ML18026B053

Waterford, Unit 3 - Issuance of Amendment No. 251 Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,(Cac No. MF9537; EPID L-2017-LLA

ML18026B053
Person / Time
Site:	Waterford
Issue date:	04/26/2018
From:	Pulvirenti A L Plant Licensing Branch IV
To:	Entergy Operations
Pulvirenti A L, NRR/DORL/LPLIV
References
CAC MF9537, EPID L-2017-LLA-0205
Download: ML18026B053 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Site Vice President Entergy Operations, Inc. Waterford Steam Electric

Station, Unit 3 17265 River Road Killona, LA 70057-3093 April 26, 2018

SUBJECT:

WATERFORD STEAM ELECTRIC

STATION, UNIT 3-ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" (CAC NO. MF9537; EPID L-2017-LLA-0205)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 251 to Facility Operating License No. NPF-38 for the Waterford Steam Electric

Station, Unit 3. This amendment changes the technical specifications (TSs) in response to your application dated March 28, 2017, as supplemented by letter dated February 28, 2018. The amendment revises TS 3.8.1.3, "Diesel Fuel Oil," by relocating the current stored diesel fuel oil numerical volume specifications from the TS to the TS Bases. In addition, the proposed amendment revises TS 3.8.1.1 and TS 3.8.1.2, "AC [Alternating Current]

Sources Operating" and "AC Sources Shutdown,"

respectively, to relocate the specific numerical value for feed tank fuel oil volume to the TS Bases and replace it with the feed tank operating time requirement.

The proposed changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control." A copy of the related Safety Evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-382

Enclosures:

1. Amendment No. 251 to NPF-38 2. Safety Evaluation cc: Listserv Sincerely, April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC. DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC

STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 251 License No. NPF-38 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Entergy Operations, Inc. (EOI), dated March 28, 2017, as supplemented by letter dated February 28, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Facility Operating License No. NPF-38 is hereby amended to read as follows:

2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 251, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license.

EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

Attachment:

Changes to the Facility Operating License No. NPF-38 and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

April 26, 2018 ATTACHMENT TO LICENSE AMENDMENT NO. 251 TO FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC

STATION, UNIT 3 DOCKET NO. 50-382 Replace the following pages of the Facility Operating License No. NPF-38 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Facility Operating License REMOVE INSERT Technical Specifications REMOVE 3/4 8-1 3/4 8-8 3/4 8-8a INSERT 3/4 8-1 3/4 8-8 3/4 8-8a or indirectly any control over (i) the facility, (ii) power or energy produced by the facility, or (iii) the licensees of the facility.

Further, any rights acquired under this authorization may be exercised only in compliance with and subject to the requirements and restrictions of this operating

license, the Atomic Energy Act of 1954, as amended, and the NRC's regulations.

For purposes of this condition, the limitations of 10 CFR 50.81, as now in effect and as they may be subsequently

amended, are fully applicable to the equity investors and any successors in interest to the equity investors, as long as the license for the facility remains in effect. (b) Entergy Louisiana, LLC (or its designee) to notify the NRC in writing prior to any change in (i) the terms or conditions of any lease agreements executed as part of the above authorized financial transactions, (ii) any facility operating agreement involving a licensee that is in effect now or will be in effect in the future, or (iii) the existing property insurance coverages for the facility, that would materially alter the representations and conditions, set forth in the staffs Safety Evaluation enclosed to the NRC letter dated September 18, 1989. In addition, Entergy Louisiana, LLC or its designee is required to notify the NRC of any action by equity investors or successors in interest to Entergy Louisiana, LLC that may have an effect on the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: 1. Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3716 megawatts thermal {100% power) in accordance with the conditions specified herein. 2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 251, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license.

EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. AMENDMENT NO. 251 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1 E distribution system, and b. Two separate and independent diesel generators, each with: 1. Diesel oil feed tanks containing a minimum one hour supply of fuel, and 2. A separate diesel generator fuel oil storage tank, and 3. A separate fuel transfer pump. APPLICABILITY:

MODES 1, 2, 3, and 4. ACTION: a. With one offsite circuit of 3.8.1.1a inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1 a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

Restore the offsite A.C. circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. b. With one diesel generator of 3.8.1.1b inoperable:

(1) Demonstrate the OPERABILITY of the remaining A.C. circuits by performing Surveillance Requirements 4.8.1.1.1a (separately for each offsite A.C. circuit) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE diesel generator (unless it has been successfully tested in the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) by performing Surveillance Requirement 4.8.1.1.2a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the absence of any potential common mode failure for the remaining diesel generator is demonstrated.

(2) Restore the diesel generator to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, unless the following condition exists: WATERFORD*

UNIT 3 3/4 8-1 AMENDMENT NO. 23,92,126,166,199,216, 251 ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.6.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1 E distribution system, and b. One diesel generator with: 1. A diesel oil feed tank containing a minimum one hour supply of fuel, and 2. The diesel fuel oil storage tanks, and 3. A fuel transfer pump. APPLICABILITY:

MODES 5 and 6. ACTION: With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE AL TERA TIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or boron concentration, or load movements with or over irradiated fuel. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the top of the fuel seated in the reactor pressure vessel, immediately initiate corrective action to restore the required sources to OPERABLE status. SURVEILLANCE REQUIREMENTS 4.6.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.6.1.1.1 and 4.6.1.1.2 (except for Surveillance Requirement 4.6.1.1.2a.5.)

WATERFORD

-UNIT 3 3/4 6-6 AMENDMENT NO. 92, 148, 185, 1Qe,21a,

Ž* 251 ELECTRICAL POWER SYSTEMS DIESEL FUEL OIL LIMITING CQt::I.DJTION FOR OPERATION 3.8.1.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG). APPLICABILITY:

When associated DG is required to be OPERABLE.

ACTION: (Note: Separate ACTION entry is allowed for each DG.) a. With the fuel oil storage tank volume less than a 7 day supply and greater than a 6 day supply, restore fuel oil storage tank volume to greater than or equal to a 7 day supply within 5 days (provided replacement fuel oil is onsite within the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). b. With one or more DGs with stored fuel oil total particulates not within limits, restore fuel oil total particulates to within limits within 7 days. c. With one or more DGs with new fuel oil properties not within limits, restore stored fuel oil properties to within limits within 30 days. d. If any of the above ACTIONS cannot be met, or if the diesel fuel oil is not within limits for reasons other than the above ACTIONS, immediately declare the associated DG(s) inoperable.

syRVEILLANCE REQUIREMENTS 4.8.1.3.1 In accordance with the Surveillance Frequency Control Program verify each fuel oil storage tank volume. 4.8.1.3.2 Verfy fuel oil properties of new or stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

WATERFORD

-UN IT 3 3/4 8-8a AMENDMENT NO. ~46.--249, 251 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 251 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC. WATERFORD STEAM ELECTRIC

STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By letter dated March 28, 2017 (Reference 1 ), as supplemented by letter dated February 28, 2018 (Reference 2), Entergy Operations Inc. (Entergy, the licensee) submitted a license amendment request (LAR) requesting changes to the technical specifications (TSs) for the Waterford Steam Electric

Station, Unit 3 (Waterford 3). One of the proposed changes revises TS Limiting Condition for Operation (LCO) 3.8.1.3, "Diesel Fuel Oil," by removing the current stored diesel fuel oil numerical volume requirements from the TS and replacing them with the diesel generator's (DG) operating time requirements consistent with Technical Specifications Task Force (TSTF) Standard Technical Specifications Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (Reference 3). The availability of this TS improvement was published in the Federal Register on May 26, 2010 (75 FR 29588). Additionally, Entergy proposed a similar change to the Waterford 3 TS LCOs 3.8.1.1 and 3.8.1.2, "AC [Alternating Current]

Sources Operating" and "AC Sources Shutdown,"

respectively, to remove the specific numerical volume value for the feed tank oil volume and replace them with a feed tank time requirement.

The supplemental letter dated February 28, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally

noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 5, 2017 (82 FR 31093). Any change to the numerical volume requirements in the TSs requires prior approval by the NRC. A licensee may need to modify diesel fuel oil numerical volume in order to take into account changes to the energy content (British Thermal Units (BTU)/gallon))

of available fuels in the market. Fluctuations in energy content could be caused by a variety of factors, including changes to regulatory requirements.

By adopting TSTF-501, Revision 1, the numerical volume requirements for stored diesel fuel oil would be removed from the TSs and duration based diesel operating time requirements would be added. Proposed revisions to the TS Bases are also included in Attachment 4 of the LAR dated March 28, 2017. If approved, the numerical volume requirements for stored diesel fuel oil could be modified under licensee control under Enclosure 2 the provisions of Title 10 of the Code of Federal Regulations

( 10 CFR) Section 50.59, "Changes, tests, and experiments,"

and, therefore, would not require prior NRC approval.

Changes to the affected TS Bases pages would be made by the licensee in accordance with TS 6.16, "Technical Specifications Bases Control Program."

1.1 Licensee-Identified Differences with TSTF-501, Revision 1 The licensee identified two deviations from TSTF-501, Revision 1, on page 2 of 5 of Attachment 1 to the LAR (Reference 1 ). First, the licensee identified that the proposal has no changes to the lube oil inventory because the Waterford 3 TSs do not include the requirements for lube oil inventory.

Secondly, the licensee identified that the proposed revision to TS LCOs 3.8.1.1 and 3.8.1.2 follows a similar approach to the TS LCO 3.8.1.3 change. The revision to TS LCOs 3.8.1.1 and 3.8.1.2 replaces each specific feed tank numerical volume requirement with the requirement to maintain a minimum 1-hour supply of fuel oil. The specific numerical volume would be moved to the TS Bases. 2.0 2.1 REGULATORY EVALUATION System Description The Waterford 3 DG Fuel Oil Storage and Transfer System provides adequate storage of diesel fuel oil and supplies it to the two emergency DGs. Diesel fuel oil storage for each diesel engine is separate and independent.

Each diesel fuel oil storage and transfer train consists of a diesel fuel oil storage tank (FOST), transfer pump, diesel oil feed tank, interconnecting piping, valves, and instrumentation and controls.

Train A normally serves Emergency Diesel Engine A, and Train B normally serves Emergency Diesel Engine B. The paths may be connected via a crossover pipe if needed. All necessary electrical power for the operation of each train is supplied from the associated emergency DG bus. The capacity of each FOST is sufficient for 7-days' operation of one emergency DG. The diesel oil transfer pumps, one located in each storage tank room, take suction from the tanks and discharge into the diesel oil feed tanks. Each diesel oil feed tank has a capacity sufficient for a period of approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with the associated emergency DG unit operating at full-load.

An automatic makeup function ensures that the feed tank contains a minimum volume of fuel in the tank, which is currently 339 gallons per TS LCO 3.8.1.1.

Each fuel oil transfer pump is started automatically during normal operation of the associated DG to makeup fuel oil to the feed tank from its FOST. After filling the feed tank, the transfer pump is stopped automatically when oil level is high enough to actuate the high level switch in the feed tank. 2.2 Description of the Proposed Changes The proposed changes revise TS 3/4.8.1, "AC Sources,"

including TS LCOs 3.8.1.1, 3.8.1.2, and 3.8.1.3 by replacing the stored diesel fuel oil volume-based inventory numerical requirements with duration-based requirements so that the volume necessary to meet the TS duration requirements may be modified under licensee control.

The specific TS changes are described in the following sections.

2.2.1 Proposed Change to TS LCO 3.8.1.1, Part b.1 and LCO 3.8.1.2, Part b.1 Part b.1 of TS LCO 3.8.1.1 is applicable during operating Modes 1 through 4 and requires two separate and independent DGs, each with diesel oil feed tanks containing a minimum oil volume of 339 gallons.

Part b.1 of TS LCO 3.8.1.2 is applicable during shutdown Modes 5 and 6 and requires one DG, with a diesel oil feed tank containing a minimum oil volume of 339 gallons.

On page 2 of 5 of Attachment 1 of the LAR, the licensee states that the proposed revision to TS 3.8.1.1 and TS 3.8.1.2 replaces the minimum specific feed tank numerical volume requirement with the [duration-based]

requirement to maintain a minimum one hour supply of fuel oil. 2.2.2 Proposed Change to the TS LCO 3.8.1.3 Actions Action a of TS LCO 3.8.1.3 applies when the fuel oil storage tank numerical volume is less than 39,300 gallons and greater than 37,000 gallons, which correspond to a 7-day supply and 6-day supply, respectively.

Fuel oil storage tank volume must be restored to 39,300 gallons within 5 days (provided replacement fuel is onsite within the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). The proposed revision would remove the numerical volumetric requirements from the TS and replace those values with comparable duration-based requirements.

The TS would be modified so that Action a of TS LCO 3.8.1.3 applies when the stored diesel fuel oil inventory is less than a 7-day supply but greater than a 6-day supply for one or more DGs, with the provision of restoring volume to a 7-day supply within 5 days (provided replacement fuel is onsite within the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). The supplemental letter dated February 28, 2018 (Reference 2), corrected format and numbering errors in the licensee's markup of page 3/4 8-8, and did not substantively change the requested revisions.

2.3 Regulatory Requirements and Guidance Used in the Evaluation of the Changes 2.3.1 Requirements The regulation, 10 CFR 50.36, Technical specifications,"

provides the regulatory requirements for the content required in the TSs. The TSs set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public. As stated in 10 CFR 50.36, the TSs include LCOs and surveillance requirements (SRs) to assure that the LCOs are met. Section 50.36(c)(2)(i) of 10 CFR states, in part, that TSs will include LCOs, which are "the lowest functional capability or performance levels of equipment required for safe operation of the facility."

Section 50.36(c)(2)(i) further states, in part, that "[w]hen a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The regulation, 10 CFR 50.36( c)(2)(ii),

states that "a technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria."

Criterion 3 of 10 CFR 50.36( c)(2)(ii) is "[a] structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."

2.3.2 Guidance Regulatory Guide (RG) 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators" (Reference 4), endorses American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel-Generators."

It provides guidance that describes methods acceptable to the NRC staff for complying with the Commission's regulations regarding fuel oil systems for standby DGs. The RG 1.137, Section C.1.c, sets forth two methods for calculation of fuel oil storage requirements as described in Section 5.4 of ANSI N195-1976, "Calculation of Fuel Oil Storage Requirements":

1) calculations based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity, and 2) calculations based on the time-dependent loads of the diesel generator.

NUREG-1432, Revision 4, "Standard Technical Specifications-Combustion Engineering Plants" (Reference 5), provides example TS LCOs and acceptable remedial actions that meet 10 CFR 50.36(c)(2)(i) requirements for a standard plant design. NRC Approved TSTF Traveler TSTF-501, Revision 1, provides an acceptable method of modifying the stored fuel oil requirements contained in the standard technical specifications.

3.0 TECHNICAL EVALUATION The licensee reviewed the model safety evaluation (SE), which was published in the Federal Register on May 26, 2010 (75 FR 29588), as part of the consolidated line item improvement process notice of availability.

The licensee concluded, as stated on page 2 of 5 of Attachment 1 of the LAR, that the justifications presented in the model SE are applicable to Waterford 3, and therefore justifies this amendment.

The licensee states that each DG is provided with a fuel oil capacity sufficient to operate that diesel for a period of 7 days. This onsite fuel oil capacity is sufficient to operate the DGs long enough to place the unit in a shutdown condition and to bring in replenishment fuel from an offsite location.

The standby AC power sources (i.e., the DGs), are a part of the primary success path and function or actuate to mitigate a design-basis accident or transient that either assumes the failure of, or presents a challenge to the integrity of a fission product barrier (Criterion 3 of 10 CFR 50.36(c)(2)(ii)).

Restrictions on the diesel fuel oil supplies are retained in the TS to satisfy 10 CFR 50.36( c )(2)(i),

since they support the operation of the standby AC power sources.

One variable used in stored diesel fuel oil calculation methods is the fuel consumption rate. The property of diesel fuel oil having the most significant effect on the fuel consumption rate is the energy content (heating value) of the fuel. There are standards which correlate the energy content to the fuel's American Petroleum Institute (API) gravity or absolute specific gravity.

Typically, plants calculate their required fuel storage values assuming the most limiting API gravity or absolute specific

gravity, and therefore, the most limiting fuel energy content.

As long as the fuel oil placed in the storage tank is within the API gravity range or absolute specific gravity range specified by the licensee, the calculations of fuel consumption and required stored volume remain valid. Currently, SR 4.8.1.3.2 requires new fuel to be tested in order to verify that the new fuel API gravity or absolute specific gravity is within the range assumed in the diesel fuel oil consumption calculations through implementation of the Waterford 3 TS 6.5.13, "Diesel Fuel Oil Testing Program."

The NRC previously approved the Waterford 3 fuel supply calculational methodology and deviations from the methods described in ANSI N195-1976 in Amendment No. 157 to the Waterford 3 license.

Amendment No. 157 was issued by letter dated February 15, 2000 (Reference 6). During review of the current LAR, the NRC staff determined that the Waterford 3 TSs contain no requirements for lube oil inventory; therefore, no changes to lube oil inventory are requested.

This deviation from the approved TSTF Traveler is acceptable.

3.1 Proposed Change to TS 3/4.8.1, "AC Sources,"

Requirements The proposed changes would revise Waterford 3 TS 3/4.8.1 by removing the current stored diesel fuel oil numerical volume requirements from the TS and replacing them with the associated diesel operating time. The fuel oil volumes necessary to support a duration-based diesel operating time would then be modified under licensee control pursuant to 10 CFR 50.59. In order to meet the storage requirements for diesel fuel oil for a.DG, TS LCOs 3.8.1.1.b.1 and 3.8.1.2.b.1.,

and Action a of TS LCO 3.8.1.3 currently contain numerical volume requirements.

The volume requirements for LCOs 3.8.1.1 and 3.8.1.2 are based on a 1-hour supply of fuel oil for each DG as measured by volume, in gallons, as calculated by the method described in ANSI N195-1976, with deviations, as approved in Amendment No. 157 (Reference 6), and contained in Section 9.5.4 of the Updated Final Analysis Safety Report (UFSAR).

The volume requirement for Action a. of TS 3.8.1.3 is based on a 7-day and 6-day supply for each emergency DG as measured by volume, in gallons, also as calculated as described in Amendment No. 157. 3.1.2 Proposed Changes to TS LCOs 3.8.1.1 and 3.8.1.2 Currently, Part b.1 of TS LCOs 3.8.1.1 and 3.8.1.2 require the licensee to verify OPERABILITY of the DG(s) by ensuring that the diesel oil feed tanks contain a minimum volume of 339 gallons of fuel. The licensee proposes to revise the LCOs to reflect that a 1-hour duration-based supply, rather than a specified numerical volume, be available for each DG. This 1-hour supply is calculated by the approved method described in ANSl-195-1976, with deviations, as approved in License Amendment No. 157 (Reference

6) and contained in Section 9.5.4 of the UFSAR. The use of this methodology will ensure that the 1-hour supply of feed tank oil will continue to be calculated in accordance with NRC-approved methods.

As a result, LCOs 3.8.1.1 and 3.8.2.1 would require the licensee to verify that the diesel oil feed tanks contain a minimum 1-hour supply of fuel for each DG. In a prior LAR for Waterford 3 dated May 8, 1991 (Reference 7), the licensee stated that "The minimum volume of fuel oil in the feed tank is based on the amount necessary to operate the diesel generator for sixty minutes at full load plus a margin of ten percent."

This ten-percent margin is included in the calculation as described above. Feed tank fuel oil level is maintained at a minimum 1-hour amount of fuel by automatic operation of the diesel fuel oil transfer system as described in UFSAR Section 9.5.4 and in SE Section 2, above. The licensee states, on page 2 of 5 of Attachment 1 to the LAR that this proposed change "merely removes the current numerical volume requirement for the feed tank and replaces it with the one-hour supply."

The NRC staff reviewed this statement and determined that the one-hour supply, which is calculated as described above, is comparable to the current volume requirement.

No other revision to these LCOs are proposed.

Therefore, this variation to the approved TSTF traveler is consistent with the approved traveler.

Therefore, the NRC staff concludes that replacing the feed tank volumes with the 1-hour duration requirement in TS LCOs 3.8.1.1 and 3.8.1.2 will continue to specify the lowest functional capability or performance level of feed tank fuel oil for the DGs and that compliance with them will assure the continued safe operation of the facility in accordance with 10 CFR 50.36(c)(2).

3.1.3 Proposed Change to Action a of TS LCO 3.8.1.3 Currently, TS LCO 3.8.1.3, Action a, applies when the FOST volume is less than 39,300 gallons and greater than 37,000 gallons.

If this condition

applies, the licensee must restore the FOST volume to greater than or equal to a 39,300 gallons within 5 days (provided replacement fuel oil is onsite within the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). The current TS Bases state that the numerical volume requirements in Action a of TS LCO 3.8.1.3 are based on volumes less than a 7-day supply and at least a 6-day supply. The amendment would remove the volumetric requirements from the TS and would modify Action a of TS LCO 3.8.1.3 to add a duration-based requirement so that with the fuel oil storage tank volume less than a 7-day supply, and greater than a 6-day supply for any DG, the licensee would have to restore the fuel oil storage tank volume to greater than a 7 day supply within 5 days (provided replacement fuel oil is onsite within the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). No other parts of Action a of TS LCO 3.8.1.3 are proposed to be modified in the application.

The NRC staff previously reviewed and approved the licensee's methodology to calculate the stored diesel fuel oil numerical volumes in Amendment No. 157 (Reference 6). The staff concludes that use of the approved methodology will ensure that the associated supply requirements of stored diesel fuel oil for each DG will be met. Because ( 1) the proposed change will ensure that an adequate supply of fuel oil is available for the DGs to perform, if needed, and (2) the proposed change to Action a of TS LCO 3.8.1.3 is consistent with the approved TSTF traveler and provides an acceptable remedial action for when the stored diesel fuel oil is determined not to be within the 7-day limit for each required DG, TS LCO 3.8.1.3, with the revised remedial Action a, continues to meet 10 CFR 50.36(c)(2).

Therefore, the proposed change to LCO 3.8.1.3 is acceptable.

3.2 TS Bases Changes Although TS bases changes are not subject to NRC approval, the NRC staff noted that the minimum quantity of fuel oil in the feed tanks was inserted into the licensee's TS bases as shown in the markups provided in Attachment 4 to the LAR. Changes to the affected TS Bases pages will be made by the licensee in accordance with the TS 6.16. NRC staff confirmed that the calculations are consistent with the methodology described in ANSI N195-1976 with exceptions, as stated in Amendment No. 157 (Reference 6). 3.3 Technical Conclusion The proposed TS changes would continue to require that the appropriate volume of stored diesel fuel oil be maintained.

The proposed changes to TS LCOs 3.8.1.1 and 3.8.1.2 continue to provide assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility.

Action a of TS LCO 3.8.1.3 continues to provide acceptable remedial actions to follow until LCO 3.8.1.3 can be met. The NRC staff concludes that replacement of the TS numerical value volume requirements does not change the current plant configuration, the current volume requirements, or the current basis for the fuel oil volume requirements.

As a result, the LCOs, as revised, will continue meet 10 CFR 50.36(c)(2) and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment on January 25, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released

offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on July 5, 2017 (82 FR 31093). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

6.0 CONCLUSION

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

7.0 REFERENCES

1. Chisum, M. R., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"'

dated March 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 17087A551).

2. Dinelli, J.C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"

dated February 28, 2018 (ADAMS Accession No. ML 180598223).

3. Technical Specifications Task Force, letter to U.S. Nuclear Regulatory Commission, "Transmittal of TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"'

(ADAMS Accession No. ML090510686).

4. U.S. Nuclear Regulatory Commission, "Fuel-Oil Systems for Standby Diesel Generators,"

Regulatory Guide 1.137, Revision 1, October 1979 (ADAMS Accession No. ML003740180).

5. U.S. Nuclear Regulatory Commission, "Standard Technical Specifications

-Combustion Engineering Plants,"

NUREG-1432, Revision 4, Volume 1, Specifications, April 2012 (ADAMS Accession No. ML 12102A165).

6. Kalyanam, N., U.S. Nuclear Regulatory Commission, letter to Mr. Charles M. Dugger, Entergy Operations, Inc., "Waterford Steam Electric

Station, Unit 3 -Issuance of Amendment No. 157 Re: Amendment for a Previously Unreviewed Safety Question Regarding Emergency Diesel Generator Fuel Oil Storage and Transfer System Design Basis," dated February 15, 2000 (ADAMS Accession No. ML003685002).

7. Barkhurst, R. P., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Waterford 3 SES, Docket No. 50-382, License No. NPF-38, Technical Specification Change Request NPF-38-114,"

dated May 8, 1991 (ADAMS Accession No. ML 18053A697).

Principal Contributor:

Peter J. Snyder Da~: April 26, 2018

SUBJECT:

WATERFORD STEAM ELECTRIC

STATION, UNIT 3-ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, "RELOCATE STORED FUEL OIL AND LUBE OIL VOLUME VALUES TO LICENSEE CONTROL" (CAC NO. MF9537; EPID L-2017-LLA-0205)

DATED APRIL 26, 2018 DISTRIBUTION:

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