LR-N18-0013, License Amendment Request (LAR) to Amend the Hope Creek Technical Specifications (TS) to Revise Action for Inoperable Emergency Diesel Generator (EDG) a or B

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License Amendment Request (LAR) to Amend the Hope Creek Technical Specifications (TS) to Revise Action for Inoperable Emergency Diesel Generator (EDG) a or B
ML18087A095
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 03/28/2018
From: Carr E
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H18-01, LR-N18-0013
Download: ML18087A095 (26)
v • d • e


Text

PSEG Nuclear LLC P. 0. Box 236, Hancocks Bridge, New Jersey 08038*0236 MAR 28 2018 0PSEG NuclearLLC 10 CFR 50.90 LR-N18-0013 LAR H18-01 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

License Amendment Request (LAR) to Amend the Hope Creek Technical Specifications (TS) to Revise Action for Inoperable Emergency Diesel Generator (EDG) A or B In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Hope Creek Generating Station (Hope Creek).

The proposed amendment revises TS 3/4.8.1, "AC Sources- Operating"; specifically ACTION b concerning one inoperable Emergency Diesel Generator (EDG). The proposed change removes the Salem Unit 3 gas turbine generator (GTG) and replaces it with portable diesel generators (DG). PSEG concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

The Enclosure provides a description and assessment of the proposed change. Attachment 1 provides the existing TS pages marked to show the proposed change. Attachment 2 provides existing TS Bases pages marked to show the proposed change for information only. provides the required actions and conservative estimated completion times. provides drawings and a site photo.

PSEG requests approval of this LAR in accordance with standard NRC approval process and schedule. Once approved, the amendment will be implemented within 60 days from the date of issuance.

There are no regulatory commitments contained in this letter.

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

LR-N18-0013 10 CFR 50.90 Page 2 If there are any questions or if additional information is needed, please contact Ms. Tanya Timberman at 856-339-1426.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 3 /p 7./2'g'

( Date)

Respectfully, Eric S. Carr Site Vice President Hope Creek Generating Station

Enclosure:

Evaluation of the Proposed Change : Technical Specification Page Markups : Bases Page Markups : Required Actions and Conservative Estimated Times to Complete : Drawings and Site Photo cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Hope Creek Commitment Tracking Coordinator

LR-N18-0013 LAR H18-01 Enclosure Evaluation of the Proposed Change

Subject:

License Amendment Request to Amend the Hope Creek Technical Specifications (TS) to Revise Action for Inoperable Emergency Diesel Generator (EDG) A or B Table of Contents 1.0

SUMMARY

DESCRIPTION .............................................................................................1 2.0 DETAILED DESCRIPTION..............................................................................................1 2.1 System Design and Operation .................................................................................1 2.2 Current Technical Specifications Requirements.......................................................1 2.3 Reason for the Proposed Change............................................................................2 2.4 Description of the Proposed Change .......................................................................2

3.0 TECHNICAL EVALUATION

.............................................................................................2

4.0 REGULATORY EVALUATION

........................................................................................9 4.1 Applicable Regulatory Requirements/Criteria...........................................................9 4.2 Precedent ..............................................................................................................10 4.3 No Significant Hazards Consideration Analysis .....................................................10 4.4 Conclusions ...........................................................................................................12

5.0 ENVIRONMENTAL CONSIDERATION

.........................................................................12

6.0 REFERENCES

..............................................................................................................12 ATTACHMENTS:

1. Technical Specification Page Markups
2. Bases Page Markups
3. Required Action and Conservative Estimated Times to Complete
4. Drawings and Site Photo

LR-N18-0013 LAR H18-01 Enclosure 1.0

SUMMARY

DESCRIPTION The proposed change revises TS 3/4.8.1, "AC Sources - Operating"; specifically Action b.2.b concerning one inoperable Emergency Diesel Generator (EDG). The proposed change removes the Salem Unit 3 gas turbine generator (GTG) and replaces it with portable diesel generators (DG).

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Hope Creek Class 1E power system supplies all Class 1E loads that are needed for safe and orderly shutdown of the reactor, maintaining the plant in a safe shutdown condition, and mitigating the consequences of an accident. The Class 1E AC power system distributes power at 4.16 kV, 480 V, and 208/120 V. The Class 1E AC power system is divided into four independent power supply channels, A, B, C, and D. Each of these four channels supplies loads in its own load group. Each Class 1E 4.16-kV bus is provided with a normal and an alternate offsite power supply feeder and one EDG feeder. All the Class 1E loads are assigned to these channels so that any combination of three out of four load groups has the capability to supply the minimum required safety loads to safely shut down the unit and mitigate the consequences of an accident. The EDGs are designed to start and attain rated voltage and frequency within 10 seconds of the receipt of the starting signal. As the EDG reaches rated voltage and frequency, logic is provided to generate a permissive interlock for the closing of the EDG circuit breaker.

Each EDG provides power to the 1E loads (and selected non-1E loads) in the event of a loss of offsite power for its associated divisional 4.16 kV switchgears. EDG support systems are provided as required to maintain the diesel generator in a state of standby readiness. The engine is rated at 6148 BHP (4430kW net) at 514 rpm (continuous). Calculations demonstrate that the maximum loading of any EDG does not exceed its continuous rating when operating at rated frequency. These EDGs automatically start under loss of coolant accident (LOCA) and/or loss of power (LOP) conditions. The generator, exciter, and voltage regulator are designed to permit the EDG to start the motors and accept loads in the time requirements and sequence as documented in the Updated Final Safety Evaluation Report (UFSAR).

The Salem Unit 3 gas turbine generator consists of a TWIN PAC Gas Turbine installation. It provides a source of emergency power in the event of a loss of power (LOP), re-energizes Salem's Group Buses, and includes its own fuel oil supply through the use of one of the combustion turbines. It acts as an independent generating module with its only dependency being the availability of fuel. The Gas Turbine Generator was also previously used as a peaking unit, providing power to the 13kV Ring Bus during peak periods of demand.

The portable diesel generators will be able to supply power as a replacement for the existing A or B EDGs.

2.2 Current Technical Specification Requirements The current AC Sources - Operating TS provides an action for the inoperable A or B diesel generator, to restore the inoperable 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 to 1

LR-N18-0013 LAR H18-01 Enclosure verify the Salem Unit 3 gas turbine generator (GTG) is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and to restore the inoperable diesel generator to operable status within 14 days. Otherwise, TS require the unit to be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.3 Reason for the Proposed Change PSEG plans to retire the Salem Unit 3 gas turbine generator. The plans to retire are due to maintenance cost associated with maintaining the system operational. Although Salem Unit 3 was assumed to be unavailable in the development of risk metrics for the current 14 day AOT, Hope Creek TS 3.8.1.1 Action b.2.b requires the GTG to be available during the extended AOT for the A or B EDGs. Therefore, the Hope Creek TS need to be revised to remove the GTG as an alternate source of power and replace it with a supplemental power source.

2.4 Description of the Proposed Change The proposed change removes the Salem Unit 3 gas turbine generator (GTG) and replaces it with portable diesel generators (DG).

TS 3.8.1.1, Action b.2.b Verify the Salem Unit 3 gas turbine generator (GTG) supplemental power source is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and restore the inoperable diesel generator to OPERABLE status within 14 days.

Note:

  1. After the initial verification period, the GTG supplemental power source may be unavailable for a single period of up to 24-hours and the once-per 12-hour requirement to verify that the GTG supplemental power source is available may be suspended during this period.

3.0 TECHNICAL EVALUATION

Under the current Technical Specifications, if either the A or B Emergency Diesel Generator (EDG) is inoperable, the EDG must be returned to operable status within 14 days. This time period is predicated on several compensatory actions, chiefly among them the availability of the Salem Unit 3 gas turbine generator as a supplemental source of power for the bus with the inoperable diesel. This TS change was approved in Amendment 188 (ML110610501). PSEG plans to retire the Salem gas turbine generator and to replace it as a supplemental power source with portable diesel generators for the purposes of maintaining the 14 day allowed outage time (AOT). The basis for the 14 day AOT duration is unchanged by use of the portable diesel generators.

The Technical Evaluation will discuss the overall change to the supplemental power source. It will define the requirements of NUREG-0800, Branch Technical Position 8-8 (BTP 8-8) and how Hope Creek meets the intent of these requirements.

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LR-N18-0013 LAR H18-01 Enclosure 3.1 Proposed Design PSEG plans to retire the Salem Unit 3 gas turbine generator. New supplemental portable diesel generators will be stored onsite along with prefabricated cables and connectors. A single receptacle panel and non-class 1E breakers will be permanently added to Hope Creek for use with the supplemental portable diesel generators in order to supply power to a Class 1E bus in the event of a loss of offsite power concurrent with a single failure during plant operation in the extended AOT.

The proposed supplemental power source consists of portable diesel generators with a combined minimum capacity of 4500kW. These will be procured as commercial grade non-safety related units.

The portable diesel generators will be capable of automatically synchronizing in parallel to feed the required load. This configuration allows the combined portable diesel generators to operate as a single unit.

These portable diesel generators can supply power to either non-safety related Bus 10A101 or 10A102 using a new breaker installed in a spare cubicle of each bus. These buses can be configured using existing breakers and interconnections to feed either safety related 4.16kV bus 10A401 or 10A402 (A or B EDG switchgears). The new breakers will be permanently connected to a dedicated receptacle panel installed inside the Turbine Building rollup door. The receptacle panel will be installed such that buses 10A101 or 10A102 cannot be cross connected, thus maintaining independence of the offsite sources and preventing paralleling of those sources. This will be accomplished by installing a key locked breaker control hand switch for each breaker that allows only one breaker to be closed at a time.

The 4500kW capacity of the portable diesel generators exceeds the 4430kW continuous rating of the existing EDGs. The EDG rating exceeds the load demand for a Loss of Offsite Power (LOOP). The diesels will be equipped with voltage regulators and speed governors that maintain the voltage and frequency within the same limits as those applicable to the A and B EDGs. The portable diesel generators will either be tested to accept the bounding EDG load configuration while maintaining the same steady state voltage and frequency limits that are imposed on the EDGs or be shown by calculation to be capable of performing within these limits. These portable diesel generators are sufficiently sized and have the capability for safe and orderly shutdown of the reactor, maintaining the plant in a safe shutdown condition and mitigating the consequences of LOOP.

Each portable diesel generator will be stored onsite within the protected area in a weather proof container on a trailer. The portable diesel generators will be provided with a 480V power source to maintain required heating and basic operation per the vendor.

The new breakers designated 10A10104 or 10A10204 will be provided with ground fault protection. Existing breaker 10A10101 or 10A10210 will be backfed when using the portable diesel generators. The overcurrent devices for these breakers are set at 1200A instantaneous, which exceeds the 780.67 full load amps (FLA) rating of the portable diesel generators and therefore the breakers will not trip. The portable diesel generators will also be provided with their own ground fault protection.

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LR-N18-0013 LAR H18-01 Enclosure The portable diesel generator components will be physically separated from the Class 1E engineered safety feature (ESF) components including the EDGs and from the offsite power sources for the unit. There are no direct connections to the Class 1E buses nor are the transfer schemes between offsite sources and the EDGs affected by the proposed connections. There is a single receptacle panel that is connected to the non Class 1E buses. The receptacle panel will be de-energized unless required to power a vital bus and the feed breakers will be open and locked via a keyed hand switch so there are no failure modes introduced whereby the two electrical feeds to the Class 1E buses can be cross connected or 13.8/4.16kV transformers can be paralleled during OPERATIONAL CONDITIONS 1, 2 and 3.

See Attachment 4 for drawings and a site photo.

Each supplemental portable diesel generator will be equipped with a fuel tank with the capacity to run for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at rated load. The portable diesel generators are configured to be refueled while running. Diesel fuel from the million gallon fuel storage tank located onsite, or other source supply will be delivered in a truck to refuel the diesels, if required.

Operator rounds will ensure the availability of the portable diesel generators and provide an additional level of overall monitoring.

3.2 NUREG-0800, Branch Technical Position 8-8 Requirements NUREG-0800, Branch Technical Position 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," specifically discusses the defense-in-depth aspects for onsite power sources from a deterministic perspective for proposed AOT extensions. No changes are being proposed to the current AOTs for the A and B EDGs. The following is a list of critical BTP 8-8 requirements and how Hope Creek meets the intent of these requirements.

a) The supplemental source must have the capacity to bring a unit to safe shutdown (cold shutdown) in case of a loss of offsite power (LOOP) concurrent with a single failure during plant operation (Mode 1).

The existing calculation E-9(Q), Standby Class 1E Diesel Generator Sizing, worst case loading for all EDGs is as follows.

EDG B EDG C Max Load

>60 Min <10 Min 10-60 Min >60 Min KW 3845.44 4326.20 3943.31 4007.37 4326.20 KVAR 2296.45 2288.68 2108.21 2110.72 2296.45 KVA 4478.96 4894.29 4471.49 4529.25 4894.29 The portable diesel generators will have a total capability of at least 4500kW @ 0.8 PF at 4160VAC and a short-time overload rating of 110% of rated continuous power for two hour duration. Therefore, the new portable diesel generators will meet the electrical load requirements for the A or B bus during a LOOP concurrent with single failure to safely shutdown the plant.

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LR-N18-0013 LAR H18-01 Enclosure b) The permanent or temporary power source can be either a diesel generator, gas or combustion turbine, or power from nearby hydro units. This source can be credited as a supplemental source, that can be substituted for an inoperable EDG during the period of extended AOT in the event of a LOOP, provided the risk-informed and deterministic evaluation supports the proposed AOT and the power source has enough capacity to carry all LOOP loads to bring the unit to a cold shutdown.

The new supplemental power source will be portable diesel generators in weather tight containers that are trailer mounted and stored onsite. See Item a) above on load capacity justification. No changes are being proposed to the existing AOT.

c) For plants using Alternate Alternating Current (AAC) or supplemental power sources discussed above, the time to make the AAC or supplemental power source available, including accomplishing the cross-connection, should be approximately one hour to enable restoration of battery chargers and control reactor coolant system inventory.

The total time required to enable the GTG to supply power to the Hope Creek vital buses is estimated to be three hours (Reference 1). The supplemental power source will be made available to supply power to energize a vital bus within three hours, consistent with the current licensing basis. As discussed in Item e) below, three hours is bounded by the required coping time for loss of all AC power for Hope Creek.

Attachment 3 provides the required actions to align the portable diesel generators to the 10A401 or 10A402 4.16kV bus. It also provides conservative estimated time frames for completing all of the actions within the three hour requirement. Attachment 3 provides the following two scenarios for aligning the equipment. The actual storage location selected will ensure all actions can be completed within three hours of a loss of all AC power.

1. Portable diesel generators are left in the storage area during the AOT and will be moved to the staging location and connected in three hours. This requires the support of two stock handlers to move equipment, two Instrument and Control (I&C) or Electrical Technicians to connect cables, and one operator to align breakers to meet the required three hours.
2. Portable diesel generators will be staged outside the Turbine Building with only the cable and breaker alignment required. This requires the support of two I&C or Electrical Technicians to connect cables, and one operator to align breakers to meet the required three hours.

d) The availability of AAC or supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational.

The portable diesel generators will be verified tested within the past 30 days prior to extending an AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. For planned outages, the portable diesels will be verified to have been tested within 30 days of the planned entry of the A or B diesel outage, or if the portable diesel testing is not current within the last 30 days, will be tested prior to entering an extended 14 day AOT. For an unplanned A or B diesel outage, portable 5

LR-N18-0013 LAR H18-01 Enclosure diesel testing will be verified to be current within the last 30 days, or the portable diesel generators will be tested satisfactorily before extending the AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days.

Testing will consist of starting and synchronizing the portable diesel generators and verifying the portable diesel generators provide rated voltage and frequency for 5 minutes. A 100%

load bank of one of the new portable diesel generators is being provided with the portable diesel generators as part of the specification. The load bank will be connected to portable diesel generators and they will be loaded to approximately 30% load to verify the voltage and frequency. In addition, all auxiliary support systems for the portable diesel generators will be verified to be operational.

e) To support the one-hour time for making this power source available, plants must assess their ability to cope with loss of all AC power for one hour independent of an AAC power source.

Existing Hope Creek calculation E-4.1(Q), HC Class 1E 125 VDC Station Battery & Charger Sizing demonstrates that the station can cope up to four hours during a station blackout (SBO) or LOOP. Therefore, this provides justification for the current three hour timeframe for connecting the Salem Unit 3 gas turbine generator, which will be maintained for the portable diesel generators.

f) The plant should have formal engineering calculations for equipment sizing and protection and have approved procedures for connecting the AAC or supplemental power sources to the safety buses.

The existing calculation E-9(Q), Standby Class 1E Diesel Generator Sizing will be revised to show the new portable diesel generators will meet the load requirements. Additionally, the new portable diesel generator requires that the diesels supply a total capability of 4500kW

@ 0.8 PF at 4160VAC and a short-time overload rating of 110% of rated continuous power for two hour duration.

The portable diesel generator also requires the vendor to prove the diesels can start fully loaded with the largest motor. See requirements below, from specification.

12.4.2.4. Motor start test or calculation - while all 3 DGs are connected in parallel and loaded to steady state loading, support the start and acceleration of a 1250HP, 3744VAC (90% of 4160VAC, per NEMA MG-1) terminal voltage with a locked rotor current of 1015 amps@ PF=0.30 starting induction motor without exceeding a twenty five percent (25%) voltage drop. The frequency dip upon one-step load application shall not exceed five percent (5%).

The existing EDGs relay settings are in calculation E-7.6. The portable diesel generators will be supplied with the same level of protection as the existing EDGs and a new calculation will be created to capture the setpoints.

Calculation E-7.5 provides the relays settings calculation for the non-class 1E 4kV system.

Existing breaker 10A10101 or 10A10210 will be backfed when using the portable diesel generators. The overcurrent devices for these breakers are set at 1200A instantaneous.

This exceeds the 780.67 FLA rating of the diesels and therefore the breaker will not trip preventing the portable diesel generators from supplying power. The next protective device 6

LR-N18-0013 LAR H18-01 Enclosure is on the 4kV diesel switchgears 10A401 and 10A402, which will have the same protection whether fed from existing EDGs or portable diesel generators.

At the time of implementation, procedures will be revised to include connecting the supplemental power source.

g) The EDG or offsite power AOT should be limited to 14 days to perform maintenance activities. The licensee must provide justification for the duration of the requested AOT (actual hours plus margin based on plant-specific past operating experience).

The proposed change to TS 3.8.1.1, Action b.2.b, removes the Salem Unit 3 gas turbine generator and replaces it with the supplemental power source. The AOT of 14 days will remain unchanged.

h) The Tech Specs (TS) must contain Required Actions and Completion Times to verify that the supplemental AC source is available before entering extended AOT.

For the inoperable A or B diesel generator, TS 3.8.1.1 Action b.2.b currently requires verification that Salem Unit 3 is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The proposed TS require the same verification for the supplemental power source within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

i) The availability if the AAC or supplemental power source shall be checked every 8-12 hours (once per shift).

TS 3.8.1.1, Action b.2.b, currently require verification that the Salem Unit 3 is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This will remain unchanged for the supplemental power source.

j) The extended AOT will be used no more than once in a 24-month period (or refueling interval) on a per diesel basis to perform EDG maintenance activities, or any major maintenance on offsite power transformer or bus.

No changes are proposed to the existing AOT. EDG out-of-service hours are tracked in accordance with Maintenance Rule Unavailability. Additional restrictions are not proposed for replacing the Salem Unit 3 gas turbine generator with the supplemental power source.

k) The preplanned maintenance will not be scheduled if severe weather conditions are anticipated.

The current Hope Creek TS Bases state Voluntary entry into this extended 14 day AOT should not be scheduled if adverse weather conditions are expected. No changes are proposed to this commitment.

l) The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT.

At the time of implementation, procedure HC.OP-SO.KJ-0001, Emergency Diesel Generators Operation, will be revised to include requirements to contact with the grid 7

LR-N18-0013 LAR H18-01 Enclosure operator (Load Dispatcher) once per day during the extended AOT to ensure no significant grid disturbances are expected during the extended AOT.

m) Component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed.

The current Hope Creek TS Bases state Any component testing or maintenance that increases the likelihood of a plant transient shall be avoided during the extended 14 day AOT. This encompasses work activities categorized by station procedures as Production Risk. No changes are proposed to this commitment.

n) TS required systems, subsystems, trains, components, and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices.

Technical Specification required equipment will be verified to be operable in accordance with TS and appropriate LCOs will be entered as applicable. Maintenance and testing activities will also be controlled in accordance with the operability requirements for the affected equipment contained within the TS. Use of the supplemental portable diesel generators in lieu of the Salem Unit 3 gas turbine generator does not alter Hope Creeks approach to ensuring operability of TS required systems, subsystems, trains, components, and devices.

Operator rounds will ensure the functionality of the portable diesel generators and provide an additional level of overall monitoring.

o) Steam-driven emergency feed water pump(s) in case of PWR units, and Reactor Core Isolating Cooling and High Pressure Coolant Injection systems in case of BWR units, will be controlled as protected equipment.

The Hope Creek TS Bases state When either the A or B EDG is removed from service for an extended 14-day AOT, both high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) shall be operable. No changes are proposed to this commitment.

3.3 Operator Actions The portable diesel generators will be moved, if required, to the designated operating location.

The cables will be run from the receptacle panel to the designated operating location.

The breaker interlock key will be issued to the Operator who proceeds to the 10A10101 or 10A10210 breaker. Infeed alignment will be properly verified. The vital bus to be re-energized will be walked down and verified.

The cables will be plugged in and the portable diesel generators started. The portable diesel generators connected and voltage will be verified. The breakers will be closed and verified.

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LR-N18-0013 LAR H18-01 Enclosure provides the required actions and estimated times to align the portable diesel generators to the bus with the EDG out of service within three hours.

3.4 Operator Training Licensed Operators will be appropriately trained on the purpose and use of the portable diesel generators. A briefing/discussion of the revised TS 3.8.1.1 and placing the portable diesel generators in service will be completed prior to a planned EDG inoperability that exceeds 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Operating crews will be briefed on the EDG work plan and procedural actions regarding LOOP and SBO.

3.5 Time Validation The portable diesel generators will be stored onsite within the protected area. Attachment 3 provides the required actions and conservative estimated times to align the portable diesel generators to the bus with the EDG out of service within three hours. The actual storage location selected will ensure all actions can be completed within three hours of a loss of all AC power, based on field validation as part of the modification process.

3.6 Maintenance and Availability The portable diesel generators will be operated and maintained according to approved procedures. The same procedure(s) will direct routine preventative maintenance and an unloaded test run. Preventative maintenance for the portable diesel generators will be controlled through the preventative maintenance program.

The portable diesel generators will be designated as protected equipment when they are credited as available. The on-line risk procedure implementing 10 CFR 50.65 requires that any work activity in a protected equipment area be reviewed to determine if the activity may cause an adverse impact on the protected equipment. If the activity is determined to result in an adverse impact, the work may not proceed unless risk assessment is performed.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria In 10 CFR 50.36, "Technical specification," the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. Based on the assessments presented herein, the proposed change to the Hope Creek TS has no significant impact on the continued conformance with the requirements of 10 CFR 50.36 10 CFR 50.63, "Loss of all alternating current power," requires that nuclear power plants must be able to withstand a loss of all AC power for an established period of time and recover from a station blackout. The proposed change to use portable diesel generators has no significant effect on the ability to withstand a loss of all AC power and recover from a station blackout.

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LR-N18-0013 LAR H18-01 Enclosure NUREG-0800, Branch Technical Position 8-8, "Onsite Emergency Diesel Generators (EDGs) and Offsite Power Sources Allowed Outage Time Extensions," dated May 2011 (ADAMS Accession No. ML113640138) provides guidance to the NRC staff in reviewing LARs for licensees proposing a permanent TS change to extend an EDG AOT beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants, "requires that preventive maintenance activities must be sufficient to provide reasonable assurance that structures, systems, and components (SSCs) are capable of fulfilling their intended functions. Maintenance and testing activities will be controlled in accordance with the operability requirements for the affected equipment contained within the TS. Use of the portable diesel generators does not alter the stations approach to ensuring operability of TS required systems, subsystems, trains, components, and devices is maximized.

10 CFR 50.90, "Application for amendment of license or construction permit," addresses the requirements for a licensee desiring to amend its license and the TS incorporated therein. This license amendment request to Hope Creek TS 3.8.1 has been prepared to meet the requirements of 10 CFR 50.90.

Following implementation of the proposed changes, Hope Creek will remain in compliance with the above regulations and guidance.

4.2 Precedent The proposed change is consistent with the following NRC-approved license amendments:

  • Tennessee Valley Authority (TVA) on October 5, 2011 (Amendment Numbers 280, 307, and 266) for Browns Ferry Nuclear Plant, Units 1, 2 & 3 (NRC ADAMS Accession No. ML11227A258). The approved TS changes are similar to the change proposed in this request.
  • FPL Energy Seabrook. LLC on September 21, 2004, (Amendment No. 97) for Seabrook Station, Unit 1 (NRC ADAMS Accession No. ML042240471).
  • South Carolina Electric & Gas Company on November 2, 2006, (Amendment No. 178) for V.C. Summer Nuclear Station, Unit 1 (NRC ADAMS Accession No. ML062760369).

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) requests an amendment to Renewed Facility Operating License No. NPF-57 for Hope Creek Generating Station (Hope Creek). The proposed change revises TS 3/4.8.1, "AC Sources - Operating"; specifically Action b.2.b concerning one inoperable Emergency Diesel Generator (EDG). The proposed change removes the requirement for the Salem Unit 3 gas turbine generator (GTG) and replaces it with the supplemental power source during the existing extended allowable outage time for the A or B EDG.

PSEG has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

10

LR-N18-0013 LAR H18-01 Enclosure

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change removes the requirement for the Salem Unit 3 gas turbine generator (GTG) and replaces it with the supplemental power source during the existing extended allowable outage time for the A or B EDG. The emergency diesel generators are safety related components which provide backup electrical power supply to the onsite Safeguards Distribution System. The emergency diesel generators are not accident initiators; the EDGs are designed to mitigate the consequences of previously evaluated accidents including a loss of offsite power. (During normal operation, the proposed portable diesel generators will not be connected to the plant.)

The proposed change does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed change does not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed change is consistent with safety analysis assumptions and resultant consequences.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change removes the requirement for the Salem Unit 3 gas turbine generator (GTG) and replaces it with the supplemental power source during the existing extended allowable outage time for the A or B EDG. The proposed change does not alter or involve any design basis accident initiators. Equipment will be operated in the same configuration and manner that is currently allowed and designed for.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed change does not alter the permanent plant design, including instrument set points, nor does it change the assumptions contained in the safety analyses. The proposed change does not impact the redundancy or availability requirements of offsite power supplies or change the ability of the plant to cope with station blackout events.

11

LR-N18-0013 LAR H18-01 Enclosure The EDGs continue to meet their design requirements; there is no reduction in capability or change in design configuration. The EDG response to LOOP, LOCA, SBO, or fire is not changed by this proposed amendment; there is no change to the EDG operating parameters. The remaining operable emergency diesel generators are adequate to supply electrical power to the onsite Safeguards Distribution System. The proposed change does not alter a design basis or safety limit; therefore it does not significantly reduce the margin of safety. The EDGs will continue to operate per the existing design and regulatory requirements.

Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

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

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NRC approval letter regarding Amendment No. 188 to the Hope Creek TSs regarding Emergency Diesel Generators A and B Allowed Outage Time Extension (TAC No.

ME3597), dated March 25, 2011 (Adams Accession No. ML110610501) 12

LR-N18-0013 LAR H18-01 Attachment 1 Technical Specification Page Markups The following Technical Specifications pages for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page 3.8.1, A.C. Sources 3/4 8-2

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued) supplemental power source

2. For the inoperable A or B diesel generator, if continued operation is permitted by LCO 3.7.1.3:

a) Restore the inoperable 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 b) Verify the Salem Unit 3 gas turbine generator (GTG) is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafte(i, and restore the inoperable diesel generator to OPERABLE status within 14 days.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. For the inoperable C or D diesel generator, if continued operation is permitted by LCO 3.7.1.3, restore the inoperable diesel generator to OPERABLE status within 14 days, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
c. With one offsite circuit of the above required AC. sources and one diesel generator of the above required AC. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining AC. sources 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. If a diesel generator became inoperable due to any causes other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE diesel generators separately for each diesel generator by performing Surveillance Requirement 4.8. 1.1.2.a.4 within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> unless the absence of any potential common mode failure for the remaining diesel generators is demonstrated*. If continued operation is permitted by LCO 3.7.1.3, restore at least two offsite circuits and all four of the above required diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of the initial loss or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A successful test(s) of diesel generator OPERABILITY per Surveillance Requirement 4.8.1.1.2.a.4 performed under this ACTION statement for the OPERABLE diesel generators satisfies the diesel generator test requirements of ACTION Statement b.
d. With both of the above required offsite circuits inoperable, restore at least one of the above required offsite circuits to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. With only one offsite circuit restored to OPERABLE status, restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial loss or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

supplemental power source

  • This test is required to be completed regardless of when the inoperable diesel generator is restored, to OPERABILITY.
  1. After the initial verification period, the GTG may be unavailable for a single period of up to 24-hours and the once-per 12-hour requirement to verify that the GTG is available may be suspended during this period.

supplemental power source HOPE CREEK 3/4 8-2 Amendment No. 188

LR-N18-0013 LAR H18-01 Attachment 2 Bases Page Markups - For Information Only The following Technical Specifications Bases pages for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification Bases Page 3/4.8.1, A.C. Sources B 3/4 8-1

3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES, D.C. SOURCES and ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C. power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for (1) the safe shutdown of the facility and (2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C.

and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one of the onsite A.C. and the corresponding D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. or D.C. source.

A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering an OPERATIONAL CONDITION or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into an OPERATIONAL CONDITION or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

The A.C. and D.C. source allowable out-of-service times are based on Regulatory Guide 1.93, "Availability of Electrical Power Sources," December 1974 as modified by plant specific analysis and diesel generator manufacturer recommendations. When two diesel generators are inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERABLE diesel generators as a source of emergency power, are also OPERABLE. This requirement is intended to provide assurance that a loss of offsite power event will not result in a complete loss of safety function of critical systems during the period two or more of the diesel generators are inoperable. The term verify as used in this context means to administratively check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITY of the component. supplemental power source LCO 3.8.1.1, Action b allows the AOT for EDG "A" or "B" to extend from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days provided the availability of the Salem Unit 3 gas turbine generator (GTG) is verified within the initial 72-hour period and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The GTG provides additional defense-in depth during the extended AOT.

supplemental power source HOPE CREEK B 3/4 8-1 HC-16-184

LR-N18-0013 LAR H18-01 Attachment 3 Required Actions and Conservative Estimated Times to Complete

Attachment #3 Scenario 1 Performance Time Actions Minutes Notes Items # Task Time (mins) Resources 015 1525 2530 3040 4045 4555 5560 6065 6570 7080 8085 8590 90100 100105 105115 115125 125130 130140 140155 155165 165170 170175 175180 1 Start of LOOP 15 Ops X See Note 1 DISPATCH operator(s) and Maintenance to 2 I&C/Elec & Ops X 2 Diesel Building to evaluate EDG 30 See Note 1 DISPATCH personnel to Outdoor Flex Storage 2 Stock Handlers X 3 Area 2 (OFSA2) to Move Cable Trailer 10 See Note 2 Open breaker for 480V power source to 2 Stock Handlers X 4 portable diesel generators. 5 See Note 3 Disconnect 480V Cables from Portable Diesel 2 Stock Handlers X 5 Generators (DG) 10 See Note 3 6 Hook tow vehicle to diesel at DG #1 15 2 Stock Handlers X See Note 2 7 Drive DG #1 to Deployment Location 10 2 Stock Handlers X See Note 2 8 Disconnect from DG # 1 15 2 Stock Handlers X See Note 2 9 Drive Back to OFSA 2 10 2 Stock Handlers X See Note 2 10 Hook tow vehicle to diesel at DG #2 15 2 Stock Handlers X See Note 2 11 Drive DG #2 to Deployment Location 10 2 Stock Handlers X See Note 2 12 Disconnect from DG # 2 15 2 Stock Handlers X See Note 2 13 Drive Back to OFSA 2 10 2 Stock Handlers X See Note 2 14 Hook tow vehicle to diesel at DG #3 15 2 Stock Handlers X See Note 2 Drive DG #3 to Deployment Location. (Note: Do 2 Stock Handlers X 15 not need to disconnect to hook up cables) 10 See Note 2 DISPATCH personnel to OFSA2 to Move Cable 2 I&C/Elec X 16 Trailer 10 See Note 2 17 Hook truck to cable trailer 5 2 I&C/Elec X See Note 3 18 Drive cable trailer to Deployment Location 5 2 I&C/Elec X See Note 3 19 Open the turbine building rollup door. 5 2 I&C/Elec X See Note 3 20 Open security grating to the Receptacle panel. 5 OPs X See Note 3 Connect four 4/0 cables from Receptacle Panel to just outside Radiological Controlled Area 2 I&C/Elec X 21 (RCA) for DG #1. 15 See Note 2 Connect four 4/0 cables from Receptacle Panel 2 I&C/Elec X 22 to just outside RCA for DG #2. 15 See Note 2 Connect four 4/0 cables from TPC Receptacle 2 I&C/Elec X 23 Panel to just outside RCA for DG #3. 15 See Note 2 Connect four 4/0 cables from DG #1 to cables 2 I&C/Elec X 24 just outside RCA. 10 See Note 2 Connect four 4/0 cables from DG #2 to cables 2 I&C/Elec X 25 just outside RCA. 10 See Note 2 just outside RCA. (Note: This overlaps with Item 15, but expectation is that cables are 2 I&C/Elec X pulled and will be connected immediately once 26 DG in place) 10 See Note 2 Connect synch cables between each of the 2 I&C/Elec X 27 diesel trailers. 5 See Note 3 The next steps 28 thru 34 & 36 are for the A EDG out of service.

28 Open Breaker BS 67 in 13.8 kV Ring Bus Verify Switchgear 10A403 SR 4.16kV BKR 29 10A40308 is Open Verify Switchgear 10A401 SR 4.16kV BKR 30 10A40101 is Open Verify Switchgear 10A401 SR 4.16kV BKR 31 10A40108 is Closed 25 Ops X Verify Switchgear 10A101 SR 4.16kV BKR 32 10A10110 is Open Verify Switchgear 10A101 SR 4.16kV BKR 33 10A10101 is Closed Open lock to breaker 10A10104 in Switchgear 34 10A101 See Note 3 35 Start DG's 10 2 I&C/Elec X See Note 3 36 Close Breaker 10A10104 in Switchgear 10A101 5 Ops X See Note 3 Notes:

Note 1 Time from Procedure HC.OPAB.ZZ0135, Station Blackout/Loss Offsite Power/Diesel Generator Malfunction Note 2 Estimated Time from Validation Plan No. HC FLEX 20151217C, Transport ALT FLEX Diesel Generator Note 3 Estimated Time from Interviewing Operators Page 1 of 2

Attachment #3 Scenario 2 Performance Time Actions Minutes Notes Items # Task Time (mins) Resources 015 1525 2530 3040 4045 4555 5560 6075 7590 90105 105115 115125 125135 135140 140150 150155 1 Start of LOOP 15 Ops X See Note 1 Diesel Building to evaluate Emergency Diesel 2 I&C/Elec & Ops X 2 Generator 30 See Note 1 DISPATCH personnel to Outdoor Flex Storage 2 I&C/Elec X 3 Area 2 to Move Cable Trailer 10 See Note 2 4 Open the turbine building rollup door. 5 2 I&C/Elec X See Note 3 5 Open security grating to the Receptacle panel. 5 OPs X See Note 3 Connect four 4/0 cables from Receptacle Panel to just outside Radiological Controlled Area 2 I&C/Elec X 6 (RCA) for Portable Diesel Generator (DG) #1. 15 See Note 2 Connect four 4/0 cables from Receptacle Panel 2 I&C/Elec X 7 to just outside RCA for DG #2. 15 See Note 2 Connect four 4/0 cables from Receptacle Panel 2 I&C/Elec X 8 to just outside RCA for DG #3. 15 See Note 2 Connect four 4/0 cables from DG #1 to cables 2 I&C/Elec X 9 just outside RCA. 10 See Note 2 Connect four 4/0 cables from DG #2 to cables 2 I&C/Elec X 10 just outside RCA. 10 See Note 2 Connect four 4/0 cables from DG #3 to cables 2 I&C/Elec X 11 just outside RCA. 10 See Note 2 Connect synch cables between each of the diesel 2 I&C/Elec X 12 trailers. 5 See Note 3 The next steps 13 thru 19 & 21 are for the A EDG out of service.

13 Open Breaker BS 67 in 13.8 kV Ring Bus Verify Switchgear 10A403 SR 4.16kV BKR 14 10A40308 is Open Verify Switchgear 10A401 SR 4.16kV BKR 15 10A40101 is Open Verify Switchgear 10A401 SR 4.16kV BKR 16 10A40108 is Closed 25 Ops X Verify Switchgear 10A101 SR 4.16kV BKR 17 10A10110 is Open Verify Switchgear 10A101 SR 4.16kV BKR 18 10A10101 is Closed Open lock to breaker 10A10104 in Switchgear 19 10A101 See Note 3 20 Start DG's 10 2 I&C/Elec X See Note 3 21 Close Breaker 10A10104 in Switchgear 10A101 5 Ops X See Note 3 Notes:

Note 1 Time from Procedure HC.OPAB.ZZ0135, Station Blackout/Loss Offsite Power/Diesel Generator Malfunction Note 2 Estimated Time from Validation Plan No. HC FLEX 20151217C, Transport ALT FLEX Diesel Generator Note 3 Estimated Time from Interviewing Operators Page 2 of 2

LR-N18-0013 LAR H18-01 Attachment 4 Drawings and Site Photo

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