ML20282A953

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

ML20282A953
Person / Time
Site:	Palo Verde
Issue date:	10/08/2020
From:	Rash B Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-08169-BJR/MDD
Download: ML20282A953 (20)

Text

10 CFR 50.90 t l aps BRUCE J. RASH Vice President Nuclear Engineering/Regulatory 102-08169-BJR/MDD Palo Verde October 8, 2020 Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7602 Tel 623.393.5102 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Renewed Operating License Number NPF-41, NPF-51, and NPF-74 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control Pursuant to Section 50.90, of Title 10 of the Code of Federal Regulations (10 CFR),

Arizona Public Service Company (APS) is submitting a request for an amendment to the Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3.

The proposed changes revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS. The TS is 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 (SR) 3.8.3.1 and 3.8.3.2 are revised to reflect the above change.

Regarding stored diesel fuel oil and lube oil, no changes to the current plant configuration are proposed in this application. In addition, no changes to any SR Frequency, Required Actions, or Completion Times are proposed in this application.

These proposed changes are consistent with NRC approved Revision 1 to TSTF Improved Standard Technical Specifications (STS) Change Traveler TSTF-501, 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).

The current licensing basis for PVNGS Units 1, 2, and 3 requires that a 7-day supply of stored diesel fuel oil and lube oil be available for each diesel generator, which is unchanged by this application.

The proposed change is also consistent with NRC clarification letter to the TSTF dated April 3, 2014 (ADAMS Accession No. ML14084A512), which requested the following commitment.

A member of the STARS Alliance, LLC Callaway Diablo Canyon Palo Verde Wolf Creek

102-08169-BJR/MDD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Application to Revise Technical Specifications to Adopt TSTF-501 Page 2 APS is providing a regulatory commitment to verify the inclusion or to revise the PVNGS Updated Final Safety Analysis Report (UFSAR) with the following information and to submit the revised description with the next UFSAR update:

The specific Emergency Diesel Generator (EDG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EDG run-duration requirements are calculated using Section 5.4 of American National Standards Institute (ANSI) N195-1976, Fuel Oil Systems for Standby Diesel-Generators, and are based on applying the conservative assumption that the EDG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators, Regulatory Position C.1.c.

The enclosure provides a description and assessment of the proposed changes. of the enclosure provides the existing TS pages marked-up to show the proposed changes. Attachment 2 of the enclosure provides revised (clean) TS pages. contains marked-up TS Bases pages, for information.

In accordance with the PVNGS Quality Assurance Program, the Plant Review Board has reviewed and approved the license amendment request (LAR).

A pre-submittal meeting for TSTF-501 was held between APS and the NRC staff on September 24, 2020. APS requests approval of the proposed license amendment by October 9, 2021, with the amendment being implemented within 90 days.

In accordance with 10 CFR 50.91(a)(1), Notice for Public Comment, the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission. In accordance with 10 CFR 50.91(b)(1), Notice for Public Comment; State Consultation, a copy of this application and its reasoned analysis about no significant hazards considerations is being provided, by copy of this letter, to the Arizona Department of Health Services - Bureau of Radiation Control.

Should you need further information regarding this letter, please contact Matthew S.

Cox, Licensing Section Leader, at (623) 393-5753.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: October 8, 2020 (Date)

Sincerely, Digitally signed by Rash, Rash, Bruce Bruce (Z77439)

DN: cn=Rash, Bruce (Z77439)

(Z77439) Date: 2020.10.08 16:16:51

-07'00' BJR/MDD/mg

ENCLOSURE Description and Assessment of Proposed License Amendment

Enclosure Description and Assessment of Proposed License Amendment Description and Assessment of Proposed License Amendment

Subject:

Application to Revise Technical Specifications to Adopt TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

2.0 PROPOSED CHANGE

S

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA

6.0 ENVIRONMENTAL CONSIDERATION

ATTACHMENTS:

1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases (Mark-Up) i

Enclosure Description and Assessment of Proposed License Amendment

1.0 DESCRIPTION

The proposed changes revise Technical Specification (TS) 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS. The TS 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. This change is consistent with NRC approved Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications (STS)

Change Traveler TSTF-501, 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).

2.0 PROPOSED CHANGE

S The proposed changes revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS. The TS 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. As a result:

• Condition A and Condition B in the Action table are revised. Currently, Condition A and Condition B are entered when the stored diesel fuel oil and lube oil numerical volume requirements are not met. The revision removes the volumetric requirements. The TS are modified so that Condition A and Condition B are entered when the stored diesel fuel oil and lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more diesel generators.

• Surveillance Requirements (SR) 3.8.3.1 and 3.8.3.2 are revised. Currently, SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. As discussed in the current TS Bases, the numerical volume requirements in SR 3.8.3.1 and SR 3.8.3.2 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 are modified so that SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil inventory is greater than or equal to a 7-day supply for each diesel generator.

• The reference to Appendix B of ANSI N195-1976 in the TS Bases is deleted. As a result, the reference will be to ANSI N195-1976.

Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF Traveler-501, Revision 1, is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

The SR 3.8.3.1 Bases in TSTF Traveler-501, Revision 1, references ANSI-N195. At the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3, the current reference is ANSI-N195, Appendix B. The reference to Appendix B of ANSI N195-1976 in the TS Bases is deleted. As a result, the reference will be to ANSI N195-1976.

Page 1 of 4

Enclosure Description and Assessment of Proposed License Amendment Arizona Public Service Company (APS) is not proposing variations or deviations from the TS changes described in TSTF-501, Revision 1, or the NRC staffs model safety evaluation (SE) published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the CLIIP Notice of Availability.

The proposed change does, however, clarify in the TS Bases mark-up that the current 7-day lubricating oil supply is at the one-inch visible level (252 gallons) in the sightglass, as compared to the low level alarm value of 2.5 inches (352 gallons),

which was selected, as a conservative value, in the existing Condition B.

The proposed change is also consistent with NRC clarification letter to the TSTF dated April 3, 2014 (ADAMS Accession No: ML14084A512), that requested the following commitment.

APS is providing a regulatory commitment to verify the inclusion or to revise the PVNGS Updated Final Safety Analysis Report (UFSAR) with the following information and to submit the revised description with the next UFSAR update:

The specific Emergency Diesel Generator (EDG) fuel oil volumes contained in the diesel fuel oil storage tank(s) necessary to ensure that EDG run-duration requirements are calculated using Section 5.4 of American National Standards Institute (ANSI) N195-1976, Fuel Oil Systems for Standby Diesel-Generators, and are based on applying the conservative assumption that the EDG is operated continuously at rated capacity. This fuel oil calculation methodology is one of the two approved methods specified in Regulatory Guide (RG) 1.137, Revision 1, Fuel Oil Systems for Standby Diesel Generators, Regulatory Position C.1.c.

3.0 BACKGROUND

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

4.0 TECHNICAL ANALYSIS

APS has reviewed the model SE published in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLIIP Notice of Availability. APS has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to PVNGS Units 1, 2 and 3 and therefore justify this amendment for the incorporation of the proposed changes to the PVNGS Units 1, 2 and 3 TS.

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Arizona Public Service Company (APS) has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Page 2 of 4

Enclosure Description and Assessment of Proposed License Amendment Description of Amendment Request: The proposed changes revise TS by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TS.

The current stored diesel fuel oil and lube oil numerical volume requirements are based on a 7-day supply. The TS 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.

Basis for proposed no significant hazards determination: As required by 10 CFR 50.91(a), the APS analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change removes the volume of diesel fuel oil and lube oil required to support 7-day operation of each onsite diesel generator and the volume equivalent to a 6-day supply and relocates them to licensee control. The specific volume of fuel oil equivalent to a 7 and 6-day supply is calculated using the NRC-approved methodology described in Regulatory Guide 1.137, Revision 1, Fuel-Oil Systems for Standby Diesel Generators and ANSI N195-1976, Fuel Oil Systems for Standby Diesel-Generators. The specific volume of lube oil 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. Because the requirement to maintain a 7-day supply of diesel fuel oil and lube oil is not changed and is consistent with the assumptions in the accident analyses, and the actions taken when the volume of fuel oil and lube oil are less than a 6-day supply have not changed, neither the probability nor the consequences of any accident previously evaluated will be affected.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: 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.

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

Page 3 of 4

Enclosure Description and Assessment of Proposed License Amendment

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change removes the volume of diesel fuel oil and lube oil required to support 7-day operation of each onsite diesel generator and the volume equivalent to a 6-day supply and relocates them to licensee control. As the bases for the existing limits on diesel fuel oil and lube 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 change does not involve a significant reduction in a margin of safety.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on May 26, 2010 (75 FR 29588).

APS has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to PVNGS Units 1, 2 and 3.

6.0 ENVIRONMENTAL CONSIDERATION

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 connection with the proposed change.

Page 4 of 4

Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 1:

Proposed Technical Specification Changes (Mark-Up)

Changed Pages 3.8.3-1 3.8.3-3

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 A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel level less within limits.

than a 7 day suggly and greater than a 6 day SUQQly < 80%

iRelisateel f~el le>.iel aRel ;:.. 7~ % iRelisateel fuel level in storage tank.

B. One or more DGs 8.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with lube oil inventory inventory to within less than a 7 day limits.

suggly and greater than a 6 day SUQQly.

< ~.a iRsRes aRel

. ~ iRsR >.iisiele iR tRe si§At§lass.

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

limits.

(continued)

PALO VERDE UNITS 1,2,3 3.8.3-1 AMENDMENT NO. 44+

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 :2: a 7 In accordance day supply of 80% indicated fuel-level. with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lubricating oil inventory is :2: a 7 day In accordance supply2.5 inches visible in the sightglass. with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Fuel Oil Testing Oil Testing Program. Program SR 3.8.3.4 Verify each DG starting air receiver pressure is In accordance

2: 230 psig. with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Surveillance Frequency Control Program PALO VERDE UNITS 1,2,3 3.8.3-3 AMENDMENT NO. 484, 4-83

Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 2:

Revised Technical Specification Pages Changed Pages 3.8.3-1 3.8.3-3

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 A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel level less within limits.

than a 7 day supply and greater than a 6 day supply in storage tank.

B. One or more DGs 8.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with lube oil inventory inventory to within less than a 7 day limits.

supply and greater than a 6 day supply.

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

limits.

(continued)

PALO VERDE UNITS 1,2,3 3.8.3-1 AMENDMENT NO. 447

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 :2: a 7 In accordance day supply of fuel. with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lubricating oil inventory is :2: a 7 day In accordance supply. with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Fuel Oil Testing Oil Testing Program. Program SR 3.8.3.4 Verify each DG starting air receiver pressure is In accordance

2: 230 psig. with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Surveillance Frequency Control Program PALO VERDE UNITS 1,2,3 3.8.3-3 AMENDMENT NO. 484, 4 Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 3:

Proposed Technical Specification Bases (Mark-Up)

Changed Pages B 3.8.3-1 B 3.8.3-3 B 3.8.3-4 B 3.8.3-6 B 3.8.3-9

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel oil capacity sufficient to operate that diesel for a period of 7 days, while the DG is supplying maximum post loss of coolant accident load demand as discussed in the FSAR, Section 9.5.4.2.1 (Ref. 1) and Regulatory Guide 1.137 (Ref. 2) . The maximum load demand is calculated using the assumption that at least two DGs are available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from storage tank to day tank by a transfer pump associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result in the loss of more than one DG. All outside tanks, pumps, and piping are located underground.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195-1976 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level.

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. Each engine oil sump contains an inventory capable of supporting a minimum of 7 days of operation. This supply is sufficient supply to allow the operator to replenish lube oil from outside sources.

Each DG has independent and redundant starting air subsystems.

Each DG starting subsystem provides a stored compressed air supply sufficient for accomplishing a DG start in ::;; 10 seconds.

Each air receiver has been sized to accomplish 5 consecutive DG starts from the receiver design working pressure without being refilled.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.3-1 REVISION G

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES 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 are governed by separate Condition entry and application of associated Required Actions.

A.1 In this Condition (i.e., < 80% indicated fuel level), the 7 day fuel oil supply for a DG is not available. However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply. The fuel oil level equivalent to a 6 day supply is 60,283 gallons. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required level; or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (~ 6 days or ~ 71 %

indicated fuel level), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

8.1 In this Condition, the 7 dayWitl=l---lube oil inventory < 2.5 inches 11isible in the sightglass, i.e., sufficient lubricating oil to support 7 days of continuous DG operation at full load conditions i§maY-not be-available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. The lube oil inventory equivalent to a 6 day supply is 216 gallons (0.5 inch visible in sightglass).

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

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.3-3 REVISION ee

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS 8.1 (continued)

The normal level of lube oil is maintained at mid-scale visible on the sightglass which ensures sufficient lube oil to support at least 13.5 days of engine operation during periods when the DG is supplying maximum post-LOCA load demand as discussed in the FSAR (Ref. 1). This is based on a conservative lube oil consumption rate of 1.5 gallons per hour and 486 gallons of available lube oil between the top of the lube oil suction pipe in the engine crankcase (minimum available level) and the mid-scale position on the sightglass. 252 gallons or 7 days of available lube oil is actually indicated at 1 inch visible in the sightglass. Wi-tR

~ 2.5 inohes visible in the sightglass, a oonservative supply of lube oil is ensured for 7 days of full load operation.

C.1 This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.3. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling), contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend.

Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable.

The 7 day Completion time allows for further evaluation, resampling, and re-analysis of the DG fuel oil.

D.1 With the new fuel oil properties defined in the Bases for SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.3-4 REVISION 00

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for 7 days at full load. The fuel oil level equivalent to a 7 day supply is 69,718 gallons (Ref. 9) when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel.

Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, and the corresponding fuel consumption rate, the onsite fuel storage volume required for 7 days of operation can be determined. SR 3.8.3.3 requires new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumption calculations . The 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

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

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of full load operation for each DG. The 2.5 inohes visible in the sightglass requirement lube oil inventory equivalent to a 7 day supply is 252 gallons (Ref. 10) and is based on the DG manufacturer consumption values for the run time of the DG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG, when the DG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer recommended minimum level.

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

SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. 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 (continued)

PALO VERDE UNITS 1,2,3 B 3.8.3-6 REVISION @&

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES REQUIREMENTS SR 3.8.3.5 (continued)

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

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 storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The presence of water does not necessarily represent failure of this SR provided the accumulated water is removed during the performance of this Surveillance.

REFERENCES 1. FSAR, Section 9.5.4.2.

2. Regulatory Guide 1.137.

3. ANSI N195-1976, Appendix B.

4. FSAR, Chapter 6.

5. FSAR, Chapter 15.

6. ASTM Standards: D4057-81; D975-07b; D976-91; D4737-90; D1796-83; D2276-89, Method A.

7. ASTM Standards, D975, Table 1.

8. "Emergency Diesel Generator and Diesel Fuel Oil Systems Instrumentation Uncertainty Calculation", 13-JC-DG-203, Parts 23 and 51

9. Calculation 13-JC-DF-0202, "Diesel Fuel Oil Storage Tank Level Instrument (DFN-L-33 & 34) Uncertainty Calculation"

10. Supplier Document M018-01413, "Lube Oil Reserve Capacity" PALO VERDE UNITS 1,2,3 B 3.8.3-9 REVISION ee