ML17163A354

Issuance of Amendment Concerning Adoption of Tstf-501, Revision 1, Relocation of Diesel Fuel and Lube Oil Volume Values to Licensee Control (CAC No. MF8693) (L-16-236)

ML17163A354
Person / Time
Site:	Perry
Issue date:	06/29/2017
From:	Kimberly Green Plant Licensing Branch III
To:	Brandi Hamilton FirstEnergy Nuclear Operating Co
Green K
References
CAC MF8693
Download: ML17163A354 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 29, 2017 Mr. David B. Hamilton Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT CONCERNING ADOPTION OF TSTF-501, REVISION 1, "RELOCATION OF DIESEL FUEL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" (CAC NO. MF8693) (L-16-236)

Dear Mr. Hamilton:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 177 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated October 27, 2016.

The amendment revises TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs and replacing them with diesel operating time requirements consistent with NRG-approved Revision 1 to Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control."

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Ki~~rt::ject Plant Licensing Branch 111 Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosures:

1. Amendment No. 177 to NPF-58

2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 177 License No. NPF-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by FirstEnergy Nuclear Operating Company, et al. (the licensee, FENOC), dated October 27, 2016, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-58 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 177, are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION DS~".~~ie~~

Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-58 and Technical Specifications Date of Issuance: June 2 9, 2O1 7

ATTACHMENT TO LICENSE AMENDMENT NO. 177 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 FACILITY OPERATING LICENSE NO. NPF-58 DOCKET NO. 50-440 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT License NPF-58 License NPF-58 3.8-21 3.8-21 3.8-23 3.8-23

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 1O CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level FENOC is authorized to operate the facility at reactor core power levels not in excess of 3758 megawatts thermal (100% power) in accordance with the conditions specified herein. *

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 177, are hereby incorporated into the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions

a. FirstEnergy Nuclear Generation, LLC Amendment No. 177

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with 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 /> fuel oil level less than a 7 within limits.

day supply and greater than or equal to a 6 day supply.

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

than a 7 day supply and greater than or equal to a 6 day supply.

(continued)

PERRY - UNIT 1 3.8-21 Amendment No. 177

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains 2'. a 7 day In accordance supply of fuel. with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory is 2'. a 7 day supply. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program SR 3.8.3.4 Verify each required DG air start receiver pressure In accordance is 2 210 psig. with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from each In accordance fuel oil storage tank. with the Surveillance Frequency Control Program SR 3.8.3.6 For each fuel oil storage tank: In accordance with the

a. Drain the fuel oil; Surveillance Frequency

b. Remove the sediment; and Control Program C. Clean the tank.

PERRY - UNIT 1 3.8-23 Amendment No. 177

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 177 TO FACILITY OPERATING LICENSE NO. NPF-58 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION. LLC PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By application dated October 27, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16302A055), FirstEnergy Nuclear Operating Company (the licensee or FENOC) requested changes to the technical specifications {TSs) for the Perry Nuclear Power Plant, Unit 1 (PNPP). The proposed changes would revise TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS and replacing them with each diesel generator's (DG) operating time requirements consistent with Technical Specifications Task Force (TSTF)

Standard Technical Specifications Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (ADAMS Accession No. ML090510686). The availability of this TS improvement was announced in the Federal Register on May 26, 2010

{75 FR 29588), as part of the consolidated line item improvement process.

The licensee requested changes to the PNPP TS to adopt TSTF-501, Revision 1. The licensee's current TSs contain numerical volume requirements for both stored diesel fuel oil and lube oil, and any change to the numerical volume requirements currently requires prior approval from the U.S. Nuclear Regulatory Commission (NRG or Commission). As an example, diesel fuel oil numerical volume requirements may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements. By adopting TSTF-501, Revision 1, the numerical volume requirements for both stored diesel fuel oil and lube oil would be removed from the TS. Proposed revisions to the TS Bases are also included in the license amendment request (LAR) dated October 27, 2016. As a result, the numerical volume requirements for both stored diesel fuel oil and lube oil could be modified under licensee control under the provisions of Title 1O of the Code of Federal Regulations (10 CFR), Section 50.59 and, therefore, would not require prior NRG approval.

Changes to the affected TS Bases pages will be made by the licensee in accordance with the TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

Enclosure 2

1.1 Licensee's Proposed Changes The proposed changes would revise TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the current stored diesel fuel oil volume and lube oil inventory numerical requirements from the TS and replacing them with duration-based diesel operating time requirements so that the volume necessary to meet the TS duration requirements may be modified under licensee control. The TS would also be modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each DG. As a result, the licensee proposed the following changes:

• Revise Condition A and Condition Bin the Action table. Currently, Condition A and Condition B apply when the stored diesel fuel oil and lube oil numerical volume requirements are not met. As discussed in the TS Bases the numerical diesel fuel oil and lube oil volume requirements in Conditions A and B are based on a volume of less than a 7-day supply but at least a 6-day supply. The proposed revision would remove the numerical volumetric requirements from the TS and replace them with the duration-based requirement. The TSs would be modified so that Condition A is entered when the stored diesel fuel oil is less than a 7-day supply but greater than or equal to a 6-day supply for one or more DGs. Condition B would be entered when stored diesel lube oil is less than a 7-day supply, but greater than or equal to a 6-day lube oil supply for one or more DGs.

• Revise Surveillance Requirements (SR) 3.8.3.1 and 3.8.3.2. Currently, SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil volume and lube oil volume numerical requirements are met. As discussed in the current TS Bases, the numerical requirements in SR 3.8.3.1 and SR 3.8.3.2 are based on maintaining at least a 7-day supply. The proposed revision would remove the volume numerical requirements from the TS. The TS would be revised so that SR 3.8.3.1 and SR 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil inventories are greater than or equal to a 7-day supply for each DG.

1.2 Licensee-Identified Differences with TSTF-501. Revision 1 The licensee identified three minor deviations from TSTF Traveler TSTF-501, Revision 1, on page 3 of 6 of the Enclosure to the LAR.

First, the licensee added words to SR 3.8.3.2 on page B 3.8-46 to correctly identify "lube oil" instead of "fuel oil" as in the markup for TSTF Traveler TSTF-501, Revision 1, for plants of the General Electric (GE) boiling-water reactor (BWR)/6 design to correct errors in the TS Bases markup provided by TSTF-501.

Secondly, the licensee deleted the words "Appendix B" from page B 3.8-50 to correctly identify that the bases now reference the entire ANSI N195-1976. No such deletion was made in TS Bases markup for TSTF Traveler TSTF-501, Revision 1, for plants of the GE BWR/6 design.

Lastly, FENOC used "greater than or equal to a 6-day supply" or"~ 6 days" in lieu of "greater than a 6-day supply" or"(> 6 days)." The licensee stated that this deviation aligned the proposed TS and TS Bases changes with the current TS and TS Bases for PNPP and avoids potential confusion when fuel oil volumes equal a 6-day supply.

2.0 REGULATORY EVALUATION

2.1 Proposed Change to TS Limiting Condition for Operation (LCO) 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," Requirements The regulation at 10 CFR, Section 50.36, "Technical specifications," provides the regulatory requirements for the content required in the TSs. As stated in 10 CFR 50.36, the TSs include LCOs and SRs to assure that the LCOs are met.

The regulation at 10 CFR 50.36(c)(2)(i) states that TSs will include LCOs which are "the lowest functional capability or performance levels of equipment required for safe operation of the facility."

Regulatory Guide (RG) 1.137, Revision 1, provides guidance that describes methods acceptable to the NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby diesel generators (ADAMS Accession No. ML003740180). RG 1.137, Section C.1.c, sets forth two methods for calculation of fuel oil storage requirements as described in Section 5.4 of American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel-Generators."

2.2 Proposed Change to the Actions Table for TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" The regulation at 10 CFR 50.36(c)(2)(i) states that TSs will include LCOs which are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." Paragraph 50.36(c)(2)(i) additionally states that "when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

2.3 Proposed Change to SRs 3.8.3.1 and 3.8.3.2 The regulation at 10 CFR 50.36(c)(3) states that "surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."

PNPP is committed to RG 1.137, Revision 1, as stated in the Updated Safety Analysis Report.

RG 1.137, Revision 1, addresses the recommended fuel oil practices as supplemented by ANSI N 195-1976. It endorses 2 methods for calculation of fuel oil storage requirements:

(1) calculations based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. It also states that for the time dependent load method, the minimum required capacity should include the capacity to power the engineered safety features.

Regulatory Position 2 of RG 1.137 states, in part, that "Appendix B to ANSI N 195-1976 should be used as a basis for a program to ensure the initial and continuing quality of fuel oil."

Additionally PNPP has an existing TS 5.5.9, "Diesel Fuel Oil Testing Program," to ensure the continuing quality of fuel oil to power the DGs.

3.0 TECHNICAL EVALUATION

3.1 Proposed Change to LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air,"

Requirements Each DG is provided with a fuel oil capacity sufficient to operate that diesel for a period of 7 days. This onsite fuel oil capacity is sufficient to operate the DGs long enough to place the unit in a shutdown condition and to bring in replenishment fuel from an offsite location.

The standby alternating current (ac) power sources are a part of the primary success path and function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Restrictions on the diesel fuel oil and lube oil supplies are retained in the TS to satisfy 10 CFR 50.36(c)(2)(i), since they support the operation of the standby ac power sources. The proposed changes would revise TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS and replacing them with the associated diesel operating time. The fuel oil and lube oil volumes necessary to support a duration-based diesel operating time may now be modified under licensee control pursuant to 10 CFR 50.59.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each emergency diesel generator (EOG) has a lube oil inventory capable of supporting a minimum of 7-days of operation. This supply is sufficient to allow the operator to replenish lube oil from outside sources.

In order to meet a 7-day supply of stored diesel fuel oil and lube oil for a DG, TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," currently contains numerical volume requirements associated with a 7-day supply for each EOG as measured by volume, in gallons. The TS Bases currently discuss that the numerical volume requirements are based on meeting a 7-day supply. The proposed change revises TS 3.8.3 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS so that the diesel fuel oil and lube oil volumes necessary to support a 7-day DG operating time may subsequently be modified under licensee control pursuant to 10 CFR 50.59. The revised TSs continue to require that the stored diesel fuel oil and lube oil inventory for each DG have a 7-day supply available. The removal of the TS numerical value volume requirement does not change the current plant configuration or the current volume requirements, or the current 7-day basis for the fuel oil and lube oil volume requirements.

Section 3.3 below discusses the methodology the licensee will use to calculate the stored diesel fuel oil and lube oil numerical volume basis. The use of this methodology will ensure that a 7-day supply of stored diesel fuel oil and lube oil for each DG will be met, thereby providing assurance that the lowest functional capability or performance levels of the DG required for safe operation of the facility will continue to be met.

Based on the above evaluation, the NRC staff finds the change to the LCO 3.8.3 requirements to be acceptable.

3.2 Proposed Change to Actions Table for TS 3.8.3, "Diesel Fuel, Oil Lube Oil. and Starting Air" Currently, Condition A is entered when the fuel oil volume requirement is not met, and Condition B is entered when the lube oil inventory requirement is not met. The current TS Bases state that the numerical volume requirements in Condition A and Condition B are based on volumes less than a 7-day supply but at least a 6-day supply. The proposal would remove the volumetric requirements from the TS and would modify Condition A and Condition B to add a duration-based requirement such that the Conditions are entered when the stored fuel oil and lube oil inventory is less than a 7-day supply, but greater or equal to a 6-day supply for one or more DGs. The use of "greater than or equal to" for the low volume 6 day supply is identified as a deviation from the approved TSTF Traveler in the LAR. Although it is a deviation from the language used in the approved traveler, this is equivalent to the current TSs because the current low volume level numeric requirement is preceded by a less-than-or-equal sign. No other parts of Condition A and Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application.

Section 3.3 below discusses the methodology the licensee will use to calculate the stored diesel fuel oil and lube oil numerical volume basis. The use of this methodology will ensure that the 7-day and 6-day supply of stored diesel fuel oil and lube oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC approved methods.

Based on the above evaluation, the NRC staff considers the change to the TS 3.8.3 Actions Table to be acceptable.

3.3 Proposed Change to SRs 3.8.3.1 and 3.8.3.2 Currently, SRs 3.8.3.1 and 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. The licensee proposes to revise SRs 3.8.3.1 and 3.8.3.2 to reflect the change in LCO requirements, namely, that a 7-day supply (rather than a specified numerical volume) be available for each DG. As a result, SRs 3.8.3.1 and 3.8.3.2 would require the licensee to verify that the stored diesel fuel oil and lube oil inventory is greater than or equal to a 7-day supply for each DG.

No other revision to these SRs is proposed. The licensee proposes to remove the current numerical volume requirement from the TS, and replace it with the associated current 7-day supply basis for fuel oil and lube oil for each DG.

The licensee describes the methodology used in determining the 7-day as well as the 6-day supply of stored diesel fuel oil and lube oil for each diesel generator on page 5 of 6 of the LAR as follows:

The specific volume of fuel oil equivalent to a 7 and 6-day supply is calculated using the NRC approved methodology described in Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators" and ANSl-N195 1976, "Fuel Oil Systems for Standby Diesel-Generators." The specific volume of lube oil equivalent to a 7-day and 6-day supply is based on the diesel generator manufacturer's consumption values for the run time of the diesel generator.

Additionally, on pages 3 and 4 of the LAR, the licensee clarified how the volume of fuel necessary to support operation of the standby DGs is managed at the site:

To clarify the PNPP calculations that determine fuel oil volume required to support operation of the standby diesel generators for a 7-day event do not include an explicit allowance for fuel oil consumption due to periodic testing.

Instead, FENOC administratively controls fuel oil volumes in support of required periodic testing, such that the TS required volumes are maintained above the 7-day supply requirement. As described in ANSI N195-1976, including an allowance for fuel consumption required by periodic testing is a consideration in determining the size of the fuel oil storage tank.

ANSI N195-1976 discusses how the stored diesel fuel oil requirement shall be calculated based upon the DGs operating at the minimum required capacity for the plant condition which is most limiting for the calculation of such capacity. One method for calculating the stored diesel fuel oil supply takes into account the time dependence of DG loads. That is, if DG loads increase or decrease during the event, the load changes shall be included in the required fuel storage calculation. If the design includes provisions for an operator to supply power to equipment other than the minimum required for the plant condition, such additional loads shall be included in the calculation of required fuel storage capacity. RG 1.137, Revision 1, supplements the above by stating that for the time-dependent load method, the minimum required capacity should include the capacity to power the engineered safety features. A minimum margin of 10 percent shall be added to the calculated storage requirement if the alternate conservative calculation discussed next is not used. Another method for calculating the stored diesel fuel oil supply, which is more conservative than the time-dependent load method, is to calculate the storage capacity by assuming that the diesel operates continuously for 7 days at its rated capacity.

Since both methods described in ANSI N195-1976 are approved for use by the NRC in RG 1.137, Revision 1, and the licensee agrees to calculate the volume of fuel oil in accordance with RG 1.137, Revision 1, there is reasonable assurance that the volume of fuel oil calculated by the licensee will meet the new duration based limits specified in SR 3.8.3.1. Additionally, the licensee will administratively control the amount of fuel oil required to support periodic testing such that the volume of fuel required for testing will exist in addition to the 7-day supply requirement.

One variable used in both stored diesel fuel oil calculation methods is the fuel consumption rate.

The property of diesel fuel oil having the most significant effect on the fuel consumption rate is the energy content (heating value) of the fuel. There are standards which correlate the energy content to the fuel's American Petroleum Institute (API) gravity or absolute specific gravity. At a minimum, plants calculate their required fuel storage values assuming the most limiting API gravity or absolute specific gravity, and therefore, the most limiting fuel energy content. As long as the fuel oil placed in the storage tank is within the API gravity range or absolute specific gravity range specified by the licensee, the calculations of fuel consumption and required stored volume remain valid. Current SR 3.8.3.3 requires new fuel to be tested in order to verify that the new fuel API gravity or absolute specific gravity is within the range assumed in the diesel fuel oil consumption calculations through implementation of the current PNPP TS 5.5.9, "Diesel Fuel Oil Testing Program."

The lube oil inventory equivalent to a 7-day supply and 6-day supply associated with Condition B, is based on the diesel generator manufacturer consumption values for the run time of the DG.

The above methods provide assurance that the necessary quantity and quality of diesel fuel oil and lube oil will be maintained. Therefore, the NRC staff considers the duration-based changes to SR 3.8.3.1 and SR 3.8.3.2 to be acceptable.

3.4 TS Bases Changes The proposed change deletes the reference to Appendix B of ANSI N195-1976 in the TS Bases for TS 3.8.3. As a result, there will only be a reference to ANSI N195-1976. LCO 3.8.3 requires, in part, that the stored diesel fuel oil and lube oil shall be within limits for each standby diesel generator. The basis for these limits is derived from RG 1.137, Revision 1, and Appendix B of ANSI N195-1976. For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. RG 1.137, Revision 1, addresses the recommended fuel oil practices, as supplemented by ANSI N195-1976, Appendix B. The fuel oil properties that are checked to ensure the proper quality of the fuel oil are sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level. Current SR 3.8.3.3 verifies these limits and remains unchanged.

The TS bases changes are consistent with the proposed TS changes. PNPP makes TS bases changes in accordance with the TS 5.5.11, 'Technical Specifications (TS) Bases Control Program."

3.5 Technical Conclusion The proposed changes to LCO 3.8.3 continue to provide assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility will continue to be met. Therefore, LCO 3.8.3 will continue meet 10 CFR 50.36(c)(2).

The SRs 3.8.3.1 and 3.8.3.2 continue to provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Therefore, SRs 3.8.3.1 and 3.8.3.2 will continue to meet 10 CFR 50.36(c)(3).

Therefore, the NRC staff finds the proposed changes to be acceptable.

3.6 Correction of Typographical Error During its review of the amendment request, the NRC staff identified an error in the title of TS 3.8.3 that was inadvertently introduced by the staff during the issuance of Amendment No. 111 on March 30, 2000 (ADAMS Accession No. ML003698612). Specifically, in the title for TS 3.8.3, the staff erroneously omitted the word "Air" from end of the title. The licensee only requested the addition of "(continued)" at the bottom of TS 3.8-21; no other changes to TS 3.8.3 or TS 3.8-21 were requested by the licensee. The header for TS page 3.8-21 correctly lists the title as "Diesel Fuel Oil, Lube Oil, and Starting Air." Additionally, the LCO 3.8.3 identifies the system as the "starting air" system.

The NRC staff has determined that the error was introduced by the staff during the preparation of the new TS page and is entirely editorial in nature. The correction to the title for TS 3.8.3 does not change any of the conclusions in the safety evaluation associated with Amendment No. 111 and does not affect the associated notice to the public.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified on June 9, 2017 of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes the surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (81 FR 92869, dated December 20, 2016). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: P. Snyder, NRR Date of issuance: June 2 9 , 2O1 7

D. Hamilton

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT CONCERNING ADOPTION OF TSTF-501, REVISION 1, "RELOCATION OF DIESEL FUEL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" (CAC NO. MF8693) (L-16-236) DATED JUNE 29, 2017 DISTRIBUTION:

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