NRC 2011-0040, License Amendment Request 264, Supplement 1, Diesel Fuel Oil Storage Requirements

License Amendment Request 264, Supplement 1, Diesel Fuel Oil Storage Requirements

ML111240285
Person / Time
Site:	Point Beach
Issue date:	05/03/2011
From:	Meyer L Point Beach
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC 2011-0040
Download: ML111240285 (31)

Text

BEACH May 3,201 1 NRC 2011-0040 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets No. 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27

References:

( 1 NextEra Energy Point Beach, LLC letter to NRC, dated January 27,2010, License Amendment Request 264, Diesel Fuel Oil Storage Requirements (MLI 00280230)

License Amendment Request 264, Sun~lement1 Diesel Fuel Oil Storaqe Requirements NextEra Energy Point Beach, LLC (NextEra) submitted License Amendment Request (LAR) 264 (Reference 1) to the NRC, pursuant to 10 CFR 50.90, to amend Facility Operating Licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively. The proposed amendment revises Technical Specification (TS), 3.8.3, Diesel Fuel Oil and Starting Air, to specify increased minimum required volume of diesel fuel oil stored in the emergency diesel generator (EDG) fuel oil storage tanks to assure that there is sufficient fuel oil to support six days of full-load operation for a single EDG. The revised requirements also incorporate instrument indicator loop uncertainty and account for unusable volume within the tank.

In response to a teleconference with the NRC, NextEra determined additional enhancements to the proposed TS 3.8.3 were desired to better align PBNP fuel oil storage requirements to current industry standards. Although not part of the current PBNP license basis, the proposed supplement assures a sufficient supply of stored diesel fuel for six days of fully loaded operation for a single EDG. provides a description of the proposed TS changes. Attachment 1 to Enclosure 1 provides a mark-up version of the proposed TS changes. Attachment 2 to Enclosure 1 provides a clean version of the proposed TS. Attachment 3 to Enclosure 1 provides a mark-up version of the proposed TS Bases mark-up. The TS Bases are being provided for information only.

NextEra is not requesting approval of the TS Bases.

Additionally, Enclosure 2 provides Calculation 2006-0035, Revision 1B, Parametric Values, which determined the required volume of diesel fuel oil stored in the fuel oil storage tanks, including instrument uncertainty, which assures sufficient fuel oil to support six days of full-load operation for a single EDG.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 The PBNP Plant Operations Review Committee has reviewed the proposed license amendment request.

In accordance with 10 CFR 50.91, a copy of this application with enclosures is being provided to the designated Wisconsin Official.

This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.

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

Executed on May 3,201 1.

Very truly yours, NextEra Energy Point Beach, LLC Enclosures cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE I NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 264, SUPPLEMENT I DIESEL FUEL OIL STORAGE REQUIREMENTS DESCRIPTION AND EVALUATION OF CHANGES 1.O

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Proposed Changes

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirementslcriteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

6.0 REFERENCES

ATTACHMENTS:

1. Proposed Technical Specification Changes (Mark-up)

2. Proposed Technical Specification Changes (Clean)

3. Proposed Technical Specification Bases Changes (For Information Only) 7 pages follow

1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Facility Operating Licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively. The proposed changes would revise Technical Specification (TS) 3.8.3, Diesel Fuel Oil and Starting Air. The proposed changes increase the minimum required volume of diesel fuel oil stored in the emergency diesel generator (EDG) fuel oil storage tanks to assure that there is sufficient fuel oil to support six days of fully loaded operation a single EDG. The revised requirements also incorporate instrument indicator loop uncertainty and reflect usable volume within the tank.

2.0 DETAILED DECRlPTlON Although not currently part of the PBNP license basis, this supplement proposes changes to Limiting Condition of Operation (LCO) 3.8.3, Condition A, which assure a sufficient supply of stored diesel fuel for six days of fully loaded operation of a single EDG. This enhancement will more closely align PBNP diesel fuel oil storage requirements with industry standards. The Required Actions are revised to assure that the minimum amount of diesel fuel is available to support Condition A.

Surveillance Requirement (SR) 3.8.3.1 is revised to address the required surveillance for the proposed changes.

The proposed changes will be implemented within 60 days following Commission approval.

2.1 Proposed Chanqes

1. Condition A Replace:

"One or more standby emergency power sources with < 11,000 gal in storage tank."

With:

"One or more standby emergency power sources with fuel level < 86.2% and

> 71.3% in storage tank."

Basis for the change: Consistent with NUREG-1431 (Reference I), the proposed change includes the requirement to maintain a fuel level which a sufficient usable supply of stored diesel fuel for six days of full-load operation of a single EDG. However, in this Condition, a six-day fuel oil supply for a diesel generator is not available, but the Condition is restricted to fuel oil reductions that maintain at least a five-day supply.

These circumstances may be caused by events, such as full-load operation caused by an inadvertent start while at the minimum required fuel level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other fuel quality degradations. Plant operators determine diesel fuel volume based on the fuel oil storage tank level indicators, which show percent of span. The proposed change to replace the volume in gallons to indicated fuel oil storage tank level would allow operators to use available instrumentation to readily verify fuel oil storage tank level is within the TS limit.

Page 1 of 7

2. Required Action A.l Replace:

"Declare associated standby emergency power source(s) inoperable."

With:

"Restore fuel oil level to within limits."

Basis for the change: Consistent with NUREG-1431 (Reference I), the proposed change allows sufficient time for obtaining the required replacement volume and performing the analyses required prior to addition of the fuel oil to the tank.

3. Required Action A.l Completion Time Replace:

"Immediately" With:

"48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />" Basis for the chanae: Consistent with NUREG-1431 (Reference I), the proposed Completion Time allows sufficient time to complete restoration of the required fuel oil volume prior to declaring the associated standby emergency power source(s) inoperable. The remaining volume will allow a single EDG at least five days of operation, if necessary.

4. Condition E Replace:

"Required Action and associated Completion Time of Condition B or C not met.

One or more standby emergency power sources' diesel fuel oil not within limits for reasons other than Condition B or C."

With:

"Required Action and associated Completion Time not met.

One or more standby emergency power sources' diesel fuel oil not within limits for reasons other than Condition A, B or C."

Basis for the chanqe: Consistent with NUREG-1431 (Reference I), the proposed change includes Condition A, which will declare the associated associated standby emergency power source(s) inoperable if sufficient volume for six days of fully loaded operation cannot be restored.

Page 2 of 7

Replace" "Verify each fuel oil storage tank contains r 11,000 gal of fuel."

With:

"Verify each fuel oil storage tank contains r 86.2% of fuel."

Basis for the chanae: The proposed change includes the requirement to maintain a fuel level corresponding to a sufficient usable supply of stored diesel fuel for one EDG for six days of full-load operation. Plant operators determine diesel fuel volume based on the fuel oil storage tank level indicators, which show percent of span. The proposed change to replace the volume in gallons to indicated fuel oil storage tank level would allow operators to use available instrumentation to readily verify fuel oil storage tank level is within the TS limit. The Frequency of 31 days is not changed.

3.0 TECHNICAL EVALUATION

The standby power supply for PBNP Units 1 and 2 consists of four shared EDGs divided into two trains, Train " A and Train "B." The two Train A EDGs, G-01 and G-02, are normally aligned as standby emergency power sources to Unit Iand Unit 2 4160 V buses 1A-05 and 2A-05, respectively. The Train B EDGs, G-03 and G-04, are normally aligned as standby emergency power to Unit 1 and Unit 2, 4160 V buses 1A-06 and 2A-06, respectively. Both EDGs in each train can be cross-connected to provide power to alternate buses if one EDG is out of service.

There are two underground fuel oil storage tanks (FOSTs). Each FOST has a capacity of approximately 35,000 gallons. Fuel can be transferred from one underground FOST to the other via a transfer pump, and manual cross-connect valves. The manual cross-connect valves are normally maintained in the closed position. The EDGs are described in PBNP Final Safety Analysis Report (FSAR) Section 8.8. The EDG fuel oil storage and transfer system is described in PBNP FSAR Section 8.8.3.

PBNP FSAR Section 8.8.1 states sufficient fuel oil is maintained by each train to provide for a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> run of one EDG at rated design load. This requirement is expressed as the current minimum FOST level limits. The basis of these tank level limits is to provide sufficient fuel for operation with the most limiting time dependent load profile over a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The current minimum TS required volume of r 11,000 gallons in each FOST only provides sufficient fuel for one EDG to operate for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Existing LC0 3.8.3 Condition A requires that FOST contain > 11,000 gallons when an associated standby emergency power source is required to be OPERABLE. Existing SR 3.8.3.1 requires that each fuel oil storage tank be verified every 31 days to contain >11,000 gallons of diesel fuel oil. This requirement is based on continuous operation of the associated EDG at rated load.

The NRC conducted a component design basis inspection of PBNP Units 1 and 2 during 2008 (Reference 2). During this inspection, it was identified that current TS LC0 3.8.3 Condition A FOST volume requirements accounted for one EDG to start following receipt of an undervoltage signal to start, load to the associated bus, and to operate at rated load for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Page 3 of 7

An Unresolved Issue (URI) was documented in Reference (2) that the PBNP EDG fuel oil calculation did not consider the most limiting condition of operation of two EDGs being required to start and operate for a maximum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This issue was subsequently closed in 2009 (Reference 3) to a green non-cited violation.

In response to the URI, the required diesel fuel volumes have been re-calculated for the two FOSTs. Required diesel fuel volumes have been calculated for six days of operation of a single EDG at the 2,000-hour rated load. The required amount of diesel fuel is calculated in gallons and percent, and an allowance for instrument uncertainty is added to determine the required tank level limit. Existing LC0 3.8.3 fuel oil storage requirements did not incorporate instrument indicator loop uncertainty values to account for unusable volume. This calculation was performed in accordance with ANSIIANS 59.51, Fuel Oil Systems for Emergency Diesel Generators.

The proposed changes to TS 3.8.3 increases the required fuel oil storage from > 11,000 gallons to 2 86.2% indicated level (approximately 32,100 usable gallons). For operation of one EDG, approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operating margin exists above the proposed required supply of stored diesel fuel. This operating margin allows for monthly surveillance runs of the EDGs without dropping below the proposed required fuel oil storage volume. The FOSTs will need to be replenished approximately every 1.5 months to accommodate monthly surveillance testing. In the event that two EDGs start, operating margin of approximately five hours exists above the proposed required supply of stored diesel fuel.

Existing LC0 3.8.3, Condition A, contains a single value for the required fuel oil volume such that sufficient fuel oil is maintained by each train to provide for a 48-hour run of one EDG at rated design load. The proposed change to Condition A, consistent with NUREG-1431 (Reference I), adds a band of values which allows operation below the required usable volume for six days of fully loaded operation for a single EDG, given a usable five-day supply (2 71.3% indicated level, or approximately 27,150 usable gallons) is maintained, and the six-day usable volume can be recovered within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The proposed change to Condition A requires SR 3.8.3.1 to be revised accordingly. The frequency of 31 days remains unchanged.

4.0 REGULATORY EVALUATION

4.1 A~plicableResulatorv Reauirementslcriteria PBNP was designed and constructed to comply with the intent of the draft AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967 (ML003674718). PBNP was licensed prior to the 1971 publication of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR 50. As such PBNP was not licensed to 10 CFR 50, Appendix A.

The origin of the PBNP GDCs relative to the Atomic Energy Commission proposed GDC is discussed in FSAR Section 1.3.

Page 4 of 7

PBNP GDC 4, GDC 19 and GDC 39, are comparable to Appendix A GDC 5, Sharing of Structures, Systems and Components, GDC 17, Electric Power Systems, and GDC 20, Protection System Functions, respectively. Therefore, the applicable regulatory requirements are:

49 PBNP GDC 4, Sharing of Systems, states, "Reactor facilities may share systems or components if it can be shown that such sharing will not result in undue risk to the health and safety of the public.

a PBNP GDC 19, Protection System Reliability, states, "Protection systems shaN be designed for high functional reliability and inservice testability necessary to avoid undue risk to the health and safety of the public."

o PBNP GDC 39, Emergency Power, states, 'Mn emergency power source shaN be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning of the engineered safety features and protection systems required to avoid undue risk to the health and safety of the public. This power source shall provide this capacity assuming a failure of a single active component. "

Regulatory Guide (RG) 1.I 37, Fuel-Oil Systems For Standby Diesel Generators (Reference 4),

endorsed ANSl N195-1976, Fuel Oil Systems for Standby Diesel Generators, as providing an acceptable method for complying with the pertinent requirements of GDC 17, subject to some clarifications and additional requirements, regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality. ANSIIANS 59.51, provides guidance for calculating storage requirements, and was used in the preparation of PBNP calculations to support this change. RG 1.I 37 and ANSl N195-1976 is an existing reference for TS Bases 3.8.3.

4.2 No Siqnificant Hazards Consideration Determination NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below.

1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

This proposed change increases the minimum required amount of stored diesel fuel in the associated common fuel oil storage tank. Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR) Section 8.8.1 currently states sufficient fuel oil is maintained by each train to provide for a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> run of one emergency diesel generator (EDG) at rated design load. The proposed change increases the required usable volume to an indicated tank level of 86.2%, a volume required to maintain a sufficient supply of stored diesel fuel for six days of full-load operation of one EDG. An increase in the minimum required fuel oil volume required in the fuel oil storage tanks does not increase the probability or consequences of an accident previously evaluated.

Page 5 of 7

Surveillance Requirement (SR) 3.8.3.1 is revised to reflect the increased amount of diesel fuel required to be maintained to support operation of the EDGs following recalculation of required values.

Following implementation of this proposed change, there will be no change in the ability of the EDGs to supply maximum post-accident load demands for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The proposed minimum volume of fuel ensures that a six day supply of fuel is available when the associated standby emergency power source is required to be operable.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The EDGs and the associated support systems, such as the fuel oil storage and transfer systems, are designed to mitigate accidents and are not accident initiators. Following this change, the EDGs will continue to supply the required maximum post-accident load demand. The proposed license amendment revises the current 48-hour fuel supply requirement to a six-day fuel supply requirement when the associated standby emergency power source is required to be operable. The new required fuel oil volumes are within the capacities of the fuel oil storage tanks.

Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

There are two underground fuel oil storage tanks on site. Each tank has a capacity of approximately 35,000 gallons and each common fuel oil tank supports one EDG train.

Fuel can be manually transferred from one tank to another via a cross-connect valve.

Sufficient fuel is maintained between the two tanks to allow one EDG to operate continuously at the required load for seven days. At the proposed minimum required level, which is 2 86.2% indicated level in the common fuel oil storage tank for two standby emergency power sources, one tank could provide enough fuel for one EDG in either Train A or Train B to continue operation for six days. Beyond the required supply of stored diesel fuel for six days of full-load operation of a single EDG, a reasonable operating margin of usable fuel oil remains in each Train's fuel oil storage tank.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NextEra concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 6 of 7

4.3 Conclusions In conclusion, based on the considerations discussed above, ( I ) there is reasonable assurance that the health and safety of the public will not be endangered by operating in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulation, and (3) the issuances of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

The Plant Operations Review Committee has reviewed this proposed supplement and concurs with this conclusion.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(~)(9).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

(I) U.S. Nuclear Regulatory Commission, "Standard Technical Specifications Westinghouse Plants," NUREG-1431, Revision 3, June 2004 (ML041830612)

(2) NRC lnspection Reports 0500026612008009 and 0500030112008009 (DRS), dated September 8, 2008, Point Beach Nuclear Plant, Units Iand 2 Component Design Basis lnspection (CDBI) Report (ML082520769)

(3) NRC lnspection Reports 0500026612009003; 0500030112009003; dated August II, 2009, Point Beach Nuclear Plant, Units 1 and 2, NRC Integrated lnspection Report (ML092230751)

(4) U.S. Nuclear Regulatory Commission, "Fuel-Oil Systems For Standby Diesel Generators," Regulatory Guide 1.137, Revision I,October 1979 (ML003740180)

Page 7 of 7

ENCLOSURE I ATTACHMENT I NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 264, SUPPLEMENT I DIESEL FUEL OIL STORAGE REQUIREMENTS PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKUP COPY) 2 pages follow

Diesel Fuel Oil and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil and Starting Air L C 0 3.8.3 Stored diesel fuel oil shall be within limits and starting air subsystem shall be OPERABLE for each required standby emergency power source.

APPLICABILITY: When associated standby emergency power source is required to be OPERABLE.

ACTIONS

..................................................... NOTE-----------------------------------------------------

Separate Condition entry is allowed for each standby emergency power source.

CONDITION REQUIRED ACTION COMPLETIONTIME A. One or more standby A. I emergency power 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> sources with fuel level R

<- 86.2% and wqwabbRestore fuel

> 71.3% in storage tank. oil level to within limits.

B. One or more standby B. I Restore fuel oil total 7 days emergency power particulates within limit.

sources with stored fuel oil total particulates not within limit.

C. One or more standby C. 1 Restore stored fuel oil 30 days emergency power properties to within sources with new fuel oil limits.

properties not within limits.

(continued)

Point Beach Unit 1 - Amendment No. 281-Unit 2 - Amendment No.

Diesel Fuel Oil and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETIONTIME D. One or more standby D. 1 Declare associated Immediately emergency power standby emergency sources with inoperable power source(s) starting air system(s). inoperable.

E. Required Action and E. 1 Declare associated associated Completion standby emergency T i m e n f B~cr C power source(s) not met. inoperable.

One or more standby emergency power sources' diesel fuel oil not within limits for reasons other than Condition & B or C.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days 2 44&00+486.2Y0of fuel.

SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained with the Diesel within the limits of, the Diesel Fuel Oil Testing Fuel Oil Testing Program. Program SR 3.8.3.3 Verify each standby emergency power source air 31 days start bottle bank pressure is 2 165 psig.

(continued)

Point Beach 3.8.3-2 Unit 1 - Amendment No. 24.G Unit 2 - Amendment No. 206 I

ENCLOSURE I ATTACHMENT 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 264, SUPPLEMENT 'I DIESEL FUEL OIL STORAGE REQUIREMENTS PROPOSED TECHNICAL SPECIFICATION CHANGES (CLEAN COPY) 2 pages follow

Diesel Fuel Oil and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil-and Starting Air L C 0 3.8.3 Stored diesel fuel oil shall be within limits and starting air subsystem shall be OPERABLE for each required standby emergency power source.

APPLICABILITY: When associated standby emergency power source is required to be OPERABLE.

ACTIONS

..................................................... NOTE-----------------------------------------------------

Separate Condition entry is allowed for each standby emergency power source.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more standby 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 /> emergency power within limits.

sources with fuel level

< 86.2% and > 71.3% in storage tank.

B. One or more standby B.l Restore fuel oil total 7 days emergency power particulates within limit.

sources with stored fuel oil total particulates not within limit.

C. One or more standby C. I Restore stored fuel oil 30 days emergency power properties to within sources with new fuel oil limits.

properties not within limits.

(continued)

Point Beach Unit 1 - Amendment No.

Unit 2 - Amendment No.

Diesel Fuel Oil and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETIONTIME D. One or more standby D. 1 Declare associated immediately emergency power standby emergency sources with inoperable power source(s) starting air system(s). inoperable.

E. Required Action and E. 1 Declare associated Immediately associated Completion standby emergency Time not met. power source(s) inoperable.

One or more standby emergency power sources' diesel fuel oil not within limits for reasons other than Condition A, B or C.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains 2 86.2% 31 days I of fuel.

SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained with the Diesel within the limits of, the Diesel Fuel Oil Testing Fuel Oil Testing Program. Program SR 3.8.3.3 Verify each standby emergency power source air 31 days start bottle bank pressure is 2 165 psig.

I (continued)

Point Beach Unit I- Amendment No.

Unit 2 - Amendment No.

ENCLOSURE I ATTACHMENT 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 264, SUPPLEMENT I DIESEL FUEL OIL STORAGE REQUIREMENTS PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (FOR INFORMATION ONLY) 5 pages follow

Diesel Fuel Oil and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil and Starting Air BASES BACKGROUND There are two underground fuel oil storage tanks on site (T-175AlB).

Each tank has a capacity of approximately 35,000 gallons. Sufficient fuel is normally maintained between the two tanks to allow one diesel to operate continuously at the required load for 7 days (Ref. 1). At minimum required level, which is -86.2% indicated level in I each emergency diesel fuel oil storage tank, one tank could provide enough fuel for an emergency diesel generator to operate for w 4 4 h t s s i x davs. For operation of one EDG. approximatelv 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operatina marain exists above the proposed required supplv of stored diesel fuel. In the event that two EDGs start. operatina marain of approximatelv five hours exists above the Pro~osedrequired SUP~IV of stored diesel fuel.

The onsite fuel oil capacity is sufficient to operate the standby emergency power sources for longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from storage tank to day tank by either of two transfer pumps associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe, valve or tank to result in the loss of more than one train of standby emergency power sources. The Train A day tanks are normally split and the Train B day tanks are normally split, but can be cross-connected allowing either tank to supply either diesel generator in the same Train.

For proper operation of the standby emergency power sources, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.I37 (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.

Each standby emergency power source has an air start system capable of storing sufficient air to roll the associated diesel generator up to starting speed fast enough to complete its starting cycle and be up to final speed and voltage within 10 seconds from receipt of a start signal.

The air start system for each standby emergency power source consists of two separate and redundant starting air banks, each capable of five successive start attempts without recharging.

Point Beach B 3.8.3-1

Diesel Fuel Oil and Starting Air B 3.8.3 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY ANALYSES analyses in the FSAR, Chapter 14 (Ref. 4), assume Engineered Safety Feature (ESF) systems are OPERABLE. The standby emergency power sources 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.

Since diesel fuel oil and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of the N K 1- 0 CFR 50.36(c)f2)fii). I Stored diesel fuel oil is required to have sufficient v s u p p l v for 6 davs of full load operations of a sinale EDG. Onsite storage of fuel oil, in conjunction with an ability to obtain additional fuel oil if required, supports the availability of standby emergency power sources 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.

Fuel oil is also required to meet specific standards for quality.

Standby emergency power source day tank requirements, as well as fuel oil transfer capability from the storage tank to the day tank, are addressed in LC0 3.8.1, "AC Sources-Operating," and LC0 3.8.2, "AC Sources-Shutdown."

The starting air system is required to have a minimum capacity such that the standby emergency power source is capable of being started and ready to accept load in 10 seconds from receipt of a start signal.

APPLICABILITY The AC sources (LC0 3.8.1 and LC0 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 A 0 0 or a postulated DBA.

Since stored diesel fuel oil and the starting air subsystem support LC0 3.8.1 and LC0 3.8.2, stored diesel fuel oil and starting air are required to be within limits when the associated standby emergency power source is required to be OPERABLE.

Point Beach B 3.8.3-2 Unit 1 - Amendment No. 281.

Unit 2 - Amendment No. 2% I

Diesel Fuel Oil and Starting Air B 3.8.3 BASES ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each standby emergency power source.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable standby emergency power source subsystem. Complying with the Required Actions for one inoperable standby emergency power source subsystem may allow for continued operation, and subsequent inoperable standby emergency power source subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

In this Condition, the

- 7 emeraencv power source is not available. However, the Condition is restricted to fuel oil level reductions that maintain at least a 5 day sursplv. These circumstances mav be caused bv events. such as full load operation reauired after an inadvertent start while at minimum reauired level. or feed and bleed operations. which mav be necessitate bv increasina rsarticulate levels or anv number of other oil quality dearedations. This restriction allows sufficient time for obtainina the reauisite replacement volume and performina the analvses reauired prior to the 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 reauired level prior to declarina the associated standbv emeraencv power source(s) inorserable. This period is acceptable based in the remainina capacitv I> 5 davs). the fact that procedures will be initiated to obtain rerslenishment. and the low probabilitv of an event durina that time.

The required 6 dav fuel oil s u ~ p l vfor a standbv emeraencv power source is satisfied when indicated tank level reads 2 86.2%. which is a~aroximatelv32.100 usable aallons. The required 5 dav fuel oil sursply for a standbv emeraencv power source is satisfied when indicated tank level reads 2 71.3%. which is arsproximatelv 27.150 usable aallons.

This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.2. 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.

Point Beach B 3.8.3-3 Unit 1 - Amendment No. W Unit 2 - Amendment No. 3 3 3 I

Diesel Fuel Oil and Starting Air B 3.8.3 ACTIONS (continued) Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and 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 standby emergency power source inoperable. The 7 day Completion Time allows for further evaluation, resampling and re-analysis of the standby emergency power source fuel oil.

With the new fuel oil properties defined in the Diesel Fuel Oil Testing Program for SR 3.8.3.2 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 Point Beach B 3.8.3-3a Unit 1 - Amendment No.

Unit 2 - Amendment No.

Diesel Fuel Oil and Starting Air B 3.8.3 BASES ACTIONS (continued) 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 a standby emergency power source start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the standby emergency power source would still be capable of performing its intended function.

With one or more standby emergency power sources' starting air system not within limits, the associated standby emergency power source may be incapable of performing its intended function and must be immediately declared inoperable.

With a Required Action and associated Completion Time-or one or more standby emergency power source's fuel oil not within limits for reasons other than addressed by Conditions A, B or C, the associated standby emergency power source 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 operation of a- sinale EDG for 6 davs at full load. The 6 dav period is sufficient time to place the unit in a safe shutdown condition and to brina in replenishment fuel from an offsite location.

of each fuel oil storage tank is 2 W u % ,equal to approximatelv 32.100 usable aallons.

The 31 day 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.

The tests listed in the Diesel Fuel Oil Testing Program 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 Point Beach B 3.8.3-4 44,wXaw I

ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 264, SUPPLEMENT I DIESEL FUEL OIL STORAGE REQUIREMENTS CALCULATION 2006-0035, REVISION IB, PARAMETRIC VALUES 8 pages follow

Calculation 2006-0035-001-B Page 5 1.0 Background, Purpose, and Scope of Calculation I.I Background This section is unaffected by this minor revision 1.2 Purpose of this Calculation This section is unaffected by this minor revision 1.3 Purpose of this Revision The purpose of this minor revision is to provide an instrument uncertainty value to be used in conjunction with calculation N-94-142-006-A, "Emergency Diesel Generator, Gas Turbine and Fire Pump Diesel Engine Fuel Oil Systems." The result will be the 5 and 6 day Tech Spec values with uncertainty included for a single EDG on a fuel oil storage tank (FOST).

1.4 Scope This minor revision is limited t o providing the required fuel oil volume and corresponding tank level indication to support on EDG for a 5 or 6 day run.

1.5 Applicability The portions of this calculation that pertain to the FOST level are applicable upon approval of License Amendment Request 264 by the NRC.

2.0 IOCFR 50.59/72.48 Review 2.1 All Changes per this minor revision are in support of LAR 264.

The activity of revising this calculation is in support of License Amendment Request (LAR) 264. This LAR will incorporate FOST level indication instrument uncertainty into Technical Specification values for the FOST level that has been identified to not currently account for uncertainty.

Calculation 2006-0035-001-8 Page 6 The conclusions of this revision have determined a value that support fuel requirements for both a 5 day and 6 day run and provide new conservative values for the Technical Specifications. Note that any activity that requires a change t o the Technical Specifications requires prior NRC approval t o implement. The new recommended Technical Specification determined by this calculation cannot be implemented until approval of LAR 264 is received from the NRC.

Upon LAR 264 approval, per FP-E-SE-03, a 10 CFR 50.59 screening/evaluation will .not need t o be performedfor the implementing documents as long as t h e change is covered by the approved license amendment. These changes would be covered by pre-screening criterion 5; "the NRC reviewed and approved the activity in its entirety as proposed a t 'PBNP."

3.0 Acceptance Criteria This section is unaffected by this minor revision 4.0 References Calculation 2006-0035 Rev. 1, "Parametric Values" Calculation N-94-142-006-A, "Emergency Diesel Generator, Gas Turbine and Fire Pump Diesel Engine Fuel Oil Systems" 5.0 Assumptions This section is unaffected by this minor revision 6.0 Design Inputs 6.2 Other Documents N-94-142-006-A, "Emergency Diesel Generator, Gas Turbine, and Fire Pump Diesel Engine Fuel Oil Systems" calculates the amount of fuel oil required t o supply one EDG for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> and 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> a t the 2000-hour rated load. N-94-142-006-A states that 27,545 gallons of fuel oil (G-Ol/G-02) and 27,116 (G-03/G-04) is required t o support operation of a single EDG a t the 2000-hour rated load for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. N-94-142-006-A also states that

Calculation 2006-0035-001-8 Page 7 32,784 gallons of fuel oil (G-01/G-02) and 32,270 (G-03/G-04) is required to support operation of a single EDG a t the 2000-hour rated load for 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.

6.1 UE&C Spec. No. 6704-1-1, Section 15980, Attachment D (Page 13 of 62) 6.2 UE&C Nuclear, Spec No. 6704.001-SP-1-20! Model

1. 508-47-6, Page 2 of 15 7.0 Methodology This section is unaffected by this minor revision 8.0 Analysis 8.4 Fuel Oil Storage Tank (FOST) Technical Specification 8.4.1 Fuel Oil Requirement for One EDG From calculation N-94-142-006-A Results and Conclusions, the fuel oil storage requirements are listed below. The unusable fuel oil volume of 1,347 gallons is combined with the fuel oil requirement:

EDG Run Time of Five ( 5 ) Davs a t Required Load Adding the fuel oil consumption rate t o the Unusable Volume (1,347 gallons) provides the following Total Gallon results:

(G-01 or G-02) 26,198 gallons + 1,347 = 27,545 gallons (G-03 or G-04) 25,769 gallons + 1,347 = 27,116 gallons From Ref. 4-18, 26,380.5 usable gallons corresponds conservatively to 69.30% indicated level. As this volume is conservative (and above) the desired value of 26,198 usable gallons, the corresponding indicated level of 69.30% will be used as the starting point in calculating the surveillance limit with a 2% instrument uncertainty. (REF. 6.1, 6.2 this calculation)

From DG-101; "When a vendor does not specify a separate drift value, the drift is typically included in the reference accuracy value. However, to be conservative, the drift is assumed equal to the reference accuracy."

Calculation 2006-0035-001-8 Page 8 DG I01 1-efei-encefor Dlift and other vendor specified uncertainties was used to all-ive at a 2% overall level indication uncertainty. Note that the loop accuracy is I%, drift is therefore 1%, power supply affect is 0.2%, and othel- non-specified uncertainties are zero or assumed in the accuracy rating. Applying the DG-I01 methodology square root sum of the squares (SRSS) the resulting en-or is 1.428%

and conservatively rounded up to 2%.

Level erroGnd= + (aind2 + d ind2 + ppwrsup 2 112

)

Where:

a = accuracy of transmitter/indicator d = drift component of instruments p=,power supply effect Adding 2% positive uncertainty as stated in Section 8.4 t o t h e minimum (process) volume yields t h e new minimum process value with indicator uncertainty:

69.30% + 2% = 71.30% (From Equation 7.2-1)

Conversion of the level in percent to volume in gallons is perfoimed using the standard linearization technique as described in DG-102, "Instrument Scaling Methodology." This provides most reasonable accuracy in converting percent level indicatd to oil volume in gallons (Ref: N 142, Rev.6, Attachment 19).

The data points from Ref. 4-18 used for this conversion are selected so that the desired tank level (71.30%) is between the two selected data points.

[Tank Level [%I / Tank Usable Volume [Gallons1 1

Calculation 2006-0035-001-B Page 9 Y 2 - Yl 172 = ----

X2 -XI

- 71.93%-71.05%

27383.1 gallons - 27052.5 gallons 0.88%

330.6 gallons

= 0.0027 -

gallon 71.30%-71.05%

+ 27052.5 gallons 0.0027 - -- -- .

gallon

= 27 145.1gallons This calculated value is rounded to the nearest 5 gallons to obtain an acceptable surveillance value. TS surveillance to support ONE EDG is satisfied when the tank level indication reads 2 7 1.3%.

Technical Specification surveillance to support ONE EDG for 5 days is satisfied when indicated tank level reads 2 71.3 % (27,150 Usable gallons)

EDG Run Time of Six ( 6 ) Days a t Required Load Adding the fuel oil consumption rate to the Unusable Volume (1,347 gallons) provides the following results:

(G-01 or G-02) 31,437 gallons + 1,347 = 32,784 gallons (G-03 or G-04) 30,923 gallons + 1,347 = 32,270 gallons From Ref. 4-18, 31,533 usable gallons corresponds to 84.21%

indicated level. As this volume is conservative to (and above) the desired value of 31,437 usable gallons, the corresponding indicated level of 84.21% will be used as the starting point in calculating the surveillance limit with 2% instrument uncertainty. (REF. 6. I, 6.2 this calculation)

Calculation 2006-0035-001-B Page 10 Adding 2% positive uncertainty as stated in Section 8.4 t o the minimum (process) volume yields t h e new minimum process value with indicator uncertainty:

84.21% + 2% = 86.21% (From Equation 7.2-1)

Conversion of the level in percent to volume in gallons is pelfonned using the standard linearization technique as described in DG-102, "Instlument Scaling Methodology." This provides most reasonable accuracy in converting percent level indicated to oil volume in gallons (Ref: N 142, Rev.6, Attachment 19).

The data points from Ref. 4-18 used for this conversion are selected so that the desired tank level (86.21%) is between the two selected data points.

Tank Levell f %] Bank Usable Volume [GaBIons]

85.96 ( y l ) 32032.5 (XI) 86.84 (yz) 32271.0(x~)

86.84% - 85.96%

3227 1gallons - 32032.5 gallons 0.88%

238.5 gallons

= 0.0037 -----

gallon 86.21% - 85.96%

ol, IV

+ 32032.5 gallons 0.0037 ------

gallon

= 32100.9 gallons

Calculation 2006-0035-001-8 Page 11 This calculated value is rounded to the nearest 5 gallons to obtain an acceptable surveillance value. TS surveillance to support ONE EDG is satisfied when the tank level indication reads 2 86.2%.

Technical Specification surveillance to support ONE EDG for 6 days is satisfied when indicated tank level reads 3 86.2% (32,100 Usable gallons) 9.0 Conclusions Technical Specification surveillance to support ONE EDG for 5 days is satisfied when indicated tank level reads 2 71.3% (27,150 Usable gallons)

Technical Specification surveillance to support ONE EDG for 6 days is satisfied when indicated tank level reads 3 86.2% (32,100 Usable gallons) 10.0 Impact on Plant Documents Technical Specification Bases 3.8.3, Diesel Fuel Oil and Starting Air o TS Bases 3.8.3 needs to be revised to reflect the new TS values for one and two EDG fuel oil requirements. This change is tracked by LAR 264 Technical Specification 3.8.3, Diesel Fuel Oil and Starting Air o TS 3.8.3 needs to be revised to reflect the new TSvalues for one and two EDG fuel oil requirements. This change is tracked by LAR 264 Foim PBF-2033, Unit 2 Turbine Building Operator Logsheet o This log records the FOST level for both tanks (T-175AIB). The log needs to be co~sectedto reflect the new TS and surveillance values. PCR 0164389 1 will track this change.

FSAR Section 8.8, Diesel Generator (DG) System o This portion of the FSAR discusses the TS value for the FOST level. This change is tracked under USAR 01643930.

01 145, Fuel Oil Transfer Between Storage Tanks, o This 01refers to the level requirements listed in OM 1.1. This change is tracked under PCR 01643935.

DBD- 16, Emergency Diesel Generator System o This DBD lists the minimum fuel oil requirements. The DBD change will be changed as part of this EC.

Calculation 2006-0035-001-8 Page '12 OM 1.1, Co~lductof Plant Opel-ations,PBNP Specific o OM 1.1 Attachme~ltA co~ltainsa table of Parametric Values. This change is tracked under PCR 01643942.