ML15222B175

Issuance of Amendment to Modify Technical Specification 3.8.1, Diesel Generator Testing Requirements

ML15222B175
Person / Time
Site:	Robinson
Issue date:	09/08/2015
From:	Martha Barillas Plant Licensing Branch II
To:	Glover R Duke Energy Progress
Barillas M
References
TAC MF2717
Download: ML15222B175 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 8, 2015 Mr. Richard M. Glover, H. B. Robinson Steam Electric Plant Site Vice President Duke Energy Progress, Inc.

3581 West Entrance Road, RNPA01 Hartsville, South Carolina 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AMENDMENT TO MODIFY TECHNICAL SPECIFICATION 3.8.1, DIESEL GENERATOR TESTING REQUIREMENTS (TAC NO. MF2717)

Dear Mr. Glover:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 242 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). This amendment changes the HBRSEP Technical Specifications (TSs) in response to your application dated September 10, 2013 (Agencywide Documents Access and Management System Accession No. ML13261A289), as supplemented by letters dated January 30, 2014(ML14037A105), June 1, 2014(ML14163A480), and December 16, 2014 (ML14365A195).

The amendment revises TS 3.8.1, "AC [Alternating Current] Sources-Operating," by adding a Note to Required Action B.3.2.2 that will exempt performance of this conditional surveillance, when one diesel generator is declared inoperable due to pre-planned maintenance and testing.

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

Sincerely,

/RAJ Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 242 to DPR-23

2. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, INC.

DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No.2 4 2 Renewed License No. DPR-23

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

A. The application for amendment by Duke Energy Progress, Inc. (the licensee),

dated September 10, 2013, as supplemented by letters dated January 30, June 1, and December 16, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B. of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 242 are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION Shana R. Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Operating License No. DPR-23 and the Technical Specifications Date of Issuance: September 8, 2O1 5

ATTACHMENT TO LICENSE AMENDMENT NO. 242 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace page 3 of Operating License No. DPR-23 with the attached page 3.

Replace the following pages of the 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.

Remove Pages Insert Pages 3.8-2 3.8-2

D. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; E. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; 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:

A. Maximum Power Level The licensee is authorized to operate the facility at a steady state reactor core power level not in excess of 2339 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.2 4 2 are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(1) For Surveillance Requirements (SRs) that are new in Amendment 176 to Final Operating License DPR-23, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 176. For SRs that existed prior to Amendment 176, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 176.

Renewed Facility Operating License No. DPR-23 Amendment No. 2 4 2

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. 8.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the offsite circuit.

AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND thereafter 8.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with required redundant inoperability of feature(s) is redundant inoperable. required feature(s)

AND B.3.1 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE DG 8.3.2.1 Determine OPERABLE DG 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not inoperable due to common cause failure.

AND

-~-----~---------NOTE----------------~~

Not required to be performed when the cause of the inoperable DG is pre-planned maintenance and testing.

B.3.2.2 Perform SR 3.8.1.2 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for OPERABLE DG.

(continued)

HBRSEP Unit No. 2 3.8-2 Amendment No. 2 4 2

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 242 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DUKE ENERGY PROGRESS, INC.

H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261

1.0 INTRODUCTION

By application dated September 10, 2013 (Agencywide Documents Access and Management System Accession No. ML13261A289), as supplemented by letters dated January 30, 2014 (ML14037A105), June 1, 2014(ML14163A480), and December 16, 2014(ML14365A195), Duke Energy Progress, Inc. (Duke Energy, the licensee), submitted a license amendment request regarding H. B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP) Technical Specifications (TSs). The proposed amendment would modify TS 3.8 Electrical Power Systems, limiting condition for operation (LCO) 3.8.1, AC [Alternating Current] Sources-Operating. A new Note would be added to Required Action (RA) B.3.2.2, the conditional surveillance on the alternate, operable emergency diesel generator (EOG), which currently requires the performance of Surveillance Requirement (SR) 3.8.1.2 within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The new Note would exempt performance of this conditional surveillance on the alternate, operable EDG when the cause of the initial inoperability of the inoperable EDG is pre-planned maintenance and testing. The exemption would not apply whenever the cause of the inoperability is corrective maintenance, even if the problem requiring corrective maintenance is discovered during the execution of the original pre-planned maintenance and testing.

The current HBRSEP TS requirement causes the operable EDG to be made inoperable by the conditional SR of RA B.3.2.2 whenever the pre-planned maintenance and testing on the alternate division EDG is not completed and returned to operable status within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />; even when it has been determined that no common cause failure potential exists within the first 24-hour period by RA B.3.2.1. This leads to the situation where both EDGs are inoperable simultaneously for the duration of the performance of SR 3.8.1.2, typically 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The licensee stated in its application that this conditional SR unnecessarily makes the plant vulnerable to a test-caused failure resulting in both EDGs being unavailable, for only a slight increase in confidence, by actively demonstrating the operability of the EDG not undergoing maintenance every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (notwithstanding the regular monthly demonstration of operability by the performance of SR 3.8.1.2). The proposed change does not eliminate the requirement to perform an operability determination of the available EDG irrespective of the reason for declaring one EDG inoperable.

Enclosure 2

The supplemental letters from the licensee dated January 30, June 1, and December 16, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Registeron December 10, 2013 (78 FR 74179).

2.0 REGULATORY EVALUATION

The EOG system provides an emergency source of alternating current (AC) electrical power to the onsite emergency AC Power subsystem, as required, for those events where offsite power (the preferred power source) is assumed not to be available. Each EOG unit shall auto start upon detection of undervoltage on that EDG's respective emergency bus, except when the Local/Remote control switch is in the LOCAL position. Once an EOG reaches design speed, the system will then close the EOG output breaker and assume the load on its respective bus. Both EDGs shall auto start upon initiation of safety injection, except when the Local/Remote control switch is in the LOCAL position. Once the EOG reaches design speed, the system will run but not pickup load unless power is lost to its respective bus.

The staff reviewed the licensee's application, as supplemented, against the following regulatory requirements and regulatory guidance documents.

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications,"

establishes the requirements related to the content of the TSs. Pursuant to 10 CFR 50.36(c)

TSs will include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings, (2) LCOs, (3) SRs, (4) design features; and (5) administrative controls. The proposed changes to the HBRSEP TS affect the LCO category.

As stated, in part, in 10 CFR 50.36(c)(2)(i), "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When 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."

HBRSEP's Updated Final Safety Analysis Report (UFSAR), Section 3.1.2.39, "Emergency Power," describes the licensee's compliance with the July 1967 Atomic Energy Commission General Design Criterion (GDC), as stated:

An emergency power source shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning of the engineered safety features and protection systems required to avoid undue risk to the health and safety of the public. This power source shall provide this capacity assuming a failure of a single active component. (GDC 39)

NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements," dated December 1992, and NUREG-1431, Revision 4, "Standard Technical Specifications [STSs] -

Westinghouse Plants," dated April 2012, contain recommendations for demonstrating that a common mode failure may not exist on the remaining EDG(s) when one EOG is scheduled for testing or maintenance.

NRC Generic Letter (GL) 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," dated July 1984, proposed actions that would improve the reliability of EDGs. In the condition where one EOG was inoperable, the actions would demonstrate operability for one EOG and the absence of a common mode failure.

GL 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," dated September 27, 2003, provides guidance for implementing line-item TS improvements to reduce testing during power operation.

Regulatory Guide (RG) 1.93 "Availability of Electric Power Sources," dated December 1974, describes operating procedures and restrictions acceptable to the NRC staff, which should be implemented if the available electric power sources are less than the LCO.

RG 1.155, "Station Blackout" calls for the use of the reliability of the diesel generator as one of the factors in determining the length of time a plant should be able to cope with a station blackout. The reliability of EDGs can be one of the main factors affecting the risk of core damage from a station blackout event. Thus, both attaining and maintaining the high reliability of EDGs at nuclear power plants contribute greatly to reducing the probability of station blackout.

3.0 TECHNICAL EVALUATION

In its letter dated September 10, 2013, the licensee proposed to change the requirement for operability testing of an EOG when the EOG for the alternate safety bus is inoperable.

The current TS requirement causes the operable EOG to be made inoperable by the conditional SR of RA B.3.2.2 whenever the preventive maintenance and testing on the alternate division EOG is not completed and returned to operable status within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. This is applicable even when it has been determined that no common-mode failure potential exists within the first 24-hour period by RA B.3.2.1. This leads to the situation where both EDGs are inoperable simultaneously for the duration of the performance of SR 3.8.1.2, typically 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The proposed amendment revises RA B.3.2.2 in TS LCO 3.8.1, "AC Sources - Operating,"

adding a NOTE to remove the requirement to start the operable EOG if it can be determined that a common-mode failure does not exist and the cause of the inoperable EOG is pre-planned maintenance and testing.

The exemption to perform RA B 3.2.2 would not apply when the cause of the inoperability is corrective maintenance, even if the problem requiring corrective maintenance is discovered during the execution of the original pre-planned preventive maintenance and testing. Currently, TS 3.8.1 specifies that if an EOG is unavailable or inoperable due to any cause, then the operability of the remaining operable EOG must be demonstrated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

HBRSEP TS 3.8.1, "AC Sources - Operating," currently states the following, in part:

Condition B: One DG inoperable Required Action B.3.2.1: Determine OPERABLE Completion Time: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG is not inoperable due to common cause failure.

Required Action B.3.2.2: Perform SR 3.8.1.2 for Completion Time: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> OPERABLE DG.

• ------*-*---~---J The licensee proposed to revise HBRSEP TS 3.8.1 as follows:

~dition B: One DG inoperable I Required Action B.3.2.1: Determine OPERABLE Completion Time: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG is not inoperable due to common cause failure.

NOTE: Not required to be performed when the cause of the inoperable DG is pre-planned maintenance and testing.

Required Action B.3.2.2: Perform SR 3.8.1.2 for Completion Time: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> OPERABLE DG.

The licensee submitted responses to NRC staff's requests for additional information (RAls) in letters dated January 30, 2014, June 1, 2014, and December 16, 2014. The intermediate responses revised the proposed TS Note wording and included RA B 3.1, which also requires performance of SR 3.8.1.2. In the final RAI response dated December 16, 2014, the licensee superseded all previous changes to the license amendment request. The proposed TS change, above, reflects the final RAI response.

The licensee stated that the use of the proposed exclusionary Note to RA B.3.2.2 would still ensure the operable EOG meets its intended safety function. This is done by taking credit for the satisfactory performance of its required SRs, specifically SRs 3.8.1.2 and 3.8.1.3, the 31-day start and load tests. The staff agrees that regular performance of these SRs is otherwise sufficient to demonstrate continued operability of an EOG, so it should not be necessary to perform them on an accelerated basis when no common cause failure exists between an EOG and the alternate EOG that has been taken out of service for pre-planned maintenance and testing.

The objective of RA B.3.2.2 is to ensure that the opposite train's EDG is not affected by a common-cause failure and to provide assurance of continued operability of the operable EOG.

However, the inoperability of an EOG does not necessarily affect the reliability of the operable EOG, unless there is some common-mode failure possibility. This is consistent with GL 93-05 and NUREG-1366 "Improvements to Technical Specifications Surveillance Requirements,"

December 1992. In GL 93-05, the NRC staff stated that, in performing the study documented in NUREG-1366, the safety can be improved, equipment degradation decreased, and an unnecessary burden on licensee personnel eliminated by reducing the frequency of certain testing required in the TSs during power operation. The changes eliminate testing that is likely to cause transients or excessive wear of equipment.

An evaluation of these changes indicated there would be a benefit to plant safety, as documented in NUREG-1366. The NUREG-1366 considered (1) unavailability of safety equipment due to testing, (2) initiation of significant transients due to testing, (3) actuation of engineered safety features that unnecessarily cycle safety equipment, (4) importance to safety of that system or component, (5) failure rate of that system or component, and (6) effectiveness of the test in discovering the failure.

The licensee stated the actions contained in TS 3.8.1, RA B.3.2.2 can also cause unnecessary testing of the operable EDG(s). This unnecessary testing can result in equipment degradation and the potential for reduced reliability. In NUREG-1366, the NRC staff recommended that the requirements to test the remaining EDG(s), when one EOG is inoperable due to any cause other than preplanned preventive maintenance or testing, be limited to those situations where the cause for inoperability has not been conclusively demonstrated to preclude the potential for a common-mode failure. NUREG-1366 and GL 93-05 require that when an EOG itself is inoperable (not including support system or independently testable components), the other EDG(s) should be tested only once and 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 can be demonstrated. NUREG-1431, STS 3.8.1.B contains language similar to the licensee's proposal in that either a common cause failure determination is performed (STS RA 3.1) OR perform SR 3.8.1.2 (STS RA 3.2). Furthermore, the proposed change states that if a common-cause possibility does not exist on the operable EDG(s), testing of the operable EDG(s) does not have to be performed. The staff finds the proposed change is consistent with the intent of NUREG-1431 and GL 93-05, and is therefore, acceptable.

HBRSEP's UFSAR licensing basis describes the licensee's compliance with the July 1967 Atomic Energy Commission GDC 39. GDC 39 "Emergency Power for Engineered Safety Features (Category A)," requires:

Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity assuming a failure of a single active component in each power system.

The licensee stated in its application that the requested TS amendment does not change the existing design of the onsite or offsite power systems. Therefore, the testing capability for the EDGs remains in agreement with GDC 39.

The NRC staff reviewed UFSAR Section 8.3.1.1.5.4 "Test and Inspection Capabilities," and confirmed that there was no EDG testing requirement in the HBRSEP UFSAR that would adversely affect the licensee's requested change to TS 3.8.1.

RG 1.93 describes operating procedures and restrictions that should be implemented if the available electric power sources are less than the LCO and actions required to be taken by the licensee when the LCO is not met. RG 1.93, Section 1.0, "The Available AC Power Sources Are One Less Than the LCO," discusses the degraded condition when one of the required offsite or onsite AC sources is not available. That is, either the offsite or the onsite AC power system has no redundancy. RG 1.93 states that each system retains full capability (one system with redundancy) to effect a safe shutdown and to mitigate the effects of a design-basis accident.

Operation could therefore safely continue if the availability of the remaining sources is verified.

When the TSs allow power operation to continue during a specific degradation level, RG 1.93 states that such continued power operation should be contingent on the following: (a) an immediate verification of the availability and integrity of the remaining sources; (b) reevaluation of the availability of the remaining EDG(s) at time intervals not to exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; (c) verification that the required maintenance activities do not further degrade the power system or in any way jeopardize plant safety; and (d) compliance with the additional conditions stipulated for each specific degradation level. The requested TS change relates to the method used to verify the availability of the remaining source(s) during planned equipment outages to comply with this requirement. The licensee's requested change is consistent with NRC guidance for verification of availability and integrity of the remaining sources as detailed in RG 1.93.

The action contained in HBRSEP TS 3.8.1, RA B.3.2.2 can cause unnecessary testing of the operable EDG(s). This unnecessary testing can result in equipment degradation and the potential for reduced reliability. As a result of the TS change, with the potential decrease in the testing frequencies, the risk of a transient and equipment degradation would be decreased, and the reliability of the equipment would not be adversely impacted.

The reliability of EDGs can be one of the main factors affecting the risk of core damage from a station blackout event. Thus, both attaining and maintaining the high reliability of EDGs contribute greatly to reducing the probability of station blackout. RG 1.155, "Station Blackout" calls for the use of the reliability of the EDG as one of the factors in determining the length of time a plant should be able to cope with a station blackout. The staff determined the requested TS amendment does not change the reliability factors delineated in RG 1.155 for coping with station blackout.

The added assurance of operability by performing the conditional surveillance of RA B.3.2.2, beyond the satisfactory performance of the periodically scheduled SRs, absent a common cause failure (RA B.3.2.1 is met) does not offset the intentional unavailability of an otherwise operable EDG and the associated potential for introducing a test-caused failure or a problem introduced by being connected parallel to offsite power. Therefore, excluding this conditional surveillance when the initial cause of inoperability is for pre-planned preventive maintenance and testing is appropriate. The proposed Note would not apply and the conditional surveillance of RA B.3.2.2 would still be performed every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> when the cause of the alternate EDG inoperability is for corrective maintenance to repair a problem, even if the problem requiring corrective maintenance is discovered during the execution of the original pre-planned maintenance and

testing. The staff determined this is consistent with HBRSEP's current licensing basis requirement for the conditional surveillance for ensuring operability in the alternate EDG.

The NRC staff concludes that the proposed change is intended to reduce unnecessary testing of EDGs as recommended by GL 93-05 and NUREG-1366. On the basis of the above review, the NRC staff finds that the proposed change maintains compliance with requirements governing the design and operation of the electrical power system, provides adequate assurance of system operability, and is consistent with the recommendations contained in GL 93-05, RG 1.93, NUREG-1366 and NUREG-1431. Therefore, the NRC staff finds the proposed change acceptable.

As stated in 10 CFR 50.36(a)(1 ), "A summary statement of the bases or reasons for such specifications ... shall also be included in the application, but shall not become part of the technical specifications." The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the TS Bases Control Program, TS 5.5.14.

Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that TS Bases changes associated with the supplemental letter dated December 16, 2014, are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors dated July 22, 1993 (58 FR 39132).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. 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 (78 FR 74179). 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 considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the

amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Khadijah West Date: September 8, 2015

..* ML152228175 *via email OFFICE LPL2-2/PM LPL2-2/LA DE/EEEB* DSS/STSB* OGC- NLO NAME MBarillas BClavton JZimmerman RElliott DRoth DATE 08/13/15 08/13/15 08/04/15 08/04/15 08/24/15 OFFICE LPL2-2/BC LPL2-2/PM NAME SHelton MBarillas DATE 08/31/15 09/08/15