|
|
| Line 18: |
Line 18: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C . 20555-0001 November 15, 2021 Mr. David P. Rhoades Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 | | {{#Wiki_filter:}} |
| | |
| ==SUBJECT:==
| |
| NINE MILE POINT NUCLEAR STATION, UNIT 2 - ISSUANCE OF AMENDMENT NO. 187 RE: ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL (EPID L-2021-LLA-0096)
| |
| | |
| ==Dear Mr. Rhoades:==
| |
| | |
| The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 187 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (Nine Mile Point 2). The amendment consists of changes to the Technical Specifications in response to your application dated May 26, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21146A045).
| |
| The amendment revised TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the technical specifications to the technical specification bases so that it may be modified under licensee control. The technical specifications are modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator.
| |
| Condition A and condition B in the action table are revised and surveillance requirements 3.8.3.1 and 3.8.3.2 are revised to reflect the above change.
| |
| | |
| D. Rhoades A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
| |
| Sincerely,
| |
| /RA/
| |
| Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410
| |
| | |
| ==Enclosures:==
| |
| : 1. Amendment No. 187 to NPF-69
| |
| : 2. Safety Evaluation cc: Listserv
| |
| | |
| NINE MILE POINT NUCLEAR STATION, LLC LONG ISLAND LIGHTING COMPANY EXELON GENERATION COMPANY, LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 187 Renewed License No. NPF-69
| |
| : 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
| |
| A. The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated May 26, 2021 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 Renewed Facility Operating License No. NPF-69 is hereby amended to read as follows:
| |
| 2.C.(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 187, are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
| |
| : 3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.
| |
| FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by James G. James G. Danna Date: 2021.11.15 Danna 08:34:33 -05'00' James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
| |
| | |
| ==Attachment:==
| |
| | |
| Changes to the License and Technical Specifications Date of Issuance: November 15, 2021
| |
| | |
| ATTACHMENT TO LICENSE AMENDMENT NO. 187 NINE MILE POINT NUCLEAR STATION, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 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 4 4 Replace the following pages of 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 3.8.1-7 3.8.1-7 3.8.3-1 3.8.3-1 3.8.3-3 3.8.3-3
| |
| | |
| (1) Maximum Power Level Exelon Generation is authorized to operate the facility at reactor core power levels not in excess of 3988 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
| |
| (2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 187 are hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
| |
| (3) Fuel Storage and Handling (Section 9.1, SSER 4)*
| |
| : a. Fuel assemblies, when stored in their shipping containers, shall be stacked no more than three containers high.
| |
| : b. When not in the reactor vessel, no more than three fuel assemblies shall be allowed outside of their shipping containers or storage racks in the New Fuel Vault or Spent Fuel Storage Facility.
| |
| : c. The above three fuel assemblies shall maintain a minimum edge-to-edge spacing of twelve (12) inches from the shipping container array and approved storage rack locations.
| |
| : d. The New Fuel Storage Vault shall have no more than ten fresh fuel assemblies uncovered at any one time.
| |
| (4) Turbine System Maintenance Program (Section 3.5.1.3.10, SER)
| |
| The operating licensee shall submit for NRC approval by October 31, 1989, a turbine system maintenance program based on the manufacturers calculations of missile generation probabilities.
| |
| (Submitted by NMPC {{letter dated|date=October 30, 1989|text=letter dated October 30, 1989}} from C.D. Terry and approved by NRC {{letter dated|date=March 15, 1990|text=letter dated March 15, 1990}} from Robert Martin to Mr.
| |
| Lawrence Burkhardt, III).
| |
| * The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.
| |
| Renewed License No. NPF-69 Amendment 117 through 186 187
| |
| | |
| AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
| |
| SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------- NOTES ---------------------------
| |
| : 1. DG loadings may include gradual loading as recommended by the manufacturer.
| |
| : 2. Momentary transients outside the load range do not invalidate this test.
| |
| : 3. This Surveillance shall be conducted on only one DG at a time.
| |
| : 4. This SR shall be preceded by, and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.
| |
| Verify each required DG is synchronized and In accordance with loaded and operates for 60 minutes at a the Surveillance load 3960 kW and 4400 kW for Division 1 Frequency Control and 2 DGs, and 2340 kW and 2600 kW for Program*
| |
| Division 3 DG.
| |
| SR 3.8.1.4 Verify each required day tank contains In accordance with one hour supply of fuel oil. the Surveillance Frequency Control Program*
| |
| SR 3.8.1.5 Check for and remove accumulated water from In accordance with each required day tank. the Surveillance Frequency Control Program*
| |
| SR 3.8.1.6 Verify each required fuel oil transfer In accordance with subsystem operates to automatically the Surveillance transfer fuel oil from the storage tank to Frequency Control the day tank. Program*
| |
| (continued)
| |
| * Following return to OPERABILITY of the HPCS System, the past due Surveillances will be completed by January 18, 2019.
| |
| NMP2 3.8.1-7 Amendment 91, 152, 174 187
| |
| | |
| 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 stored fuel 48 hours stored fuel oil level less oil level to within than a 7 day supply and limit.
| |
| greater than a 6 day supply.
| |
| B. One or more DGs with B.1 Restore lube oil 48 hours lube oil inventory less than inventory to within a 7 day supply and greater limit.
| |
| than a 6 day supply.
| |
| (continued)
| |
| NMP2 3.8.3-1 Amendment 91 187
| |
| | |
| 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 a 7 day In accordance with supply of fuel. the Surveillance Frequency Control Program*
| |
| SR 3.8.3.2 Verify lube oil inventory is a 7 day supply. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program*
| |
| SR 3.8.3.4 Verify each DG air start receiver pressure In accordance with is: the Surveillance Frequency Control
| |
| : a. 225 psig for Division 1 DG and Program Division 2 DG; and
| |
| : b. 190 psig for Division 3 DG.
| |
| SR 3.8.3.5 Check for and remove accumulated water from In accordance with each fuel oil storage tank. the Surveillance Frequency Control Program*
| |
| * Following return to OPERABILITY of the HPCS System, the past due Surveillances will be completed by January 18, 2019.
| |
| NMP2 3.8.3-3 Amendment 91, 152, 174 187
| |
| | |
| SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 187 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT NUCLEAR STATION, LLC LONG ISLAND LIGHTING COMPANY EXELON GENERATION COMPANY, LLC.
| |
| NINE MILE POINT NUCLEAR STATION, UNIT 2 DOCKET NO. 50-410
| |
| | |
| ==1.0 INTRODUCTION==
| |
| | |
| By application dated May 26, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21146A045), Exelon Generation Company, LLC (Exelon, the licensee), submitted a license amendment request (LAR) to modify the technical specifications (TSs) for Nine Mile Point Nuclear Station, Unit 2 (NMP2). The proposed changes would revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, Surveillance Requirement (SR) 3.8.3.1 (verification of fuel oil storage tank volume), and SR 3.8.3.2 (verification of lube oil inventory volume), by removing the current stored diesel fuel oil and lube oil numerical volume requirements and replacing them with duration-based diesel 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 published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the consolidated line item improvement process (CLIIP). In addition, the licensee proposed changes that would revise SR 3.8.1.4 (verification of diesel generator (DG) day tank fuel oil volume) to replace the specific day tank numerical volume requirement with a duration-based diesel operating time requirement. The licensee also proposed associated changes to the TS Bases.
| |
| Any change to the numerical volume requirements in the TSs requires prior approval by the U.S. Nuclear Regulatory Commission (NRC or the Commission). Licensees may need to modify diesel fuel oil numerical volumes to account for changes to the energy content (British Thermal Units (BTU)/gallon) of available fuel oils in the market. Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements. The proposed changes would remove the numerical volume requirements for stored diesel fuel oil and lube oil from the TSs and would replace them with duration-based diesel operating time Enclosure 2
| |
| | |
| requirements. This amendment would permit the numerical volume requirements for stored diesel fuel oil and lube oil to be modified under licensee control pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests, and experiments, and, therefore, would not require prior NRC approval.
| |
| | |
| ==2.0 REGULATORY EVALUATION==
| |
| | |
| 2.1 System Description 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 and lube oil requirements are retained in the TSs as a limiting condition for operation (LCO) under 10 CFR 50.36(c)(2)(i) because they support the operation of the standby AC power sources.
| |
| NMP2s standby AC power system is powered by three independent DGs capable of an automatic start at any time and capable of continued operation at rated load, voltage, and frequency until manually stopped. The Division 3 DG supplies power only to the high pressure core spray (HPCS) system. The Division 1 and 2 DGs are redundant, and each is capable of powering the non-HPCS safety-related loads. The DG auxiliary and support subsystems, such as fuel oil and fuel oil transfer, lubricating oil, jacket water, service water, and starting air are required for operation of each DG. Each DG has a fuel oil (day) tank.
| |
| Each DG fuel oil day tank is supplied from its respective fuel oil storage tank. A fuel oil storage tank is capable of providing sufficient fuel oil for 7 days of operation of one DG under postulated accident conditions. Fuel oil is transferred from the storage tank to the day tank by either of two transfer pumps associated with each storage tank. Each fuel oil day tank provides enough fuel to allow a minimum of 1 hour of DG operation at full load plus ten percent.
| |
| 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. A DG 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.
| |
| 2.2 Description of the Proposed Changes The proposed changes would revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air and SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4, by removing the current stored diesel fuel oil volume and lube oil inventory numerical requirements and replacing them with duration-based diesel operating time requirements. The proposed changes would mean that the volume necessary to meet the TS duration requirements may be modified under licensee control. The specific TS changes are described in the following sections.
| |
| 2.2.1 Proposed Changes to TS 3.8.3 ACTIONS Table Conditions A and B Conditions A and B of TS LCO 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, would be revised in the ACTIONS Table. Currently, Conditions A and 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 volume requirement in Condition A is based on a combined volume of
| |
| | |
| less than a 7-day supply, but at least a 6-day supply. The numerical DG lube oil inventory requirement in Condition B is a volume of less than a 7-day supply, but greater than a 6-day supply. The proposed amendment would remove the numerical volumetric requirements from the TSs and replace them with duration-based requirements. Specifically, 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 a 6-day supply for one or more DGs. Condition B would be entered when the stored DG lube oil contains less than a 7-day supply, but greater than a 6-day lube oil supply for one or more DGs.
| |
| 2.2.2 Proposed Changes to SR 3.8.3.1, SR 3.8.3.2, and SR 3.8.1.4 Currently, SR 3.8.3.1 requires the licensee to verify that the fuel oil storage tanks contain a combined volume greater than or equal to 50,000 gallons of fuel oil for each Division 1 and 2 DG, and greater than or equal to 35,342 gallons of fuel oil for the Division 3 DG. SR 3.8.3.2 requires the licensee to verify that the lube oil inventory volume is greater than or equal to 99 gallons for each Division 1 and 2 DG, and greater than or equal to 168 gallons of lube oil for the Division 3 DG. SR 3.8.1.4 requires the licensee to verify that each DG day tank contains a volume greater than or equal to 403 gallons of fuel oil for the Division 1 and 2 DG, and 282 gallons of fuel oil for the Division 3 DG. As described in the current TS Bases, the numerical requirements in SRs 3.8.3.1 and 3.8.3.2 are based on maintaining at least a 7-day supply, while the numerical requirement in SR 3.8.1.4 is based on a one-hour supply at full load plus 10 percent. The proposed amendment would remove the numerical volume requirements from these SRs. SRs 3.8.3.1 and 3.8.3.2 would be revised to require the licensee to verify that the stored diesel fuel oil volume and lube oil inventory are greater than or equal to a 7-day supply for each DG. SR 3.8.1.4 would be revised to require the licensee to maintain a minimum one-hour supply of fuel oil.
| |
| 2.3 Licensee-Identified Differences with TSTF-501, Revision 1 In the LAR, the licensee proposed two variations from TSTF-501, Revision 1, as described below:
| |
| Variation 1: NMP2 SR 3.8.1.4, concerning fuel oil day tank inventory, currently specifies verification of greater than or equal to a minimum volume of fuel oil. The licensee proposed a revision to SR 3.8.1.4 to remove the day tank volume requirement and replace it with a durational requirement.
| |
| Variation 2: The NMP2 calculations that determine fuel oil volumes do not include the fuel oil volume required to support periodic testing. Instead, the licensee administratively controls fuel oil in support of periodic testing.
| |
| 2.4 Regulatory Requirements and Guidance Used in the Evaluation of the Changes 2.4.1 Regulatory Requirements The regulation in 10 CFR 50.36, Technical specifications, provides the regulatory requirements for the content of the TSs and requires, in part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a production or utilization facility. Specifically, 10 CFR 50.36(c) requires that TSs include items in five specific categories related to station operation. These categories are (1) safety
| |
| | |
| limits, limiting safety system settings, and limiting control settings, (2) LCOs, (3) SRs, (4) design features, and (5) administrative controls.
| |
| The regulation in 10 CFR 50.36(c)(2), Limiting conditions for operation, states, in part, that TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Section 50.36(c)(2)(i) of 10 CFR further states that [w]hen 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.
| |
| The regulation in 10 CFR 50.36(c)(3), Surveillance requirements, states that [s]urveillance requirements are requirements related 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.
| |
| 2.4.2 Guidance Regulatory Guide (RG) 1.137, Revision 1, Fuel-Oil Systems for Standby Diesel Generators (ADAMS Accession No. ML003740180), provides guidance that describes a method acceptable to the NRC staff for complying with the Commissions regulations regarding fuel oil systems for standby DGs and endorses American National Standards Institute (ANSI) standard ANSI N195-1976, with certain limitations. RG 1.137, Section C.1.c sets forth two methods for the calculation of fuel oil storage requirements as described in ANSI N195-1976, Section 5.4 Calculation of Fuel Oil Storage Requirements. These methods are: (1) calculations based on the assumption that the DG operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. If the time-dependent load method is used, the minimum required capacity should include the capacity to power engineered safety features.
| |
| NUREG-1434, Revision 4, Standard Technical Specifications for General Electric BWR
| |
| [Boiling-Water Reactor]/6 Plants (ADAMS Accession No. ML12104A195), provides example TS LCOs and acceptable remedial actions that meet the requirements in 10 CFR 50.36(c)(2)(i) for a standard plant design.
| |
| The NRC-approved TSTF Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (ADAMS Accession No. ML090510686), provides an acceptable method of modifying the stored fuel oil and lube oil requirements contained in the standard technical specifications.
| |
| | |
| ==3.0 TECHNICAL EVALUATION==
| |
| | |
| The licensee reviewed the model safety evaluation (SE), which was published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the CLIIP notice of availability. The licensee concluded, as stated on page 2 of Attachment 1 of the LAR, that the justifications presented in the model SE are applicable to NMP2, and therefore justify this amendment.
| |
| A DG is provided with a fuel oil capacity sufficient to operate that DG for a period of 7 days.
| |
| This onsite fuel oil capacity is sufficient to operate the DG long enough to place NMP2 in a shutdown condition and to bring in replenishment fuel oil from offsite sources.
| |
| | |
| The standby AC power sources (i.e., the DGs), 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. Requirements for diesel fuel oil and lube oil supplies are retained in the TSs under 10 CFR 50.36(c)(2)(i) because they support the operation of the standby AC power sources.
| |
| The proposed changes would revise TS 3.8.3 and SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs and replacing them with the associated duration-based diesel operating times. These changes would permit the fuel oil and lube oil volumes necessary to support a duration-based diesel operating time to be modified under licensee control pursuant to 10 CFR 50.59. The NRC staffs evaluation of the proposed TS changes is provided in the following sections.
| |
| 3.1 NRC Staff Evaluation of Proposed Changes to TS 3.8.3 ACTIONS Table Conditions A and B Currently, Condition A of TS 3.8.3 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 Conditions A and B are based on volumes less than a 7-day supply, but at least a 6-day supply. The proposed changes would remove the numerical volumetric requirements from the TSs and would modify Conditions A and B to replace them with duration-based diesel operating time requirements, such that Condition A is entered when the stored fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply and Condition B is entered when the lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more DGs. No other parts of Condition A or B are proposed to be modified.
| |
| As described in Section 3.2 below, the licensee stated that the stored diesel fuel oil numerical volumes sufficient to meet the duration-based operating time requirements will be calculated using Section 5.4 of ANSI N195-1976, Fuel Oil Systems for Standby Diesel Generators, and the volumes are based on applying the conservative assumption that the DG is operated continuously for seven days at its rated capacity. The use of this methodology will ensure that the supplies of stored diesel fuel oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC-approved methods. The lube oil volume 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.
| |
| Based on the above evaluation, the NRC staff concludes that the changes to the TS 3.8.3 ACTIONS Table are acceptable.
| |
| 3.2 NRC Staff Evaluation of Proposed Changes to SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 Currently, 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 numerical volume requirements are met. SR 3.8.1.4 requires the licensee to verify that each day tank contains the required volume of diesel fuel oil.
| |
| The licensee proposed to revise SR 3.8.3.1 and SR 3.8.3.2 to reflect the change from numerical volume requirements to durational requirements made in TS 3.8.3 ACTIONS Table.
| |
| Specifically, SRs 3.8.3.1 and 3.8.3.2 would be revised to require availability of a 7-day supply of fuel oil and lube oil for each DG, rather than a specified numerical volume. As a result, SR 3.8.3.1 and SR 3.8.3.2 would require the licensee to verify that the combined volume of the
| |
| | |
| fuel oil storage tanks and the lube oil inventory are each greater than or equal to a 7-day supply for a DG.
| |
| The licensee also proposed to revise SR 3.8.1.4, which contains the DG day tank volumetric requirement. The proposed change to SR 3.8.1.4 is similar to the proposed change for SR 3.8.3.1 in that the numerical volume requirements would be replaced with durational requirements. The revised SR 3.8.1.4 would require the licensee to verify that the stored diesel fuel oil volume in each day tank is greater than or equal to a one-hour supply of fuel oil. The licensees proposed inclusion of changes to the day tank storage requirements in the LAR is identified as Variation 1 in Section 2.3 of this SE.
| |
| On page 3 of Attachment 1 of the LAR, the licensee describes how the volume of fuel oil necessary to support operation of the standby DGs is managed at the site, as follows:
| |
| NMP2 calculations that determine fuel oil volumes required to support operation of the DGs for the 7-days do not include an explicit allowance for fuel oil consumption due to periodic testing. Instead, NMP2 administratively controls fuel oil in support of required periodic testing, such that the required volumes for the fuel oil tanks are maintained.
| |
| This is identified as Variation 2 in Section 2.3 of this SE.
| |
| The methodology in ANSI N195-1976 discusses how the stored diesel fuel oil requirement should be calculated based upon the DGs operating at the minimum required capacity for the plant condition that is most limiting for the calculation of such capacity. One method for calculating the stored diesel fuel oil supply in ANSI N195-1976 takes into account the time dependence of DG loads. That is, if DG loads increase or decrease during the event, the load changes should be included in the required fuel oil 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 should be included in the calculation of required fuel oil storage capacity. Revision 1 of RG 1.137 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 engine operates continuously for seven days at its rated capacity.
| |
| Since both methods described in ANSI N195-1976 are approved for use by the NRC staff in RG 1.137, Revision 1, and the licensee calculates the volume of fuel oil in accordance with RG 1.137, Revision 1, the NRC staff has 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 and SR 3.8.1.4. Additionally, the licensee will administratively control the amount of fuel oil required to support periodic testing, such that the volume of fuel oil 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 oil consumption rate. The property of diesel fuel oil having the most significant effect on the fuel oil consumption rate is the energy content (heating value) of the fuel oil. Standards exist that correlate the energy content to the fuel oils American Petroleum Institute (API) gravity or absolute specific gravity. At a minimum, licensees calculate the required fuel oil storage values for their plants
| |
| | |
| assuming the most limiting API gravity or absolute specific gravity, and therefore, the most limiting fuel oil 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 oil consumption and required stored volume remain valid. Current SR 3.8.3.3 requires new fuel oil to be tested in accordance with, and maintained within the limits of current TS 5.5.9, Diesel Fuel Oil Testing Program to verify that the fuel oils API gravity or absolute specific gravity is within the range assumed in the diesel fuel oil consumption calculations.
| |
| The lube oil inventory equivalent to a 7-day supply, as well as the 6-day supply associated with TS 3.8.3 Condition B, is based on the DG manufacturer consumption values for the run time of the DG.
| |
| The above methods still provide assurance that the necessary quantity and quality of diesel fuel oil and lube oil will continue to be maintained and calculated in accordance with NRC-approved methods. Variation 1 is acceptable because revising the day tank supply to a duration-based amount continues to provide assurance that the necessary quality of systems and components is maintained, and that facility operation will be within safety limits, and that the LCOs will be met. The method used to calculate the day tank oil volumes is one of the acceptable methods provided in RG 1.137. Variation 2 is acceptable because the calculation method used to determine the volume of oil required to be controlled is one of the acceptable methods provided in RG 1.137 and continues to provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within the safety limits, and that the LCOs will be met because only the calculated volume of oil, less testing volume, is necessary if the DG was used in an accident. Therefore, the NRC staff considers the duration-based changes to SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 to be acceptable.
| |
| 3.3 TS Bases Changes The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. Consistent with 10 CFR 50.36(a)(1),
| |
| the licensee submitted corresponding TS Bases changes that provide the reasons for the proposed TSs changes. The licensee makes changes to the NMP2 TS Bases in accordance with TS 5.5.10, TS Bases Control Program.
| |
| 3.4 Technical Conclusion The proposed changes will continue to require that the appropriate volumes of stored diesel fuel oil and lube oil are maintained. The proposed changes to TS 3.8.3 ACTIONS Table 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. Conditions A and B of TS 3.8.3 ACTIONS Table continue to provide acceptable remedial actions to follow until LCO 3.8.3 can be met. The NRC staff concludes that replacement of the TS numerical value volume requirements with durational requirements does not change the current plant configuration, the current volume requirements, or the current basis for fuel oil and lube oil volume requirements.
| |
| Therefore, the changes to TS 3.8.3 ACTIONS Table will continue to meet 10 CFR 50.36(c)(2) and are acceptable.
| |
| In addition, the proposed changes to SRs 3.8.3.1, 3.8.3.2, and 3.8.1.4 continue to provide assurance that the necessary quality of systems and components is maintained, the facility will
| |
| | |
| be within safety limits, and that the LCO will be met. The revised SRs will continue to meet 10 CFR 50.36(c)(3), and are therefore acceptable.
| |
| | |
| ==4.0 STATE CONSULTATION==
| |
| | |
| In accordance with the Commissions regulations, the New York State official was notified of the proposed issuance of the amendment on October 19, 2021. The State official had no comments.
| |
| | |
| ==5.0 ENVIRONMENTAL CONSIDERATION==
| |
| | |
| The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, and changes 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 (86 FR 36780). 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.
| |
| | |
| ==6.0 CONCLUSION==
| |
| | |
| The staff 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 Contributor: K. West Date: November 15, 2021
| |
| | |
| ML21295A734 *by safety evaluation email OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NAME BBallard RGuzman KEntz DATE 10/27/2021 10/27/2021 10/26/2021 OFFICE NRR/DSS/STSB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME NJordan (Acting) JDanna RGuzman DATE 10/10/2021 11/10/2021 11/15/2021}}
| |
