L-24-247, Davis-Nesse Nuclear Power Station, Unit 1 - License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control
| ML25058A170 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/26/2025 |
| From: | Tony Brown Vistra Operations Company |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-24-247 | |
| Download: ML25058A170 (1) | |
Text
Davis-Besse Nuclear Power Station Terry J. Brown Site Vice President 5501 N. State Route 2 Oak Harbor, Ohio 43449 10 CFR 50.90 L-24-247 February 26, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Davis-Besse Nuclear Power Station, Unit No.1 Docket No. 50-346, License No. NPF-3 LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Vistra Operations Company LLC is submitting a request for an amendment to the Technical Specifications (TS) for Davis-Besse Nuclear Power Station, Unit No.1.
The proposed changes revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS is modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator. Condition A and Condition B in the Action table are revised and Surveillance Requirements (SR) 3.8.3.1 and 3.8.3.2 are revised to reflect the above change. In addition, the reference to Appendix B of ANSI N195-1976, Fuel Oil Systems for Standby Diesel-Generators, in the TS Bases is deleted.
Additionally, Vistra Operations Company LLC is proposing a similar change to TS 3.8.1, AC Sources -
Operating, to remove the specific numerical value for the fuel oil volume and replace it with the time requirement of greater than or equal to 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply of fuel oil in each day tank.
Regarding stored diesel fuel oil and lube oil, no changes to the current plant configuration, current numerical volume requirements, current 7-day, or 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> day tank basis are proposed in this application; the proposal merely swaps the current numerical volume requirements from the TS to the TS Bases and swaps the associated current 7-day and 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> basis from the TS Bases to the TS. In addition, no changes to any SR Frequency, Required Actions, or Completion Times are proposed in this application.
6555 SIERRA DRIVE IRVI NG, TEXAS 75039 o 214-812-4600 V ISTRACORP.COM
L-24-247 Evaluation of the Proposed Change Page 1 of 5
Subject:
License Amendment Request to Adopt TSTF-501
1.0 DESCRIPTION
2.0 PROPOSED CHANGE
S
3.0 BACKGROUND
4.0 TECHNICAL ANALYSIS
5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Determination 5.2 Applicable Regulatory Requirements/Criteria
6.0 ENVIRONMENTAL CONSIDERATION
7.0 REFERENCES
L-24-247 Page 2 of 5
1.0 DESCRIPTION
The proposed changes revise Technical Specification (TS) 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS is modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator. This change is consistent with NRC-approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications (STS) Change Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control. This change is consistent with a change approved by the NRC in reference 3.
Minor differences between the proposed plant-specific TS changes, and the changes proposed by TSTF-501 are listed in Section 2.0. The availability of this TS improvement was announced in the Federal Register on May 26, 2010 (75 FR 29588) as part of the consolidated line item improvement process (CLIIP).
2.0 PROPOSED CHANGE
S The proposed changes revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS is modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator. As a result:
Condition A and Condition B in the Action table are revised. Currently, Condition A and Condition B are entered when the stored diesel fuel oil and lube oil numerical volume requirements are not met.
As discussed in the current TS Bases, the numerical volume requirements in Condition A and Condition B are based on volumes less than a 7-day supply, but greater than a 6-day supply. The revision relocates the volumetric requirements from the TS and places it in the TS Bases. The TS are modified so that Condition A and Condition B are entered when the stored diesel fuel oil and lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more diesel generators.
Surveillance Requirements (SR) 3.8.3.1 and 3.8.3.2 are revised. Currently, SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. As discussed in the current TS Bases, the numerical volume requirements in SR 3.8.3.1 and SR 3.8.3.2 are based on maintaining at least a 7-day supply. The revision removes the volumetric requirements from the TS and places it in the TS Bases. The TS are modified so that SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil inventory is greater than or equal to a 7-day supply for each diesel generator.
The reference to Appendix B of ANSI N195-1976 in the TS Bases is deleted. As a result, the only reference will be to ANSI N195-1976.
Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF Traveler-501, Revision 1, is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.
Vistra Operations Company LLC (Vistra OpCo) is proposing variations or deviations from the TS changes described in TSTF-501, Revision 1, or the NRC staffs model safety evaluation (SE) published in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLIIP Notice of Availability. The following are the proposed changes:
L-24-247 Page 3 of 5 This application also proposes a revision to TS 3.8.1, AC Sources-Operating, following a similar approach to the TS 3.8.3 change discussed above. The proposed revision to SR 3.8.1.4 replaces the specific numerical volume requirement with the requirement to maintain greater than or equal to a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply of fuel oil in each day tank.
The specific numerical volume needed to support this requirement is placed in the TS Bases. Similar to the technical justification provided in the model SE as part of the CLIIP, this proposed change is acceptable since it merely swaps the current numerical volume requirement from the TS to the TS Bases and swaps the greater than or equal to a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply requirement from the TS Bases to the TS. This change is consistent with a similar change approved by the NRC in Reference 3.
3.0 BACKGROUND
The background for this application is addressed by the model safety evaluation referenced in the NRCs Notice of Availability published on May 26, 2010 (75 FR 29588) and TSTF-501, Revision 1. Additional information is provided in NRC Letter to Technical Specifications Task Force, 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, April 3, 2014 [ADAMS Accession No. ML14084A512].
4.0 TECHNICAL ANALYSIS
Vistra OpCo has reviewed the model SE published in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLIIP Notice of Availability and the NRC letter to TSTF on April 3, 2014 [ADAMS Accession No. ML14084A512]. Vistra OpCo has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Davis-Besse Nuclear Power Station Unit No. 1 (DBNPS) and therefore justify this amendment for the incorporation of the proposed changes to the DBNPS TS.
5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Vistra OpCo has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
Description of Amendment Request: The proposed changes revise TS by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the TS to the TS Bases so that it 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 and a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply in the day tank. The TS are modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator and a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply available in each day tank.
Basis for proposed no significant hazards determination: As required by 10 CFR 50.91(a), Vistra OpCo analysis of the issue of no significant hazards consideration is presented 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 of diesel fuel oil and lube oil required to support a 7-day operation of each onsite diesel generator, and the volume equivalent to a 6-day supply, to licensee control.
The specific volume of fuel oil equivalent to a 7 and 6-day supply is 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 volume L-24-247 Page 4 of 5 of lube oil equivalent to a 7-day and 6-day supply is based on the diesel generator manufacturers consumption values for the run time of the diesel generator. 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 the actions 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.
The proposed change also replaces the specific numerical volume to maintain a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply of fuel oil in each day tank. The specific numerical volume needed to support this requirement is placed in the TS Bases.
The specific volume and time are not changed and is consistent with the existing plant design basis to support the diesel generator under accident loading conditions. Because the requirement to maintain a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply of diesel fuel oil is not changed and is consistent with the assumptions in the accident analyses, and the actions taken when the volume of fuel oil are less than a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply have not changed, neither the probability nor the consequences of any accident previously evaluated will be affected.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The change does not involve a physical alteration of the plant (that is, no new or different type of equipment 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 of accident 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 numerical volume of diesel fuel oil and lube oil required to support 7-day operation of each onsite diesel generator, and 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 of safety is reduced as part of this change.
The proposed change also replaces the specific numerical volume to maintain a 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> supply of fuel oil in each day tank and replaces them with the time requirements. As the bases for the existing limits on diesel fuel oil are not changed, no change is made to the accident analysis assumptions and no margin of safety is reduced as part of this change.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
5.2 APPLICABLE REGULATORY REQUIREMENTS /CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on May 26, 2010 (75 FR 29588). Vistra OpCo has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to DBNPS.
L-24-247 Page 5 of 5
6.0 ENVIRONMENTAL CONSIDERATION
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 10 CFR Part 20, and 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 effluent 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.
7.0 REFERENCES
- 1. Federal Register, Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control, published on May 26, 2010, 75 FR 2958.
- 2. NRC Letter to Technical Specifications Task Force, 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, April 3, 2014 [ADAMS Accession No. ML14084A512].
- 3. Beaver Valley Power Station, Unit Nos. 1 and 2 - Issuance of License Amendment Regarding the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control, March 16, 2023 [ADAMS Accession No. ML23019A003].
L-24-247 Markup of Proposed TS and TS Bases Pages (13 pages follow)
AC Sources - Operating 3.8.1 Davis-Besse 3.8.1-6 Amendment 301 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.3
NOTES-----------------------------
1.
EDG 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 EDG 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 3.8.1.8.
Verify each EDG is synchronized and loaded and operates for 60 minutes at a load 2340 kW and 2600 kW.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.4 Verify each day tank contains 4000 gal20 hours of supply.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each day tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.6 Verify interval between each sequenced load block is within +/- 10% of design interval for each emergency load sequencer and each emergency time delay relay.
In accordance with the Surveillance Frequency Control Program
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 Davis-Besse 3.8.3-1 Amendment 279 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 emergency diesel generator (EDG).
APPLICABILITY:
When associated EDG is required to be OPERABLE.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each EDG.
REQUIRED ACTION COMPLETION TIME A. One or more EDGs with fuel level < 32,000 gal and > 26,800 gal 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 EDGs with lube oil inventory
< 260 gal and > 236 gal.
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 EDGs with stored fuel oil total particulates not within limit.
C.1 Restore fuel oil total particulates to within limits.
7 days D. One or more EDGs with new fuel oil properties not within limits.
D.1 Restore stored fuel oil properties to within limits.
30 days E. One or more EDGs with required starting air receiver pressure
< 210 psig and 139 psig.
E.1 Restore starting air receiver pressure to 210 psig.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> greater than a 6 day supply CONDITION less than a 7 day supply greater than a 6 day supply less than a 7 day supply
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 Davis-Besse 3.8.3-2 Amendment 301 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F.
Required Action and associated Completion Time of Condition A, B, C, D, or E not met.
OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.
F.1 Declare associated EDG inoperable.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains 32,000 gal of fuel.
In accordance with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory for each EDG is 260 gal.
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 a 7 day supply of fuel a 7 day supply of lube oil
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 Davis-Besse 3.8.3-3 Amendment 301 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.3.4 Verify each required EDG air start receiver pressure is 210 psig.
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 No Changes on this Page - included for context
AC Sources - Operating B 3.8.1 Davis-Besse B 3.8.1-15 Revision 32 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.8.1.3 Consistent with Regulatory Guide 1.9 (Ref. 3), this Surveillance verifies that the EDGs are capable of synchronizing with the offsite electrical system and accepting loads 90% to 100% of the continuous rating of the EDG. A run time of 60 minutes ensures the engine temperatures are stabilized, while minimizing the time that the EDG is connected to the offsite source.
Although no power factor requirements are established by this SR, the EDG is normally operated at a lagging power factor between 0.8 and 0.95. The 0.8 value is the design rating of the machine, while the 0.95 is an administrative limitation. The load band is provided to avoid routine overloading of the EDG. Routine overloading may result in more frequent teardown inspections being required in order to maintain EDG reliability.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients because of changing bus loads do not invalidate this test. Note 3 indicates that this Surveillance should be conducted on only one EDG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful EDG start must precede this test to credit satisfactory performance.
SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank is greater than or equal to 4000 gallons.within the required limit. The level is expressed as an equivalent volume in gallons, and ensures adequate fuel oil for approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of EDG operation at full load. This volume is also credited (in conjunction with the minimum required level in the associated storage tank) to support 7 days of EDG operation at full load.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-1 Revision 32 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES BACKGROUND Each emergency diesel generator (EDG) is provided with storage tanks having a fuel oil capacity sufficient to operate that diesel for a period of 7 days while the EDG is supplying maximum post loss of coolant accident load demand discussed in the UFSAR, Section 8.3.1 (Ref. 1). The maximum load demand is calculated using the assumption that at least two EDGs are available. This onsite fuel oil capacity is sufficient to operate the EDGs for longer than the time to replenish the onsite supply from outside sources.
Fuel oil is transferred from the storage tank to the day tank by a submersed transfer pump inside each storage tank. Each storage tank is installed above grade elevation.
For proper operation of the standby EDGs, it is necessary to ensure the proper quality of the fuel oil. While Davis-Besse is not committed to this Regulatory Guide, Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3).
The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level.
The EDG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated EDG 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 engine oil sump normally contains an 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.
Each EDG has an air start system with two air start receivers per subsystem, and each air start receiver has adequate capacity for five successive start attempts on the EDG without recharging the air start receiver.
APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the UFSAR, Section 6 (Ref. 4) and Section 15 (Ref. 5),
ANALYSES assume Engineered Safety Features (ESF) systems are OPERABLE.
The EDGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.
and Regulatory Guide 1.137 (Ref. 2).
The onsite storage in addition to the engine oil sump is sufficient to ensure 7 days of continuous operation.
INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-2 Revision 32 BASES APPLICABLE SAFETY ANALYSES (continued)
Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full load operation. It is also required to meet specific standards for quality.
Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full load for 7 days. This requirement, in conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of EDGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. EDG day tank fuel requirements, as well as transfer capability from the storage tank to the day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown."
The starting air subsystem is required to have a minimum capacity for five successive EDG start attempts without recharging the air start receivers.
Thus, only one of the two air start receivers for each EDG is required to be OPERABLE.
APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated EDG is required to be OPERABLE.
ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each EDG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable EDG subsystem. Complying with the Required Actions for one inoperable EDG subsystem may allow for continued operation, and subsequent inoperable EDG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.
A.1 In this Condition, the 7 day fuel oil supply for an EDG is not available.
However, the Condition is restricted to fuel oil level reductions, that maintain at least a 6 day supply. These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations which may The fuel oil level equivalent to a 6 day supply is 26,800 gallons INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-3 Revision 32 BASES ACTIONS A.1 (continued) be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the EDG inoperable. This period is acceptable based on the remaining capacity ( 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.
B.1 With lube oil inventory < 260 gal, sufficient lube oil to support 7 days of continuous EDG operation at full load conditions may not be available.
However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. This restriction allows sufficient time to obtain the requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the EDG inoperable. This period is acceptable based on the remaining capacity ( 6 days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.
C.1 This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.3. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),
contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated EDG inoperable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the EDG fuel oil.
In this Condition, the 7 day lube oil inventory, i.e.,
The lube oil inventory equivalent to a 6 day supply is 236 gallons.
is INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-4 Revision 32 BASES ACTIONS (continued)
D.1 If the test results for the new fuel oil properties defined in the Bases for SR 3.8.3.3 that are not required to be obtained prior to addition of the new fuel oil to the storage tanks are not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.
Even if an EDG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the EDG would still be capable of performing its intended function.
E.1 With starting air receiver pressure < 210 psig in the required air start receiver, sufficient capacity for five successive EDG start attempts does not exist. However, as long as the receiver pressure is 139 psig, there is adequate capacity for at least one start attempt, and the EDG can be considered OPERABLE while the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the EDG inoperable.
This period is acceptable based on the remaining air start capacity, the fact that most EDG starts are accomplished on the first attempt, and the low probability of an event during this brief period.
F.1 With a Required Action and associated Completion Time not met, or one or more EDGs with fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated EDG may be incapable of performing its intended function and must be immediately declared inoperable.
SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each EDG's operation for 7 days at full load. Credit for the minimum required level in the associated day tank (4000 gallons per SR 3.8.1.4) is being taken to support the 7 days of EDG operation. The 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.
Insert 'A' INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-5 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.8.3.1 (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of full load operation for each EDG. The 260 gal requirement is based on the EDG manufacturer consumption values for the run time of the EDG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the EDG, when the EDG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer recommended minimum level.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:
a.
Sample the new fuel oil in accordance with ASTM D4057-95 (Ref. 6);
b.
Verify in accordance with the tests specified in ASTM D975-06 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 0.825 and 0.876 or an API gravity at 60°F of 30° and 40° when tested in accordance with ASTM D1298-85 (Ref. 6), a kinematic viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a flash point of 125°F; and The lube oil inventory equivalent to a 7 day supply is 260 gallons and INFORMATION ONLY
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-6 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.8.3.3 (continued) c.
Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176-86 or a water and sediment content within limits when tested in accordance with the test specified in ASTM D975-06 (Ref. 6).
Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.
Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-06 (Ref. 7) are met for new fuel oil when tested in accordance with ASTM D975-06 (Ref. 6), except that the analysis for sulfur may be performed in accordance with ASTM D4294-90 (Ref. 6).
The 31 day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on EDG operation. This Surveillance ensures the availability of high quality fuel oil for the EDGs.
Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.
Particulate concentrations should be determined in accordance with ASTM D2276-88 (Ref. 6). The total particulate concentration in the fuel oil has a limit of 10 mg/l.
The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.
SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each EDG is available. The system design requirements for each air start receiver provide for a minimum of five engine start cycles without recharging. The pressure specified in this SR is intended to reflect the lowest value at which the five starts can be accomplished using only one of the two air start receivers for each EDG.
No Changes on this Page - included for context
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Davis-Besse B 3.8.3-7 Revision 32 BASES SURVEILLANCE REQUIREMENTS SR 3.8.3.4 (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.8.3.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during EDG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance.
REFERENCES 1.
UFSAR, Section 8.3.1.
2.
3.
ANSI N195-1976, Appendix B.
4.
UFSAR, Section 6.
5.
UFSAR, Section 15.
6.
ASTM Standards: D4057-95; D975-06; D1298-85; D4176-86; D4294-90; D2276-88.
7.
ASTM Standards, D975-06, Table 1.
INFORMATION ONLY
The fuel oil level equivalent to a 7 day supply is 32,000 gallons when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, and the corresponding fuel consumption rate, the onsite fuel storage volume required for 7 days of operation can be determined. SR 3.8.3.3 requires new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumption calculations.
Insert 'A'
L-24-247 Proposed TS pages (Re-typed)
(3 pages follow)
AC Sources - Operating 3.8.1 Davis-Besse 3.8.1-6 Amendment SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.3
NOTES-----------------------------
- 1. EDG 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 EDG 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 3.8.1.8.
Verify each EDG is synchronized and loaded and operates for 60 minutes at a load 2340 kW and 2600 kW.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.4 Verify each day tank contains 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of fuel oil.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each day tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.6 Verify interval between each sequenced load block is within +/- 10% of design interval for each emergency load sequencer and each emergency time delay relay.
In accordance with the Surveillance Frequency Control Program
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 Davis-Besse 3.8.3-1 Amendment 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 emergency diesel generator (EDG).
APPLICABILITY:
When associated EDG is required to be OPERABLE.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each EDG.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more EDGs 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 EDGs 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 EDGs with stored fuel oil total particulates not within limit.
C.1 Restore fuel oil total particulates to within limits.
7 days D. One or more EDGs with new fuel oil properties not within limits.
D.1 Restore stored fuel oil properties to within limits.
30 days
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 Davis-Besse 3.8.3-3 Amendment 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 lube oil inventory is a 7 day supply for each EDG.
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