ML19018A206

Issuance of Amendment Nos. 290 and 318 to Revise Note on Brunswick TS 3.8.3 for One-Time Extension of Main Fuel Oil Storage Tank Completion Time

ML19018A206
Person / Time
Site:	Brunswick
Issue date:	05/06/2019
From:	Dennis Galvin Plant Licensing Branch II
To:	William Gideon Duke Energy Progress
Galvin D
References
EPID L-2018-LLA-0110
Download: ML19018A206 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 6, .201 9 Mr. William R. Gideon Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 290 AND 318 TO REVISE NOTE ON BRUNSWICK TS 3.8.3 FOR ONE-TIME EXTENSION OF MAIN FUEL OIL STORAGE TANK COMPLETION TIME (EPID L-2018-LLA-0110)

Dear Mr. Gideon:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 290 and 318 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2, respectively. These amendments are in response to your license amendment request dated April 25, 2018, as supplemented by letter dated March 26, 2019.

The amendments revise an existing note on Technical Specification (TS) 3.8.3, "Diesel Fuel Oil" by extending the expiration date of the note to June 1, 2020 to allow, on a one-time basis, the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing required inspection, cleaning, and any necessary repair activities. The TS 3.8.3 note is also revised to make the allowance contingent upon meeting the compensatory measures contained in the letter dated March 26, 2019.

R. Gideon A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely, Dennis J. Galvin, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 290 to DPR-71

2. Amendment No. 318 to DPR-62

3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS. LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 290 Renewed License No. DPR-71

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

A. The application for amendment filed by Duke Energy Progress, LLC (the licensee), dated April 25, 2018, as supplemented by letter dated March 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. DPR-71 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 290, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION tt I,, ~ / U,t lf'!'"'

Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: May 6, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 290 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace page 6 of Renewed Facility Operating License No. DPR-71 with the attached revised page 6.

Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3.8-20 3.8-20

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 290, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 290

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES----------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be ~ 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required DGs A.1 Restore required day fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the oil storage tank level to associated day fuel oil within limit.

storage tank(s) < 22,650 gal per required DG and

~ 17,000 gal per required DG.

Fuel oil level in the main fuel oil storage tank~ 20,850 gal per required DG.

(continued)

Brunswick Unit 1 3.8-20 Amendment No. 290 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 318 Renewed License No. DPR-62

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

A. The application for amendment filed by Duke Energy Progress, LLC (the licensee}, dated April 25, 2018, as supplemented by letter dated March 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. DPR-62 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 318, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: May 6, 201 9

ATTACHMENT TO LICENSE AMENDMENT NO. 318 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace page 6 of Renewed Facility Operating License No. DPR-62 with the attached revised page 6.

Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3.8-20 3.8-20

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 318, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 318

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

---

NOTES------------------------------------------------------

1. Separate Condition entry is allowed for each DG.

2. On a one-time basis, the main fuel oil storage tank may be made inoperable and drained, to support cleaning, inspection, and associated repair activities, for 14 days without entering Conditions A or B. If not restored within 14 days, Condition D must be entered.

Fuel oil level in the day fuel oil storage tank(s) shall be confirmed to be ~ 22,650 gal per required DG prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This Note expires upon completion of these activities, but no later than June 1, 2020. This allowance is contingent upon meeting the compensatory measures contained in Duke Energy letter RA-19-0157.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required DGs A.1 Restore required day fuel 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with fuel oil level in the oil storage tank level to associated day fuel oil within limit.

storage tank(s) < 22,650 gal per required DG and

~ 17,000 gal per required DG.

Fuel oil level in the main fuel oil storage tank~ 20,850 gal per required DG.

(continued)

Brunswick Unit 2 3.8-20 Amendment No. 318 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS NOS. 290 AND 318 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By license amendment request (LAR) dated April 25, 2018 (Reference 1) as supplemented by letter dated March 26, 2019 (Reference 2), Duke Energy Progress, LLC (the licensee),

requested changes to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant, Unit Nos. 1 and 2 (Brunswick or BSEP).

This amendment would revise Note 2 in TS 3.8.3, "Diesel Fuel Oil," by extending the expiration date of the note to June 1, 2020 to allow, on a one-time basis, the main fuel oil storage tank to be made inoperable for up to 14 days for the purpose of performing inspection, cleaning, and associated repair activities. The TS 3.8.3 Note 2 is also revised to make the allowance contingent upon meeting the compensatory measures contained in the letter dated March 26, 2019.

Note 2 was added to TS 3.8.3 by amendments dated September 27, 2007 (Reference 3). This note allowed, on a one-time basis, the main fuel oil storage tank to be made inoperable for up to 14 days for the purpose of performing inspection, cleaning, and associated repair activities with an expiration date of December 31, 2008. In this April 25, 2018 LAR, the licensee requested that the expiration date in Note 2 be revised to June 1, 2020, to perform 10-year inspection, cleaning, and associated repair activities of the main fuel oil storage tank. By letter dated March 26, 2019, the licensee requested that Note 2 be revised to make the allowance contingent upon meeting the compensatory measures contained in that letter. The March 26, 2019, letter identifies 10 compensatory measures as described in Section 2.2 of this SE.

The supplement dated March 26, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 3, 2018 (83 FR 31183).

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 System Description As described by the licensee in the LAR, the emergency diesel generators (EDGs) comprise a major part of the emergency power supply when offsite power is lost or an event occurs. There are four EDGs that supply power to the Brunswick safety-related electrical buses. EDG 1 and EDG 2 supply emergency buses E1 and E2, respectively, and are assigned to Unit 1. EDG 3 and EDG 4 supply emergency buses E3 and E4, respectively, and are assigned to Unit 2.

However, certain Unit 1 loads are supplied by emergency buses E3 and E4 and certain Unit 2 loads are supplied by emergency buses E1 and E2. As such, the LAR notes that operability of any single EDG affects both Units 1 and 2. The emergency power system is described in Section 8.3, "Onsite Power Systems" of the Brunswick Updated Final Safety Analysis Report (UFSAR) (Reference 4).

As described in the Brunswick UFSAR Section 8.3.1.1.6.2.8, "Fuel Oil System," the diesel fuel oil system is designed to supply each EDG with enough fuel oil to operate for approximately 7 days at rated load. The system consists, in part, of:

• One main fuel oil storage tank, which contains sufficient capacity (i.e., 225,000 gallons) to provide for approximately 3-days of operation for each of the four EDGs at rated load.

The main fuel oil storage tank is seismically designed but not seismically qualified.

• Four Seismic Class I day fuel oil storage tanks (i.e., 23,300 gallons per tank), one per EDG, each located in its own vault. The day fuel oil storage tanks, in combination with the engine mounted fuel tanks, provide approximately 4-days of diesel generator (DG) operation at rated load. The day fuel oil storage tanks are known as the 4-day tanks, each in its own vault.

• Four Seismic Class I engine mounted fuel tanks (i.e., 550 gallons per tank), one attached to each EDG.

Gravity fill is used to maintain fuel oil level in the 4-day tanks. Two redundant transfer pumps between each 4-day tank and its associated engine mounted fuel tank maintain fuel oil level in the engine mounted fuel tanks. Automatic makeup to the engine mounted fuel tanks occurs upon low level.

As stated in the LAR application, added assurance is available regarding supply to the 4-day tanks following damage to the main fuel oil storage tank because fuel oil can be readily o~tained and delivered either by truck or rail directly to Brunswick or by barge to local docks and off-loaded into trucks for transport to Brunswick.

In addition to supplying the four EDGs, the main fuel oil storage tank also supplies fuel to the diesel driven fire pump fuel oil tank. This Standby Diesel Fire Pump fuel oil tank is filled by gravity through a 1.5-inch line off the bottom of the main fuel oil storage tank. Two manual isolation valves on this line are locked closed at all times, except when filling the Standby Diesel Fire Pump fuel oil tank. The Standby Diesel Fire Pump fuel oil tank provides sufficient fuel to operate the pump for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Brunswick also has a supplemental DG and two FLEX DGs.

The supplemental DG is rated at 4,000 kilowatt (kW) and can be connected to the emergency busses (i.e., E1, E2, E3, or E4) in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The supplemental DG is made available as a defense-in-depth alternate source of alternating current (AC) power to one emergency bus to mitigate a station blackout event during a Loss of Offsite Power. The supplemental DG has a 10,000-gallon storage tank with a minimum of 6,700 gallons

.(i.e., 24-hour supply) available.

The two permanently installed 500 kW FLEX DGs each have an integral 526-gallon sub-base fuel tank (i.e., which provide a minimum 13-hour full-load runtime capacity), a self-contained, closed loop cooling system, and an exhaust system. Each is a fully contained system, capable of starting and operating with no reliance on other equipment or systems. The FLEX DGs provide the capability to power 480-Volt emergency buses E6 and EB in the event of an extended loss of station AC power following a Beyond Design Basis External Event. The FLEX DGs can supply power to the battery chargers via the emergency buses.

2.2 Description of the Proposed TSs Change Currently, TS 3.8.3, "Diesel Fuel Oil," requires each EDG to be operable and have a minimum of 43,500 gallons of fuel oil available for use (a minimum of 22,650 gallons in the day fuel oil storage tank and a minimum of 20,850 gallons in the main fuel oil storage tank). This provides approximately 7-days of operation at rated load. Should less than 43,500 gallons of fuel oil be available to a required EDG, Conditions A and B of TS 3.8.3 require that the fuel oil level must be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, otherwise that EDG must immediately be declared inoperable.

Since operability of the main fuel oil storage tank affects all four EDGs, a dual-unit shutdown would be necessary to accomplish the required inspections, cleaning, and associated repair activities of the main fuel oil storage tank.

As stated by the licensee, the completion time requirements in Conditions A and B do not provide sufficient time to inspect, clean, and/or repair the main fuel oil storage tank if draining of the tank is required. Therefore, the licensee requested a revision to the existing Note 2 in TS 3.8.3 that would revise the expiration date of Note 2 from December 31, 2008, to June 1, 2020. Note 2 allows, on a one-time basis, for the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing required cleaning, inspection, and necessary repair activities. The extension of the expiration date of Note 2 would permit completion of the required inspections, cleaning, and associated repair activities during the inspection planned for May 2019. The revised note stipulates expiration of its applicability upon completion of the inspection, cleaning, and associated repair activities, but no later than June 1, 2020.

The revised Note 2 makes the allowance (i.e., the main fuel oil storage tank to be inoperable for up to 14 days) contingent upon meeting the compensatory measures contained in the letter dated March 26, 2019, as follows:

1. Fuel oil removed from the main fuel oil storage tank will be maintained in temporary, onsite storage. This will ensure that a full seven-day fuel oil supply for each required diesel is available onsite.

2. Plant procedures will be developed to transfer fuel oil from the temporary, onsite storage to the 4-day fuel oil storage tanks should the need arise.

3. If electric transfer pumps are used, they will be powered by an EOG supplied electrical bus or a separate generator versus the plant electrical system.

4. BSEP will maintain on-site adequate inventory of diesel fuel oil to refill the diesel:.driven fire pump fuel oil supply tank to meet a minimum time exposure window of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

5. Plant procedures will be developed to transfer fuel oil from the temporary, onsite storage to the diesel-driven fire pump fuel supply storage tank should the need arise.

6. Adequate barriers to prevent any fire associated with the repair (i.e., welding, hot surfaces, and volatile gases) from propagating to the diesel fuel oil 4-day tank or headers will be provided.

7. Elective maintenance and testing, that affects Emergency Diesel Generator operability, will not be permitted.

8. Elective switchyard activities and other elective on-site electrical maintenance that could cause any unstable offsite or on-site power conditions will not be scheduled.

9. Removal of the main fuel oil storage tank from service will not be permitted when severe weather is forecast for the area or if there is a foreseen need for EOG operation.

10. Restoration of the main fuel oil storage tank will be pursued in an expeditious manner if long-term Emergency Diesel Generator operation is required.

Inclusion of these actions in the revised Note 2 establishes the compensatory actions as a licensing obligation (i.e., a legally binding requirement) rather than a commitment.

2.3 Regulatory Requirements and Guidance The regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TSs include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation, surveillance requirements, (4) design features, and (5) administrative controls. More specifically, 10 CFR 50.36(c)(2)(i) states that "[w]hen 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 Brunswick design was reviewed for construction under the General Design Criteria for Nuclear Power Plant Construction, issued for comment by the Atomic Energy Commission in July 1967 and is committed to meet the intent of the General Design Criteria (GDC), published in the Federal Register on July 7, 1971, as Appendix A to 10 CFR Part 50.

GDC 17, "Electric power systems," requires, in part, an onsite electric power system for the functioning of structures, systems, and components important to safety. GDC 17 requirements include sufficient independence and redundancy for the onsite electric power system to perform safety functions, assuming a single failure.

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," provides guidelines for the review of diesel fuel oil and other supporting systems

in Section 9.5.4, "Emergency Diesel Engine Fuel Oil Storage and Transfer System" (Reference 5).

Regulatory Guide (RG) 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators" dated October 1979 (Reference 6) describes an acceptable method for complying with the regulations regarding fuel oil systems for standby diesel generators and assurance of adequate fuel-oil quality. More specifically, RG 1.1.37 provides regulatory positions on fuel oil system design criteria and features for standby diesel generators subject to the requirements of GDC 17.

3.0 TECHNICAL EVALUATION

The licensee stated that periodic draining of the main fuel oil storage tank is the preferred method for performing inspection, cleaning, or repair activities, and that internal tank inspection and cleaning is performed on a 10-year frequency in accordance with RG 1.137. The next internal inspection of the main fuel oil storage tank is planned for May 2019 and the licensee estimates that the required draining, inspecting/cleaning, and re-filling of the main fuel oil storage tank will take 7 to 10 days. The requested 14-day completion time provides margin should the evolution take longer than expected and eliminates the requirement for a dual-unit outage to accomplish the inspections.

The proposed change would revise Note 2 in TS 3.8.3 to allow the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing inspection, cleaning, and associated repair activities on a one-time basis. The proposed change to Note 2 specifies that the licensee must confirm that the oil level in the day fuel oil storage tanks (i.e., the 4-day tanks) is greater than or equal to 22,650 gallons per required EOG before removing the main fuel oil storage tank from service, and once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

The proposed change would further revise Note 2 in TS 3.8.3 to make the allowance (i.e., the main fuel oil storage tank to be inoperable for up to 14 days) contingent upon meeting the compensatory measures contained in the letter dated March 26, 2019.

Compensatory Measures 1 and 4 require that the fuel removed from the main fuel oil storage tank to be maintained onsite to ensure that a full 7-day fuel oil supply for each required diesel is available onsite and to provid~ a 36-hour supply for the diesel-driven fire pump. With respect to the EDGs, maintaining sufficient fuel oil onsite to operate the required EDGs for 7 days at rated load is in accordance with RG 1.137.

The compensatory measures also require that (1) procedures be developed for fuel oil transfers (Compensatory Measures 2 and 5), (2) elective maintenance and activities not be performed that could cause unstable power conditions resulting in need for EDGs (Compensatory Measures 7 and 8), (3) measures be put in place to prevent the propagation of potential fires (Compensatory Measure 6), (4) the main fuel oil storage tank will not be removed from service when severe weather is forecasted (Compensatory Measure 9), and (5) in the event of an emergency requiring operation of the EDGs while the main fuel oil storage tank is inoperable, actions will be taken to return the tank to an operable status in an expeditious manner (Compensatory Measure 10).

The NRC staff finds the 1O compensatory measures adequately describe and address the appropriate actions to be taken, as necessary, during the required draining, inspecting/cleaning, and refilling of the main fuel oil storage tank. The NRC staff concludes the compensatory

actions have an appropriate scope so as to minimize the likelihood of needing to use the EDGs while retaining the availability of a functional alternative to the main fuel oil tank (i.e., maintaining sufficient fuel oil onsite and available to supply the EDGs and the diesel-driven fire pump), if needed.

The NRC staff further finds that additional defense-in-depth is provided by the supplemental DG and two FLEX DGs. The NRC staff also notes that, if needed, additional fuel oil can be obtained from offsite sources, as discussed in the Brunswick UFSAR Section 8.3.1.1.6.2.8, "Fuel Oil System."

Based on the discussion above, including the compensatory measures referenced in the revised Note 2 of TS 3.8.3, the NRC staff concludes that there is reasonable assurance that the risk of the requested one-time allowance will be minimized and adequate controls are in place to ensure that the EDGs retain the ability to perform their design functions during the inspection, maintenance, and associated repair activities of the main fuel oil storage tank. While the main fuel oil storage tank is unavailable, the EDGs will remain available with adequate fuel supply retained onsite consistent with TS volumetric requirements. As such, the revised TS 3.8.3 provides reasonable assurance the health and safety of the public will not be endangered.

Additionally, the proposed change does not affect Brunswick's compliance with the intent of GDC 17. Therefore, the NRC staff finds it acceptable for the proposed amendments to extend the expiration of Note 2 of TS 3.8.3 to June 1, 2020, to allow, on a one-time basis, the main fuel oil storage tank to be inoperable for up to 14 days for the purpose of performing required inspection, cleaning, and any necessary repair activities.

The licensee provided risk insights in Section 3.2 of the LAR. As the risk insights were not submitted in accordance with RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," (Reference 7) and because the NRC staff was able to reach its conclusions about the licensee's proposed changes based on traditional engineering analysis, the risk information did not impact the NRC's staff's analysis and the NRC staff did not approve this risk information.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the North Carolina State official was notified of the proposed issuance of the amendments on February 4, 2019. The North Carolina State official had the following comment:

The NRC should consider limiting the one-time inoperability of the fuel oil storage tank during non-hurricane likely months (i.e., November-June). Experience as recently as Hurricane Florence has shown that the following licensee's statement of the availability of offsite fuel oil is inaccurate. The flooding during Florence caused inaccessibility to the site by any offsite resources.

Furthermore, while the main fuel oil storage tank is out of service, the availability of onsite and offsite fuel oil sources ensures that an adequate supply of fuel oil remains available. [Licensee statement from the LAR that the North Carolina State official considers inaccurate].

The NRC staff considered the issues in the state comment in its review. The NRC staff response to the state comment follows.

The revised Note 2 in TS 3.8.3 makes the allowance (i.e., the main fuel oil storage tank to be inoperable for up to 14 days) contingent upon meeting the 10 compensatory measures contained in the letter dated March 26, 2019 (see Section 2.2 of this safety evaluation).

Compensatory Measure 9 does not permit the main fuel oil storage tank to be removed from service when severe weather is forecasted. Compensatory Measures 7 and 8 minimize challenges to the site power supplies, and thus reduce the potential need for the EOGs.

Should there be a need for the EOGs despite the forgoing measures, each Brunswick EOG has a protected 4-day tank that will be unaffected by the inspection and cleaning activities. The LAR describes this available supply stating:

Four Seismic Class I day fuel oil storage tanks (i.e., 23,300 gallons per tank), one per EOG, each located in its own vault. The day fuel oil storage tanks, in combination with the engine mounted fuel tanks, provide approximately four days of diesel generator operation at rated load. The day fuel oil storage tanks are known as the 4-day tanks, each in its own vault.

Note 2 in TS 3.8.3 requires the fuel oil level in the 4-day tanks to be confirmed prior to removing the main fuel oil storage tank from service and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

In addition, Compensatory Measure 1 requires that a 7-day fuel supply be retained onsite, Compensatory Measure 2 requires that plant procedures be developed to transfer fuel oil from the temporary, onsite storage to the 4-day fuel oil storage tanks, and Compensatory Measure 10 requires restoration of the main fuel oil storage tank to be pursued in an expeditious manner if long-term EOG operation is required.

The NRC staff notes that the flooding during Hurricane Florence did not cause total inaccessibility to the Brunswick site. Hurricane Florence did cause inaccessibility to the Brunswick site for many licensee staff, and thus, the licensee declared a notice of unusual event that lasted approximately 3 days.

As discussed in Section 3.0 of this safety evaluation and the foregoing, the NRC staff finds the licensee has incorporated sufficient measures into the TS. Further, the NRC staff has not identified the need to impose an additional condition limiting the one-time inoperability of the fuel oil storage tank to between November and June.

5.0 ENVIRONMENTAL CONSIOERATION The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. 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 July 3, 2018 (83 FR 31183), 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 Commission's 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.

7.0 REFERENCES

1. Gideon, William R., Duke Energy Progress, LLC, letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2 - Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time," dated April 25, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18121A366).

2. Gideon, William R., Duke Energy Progress, LLC, letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2 - Supplement to Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time," dated March 26, 2019 (ADAMS Accession No. ML19085A340).

3. Bailey, Stewart N., U.S. Nuclear Regulatory Commission, letter to J. Scarola, Carolina Power & Light Company, "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendment Related to Main Fuel Oil Storage Tank (TAC Nos. MD3305 and MD3306),"

dated September 27, 2007 (ADAMS Package Accession No. ML072600464).

4. Gideon, William R., Duke Energy Progress, Inc., letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2 - Updated Final Safety Analysis Report, Revision 26," dated August 13, 2018 (ADAMS Package Accession No. ML18249A165).

5. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 9.5.4, "Emergency Diesel Engine Fuel Oil Storage and Transfer System," Revision 3, dated March 2007 (ADAMS Accession No. ML070680388).

6. U.S. Nuclear Regulatory Commission Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators" dated October 1979 (ADAMS Accession No. ML003740180).

7. U.S. Nuclear Regulatory Commission Regulatory Guide 1.174, Revision 3, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," dated January 2018 (ADAMS Accession No. ML17317A256).

Principal Contributor: Gordon Curran Date: May 6, 2019

ML19018A206 *b email OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DSS/SCPB/BC*

NAME DGalvin BClayton SAnderson DATE 4/17/2019 4/16/2019 4/12/2019 OFFICE NRR/DSS/STSB/BC(A)* OGC-NLO* NRR/DORL/LPL2-2/BC NAME PSnyder RSusko UShoop DATE 4/12/2019 4/29/2019 5/6/2019 OFFICE NRR/DORL/LPL2-2/PM NAME DGalvin DATE 5/6/2019