NG-14-0291, License Amendment Request (TSCR-1 51) 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

License Amendment Request (TSCR-1 51) 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

ML15029A600
Person / Time
Site:	Duane Arnold
Issue date:	01/26/2015
From:	Vehec T NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-14-0291, TSTF-501, Rev. 1
Download: ML15029A600 (20)

Text

NEXTera ENERGY.ý/.

January 26, 2015 NG-14-0291 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 License Amendment Request (TSCR-1 51) 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"

Reference:

NRC Letter, "Identification and Resolution of Issues Regarding Plant-Specific Adoption of Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"' dated April 3, 2014 (ML14084A512)

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) is submitting a request for an amendment to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

The proposed amendment would 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 proposed amendment would revise the TS to require a 7-day supply of stored diesel fuel oil and lube oil inventory be available for each diesel generator.

The proposed changes are consistent with NRC-approved Revision 1 of TSTF-501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." The availability of the TS improvement was announced in the FederalRegister on May 26, 2010 [75 FR 29588] as part of the consolidated line item improvement process (CLIIP).

Attachment 1 provides a description and assessment of the proposed change.

Attachment 2 provides the existing TS pages marked up to show the proposed change.

Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked to show the proposed change. Changes to the existing TS Bases, N glDa NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA52324 ý-1 *c

Document Control Desk NG-14-0291 Page 2 of 2 consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. They are provided in Attachment 4 for information only. Attachment 5 provides a new Regulatory Commitment made in this submittal in accordance with Reference 1. There are no revisions to existing Regulatory Commitments.

NextEra Energy Duane Arnold requests approval of the proposed license amendment by December 1, 2015, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Iowa official.

The Duane Arnold Energy Center Onsite Review Group has reviewed the proposed license amendment request.

If you have any questions or require additional information, please contact J. Michael Davis at 319-851-7032.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 26, 2015.

T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosures cc: Regional Administrator, USNRC, Region III, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

ATTACHMENT I NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-151)

ADOPTION OF TSTF-501, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" EVALUATION OF PROPOSED CHANGES

2.0 PROPOSED CHANGE

S

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA

7.0 REFERENCES

4 pages follow

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 are modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for a diesel generator. This change is consistent with NRC-approved Technical Specifications 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." The availability of this TS improvement was announced in the Federal Registeron 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 are modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for a 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 Basis, 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 relocates 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 a diesel generator.

Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-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.

The SR 3.8.3.1 Bases in TSTF Traveler-501, Revision 1, references ANSI N195. At Duane Arnold Energy Center, the current reference is ANSI N195. This application does not propose to modify the current ANSI N195 reference.

NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) is not proposing variations or deviations from the TS changes described in TSTF-501, Revision 1, or the NRC Page 1 of 4

staff's model safety evaluation (SE) published in the FederalRegisteron May 26, 2010 [75 FR 29588] as part of the CLIIP Notice of Availability. NextEra Energy Duane Arnold is proposing the following difference with TSTF-501, Revision 1:

Reference 7.1 provided resolution of issues regarding plant-specific adoption of TSTF-501, Revision 1. NextEra Energy Duane Arnold is providing a Regulatory Commitment in Enclosure 5 to ensure an acceptable and consistent fuel oil calculation methodology is maintained to satisfy the NRC staff's position in Reference 7.1. The NRC staff model SE should be revised as discussed in Reference 7.1.

3.0 BACKGROUND

The background for this application is addressed by the model safety evaluation referenced in the NRC's Notice of Availability published on May 26, 2010 [75 FR 29588] and TSTF-501, Revision 1.

4.0 TECHNICAL ANALYSIS

NextEra Energy Duane Arnold has reviewed the model SE published in the FederalRegister on May 26, 2010 [75 FR 29588] as part of the CLIIP Notice of Availability. NextEra Energy Duane Arnold has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Duane Arnold Energy Center and therefore justify this amendment for the incorporation of the proposed changes to the Duane Arnold Energy Center TS.

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION NextEra Energy Duane Arnold 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. 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 a diesel generator.

Basis for proposed no significant hazards determination: As required by 10 CFR 50.91 (a), the NextEra Energy Duane Arnold 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 7-day operation of an 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-day and Page 2 of 4

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 of lube oil equivalent to a 7-day and 6-day supply is based on the diesel generator manufacturer's 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 is less than a 6-day 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 (i.e., 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 volume of diesel fuel oil and lube oil required to support 7-day operation of an 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. 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 FederalRegister Notice of Availability on May 26, 2010 [75 FR 29588]. NextEra Energy Duane Arnold has reviewed the NRC staff's model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to Duane Arnold Energy Center.

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 Page 3 of 4

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) result in 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 needs be prepared in connection with the proposed change.

7.0 REFERENCES

7.1 NRC Letter, "Identification and Resolution of Issues Regarding Plant-Specific Adoption of Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to.Licensee Control,"' dated April 3, 2014 (ML14084A512)-. -

Page 4 of 4

ATTACHMENT 2 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-151)

ADOPTION OF TSTF-501, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKUP COPY) 2 pages follow

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 ---------------------------

For Conditions B, E, and F, separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil level 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 /> 36,3,- 7 , l .within limits.

• -v.*1,,2* Win less than a 7 day supply and storage tank. greater than a 6 day supply B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory - 2 inventory to within gal and,>-. 221" ,-limits.

l C. Stored fuel oil total C.1 Restore fuel oil total 30 days particulates not within particulates to within limit. limits.

(continued)

DAEC 3.8-14 Amendment 224

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil storage tank contains In accordance with 36,3_4 o uel. the Surveillance Frequency Control a 7 day supply I - Program SR 3.8.3.2 Verify lube oil inventory is- for each DG. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel In accordance with oil are tested in accordance with, and the Diesel Fuel Oil maintained within the limits of, the Diesel Fuel Testing Program Oil Testing Program.

SR 3.8.3.4 Verify required air start receiver pressure is > In accordance with 150 psig. the Surveillance Frequency Control Program SR 3.8.3.5 Check for the presence of water in the fuel oil in In accordance with the fuel oil storage tank and remove water as the Surveillance necessary. Frequency Control Program DAEC 3.8-16 Amendment 2-W

ATTACHMENT 3 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-151)

ADOPTION OF TSTF-501, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" REVISED TECHNICAL SPECIFICATION PAGES 2 pages follow

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 ----------------------------

For Conditions B, E, and F, separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil level less 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 /> than a 7 day supply within limits.

and greater than a 6 day supply.

B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory less inventory to within than a 7 day supply limits.

and greater than a 6 day supply.

C. Stored fuel oil total C.1 Restore fuel oil total 30 days particulates not within particulates to within limit, limits.

(continued)

DAEC 3.8-14 Amendment

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil storage tank contains In accordance with a 7 day supply of fuel. the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory is a 7 day supply for In accordance with each DG. the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel In accordance with oil are tested in accordance with, and the Diesel Fuel Oil maintained within the limits of, the Diesel Fuel Testing Program Oil Testing Program.

SR 3.8.3.4 Verify required air start receiver pressure is _> In accordance with 150 psig. the Surveillance Frequency Control Program SR 3.8.3.5 Check for the presence of water in the fuel oil in In accordance with the fuel oil storage tank and remove water as the Surveillance necessary. Frequency Control Program DAEC 3.8-16 Amendment

ATTACHMENT 4 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-151)

ADOPTION OF TSTF-501, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARKUP COPY)

FOR INFORMATION ONLY 5 pages follow

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air land Regulatory Guide 1.137 (Ref. 2)

BASES/

BACKGROUND The Diesel Generators (DG are provided with a storage tank having a fuel oil capacity sfficient to operate a DG for a period of 7 days while a DG is su lying maximum post Loss of Coolant Accident (LOCA) Ioad emand discussed in UFSAR, Section 9.5.4 (Ref. 1). The maximum load demand is calculated using the assumption that only one DG is 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.

Fuel oil is transferred from storage tank to the day tanks by either of two transfer pumps. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe or valve, to result in the loss of more than one DG. The outside tanks, pumps, and piping are located underground.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. 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 (or Saybolt Universal Viscosity), specific gravity (or API gravity),

and total particulate contamination.

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 diesel engine working surfaces and to remove excess heat generated by friction during operation. The DG Lube Oil System is designed to provide automatic lube oil makeup to the DG crankcase for a minimum of 7 days of operation per UFSAR Section 8.3.1 (Ref. 7). This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Each DG has two independent starting air supply systems each with adequate capacity for five successive normal start attempts per air receiver without recharging. A minimum of fifteen normal DG starts are provided for each DG per UFSAR (continued)

DAEC B 3.8-32 TSCR-86 151-

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES (continued)

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 Abnormal Operational Transient or a postulated DBA. Because stored diesel fuel oil, lube oil, and 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 DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG for Conditions B, E, and F. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) governed by separate Condition entry and application of associated Required Actions.

IThe fuel oil level equivalent to a 6 day supply is 31,238 gallons.

A. 1 In this Condition I >With the fulel oil level 'I 4nteGe~g ak h 7 day fuel oil supply for a is not available. However, the Condition is restricted t uel oil level reductions that maintain at least a 6 day supply. Fhese circumstances may be caused by events such as:

a. Full load operation required for an inadvertent start while at minimum required level; or

b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the 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 DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will (continued)

DAEC B 3.8-34 Ame.nd-ment 223 1 TSCR-151 ]

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS A.1 (continued) be initiated to obtain replenishment, and the low probability of an event during this brief period.

B.1 i.e.,

In this Condition, > iVf4lube oil inventory <-257 gsu9c,, _fficient lube oil inyente~y to 1 the 7 day support 7 days of continuous DG operation at full load conditions fafy not be available. However, the Condition is restricted to lube oil level reductions that maintain at least a 6 day suppl This restriction allows sufficient time for obtaining the reqL 'ite 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 con ered sufficient to complete restoration of the required volume ior to declaring the DG inoperable. This period is acceptabl ased on the remaining capacity (> 6 days), the low ra 'of usage, the fact that procedures will be initiated to obtain r enishment, and the low probability of an event during this b f period.

IThe lube oil inventory equivalent to a 6 day supply is 221 gallons.

C.1 This Condition is entered as a result of a failure to meet the acceptance criterion for particulates. 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, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a period prior to declaring both DGs inoperable. The 30 day Completion Time starts when initial analysis results are known and allows for further evaluation, resampling, and re-analysis of the DG fuel oil.

(continued)

DAEC B 3.8-35 TSCR-@8O[ 1-51

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS F.1 (continued) With a Required Action and associated Completion Time not met, or the stored diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 Insert 1 REQUIREMENTS This SR provides verl ication that there is an adequate inventory of fuel oil in the sto ge tank to support a single DG's operation for 7 days at full load. he 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.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

Ilube oil inventory equivalent to a 7 day supply is 257 gallons and SR 3.8.3.2 This Surveillance ensure hat sufficient lubricating oil inventory is available to support east 7 days of full load operation for each DG. The 257 gallon requirement for each "DGis based on the DG manufacturer's consumption values for the run time of the DG.

Implicit in this SR is the requirement to verify the capability to transfer the lube oil from the lube oil makeup tank to the DG. The requirement is considered to be fulfilled by observing that the DG lube oil sump level is maintained in the normal band by the lube oil sump level controller.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. A Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the plant staff.

(continued)

DAEC B 3.8-37 TSC R4-- 15-1

INSERT I The fuel oil level equivalent to a 7 day supply is 36,317 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.

ATTACHMENT 5 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-151)

ADOPTION OF TSTF-501, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL"

SUMMARY

OF REGULATORY COMMITMENT NextEra Energy Duane Arnold is providing a regulatory commitment to revise the Duane Arnold Energy Center Updated Final Safety Analysis Report with the following information.

Regulatory Commitment Due Date/Event The specific Emergency Diesel Generator (EDG) fuel oil volume To be submitted contained in the diesel fuel oil storage tank necessary to ensure with the next that EDG run-duration requirements are calculated using Section UFSAR update 5.4 of American National Standards Institute (ANSI) N195-1976, following receipt of "Fuel Oil Systems for Standby Diesel-Generators," and is based Technical on applying the conservative assumption that the EDG is Specification operated continuously at rated capacity. This fuel oil calculation amendment 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.