ML21068A409

NRR E-mail Capture - Entergy Fleet (GGNS and RBS) -Approval of TSTF-501 LAR, Relocate Sored Fuel Oil and Lube Oil Volume Values to Licensee Control

ML21068A409
Person / Time
Site:	Grand Gulf, River Bend
Issue date:	03/09/2021
From:	Siva Lingam NRC/NRR/DORL/LPL4
To:	Schrage J Entergy Nuclear Operations
References
EPID L-2020-LLA-0032
Download: ML21068A409 (24)

Text

From: Lingam, Siva Sent: Tuesday, March 9, 2021 1:00 PM To: Schrage, John Cc: Dixon-Herrity, Jennifer; Blechman, Paula; Burkhardt, Janet; Buckberg, Perry; Gaston, Ronald William; Couture III, Philip; Hardy, Jeffery A; Schenk, Timothy A; bjohns@entergy.com

Subject:

FW: Entergy Fleet (GGNS and RBS) - Approval of TSTF-501 LAR, Relocate Sored Fuel Oil and Lube Oil Volume Values to Licensee Control (EPID L-2020-LLA-0032)

Attachments: ML21040A292.pdf We were not able to replace the unsigned document in ADAMS with the attached digitally signed document because of process problems associated with fast Web review. As a result, we replaced the unsigned ADAMS document with another one by placing R/A (record approved) in lieu of digital signatures (ADAMS Accession No. ML21040A292). Therefore, please use the attached digitally signed document as an official document to the licensee, and ignore the previous document(s) you received by listserv. Sorry again for the inconvenience! Thank you.

From: Lingam, Siva Sent: Friday, March 05, 2021 7:43 AM To: Schrage, John Cc: Dixon-Herrity, Jennifer ; Gaston, Ronald William ; Couture III, Philip ; Hardy, Jeffery A ; Schenk, Timothy A ; bjohns@entergy.com; Buckberg, Perry

Subject:

Entergy Fleet (GGNS and RBS) - Approval of TSTF-501 LAR, Relocate Sored Fuel Oil and Lube Oil Volume Values to Licensee Control (EPID L-2020-LLA-0032)

Attached please find an advanced copy of the subject amendment that was digitally signed by my Branch Chief. Looks like, there was an overlook on our administration assistant side that she accidentally processed the incorrect version of the document, i.e., the one that was not digitally signed by my Branch Chief. My Branch Chief did digitally sign yesterday, however, document without digital signatures was processed by mistake. Until we fix this, please use the attached copy. Sorry for the inconvenience!

Thank you.

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Grand Gulf Nuclear Station Entergy Fleet Location: O-9E22; Mail Stop: O-9E03 Telephone: 301-415-1564 E-mail address: Siva.Lingam@nrc.gov

Hearing Identifier: NRR_DRMA Email Number: 1064 Mail Envelope Properties (SJ0PR09MB610976B4B717F8EF9AF0AFC3F6929)

Subject:

FW: Entergy Fleet (GGNS and RBS) - Approval of TSTF-501 LAR, Relocate Sored Fuel Oil and Lube Oil Volume Values to Licensee Control (EPID L-2020-LLA-0032)

Sent Date: 3/9/2021 1:00:14 PM Received Date: 3/9/2021 1:00:14 PM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients:

"Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>

Tracking Status: None "Blechman, Paula" <Paula.Blechman@nrc.gov>

Tracking Status: None "Burkhardt, Janet" <Janet.Burkhardt@nrc.gov>

Tracking Status: None "Buckberg, Perry" <Perry.Buckberg@nrc.gov>

Tracking Status: None "Gaston, Ronald William" <rgasto1@entergy.com>

Tracking Status: None "Couture III, Philip" <pcoutur@entergy.com>

Tracking Status: None "Hardy, Jeffery A" <jhardy@entergy.com>

Tracking Status: None "Schenk, Timothy A" <TSCHENK@entergy.com>

Tracking Status: None "bjohns@entergy.com" <bjohns@entergy.com>

Tracking Status: None "Schrage, John" <jschrag@entergy.com>

Tracking Status: None Post Office: SJ0PR09MB6109.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1783 3/9/2021 1:00:14 PM ML21040A292.pdf 500208 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

March 4, 2021 Mrs. Mandy Halter Vice President, Regulatory Assurance Entergy Services, LLC M-ECH-29 1340 Echelon Parkway Jackson, MS 39213

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 AND RIVER BEND STATION, UNIT 1 - ISSUANCE OF AMENDMENTS RE: ADOPTION OF TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL (EPID L-2020-LLA-0032)

Dear Mrs. Halter:

The U.S. Nuclear Regulatory Commission (the Commission) has issued amendments consisting of changes to the technical specifications (TSs) in response to your application dated February 26, 2020, as supplemented by letter dated March 3, 2021, for Grand Gulf Nuclear Station, Unit 1 (Grand Gulf) and River Bend Station, Unit 1 (River Bend). The following amendments are enclosed:

x Amendment No. 228 to Renewed Facility Operating License No. NPF-29 for Grand Gulf.

x Amendment No. 206 to Renewed Facility Operating License No. NPF-47 for River Bend.

The amendments revise the Grand Gulf and River Bend TSs to adopt Technical Specifications Task Force (TSTF) 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.

The amendments revise Grand Gulf and River Bend 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 TSs and placing them in the TS Bases so that they may be modified under licensee control.

The TSs are also revised such that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator at Grand Gulf and River Bend.

Corresponding Surveillance Requirements and TS Bases are also revised to reflect the above changes.

M. Halter 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/

Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-416 and 50-458

Enclosures:

1. Amendment No. 228 to NPF-29

2. Amendment No. 206 to NPF-47

3. Safety Evaluation cc: Listserv

ENTERGY OPERATIONS, INC.

SYSTEM ENERGY RESOURCES, INC.

COOPERATIVE ENERGY, A MISSISSIPPI ELECTRIC COOPERATIVE ENTERGY MISSISSIPPI, LLC DOCKET NO. 50-416 GRAND GULF NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 228 Renewed License No. NPF-29

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

A. The application for amendment by Entergy Operations, Inc. (the licensee), dated February 26, 2020, as supplemented by letter dated March 3, 2021, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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-29 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 228 are hereby incorporated into this renewed license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Digitally signed by Jennifer L. Dixon-Herrity Dixon-Herrity Date: 2021.03.04 14:53:29 -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-29 and the Technical Specifications Date of Issuance: March 4, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 228 RENEWED FACILITY OPERATING LICENSE NO. NPF-29 GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416 Replace the following pages of Renewed Facility Operating License No. NPF-29 and the Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.8-22 3.8-22 3.8-24 3.8-24

amended, are fully applicable to the lessors and any successors in interest to those lessors, as long as the renewed license of GGNS Unit 1 remains in effect.

(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54. In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.

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

(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 4408 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 228 are hereby incorporated into this renewed license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an indicate only mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an indicate only mode will be conducted.

4 Amendment No. 228

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ENTERGY LOUISIANA, LLC AND ENTERGY OPERATIONS, INC.

DOCKET NO. 50-458 RIVER BEND STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 206 License No. NPF-47

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

A. The application for amendment by Entergy Operations, Inc. (the licensee, EOI),

dated February 26, 2020, as supplemented by letter dated March 3, 2021, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

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-47 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 206 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Digitally signed by Jennifer L. Dixon-Herrity Dixon-Herrity Date: 2021.03.04 14:54:28 -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-47 and the Technical Specifications Date of Issuance: March 4, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 206 RENEWED FACILITY OPERATING LICENSE NO. NPF-47 RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458 Replace the following pages of the Renewed Facility Operating License No. NPF-47 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.8-21 3.8-21 3.8-23 3.8-23

(2) EOI, pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use and operate the facility at the above designated location in accordance with the procedures and limitations set forth in this renewed license; (3) EOI, pursuant to Section 103 of the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) EOI, pursuant to Section 103 of the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) EOI, pursuant to Section 103 of the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) EOI, pursuant to Section 103 of the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

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

(1) Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3091 megawatts thermal (100% rated power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 206 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 206

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 228 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-29 AND AMENDMENT NO. 206 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-47 ENTERGY OPERATIONS, INC.

GRAND GULF NUCLEAR STATION, UNIT 1 RIVER BEND STATION, UNIT 1 DOCKET NOS. 50-416 AND 50-458

1.0 INTRODUCTION

By application dated February 26, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20057G004), as supplemented by letter dated March 3, 2021 (ADAMS Accession No. ML21062A198), Entergy Operations, Inc. (the licensee) requested changes to the Technical Specifications (TSs) for Grand Gulf Nuclear Station, Unit 1 (Grand Gulf) and River Bend Station, Unit 1 (River Bend).

The proposed changes would revise Grand Gulf and River Bend 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 TSs and placing them in the TS Bases so that they may be modified under licensee control, consistent with Technical Specifications Task Force (TSTF)

Improved Standard Technical Specifications Change Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control dated February 20, 2009 (ADAMS Accession No. ML090510686). The TSs would also be revised such that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator (DG) at Grand Gulf and River Bend. The licensee also proposed associated changes to the corresponding surveillance requirements (SRs) and TS Bases.

Any change to the TSs, including the numerical volume requirements contained therein, requires prior approval from the U.S. Nuclear Regulatory Commission (NRC, the Commission).

A licensee may need to modify diesel fuel oil numerical volumes to account for changes to the energy content (British Thermal Units (BTU)/gallon) of available fuels in the market.

Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements. Accordingly, the licensees 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 requirements. If approved, these Enclosure 3

amendments would permit the numerical volume requirements for stored diesel fuel oil and lube oil to be modified under licensee control. Changes to the affected TS Bases pages will be made by the licensee in accordance with the TS 5.5.11, Technical Specifications (TS) Bases Control Program.

The supplemental letter dated March 3, 2021, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 7, 2020 (85 FR 19510).

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 Title 10 of the Code of Federal Regulations Part 50, Section 50.36(c)(2)(i) because they support the operation of the standby AC power sources.

Grand Gulfs and River Bends standby AC power systems are each 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. Each DG is provided with a storage tank having a diesel fuel oil capacity sufficient to operate that DG for a period of 7 days while the DG is supplying maximum post loss-of-coolant accident load demand. 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. Diesel fuel oil is transferred from each storage tank to its respective day tank by a transfer pump associated with each storage tank.

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 DGs diesel engine working surfaces and to remove excess heat generated by friction during operation. Each DG engine oil sump contains an 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 Grand Gulf and River Bend TS 3.8.3 by removing the current stored diesel fuel oil and lube oil numerical volume requirements from the TSs and placing them in the TS Bases so that they 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 3.8.3 would be revised in the Actions table. Currently, Conditions A and B are entered when the stored fuel oil numerical volume requirement is not met. As discussed in the current TS Bases, the numerical volume requirements for Grand Gulf and River Bend are based on volumes less than a 7-day supply, but at least a 6-day supply. The

proposed TS revision incorporates the volumetric requirements from the TSs into the TS Bases.

In addition, the Grand Gulf and River Bend TSs are revised so that Condition A is entered when the stored diesel fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply.

Condition B would be entered when the stored lube oil inventory is less than a 7-day supply, but greater than a 6-day supply.

2.2.2 Proposed Changes to SRs 3.8.3.1 and 3.8.3.2 Currently, SR 3.8.3.1 requires the licensee to verify that each fuel oil storage tanks numerical volume requirements are met. SR 3.8.3.2 requires the licensee to verify that the stored lube oil numerical volume requirements are met. As discussed in the current TS Bases, the numerical volume requirements of SR 3.8.3.1 and SR 3.8.3.2 are based on maintaining at least a 7-day supply. The revision would incorporate the volumetric requirements from the TSs into the TS Bases. The licensee proposed that the TSs be revised so that SR 3.8.3.1 requires the licensee to verify that the stored lube oil inventory is greater than or equal to a 7-day supply for each DG at Grand Gulf and River Bend. The licensee further proposed that the TSs be revised so that SR 3.8.3.2 requires the licensee to verify that the lube oil inventory is greater than or equal to a 7-day supply for all DGs at Grand Gulf and River Bend.

2.2.3 Proposed Changes to the TS Bases The reference to Appendix B of American National Standards Institute (ANSI) N195-1976, Fuel Oil Systems for Standby Diesel-Generators, in the Grand Gulf and River Bend TS Bases is deleted to correctly identify that the bases now reference the entire ANSI N195-1976. As a result, the only reference will be to ANSI N195-1976.

2.3 Regulatory Requirements and Guidance Used in the Evaluation of the Proposed Changes 2.3.1 Regulatory Requirements The regulation in 10 CFR 50.36, Technical specifications, provides the regulatory requirements for the content of the TSs and requires, in relevant part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a 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)(i), states, in part, that LCOs 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, When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The regulation in 10 CFR 50.36(c)(3) states that SRs 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.

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), that the TSs provide reasonable assurance that the health and safety of the public will not be endangered and, as stated in 10 CFR 50.40(d), that any applicable requirements of 10 CFR Part 51 have been satisfied.

2.3.2 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 Commission's regulations regarding diesel fuel oil systems for standby DGs and endorses ANSI standard ANSI N195-1976, with certain limitations. RG 1.137, Section C.1.c sets forth two methods for the calculation of diesel 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 DG. If the time-dependent load method is used, the minimum required capacity should include the capacity to power engineered safety features.

NUREG-1434, Revision 4.0, Standard Technical Specifications General Electric BWR [Boiling-Water Reactors]/6 Plants, dated April 2012 (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, provides an acceptable method of modifying the stored diesel fuel oil and lube oil requirements contained in the Standard Technical Specifications.

3.0 TECHNICAL EVALUATION

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 diesel 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 DG operating time requirements, such that Condition A is entered when the stored diesel fuel oil inventory is less than a 7-day supply, but greater than a 6-day supply, 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 and lube oil numerical volumes sufficient to meet the duration-based operating time requirements will be calculated using Section 5.4 of ANSI N195-1976, and the volumes are based on DG manufacturers consumption values for the run-time of the DGs. The use of this methodology

will ensure that the supplies of stored diesel fuel oil and lube oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC-approved methods.

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 and 3.8.3.2 Currently, SRs 3.8.3.1 and 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. The licensee proposes to revise SRs 3.8.3.1 and 3.8.3.2 to reflect the change from numerical volume requirements to durational requirements made in the 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 diesel fuel oil and lube oil for each DG, rather than a specified numerical volume. As a result, SRs 3.8.3.1 and 3.8.3.2 would require the licensee to verify that the combined volume of the diesel 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 stated in its application that an NRC-approved fuel oil calculation methodology is currently used to calculate fuel oil volumes. Specifically, on page 3 of the enclosure to the application, the licensee states:

The specific volume of fuel oil equivalent to a 7 and 6-day supply for [Grand Gulf]

and [River Bend] are calculated using the NRC-approved methodology described in Regulatory Guide (RG) 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 manufacturers consumption values for the run-time of the diesel generators.

The methodology for determining the 7-day stored diesel fuel oil supply for each DG, as well as the 7-day supply associated with Condition A, is calculated in accordance with RG 1.137, Revision 1 and ANSI N195 1976. 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, which is most limiting for the calculation of such capacity. One method for calculating the stored 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 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 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 fuel oil supply, which is more conservative than the time-dependent load method, is to calculate the storage capacity by assuming that the DG operates continuously for 7 days at its rated capacity. Both calculation methods shall include an explicit allowance for fuel consumption required by periodic testing.

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

One variable used in both stored diesel fuel oil calculation methods is the fuel consumption rate.

The property of diesel fuel oil having the most significant effect on the fuel consumption rate is the energy content (heating value) of the fuel. There are standards that correlate the energy content to the fuels American Petroleum Institute (API) gravity or absolute specific gravity. At a minimum, plants calculate their required fuel storage values assuming the most limiting API gravity or absolute specific gravity, and therefore, the most limiting fuel energy content. As long as the diesel 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 consumption and required stored volume remains valid. Current SR 3.8.3.3 requires new fuel to be tested in order to verify that the new fuel API gravity or absolute specific gravity is within the range assumed in the diesel fuel oil consumption calculations.

The 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.

Accordingly, the NRC staff finds that the above methods used by the licensee still provide reasonable assurance that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met. Therefore, the changes to SRs 3.8.3.1 and 3.8.3.2 are acceptable.

3.3 TS Bases Changes The regulation at 10 CFR 50.36(a)(1) states, in part, 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 technical specifications. 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 NRC staff concludes that the proposed TS Bases changes describe the bases for the affected TSs and follow the Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132).

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 reasonable 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 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 diesel 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 and 3.8.3.2 continue to provide reasonable 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. Because the revised SRs will continue to meet 10 CFR 50.36(c)(3), the NRC staff finds them acceptable.

In summary, the NRC staff finds that the proposed Grand Gulf and River Bend TSs changes collectively provide reasonable assurance that the health and safety of the public will not be endangered.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Mississippi and Louisiana officials were notified of the proposed issuance of the amendments on February 5, 2021. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted areas as defined in 10 CFR Part 20 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on April 7, 2020 (85 FR 19510), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: T. Sweat Date: March 4, 2021

ML21040A292 *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DSS/STSB/BC* NRR/DSS/SCPB/BC*

NAME SLingam PBlechman VCusumano BWittick DATE 02/16/2021 02/12/2021 02/05/2021 02/22/2021 OFFICE OGC - NLO* NRR/DORL/LPL4/BC* NRR/DORL/LPL/PM*

NAME JMcManus JDixon-Herrity SLingam DATE 03/03/2021 03/03/2021 03/04/2021