and In accordance with achieves in d 10 seconds, voltage t 6800 V, and the Surveillance frequency t 58.8 Hz. Verify after DG fast start from Frequency Control standby conditions that the DG achieves steady state Program voltage t 6800 V and d 7260 V, and frequency t 59.8 Hz and d 60.1 Hz.
(continued)
Watts Bar - Unit 2 3.8-6 Amendment 36,
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 level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> level less than a 7 day within limits.
supply and greater than a 6 day supply 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 a 6 day supply.
C. One or more DGs with C.1 Restore fuel oil total 7 days stored fuel oil total particulates within limit.
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.
(continued)
Watts Bar - Unit 2 3.8-18 Amendment
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 < 190 psig and t 190 psig.
t 170 psig.
F. Required Action and F.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
One or more DGs 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 t a 7 day In accordance with supply of fuel. the Surveillance Frequency Control Program
SR 3.8.3.2 Verify lubricating oil inventory is t 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 with tested in accordance with, and maintained within the the Diesel Fuel Oil limits of, the Diesel Fuel Oil Testing Program. Testing Program
(continued)
Watts Bar - Unit 2 3.8-19 Amendment 36,
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NOS. 163 AND 70
TO FACILITY OPERATING LICENSE NOS. NPF-90 AND NPF-96
TENNESSEE VALLEY AUTHORITY
WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2
DOCKET NOS. 50-390 AND 50-391
1.0 INTRODUCTION
By application dated June 28, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23179A086), Tennessee Valley Authority (TVA, the licensee),
requested changes to the technical specifications (TS) for Watts Bar Nuclear Plant (Watts Bar),
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 lubricating 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
[alternating current] Sources - Operating, SR 3.8.1.4 (verification of each diesel generator (DG) skid-mounted day tank fuel oil volumes) 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 volu me requirements for stored diesel fuel oil and lube oil to be modified under licensee control pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests, and experiments, and, therefore, would
Enclosure 3
not require a license amendment pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit.
2.0 REGULATORY EVALUATION
2.1 System Description
The standby 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.
The Watts Bar standby AC power system is powered by four DGs capable of an automatic start at any time and capable of continued operation at rated load, voltage, and frequency until manually stopped. The DGs supply power to four pow er trains that are shared between the two units. Each DG is provided with four interconnected storage tanks embedded in the building foundation having a fuel oil capacity sufficient to operate that diesel for a period of 7 days while the DG is supplying maximum post loss-of-coolant-accident load demand. The maximum load demand is calculated assuming that a minimum of any two DGs are available. 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 7-day storage tanks to the skid-mounted day tank by a pump located on each skid-mounted day tank. Each DG incorporates two diesel engines operating in tandem and directly coupled to the generator.
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, described 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 Sources - Operating, by removing the current stored diesel fuel oil volume and lube oil inventory numerical requirements and replaci ng 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 licens ee 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 Watts Bar.
Though Units 1 and 2 have separate TS volumes, the proposed changes are identical for each.
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 is based on volumes of less than a 7-day supply, but greater than a 6-day supply. 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 a 6-day supply. The proposed amendments 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, and SR 3.8.1.4
Currently, SR 3.8.3.1 requires the licensee to verify that fuel oil storage tanks contain a volume greater than or equal to 56,754 gallons of fuel oil. SR 3.8.3.2 requires the licensee to verify that the lubricating oil inventory volume is greater than or equal to 287 gallons for each DG.
SR 3.8.1.4 requires the licensee to verify that each DGs skid-mounted day tank contains a volume of greater than or equal to 218.5 gallons of fuel oil. The proposed amendments 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 7-day supply. For SR 3.8.3.2, it would require verifica tion that the lubricating oil inventory is greater than or equal to a 7-day supply. SR 3.8.1.4 would be revised to require the licensee verify that each skid-mounted day tank contains a minimum 1-hour supply of fuel oil.
2.2.3 Licensee-Identified Variations from TSTF-501
In the LAR, the licensee proposed variations from TSTF-501, Revision 1, as described below:
Variation 1: The LAR includes a proposed change to remove the fuel oil volume requirement for the skid-mounted day tanks in SR 3.8.1.4 and replace it with a durational requirement.
Variation 2: The licensee indicated in the LAR that a regulatory commitment was not needed because the Watts Bar dual-unit Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, has been revised to identify the NRC-approved calculation methodology of Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators, Revision 1.
Variation 3: Editorial changes were proposed to make the text consistent with that in Westinghouse standard TS.
o TS 3.8.3 Condition B: The term diesel engines would be abbreviated as DG.
o SR 3.8.3.1: The phrase Verify each 7 day fuel oil storage tank would be changed to Verify each fuel oil storage tank.
o SR 3.8.3.2: In addition to the TSTF-501 change, the phrase per engine would be deleted from Verify lubricating oil inventory is 287 gal per engine.
2.2.4 Proposed Changes to TS Bases
Consistent with 10 CFR 50.36(a)(1), the licensee submitted corresponding changes to the TS Bases that provide the reasons for the proposed TS changes. The proposed changes to the applicable TS Bases sections are shown in Attachment 2 to the LAR. The Watts Bar TSs contain a TS Bases Change Program, TS 5.6, Technical Specification (TS) Bases Control Program, that allows the licensee to make changes to the Watts Bar TS Bases under appropriate administrative controls and reviews.
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.
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 technical specifications.
2.3.2 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 American National Standards Institute (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 standard TS. Though the TSTF-501 traveler was developed based on changes to Revision 3 of NUREG-1431, Standard Technical Specifications for West inghouse Plants, the NRC staffs review of this LAR includes consideration of whether the proposed changes are consistent with the latest revision.
NUREG-1431, Revision 5, (ML21259A155), prov ides example TS LCOs and acceptable remedial actions that meet the requirements in 10 CFR 50.36(c)(2)(i) for a standard plant design.
In a letter to the TSTF dated April 3, 2014 (ML14084A512), the NRC staff addressed concerns with TSTF-501 that TS requirements would be moved to and effectively made requirements in the TS bases. As stated above in 10 CFR 50.36(a)(1), the TS Bases shall not become part of the TSs. To remedy the concerns, the staff requested in the letter that licensees submit a regulatory commitment, with their TSTF-501 LARs, that the diesel fuel oil calculation methodology will be added to their UFSARs.
3.0 TECHNICAL EVALUATION
The licensee assessed the model safety evaluation (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 the Enclosure to the LAR, that the justifications presented in the model SE are applicable to Watts Bar Units 1 and 2, and therefore justify these amendments.
Each DG is provided with a fuel oil capacity sufficient to operate that DG for a period of 7 days.
This onsite fuel oil capacity is sufficient to operate the DG long enough to place Watts Bar 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 SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 and TS 3.8.3 action statements by removing the current stored diesel fuel oil and lubricating 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 lubricating oil volumes necessary to support a duration-based DG operating time to be modified under licensee control pursuant to 10 CFR 50.59, Changes, tests and experiments. 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
Currently, Condition A of TS 3.8.3 is entered when the fuel oil volume requirement is not met and Condition B is entered when the lube oil inventory requirement is not met. The current TS Bases state that the numerical volume requirements in Conditions A and B are based on volumes less than a 7-day supply, but greater than a 6-day supply. The proposed changes would remove the numerical volumetric r equirements from the TSs and would modify Conditions A and B to replace them with duration-based diesel operating time requirements, such that Condition A is entered when the stored fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply, and Condition B is entered when the lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more DGs..
As described in Section 3.2 below, the licensee stated in the LAR that the stored diesel fuel oil and lube oil numerical volumes sufficient to meet the duration-based operating time requirements will be calculated using ANSI N195-1976, and the volumes are based on DG manufacturers consumption values for the run-time of the DGs. The use of this methodology
will ensure that the supplies of stored diesel fuel oil and lube oil for each DG that dictate condition entry will continue to be calculat ed in accordance with NRC-approved methods.
Based on the above evaluation, the NRC staff concludes that the changes to the TS 3.8.3 Actions table are acceptable.
3.2 NRC Staff Evaluation of Proposed Changes to SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4
Currently, SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lubricating oil numerical volume requirements, respectively, are met. SR 3.8.1.4 requires the licensee to verify that each skid-mounted day tank contains the required volume of diesel fuel oil.
The licensee proposed to revise SR 3.8.3.1 and SR 3.8.3.2 to reflect the change from numerical volume requirements to durational requirements made in the TS 3.8.3 Actions table.
Specifically, SRs 3.8.3.1 and 3.8.3.2 would be revised to require availability of a 7-day supply of fuel oil and lubricating oil for each DG, respecti vely, rather than a specified numerical volume.
As a result, SR 3.8.3.1 and SR 3.8.3.2 would require the licensee to verify that the combined volume of the fuel oil storage tanks and the lubricating oil inventory are each greater than or equal to a 7-day supply for a DG.
The licensee also proposed to revise SR 3.8.1.4, which contains the DG day tank volumetric requirement. The proposed change to SR 3.8.1.4 is similar to the proposed change for SR 3.8.3.1 in that the numerical volume requirements would be replaced with durational requirements. The revised SR 3.8.1.4 would require the licensee to verify that the stored diesel fuel oil volume in each day tank is greater than or equal to a one-hour supply of fuel oil. The licensees proposed inclusion of changes to the day tank storage requirements in the LAR is identified as Variation 1 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 takes into account 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 suppl ements 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 below 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. Both calculation methods shall include an explicit allowance for fuel consumption required by periodic testing. This includes the fuel required for operation of the engine at the minimum loads specified by the engine manufacturer. Since both methods described in ANSI N195-1976 are approved for use in RG 1.137, Revision 1, and the licensee calculates the volume of fuel oil in accordance with RG 1.137, Revision 1, the NRC staff has reasonable assurance that the volume of fuel oil
calculated by the licensee will meet the dur ation-based limits proposed in SR 3.8.3.1 and SR 3.8.1.4.
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 5.7.2.16, 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 suppl y, as well as the 6-day supply associated with TS 3.8.3 Condition B, is based on the DG manufactu rer 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 skid-mounted day tank supply 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.
Accordingly, the NRC staff finds that the above methods used by the licensee still provide reasonable assurance that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met, consistent with 10 CFR 50.36(C)(3). Therefore, the changes to SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 are acceptable.
3.3 Evaluation of Regulatory Commitment Variation
The 2014 NRC letter to the TSTF resolved license amendment issues discovered after the approval of TSTF-501. Following this, as licensees applied to adopt TSTF-501, the LARs would include a regulatory commitment to add a statement to the UFSAR. The statement would be added to the UFSAR to ensure an acceptable and consistent fuel oil calculation methodology is maintained. TVA did not include a regulatory commitment in its LAR, which is identified as Variation 2 in Section 2.2.3 of this SE. The licensee stated that the regulatory commitment is not necessary because the Watts Bar dual-unit UFSAR already contains the fuel oil calculation methodology. Section 4.0 of the Enclosure to the LAR states, in part, [t]he WBN UFSAR, Section 9.5, states that the methods described in Regulatory Guide 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators, Regulatory Position C.1.c, and ANSI N195-1976, Fuel Oil Systems for Standby Diesel-Generators, Section 5.4, are used to calculate required fuel oil volumes. Based on the licensees statement, the NRC staff determined a regulatory commitment is not needed.
3.4 Other Technical Specification Changes
The licensee proposed editorial changes to make the TS 3.8.3 text consistent with that in Westinghouse standard TS, which is identified as Variation 3 in Section 2.2.3 of this SE. The NRC staff reviewed the proposed changes and found them acceptable because they are non-technical in nature, simplify the requirements, and align the text in the Watts Bar TSs with that in NUREG-1431.
3.5 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 the 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 replac ement 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, and 3.8.1.4 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 Commissions regulations, the Tennessee State official was notified of the proposed issuance of the amendment on October 16, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change an inspection or a surveillance requirement. 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 previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on August 8, 2023 (88 FR 53541), and there has been no public comment on such find ing. 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 Commissions 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 Contributor: K. West, NRR
Date: December 6, 2023
ML23293A057 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DSS/STSB/BC(A)
NAME KGreen RButler (ABaxter for) RElliott DATE 10/20/23 11/03/23 10/13/23 OFFICE NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME DWrona KGreen DATE 12/06/23 12/06/23