ML23088A123

Attachment 3: Marked-Up Technical Specification, Bases Pages

ML23088A123
Person / Time
Site:	Callaway
Issue date:	03/29/2023
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML23088A118	List: ML23088A120 ML23088A121 ML23088A122 ML23088A123 ML23088A124 ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control
References
ULNRC-06751
Download: ML23088A123 (1)

Text

Attachment 3 to ULNRC-0675 I Page 1 of 5 ATTACHMENT 3 MARKED-UP TS BASES PAGES (PROVIDED FOR INFORMATION ONLY) to ULNRC-0675 I Page 2 of 5 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 discussed in the FSAR, Section 9.5.4.2 (Ref. I) and Regulatory Guide 1.137 (Ref. 2). The maximum load demand is calculated based on the fuel consumption by one DG for operation at continuous rating for 7 days.

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 pumps 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 resulting 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. Regula tory Guide I .1 37 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (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. The contained volume of lube oil in each diesel engine crankcase is sufficient to allow full load operation for greater than 7 days.

With a contained volume equivalent to the add oil mark on the dipstick, a 10 day supply is available to support full load operation of the engine.

The lube oil system is designed with an automatic makeup supply that begins makeup before the low level alarm is received and before reaching the add oil level on the dipstick. The capacity and controls associated with the lube oil system are sufficient to ensure a minimum of 7 days of operation. Refer to the table below:

to ULNRC-0675 I Page 3 of 5 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 In this Condition, the 7 day fue I oil supply (80900 gallons) 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 equivalent to a 6 day supply is 69,800 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 per iod 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), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

B.1 In this Condition there may not be an adequate amount of lube oil capacity to support the 7 days of full load operation of the diesel engi ne.

However, in the unlikely event that this Condition is entered the lower limit was established to ensure that there was at least a 6 day supply of lube oil. The lube oil inventory ecwivalent to a 7 day supply is 750 gallons, and a 6 day sunrly is 686 gallons. 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 diesel generator inoperable.

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 to U LNRC-0675 I Page 4 of 5 ACTIONS j. (continued) limits and not within Ii mits specified by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUI REM ENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DGs operation for 7 days at full load.

The fuel oil inventory equivalent to a 7 day suprly i s 80,900 gallons 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 oi I consumption calculation. 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 based on operating experience, equipment reliability, and plant risk and 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 750 gal requirement lube oil inventory eQuivalent to a 7 day supply is 750 gallons andis based on the DG manufacturer consumption values for the run time of the DG. There are several methods available to verify a lube oil volume greater than or equal to 750 gallons. The preferred method is to verify that lube oil level is greater than the required inventory with the engine dipstick. Other indirect methods, such as the local level indicator or the absence of a low level alarm are acceptable as alternate methods.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

to ULNRC-0675 I Page5 of 5 SURVEILLANCE SR 3.83.5 (continued)

REQUI REM ENTS 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 based on operati ng experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance.

SR 3.8.3.6 This SR is not applicable.

REFERENCES 1. FSAR, Section 9.5.4.2.

2. Regulatory Guide 1.137.

3. ANSI N195-1976, AppendixB.

4. FSAR, Chapter 6.

5. FSAR, Chapter 15.

6. ASTM Standards: D4057; D975-81; DI 796-83; DI 552-79; D2622-82; D2276, Method A, D4294-90, DI 298-85.

7. ASTM Standards, D975, Table I.

8. ASME, Boiler and Presser Vessel Code, Section Xl.