ML12278A012

Application for Technical Specification Improvement to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

ML12278A012
Person / Time
Site:	Calvert Cliffs
Issue date:	10/02/2012
From:	George Gellrich Constellation Energy Nuclear Group, Calvert Cliffs 3 Nuclear Project
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-501-A, Rev 1
Download: ML12278A012 (19)

Text

George H. Gelirich Calvert Cliffs Nuclear Power Plant, LLC Site Vice President 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax CENG.

a joint venture of O E.r**° JoeDF CALVERT CLIFFS NUCLEAR POWER PLANT October 2, 2012 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Application for Technical Specification Improvement to Adopt TSTF-501-A, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" In accordance with 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, LLC is submitting a request for an amendment to the Technical Specifications for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) Units 1 and 2. The proposed changes would allow Calvert Cliffs to relocate the current stored diesel fuel oil numerical volume requirements from the Technical Specification to the Technical Specification Bases so that it may be modified under licensee control. The Technical Specification is modified so that the stored diesel fuel oil inventory will require that a 7-day supply be available for a diesel generator. Conditions A, B, and C in the Actions are revised and Surveillance Requirement (SR) 3.8.3.1 is revised to reflect the above change.

Regarding stored diesel fuel oil, no changes to the current plant configuration, current numerical volume requirements, or current 7-day basis are proposed in this application; the proposal merely relocates the current numerical volume requirements from the Technical Specification to the Technical Specification Bases and relocates the 7-day basis from the Technical Specification Bases to the Technical Specification.

In addition, no changes to the SR Frequency, Required Actions, or Completion Times are proposed in this application.

The changes are consistent with Nuclear Regulatory Commission-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-501-A, Revision 1. The availability of this Technical Specification improvement was announced in the Federal Register on May 26, 2010 (75 FR 29588) as part of the consolidated line item improvement process.

Document Control Desk October 2, 2012 Page 2 The current licensing basis for Calvert Cliffs requires a 7-day supply of stored diesel fuel oil for a diesel generator. The Calvert Cliffs Technical Specification does not include similar requirements for lube oil inventory.

Calvert Cliffs is also proposing a similar change to SR 3.8.1.5 in Technical Specification 3.8.1, "AC Sources-Operating" to relocate the specific numerical value for the day tank fuel oil volume from the Technical Specification to the Technical Specification Bases.

Attachment (1) provides a description and assessment of the proposed changes. Attachment (2) provides the existing Technical Specification pages marked up to show the proposed changes. Attachment (3) provides the existing Technical Specification Bases pages marked up to show the proposed changes.

Calvert Cliffs Nuclear Power Plant requests approval of the proposed license amendment by July 1, 2013 with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Maryland Official.

The proposed amendment request has been reviewed by the Plant Operations Review Committee.

There are no regulatory commitments contained in this letter.

Document Control Desk October 2, 2012 Page 3 Should you have questions regarding this matter, please contact Mr. -Douglas E. Lauver at (410) 495-5219.

Very truly yours,

ý' ý X ozzý STATE OF MARYLAND COUNTY OF CALVERT

TO WIT:

I, George H. Gellrich, being duly sworn, state that I am Site Vice President - Calvert Cliffs Nuclear Power Plant, LLC (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other CCNPP employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me a Notary Pubtic in and for the State of Maryland and County of this ýý day of (}-'/

,20 12.

WITNESS my Hand and Notarial Seal:

My Commission Expires:

Notary Public

/

Date GHG/PSF/bjd Attachments:

(1)

(2)

(3)

Description and Assessment of Proposed Changes Marked up Technical Specification Pages Marked up Technical Specification Bases Pages cc:

N. S. Morgan, NRC W. M. Dean, NRC Resident Inspector, NRC S. Gray, DNR

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES TABLE OF CONTENTS

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS

7.0 REFERENCES

Calvert Cliffs Nuclear Power Plant, LLC October 2, 2012

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES

1.0 DESCRIPTION

This letter is a request for an amendment to Renewed Operating Licenses DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Units 1 and 2. The proposed changes would revise Technical Specification (TS) 3.8.3, "Diesel Fuel Oil," by relocating the current stored diesel fuel oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS is modified so that the stored diesel fuel oil inventory will require that a 7-day supply be available for a diesel generator. This change is consistent with Technical Specification Task Force (TSTF) change traveler TSTF-501-A, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." The availability of this TS improvement was announced in the Federal Register on May 26, 2010 (75 FR 29588) as part of the consolidated line item improvement process (CLIIP).

Additionally, Calvert Cliffs is proposing a similar change to SR 3.8.1.5 in Technical Specification 3.8.1, "AC Sources-Operating" to relocate the specific numerical value for the day tank fuel oil volume from the Technical Specification to the Technical Specification Bases.

This change is consistent with a change approved in Reference 1.

2.0 PROPOSED CHANGE

The proposed changes revise TS 3.8.3, "Diesel Fuel Oil" by relocating the current stored diesel fuel oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS is modified so that the stored diesel fuel oil inventory will require that a 7-day supply be available for a diesel generator. As a result:

• Conditions A, B, and C in the Action are revised. Currently Conditions A, B, and C are entered when the stored diesel fuel oil numerical volume requirements are not met. As discussed in the current TS Bases, the numerical volume requirements of Conditions A, B, and C are based on volumes less than a 7-day supply, but greater than a 6-day supply.

The revision relocates the volumetric requirements from the TS and places it in the TS Bases. The TS is modified so that Conditions A, B, or C are entered when the stored diesel fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply for a diesel generator.

" Surveillance Requirement (SR) 3.8.3.1 is revised. Currently, SR 3.8.3.1 verifies that the stored diesel fuel oil numerical volume requirements are met. As discussed in the current TS Bases, the numerical volume requirements in SR 3.8.3.1 are based on maintaining at least a 7-day supply. The revision relocates the volumetric requirements from the TS and places it in the TS Bases. The TS is modified so that SR 3.8.3.1 verifies that the stored diesel fuel oil volume is greater than or equal to a 7-day supply for a diesel generator.

Proposed revisions to the TS Bases are also included in this license amendment request. Adoption of the TS Bases associated with TSTF-501-A, Revision 1, is an integral part of implementing this TS change.

The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

Calvert Cliffs is proposing variations or deviations from the TS changes described in TSTF-501-A, Revision 1, or the Nuclear Regulatory Commission (NRC) Staff s model safety evaluation (SE) published in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLIIP Notice of Availability.

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

• A revision to TS 3.8.1, "AC Sources-Operating," following a similar approach to the TS 3.8.3 changes discussed above is proposed. 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 one 1

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES hour supply of fuel oil. The specific volume needed to support this requirement is relocated to the TS Bases. Similar to the technical justification provided in the model SE as part of the CLIIP, this proposed change is acceptable since it merely relocates the current numerical volume requirement for the day tank from the TS to the TS Bases and relocates the one hour supply requirement from the TS Bases to the TS. This change is consistent with a similar change approved in Reference 1.

Corresponding changes are made to the TS Bases and the No Significant Hazards Consideration Determination to reflect the deviations above.

3.0 BACKGROUND

The background for this application is addressed by the model SE in NRC's Notice of Availability published on May 26, 2010 (75 FR 29588) and TSTF-501-A, Revision 1.

4.0 TECHNICAL ANALYSIS

Calvert Cliffs has reviewed the model SE published in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLIIP Notice for Comment.

Calvert Cliffs has concluded that the technical justifications presented in the model SE prepared by the NRC staff are applicable to Calvert Cliffs Units 1 and 2, and, therefore, justify this amendment for the incorporation of the proposed changes to Calvert Cliffs TSs.

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes revise the TSs by relocating the current stored fuel oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The current numerical volume requirements are based on a 7-day supply in the storage tanks and a one hour supply in the day tank. The TS is modified so that the stored diesel fuel oil inventory will require that a 7-day storage tank supply and a one hour day tank supply be available for a diesel generator.

This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated, or No.

The proposed change relocates the volume of diesel fuel oil required to support 7-day operation of an onsite diesel generator, and the volume equivalent to a 6-day supply, to licensee control.

The specific volume of fuel oil equivalent to a 7-and 6-day supply is calculated using the limiting energy content of the fuel, the required diesel generator output and the corresponding fuel oil consumption rate. Because the requirement to maintain a 7-day supply of diesel fuel oil is not changed and is consistent with the assumptions in the accident analysis, and the actions taken with the volume of fuel oil is less than a 6-day supply have not changed, neither the probability nor the consequences of any accident previously evaluated will be affected.

The proposed change also relocates the volume of diesel fuel oil required to support one hour of diesel generator operation at full load in the day tank. The specific volume and time is not changed 2

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES and is consistent with the existing plant design basis to support a diesel generator under accident load conditions.

Therefore, operation of the facility in accordance with the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Create the possibility of a new or different type of accident from any accident previously evaluated,-

or No.

The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

The change does not alter assumptions made in the safety analysis but ensures that the diesel generator operates as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.

The proposed change also relocates the volume of diesel fuel oil required to support one hour of diesel generator operation at full load in the day tank. The change does not alter assumptions made in the safety analysis but ensures that the diesel generator operates as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

No.

The proposed change relocates the volume of diesel fuel oil required to support 7-day operation of an onsite diesel generator, and the volume equivalent to a 6-day supply, and one hour day tank supply to licensee control. As the basis for the existing limits on diesel fuel oil are not changed, no change is made to the accident analysis assumptions and no margin of safety is reduced as part of this change.

The proposed change also relocates the volume of diesel fuel oil required to support one hour of diesel generator operation at full load in the day tank. As the basis for the existing limits on diesel fuel oil are not changed, no change is made to the accident analysis assumptions and no margin of safety is reduced as part of this change.

Therefore, the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the above, Calvert Cliffs concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of"no significant hazards consideration" is justified.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of this proposed change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on May 26, 2010 (75 FR 29588). Calvert Cliffs has reviewed the NRC staff s model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is generally applicable to Calvert Cliffs.

3

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES 6.0 ENVIRONMENTAL EVALUATION The proposed change would 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, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22 (b), no environmental impact statement or environmental assessment need be prepared in conjunction with the proposed change.

7.0 REFERENCES

1.

Letter from M. L. Chawla (NRC) to J. M. Davis (Fermi-2), dated February 24, 2012, Issuance of Amendment Re: TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," ML113500433 4

ATTACHMENT (2)

MARKED UP TECHNICAL SPECIFICATION PAGES Calvert Cliffs Nuclear Power Plant, LLC October 2, 2012

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, and operates for Ž 60 minutes at a load

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

31 days SR 3.8.1.5 Verify each day tank contains o f fu el'i 31 days

,i 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 CALVERT CLIFFS - UNIT 2 3.8.1-12 Amendment No.

265 Amendment No.

242

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 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 limits.

cAs~s4\\ar o-'

u p

0C" rvr

ý r%0 elc CALVERT CLIFFS -

UNIT 1 CALVERT CLIFFS -

UNIT 2 3.8.3-1 Amendment No.

227 Amendment No. 201

Diesel Fuel Oil 3.8.3 B.

---

NOTE-------

Only applicable to Unit 1.

FOST 21 with fuel oil volu e<0JUU dT B. 1 Verify combined available fuel oil volume of FOST 21 and OPERABLE FOST 11 4\\u or-e-ovaA-A-,

ci, 60 AND B.2 Verify combined available fuel oil volume of FOST 21 and OPERABLE FOST 11 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AND Once per 31 days thereafter ofreaA-'r 4Vcr" o r-euA

+0r 0--

Upt CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.8.3-2 Amendment No.

227 Amendment No.

201

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION IREQUIRED ACTION COMPLETION TIME C.

NOTE Only applicable to Unit 2.

C.1 AND C.2 FOST 21 with fuel oil Verify combined available fuel oil volume of FOST 21 and OPERABLE FOST 11

Ž"

72-P,860A A V ga I onz NOTES------

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

2.

Only applicable between April 1 and September 30.

Restore FOST 21 fuel oil volume to within limits.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

ý r&Je-A

(,or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 48 hours AND C.3 Restore FOST 21 fuel 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 CALVERT CLIFFS - UNIT 2 3.8.3-3 Amendment No.

227 Amendment No.

201

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.

OR 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:

a.

b.

FOST 1A an FOST 21 31 days 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 I CALVERT CLIFFS -

UNIT 2 3.8.3-4 Amendment No.

227 Amendment No.

201

ATTACHMENT (3)

MARKED UP TECHNICAL SPECIFICATION BASES PAGES Calvert Cliffs Nuclear Power Plant, LLC October 2, 2012

AC Sources-Operating B 3.8.1 BASES Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0.

The 0.8 value is the design rating of the machine, while 1.0 is an operational limitation.

The 31-day Frequency for this SR is consistent with Reference 3.

This SR is modified by four Notes.

Note 1 indicates that the diesel engine runs for this surveillance test may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.

Note 2 states that momentary transients because of changing bus loads do not invalidate this test.

Note 3 indicates that this surveillance test shall be conducted on only one DG at a time in order to prevent routinely paralleling multiple DGs and to minimize the potential for effects from offsite circuit or grid perturbations.

Note 4 stipulates a prerequisite requirement for performance of this SR.

A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.5 Tr'e-9,,A ot, Ieud This SR provides verification that the level of fuel oil in e-M V

the day tank is at or above the level at which fuel oil is o "V 0

"U s L5 automatically added.

The level required by the SR is 3 2,5oiors

-Lr

'Ese ected to ensure adequate fuel oilfor a minimum of I Ab&-

A Z-75 one hour of DG operation at full load plus 10%.

SitOAý%

Po-tý&s The 31-day Frequency is adequate to assure that a sufficien I i A,

2* *A z8, supply of fuel oil is available, since low level alarms are Drovided, and unit operators would be aware of any large t

uses of fuel oil during this period.

SR 3.8.1.6 Microbiological fouling is a major cause of fuel oil degradation.

There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive.

Removal of water from the fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival.

This is the most effective means of controlling microbiological fouling.

CALVERT CLIFFS -

UNITS 1 & 2 B 3.8.1-26 Revision 26 CALVERT CLIFFS - UNITS I & 2 B 3.8.1-26 Revision 26

Diesel Fuel Oil B 3.8.3 BASES is required to be within limits when the associated DG is required to be OPERABLE.

For both Unit 1 and Unit 2, the FOST No.

1A associated DG is only DG No.

1A. For Unit 1, the FOST No.

21 associated DGs are DG Nos.

1B and 2B.

For Unit 2, the FOST No.

21 associated DGs are DG Nos.

2A and 2B.

Alignment does not affect the association of DG and FOST since the individual DG fuel oil day tank provides sufficient volume for the DG to perform its safety function while re-alignment is accomplished, if necessary.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem.

Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

A.1, B.1, B.2, C.1. C.2. and C.3 In this Condition, the seven day fuel oil supply for a DG is not available.

However, fuel oil volume reduction is limited to 6/7 of the required volume which will provide 0il tI sufficient capacity to operate one DG on one unit on accident loads, and one DG on the other unit on shutdown

-* f o

loads for approximately six days.

These circumstances may SIX ao-- S Is be caused by events such as full load operation required S~L cx

• suppL1 IS

• after an inadvertent start while at minimum required level; q2,'q3

\\

or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil (Fori

{Aquality degradations.

This restriction allows sufficient

-7Z, o

S

&C

• s time for obtaining the requisite replacement volume and (FOS-1

.T z

performing the analyses required prior to addition of fuel FOSTZ~J.1 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 (approximately six days), the fact that procedures will be initiated to CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-3 Revision 2

Diesel Fuel Oil B 3.8.3 BASES F.1 With a Required Action and associated Completion Time not met, or one or more DGs with diesel fuel oil 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.

"Associated DG(s)" are identified in the Applicability Bases.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the DG FOSTs to support one unit on accident loads and one unit on shutdown loads for A

seven days.

The seven day period is sufficient time to place t e unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade (i.e., 2D and 2D low sulfur) and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion.

Note that further references to American Society for Testing Materials (ASTM) 2D fuel oil include both 2D and 2D low sulfur.

If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks.

These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days.

The tests, limits, and applicable ASTM Standards are as follows:

a.

Sample the new fuel oil in accordance with Reference 3, ASTM D4057-1995; CALVERT CLIFFS - UNITS I & 2 B 3.8.3-7 Revision 2

Insert I The fuel oil level ensuring a 7 day supply is 49,500 gallons (FOST IA) and 85,000 gallons (FOST 21).

The required fuel oil storage volume is determined using the most limiting energy content of the stored fuel. Using the limiting energy content, the required diesel generator output and the corresponding fuel oil consumption rate, the onsite fuel oil storage volume required for 7 days of operation can be determined. Surveillance Requirement 3.8.3.2 requires new fuel to be tested to verify that the energy content is within the range assumed in the diesel fuel oil consumption calculations.