ML13039A332: Difference between revisions

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Other than the cross tie capability, the Unit 1 7-day requirement and basis has not changed from the original August 11,2011 submittal (ML 112240140).
Other than the cross tie capability, the Unit 1 7-day requirement and basis has not changed from the original August 11,2011 submittal (ML 112240140).
The TS requirement will still maintain the 7 -day fuel oil supply for each train of EDGs and DDCLPs. Therefore, the ability to mitigate an accident has not been reduced by this proposed change. The only function that has been affected is the potential ability to operate with reduced volume in one or two of the tanks while crediting fuel oil in the other same train tank(s). The 14-day fuel oil supply requirement for a maximum probable flood will be retained in the Updated Safety Analysis Report (USAR) for Unit 1. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) Unit 2 has dedicated fuel oil storage tanks for each EDG so there are no changes to the crediting of the 7-day supply. In addition, the 14-day fuel oil supply requirement for a maximum probable flood will be retained in the USAR for Unit 2. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) This proposed license basis change necessitates additional changes to the TS 3.7.8 Bases and TS 3.8.3 Bases which are provided in marked up format as Attachment 1 to this Enclosure.
The TS requirement will still maintain the 7 -day fuel oil supply for each train of EDGs and DDCLPs. Therefore, the ability to mitigate an accident has not been reduced by this proposed change. The only function that has been affected is the potential ability to operate with reduced volume in one or two of the tanks while crediting fuel oil in the other same train tank(s). The 14-day fuel oil supply requirement for a maximum probable flood will be retained in the Updated Safety Analysis Report (USAR) for Unit 1. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) Unit 2 has dedicated fuel oil storage tanks for each EDG so there are no changes to the crediting of the 7-day supply. In addition, the 14-day fuel oil supply requirement for a maximum probable flood will be retained in the USAR for Unit 2. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) This proposed license basis change necessitates additional changes to the TS 3.7.8 Bases and TS 3.8.3 Bases which are provided in marked up format as Attachment 1 to this Enclosure.
These marked up Bases supersede in their entirety the marked up Bases provided in the original submittal dated August 11, 2011 (ML 112240140), Enclosure Attachment  
These marked up Bases supersede in their entirety the marked up Bases provided in the original submittal dated August 11, 2011 (ML 112240140), Enclosure Attachment
: 2. Pages B 3.7.8-16, B 3.8.3-5 and B 3.8.3-6 have been revised. NRC Request for Additional Information (RAil EEEB-13 The license amendment request (LAR) states that six Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) supply fuel oil to the two emergency diesel generators (EDGs) 01/02 and the two diesel-driven cooling water pumps (DDCLPs).
: 2. Pages B 3.7.8-16, B 3.8.3-5 and B 3.8.3-6 have been revised. NRC Request for Additional Information (RAil EEEB-13 The license amendment request (LAR) states that six Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) supply fuel oil to the two emergency diesel generators (EDGs) 01/02 and the two diesel-driven cooling water pumps (DDCLPs).
These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any diesel day tank. Therefore, any combination of the six tanks can be used to meet the 14-day storage capacity requirement for a probable maximum flood. This licensing basis will be maintained.
These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any diesel day tank. Therefore, any combination of the six tanks can be used to meet the 14-day storage capacity requirement for a probable maximum flood. This licensing basis will be maintained.
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Page 11 of 11 ENCLOSURE, ATTACHMENT 1 Technical Specification Bases (Markup) B 3.7.8-4 B 3.7.8-12 B 3.7.8-13 B 3.7.8-14 B 3.7.8-16 B 3.7.8-17 B 3.7.8-20 B 3.8.3-1 B 3.8.3-2 B 3.8.3-3 B 3.8.3-4 B 3.8.3-5 B 3.8.3-6 B 3.8.3-7 B 3.8.3-8 15 pages follow BASES APPilCABlE SAFETY ANALYSES (continued)
Page 11 of 11 ENCLOSURE, ATTACHMENT 1 Technical Specification Bases (Markup) B 3.7.8-4 B 3.7.8-12 B 3.7.8-13 B 3.7.8-14 B 3.7.8-16 B 3.7.8-17 B 3.7.8-20 B 3.8.3-1 B 3.8.3-2 B 3.8.3-3 B 3.8.3-4 B 3.8.3-5 B 3.8.3-6 B 3.8.3-7 B 3.8.3-8 15 pages follow BASES APPilCABlE SAFETY ANALYSES (continued)
LCO Prairie Island Units I and 2 CL System B 3.7.8 failure of any active component, assuming the loss of offsite power. This assumes a maximum CL temperature of 95°F occurring simultaneously with design heat loads for the system. The CL System satisfies Criterion 3 of 10 CPR 50.36(c)(2)(ii).
LCO Prairie Island Units I and 2 CL System B 3.7.8 failure of any active component, assuming the loss of offsite power. This assumes a maximum CL temperature of 95°F occurring simultaneously with design heat loads for the system. The CL System satisfies Criterion 3 of 10 CPR 50.36(c)(2)(ii).
Two CL trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power. A CL train is considered OPERABLE when: a. The safeguards CL pump, aligned to the train, is OPERABLE;  
Two CL trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power. A CL train is considered OPERABLE when: a. The safeguards CL pump, aligned to the train, is OPERABLE;
: b. The associated header is OPERABLE; and c. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.
: b. The associated header is OPERABLE; and c. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.
A diesel driven safeguards CL pump is considered OPERABLE when: a. The pump can meet the design flow/pressure requirements in accordance with the Inservice Testing Program; b. The associated piping, valves, auxiliaries, and instrumentation and controls required to perform the safety related function are OPERABLE; and c. There is a minimum 7 day stored diesel driven CL pump fuel oil supply of 19,500 gallons available fefin that train's tankse ffies.el driven safeguards pumps. The fuel oil supply equivalent to 7 days is 9.750 gallons. B 3.7.8-4 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 BASES ACTIONS Prairie Island Units 1 and 2 B.1. B.2 and B.3 (continued)
A diesel driven safeguards CL pump is considered OPERABLE when: a. The pump can meet the design flow/pressure requirements in accordance with the Inservice Testing Program; b. The associated piping, valves, auxiliaries, and instrumentation and controls required to perform the safety related function are OPERABLE; and c. There is a minimum 7 day stored diesel driven CL pump fuel oil supply of 19,500 gallons available fefin that train's tankse ffies.el driven safeguards pumps. The fuel oil supply equivalent to 7 days is 9.750 gallons. B 3.7.8-4 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 BASES ACTIONS Prairie Island Units 1 and 2 B.1. B.2 and B.3 (continued)
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Under some plant conditions, the vertical motor driven CL pump is required to operate to provide additional CL flow. When this pump is operated to support plant operations, this test can not be performed and this pump is considered inoperable as a safeguards CL pump. SR 3.7.8.5 This SR verifies proper automatic operation of the CL System valves on an actual or simulated safety injection actuation signal, including those valves that isolate non-essential equipment from the system. B 3.7.8-17 Unit 1 -Revision 185 Unit 2 -Revision 185 BASES CL System B 3.7.8 SURVEIILANCE SR 3.7.8.6 (continued)
Under some plant conditions, the vertical motor driven CL pump is required to operate to provide additional CL flow. When this pump is operated to support plant operations, this test can not be performed and this pump is considered inoperable as a safeguards CL pump. SR 3.7.8.5 This SR verifies proper automatic operation of the CL System valves on an actual or simulated safety injection actuation signal, including those valves that isolate non-essential equipment from the system. B 3.7.8-17 Unit 1 -Revision 185 Unit 2 -Revision 185 BASES CL System B 3.7.8 SURVEIILANCE SR 3.7.8.6 (continued)
REQUIREMENTS REFERENCES Prairie Island Units 1 and 2 Operating experience has shown that these components usually pass the Surveillance when performed.
REQUIREMENTS REFERENCES Prairie Island Units 1 and 2 Operating experience has shown that these components usually pass the Surveillance when performed.
Therefore, the Frequency is acceptable from a reliability standpoint.  
Therefore, the Frequency is acceptable from a reliability standpoint.
: l. USAR, Section 10.4. 2. USAR, Section 6. 3. Regulatory Guide 1.137. 4. ANSI N195-1976.  
: l. USAR, Section 10.4. 2. USAR, Section 6. 3. Regulatory Guide 1.137. 4. ANSI N195-1976.
: 5. ASME Code for Operation and Maintenance of Nuclear Power Plants. B 3.7.8-20 Unit 1 -Revision 195 Unit 2 -Revision 195 Diesel Fuel Oil B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil BASES BACKGROUND APPUCABIE SAFETY ANALYSES Prairie Island Units 1 and 2 Each diesel generator (DG)'H::fl:it is provided with a stored DG fuel oil capacity supply sufficient to operate thate diesel generator (DGsj for a period of -l4--7 days while the DG is supplying maximum post loss of coolant accident load demand as discussed in the USAR (Ref. 1). The onsite fuel oil capacity supply is sufficient to operate the DGs for longer than the time to replenish the on site supply from outside sources. New DG fuel oil is placed in a receiving tank where it is tested in accordance with the Prairie Island Nuclear Generation Plant (PINGP) Diesel Fuel Oil Testing Program. Once the test results have verified that the fuel oil is within limits, the fuel oil may be transferred to the safeguards fuel oil storage tanks. Fuel oil is then transferred from the safeguards fuel oil storage tank to the day tank by the fuel oil 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 to result in the loss of more than one DG. For proper operation of the DGs, it is necessary to ensure the proper quality of the fuel oil. PINGP ensures fuel oil quality through implementation of the Diesel Fuel Oil Testing Program. The initial conditions of Design Basis Accident (DBA) and transient analyses in the USAR (Ref. 2) assume Engineered Safety Feature (ESF) systems are OPERABLE.
: 5. ASME Code for Operation and Maintenance of Nuclear Power Plants. B 3.7.8-20 Unit 1 -Revision 195 Unit 2 -Revision 195 Diesel Fuel Oil B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil BASES BACKGROUND APPUCABIE SAFETY ANALYSES Prairie Island Units 1 and 2 Each diesel generator (DG)'H::fl:it is provided with a stored DG fuel oil capacity supply sufficient to operate thate diesel generator (DGsj for a period of -l4--7 days while the DG is supplying maximum post loss of coolant accident load demand as discussed in the USAR (Ref. 1). The onsite fuel oil capacity supply is sufficient to operate the DGs for longer than the time to replenish the on site supply from outside sources. New DG fuel oil is placed in a receiving tank where it is tested in accordance with the Prairie Island Nuclear Generation Plant (PINGP) Diesel Fuel Oil Testing Program. Once the test results have verified that the fuel oil is within limits, the fuel oil may be transferred to the safeguards fuel oil storage tanks. Fuel oil is then transferred from the safeguards fuel oil storage tank to the day tank by the fuel oil 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 to result in the loss of more than one DG. For proper operation of the DGs, it is necessary to ensure the proper quality of the fuel oil. PINGP ensures fuel oil quality through implementation of the Diesel Fuel Oil Testing Program. The initial conditions of Design Basis Accident (DBA) and transient analyses in the USAR (Ref. 2) assume Engineered Safety Feature (ESF) systems are OPERABLE.
The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded.
The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded.
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6;FlCE WAS  
6;FlCE WAS  
]8'OIA. PER ORR Pl-I!a.!!il!
]8'OIA. PER ORR Pl-I!a.!!il!
OWN, ASJ l-ll-Ca D<<'DI CKR IIlV!!il HQO', r"'"#-' FILMED J/!!'" 76 AS BUILT A f-B f-"78' 078 u 3-2FO-54I 77 ISStJED FOR COllSTAUCTlON c ADDED DiEMlCAl ADDITlON PIPING A','O REVISED FILL CQ."NECTItr-l.  
OWN, ASJ l-ll-Ca D<<'DI CKR IIlV!!il HQO', r"'"#-' FILMED J/!!'" 76 AS BUILT A f-B f-"78' 078 u 3-2FO-54I 77 ISStJED FOR COllSTAUCTlON c ADDED DiEMlCAl ADDITlON PIPING A','O REVISED FILL CQ."NECTItr-l.
: OWN, 6-26-eCJ b <1>-,OJ L ____ _ 05 BULK FUEL OIL STORAGE VAULT 3-2FO-I 2FD-4-15 0 SEE D&#xa3;TAJL 3-2FD-28 THIS OWG. 2-2FO-40 3-2FO-53 M1TANK LEVEL STICK 6ri\ 2-2FO-30 4"E FILL W 4"X3" RED. 3" y N rmmn-1h_--,'
: OWN, 6-26-eCJ b <1>-,OJ L ____ _ 05 BULK FUEL OIL STORAGE VAULT 3-2FO-I 2FD-4-15 0 SEE D&#xa3;TAJL 3-2FD-28 THIS OWG. 2-2FO-40 3-2FO-53 M1TANK LEVEL STICK 6ri\ 2-2FO-30 4"E FILL W 4"X3" RED. 3" y N rmmn-1h_--,'
78" 3-2FO-53 l 06 BULK FUEL OIL STORAGE VAUL 4-2FO-44/ 4-2FD-64 NOZl. 'tU LOCKING} CAP (TYPICAl)
78" 3-2FO-53 l 06 BULK FUEL OIL STORAGE VAUL 4-2FO-44/ 4-2FD-64 NOZl. 'tU LOCKING} CAP (TYPICAl)
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! .. 4" 4-2FD-18 4-2fO-42 Y Y ( '-4I-"3--"2F'-'0'-'-2o,-7
! .. 4" 4-2FD-18 4-2fO-42 Y Y ( '-4I-"3--"2F'-'0'-'-2o,-7
________ -I V E3HIGH 23 05 TANK -r@ _J e LEAKAGE 2-2FO-48 c __ : : __ "
________ -I V E3HIGH 23 05 TANK -r@ _J e LEAKAGE 2-2FO-48 c __ : : __ "
yy REFER TD SPECS  
yy REFER TD SPECS
:56, HIAW -02400-66 H!AW -
:56, HIAW -02400-66 H!AW -
HIAIri -
HIAIri -
H!AW -0240-0-81 (ERECTlDNI (SUPPOR1S) (HAIERJAl) (VAlVES) --6 lEA 1<AGE LEAK RCL 6-26-e'l RICHARD C. Llh'DElERG 6-25-3'1 PE'44886 APP'DIACL 6-26-0'1 U/CORPOOATED AlE's REV.'77'PER DAR PI-0CJ-24'1 TO PUMP SUCTlON CERTlFIED REV. '77', SHOWN OPP. HAND 1<<)0",&#xa3;C-12252 f--D LINE 3 APP'DI CHA 2+13 78 AS REV'OVLV2FO-13-1FAo."1A II 7 8 n :  
H!AW -0240-0-81 (ERECTlDNI (SUPPOR1S) (HAIERJAl) (VAlVES) --6 lEA 1<AGE LEAK RCL 6-26-e'l RICHARD C. Llh'DElERG 6-25-3'1 PE'44886 APP'DIACL 6-26-0'1 U/CORPOOATED AlE's REV.'77'PER DAR PI-0CJ-24'1 TO PUMP SUCTlON CERTlFIED REV. '77', SHOWN OPP. HAND 1<<)0",&#xa3;C-12252 f--D LINE 3 APP'DI CHA 2+13 78 AS REV'OVLV2FO-13-1FAo."1A II 7 8 n :
: I>'.A1CHSIl&#xa3;S1A'dlAAO 6' SYMBOLS,LEGEh'D.ADOED D.A HIGH A 10 SAFETY 2PI PEA DHR PI-I0--157 NO. OWN, DB lil-H-lll DETAIL 1 ---FOR VAlVE &. INSTRUMEfHATION NUI-'.BERS SEE CHART 1 n-tlS DRA'w'ING.
: I>'.A1CHSIl&#xa3;S1A'dlAAO 6' SYMBOLS,LEGEh'D.ADOED D.A HIGH A 10 SAFETY 2PI PEA DHR PI-I0--157 NO. OWN, DB lil-H-lll DETAIL 1 ---FOR VAlVE &. INSTRUMEfHATION NUI-'.BERS SEE CHART 1 n-tlS DRA'w'ING.
0<<'0. JEK m-II-liI MOQ",EC-15050 APP'DI CHR HH2-la 05/06 FUEL OIL STORAGE VAULT CHART 1. LINE 1 LJNE 2 LINE 3 2-2FO-Q 112-2FD-1l4 112-2FO-1I5 2-2FO-2 1I2-2F0-116 1/2-2FO-1l7 2-2FD-34 l!2-2FG-TI0 112-2FO-111 2-2FO-28 1I2-2FO-112 112-2FO-113 PUMP '40, 2POSH NO. 2PI NO, VLV, 1 NO. STRAINER 21 05 5004 5008 2FO-8-17 258-041 23 05 5006 500<} 2FO-8-1<}
0<<'0. JEK m-II-liI MOQ",EC-15050 APP'DI CHR HH2-la 05/06 FUEL OIL STORAGE VAULT CHART 1. LINE 1 LJNE 2 LINE 3 2-2FO-Q 112-2FD-1l4 112-2FO-1I5 2-2FO-2 1I2-2F0-116 1/2-2FO-1l7 2-2FD-34 l!2-2FG-TI0 112-2FO-111 2-2FO-28 1I2-2FO-112 112-2FO-113 PUMP '40, 2POSH NO. 2PI NO, VLV, 1 NO. STRAINER 21 05 5004 5008 2FO-8-17 258-041 23 05 5006 500<} 2FO-8-1<}
258-043 22 06 6004 6008 2FO-8-21 2FO-8-22 2FO-8-27 258-042 24 Ub 601lb 600q 2FO-8-23 2FO-B-24 f 2FO-8-28 258-044 (SR IISR Ic1JJi LEGEND CLASS BREAK QA TYPE '78' --SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS --NSR -NON-SAFETY-RELATED IA,IB,IC,lIA,lIB  
258-043 22 06 6004 6008 2FO-8-21 2FO-8-22 2FO-8-27 258-042 24 Ub 601lb 600q 2FO-8-23 2FO-B-24 f 2FO-8-28 258-044 (SR IISR Ic1JJi LEGEND CLASS BREAK QA TYPE '78' --SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS --NSR -NON-SAFETY-RELATED IA,IB,IC,lIA,lIB  
&. lJI DENOTES PIPING OA TYPES, J, TAt-;K OVERFLOW LOOP SEAL TO BE FILLED WITH 50" ETHYLENE GLYCOL SOLUTION, 2. FOR VAlVE POSITIONS SEE DPS t'AI-.'UAl C PROCEDURE CHECKLIST.  
&. lJI DENOTES PIPING OA TYPES, J, TAt-;K OVERFLOW LOOP SEAL TO BE FILLED WITH 50" ETHYLENE GLYCOL SOLUTION, 2. FOR VAlVE POSITIONS SEE DPS t'AI-.'UAl C PROCEDURE CHECKLIST.
: 3. UNLESS OTHER'WISE SHOWN, CLASS BOUNDARIES STOP AT VEN1 AND DRAIN VALVES WITH ETC.l 4, FOA SYMBOLS SEE Xlt-l-lC5.
: 3. UNLESS OTHER'WISE SHOWN, CLASS BOUNDARIES STOP AT VEN1 AND DRAIN VALVES WITH ETC.l 4, FOA SYMBOLS SEE Xlt-l-lC5.
M---3'l214.  
M---3'l214.
: 5.  
: 5.  
"78" ". .... ' __ k.b:II .. _""'*"-..... .-.-..II .... _,.--,lopoMdo:ltr " ... -...-.,.-..  
"78" ". .... ' __ k.b:II .. _""'*"-..... .-.-..II .... _,.--,lopoMdo:ltr " ... -...-.,.-..  
Line 302: Line 302:
_.----.j FD-1I3-17  
_.----.j FD-1I3-17  
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PRESS  
PRESS
[z N :d:: '-jFD-23-,1 FUEL RTRN . SEE DETAIL '1' 1._.1_
[z N :d:: '-jFD-23-,1 FUEL RTRN . SEE DETAIL '1' 1._.1_
t --02 EMERG OSL Hill 1%-FO-19 I 2oG[13 I I
t --02 EMERG OSL Hill 1%-FO-19 I 2oG[13 I I
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_______ .. -----------'
_______ .. -----------'
_79 E I-F I-I-I Lfl Lfl N (J' (") J. I-H i -j SA-27-7 I SA-26-1 PlWRlE 1Su.H0 PlANT ---o L.:.l IF-3'i255-I,ffiNil<SPf;&#xa3;1tUW0f cool 6 7 8 9 1 0 mllm.... 12 2 4 5 A B c He: D F G H 2 1-2EG-512 3 -2&#xa3;0-530 M J 0 12EG-i-47J 4 N "' '" o 1-2EG-SIS 12EG-I-4SI NF-118252 A-5 i 5 I-2EG-56 1-2EG-54 6 l"RETUflN LitlE 1\:F-118252 A-5 'i' :J 3-2&#xa3;G-48  
_79 E I-F I-I-I Lfl Lfl N (J' (") J. I-H i -j SA-27-7 I SA-26-1 PlWRlE 1Su.H0 PlANT ---o L.:.l IF-3'i255-I,ffiNil<SPf;&#xa3;1tUW0f cool 6 7 8 9 1 0 mllm.... 12 2 4 5 A B c He: D F G H 2 1-2EG-512 3 -2&#xa3;0-530 M J 0 12EG-i-47J 4 N "' '" o 1-2EG-SIS 12EG-I-4SI NF-118252 A-5 i 5 I-2EG-56 1-2EG-54 6 l"RETUflN LitlE 1\:F-118252 A-5 'i' :J 3-2&#xa3;G-48  
....... _--_ .* --*.. _-----"-"-"*"1  
....... _--_ .* --*.. _-----"-"-"*"1
: :
: :
ie i LOW --i-@""-ik.
ie i LOW --i-@""-ik.
12E6-H61-I 5104A l!J i _______________________  
12E6-H61-I 5104A l!J i _______________________
: ____ i SEE DETA1L 1 i (TYP IS) !
: ____ i SEE DETA1L 1 i (TYP IS) !
i VALVE i (TYP IS) FEED AAMp------1 I t_ I _______ nn_nnn d 2EG-'l-SY
i VALVE i (TYP IS) FEED AAMp------1 I t_ I _______ nn_nnn d 2EG-'l-SY
Line 350: Line 350:
HIAW -02400-79 (SUPPORTS)
HIAW -02400-79 (SUPPORTS)
HIAW -32430-80 (MATERIAL)
HIAW -32430-80 (MATERIAL)
HIAW -32433-8J (VALVES) 8 NOTES: 1. FOR VALVE POSITIONS SEE OPS MANUAL C PROCEDURE CHECKLIST, FEED RA."W 2. UNLESS OTHERWISE SHOWN, CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAM ITEMS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.  
HIAW -32433-8J (VALVES) 8 NOTES: 1. FOR VALVE POSITIONS SEE OPS MANUAL C PROCEDURE CHECKLIST, FEED RA."W 2. UNLESS OTHERWISE SHOWN, CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAM ITEMS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.
: 3. FOR SYMBOLS SEE XH-H05, NF-392J4.
: 3. FOR SYMBOLS SEE XH-H05, NF-392J4.
9 10 _MOl _.-LEGEND I CLASS BOUNDARY ---SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS ---NSR -NON-SAFETY-RELATED JA.IB,IC,IIA,IlB  
9 10 _MOl _.-LEGEND I CLASS BOUNDARY ---SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS ---NSR -NON-SAFETY-RELATED JA.IB,IC,IIA,IlB  
Line 376: Line 376:
HIAW -32400-7'3 (SUPPORTS)
HIAW -32400-7'3 (SUPPORTS)
HIAW -02400-80 (MATERIAl)
HIAW -02400-80 (MATERIAl)
HIAW -02403-81 (VALVES) 8 NOTES: 1. FOR VALVE POSITIONS SEE DPS HANUAL C PROCEDURE CHECKLIST.  
HIAW -02403-81 (VALVES) 8 NOTES: 1. FOR VALVE POSITIONS SEE DPS HANUAL C PROCEDURE CHECKLIST.
: 2. UNLESS OTHERWISE SHOWN. CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAH lTEHS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.  
: 2. UNLESS OTHERWISE SHOWN. CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAH lTEHS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.
: 3. FOR SYMBOLS SEE XH-l-H35.
: 3. FOR SYMBOLS SEE XH-l-H35.
NF-3'3214.
NF-3'3214.
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10.3.13.1.2.1 Unit 1 The Unit 1 design minimum storage capacity of diesel fuel oil is based on one emergency diesel generator (EOG), 01 or 02, operating at the loads stated in Table 8.4-1 plus one diesel driven cooling water pump (OOCLP), 12 or 22, for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 1 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG and OOCLP in accordance with Technical Specifications.
10.3.13.1.2.1 Unit 1 The Unit 1 design minimum storage capacity of diesel fuel oil is based on one emergency diesel generator (EOG), 01 or 02, operating at the loads stated in Table 8.4-1 plus one diesel driven cooling water pump (OOCLP), 12 or 22, for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 1 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG and OOCLP in accordance with Technical Specifications.
The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained.
The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained.
The onsite Unit 1 fuel oil supply is sufficient to operate one EOG and one DOCLP for longer than the time to replenish the onsite supply from outside sources. (Reference  
The onsite Unit 1 fuel oil supply is sufficient to operate one EOG and one DOCLP for longer than the time to replenish the onsite supply from outside sources. (Reference
: 72) 10.3.13.1.2.2 Unit 2 The Unit 2 design minimum storage capacity of diesel fuel oil is based on one EDG, 05 or 06, operating at the loads stated in Table 8.4-2 for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 2 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG in accordance with Technical Specifications.
: 72) 10.3.13.1.2.2 Unit 2 The Unit 2 design minimum storage capacity of diesel fuel oil is based on one EDG, 05 or 06, operating at the loads stated in Table 8.4-2 for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 2 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG in accordance with Technical Specifications.
The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained, The onsite Unit 2 fuel oil supply is sufficient to operate one EOG for longer than the time to replenish the onsite supply from outside sources, (Reference  
The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained, The onsite Unit 2 fuel oil supply is sufficient to operate one EOG for longer than the time to replenish the onsite supply from outside sources, (Reference
: 73)
: 73)
PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT 10.3.13.2.2 Unit 2 USAR Section 10 Revision 32P Page 10.3-34 The Unit 2 fuel oil system consists of a non-Design Class I fuel oil receiving tank, four Design Class I fuel oil storage tanks, four fuel oil transfer pumps, two fuel oil day tanks, one fuel oil recirculating pump, four fuel oil transfer recirculation filters, a receiving tank recirculating filter, and associated piping, valving and instrumentation.
PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT 10.3.13.2.2 Unit 2 USAR Section 10 Revision 32P Page 10.3-34 The Unit 2 fuel oil system consists of a non-Design Class I fuel oil receiving tank, four Design Class I fuel oil storage tanks, four fuel oil transfer pumps, two fuel oil day tanks, one fuel oil recirculating pump, four fuel oil transfer recirculation filters, a receiving tank recirculating filter, and associated piping, valving and instrumentation.

Revision as of 22:28, 28 April 2019

Supplement to License Amendment Request (LAR) to Add Diesel Fuel Oil License Bases and Revise Technical Specifications (TS) 3.7.8, Cooling Water (Cl) System and 3.8.3, Diesel Fuel Oil.
ML13039A332
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 02/08/2013
From: Lynch J E
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-13-001, TAC ME6849, TAC ME6850
Download: ML13039A332 (42)


Text

tl Xcel Energy FEB 0 8 2013 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 L-PI-13-001 10 CFR 50.90 Supplement to License Amendment Request (LAR) to Add Diesel Fuel Oil License Bases and Revise Technical Specifications (TS) 3.7.8, "Cooling Water (CL) System" and 3.8.3, "Diesel Fuel Oil" (TAC Nos. ME6849 AND ME6850) By letter dated August 11, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 112240140), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requested NRC review and approval of additional diesel fuel oil (DFO) license bases and amendments to TS 3.7.8, "Cooling Water (CL) System" and 3.8.3, "Diesel Fuel Oil" for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. NSPM supplemented this LAR by letters dated February 21,2012 (ML 12054A057), July 9, 2012 (ML 12192A213) and October 4,2012 (ML 12279A116).

By letter dated January 22,2013 (ML 13011A389), NRC Staff provided clarification questions on information provided in the October 4, 2012 (ML 12279A 116) supplement.

The enclosure to this letter provides responses to the NRC Staff clarification questions and a refinement to the license basis changes proposed by this LAR. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.90. The supplemental information provided in this letter and enclosure does not impact the conclusions of the Determination of No Significant Hazards Consideration or Environmental Assessment presented in the August 11,2011 (ML 112240140) submittal as supplemented February 21,2012 (ML 12054A057), July 9,2012 (ML 12192A213) and October 4,2012 (ML 12279A116).

In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR supplement by transmitting a copy of this letter and enclosure to the designated State Official.

1717 Wakonade Drive East

651.388.1121 Document Control Desk Page 2 If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on d./ r j/ 3 d!aZ;:;-Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota Enclosures (1) cc: Administrator, Region III, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota ENCLOSURE Response to Requests for Additional Information for License Amendment Request (LAR) to Add Diesel Fuel Oil License Bases and Revise Technical Specifications (TS) 3.7.8, "Cooling Water (CL) System" and 3.8.3, "Diesel Fuel Oil" (TAC Nos. ME6849 and ME6850) This enclosure provides responses from Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), to Nuclear Regulatory Commission (NRC) clarification questions provided by letter dated January 22, 2013 (ML 13011A389) regarding the LAR requesting NRC review and approval of additional diesel fuel oil (DFO) license bases and amendments to TS 3.7.8, "Cooling Water (CL) System" and TS 3.8.3, "Diesel Fuel Oil" for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, submitted by letters dated August 11,2011 (ML 112240140) as supplemented February 21, 2012 (ML 12054A057), July 9, 2012 (ML 12192A213) and October 4, 2012 (ML 12279A 116). This enclosure also describes a proposed refinement to the licensing basis changes for the Unit 1 diesel fuel oil system: the cross tie capability between the diesel driven cooling water pump (DDCLP) fuel oil system and the Unit 1 emergency diesel generator (EDG) fuel oil system will not be credited for meeting TS fuel oil supply requirements.

Additional Licensing Basis Change The original intent of the diesel fuel oil LAR submitted by letter dated August 11,2011 (ML 112240140) was, for Unit 1, to add train specific 7-day fuel oil requirement for each EDG and each DDCLP to the Technical Specifications.

The Unit 1 7-day supply is sufficient to operate the EDG and DDCLP for longer than the time to replenish the onsite supply from outside sources while supplying maximum post design basis accident loads. The original submittal included a combined 7 day volume requirement for each train of one EDG and one DDCLP based on the ability to cross tie between storage tanks. The intent of this cross tie function was to provide some flexibility in storage tank volumes. As noted in response to RAI EEEB-1c by letter dated February 21,2012 (ML 12054A057):

The new volume requirements are more restrictive on removing a tank from service. There is currently not enough volume in the remaining operable tanks to remove a tank or pump from service without entering a Condition for an LCO [Limiting Condition for Operation]

not met under the proposed TS based on tank volumes and the new train separation requirements.

If the proposed TS are approved by the NRC, storage tank and pump maintenance will have to be planned for performance during refueling outages to avoid entry into a Condition for an LCO not met. However, the new 7 day train Page 1 of 11 Diesel Fuel Oil RAls requirements will maintain a safer fuel oil storage configuration to protect the plant during a DBA [design basis accident].

Maintaining the cross tie between the EDG and DDCLP fuel oil supplies as part of the TS compliance will require additional surveillance testing. The limited tank volume flexibility does not offset the additional testing requirements, therefore the cross tie ability will no longer be credited for meeting the 7 -day TS supply requirement.

Other than the cross tie capability, the Unit 1 7-day requirement and basis has not changed from the original August 11,2011 submittal (ML 112240140).

The TS requirement will still maintain the 7 -day fuel oil supply for each train of EDGs and DDCLPs. Therefore, the ability to mitigate an accident has not been reduced by this proposed change. The only function that has been affected is the potential ability to operate with reduced volume in one or two of the tanks while crediting fuel oil in the other same train tank(s). The 14-day fuel oil supply requirement for a maximum probable flood will be retained in the Updated Safety Analysis Report (USAR) for Unit 1. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) Unit 2 has dedicated fuel oil storage tanks for each EDG so there are no changes to the crediting of the 7-day supply. In addition, the 14-day fuel oil supply requirement for a maximum probable flood will be retained in the USAR for Unit 2. The 14-day supply will still have the ability to be satisfied through cross tie capability from storage tank to storage tank. The flow path integrity will be verified through testing performed every refueling cycle. (See marked up USAR provided in response to EEEB-15.c below.) This proposed license basis change necessitates additional changes to the TS 3.7.8 Bases and TS 3.8.3 Bases which are provided in marked up format as Attachment 1 to this Enclosure.

These marked up Bases supersede in their entirety the marked up Bases provided in the original submittal dated August 11, 2011 (ML 112240140), Enclosure Attachment

2. Pages B 3.7.8-16, B 3.8.3-5 and B 3.8.3-6 have been revised. NRC Request for Additional Information (RAil EEEB-13 The license amendment request (LAR) states that six Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) supply fuel oil to the two emergency diesel generators (EDGs) 01/02 and the two diesel-driven cooling water pumps (DDCLPs).

These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any diesel day tank. Therefore, any combination of the six tanks can be used to meet the 14-day storage capacity requirement for a probable maximum flood. This licensing basis will be maintained.

Page 2 of 11 Diesel Fuel Oil RAls Based on a review of the fuel oil and diesel system flow diagram NF-39232, mechanical isolation valves such as FO-2-6, FO-2-7, FO-13-4, FO-13-5 and the associated piping system may be used to meet the 14-day storage requirement in Unit 1 EDG system. Verify that the operability of these and other similar valves and piping systems that may be used to transfer fuel within the interconnected fuel oil system with six safety related tanks will be routinely tested using plant procedures to demonstrate the 14-day fuel oil supply capability.

NSPM Response to RAI EEEB-13: The cross tie capability to transfer fuel between trains of the diesel fuel oil system will be verified by test each refueling cycle to demonstrate the 14-day fuel oil supply capability.

For Unit 1, the capability to transfer fuel between the DDCLP fuel oil system and EDG fuel oil system will also be demonstrated.

These test requirements will be stated in the USAR. (See marked up USAR provided in response to EEEB-15.c below.) NRC RAI RAI EEEB-14 The "Proposed Changes" section of the LAR states that this LAR also proposes "revisions to the associated TS 3.7.8 and 3.8.3 to require the Unit 1 [diesel fuel oil (DFO)] storage system to have two trains of [fuel oil supply (FOS)] sufficient to operate one Unit 1 EDG and DDCLP for seven days and for the Unit 2 DFO storage system to have two trains of FOS sufficient to operate one Unit 2 EDG for seven days." [emphasis added] Clarify the intent of the above statements and provide a listing of the components in the FOS trains for each EDG. NSPM Response to RAI EEEB-14: The intent of this TS requirement, with the proposed license basis change described above, is that: 1) the Unit 1 EDG diesel fuel oil (DFO) system Train A will maintain the quantity of DFO capable of operating EDG D1 for seven days while mitigating a design basis accident (DBA) during a loss of offsite power (LOOP); 2) the Unit 1 EDG DFO system Train B will maintain the quantity of DFO capable of operating EDG D2 for seven days while mitigating a DBA during a LOOP; 3) the 12 DDCLP DFO system will maintain the quantity of DFO capable of operating 12 DDCLP for seven days while mitigating a DBA during a LOOP; 4) the 22 DDCLP DFO system will maintain the quantity of DFO capable of operating 22 DDCLP for seven days while mitigating a DBA during a LOOP; 5) the Unit 2 DFO system Train A will maintain the quantity of DFO capable of operating EDG D5 for seven days while mitigating a DBA during a LOOP; and 6) the Unit 2 DFO system Train B will maintain the quantity of DFO capable of operating EDG D6 for seven days while mitigating a DBA during a LOOP. Page 3 of 11 Diesel Fuel Oil RAls The listings of pumps, tanks and valves in the DFO system train for each EDG are provided below (instrumentation root valves have not been included in the following component list). Manual valves in the direct flow path from the storage tank to the supplied EDG day tank are also listed. Unit 1 cross-tie valves which allow movement of DFO between the CL storage tanks and the Unit 1 EDG storage tanks are not provided since, as discussed above, these flow paths will not be credited for providing the required DFO volumes. The Unit 1 components, except for the day tanks, are shown on flow diagram NF-39232, "Flow Diagram Fuel & Diesel System Unit 1 & 2", Revision 80 provided previously with RAI responses dated February 21,2012 (ML 12054A057).

The Unit 2 components, except for the day tanks, are shown on flow diagram NF-118252, "Flow Diagram D5/D6 Dsl Gen Fuel Oil System Unit 1 & 2," Revision 78. The EDG day tanks are shown on drawings NF-39255-1, "Flow Diagram Diesel Generators D1 & D2 Unit 1 & 2", Revision 79; NF-118248, "Flow Diagram Fuel Oil System D5, Unit 2", Revision 76; and NF-118249, "Flow Diagram Fuel Oil System D6, Unit 2", Revision 76. These drawings are provided in Attachment 2 to this Enclosure.

Unit 1 Train A supplies D1 EDG Major Components

  • 121 DSL GEN FOST XFER PUMP (045-271)
  • 122 DSL GEN FOST XFER PUMP (045-272)
  • 121 DSL GEN OIL STG TNK (053-221)
  • 122 DSL GEN OIL STG TNK (053-222)
  • D1 DSL GEN FUEL OIL DAY TANK (053-201)

Instruments

  • LA 16698
  • LA 16780
  • PI 11462 Valves
  • FO-2-7
  • FO-2-8
  • FO-2-9
  • FO-2-10
  • FO-2-11
  • FO-2-12
  • FO-2-13 Page 4 of 11 Diesel Fuel Oil RAls
  • F0-4-3
  • FO-4-4
  • FO-21-7
  • FO-113-1
  • FO-113-2
  • FO-113-9
  • FO-113-10
  • FO-113-16 Unit 1 Train B supplies 02 EDG Major Components
  • 123 DSL GEN FOST XFER PUMP (045-273)
  • 124 DSL GEN FOST XFER PUMP (045-274)
  • 123 DSL GEN OIL STG TNK (053-223)
  • 124 DSL GEN OIL STG TNK (053-224)
  • 02 DSL GEN FUEL OIL DAY TANK (053-202)

Instruments

  • LA 16699
  • LA 16781
  • PT 17136 Valves
  • FO-2-2
  • FO-2-3
  • FO-2-4
  • FO-2-5
  • FO-2-6
  • FO-2-14
  • FO-2-15
  • FO-4-1
  • FO-4-2
  • FO-21-6
  • FO-113-3
  • FO-113-4
  • FO-113-11
  • FO-113-12 Page 5 of 11 Diesel Fuel Oil RAls
  • FO-113-17 Unit 2 Train A supplies 05 EOG Major Components
  • 21 OSL GEN FOST XFER PUMP (245-881)
  • 23 OSL GEN FOST XFER PUMP (245-883)
  • 21 OSL GEN OIL STG TNK (253-331)
  • 23 OSL GEN OIL STG TNK (253-333)
  • 21 05 FO DAY TNK (253-361)

Instruments

  • 2LSH 5013
  • 2LSHH 5013
  • 2LSLL 5012
  • 2LSL 5012
  • 2LT 5001
  • 2LT 5002
  • 2LT 5011
  • 2PI5003
  • 2PI5005 Valves
  • 2FO-4-2 Page 6 of 11 Diesel Fuel Oil RAls
  • 2FO-8-7 Unit 2 Train B supplies 06 EDG Major Components
  • 22 DSL GEN FOST XFER PUMP (245-882)
  • 24 DSL GEN FOST XFER PUMP (245-884)
  • 22 DSL GEN OIL STG TNK (253-332)
  • 24 DSL GEN OIL STG TNK (253-334)
  • 2206 FO DAY TNK (253-362)

Instruments

  • 2LSHH 6013
  • 2LSH 6013
  • 2LSLL 6012
  • 2LSL 6012
  • 2LT 6001
  • 2LT 6002
  • 2LT6011
  • 2PI6003
  • 2PI6005 Valves
  • 2FO-3-33 Page 7 of 11 Diesel Fuel Oil RAls
  • 2FO-S-9 NRC RAI EEEB-15 NSPM's February 21,2012, response to RAI EEEB-1a states that the Unit 1 EDG system has two safety related tanks (121 and 122 DSL GEN OIL) associated with EDG D1, and one safety related tank, 121 DSL CLWP. (EDG D2 has a similar set of tanks). The LAR states that any combination of the three tanks may be used to meet the day fuel oil requirement of the EDG D1 and CLWP 1. a) Technical Specification Surveillance Requirement (SR) 3.S.1.5 requires the licensee to verify, every 31 days, that the fuel oil transfer system operates to transfer fuel oil from storage tank to day tank. Validate that the surveillance requirements associated with proposed change will confirm the operability of all flow paths associated with each DSL tank and the associated EDG and the CLWP. b) It is the NRC staff's understanding that the combination of 121 and 122 DSL GEN and 121 DSL CLWP storage tanks will constitute one train offuel oil system associated with EDG D1 emergency power supply system and storage tanks 123 and 124 DSL GEN coupled with 122 DSL CLWP will comprise the redundant train of the fuel oil system for EDG D2. Verify that the intent of the proposed LAR is to have a seven-day storage capacity in each train of the Unit 1 EDG system as described above. Similarly the Unit 2 EDG system has 2 safety related tanks associated with each EDG. Verify that each train (2 tanks per train) will maintain the seven-day storage capacity.

c) Provide the revised Updated Safety Analysis Report (USAR) description of the specific EDG fuel oil components, using plant-specific nomenclature, that comprise each credited seven-day EDG fuel oil train as described in the proposed TS Bases, that will be incorporated in the USAR prior to implementation of this license amendment.

d) Clarify the intent of words "one or both" as used in proposed changes to TS 3.7.S and 3.S.3. Describe if "one or both" is related to each train of equipment or specific components or tanks. Page S of 11 Diesel Fuel Oil RAls NSPM Response to RAI EEEB-15: EEEB-15a:

As described above, NSPM proposes to change the license basis to not credit the cross tie capability between the OOCLP fuel oil system and the Unit 1 EOG fuel oil system for meeting the 7 -day fuel oil supply required by the proposed TS. With this license basis change, the current requirements of TS SR 3.8.1.5 validate the fuel oil flow paths that are credited for meeting the TS OFO supply requirements.

That is, as stated in the TS Bases for this SR, "This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank." Since only EOG OFO tanks will be credited for providing the 7-day supply to each EOG, this SR will confirm the operability of all flow paths associated with each EOG tank and the associated EOG. Flow from the OOCLP OFO tank to the associated OOCLP day tank is also verified by test each month. EEEB-15b:

With the proposed license basis change described above, the intent of proposed TS 3.8.3 and 3.7.8 is: 1) 121 and 122 OSL GEN OIL STG TNKs, the Unit 1 Train A EOG tanks, will provide a seven-day storage capacity for 01 EOG, the Unit 1 Train A EOG; 2) 123 and 124 OSL GEN OIL STG TNKs, the Unit 1 Train B EOG tanks, will provide a seven-day storage capacity for 02 EOG, the Unit 1 Train B EOG; 3) 21 and 23 05 FO STORAGE TANKs will provide a seven-day storage capacity for 05 EOG, the Unit 2 Train A EOG; and 4) 22 and 24 06 FO STORAGE TANKs will provide a seven-day storage capacity for 06 EOG, the Unit 2 Train B EOG. Each EOG OFO train comprises two tanks and these two tanks will be maintained with the volumes specified in the Bases to provide a 7-day supply for their associated EOG. EEEB-15c:

The specific EOG fuel oil components, using plant-specific nomenclature, that comprise each credited seven-day EOG fuel oil train are shown on USAR Figures 10.3-18 and 10.3-19 for Unit 1 and 2 EOGs respectively.

Attachment 3 to this Enclosure provides a draft USAR markup which incorporates the license basis changes proposed in this LAR. When the PINGP TS were converted to the NUREG-1431, "Standard Technical Specifications, Westinghouse Plants", format and content, the convention was adopted to the extent possible to include details in the TS Bases which were not provided in the USAR. Use of this convention facilitates ease of maintenance since the information is Page 9 of 11 Diesel Fuel Oil RAls limited to the TS Bases or USAR and only one document requires updating when there are changes. Consistent with this convention, the USAR markup references the TS Bases which provides a more detailed description of the license basis for the 7 -day fuel oil supply requirements.

EEEB-15d:

The "one or both" refers to each train of equipment.

This proposed TS was written to be consistent with NUREG-1431 content and guidance as modified by Technical Specification Task Force (TSTF) industry traveler 501. The TS 3.8.3 LCO statement specifies "Each stored diesel generator (OG) fuel oil supply shall be within limits", that is, the fuel oil supply associated with that train of EOG shall be within the limits as defined by SR 3.8.3.1 which requires "each stored OG fuel oil supply contains;:::

7 day supply". NUREG-1431 as modified by TSTF-501 in Condition A states, "One or more OGs with fuel level less than a [7] day supply and greater than a [6] day supply in storage tank". Since PINGP has only two trains, "one or more" was revised to "one or both". Since there is more than one tank associated with each EOG at PINGP, Condition A was also modified to state, "stored OG fuel oil supply(s)

< 7 days and;::: 6 days". The optional "(s)" on supply would apply if both trains of supply were less than required.

NRC RAI EEEB-16 In NSPM letter dated October 4,2012 (ADAMS Accession No. ML 12279A116), the licensee stated that a large break LOCA [loss of coolant accident]

event with large loads such as the residual heat removal pumps, high pressure safety injection pumps and containment spray pumps secured after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is the bounding case for fuel oil consumption.

a) Verify that events such as a small break LOCA (2 inch or smaller), a steam generator tube rupture or a small steam line break do not require operation of large loads for an extended duration (i.e., longer than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). b) What process ensures that the major loads would be reduced after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for all design basis accidents considered in Section 14 of the PINGP USAR? NSPM Response to RAI EEEB-16: EEEB-16a:

To verify that events do not require operation of large loads for extended duration, the safety analysis discussed in USAR Section 14 was reviewed for bounding scenarios for the loading of the 01, 02, OS, and 06 emergency diesel generators.

Page 10 of 11 Diesel Fuel Oil RAls As stated in USAR Section 14.1.1, the accidents discussed in USAR Section 14.4 (with the exception of the reactor coolant pump locked rotor accident) are accommodated, at most, with a reactor shutdown or trip. The locked rotor accident requires a reactor trip and excess pressure relief through the safety valves. These accidents would not require use of the engineered safety features.

The accidents discussed in USAR Section 14.5 do not require the use of all the engineered safety features.

The accidents may require use of some of them for short durations.

The maximum duration noted for these major loads would be for the steam line rupture at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The loading for a small break LOCA accident could require the safety injection (SI) pumps to run for 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. EEEB-16b:

The process that ensures the major loads are reduced after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is PINGP Procedure SWI 0-35, "Emergency Operating Procedure Verification, Validation

& Maintenance." This procedure documents the time critical operator actions at PINGP. The maximum two durations noted previously (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) are controlled by this procedure.

For the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> steam line rupture requirement, per SWI 0-35, Attachment 1, Section 4, switchover to residual heat removal (RHR) will take place within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. For the 7.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> small break LOCA requirement, per SWI 0-35, Attachment 1, Section 12, requires the SI pumps to be secured and to align the reactor coolant system to RHR shutdown cooling or low head recirculation within 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to preclude boron precipitation.

Page 11 of 11 ENCLOSURE, ATTACHMENT 1 Technical Specification Bases (Markup) B 3.7.8-4 B 3.7.8-12 B 3.7.8-13 B 3.7.8-14 B 3.7.8-16 B 3.7.8-17 B 3.7.8-20 B 3.8.3-1 B 3.8.3-2 B 3.8.3-3 B 3.8.3-4 B 3.8.3-5 B 3.8.3-6 B 3.8.3-7 B 3.8.3-8 15 pages follow BASES APPilCABlE SAFETY ANALYSES (continued)

LCO Prairie Island Units I and 2 CL System B 3.7.8 failure of any active component, assuming the loss of offsite power. This assumes a maximum CL temperature of 95°F occurring simultaneously with design heat loads for the system. The CL System satisfies Criterion 3 of 10 CPR 50.36(c)(2)(ii).

Two CL trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power. A CL train is considered OPERABLE when: a. The safeguards CL pump, aligned to the train, is OPERABLE;

b. The associated header is OPERABLE; and c. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

A diesel driven safeguards CL pump is considered OPERABLE when: a. The pump can meet the design flow/pressure requirements in accordance with the Inservice Testing Program; b. The associated piping, valves, auxiliaries, and instrumentation and controls required to perform the safety related function are OPERABLE; and c. There is a minimum 7 day stored diesel driven CL pump fuel oil supply of 19,500 gallons available fefin that train's tankse ffies.el driven safeguards pumps. The fuel oil supply equivalent to 7 days is 9.750 gallons. B 3.7.8-4 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 BASES ACTIONS Prairie Island Units 1 and 2 B.1. B.2 and B.3 (continued)

CL System B 3.7.8 The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," should be entered if an inoperable CL train results in an inoperable decay heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

The 4 and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Times are based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period. In addition, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for Required Actions B.1 and B.2 is within the time period anticipated to verify OPERABILITY of the required CL pump by administrative means. C.1 and C.2 If at least one safeguards CL pump for a train or a CL supply header cannot be restored to OPERABLE status within the associated Completion Time, the units must be placed in a MODE in which the LCO does not apply. To achieve this status the units must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This Condition is modified by a note indicating that separate Condition entry is allowed for each stored diesel driven CL pump fuel oil supply. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each B 3.7.8-12 Unit 1 -Revision 184 Unit 2 -Revision 184 BASES ACTIONS BABES i\:CTIONS Prairie Island Units I and 2 D.1 (continued)

CL System B 3.7.8 inoperable stored diesel driven CL pump fuel oil supply. Comnlving with the Required Actions for one inoperable stored diesel driven CL pump fuel oil supply may allow for continued operation, and subsequent inoperable stored diesel driven CL pump fuel oil supply is governed by separate Condition entry and application of associated Required Actions. In this Condition, the 7 day stored diesel driven CL pump fuel oil supply for the diesel driven CL pumps is not available.

However, the Condition is restricted to fuel oil supply reductions that maintain at least a day supply. The fuel oil supply equivalent to a 6 day supply is 8,500 gallons. 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(s). 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 supply prior to D.1 (continued) declaring the diesel driven CL pumps inoperable.

This period is acceptable based on the remaining day fuel oil supply, the fact that procedures will be initiated to obtain replenishment, availability of the vertical motor driven CL pump and the low probability of an event during this brief period. The second Completion Time for Required Action D.1 establishes a limit on the maximum time allowed for combinations of Conditions A and D to be inoperable during any continuous failure to meet this LCO for these Conditions.

The 9 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which B 3.7.8-13 Unit 1 -Revision 184 Unit 2 -Revision 184 CL System B 3.7.8 Conditions A and D are entered concurrently.

The AND connector between 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and 9 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met. This Condition is modified by a note indicating that separate Condition entry is allowed for each stored diesel driven CL pump fuel oil supply. This is acceptable.

since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable stored diesel driven CL pump fuel oil supply. Complying with the Required Actions for one inoperable stored diesel driven CL pump fuel oil supply may allow for continued operation.

and subsequent inoperable stored diesel driven CL pump fuel oil supply is governed by separate Condition entry and application of associated Required Actions With the stored fuel oil supply not within the limits specified or Required Actions and associated Completion Times of Condition D not met, the diesel driven CL pumps-may be incapable of performing theif intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS BASES This SR is modified by a Note indicating that the isolation of the CL System components or systems may render those components inoperable, but does not affect the OPERABILITY of the CL System. SURVEILLANCE SR 3.7.8.1 (continued)

REQUIREMENTS Prairie Island Units 1 and 2 This SR verifies the correct alignment for manual, power operated, and automatic valves in the CL System flow path to assure that the proper flow paths exist for CL System operation.

This SR does not B 3.7.8-14 Unit 1 -Revision 184 Unit 2 -Revision 184 BASES SURVEIlLANCE REQUIREMENTS (continued)

Prairie Island Units I and 2 SR 3.7.8.3 CL System B 3.7.8 This SR provides verification that there is an adequate supply inventory of diesel driven CL pump fuel oil in the storage tanks to support the-each train's diesel driven CL pump operation of one diesel driven CL pump for 7 days. The stored diesel:g.G fuel oil supply equivalent to a 7 day supply for one train, is 9,750 gallons when calculated in accordance with Regulatory Guide 1.137 (Ref. 3) and ANSI N195-1976 (Ref. 4). The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using 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 3.8.3.2 requires new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel driven CL pump 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 specified fuel oil inventory for the diesel driven cooling \vater pumps is in addition to the fuel oil inventory specified for the Unit 1 diesel generators (DGs) (LCO 3.8.3) that must be available in the Unit 1 diesel fuel oil storage system. The diesel driven cooling water pump Unit 1 fuel oil system has two safety related trains. Each train consists of There moe !lYQfour Design Class I fuel oil storage tanks for the same train Unit 1 DGs and two one Design Class I fuel oil storage tanks for the diesel driven cooling water pumps. These Design Class I tanks are interconnected such that any tank can be manually aligned to supply any Unit 1 either the DG or diesel driven cooling v/ater pump day tank for that train. Any combination of inventory in these tanks may be used to satisfy the inventorysupplv requirements for the train's diesel driven cooling water pumps and the Unit 1 DGs. Since the fuel oil for the CL pumps comes from the common fuel oil tanks shared by the Unit 1 diesel generators, Tthe testing and the quality of the fuel oil is controlled by Technical Specification 5.5.11, "Diesel Fuel Oil Testing Program." B 3.7.8-16 Unit 1 -Revision 185 Unit 2 -Revision 185 BASES CL System B 3.7.8 The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and plant operators would be aware of any large uses of fuel oil during this period. SR 3.7.8.4 This SR verifies the vertical motor driven CL pump, when required to meet the LCO, is OPERABLE to provide assurance that equipment, when lined up in the safeguards mode, will perform as expected in the safety analysis.

SURVEILLANCE SR 3.7.8.4 (continued)

REQUIREMENTS Prairie Island Units 1 and 2 For this test, an acceptable level of performance shall be: a. Pump starts and reaches required developed head; and b. Control board indications and visual observations indicate that the pump is operating properly for at least 15 minutes. The 92 day Frequency is based on the Inservice Testing Program requirements (Ref.

Under some plant conditions, the vertical motor driven CL pump is required to operate to provide additional CL flow. When this pump is operated to support plant operations, this test can not be performed and this pump is considered inoperable as a safeguards CL pump. SR 3.7.8.5 This SR verifies proper automatic operation of the CL System valves on an actual or simulated safety injection actuation signal, including those valves that isolate non-essential equipment from the system. B 3.7.8-17 Unit 1 -Revision 185 Unit 2 -Revision 185 BASES CL System B 3.7.8 SURVEIILANCE SR 3.7.8.6 (continued)

REQUIREMENTS REFERENCES Prairie Island Units 1 and 2 Operating experience has shown that these components usually pass the Surveillance when performed.

Therefore, the Frequency is acceptable from a reliability standpoint.

l. USAR, Section 10.4. 2. USAR, Section 6. 3. Regulatory Guide 1.137. 4. ANSI N195-1976.
5. ASME Code for Operation and Maintenance of Nuclear Power Plants. B 3.7.8-20 Unit 1 -Revision 195 Unit 2 -Revision 195 Diesel Fuel Oil B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil BASES BACKGROUND APPUCABIE SAFETY ANALYSES Prairie Island Units 1 and 2 Each diesel generator (DG)'H::fl:it is provided with a stored DG fuel oil capacity supply sufficient to operate thate diesel generator (DGsj for a period of -l4--7 days while the DG is supplying maximum post loss of coolant accident load demand as discussed in the USAR (Ref. 1). The onsite fuel oil capacity supply is sufficient to operate the DGs for longer than the time to replenish the on site supply from outside sources. New DG fuel oil is placed in a receiving tank where it is tested in accordance with the Prairie Island Nuclear Generation Plant (PINGP) Diesel Fuel Oil Testing Program. Once the test results have verified that the fuel oil is within limits, the fuel oil may be transferred to the safeguards fuel oil storage tanks. Fuel oil is then transferred from the safeguards fuel oil storage tank to the day tank by the fuel oil 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 to result in the loss of more than one DG. For proper operation of the DGs, it is necessary to ensure the proper quality of the fuel oil. PINGP ensures fuel oil quality through implementation of the Diesel Fuel Oil Testing Program. The initial conditions of Design Basis Accident (DBA) and transient analyses in the USAR (Ref. 2) assume Engineered Safety Feature (ESF) systems are OPERABLE.

The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems. B 3.8.3-1 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 BASES APPilCABLE SAFETY ANALYSES ( continued)

LCO Diesel Fuel Oil B 3.8.3 Since the diesel fuel oil system supports the operation of the standby AC power sources, it satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Stored DG diesel fuel oil supply is required to have sufficient supply for 7 days of DG operation at maximum post loss of coolant accident load demandetl:e DO on each unit to operate for 14 days (Ref. I), It is also required to meet specific standards for quality. This requirement, in conjunction with an ability to obtain replacement supplies within +/-4-7 days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel requirements, as well as transfer capability from the safeguards storage tank to the day tank, are addressed in LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, "AC Sources-Shutdown." APPilCABIIlTY ACTIONS Prairie Island Units 1 and 2 The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored DG diesel fuel oil supply supports LCO 3.8.1 and LCO 3.8.2, it is required to be within limits when the associated DGfs) is required to be OPERABLE.

The ACTIONS Table is modified by a note indicating that separate Condition entry is allowed for each stored DG fuel oil supply. This is acceptable.

since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable stored DG fuel oil supply. Complying with the Required Actions for one inoperable stored DG fuel oil supply may allow for continued operation.

and subsequent inoperable stored DG fuel oil supply is governed by separate Condition entry and application of associated Reguired Actions. B 3.8.3-2 Unit 1-Amendment No. 158 Unit 2 -Amendment No. 149 BASES Prairie Island Units 1 and 2 A.l Diesel Fuel Oil B 3.8.3 In this Condition, the -l4--7 day stored DG fuel oil supply for DG& is not available.

However, the Condition is restricted to fuel oil supply reductions that maintain at least a day supply. The fuel oil supply equivalent to a 6 day supply is 22.000 gallons (Unit 2-35,250 gallons).

These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required supply, 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 B 3.8.3-3 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 BASES ACTIONS Prairie Island Units 1 and 2 A.l (continued)

Diesel Fuel Oil B 3.8.3 required prior to addition of fuel oil to the tank(s). 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 supply prior to declaring the DG& inoperable.

This period is acceptable based on the remaining capacity (> -:b!--6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.2. If fuel oil properties in one or more required DG fuel oil tank(s) are not within limits, actions must be taken to restore the fuel oil properties to within limits. If the fuel oil properties in the fuel oil tank(s) are not within limits, it 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 it is prudent to allow a brief period prior to declaring the associated DG inoperable or isolating the associated fuel oil tank(s). Therefore the 7 day Completion Time allows for further evaluation, resampling and re-analysis of the DG fuel oil. With a Required Action and associated Completion Time of Condition B not met, the associated fuel oil tank must be isolated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Isolation of a specific fuel oil tank may not make the associated DG inoperable since the DG can take suction from another fuel oil tank. Isolation of the associated fuel oil tank may cause entry into Conditions A or D which could result in the DG being inoperable.

B 3.8.3-4 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 ACTIONS D.l ( continued)

With the stored fuel oil supply not within the limits specified or Required Actions and associated Completion Times of Conditions A or C not met, the DOs-may be incapable of performing theHthe intended function and must be immediately declared inoperable.

A Note has been added to Condition D requiring entry into the applicable Conditions and Required Actions of LCO 3.7.8, "CL System" for CL train(s) made inoperable as a result of stored fuel oil properties not within limits. Since the diesel generators and the diesel driven CL pumps share a common storage tank, the diesel fuel oil properties are maintained by Specification 5.5.11, "Diesel Fuel Oil Testing Program." Therefore, if the fuel oil properties are not within limits, both the diesel generators and the diesel driven CL pumps are affected and appropriate Required Actions taken. SURVEILLANCE SR 3.8.3.1 REQUIREMENTS Prairie Island Units 1 and 2 This SR provides verification that there is an adequate inventory supply of DO fuel oil in the storage tanks to support tfte.-DG operation of one DG for +/-4-7 days. The stored DG fuel oil supply equivalent to a 7 day supply is 26,750 gallons (Unit 2 -39,900 gallons) when calculated in accordance with Regulatory Guide 1.137 (Ref. 3) and ANSI N195-1976 (Ref. 4). The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using 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 3.8.3.2 requires new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the DG diesel fuel oil consumption calculations.

The 144 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 specified fuel oil inventory for the Unit 1 diesel generators (DGs) is in addition to the fuel oil inventory specified for the diesel driven cooling water pumps (LCO 3.7.8) that must be available in B 3.8.3-5 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 Prairie Island Units 1 and 2 the Unit 1 diesel fuel oil storage system. The Unit 1 fuel oil system has two safety related trains. Each train consists of There are teurtwo Design Class I fuel oil storage tanks for the same train .unit -l-DGs and Design Class I fuel oil storage tanks for the diesel driven cooling water pumps. These Design Class I tanks are interconnected such that any tank can be manually aligned to supply the same train any eithef' theUnit 1 DG or diesel driven cooling water pump day tank for that train. Any combination of inventory in these tanks may be used to satisfy the inventory supply requirements for the Unit ltrain's DGs and the diesel driven cooling 'llater pumps. B 3.8.3-6 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 SURVEIILANCE SR 3.8.3.1 (continued)

REQUIREMENTS Prairie Island Units 1 and 2 Unit 2 DG fuel oil system has two safety related trains. Each train consists of There are four Unit 2 two Design Class I fuel oil storage tanks for the same train DG. These fe:u.ftwo Unit 2 tanks are interconnected such that any tank can be manually aligned to supply either Unit 2the same train DG day tank. Any combination of inventory in these fe.Hf.-two Unit 2 tanks may be used to satisfy the Unit 2 DG inventory supply requirements for the train's DG. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. SR 3.8.3.2 The tests for the new fuel oil prior to addition into the safeguards storage tank(s) 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 safeguards storage tanks without concern for contaminating the entire volume of fuel oil in the safeguards storage tanks. These tests are to be conducted prior to adding the new fuel to the safeguards storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests and limits for new and stored fuel are described in the Diesel Fuel Oil Testing Program of Specification 5.5.11. B 3.8.3-7 Unit 1 -Amendment No. 158 Unit 2 -Amendment No. 149 SURVEIILANCE SR 3.8.3.2 (continued)

REQUIREMENTS REFERENCES Prairie Island Units 1 and 2 Failure to meet any of the limits specified in the Diesel Fuel Oil Testing Program is cause for rejection of the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks. Failure to meet any of the limits for stored fuel requires entry into Condition B. 1. USAR, Sections 8.4 and 10.3. 2. USAR, Section 14. 3. Regulatory Guide 1.137. 4. ANSI N195-1976.

B 3.8.3-8 Unit 1-Amendment No. 158 Unit 2 -Amendment No. 149 ENCLOSURE,ATTACHMENT2 NF-118252, "Flow Diagram 05/06 Dsl Gen Fuel Oil System Unit 1 & 2," Revision 78 NF-39255-1, "Flow Diagram Diesel Generators 01 & 02 Unit 1 & 2", Revision 79 NF-118248, "Flow Diagram Fuel Oil System 05, Unit 2", Revision 76 NF-118249, "Flow Diagram Fuel Oil System 06, Unit 2", Revision 76 4 pages follow A f--B f--c f--D E f--F f--G f-H I 2 I 3 I 11,]8 11 FILTER VALVE NUMBERS (SEE DETAIL 21 FIL TER 391 2FO-1l-2 2FO-10-4 DETAIL 2 4" VENT AND FLAME ARRESTOR LOWER DRAIN 2FO-10-5 2FO-10-7 2FO-W-9

________ __

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  • 7 2-2FO-14 I 8 I I 2FOt8 I . -.:J
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'----.f I 10 4" VENT AND FLAME ARRESTOR t I 11 4'x2'RED 4-2FO-57 2105/06 RECEIVING TANK DETAIL 3 4"VENT AND FLAME ARRESHlR I 12 REVISIONS SPEC. REF. ADO LJI.'ES 112-2HH21, l12-2fD--122.1I2-2fO-123, 1/2-2FO-124,1I2-2FO-125, lI2-2fO-I26,1/2-2FO-127.

112-2fO-128,1/2-2FO-12'1.

J12-2fD--I32,1I2-2FO-131, J12-2FO-JJ2,1/2-2FO-133.

l12-2FO-134,lI2-2FO-135 1/2-2FO-136,3/4-2FO-1l8, 3/-l-2FD--U'l.Y4-2FO-12il, 2-2FD-Q,2-2FD--2,2-2FD--34, 2-2FD-26,1/2-2FO-U4, 112-2fO-1I6,1I2-2FO-lJIl.

lI2-2FO-112.112-2fO-II5, lI2-2fO-1I7,1I2-2FO-lll, 1/2-2FD-1I3

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OWN, 6-26-eCJ b <1>-,OJ L ____ _ 05 BULK FUEL OIL STORAGE VAULT 3-2FO-I 2FD-4-15 0 SEE D£TAJL 3-2FD-28 THIS OWG. 2-2FO-40 3-2FO-53 M1TANK LEVEL STICK 6ri\ 2-2FO-30 4"E FILL W 4"X3" RED. 3" y N rmmn-1h_--,'

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0<<'0. JEK m-II-liI MOQ",EC-15050 APP'DI CHR HH2-la 05/06 FUEL OIL STORAGE VAULT CHART 1. LINE 1 LJNE 2 LINE 3 2-2FO-Q 112-2FD-1l4 112-2FO-1I5 2-2FO-2 1I2-2F0-116 1/2-2FO-1l7 2-2FD-34 l!2-2FG-TI0 112-2FO-111 2-2FO-28 1I2-2FO-112 112-2FO-113 PUMP '40, 2POSH NO. 2PI NO, VLV, 1 NO. STRAINER 21 05 5004 5008 2FO-8-17 258-041 23 05 5006 500<} 2FO-8-1<}

258-043 22 06 6004 6008 2FO-8-21 2FO-8-22 2FO-8-27 258-042 24 Ub 601lb 600q 2FO-8-23 2FO-B-24 f 2FO-8-28 258-044 (SR IISR Ic1JJi LEGEND CLASS BREAK QA TYPE '78' --SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS --NSR -NON-SAFETY-RELATED IA,IB,IC,lIA,lIB

&. lJI DENOTES PIPING OA TYPES, J, TAt-;K OVERFLOW LOOP SEAL TO BE FILLED WITH 50" ETHYLENE GLYCOL SOLUTION, 2. FOR VAlVE POSITIONS SEE DPS t'AI-.'UAl C PROCEDURE CHECKLIST.

3. UNLESS OTHER'WISE SHOWN, CLASS BOUNDARIES STOP AT VEN1 AND DRAIN VALVES WITH ETC.l 4, FOA SYMBOLS SEE Xlt-l-lC5.

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I ('1/-62-4 Icw-j 20-141 -.. tHj--J D lOG-5§! B I V FUEL PI*1P 02 FO-50-2 I --.-.-HAN0l-R1-8'5-1261 045-}251 PMP 02-045-1262 D2-IH5-1252 VENT TO _ CONTAI.jINATED ATM NSR III FUEL TNK LA \ D1 lDG-37 16732)01 D2 20G-37 0 Ijl [

CLEAN FUEL TNK LA 16733)02 DETAIL 'I' 1-/

5 I-CW-77-1 I 20G-I 1 7 I u 120 1 G-16I 120G-,sl-V r.I III I IC ... 5' v I STAND-BY Q JCKT CLNT PMP 112 HP 045-1222 :--Qi5HJ 6 ... r l.CJ o 7 1 ORN LN TO OSL GEN OIL STG TI\'1<S NF-39232 E-10 8 )f------1 IFD-32-4 r: '-Qlll8J 0 [...,..I--JI'-----j . 10 -....rEq srG TNK CONT ALM PIPING NF-39232 H-S I .. _ .. ---1 aSL GEN FO DAY TNK (¥ L VL CONT & AU-l PIPING

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I.:J 2oG-33 ,--D1 &. 02 C I I--4-CL-32 Y 8-10 11 I 12 REVISIONS L \ /?\

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&. C.,Q-552.

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&. I1t DENOTES PIPING OA TYPES. NOTES: 2' __ _ I. FOR VALVE POSITIONS SEE OPS MANUAL C PROCEDURE CHECKLIST.

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L VL 2-FO-69 DET '3' CLASSED AS NON-SAFETY-RELATED.

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_ CL SYS FLOW OIA UNIT 1 NF-3g217-2

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  • ___________

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HIAW -02400-79 (SUPPORTS)

HIAW -32430-80 (MATERIAL)

HIAW -32433-8J (VALVES) 8 NOTES: 1. FOR VALVE POSITIONS SEE OPS MANUAL C PROCEDURE CHECKLIST, FEED RA."W 2. UNLESS OTHERWISE SHOWN, CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAM ITEMS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.

3. FOR SYMBOLS SEE XH-H05, NF-392J4.

9 10 _MOl _.-LEGEND I CLASS BOUNDARY ---SR -SAFETY-RELATED FLUID BOUNDARY; NON-CODE CLASS ---NSR -NON-SAFETY-RELATED JA.IB,IC,IIA,IlB

& III DENOTES PIPING OA TYPES. DENOTES VALVES AND INSTRUMENTS FURNISHED WITH EQUIPMENT BY SACH pER HIAW-02610. (MANUFACTURERS STANDARDS).

DENOTES SACH MANUFACTURERS STANDARDS, INSTRUMENTATION BOUNDED BY AND ENCLOSED BY THIS LINE REPRESENTS SACH SUPPLIED INSTRUMENTATION.

FLOW DIAGRAM FUEL 05 _ 76 NF-118248

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HIAW -32400-7'3 (SUPPORTS)

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2. UNLESS OTHERWISE SHOWN. CLASS BOUNDARIES STOP AT VENT AND DRAIN VALVES WITH DOWNSTREAH lTEHS (e.g., PIPE. CAPS, ETC.) CLASSED AS NON-SAFETY-RELATED.
3. FOR SYMBOLS SEE XH-l-H35.

NF-3'3214.

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INSTRUMENTATION BOUNDED BY AND ENCLOSED BY THIS LINE REPRESENTS SACH SUPPUED INSTRUMENTATlON.

FLOlv DIAGRAM FUEL OIL SYSTEM D6 UNIT 2 -.. 1_ 76 NF-11824'l B720 --.--

CM] 12 [J" N CO J z H ENCLOSURE, ATTACHMENT 3 Draft Updated Safety Analysis Report Section 10.3.13 7 pages follow PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT I SO" rrop()J'&d FO LfiR I USAR Section 10 Revision 32P Page 10.3-32 The Control Rooms and 480V switchgear areas are provided with a direct expansion type mechanical cooling system for non-safety related auxiliary cooling. Each cooling system consists of an outdoor compressor/condenser unit, a room-mounted evaporator/fan unit, interconnecting tubing, control equipment, and power supply. The safety-related building ventilation system includes two 100% capacity vane axial type supply fans and two 100% capacity exhaust fans per train. The fans have direct-drive totally enclosed, air over (TEAO) motors. One supply and one exhaust fan per train are normally operating, with the other fan in standby. All safety-related equipment is powered from safeguards buses. The Lube Oil and Fuel Oil Tank Rooms are provided with exhaust fans to prevent the buildup of fumes. The 05/D6 Diesel Generator Room Ventilation system includes the non-safety related normal mode ventilation fans, provided for human comfort; the safety-related cooling fans (one per train) which operate upon receipt of a diesel generator start signal; and the associated ductwork and controls.

The diesel generator room cooling fans will function to limit the maximum ambient temperature to 120°F in conformance with equipment operating temperature ratings, and supply the volumetric flow of air necessary to cool the generator bearings.

The outside air is modulated with return air to maintain a minimum temperature of 50°F in the Diesel Generator Engine Room. The diesel generator room cooling fans are vane axial type with direct-drive TEAO motors, and are supplied from safeguards buses. The ventilating equipment is accessible for periodic testing and inspection during normal operation.

10.3.13 Fuel Oil System 10.3.13.1 Design Basis 10.3.13.1.1 Function The fuel oil system receives and stores diesel fuel oil and delivers it to the fuel oil systems of both safety and non-safety related components consisting of six diesel generators, two diesel driven cooling water pumps, one heating boiler, and a diesel driven fire pump. Since four of the diesel generators, 01/D2 and 05/06, and the cooling water pumps are safety related components, provisions are made in the design and installation to ensure that these components will operate in the event of an abnormal or emergency condition.

The fuel oil system for Unit 1 provides fuel oil for the operation of all but two safety related emergency diesel generators, D5/06; the fuel oil system for Unit 2 provides fuel oil solely for the operational needs of emergency diesel generators D5/D6. The fuel oil system also provides a means of transferring fuel oil between fuel oil storage tanks and a means of filtering new and transferred oil.

PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT 10.3.13.1.2 Design Minimum Storage Capacity USAR Section 10 Revision 32P Page 10.3*33 The-HftiH-Elesigrt-mifliml:lm storagEH*lf*lsity-ekiiesel--ftlel-oiWs-OOsed-oo-Olle emergeFley-EIiesel-§eflefater{E9et,-94-eF-8r,el3 eFatifl§-ffi-the-leaes-statee-ir'l oil amHhe-ffiesekiFiveIT 72-} 16:3-:1-5:4

.2.2 in ::r-able 8.4 2 fer 14 -wel:l16-feE]l:Iire 70,595 gatlens-ef-ftlel-BiHiAe..fGF-OOnGiti0A-{2-}-GIl@-EDG-would.+equil:e.

=r&,496-gaHeAs. (RefereAee 10.3.13.2 Description 10.3.13.2.1 Unit 1 Four Design Class I fuel oil storage tanks supply fuel oil to the two emergency diesel generators (EDGs) D1/o2. Each tank is equipped with a transfer pump to pump fuel from the tank to the nominal capacity 500 gallon day tank of either EDG. For the two diesel driven cooling water pumps, fuel oil supply is from two Design Class I fuel oil storage tanks. Similarly each tank is provided with a transfer pump to transfer fuel to either diesel driven cooling water pump nominal capacity 500 gallon day tank. Two non-Design Class I fuel oil storage tanks supply fuel oil to the heating boiler booster pumps and/or the D3/D4 fuel oil day tanks supply pumps. A small 4,000 gallon non-Design Class I fuel oil storage tank supplies the day tank for the diesel fire pump. Interconnecting piping, valves, and instrumentation are shown in Figure 10.3-18. The fuel oil storage tanks are normally filled from the fuel oil transfer house through a filter. The safety related diesel generator fuel oil storage tanks are filled either from the normal fill connection or from an emergency safeguards fill connection.tThe diesel cooling water and diesel fire pump fuel oil storage tanks are also filled from either the normal fill connection or emergency safeguards fill connection.

An alternate fill connection is provided for each of the heating boiler oil storage tanks. Piping and valving is provided to transfer fuel oil from anyone fuel oil storage tank to any other fuel oil storage tank by using the proper valve lineup. A submersible pump associated with each fuel oil storage tank pumps the fuel oil to the transfer house where the oil is then routed to the desired fuel oil storage tank. The boundary between safety and non-safety related components is provided by normally closed isolation valves. fflo sJ3eeial-valvEHiflel:ij7.

10.3.13.1.2.1 Unit 1 The Unit 1 design minimum storage capacity of diesel fuel oil is based on one emergency diesel generator (EOG), 01 or 02, operating at the loads stated in Table 8.4-1 plus one diesel driven cooling water pump (OOCLP), 12 or 22, for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 1 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG and OOCLP in accordance with Technical Specifications.

The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained.

The onsite Unit 1 fuel oil supply is sufficient to operate one EOG and one DOCLP for longer than the time to replenish the onsite supply from outside sources. (Reference

72) 10.3.13.1.2.2 Unit 2 The Unit 2 design minimum storage capacity of diesel fuel oil is based on one EDG, 05 or 06, operating at the loads stated in Table 8.4-2 for 14 days to meet minimum flooding requirements discussed in USAR, Section 2. The Unit 2 design minimum fuel oil capacity is also capable of maintaining a 7 day fuel oil supply for each EOG in accordance with Technical Specifications.

The 14 day and 7 day are both licensing requirements will so the most limiting calculated fuel oil volume will always be maintained, The onsite Unit 2 fuel oil supply is sufficient to operate one EOG for longer than the time to replenish the onsite supply from outside sources, (Reference

73)

PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT 10.3.13.2.2 Unit 2 USAR Section 10 Revision 32P Page 10.3-34 The Unit 2 fuel oil system consists of a non-Design Class I fuel oil receiving tank, four Design Class I fuel oil storage tanks, four fuel oil transfer pumps, two fuel oil day tanks, one fuel oil recirculating pump, four fuel oil transfer recirculation filters, a receiving tank recirculating filter, and associated piping, valving and instrumentation.

The basic drawing of the Unit 2 fuel oil system is shown in Figure 10.3-19. The fuel oil receiving tank supplies fuel oil to the fuel oil storage tanks and the fuel oil recirculation pump. The four fuel oil storage tanks supply fuel oil to the fuel oil day tanks via the fuel oil transfer pumps. The two fuel oil day tanks each have a nominal capacity of 600 gallons. The fuel oil receiving tank is filled from a truck fill connection.

The fuel oil storage tanks are filled from the fuel oil receiving tank by gravity feed. Also, there is an emergency fuel oil storage tank fill connection located in the D5/D6 building.

The emergency fill connection can be utilized in the event of flooding which could render the receiving tank fill connection inaccessible.

The fuel oil day tanks can only be filled from the fuel oil storage tanks. Piping is provided to permit the transfer of fuel oil from one storage tank to another storage tank or to the receiving tank by using the appropriate valve lineup. The transfer can be accomplished by performing a tank recirculation lineup through the fuel oil transfer recirculation filters and pumping the tank contents through the recirculation header to another tank. The fuel oil storage tanks of each diesel generator building are located in a Seismic Category I reinforced concrete fuel oil storage vault. The fuel oil storage vaults are located below ground level. The vaults provide the required three-hour rated fire protection barrier and are designed to withstand the effects of tornado generated missiles, site flood and buoyancy force considerations.

The storage vaults are provided with leak detection sumps. If a sump fills with water and/or fuel oil, an alarm will activate on the main diesel generator local control panel. The base of the fuel oil receiving tank is located below ground level and the tank is in a concrete lined retention basin. The basin is sized to contain the tank volumetric contents, should a leak occur.

to..h ks I The fuel oil elay-taflk associated with one EDG can be filled directly from the fuel oil storage tanks of the other EDG by performing a valve lineup through the receiving tank return line. However, each fuel oil day tank is dedicated to its respective EDG and cannot supply fuel oil to the other EDG directly.

CD PRAIRIE ISLAND UPDA TED SAFETY ANAL YS/S REPORT 10.3.13.3 Performance Analysis 40.3.13.3.1 UniH USAR Section 10 Revision 32P Page 10.3*35 (19 (49,§G9-Aemffiat,4-7,BGG-avaUaele-galleR&-eaGR}-fer-tRe-atesekJFW.eR-GGGliRQ-wat$

taRks-will-meeHI=le-sffif8§8-eapaefty-reqt:lfr-ements.

1-th&43.3.2 Uflit-2 +l:\ere are fe1:lF-YHit4-Qesi§R-G1 ass I fuel-eU-sterage-taRks (32, 200-J:\Qm.i.RaI, 06afH>&ffiaRtlally-aligfleti-te-sI:ij3f3ly-eitReHiieseklay-taRk.--+AerefeFe;-aRy-oommRat.ioR-ef.

tI'lfee4aAks-wUl-meet tne-steraQ-e-Gaf)aGity and ffte-9iesel-Fuel Oil License Renewal-Fttel-eit I 6hemtstry-AgiAg-Management-Pffl§f8m-as-tieseriaeG-iA-Apf)6AGiX-h. 10.3.13.5 Instrumentation and Control 10.3.13.5.1 Unit 1 The fuel oil storage tanks are provided with level instrumentation to indicate tank liquid level at the control room (except for the heating boiler fuel oil storage tank) and filter house. High level will actuate an alarm in the control room except for the heating boiler fuel oil storage tank. Level switches are provided in the fuel oil day tanks for automatic makeup. ..-o . --/..

10.3.13.3.1 Unit 1 There are four Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) for the Unit 1 EDGs and two Design Class I fuel oil storage tanks (19,500 nominal, 17,500 available gallons each) for the diesel driven cooling water pumps. The six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any diesel storage tank. Therefore any combination of the tanks will meet the 14 day fuel oil supply requirements.

The 7 day fuel oil supply configuration requirements will be maintained in accordance with Technical Specifications.

The Unit 1 Design Class I fuel oil storage tanks can also be refilled from either of the two Design Class I heating boiler fuel oil storage tanks (35,000 nominal gallons each). 10.3.13.3.2 Unit 2 There are four Unit 2 Design Class I fuel oil storage tanks (32,800 nominal, 30,800 available gallons each). The four tanks are interconnected such that any storage tank can be manually aligned to supply any diesel storage tank. Therefore, any combination of the tanks will meet the storage capacity requirements for the 14 day fuel oil supply requirements.

The 7 day fuel oil supply configuration requirements will be maintained in accordance with Technical Specifications.

10.3.13.4 Testing and Inspection Fuel oil sampling is done in accordance with the Diesel Fuel Oil Testing Program for each Diesel Class I fuel oil storage tank and verified by analysis that the samples are within acceptable limits. In addition, the operability of the fuel oil transfer pumps and fuel flow paths from associated storage tanks to associated days tanks are verified in accordance with the Technical Specifications.

The interconnecting capability for the 14 day fuel oil supply requirement will be tested every refueling cycle for the associated Unit. The testing will verify flow path integrity for all the various storage tank to storage tank configurations.

The Diesel Fuel Oil Testing Program is credited as part of the License Renewal Fuel Oil Chemistry Aging Management Program as described in Appendix L.

PRAIRIE ISLAND UPDA TED SAFETY ANAL YSIS REPORT 10.3.13.5.2 Unit 2 USAR Section 10 Revision 32P Page 10.3-36 The fuel oil storage tanks are provided with level instrumentation, mounted on the diesel generator benchboard control panel and monitored by a computer.

Tank high and low levels annunciate in the diesel generator control room. A separate leak detection monitoring instrument system is provided for each pair of tanks serving a single diesel generator set. Level instrumentation is provided with each fuel oil day tank for automatic makeup.