TSTF-08-14, Response to NRC May 5, 2008 Request for Additional Information Regarding TSTF-501, Revision 0, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

Response to NRC May 5, 2008 Request for Additional Information Regarding TSTF-501, Revision 0, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

ML082620238
Person / Time
Site:	Technical Specifications Task Force
Issue date:	09/17/2008
From:	David Bice, Gambrell R, Joseph Messina, Yates B Babcock & Wilcox, BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force, Westinghouse Owners Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-08-14
Download: ML082620238 (4)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY September 17, 2008 TSTF-08-14 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to NRC May 5, 2008 Request for Additional Information Regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control"

REFERENCE:

Letter from Robert B. Elliott (NRC) to the Technical Specifications Task Force, "Request for Additional Information Regarding TSTF-501, Revision 0,

'Relocate Stored Fuel Oil and Lube Oil Values to Licensee Control'," dated May 5, 2008.

Dear Sir or Madam:

In the referenced letter, the NRC provided a Request for Additional Information (RAI) regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." This letter responds to the NRC's request.

The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.

Should you have any questions, please do not hesitate to contact us.

Bert Yates (PWROG/W) John Messina (BWROG)

David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W)

Enclosure cc: Robert Elliott, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administered by EXCEL Services Corporation

Response to NRC May 5, 2008 Request for Additional Information (RAI) Regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" The following is the Technical Specifications Task Force (TSTF) response to NRCs May 5, 2008 letter requesting the following information to complete the review of TSTF-501.

1. Discuss how a Diesel Fuel Oil, Lube Oil, and Starting Air TS that allows less than a 7 day fuel-oil storage requirement without requiring operator actions is in accordance with GDC 17 of Appendix A to 10 CFR 50.

Background:

General Design Criterion (GDC) 17, Electric Power Systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. In addition, Criterion 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability. NRC Regulatory Guide (RG) 1.137 describes methods acceptable to the NRC staff for complying with GDC 17 of Appendix A to 10 CFR 50 regarding fuel oil systems for standby diesel generators. Regulatory position 1.c of RG 1.137 states:

Section 5.4, Calculation of Fuel Oil Storage Requirements, of ANSI N195-1976 sets forth two methods for the calculation of fuel-oil storage requirements. These two methods are (1) calculations based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. For the time-dependent load method, the minimum required capacity should include the capacity to power the engineered safety features.

The two calculation methods found in Section 5.4 of ANSI N195-1976 are based on meeting the requirements as found in Section 5.2 and 5.3 of ANSI N195-1976. Section 5.2 and 5.3 of ANSI N195-1976 state:

The on-site oil storage shall be sufficient to operate the minimum number of diesel-generators following the limiting design basis accident for either seven (7) days, or the time required to replenish the oil from sources outside the plant site following any limiting design-basis event without interrupting the operation of the diesel, whichever is longer.

The use of the bracketed term, [7] days, in TSTF-501 for the Diesel Fuel Oil, Lube Oil, and Starting Air TS, would change the STS NUREGs to reflect that the fuel-oil storage requirement is a plant specific value. As a result, licensees may attempt to adopt TSTF-501, without technical branch review under the CLIIP process, even if they have less than a 7 day fuel-oil storage requirement. It is the NRC staffs position, as documented in RG 1.137, that 7 days is the minimum requirement for fuel-oil storage requirements in order to meet GDC 17 of Appendix A to 10 CFR 50. As such, the staff believes that the fuel-oil storage requirements in Diesel Fuel Oil, Lube Oil, and Starting Air TS, should be an un-bracketed term of 7 days.

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Response to NRC May 5, 2008 Request for Additional Information (RAI) Regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control"

Response

The RAI assumes that adopting TSTF-501 would allow a plant to change their current licensing basis value for the number of days of fuel oil under the CLIIP process. That is not the purpose of the changes proposed in TSTF-501. TSTF-501 revises the format of the required fuel oil volume as expressed in the Technical Specifications from "gallons" to "days of diesel generator operation". Under the CLIIP process, plants would insert their CLB value for the number of days of fuel oil they are currently required to maintain onsite into the Action in place of the bracketed "[7]".

The reason the 7 day value is bracketed, as stated in TSTF-501 under "Proposed Change," is because some plants have received NRC approval of a licensing basis volume less than 7 days. Licensees will insert the number of days of fuel oil and lube oil required by their current licensing basis for the bracketed value of [7] days, and should insert one day less than their licensing basis required volume in place of the bracketed value of [6] days, in Conditions A and B.

The Staff's question, ("Discuss how a TS that allows less than a 7 day fuel-oil storage requirement without requiring operator actions is in accordance with GDC 17") is not related to the proposed change. The answer to that unrelated question would be found in the site-specific NRC approval of the license amendments that approved less than seven days of fuel oil. That question is outside the scope of TSTF-501, as TSTF-501 states, "Licensees should insert the number of days of fuel oil and lube oil required by the licensing basis for the bracketed value of [7] days." Should a licensee attempt to adopt TSTF-501 utilizing the CLIIP and propose to change their licensing basis, the Staff acceptance review procedures (LIC-109) specify that requested licensing actions that deviate from the model CLIIP should be removed from the CLIIP process.

Inclusion of a bracketed [7] days in TSTF-501 does not allow any change to the requesting plant's licensing basis. It simply acknowledges that a plant's current licensing basis value, as approved by the NRC, may be less than 7 days. An informal industry survey indicated that the Technical Specifications of over 20% of the plants require a fuel oil volume less than that equivalent to 7 days of operation. For those plants with a Technical Specification limit less than 7 days, the typical justification was based on a plant-specific design that provides less than 7 days of fuel oil for each individual diesel generator but at least 7 days of operation for a single diesel generator, or on demonstration of a time less than 7 days to replenish fuel oil from an outside source as allowed by the quoted Sections 5.2 and 5.3 of ANSI N195-1976.

There may be other justifications that the NRC has accepted for a diesel fuel oil value less than 7 days.

The Background section of the RAI states, "It is the NRC staffs position, as documented in RG 1.137, that 7 days is the minimum requirement for fuel-oil storage requirements in order to meet GDC 17 of Appendix A to 10 CFR 50." As described above, this statement is inconsistent with RG 1.137 and many NRC approved license amendments. It is also inconsistent with the purpose of Regulatory Guides. As stated at the bottom of the first page of Regulatory Guide 1.137, under "USNRC Regulatory Guides," "Regulatory Guides are Page 2

Response to NRC May 5, 2008 Request for Additional Information (RAI) Regarding TSTF-501, Revision 0, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" used to describe and make available to the public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the staff in evaluating specific problems or postulated accidents, or to provide guidance to applicants. Regulatory Guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for findings requisite to the issuance or continuance of a permit or license by the Commission."

The industry concern with removing the brackets from the [7] day value in the Technical Specifications is that it would imply that a plant must justify their current licensing basis value if that value is less than a 7 day volume for each diesel generator. That would represent an unwarranted burden to the NRC and the licensees as that justification has already been presented to and accepted by the NRC.

The industry proposes that the bracketed [7] value be retained in the Traveler. In order to address the NRC's concern, we recommend that the NRC's Model Application contain a requirement similar to the following: "Licensees that propose a value other than 7 days in SR 3.8.3.1, SR 3.8.3.2, Condition 3.8.3.A or Condition 3.8.3.B, consistent with their current licensing basis, must provide a reference to the NRC's previous approval of the current licensing basis value(s) and a summary of the basis for the NRC's approval. Requests to revise the current licensing basis requirement on the required number of days of fuel oil or lubrication oil that must be maintained will not be processed under the Consolidated Line Item Improvement Process." This will ensure that licensees will not adopt TSTF-501 without technical branch review if they are requesting a change to their licensing basis to require less than their current fuel-oil and lubricating oil storage requirement.

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