ML23347A121
| ML23347A121 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/11/2024 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Callaway Energy Center |
| Chawla M | |
| References | |
| EPID L-2023-LLA-0046 | |
| Download: ML23347A121 (1) | |
Text
January 11, 2024 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077
SUBJECT:
CALLAWAY PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 236 TO ADOPT TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE VOLUME VALUES TO LICENSEE CONTROL (EPID L-2023-LLA-0046)
Dear Mr. Diya:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 236 to Renewed Facility Operating License No. NPF-30 for the Callaway Plant, Unit No. 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated March 29, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23088A118).
The amendment revises 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 Technical Specifications Task Force (TSTF) Standard TS traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control, dated February 20, 2009 (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 associated changes to the TS Bases.
F. Diya A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosures:
- 1. Amendment No. 236 to NPF-30
- 2. Safety Evaluation cc: Listserv
UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 236 License No. NPF-30
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Union Electric Company (UE, the licensee),
dated March 29, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions 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.
- 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-30 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. 236 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This amendment is effective as of its date of issuance, and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-30 and the Technical Specifications Date of Issuance: January 11, 2024 Jennivine K.
Rankin Digitally signed by Jennivine K. Rankin Date: 2024.01.11 17:22:32 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 236 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 Replace the following pages of Renewed Facility Operating License No. NPF-30 and 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.
Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.8-22 3.8-22 3.8-24 3.8-24
Renewed License No. NPF-30 Amendment No. 236 (3)
UE, 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)
UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)
UE, 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 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 UE is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100% power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan*
The Technical Specifications contained in Appendix A, as revised through Amendment No. 236 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Environmental Qualification (Section 3.11, SSER #3)**
Deleted per Amendment No. 169.
Amendments 133, 134, & 135 were effective as of April 30, 2000 however these amendments were implemented on April 1, 2000.
The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
CALLAWAY PLANT 3.8-22 Amendment No. 236 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 -----------------------------------------------------------
NOTE -----------------------------------------------------------
Separate Condition entry is allowed for each DG.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more DGs with fuel level less than a 7 day supply and greater than a 6 day supply in storage tank.
A.1 Restore fuel oil level to within limits.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> B.
One or more DGs with lube oil inventory less than a 7 day supply and greater than a 6 day supply.
B.1 Restore lube oil inventory to within limits.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> C.
One or more DGs with stored fuel oil total particulates not within limit.
C.1 Restore fuel oil total particulates within limit.
7 days D.
One or more DGs with new fuel oil properties not within limits.
D.1 Restore stored fuel oil properties to within limits.
30 days (continued)
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 CALLAWAY PLANT 3.8-24 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains a 7 day supply of fuel.
In accordance with the 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 tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
In accordance with the Diesel Fuel Oil Testing Program SR 3.8.3.4 Verify pressure in two starting air receivers is 435 psig or pressure in one starting air receiver is 610 psig, for each DG starting air subsystem.
In accordance with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.3.6 Not used.
Amendment No. 236
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 236 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By application dated March 29, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23088A118), Union Electric Company, doing business as Ameren Missouri (the licensee) requested changes to the technical specifications (TS) for Callaway Plant, Unit No. 1 (Callaway).
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 Technical Specifications 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 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 Regulations (10 CFR) Section 50.59, Changes, tests, and experiments, and, therefore, would 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 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.
The Callaway standby AC power system is powered by two diesel generators (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 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 based on the fuel consumption by one DG for operation at a continuous rating 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 the storage tank to the day tank by transfer pumps associated with each day 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, described in the license amendment request (LAR), would revise conditions and SRs in TS 3.8.3 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 Callaway.
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 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 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 and SR 3.8.3.2 Currently, SR 3.8.3.1 requires the licensee to verify that fuel oil storage tanks contain a volume greater than or equal to 80,900 gallons of fuel oil. SR 3.8.3.2 requires the licensee to verify that the lube oil inventory volume is greater than or equal to 750 gallons for each DG. 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 7-day supply. 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.
2.2.3 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 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. The licensee shall make changes to the Callaway TS Bases in accordance with TS 5.5.14, Technical Specifications (TS) Bases Control Program.
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 relating 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.
2.3.2 Guidance Regulatory Guide (RG) 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, 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 Westinghouse 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, 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 stated in the cover letter of the LAR that [t]his request is consistent with TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control.
3.1 NRC Staff Evaluation of Proposed Changes to TS 3.8.3 Actions Table Conditions A and B 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 Callaway in a shutdown condition and to bring in replenishment fuel oil from offsite sources.
The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated diesel generator under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each DG has a lube oil inventory 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.
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 requirements from the TSs and would modify Conditions A and B to replace them with duration-based DG operating time requirements, such that Condition A is entered when the stored diesel 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. No other parts of Condition A or B are proposed to be modified.
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.
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 calculated 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 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 and 3.8.3.2 Currently, SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil numerical volume requirements are met.
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 lube oil for each DG, 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 lube oil inventory are each greater than or equal to a 7-day supply for a DG.
In the enclosure to the LAR, the licensee described how the volumes of fuel oil and lube oil necessary to support operation of the standby DGs are calculated: Specifically, the licensee states:
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.
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 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 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 DG 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 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.
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 5.5.13, 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.
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 and 3.8.3.2 are acceptable.
3.3 Implementation Requirement to Revise the Final Safety Analysis Report (FSAR)
To ensure an acceptable and consistent fuel oil calculation methodology is maintained, the licensee provided a commitment in its March 29, 2023, letter to revise the Callaway FSAR with the following information (or equivalent) and to submit the revised description with the next FSAR update:
The specific diesel generator (DG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary for meeting DG run-duration requirements are calculated using Section 5.4 of American National Standards Institute (ANSI)
N195-1976, Fuel Oil Systems for Standby Diesel-Generators, and are based on applying the conservative assumption that the DG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators, Regulatory Position C.1.c.
The NRC staff finds that licensee control of the fuel oil calculation methodology in the FSAR will continue to adequately ensure public health and safety, as any deviation from the calculation methodology described above requires the licensee to perform an evaluation pursuant to the provisions of 10 CFR 50.59 to determine whether the change requires prior NRC approval. The NRC staff did not rely upon this regulatory commitment in its approval of the proposed changes.
3.4 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 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 and 3.8.3.2 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 Commissions regulations, the Missouri State official was notified of the proposed issuance of the amendment on December 11, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in Federal Register on June 13, 2023 (88 FR 38552), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be
conducted in compliance with the 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: January 11, 2024
- concurrence by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC*
NAME MChawla PBlechman SMehta DATE 12/13/2023 12/13/2023 11/30/2023 OFFICE OGC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME RSiegman JRankin MChawla DATE 1/5/2023 1/10/2024 01/11/2024