RS-08-062, Request for a License Amendment to Technical Specification 3.8.3, Diesel Fuel Oil and Starting Air to Relocate Stored Fuel Oil Volumes to Licensee Control

Request for a License Amendment to Technical Specification 3.8.3, Diesel Fuel Oil and Starting Air to Relocate Stored Fuel Oil Volumes to Licensee Control

ML081230594
Person / Time
Site:	LaSalle
Issue date:	05/02/2008
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-08-062
Download: ML081230594 (21)

Text

Exelon Nuclear www.exeloncorp .com Exelon.

4300 Winfield Road Nuclear Warrenville, IL 60555 10 CFR 50 .90 RS-08-062 May 2, 2008 U . S . Nuclear Regulatory Commission Attn : Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos . 50-373 and 50-374

Subject:

Request for a License Amendment to Technical Specification 3.8.3, "Diesel Fuel Oil and Starting Air" to Relocate Stored Fuel Oil Volumes to Licensee Control References : (1) Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (2) Letter from T. J . Kobetz (U . S. NRC) to Members of the TSTF, "Acceptance for Review and Establishment of Milestone Schedule for TSTF Traveler 501, Revision 0, 'Relocate Stored Fuel Oil and Lube Oil Volumes to Licensee Control,'"

dated September 24, 2007 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical Specifications (TS) of Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2. Specifically, the proposed change will revise TS 3.8.3, "Diesel Fuel Oil and Starting Air," to replace the numerical volume requirements for stored diesel fuel oil inventory with requirements that state that volumes equivalent to seven-days and six-days of fuel oil are available. EGC is requesting to move the diesel fuel oil numerical volumes equivalent to seven-day and six-day supplies to the TS Bases.

These proposed changes are generally consistent, but contain minor plant-specific variances, from Reference 1, which was accepted for review by the NRC in Reference 2.

Administrative controls are currently in place at LSCS to address TS 3.8 .3 non-conservatisms in accordance with NRC Administrative Letter 98-10. These non-conservatisms were identified through analyses of TS fuel oil storage requirements considering both the entire range of American Petroleum Institute (API) gravities allowed by the LSCS Fuel Oil Testing Program and the impact of ultra-low sulfur diesel (ULSD) fuel oil. The proposed changes will address these non-conservatisms .

May 2, 2008 U . S . Nuclear Regulatory Commission Page 2 This request is subdivided as follows:

" Attachment 1 provides an evaluation supporting the proposed change.

" Attachment 2 includes the marked-up TS pages with the proposed changes indicated.

" Attachment 3 includes the marked-up TS Bases pages with the proposed changes indicated. The TS Bases pages are provided for information only, and do not require NRC approval .

EGC requests approval of the proposed change by May 4, 2009, with the amendment being implemented within 60 days of issuance.

The proposed amendment has been reviewed by the LSCS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

EGC is notifying the State of Illinois of this application for a change to the TS by sending a copy of this letter and its attachments to the designated State Official in accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

There are no regulatory commitments contained within this letter . Should you have any questions concerning this letter, please contact Mitchel Mathews at (630) 657-2819.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of May 2008.

Respectfully, P6 Patrick R. Simpson R

Manager - Licensing  : Evaluation of Proposed Change : Markup of Proposed Technical Specifications Page Changes : Markup of Proposed Technical Specifications Bases Page Changes

ATTACHMENT 1 Evaluation of Proposed Change

Subject:

Request for a License Amendment to Technical Specification 3 .8.3, "Diesel Fuel Oil and Starting Air" to Relocate Stored Fuel Oil Volumes to Licensee Control 1 .0 DESCRIPTION

2.0 PROPOSED CHANGE

S

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria 6.0 ENVIRONMENTAL EVALUATION 7.0 PRECEDENT

8.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Change 1 .0 DESCRIPTION In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical Specifications (TS) of Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2 . The proposed change will revise TS 3.8.3, "Diesel Fuel Oil and Starting Air," consistent with Technical Specification Task Force (TSTF) Traveler TSTF-501 (Reference 1), to replace the numerical volume requirements for stored diesel fuel oil inventory in the TS Actions with a generic requirement for a seven-day supply of fuel oil available.

Additionally, EGC is proposing the replacement of diesel fuel oil numerical volumes equivalent to a six-day supply, used in the TS Actions, with an equivalent generic statement regarding the availability of a six-day supply of fuel oil. Due to the properties of Ultra Low Sulfur Diesel (ULSD) Fuel, this change will also address, through the TS Bases markup, a more conservative change in the volume of diesel fuel oil required to support seven days and six days of diesel generator (DG) continuous operation .

2 .0 PROPOSED CHANGES The existing TS 3.8 .3 Condition A.1 states that if one or more of the Division 1, Division 2, or opposite unit Division 2 DG, has a fuel oil storage tank level less than 31,000 gallons, but greater than or equal to 26,550 gallons when the associated DG is required to be Operable, the affected fuel oil tank level must be restored to within limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This 31,000-gallon requirement is based on maintaining a seven-day supply of usable diesel fuel oil available in the associated fuel oil storage tank when the associated DG is required to be Operable . The 26,550-gallon requirement is based on the need to maintain at least a six-day supply of usable diesel fuel when the associated DG is required to be Operable . With less than a six-day supply of usable fuel oil available, TS 3.8 .3 Condition E requires declaring the associated DG inoperable immediately. The proposed change removes the numerical volume requirements from TS 3.8 .3 Condition A.1 and replaces them with equivalent non-numerical seven-day and six-day requirements . EGC proposes the revision of the Bases of TS 3 .8.3 to include the numerical fuel oil volume requirements for the Division 1, Division 2, and opposite unit Division 2 DG.

The existing TS 3.8.3 Condition A.2 states that if the Division 3 DG has a combined day tank and fuel oil storage tank level of less than 29,750 gallons, but greater than or equal to 25,550 gallons when the associated DG is required to be Operable, the available fuel oil volume must be restored to within limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The 29,750-gallon level requirement is based on maintaining a seven-day supply of diesel fuel oil available when the associated Division 3 DG is required to be Operable . The 25,550-gallon storage level requirement is based on maintaining at least a 6-day supply of diesel fuel oil available when the associated DG is required to be Operable . With less than a six-day supply of diesel fuel oil available, TS 3.8.3 Condition E requires declaring the associated Division 3 DG inoperable immediately. The proposed change removes the numerical volume requirements for TS 3.8.3 Condition A.2 and replaces them with equivalent non-numerical seven-day and six-day requirements . EGC proposes the revision of the Bases of TS 3.8.3 to include the six and seven-day numerical fuel oil volume requirements for the Division 3 DG.

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ATTACHMENT 1 Evaluation of Proposed Change Surveillance Requirement (SR) 3.8.3.1 .a requires the verification greater than or equal to 31,000 gallons of fuel oil in the storage tanks for the Division 1, Division 2, and the opposite unit Division 2 DGs every 31 days when the associated DG is required to be Operable . Surveillance Requirement (SR) 3 .8.3.1 .b requires the verification greater than or equal to 29,750 gallons of fuel oil in the combined storage tank and day tank for the Division 3 DG every 31 days when the associated DG is required to be Operable . The proposed change removes the numerical volume requirements from SR 3 .8 .3.1 and replaces them with equivalent generic requirements for maintaining a seven-day supply of fuel oil. EGC proposes the revision of the Bases of SR 3 .8 .3 to include the numerical fuel oil volume requirements for the Division 1, Division 2, opposite unit Division 2, and Division 3 DG.

Additionally, the proposed change, as stated in the attached TS 3 .8.3 Bases markup, includes new, conservative fuel oil storage requirements . These requirements stem from the preparation of LSCS for the exclusive use of ULSD fuel. Due to the chemical properties of ULSD fuel, this transition will result in an increase in the volume of fuel oil required to satisfy the seven-day diesel operation requirements in TS . The current TS minimum volumes of the fuel oil storage and fuel oil day tanks will no longer be sufficient for the Division 1, Division 2 and Division 3 DGs following full transition to ULSD . Table 1 lists the numerical usable volumes equivalent to seven-day and six-day supplies, including the increased storage requirements following full transition to the use of ULSD at LSCS . Both the seven-day and six-day fuel oil volume requirements for the Division 1, Division 2, and opposite unit Division 2 DG include a minimum of 250 gallons of fuel oil in the associated fuel oil day tank . Both the seven-day and six-day fuel oil volume requirements for the Division 3 DG include a minimum of 550 gallons of fuel oil in the associated fuel oil day tank. SR 3 .8 .1 .4 verifies the Division 1, Division 2, and Division 3 day tank minimum volume requirements .

Table 1 : Usable Diesel Fuel Storage Requirements*

Seven-da fuel supply Six-day fuel supply Required Diesel Current Proposed Current Proposed Generator Requirement Requirement Requirement Requirement Division 1 DG fuel oil 31,250 32,200 26,800 27,600 storage tank and day tank (gallons)

Division 2 DG fuel oil 31,250 32,200 26,800 27,600 storage tank and day tank (gallons)

Opposite Unit Division 2 31,250 32,200 26,800 27,600 DG fuel oil storage tank and day tank (gallons)

Division 3 DG combined 29,750 30,000 25,550 25,900 fuel oil storage tank and day tank (gallons)

• The proposed numerical volumes requirements are based on calculating the maximum required fuel consumption (Ibm) over the American Petroleum Institute (API) gravity range allowed by SR 3 .8.3.2 converted to a single volumetric value (gallons) at an API gravity of 30 at a nominal temperature of 60°F.

Fuel oil volumes listed are usable volume .

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ATTACHMENT 1 Evaluation of Proposed Change The DG fuel oil numerical volumes equivalent to seven-day and six-day supplies will be controlled under the TS Bases Control Program as defined in TS 5.5.11 .

3.0 BACKGROUND

Each LSCS DG is provided with a fuel oil storage tank and a day tank . The Division 1, Division 2, and the opposite unit Division 2 DG onsite fuel oil systems were designed to provide capacity sufficient to operate the associated DG for a period of seven days while the DG is supplying rated load. The Division 3 onsite fuel oil system was designed to provide capacity sufficient to operate that DG for a period of seven days while the DG is supplying maximum expected load profile. This onsite fuel oil capacity was evaluated to be sufficient to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location .

In January 2001 and in June 2004, the U .S . Environmental Protection Agency (EPA) finalized the "Clean Diesel Trucks and Buses Rule," and the "Clean Non-road Diesel Rule," respectively .

These rules contain more stringent standards for new diesel engines and fuels as discussed in NRC Information Notice (IN) 2006-22, (Reference 5).

The EPA rules require a reduction in the sulfur content for land-based non-road diesel fuels .

These requirements are being accomplished in two steps, with an interim step from uncontrolled levels of sulfur in fuel oil to a 500 ppm cap which began in June 2007 . The final step will be a reduction in sulfur content to 15 ppm, and will commence in June 2010 . Although the 15 ppm requirement for land-based diesel engines does not take effect until 2010, many fuel oil producers have already shifted to the exclusive production of ULSD to meet regulatory requirements and to meet the demand generated by the fact that laws for the use of ULSD are already in place for over-the-road diesel engines . As a result, several nuclear power plant licensees, including LSCS, have received shipments of ULSD .

In general, the processing required to reduce sulfur in diesel fuel reduces the aromatics content and the density of the diesel fuel. This process also results in a reduction of the volumetric energy content (BTU/gal) of the fuel . EGC in its evaluations used a 1 % reduction in energy content for ULSD compared to the diesel fuel that was used as the basis in the design of LSCS .

The reduced volumetric energy capacity of the ULSD will result in increased fuel consumption required to achieve rated load . Therefore, the current LSCS TS limits for minimum diesel fuel oil storage usable volume in TS 3 .8.3 will be insufficient to ensure seven-day DG operation as described in the TS Bases for the LCO.

An evaluation of current fuel oil TS requirements for the Division 1 and Division 2 DG fuel oil systems at LSCS identified a lack of conservatism, which was due to original evaluations not considering the fuel oil consumption over the entire range of API gravities permitted by the LSCS Diesel Fuel Oil Testing Program. Compensatory actions are in place to meet the expectations of NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," and will remain in effect until this license amendment is implemented following approval . These measures included raising the diesel fuel oil storage tank alarm setpoints and minimum tank volumes for the Division 1 and Division 2 DG fuel oil storage tanks. The properties of ULSD were used when determining minimum storage tank volumes equivalent to seven-day and six-day supplies .

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ATTACHMENT 1 Evaluation of Proposed Change In reviewing the design calculation establishing the basis for the seven-day volume, EGC determined that the current seven-day volume specified in TS 3.8 .3 would become non-conservative when considering the use of ULSD fuel oil. While the process required to reduce sulfur content and lower aromatic content is related to the density of the fuel, the specification of specific sulfur and aromatic content has only a nominal impact on the calculation . The most significant fuel parameter relative to the energy content of the fuel oil is the API gravity. It was determined when evaluating fuel oil consumption over the entire range of API gravities allowed by the LSCS Diesel Fuel Oil Testing Program, and considering the impact of ULSD, the volume requirements in TS needed to be increased .

The requirements on diesel fuel oil may continue to change in the future, and the addition of additives to compensate for the issues associated with ULSD discussed in IN 2006-22 may further affect the volumetric energy content (and, as a result, the stored diesel fuel oil volume requirements) . These changes would result in future license amendments to revise the stored fuel oil volume in order to ensure that the volume provides for at least seven days of diesel generator operation . In order to facilitate the expeditious revision of the fuel oil volume requirements when needed, and to avoid the unnecessary expenditure of licensee and NRC resources to prepare and review future license amendment requests that simply revise the volume equivalent to seven and six day supplies, the proposed change places the requirement to have stored fuel oil sufficient to support seven days of diesel generator operation in the TS with the equivalent numerical volume under licensee control in the TS Bases.

4.0 TECHNICAL ANALYSIS

The LSCS diesel fuel oil inventory TS requirements, as described in the TS Bases Section 3.8.3, provide verification that there is an adequate inventory of fuel oil available. For the Division 1 and 2 DGs and the opposite unit Division 2 DG, the combined fuel oil storage tank and day tank usable volumes are sufficient to support DG operation for seven days at rated load . For the Division 3 DGs, the combined fuel oil storage tank and day tank usable volumes are sufficient to support Division 3 DG operation for seven days while the Division 3 DG is supplying maximum expected load profile. This requirement, in conjunction with an ability to obtain replacement supplies within seven days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated Design Basis Accident (DBA) with loss of offsite power. Therefore, the principal safety concern with the volume of the stored diesel fuel oil is that there is a seven-day supply . This proposed change does not alter the licensing basis of the plant, but only revises the presentation of the licensing basis assumption (i .e., days versus gallons) .

Historically, the specific volume of fuel oil required to provide a seven-day supply was specified in the TS to facilitate the comparison by the operator of the indicated tank level to the volume limit. However, recent State and Federal regulatory changes that affect diesel fuel oil energy content and the anticipation of future changes, supports the relocation of the specific volume limit to the TS Bases under licensee control and placing the basis of the limit in TS . There are several examples of precedent for this type of relocation of specific limits to licensee control while retaining the requirement in TS, such as Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," Generic Letter 96-03, "Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Page 5 of 11

ATTACHMENT 1 Evaluation of Proposed Change Limits," and TSTF-2-A, "Relocate the 10-year sediment cleaning of the fuel oil storage tank to licensee control ."

The methodology for calculating the fuel oil storage volume equivalent to a seven-day and six-day supply is well established. The TS requirements for fuel oil inventory at LSCS have been determined using fuel oil consumption rates as provided by the specific engine manufacturer .

The storage requirements have been conservatively modified to account for a one percent volumetric energy content difference between fuel oil historically received by LSCS and ULSD, and further modified to account for current non-conservatisms identified through consideration of the affect of the range of API gravity values allowed by the LSCS Diesel Fuel Oil Testing Program. The numerical DG fuel oil volumes equivalent to a seven-day supply will be relocated to the TS Bases in Table B3.8.3-1, and will be controlled under the TS Bases Control Program implemented by Appendix H of the LSCS Technical Requirements Manual (TRM). Any changes to the volume will be reviewed under the TS Bases Control Program, which requires changes to be evaluated under 10 CFR 50.59, "Changes, tests and experiments." Future changes to the fuel oil volume or method of calculation that do not meet the criteria in 10 CFR 50.59(c)(1) will be submitted to the NRC for prior review in accordance with 10 CFR 50.90.

The TS provide a limited Completion Time to continue to operate with available diesel fuel oil less than the seven-day supply, but greater than a six-day supply . These circumstances may be caused by events such as full load operation required for an inadvertent start while at minimum required level, or 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 to obtain the requisite replacement volume and to perform the analyses required prior to addition of the fuel oil to the storage tank. The calculation of the volume equivalent to a six-day supply is performed in the same manner as the calculation of the seven-day supply .

The calculation was performed using API gravity values over the range allowed by the LSCS Diesel Fuel Oil Testing Program . Relocating the specific volumes in the TS with the condition that a six-day supply is available and placing the numerical value in the TS Bases is acceptable for the same reasons provided above for relocating the seven-day limit.

Additionally, in Reference 7, the NRC requested additional information related to TSTF-501 from the TSTF. Specifically, the NRC asked the TSTF to: 1) Discuss what effects a mixture of ULSD and LSD fuel in the storage tank will have on the fuel consumption rate, in order to ensure that a [7] day supply is maintained, as required by the TS per Criterion 3 of 10 CFR 50 .36(d)(2)(ii), 2) Discuss how storage sampling will be performed (including acceptance criteria), in order to verify that any assumptions used in the fuel consumption rate calculation are valid, thereby ensuring that a [7] day supply is maintained, as required by the TS per Criterion 3 of 10 CFR 50.36(d)(2)(ii), and 3) Discuss the effects of deleting the reference to Appendix B in ANSI N195-1976 on the current acceptable basis for maintaining the quality of fuel oil, as required by the TS per Criterion 3 of 10 CFR 50.36(d)(2)(ii) . The following is LSCS's response to the NRC's request for additional information :

1) The mixing of ULSD and LSD fuels will not substantially affect fuel consumption . As noted above, during the review and update of the fuel oil consumption calculation it was determined that the most significant fuel oil parameter affecting consumption is the API gravity. The fuel consumption calculation was performed assuming the worst parameter values allowed by the Diesel Fuel Oil Testing Program. Mixing of fuel with different parameter values will result in a parameter value somewhere between the value of the Page 6 of 11

ATTACHMENT 1 Evaluation of Proposed Change stored fuel and that of the added fuel. As long as both values are within specification, the resulting mixture will also remain within specification ; therefore, since the consumption calculation assumed the worst allowable values for the fuel oil quality parameters, mixing will not affect the seven-day value.

2) The proposed change does not affect the stored fuel-sampling program. Sampling will continue in accordance with Technical Specification 5.5.10, "Diesel Fuel Oil Testing Program," and the acceptance criteria will continue to be as specified for ASTM 2D fuel oil.

3) EGC will not delete the reference to Appendix B of ANSI N195 -1976 .

The assumption that all fuel oil in the storage tanks is ULSD is a conservative assumption as the volumetric energy content of ULSD is less than any mixture of ULSD and fuel oil presently contained in the storage tanks.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical Specifications (TS) of Facility Operating License Nos . NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2. Specifically, the proposed change will revise TS 3.8 .3, "Diesel Fuel Oil and Starting Air," to replace the numerical volume requirements for stored diesel fuel oil inventory with the requirement that a seven-day supply be available. The diesel fuel oil numerical volumes equivalent to a six-day supply, used in the Actions, are replaced with a statement that there is a six-day supply . The diesel fuel oil numerical volumes equivalent to seven-day and six -day supplies will be relocated to the TS Bases.

The proposed change resulted from analyses conducted at LSCS when considering the impact of the transition to Ultra Low Sulfur Diesel (ULSD) fuel, which will result in an increase in the fuel oil storage volume to satisfy the seven-day diesel operation requirements in TS. The change in volume requirements for the Division 1 and Division 2 Diesel Generators (DGs) also accounts for non-conservatisms identified when evaluating fuel oil consumption over the range of API gravities allowed by the LSCS Diesel Fuel Oil Testing Program. The current minimum TS required volumes of the storage and day tanks will not be sufficient for the Division 1, Division 2, and Division 3 Diesel Generators (DGs) following full transition to ULSD .

The requirements on diesel fuel oil may continue to change, resulting in future license amendments to revise the stored fuel oil volume in order to ensure the minimum TS value is equivalent to a seven-day supply . Therefore, this proposed license amendment relocates the numerical volumes equivalent to seven-day and six-day supplies to the TS Bases.

Due to non-conservatisms previously discussed, compensatory actions are in place at LSCS to ensure the Division 1, 2, and 3 DG maintain volumes equivalent to a seven-day supply, to maintain the safety function of the DGs during the transition period . Administrative controls are in place to monitor storage tank levels as needed .

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ATTACHMENT 1 Evaluation of Proposed Change According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability or consequences of an accident previously evaluated ; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated ; or Involve a significant reduction in a margin of safety .

In support of this determination, an evaluation of each of the three criteria set forth in 10 CFR 50.92 is provided below regarding the proposed license amendment.

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

Response : No The proposed change relocates the numerical volume of diesel fuel oil required to support seven-day operation of the onsite DGs, and the numerical volume equivalent to a six-day supply, to licensee control. The specific volumes of fuel oil equivalent to a seven-day and six-day supply is calculated considering the DG manufacturer's fuel oil consumption rates and the energy content of ULSD fuel . Moreover, these calculations consider the entire range of API gravities allowed by the LSCS Diesel Fuel Oil Testing Program. The requirement to meet UFSAR 9.5.4.1 .1 .d diesel loading assumptions, maintain a seven-day supply, and the actions taken when the volume of fuel oil available is less than a six-day supply have not changed . These requirements remain consistent with the assumptions in the accident analyses, and neither the probability nor the consequences of any accident previously evaluated will be affected by the proposed change.

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

2. Does the proposed TS change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response : No The proposed change does not involve any physical alteration of the plant (i .e ., no new or different type of equipment will be installed), or affect the control parameters governing unit operation, or the response of plant equipment to transient conditions .

The proposed change does not alter assumptions made in the safety analysis . The proposed change is consistent with the safety analysis assumptions.

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ATTACHMENT 1 Evaluation of Proposed Change Based on the above information, 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 TS change involve a significant reduction in a margin of safety?

Response : No The proposed change relocates the numerical volumes of diesel fuel oil required to support seven-day operation of the onsite DGs, and the numerical volumes equivalent to a six-day supply, to licensee control . 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 .

Based on the above evaluation, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50 .92(c), and, accordingly, a finding of "no significant hazards" is justified .

5.2 Applicable Regulatory Requirements/Criteria General Design Criterion (GDC) 17, "Electric Power System," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety . In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability.

As stated in the Bases for TS 3.8.3, Regulatory Guide (RG) 1 .137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators," dated October 1979, describes a method acceptable to the NRC for complying with the NRC's regulations regarding diesel fuel oil systems for standby DGs and assurance of adequate diesel fuel oil quality. RG 1 .137 states that Appendix B to ANSI N195-1976, "Fuel Oil Systems for Standby Diesel Generators," should be used as a basis for a program to ensure the initial and continuing quality of diesel fuel oil as supplemented by eight additional provisions described in the RG for maintaining the properties and quality of diesel fuel oil.

The proposed change does not affect the design of the onsite electrical power system, the quality of the onsite electrical power system, or the method of determining the necessary quantity of onsite diesel fuel oil .

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the approval of the propose change will not be inimical to the common defense and security or to the health and safety of the public .

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ATTACHMENT 1 Evaluation of Proposed Change 6.0 ENVIRONMENTAL EVALUATION EGC has evaluated this proposed operating license amendment consistent with the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51 .21, "Criteria for and identification of licensing and regulatory actions requiring environmental assessments." The proposed change will modify 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure .

Accordingly, EGC has determined that this proposed change meets the criteria for a categorical exclusion set forth in paragraph (c)(9) of 10 CFR 51 .22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review ." Therefore, in accordance with 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 PRECEDENT James A. FitzPatrick Nuclear Power Plant (Reference 9) has submitted an amendment request to move the numerical TS volume requirements for diesel fuel oil to licensee control consistent with TSTF-501 .

8.0 REFERENCES

1 . Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," dated July 20, 2007 2 . Letter from T. J. Kobetz (U. S. NRC) to Members of the TSTF, "Acceptance for Review and Establishment of Milestone Schedule for TSTF Traveler 501, Revision 0, 'Relocate Stored Fuel Oil and Lube Oil Volumes to Licensee Control,"' dated September 24, 2007

3. Regulatory Guide 1 .137, Revision 1, "Fuel Oil Systems for Standby Diesel Generators,"

dated October 1979

4. ANSI N195-1976, "Fuel Oil Systems for Standby Diesel Generators"

5. NRC Information Notice 2006-22, "New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," dated October 12, 2006

6. Letter from U .S. NRC to Members of the TSTF, "Acceptance for Review and Establishment of Milestone Schedule for TSTS Traveler 501, Revision 0, 'Relocate Stored Fuel Oil and Lube Oil Volumes to Licensee Control,' (TAC No. MD6138)," dated September 24, 2007 Page 10 of 11

ATTACHMENT 1 Evaluation of Proposed Change

7. Letter from U. S. NRC to Technical Specification Task Force (TSTF) , "Request for Additional Information Regarding TSTF-501, Revision 0, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"' dated December 13, 2007 8 . LaSalle County Power Station Updated Final Safety Analysis Report (UFSAR), Revision 17, dated April 2008 9 . Letter from P. Dietrich (Entergy Nuclear Operations, Inc.) to U. S. NRC, "Application for Amendment to Technical Specifications Regarding Diesel Fuel Oil, Lube Oil, and Starting Air Consistent with TSTF-501 and Diesel Fuel Oil Testing Program consistent with TSTF-374," dated January 22, 2008 Page 11 of 11

ATTACHMENT 2 LASALLE COUNTY STATION UNITS 1 and 2 Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18 Markup of Proposed Technical Specifications Page Changes REVISED TS PAGES 3.8 .3-1 3 .8 .3-3

Diesel Fuel Oil and Starting Air 3 .8 .3 3 .8 ELECTRICAL POWER SYSTEMS 3 .8 .3 Diesel Fuel Oil and Starting Air LCO 3 .8 .3 The stored diesel fuel oil and starting air subsystem shall be within limits for each required diesel generator (DG) .

APPLICABILITY : When associated DG is required to be OPERABLE .

ACTIONS

___---------_____------_____---____-_NOTE-___----_-__----____-______----_-___-

Separate Condition entry is allowed for each DG .

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with A .1 Restore stored fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> stored fuel oil level : oil level to within combined day limit .

tank and 1 . In the*fuel oil storage tank for the Division 1 and Division 2 DGs, less than a 7-day supply and and the opposite greater than or equal to a 6-unit Division 2 day supply, DG, ai IU _ LV, T7Dy Q-and

2. In the combined day tank and fuel oil storage tank less than a 7-day supply and for the Division 3 greater than or equal to a 6-DG, ,- 58 g-Ti day supply .

(continued)

LaSalle 1 and 2 3 .8 .3-1 Amendment No . X33

Diesel Fuel Oil and Starting Air 3 .8 .3 SURVEILLANCE REQUIREMENTS a 7-day supply a . >_ 91,888 gm} of fuel i n eAH fuel oil storage tank for the Division 1 and and daytank Division 2 Gs and the opposite unit Division 2 DG .

-day supply

b. >_ 29,~58 1:81 of fuel in the combined fuel oil storage tank and day tank for the Division 3 DG .

SR 3 .8 .3 .2 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program . Testing Program SR 3 .8 .3 .3 Verify each DG air start receiver pressure is >_ 200 psig .

SR 3 .8 .3 .4 Check for and remove accumulated water from each fuel oil storage tank .

LaSalle 1 and 2 3 .8 .3-3 Amendment No . t44/'t33

ATTACHMENT 3 LASALLE COUNTY STATION UNITS 1 and 2 Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18 Markup of Proposed Technical Specifications Bases Page Changes REVIS ED TS BASES PAGES B 3 .8.3-3 B 3.8.3-5 B 3.8.3-8 ADDED TS BASES PAGE B 3 .8.3-9

Diesel Fuel Oil and Starting Air B 3 .8 .3 BASES APPLICABILITY oil and starting air subsystems support LCO 3 .8 .1 and (continued) LCO 3 .8 .2, stored diesel fuel 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 . 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) are governed by separate Condition entry and application of associated Required Actions .

less than the 7 day fuel oil supply shown in Table 133 .8.3-1 With stored fuel oil level ,

the 7 day fuel oil supply for a DG 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 :

as shown in Table 133 .8.3-1 a . Full load operation required after 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 actions will be initiated to obtain replenishment, and the low probability of an event during this brief period .

(continued)

The usable fuel oil volume equivalent to a 6 day supply for the Division 1 and Division 2 DGs, the opposite unit Division 2 DG, and the Division 3 DG is the Six-day Fuel Oil Supply listed in Table B3 .8 .3-1 . The volumes listed in Table B3 .8 .3-1 are the usable volumes of the associated fuel oil storage tank and day tank combined . The usable tank volume plus the unusable tank volume equals the actual tank volume .

LaSalle 1 and 2 B 3 .8 .3-3 Revision

Diesel Fuel Oil and Starting Air B 3 .8 .3 BASES ACTIONS D-1 (continued) for at least one start, and the DG 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 DG inoperable . This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period .

E.. l With a Required Action and associated Completion Time of Condition A, B, C, or D not met, or the stored diesel fuel oil or starting air subsystem not within limits of this Specification for reasons other than addressed by Conditions A through D, the associated DG 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 associated fuel oil storage ta_ nk If or the Division 1 and 2 DGs and the opposite unit and day tank Division 2 DG-adequate f-,el is available to support each DG's operation The usable fuel oil volume for 7 days at rated load . This SR provides verification equivalent to a 7 day supply for the Division 1 and that there is an adequate inventory of fuel oil in the Division 2 DGs, the opposite associated fuel oil storage tank and day tank for the unit Division 2 DG, and the Division 3 DG to support its operation for 7 days at maximum Division 3 DG is the Seven- expected load profile . Each DG's storage tank supplies fuel day Fuel Oil Supply listed in to ensure an adequate supply is maintained in its respective Table B3.8.3-1 . The day tank . Each DG's day tank supplies fuel to the DG volumes listed in Table The 7 day period is sufficient time to place the unit in a safe B3.8.3-1 are the usable volumes of the associated shutdown condition and to bring in replenishment fuel from fuel oil storage tank and day an offsite location .

tank combined . The usable tank volume plus the The 31 day Frequency is adequate to ensure that a sufficient unusable tank volume supply of fuel oil is available, since low level alarms are equals the actual tank volume .

(continued)

LaSalle I and 2 B 3 .8 .3-5 Revision

Diesel Fuel Oil and Starting Air B 3 .8 .3 BASES SURVEILLANCE SR 3 .8 .3 .3 (continued)

REQUIREMENTS The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure .

SR 3 .8 .3 .4 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 oil storage tank once every 92 days 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 DG operation . Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and 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 Frequencies are established by Regulatory Guide 1 .137 (Ref . 2) . This SR is for preventive maintenance . The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance .

REFERENCES l . UFSAR, Section 9 .5 .4 .

2. Regulatory Guide 1 .137 .

3. ANSI N195, Appendix B, 1976 .

4. UFSAR, Chapter 6 .

5. UFSAR, Chapter 15 .

6. ASTM Standards : D4057-95 ; D975-98b ; D1298-99 ; D445-97 ; D93-99c ; D4176-93 ; D2709-96e ; D1552-95 ; D2622-98 ;

D4294-98 ; D5452-98 .

LaSalle 1 and 2 B 3 .8 .3-8 Rev isio

Insert new page B 3 .8 .3-9 1 Diesel Fuel Oil and Starting Air B 3 .8 .3 BASES (continued)

Table B3 .8 .3-1 : Division 1, Division 2, Opposite Unit Division 2, &

Division 3 DG Usable Fuel Oil Volumes DG Seven-day Fuel Oil Supply Six-day Fuel Oil Supply Division 1 32,200 gallons 27,600 gallons Division 2 32,200 gallons 27,600 gallons Opposite Unit 32,200 gallons 27,600 gallons Division 2 Division 3 30,000 gallons 25,900 gallons LaSalle 1 and 2 B 3 .8 .3-9 Revision