ML16224A342

Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3

ML16224A342
Person / Time
Site:	Peach Bottom
Issue date:	08/11/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16224A342 (11)

Text

200 Exelon Way Kennett Square, PA 19348 Exelon Generation www.exeloncorp.com 10 CFR 50.90 August 11, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Response to Request for Additional Information Regarding Proposed License Amendment concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3

References:

1) Letter from J. Barstow (Exelon Generation Company, LLC) to the U.S.

Nuclear Regulatory Commission, .. Application to Revise Technical Specifications to Adopt TSTF-501-A, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,' Revision 1, using the Consolidated Line Item Improvement Process (ML16173A371 ), .. dated June 20, 2016.

2) E-mail correspondence from R. Ennis (U.S. Nuclear Regulatory Commission) to S. J. Hanson (Exelon Generation Company, LLC),

.. Peach Bottom Atomic Power Station - Request for Additional Information Regarding Proposed License Amendment concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) (ML16221A680),"

dated July 26, 2016.

By application dated June 20, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS),

Units 2 and 3 (Reference 1). The amendments would revise the Technical Specification (TS) 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on 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 .. (ADAMS Accession No. ML090510686).

U.S. Nuclear Regulatory Commission Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements August 11, 2016 Page 2 In the Reference 2 e-mail correspondence, the U.S. Nuclear Regulatory Commission (NRC) requested additional information. Attachment 1 contains Exelon's response to the NRC request for additional information. Attachment 2 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). Attachment 2 replaces the TS Bases markups submitted in Reference 1. The TS page markups submitted in Reference 1 are not affected by this response.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the U.S. NRC in Reference

1. The additional information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments in this response.

If you have any questions concerning this response, please contact Stephanie J. Hanson at 610-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11 lh day of August 2016.

Respectfully,

~~~

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3

2. Markup of Proposed Technical Specifications Bases Pages (Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Pennsylvania Bureau of Radiation Protection S. T. Gray, State of Maryland

ATTACHMENT 1 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 5Q-277 and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3

Response to Request for Additional Information Attachment 1 TSTF-501-A DG Lube Oil Inventory Requirements Page 1 of 3 Docket Nos. 50-277 and 50-278 By application dated June 20, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The amendments would revise the Technical Specification (TS} 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on 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 .. (ADAMS Accession No. ML090510686).

The NRC staff has determined that additional information is needed to complete its review. The specific requests for additional information (RAI) questions are restated below along with Exelon*s response.

Question 1 (DORL-RAI-1 ):

Attachment 3 to the licensee*s application dated June 20, 2016, provided marked up TS Bases pages (for information only) which would be implemented, in accordance with the TS Bases Control Program, as part of the proposed amendment. The proposed markup for the Bases for TS 3.8.3, Limiting Condition for Operation (LCO), Action B.1 is not consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. Specifically, the licensee did not propose any changes to the first sentence in this section. In addition, TSTF-501, Revision 1, includes changes to the TS Bases for SR 3.8.3.2. The licensee did not propose any Bases changes for PBAPS SR 3.8.3.2. The licensee's application did not identify these differences as proposed deviations to the TSTF. Please provide justifications for these deviations or provide a supplement with proposed TS Bases changes consistent with TSTF-501, Revision 1.

Response

Exelon proposes to revise the TS Bases to be consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1.

For information, a copy of the revised marked up TS Bases pages that reflect the proposed change are provided in Attachment 2.

Question 2 (DORL-RAI-2):

The NRC's model safety evaluation for TSTF-501, Revision 1, explains the reason why licensees would want to adopt this TSTF. Specifically, the DG fuel oil numerical volume inventory requirement (in gallons) may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Replacing the TS inventory requirements for stored fuel oil in gallons with inventory requirements specified in number of days of DG operating time could allow the licensee to make changes to the required number of gallons under licensee control, and therefore, may not require NRC prior approval.

Since the fuel oil inventory is based on 7-days of DG operating time, the 7-day inventory requirement also applies to the DG lube oil supply.

Response to Request for Additional Information Attachment 1 TSTF-501-A DG Lube Oil Inventory Requirements Page 2 of 3 Docket Nos. 50-277 and 50-278 As discussed in the licensee's application, Exelon is only proposing to adopt the TSTF-501 changes pertaining to lube oil (i.e., fuel oil changes are not proposed). The licensee's application indicated that the technical justifications in the NRC staff's model SE are applicable to the proposed changes to the lube oil requirements for PBAPS. However, given that the model SE focuses on the reasons for potential changes in fuel oil volume requirements, the NRC staff concludes that the model SE is not sufficient to address the reason for changing only the lube oil requirements. Since the nature of consumption of fuel oil and lube oil are different, it is not clear of the reason for the proposed amendment. Please provide additional justification for the reasons for the proposed amendment request (e.g., reasons why the number of gallons of lube oil, currently required in the TSs for the 7-day DG operating period, may change).

Response

The diesel generator lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated diesel generator 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 diesel generator has a lube oil inventory capable of supporting a minimum of 7 days of operation. The stored inventory ensures 7 days of operation with manual replenishment as needed.

In order to meet a 7-day supply of stored lube oil for each diesel generator, TS 3.8.3, 11 Diesel Fuel Oil, Lube Oil, and Starting Air, 11 currently contains numerical volume requirements associated with a 7-day supply for each diesel generator. PBAPS 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 relocating the current stored diesel lube oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control.

The TS are modified so that the stored diesel lube oil inventory will require that a 7-day supply be available for each diesel generator. Additionally, NRC Information Notice 96-67, 11 Vulnerability of Emergency Diesel Generators to Fuel Oil/Lubricating Oil Incompatibility, II noted that the reduced amount of sulfur in Ultra Low Sulfur Diesel (ULSD) will result in more unreacted additive in the lubricating oil. This may result in the formation of deposits when some of the oil is burned, which may affect the volume of lube oil required to support 7-day operation.

Relocating the specific volume of lube oil equivalent to a 7-day supply to licensee control will allow licensees to adjust the required volume without submitting a license amendment request to the NRC. No changes to the current plant configuration, current numerical volume requirements, or current 7-day basis are proposed in the application; PBAPS proposes to relocate the current numerical volume requirements from the TS to the TS Bases and relocate the associated current 7-day basis from the TS Bases to the TS.

Currently, Condition B is entered when the stored diesel lube oil numerical volume requirements are not met. As discussed in the current TS Bases, the numerical volume requirements in Condition B are based on volumes less than a 7 -day supply, but greater than a 6-day supply.

The proposed amendment will relocate the volumetric requirements from the TS and place them in the TS Bases. The TS are modified so that Condition B is entered when the stored diesel lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more diesel generators.

Response to Request for Additional Information Attachment 1 TSTF*501-A DG Lube Oil Inventory Requirements Page 3 of 3 Docket Nos. 50-277 and 50-278 No other parts of Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application; PBAPS proposes to relocate the current numerical volume requirements that dictate Condition entry from the TS to the TS Bases and relocate the associated current less than 7 -day but greater than 6-day basis for Condition entry from the TS Bases to the TS.

No other parts of the SRs (i.e., Frequencies) are proposed to be modified in the application; PBAPS proposes to relocate the current numerical volume requirement verification from the TS to the TS Bases and relocate the associated current 7-day basis for verification from the TS Bases to the TS.

The lube oil inventory equivalent to a ?*day supply, as well as the 6-day supply associated with Condition B, is based on the diesel generator manufacturer's consumption values for the run time of the diesel generator.

The above method still provides assurance that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met. Therefore, the proposed change to SR 3.8.3.2 is acceptable.

ATIACHMENT2 Markup of Technical Specifications Bases Pages (For Information Only)

Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-2n and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Unit 2 TS Bases Pages B 3.8-51 B 3.8-53 Unit 3 TS Bases Pages B 3.8-51 B 3.8-53

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

With fuel oil level < 33,000 gal in a storage tank (which includes margin for the unusable volume of oil), 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 (with fuel oil transfer between storage tanks). These circumstances may be caused by events such as:

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

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

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

In this condition,

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inventory < 350 gal , sufficient lube oil to the 7 day support 7 day of continuous DG operation at full load conditions ~ not ee available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day su This restriction allows sufficient o aining requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the DG The lube oil inoperable. This period is acceptable based on the inventory remaining capacity (> 6 days), the low rate of usage, the equivalent to a 6 fact that procedures will be initiated to obtain replenishment, and the low probability of an event during day supply is 300 this brief period.

gallons.

(continued)

PBAPS UNIT 2 B 3.8-51 Revision No. 114

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS .L1 (continued) 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.

With a Required Action and associated Completion Time of Condition A, B, C, D, or E not met, or the stored diesel fuel oil , 1 ube oil , or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate useable inventory of fuel oil in the storage tanks to support each DG's operation of all four DGs for 7 days at the worst case post accident time-dependent load profile.

The 7 day period is sufficient time to place both Unit 2 and Unit 3 in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory (combined inventory in the DG lube oil sump, lube oil storage tank, and in a seismically qualified structure) is available to support at least 7 days of full load operation for each DG. Alt~o~§~ t~c 350 §alloA rcq~ircfficAt exceeds the DG rna cturer's consumption values for the run time of the The lube oil , ~ entire inventory of lube oil required by Technical Specifi tions shall be stored in a location which is seismic inventory equivalent Class I and is protected against other natural phenomena.

to a 7 day supply is Implicit in this SR is the requirement to verify the 350 gallons and is based on PBAPS UNIT 2 B 3.8-53 Revision No. 122

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

With fuel oil level < 33,000 gal in a storage tank (which includes margin for the unusable volume of oil), 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 (with fuel oil transfer between storage tanks). These circumstances may be caused by events such as:

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

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

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered suffic i ent to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

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the7day

-.~----7~ ~ 1u support oi 1 inventory ~ sufficient 1 ube oi 1 to days of continuous DG operation at full load condition ffitt1 not fre available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day suppl This restriction allows sufficient The lube oil time for obt *

• g the requisite replacement volume. A inventory perio ~8 hours is considered sufficient to complete equivalent to a 6 storation of the required volume prior to declaring the DG inoperable. This period is acceptable based on the day supply is 300 remaining capacity (> 6 days), the low rate of usage, the gallons. fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

(continued)

PBAPS UNIT 3 B 3.8-51 Revision No. 119

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

With a Required Action and associated Completion Time of Condition A, B, C, D, or E not met, or the stored diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate useable inventory of fuel oil in the storage tanks to support each DGis operation of all four DGs for 7 days at the worst case post accident time-dependent load profile.

The 7 day period is sufficient time to place both Unit 2 and Unit 3 in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory (combined inventory in the DG lube oil sump, lube oil storage tank, and in a seismically qualified structure) is available to support at least 7 days of full load operation for each D A l t~ou§~ t~e 350 §alloA requireffieAt exceeds the DG acturerls consumption values for the run time of the The lube oil , tfie entire inventory of lube oil required by Technical inventory equivalent Spe 'fications shall be stored in a location which is seismic Class I and is protected against other natural pheonomena.

to a 7 day supply is Impl *cit in this SR is the requirement to verify the 350 gallons and is based on PBAPS UNIT 3 B 3.8-53 Revision No. 124