ML14239A491

Issuance of Amendments Regarding the Adoption of Technical Specification Task Force 501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (TAC Nos. ME9794-95)

ML14239A491
Person / Time
Site:	Calvert Cliffs
Issue date:	10/21/2014
From:	Nadiyah Morgan Plant Licensing Branch 1
To:	George Gellrich Calvert Cliffs
Morgan N
References
TAC ME9794, TAC ME9795
Download: ML14239A491 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 21, 2014 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2-ISSUANCE OF AMENDMENTS REGARDING THE ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE 501-A, REVISION 1, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" (TAC NOS. ME9794 AND ME9795)

Dear Mr. Gellrich:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 306 to Renewed Facility Operating License No. DPR-53 and Amendment No. 284 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2.

The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 2, 2012, as supplemented by letters dated November 26,2012, July 1, 2013, February 7, 2014, and October 3, 2014.

The amendments revise TS 3.8.3, "Diesel Fuel Oil" by removing the current stored diesel fuel oil numerical volume requirements from the TSs and replacing them with diesel generator operating time requirements. The amendments also revise TS 3.8.1, "AC Sources-Operating" by replacing the specific diesel generator day tank fuel oil numerical volume requirements with the requirement to maintain greater than or equal to a 1-hour supply of fuel oil.

The revisions are consistent with the Commission-approved Technical Specification Task Force Traveler 501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," issued in the Federal Register (FR) on May 26, 2010 (75 FR 29588).

G. Gellrich A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 306 to DPR-53

2. Amendment No. 284 to DPR-69

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE CALVERT CLIFFS NUCLEAR POWER PLANT, LLC EXELON GENERATION COMPANY, LLC CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO.1 DOCKET NO. 50-317 Amendment No. 306 Renewed License No. DPR-53

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

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, LLC (the licensee) dated October 2, 2012, as supplemented by letters dated November 26, 2012, July 1, 2013, February 7, 2014 and October 3, 2014, 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.

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 Renewed Facility Operating License No. DPR-53 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.

3. Implementation Requirements A. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

B. Upon implementation of Amendment No. 306, the licensee shall incorporate in the Updated Final Safety Analysis Report (UFSAR) the following information as set forth in the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description with the next UFSAR update:

The specific emergency diesel generator fuel oil volumes (equivalent to duration based requirements) contained in the fuel oil storage tanks referenced in Technical Specification 3.8.3 and the day tanks referenced in Technical Specification 3.8.1 are calculated using the method provided in American National Standards Institute N195-1976, Section 5.4, as endorsed by Regulatory Guide 1.137, Revision 1, Section C. I. c. The fuel oil calculation is based on applying the conservative assumption that the emergency diesel generator is operated continuously at rated capacity. This is one of two approved methods specified in Regulatory Guide 1.137, Revision 1.

C. The UFSAR change shall be implemented in the next periodic update of the UFSAR, in accordance with Title 10 of the Code of Federal Regulations Section 50.71 (e).

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: October 21 , 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE CALVERT CLIFFS NUCLEAR POWER PLANT, LLC EXELON GENERATION COMPANY. LLC CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NO. 2 DOCKET NO. 50-318 Amendment No. 284 Renewed License No. DPR-69

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

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, LLC (the licensee) dated October 2, 2012, as supplemented by letters dated November 26, 2012, July 1, 2013, February 7, 2014, and October 3, 2014, 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.

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 Renewed Facility Operating License No. DPR-69 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 284, are hereby incorporated into this license.

The licensee shall operate the facility in accordance with the Technical Specifications.

3. Implementation Requirements A. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

B. Upon implementation of Amendment No. 284, the licensee shall incorporate in the Updated Final Safety Analysis Report (UFSAR) the following information as set forth in the NRC staff's safety evaluation attached to this amendment, and shall submit the revised description with the next UFSAR update:

The specific emergency diesel generator fuel oil volumes (equivalent to duration based requirements) contained in the fuel oil storage tanks referenced in Technical Specification 3.8.3 and the day tanks referenced in Technical Specification 3.8.1 are calculated using the method provided in American National Standards Institute N195-1976, Section 5.4, as endorsed by Regulatory Guide 1.137, Revision 1, Section C. I. c. The fuel oil calculation is based on applying the conservative assumption that the emergency diesel generator is operated continuously at rated capacity. This is one of two approved methods specified in Regulatory Guide 1.137, Revision 1.

C. The UFSAR change shall be implemented in the next periodic update of the UFSAR, in accordance with Title 10 of the Code of Federal Regulations Section 50.71 (e).

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: October 21 , 2014

ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 284 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 DOCKET NOS. 50-317 AND 50-318 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 Replace the following pages of the 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 Pages Insert Pages 3.8.1-12 3.8.1-12 3.8.3-1 3.8.3-1 3.8.3-2 3.8.3-2 3.8.3-3 3.8.3-3 3.8.3-4 3.8.3-4

(4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:

(1) Maximum Power Level Exelon Generation is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 227 to Facility Operating License No. DPR-53, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 227. For SRs that existed prior to Amendment 227, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 227.

(3) Additional Conditions The Additional Conditions contained in Appendix C as revised through Amendment No. 305 are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Additional Conditions.

(4) Secondary Water Chemistry Monitoring Program Exelon Generation shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

Amendment No. 306

(4) Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now and hereafter applicable; and is subject to the additional conditions specified and incorporated below:

(1) Maximum Power Level Exelon Generation is authorized to operate the facility at reactor steady-state core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 284 are hereby incorporated into this license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 201 to Facility Operating License No. DPR-69, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 201. For SRs that existed prior to Amendment 201, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 201.

(3) Less Than Four Pump Operation The licensee shall not operate the reactor at power levels in excess of five (5) percent of rated thermal power with less than four (4) reactor coolant pumps in operation. This condition shall remain in effect until the licensee has submitted safety analyses for less than four pump operation, and approval for such operation has been granted by the Commission by amendment of this license.

(4) Environmental Monitoring Program If harmful effects or evidence of irreversible damage are detected by the biological monitoring program, hydrological monitoring program, and the radiological monitoring program specified in the Appendix 8 Technical Amendment No. 284

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.4 ------------------ NOTES ------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients below the load limit do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This Surveillance Requirement shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.3 or SR 3.8.1.9.

Verify each DG is synchronized and loaded, 31 days and operates for~ 60 minutes at a load

~ 4000 kW for DG 1A and ~ 2700 kW for DGs 1B, 2A, and 2B.

SR 3.8.1.5 Verify each day tank contains ~ a one hour 31 days supply.

SR 3.8.1.6 Check for and remove accumulated water from 31 days each day tank.

SR 3.8.1.7 Verify the fuel oil transfer system operates 31 days to automatically transfer fuel oil from storage tank[s] to the day tank.

CALVERT CLIFFS - UNIT 1 3.8.1-12 Amendment No. 306 CALVERT CLIFFS - UNIT 2 Amendment No. 284

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil storage tank A.1 Restore fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (FOST) 1A with fuel volume to within oil volume less than limits.

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

CALVERT CLIFFS - UNIT 1 3.8.3-1 Amendment No. 306 CALVERT CLIFFS - UNIT 2 Amendment No. 284

Di ese 1 Fue 1 Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. -------- NOTE-------- B.1 Verify combined 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Only applicable to available fuel oil Unit 1. volume of FOST 21 and

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OPERABLE FOST 11 greater than or equal FOST 21 with fuel oil to a 6 day supply.

volume less than a 7 day supply. AND B.2 Verify combined 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> available fuel oil volume of FOST 21 and AND OPERABLE FOST 11 greater than or equal Once per 31 days to a 7 day supply. thereafter CALVERT CLIFFS - UNIT 1 3.8.3-2 Amendment No. 306 CALVERT CLIFFS - UNIT 2 Amendment No. 284

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. --------NOTE-------- C.1 Verify combined 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Only applicable to available fuel oil Unit 2. volume of FOST 21 and OPERABLE FOST 11 greater than or equal FOST 21 with fuel oil to a 6 day supply.

volume less than a 7 day supply. AND C.2 -------NOTES-------

1. Only applicable during MODE 1, 2, 3, or 4.

2. Only applicable between April 1 and September 30.

Restore FOST 21 fuel 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> oil volume to within limits.

C.3 Restore FOST 21 fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> oil volume to within limits.

D. One or more DGs with D.1 Restore fuel oil 7 days stored fuel oil total total particulates to particulates not within limits.

within limits.

CALVERT CLIFFS - UNIT 1 3.8.3-3 Amendment No. 306 CALVERT CLIFFS - UNIT 2 Amendment No. 284

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One or more DGs with E.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.

limits.

F. Required Action and F.1 Declare associated Immediately associated Completion DG(s) inoperable.

Time not met.

One or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil volume of: 31 days

a. FOST 1A ~ a 7 day supply, and

b. FOST 21 ~ a 7 day supply.

SR 3.8.3.2 Verify fuel oil properties of new and stored In accordance fuel oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Oil Fuel Oil Testing Program. Testing Program CALVERT CLIFFS - UNIT 1 3.8.3-4 Amendment No. 306 CALVERT CLIFFS - UNIT 2 Amendment No. 284

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 284 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 CALVERT CLIFFS NUCLEAR POWER PLANT. LLC EXELON GENERATION COMPANY. LLC CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

By application dated October 2, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12278A012), as supplemented by letters dated November 26,2012 (ADAMS Accession No. ML12333A316), July 1, 2013 (ADAMS Accession No. ML13189A130) February 7, 2014 (ADAMS Accession No. ML14042A046), and October 3, 2014 (ADAMS Accession No. ML14280A120, Calvert Cliffs Nuclear Power Plant, LLC, the licensee, submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (Calvert Cliffs), Technical Specifications (TSs). The NRC staff published a no significant hazards consideration determination in the Federal Register (FR) on March 4, 2013 (78 FR 14130). The supplements dated November 26, 2012, July 1, 2013, February 7, 2014, and October 3, 2014, provided additional information that clarified the application, but did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.

The proposed changes revise TS 3.8.3, "Diesel Fuel Oil" by removing the current stored diesel fuel oil numerical volume requirements from the TSs and replacing them with diesel generator (DG) operating time requirements consistent with NRC staff approved Technical Specifications Task Force (TSTF) Standard Technical Specifications Traveler 501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." The proposed changes also similarly revise TS 3.8.1, "AC Sources-Operating" by replacing the specific DG day tank fuel oil numerical volume requirements with the requirement to maintain greater than or equal to a 1-hour supply of fuel oil.

Enclosure

2.0 BACKGROUND

The licensee requested changes to the Calvert Cliffs TSs to adopt TSTF-501, Revision 1 (ADAMS Accession No. ML090510686). The licensee's current TSs contain numerical volume requirements for stored DG fuel. Any changes to the numerical volume requirements currently require prior approval from the NRC. 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. By adopting TSTF-501, Revision 1, the numerical volume requirements for stored diesel fuel oil are removed from the TS. As a result, the numerical volume requirements for stored diesel fuel oil could be modified under licensee control, as long as the required supply of fuel specified in the licenses is maintained. Such modifications would take place under the provisions of Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.59, and therefore, would not necessarily require prior NRC approval.

In the October 2, 2012 application, the licensee proposed the following deviations from the changes described in TSTF-501, Revision 1, and the NRC staff's model safety evaluation (SE) published in the Federal Register on May 26, 2010, (75 FR 29588) as part of the consolidated line item improvement process (CLIIP) Notice of Availability:

• No changes associated with lube oil inventory are included in this proposed change because the Calvert Cliffs TS do not include the requirements for DG lube oil inventory.

• A revision toTS 3.8.1, "AC Sources-Operating," following an approach similar to the TS 3.8.3 changes discussed below. The proposed revision to surveillance requirement (SR) 3.8.1.5 replaces the specific DG day tank numerical volume requirements with the requirement to maintain greater than or equal to a one-hour supply of fuel oil.

The proposed changes would revise TS 3.8.3, "Diesel Fuel Oil" by removing the current stored diesel fuel oil volume level numerical requirements from the TS and replacing them with 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 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 (Fuel Oil Storage Tank (FOST) 1A), Condition B (applicable to Unit 1 only) or Condition C (applicable to Unit 2 only) in the Action table. Currently, Condition A, B, or C is entered when the stored diesel fuel oil volume level numerical requirements are not met. As discussed in the current TS Bases, the numerical diesel fuel oil volume requirement in Condition A is based on a volume of less than a 7-day supply, and greater than or equal to an a 6-day supply. The numerical diesel fuel oil level requirement in Condition Band Cis based on a volume of less than a 7-day supply. The proposed revision would remove the numerical requirements from the TS. The TS would be modified so that Condition A is entered when the diesel fuel oil in FOST 1A has less than a 7-day supply, but greater than or equal to a 6-day fuel oil supply.

Condition B (applicable to Unit 1 only) would be entered when the stored diesel fuel oil in FOST 21 is less than a 7-day supply. Condition C (only applicable to Unit 2) is entered when stored diesel fuel oil in FOST 21 is less than a 7-day supply.

• Revise SR 3. 8. 3. 1. Currently, SR 3. 8. 3.1 requires the licensee to verify that the stored diesel fuel oil volume level numerical requirements are met. As discussed in the current TS Bases, the numerical requirements in SR 3.8.3.1 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 requires the licensee to verify that the stored diesel fuel oil inventories in FOST 1A and FOST 21 are greater than or equal to a 7-day supply for each required DG.

The licensee stated that the license amendment request is consistent with NRC-approved TSTF-501, Revision 1. The availability of this TS improvement was announced in the Federal Register on May 26, 2010 (75 FR 29588) (Reference 5) as part of the CLIIP.

3.0 REGULATORY EVALUATION

3.1 Proposed Change to Limiting Conditions for Operation (LCO) 3.8.3. "Diesel Fuel Oil,"

Requirements The regulation at 10 CFR 50.36, "Technical specifications," provides the regulatory requirements for the content required in the TS. The regulation at 10 CFR 50.36(c)(2)(i) states that TS will include limiting conditions for operation (LCO) which are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." As stated in 10 CFR 50.36, the TS also include SRs to assure that the LCOs are met.

Regulatory Guide (RG) 1.137, Revision 1 describes a method acceptable to the NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby diesel generators. Section C.1.c of RG 1.137 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."

3.2 Proposed Change to Action Table forTS 3.8.3, "Diesel Fuel Oil,"

Paragraph 50.36(c)(2)(i) goes on to state 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." Pursuant to this amendment, Condition A, Condition B, and Condition C in the Action table forTS 3.8.3, "Diesel Fuel Oil," are revised to reflect the change in LCO requirements. Currently, Condition A, Condition B, or Condition C are entered when the stored diesel fuel oil volume numerical requirements are not met. As discussed in the current TS Bases, the numerical volume requirements in Condition A are based on volumes less than 7-day supply and greater than or equal to a 6-day supply. The proposal removes the volumetric requirements from the TS and replaces them with diesel generator operating time requirements. The TS is modified so that Condition A is entered when the stored diesel fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply for fuel oil storage tank 1A. Condition B (applicable to Unit 1 only) is entered when the when the fuel oil in FOST 21 is less than a 7-day supply. Condition C (applicable to Unit 2 only) is entered when stored diesel in FOST 21 is less than a 7-day supply.

These remedial actions are permitted by 10 CFR 50.36(c)(2)(i), and the technical justification for allowing these remedial actions is discussed in Section 4.0 of this SE.

3.3 Proposed Change to SR 3.8.3.1 Paragraph 50.36(c)(3) states TS will include SRs which 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 [LCOs] will be met."

Currently, SR 3.8.3.1 verifies that the stored diesel fuel oil numerical volume requirements are met. SR 3.8.3.1 is revised to reflect a change in LCO requirements. As a result, the SR is modified so that SR 3.8.3.1 verifies that the stored diesel fuel oil inventory is greater than or equal to a 7-day supply in each fuel oil storage tank, and the SR no longer includes numerical volume requirements.

3.4 Proposed Change to SR 3.8.1.5 Currently, SR 3.8.1.5 verifies that the DG day tank numerical volume requirements are met. As with the changes noted above, the proposed revision to SR 3.8.1.5 replaces the specific day tank numerical volume requirement with the requirement to maintain greater than or equal to a 1-hour supply of fuel oil.

4.0 TECHNICAL EVALUATION

4.1 LCO 3.8.3 Each required DG is provided with a fuel oil capacity sufficient to operate that diesel for a period of 7-days while the DG is supplying maximum load demand. This on site fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

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. Diesel fuel oil is retained in the TS to satisfy 10 CFR 50.36(c)(2)(i) since it supports the operation of the standby AC power sources. The proposed changes revise TS 3.8.3, "Diesel Fuel Oil," by removing the current stored diesel fuel oil numerical volume requirements from the TS and replacing them with the required diesel operating time so that the fuel oil volumes necessary to support the required diesel operating time may be modified under licensee control.

In order to meet a 7-day supply of stored diesel fuel oil for each required DG, TS 3.8.3, "Diesel Fuel Oil," currently contains numerical volume requirements associated with a 7-day supply for each required DG as measured by volume, in gallons. The TS Bases currently state that the numerical volume requirements are based on meeting a 7-day supply. The proposed change would revise TS 3.8.3 by removing the current stored diesel fuel oil numerical volume requirements from the TS so that the fuel oil volume necessary to support the required diesel operating time may subsequently be modified under licensee control pursuant to 10 CFR 50.59.

The revised TS continue to require that the stored diesel fuel oil inventory has a 7-day supply available for each required DG. The removal of the TS numerical volume requirement does not change the current plant configuration or the current 7-day basis for the fuel oil and lube oil volume requirements.

Section 4.3 discusses the methodology as to how the stored diesel fuel oil numerical volume basis in the TS Bases may be modified under licensee control. The use of this methodology is consistent with RG 1.137 and will ensure that a 7-day supply of stored diesel fuel 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, and the considerations discussed in Section 4.3 below, the NRC staff finds the change to the LCO 3.8.3 requirements to be acceptable.

4.2 Action Table forTS 3.8.3 Currently, Condition A is entered when the stored diesel fuel oil numerical volume requirements are not met. As discussed in the current TS Bases, the numerical volume requirements in Condition A are based on volumes less than a 7-day supply and greater than a 6-day supply, Condition B (applicable to Unit 1 only) is less than a 7-day supply, or Condition C {applicable to Unit 2 only) is less than a 7-day supply. The proposal would remove the volumetric requirements from the TS. The TS are modified so that Condition A is entered when the stored diesel fuel oil in FOST 1A is less than a 7-day supply and greater than or equal to a 6-day supply. Condition B (applicable to Unit 1 only) or Condition C (applicable to Unit 2 only) is entered when the stored diesel fuel oil in FOST 21 is less than a 7-day supply. No other parts of Condition A, B, or C (i.e., Required Actions or Completion Times) are proposed to be modified in the application.

Section 4.3 discusses the methodology to be used in modifying the stored diesel fuel oil numerical volume basis in the TS Bases under licensee control. The use of this methodology will ensure that the 7-day and 6-day supply of stored diesel fuel oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC-approved methods.

Based on the above evaluation, and the considerations discussed in Section 4.3 below, the NRC staff considers the modification to the TS 3.8.3 Action Table to be acceptable.

4.3 SR 3.8.3.1 Currently, SR 3.8.3.1 requires the licensee to verify that the stored diesel fuel oil numerical volume requirements are met. The licensee proposes to revise SR 3.8.3.1 to reflect the change in LCO requirements, namely that a 7-day supply (rather than a specified numerical volume) be available to each required DG. As a result, SR 3.8.3.1 would require the licensee to verify that the stored diesel fuel oil inventory is greater than or equal to a 7-day supply for each required DG. The licensee proposes to remove the current numerical volume requirement from the TS and replace it with the associated current 7-day supply for fuel oil for each DG.

During the acceptance review of the LAR, NRC staff requested additional supplemental information (Reference 2). Specifically, the marked up TS Bases provided in the LAR did not provide a reference to the method of calculating the required stored diesel fuel oil volume equivalent to a 7-day supply. The requested supplemental information was provided by the licensee by letter dated November 26, 2012 (Reference 3).

The licensee stated in Reference 3 that the method provided in ANSI N195-1976, Section 5.4, as endorsed by RG 1.137, Revision 1, Section C. 1.c, is used to calculate the required stored

diesel fuel oil volume equivalent to a 7-day supply. Calvert Cliff uses the "conservative" calculation method described by ANSI N195-1976, Section 5.4, to calculate the required stored diesel fuel oil volume. In its letter, the licensee also provided marked up TS Bases pages to replace the pages previously provided for SR 3.8.3.1. Additionally, the licensee stated that the DG day tank volume meets ANSI N195-1976, Section 6.1, to provide at least 60 minutes of operation based on the fuel consumption at 100 percent of the continuous rating of the DG plus a margin of 10 percent.

The guidance at ANSI N 195-1976 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. 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 seven days at its rated capacity. As stated above, Calvert Cliffs utilizes the more conservative, continuous 7-day operation at rated capacity methodology. Both calculation methods shall include an explicit allowance for fuel consumption required by periodic testing.

This includes the fuel required for operation of the engine at the minimum loads specified by the engine manufacturer.

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 TS Diesel Fuel Oil Testing Program, the calculations of fuel consumption and required stored volume remain valid. Current TS SR 3.8.3.2 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.

The licensee's continued adherence to the methods described above, which it is required to incorporate into its Updated Final Safety Analysis Report (UFSAR), provides 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. Based on the above evaluation, the NRC staff finds the change to SR 3.8.3.1 acceptable.

4.4 SR 3.8.1.5 Currently, SR 3.8.1.5 requires the licensee to verify that the DG day tank fuel oil numerical volume requirements are met. As discussed in the current TS Bases, the numerical volume requirements in SR 3.8.1.5 are based on maintaining an adequate fuel oir supply for a minimum of a hour of DG operation at full load plus 10 percent. The licensee proposes to revise SR 3.8.1.5 by removing the current day tank fuel oil numerical volume requirements from the TS

and replacing them with a minimum 1-hour DG operating duration requirement so that the fuel oil volumes necessary to support the 1-hour operating requirements may be modified under licensee control.

During its review, the NRC staff issued a request for additional information (Reference 4) to query the licensee on the methods and standards used to calculate the required numerical volume of fuel oil stated in the proposed revision of TS SR 3.8.1.5. The licensee stated in a July 1, 2013, letter (Reference 5) to the NRC staff that, as discussed above, it uses the more conservative calculational method described by ANSI N 195-1976, Section 5.4, to calculate the required day tank stored diesel fuel oil volume.

The licensee is removing the numerical volume requirement from the TS and replacing it with the minimum one-hour diesel generator operating time requirement. The licensee's continued adherence to the methods described above, which it is required to incorporate into its UFSAR, provides 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. Based on the above evaluation, the NRC staff finds the change to SR 3.8.3.1.5 acceptable.

4.5 Implementation Requirement to Revise the UFSAR To ensure an acceptable and consistent fuel oil calculation methodology is maintained, the licensee provided a commitment in its October 3, 2014, letter, to revise the Calvert Cliffs UFSAR with the following information:

The specific emergency diesel generator fuel oil volumes (equivalent to duration based requirements) contained in the fuel oil storage tanks referenced in Technical Specification 3.8.3 and the day tanks referenced in Technical Specification 3.8.1 are calculated using the method provided in American National Standards Institute N195-1976, Section 5.4, as endorsed by Regulatory Guide 1.137, Revision 1, Section C.l.c. The fuel oil calculation is based on applying the conservative assumption that the emergency diesel generator is operated continuously at rated capacity. This is one of two approved methods specified in Regulatory Guide 1.137, Revision 1.

As an implementation requirement for the amendment, the NRC staff has required the licensee to place the fuel oil calculation methodology in its UFSAR. The NRC staff finds that licensee control of the fuel oil calculation methodology in the UFSAR will continue to adequately ensure public health and safety, as any deviation from the calculation methodology described above requires the licensee to perform an evaluation pursuant to the provisions of 10 CFR 50.59 to determine whether the change requires prior NRC approval.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve 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, published in the FR on March 4, 2013 (78 FR 14130), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. Accordingly, the amendments meet 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 amendments.

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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1. Letter from Calvert Cliffs, LLC to the U.S. NRC dated October 2, 2012, "Application for Technical Specification Improvement to Adopt TSTF-501-A, [Technical Specification Task Force], Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (ADAMS Accession No. ML12278A012).

2. Letter from N. S. Morgan (NRC) to G. H. Gellrich (Calvert Cliffs), dated November 16, 2012, "Calvert Cliffs Nuclear Power Plant, Unit No. 1 and 2 -Acceptance Review Results Regarding TSTF-501-A License Amendment Request" (TAC No. ME9794 and ME9795)"

(ADAMS Accession No. ML12320A071 ).

3. Letter from Calvert Cliffs, LLC to the U.S. NRC dated November 26, 2012, "Supplemental Information re: Application for Technical Specification Improvement to Adopt TSTF-501-1, Revision 1" (ADAMS Accession No. ML12333A316).

4. Letter from N. S. Morgan (NRC) to Mr. G. H. Gellrich (Calvert Cliffs), dated May 31, 2013, Request for Additional Information Regarding Adoption of TSTF-501 -A, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" License Amendment (TAC Nos. ME9794 and ME9795) (ADAMS Accession No. ML13141A689).

5. Letter from Calvert Cliffs, LLC to the U.S. NRC dated July 1, 2013, "Response to Request for Additional Information Regarding Adoption of TSTF-501-A, Revision 1,

"Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (ADAMS Accession No. ML13189A130).

6. Letter from Calvert Cliffs, LLC to the U.S. NRC dated February 7, 2014, "Supplemental Information re: Application for Technical Specification Improvement to Adopt TSTF-501-1, Revision 1" (ADAMS Accession No. ML14042A046).

7. Letter from Exelon Generation to the U.S. NRC dated October 3, 2014, "Supplemental Information re: Application for Technical Specification Improvement to Adopt TSTF-501-1, Revision 1" (ADAMS Accession No. ML14280A120).

8. Transmittal of TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (ADAMS Accession No. ML090510686).

9. TSTF-501-A, Federal Register, Notice of Availability published on May 26, 2010 (75 FR 29588).

Principal Contributors: G. Waig N. Morgan Date: October 21 , 2014

DATED: October 21, 2014 AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 CALVERT CLIFFS UNIT NO. 1 AMENDMENT NO. 284 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 CALVERT CLIFFS UNIT NO. 2 DISTRIBUTION:

PUBLIC LPLI-1 RIF RidsNrrDoriDpr RidsNrrDoriLpll-1 RidsNrrPMCalvertCiiffs RidsNrrLAKGoldstein RidsNrrDssStsb RidsNrrDssSbpb M. Levine RidsNrrDeEpnb R. Wolfgang RidsRgn1 MaiiCenter RidsOgcMaiiCenter RidsAcrsAcnw_MaiiCTR cc w/encls: Distribution via List

• .. ML14239A491 *via email OFFICE LPLI-1/PM LPLI-1/LA DSS/STSB/BC DSS/DBPB/BC DE/EPNB/BC NAME NMorgan KGoldstein REIIiott GCasto DAiley DATE 9/5/2014 09/03/14 9/15/14 9/17/14 9/18/14 OFFICE DE/EEEB/BC OGC LPLI-1/BC LPLI-1/PM NAME JZimmerman Jlindell BBeasley NMorgan DATE 9/18/14 9/30/14 10/21/14 10/21/14