NMP2L2643, License Amendment Request-Adoption of TSTF-283-A, Revision 3, Modify Section 3.8 Mode Restriction Notes

License Amendment Request-Adoption of TSTF-283-A, Revision 3, Modify Section 3.8 Mode Restriction Notes

ML17095A081
Person / Time
Site:	Nine Mile Point
Issue date:	04/05/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP2L2643
Download: ML17095A081 (36)

Text

200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.91 (a)(5)

NMP2L2643 April 5, 2017 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410

SUBJECT:

License Amendment Request-Adoption of TSTF-283-A, Revision 3, "Modify Section 3.8 Mode Restriction Notes" Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2).

The proposed amendment is consistent with NRG-approved Technical Specification Task Force 283, Revision 3, "Modify Section 3.8 Mode Restriction Notes."

The proposed changes modify the NMP2 TS 3.8.1, "AC Sources - Operating," and TS 3.8.4, "DC Sources - Operating." Consistent with TSTF-283-A, Notes would be added to allow greater flexibility in performing Surveillance Requirements (SRs) in Modes 1, 2, or 3. The Surveillance Notes will allow full or partial performance of the SRs to re-establish Operability provided an assessment determines the safety of the plant is maintained or enhanced.

These Surveillances currently have Notes prohibiting their performance in Modes 1 or 2, or in Modes 1, 2, or 3.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendment."

The proposed changes have been reviewed by the NMP Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

This LAR contains no regulatory commitments.

Attachment 1 provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked up TS Bases pages for reference only.

Amendment Request Modify Section 3.8 Mode Restriction Notes Docket Nos. 50-41 O April 5, 2017 Page2 Exelon requests approval of the proposed amendment by April 5, 2018. Once approved, the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Ron Reynolds at (610) 765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of April 2017.

Respectfully,

,J._ J T"" L.)Y--- -fr"'-

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. Markup of Proposed Technical Specifications Bases Pages cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - NMP NRC Project Manager, NRR - NMP A.L.P~eraon,NYSERDA

ATTACHMENT 1 License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket Nos. 50-410 EVALUATION OF PROPOSED CHANGES

Subject:

Adoption of TSTF-283-A, Revision 3, "Modify Section 3.8 Mode Restriction Notes" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 1 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2).

Exelon requests approval of this license amendment request by April 5, 2018.

2.0 DETAILED DESCRIPTION The modified Surveillance Notes described below will allow full or partial performance of the Surveillance Requirements (SRs) to re-establish Operability provided an assessment determines the safety of the plant is maintained or enhanced. These Surveillances currently have Notes prohibiting their performance in Modes 1 or 2, or in Modes 1, 2, or 3.

These changes are consistent with the Nuclear Regulatory Commission-approved Industry/Technical Specification Task Force (TSTF) 283, Revision 3 (TSTF-283-A)

(Reference 1) on eliminating mode restrictions on the performance of SRs in TSs 3.8.1 and 3.8.4. The NRC has approved the TSTF for inclusion in the Improved Standard Technical Specifications (ISTS) in NUREG-1433, Revision 4, for BWR/4 plants, and for consideration for being added to plant TSs. The intent of the TSTF is to allow testing of the Emergency Diesel Generators (EDGs) and Class 1E batteries in modes not currently allowed for the purpose of maintaining or re-establishing system or component Operability (e.g., post maintenance testing), provided a safety assessment is made before the testing for Operability.

Numbering differences between the NMP2 SRs and the NUREG-1433, Revision 4, formats are described below. The ISTS number is in parenthesis following the NMP2 SR number. Each SR is annotated in parenthesis with (Insert 1) or (Insert 2), as appropriate per TSTF-283-A, to align with the marked up TS pages in Attachment 2. The TS Bases are marked up in Attachment 3 using (Bases Insert 1) and (Bases Insert 2), as appropriate. For those SRs that include restriction in Mode 3, the applicable Bases Insert is modified to include Mode 3. The TS Bases markups are included as information only.

The following twelve (12) SRs are affected, followed by a summary of variations from TSTF-283-A:

1. SR 3.8.1.7 (ISTS SR 3.8.1.9), with tests the ability of the DG to reject a load greater than or equal to its associated single largest post-accident load, contains a Note prohibiting performance in Mode 1 or 2. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1 or 2, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

2. SR 3.8.1.8 (ISTS SR 3.8.1.10), which tests emergency DG operation following a load rejection of greater than or equal to 4400 kW for Division 1 or 2 DGs, contains a Note prohibiting performance in Mode 1 or 2. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1 or 2, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 2 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes

3. SR 3.8.1.9 (ISTS SR 3.8.1.11), which tests the response to a loss of offsite power signal, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 2)

4. SR 3.8.1.10 (ISTS SR 3.8.1.12), which tests the response to an Emergency Core Cooling system (ECCS) initiation, contains a Note prohibiting performance in Mode 1 or 2. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1 or 2, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 2)

5. SR 3.8.1.11 (ISTS SR 3.8.1.13), which tests that each DGs automatic trips are bypassed on a loss of voltage signal concurrent with an ECCS initiation signal, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

6. SR 3.8.1.12 (ISTS SR 3.8.1.14), which performs a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> loaded test run of the DG, contains a Note prohibiting performance in Mode 1 or 2. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1 or 2, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

7. SR 3.8.1.14 (ISTS SR 3.8.1.16), which verifies transfer from DG to offsite power, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

8. SR 3.8.1.15 (ISTS SR 3.8.1.17), which verifies that a DG operating in test mode will return to ready-to-load condition and energize the emergency load from offsite power on receipt of an ECCS initiation signal, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 2)

9. SR 3.8.1.16 (ISTS SR 3.8.1.18), which verifies the interval between each sequenced load, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 1)

10. SR 3.8.1.17 (ISTS SR 3.8.1.19), which verifies the response to a loss of offsite power signal and ECCS actuation signal, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 3 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes prohibited in Mode 1, 2, or 3, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 2)

11. SR 3.8.4.7 (ISTS SR 3.8.4.3), which verifies battery capacity for emergency loads contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced. (Insert 2)

12. SR 3.8.4.8 (ISTS SR 3.8.6.6), which verifies battery capacity during performance discharge testing, contains a Note prohibiting performance in Mode 1, 2, or 3. The Note is proposed to be modified to state that performance is normally prohibited in Mode 1, 2, or 3, but portions of the SR may be performed to reestablish operability provided an assessment determines the safety of the plant is maintained or enhanced.

(Insert 2)

Variations Exelon is proposing the following variations from the TS changes described in TSTF-283.

These variations do not affect the applicability of TSTF-283 or the NRC Staff's Safety Evaluation to the proposed license amendment.

The NMP2 TS contain a Surveillance Frequency Control Program. Therefore, the Surveillance Requirement Frequencies for TS 3.8 are "In accordance with the Surveillance Frequency Control Program."

The table below describes three additional variations from the approved traveler.

Numbering differences between the SRs at NMP and the NUREG-1433, Revision 4, (ISTS) format are described in Section 2.0 above and are not repeated here.

NMP2 TS SR requirement and reason for TSTF-283-A SR for BWR/4 change NMP2 TS do not have this SR as it is not part SR 3.8.1.8 - verify transfer between of the NMP2 design. Therefore this SR is not offsite power circuits.

being incorporated.

NMP2 TS equivalent is SR 3.8.1.17. The SR 3.8.1.19 - Verifies response to a NMP2 SR includes 3 additional requirements loss of offsite power signal and ECCS under sub-criteria c. These additional actuation signal.

requirements already in the NMP2 SR are not being changed and are being retained.

NMP2 TS SR 3.8.4.6 does not have the Note SR 3.8.4.6 - Verify Battery Charger prohibiting performance in modes 1, 2 or 3. performance.

Therefore, it is not included in the submittal.

This SR is included in Attachment 2 for completeness, but no changes are proposed.

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 4 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes There is a minor variation from TSTF-283 in the Bases. Eight of the twelve SRs identified above restrict their activity in Modes 1, 2, or 3 while the Bases Inserts provided in TSTF-283 identify Modes 1 and 2. These SRs are as follows:

SR Number Bases Insert No. SR Number Bases Insert No.

SR 3.8.1.9 2 SR 3.8.1.16 1 SR 3.8.1.11 1 SR 3.8.1.17 2 SR 3.8.1.14 1 SR 3.8.4.7 2 SR 3.8.1.15 2 SR 3.8.4.8 2 Therefore, the TS Bases markups for these SRs have the following statement, Applicability modified to include Mode 3. This is considered administrative in nature and has no effect on the adoption of TSTF-283.

3.0 TECHNICAL EVALUATION

Summary of the Approved Traveler Justification The proposed changes will reduce the potential for a plant shutdown should corrective maintenance (planned or unplanned) performed during power operation result in the need to perform any of the revised SRs to demonstrate operability.

The allowance to perform the SRs in currently prohibited Modes is restricted to only allow the SRs to be performed for the purpose of reestablishing operability (e.g. post-work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated operability concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed SR, a successful SR, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the SR; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the SR is performed. Risk insights or deterministic methods may be used for this assessment.

Note that the Maintenance Rule provision contained in 10 CFR 50.65(a)(4) states that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. This includes the performance of SRs to reestablish operability. Therefore, in addition to the assessment required by the SR Notes, an assessment of plant risk will also be performed.

Differences Between the Plant-Specific Justification and the Approved Traveler Justification The justification presented in the approved Traveler is applicable to NMP2. The Traveler is being adopted by NMP2 with no significant changes beyond those described above in Section 2.0.

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 5 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes NRC Approval The NRC implemented the approved Traveler through issue of Revision 2 of the ISTS NUREGs. NUREG-1433, Revision 4, was used for the ISTS SR numbers impacted.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

Appendix A to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, "General Design Criteria for Nuclear Power Plants," contains the following pertinent criteria:

Criterion 17, Electric Power Systems, states:

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed *and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Criterion 18, Inspection and Testing of Electric Power Systems, states:

Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring,

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 6 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

Title 10 of the Code of Federal Regulations (10 CFR), 10CFR 50.36(c)(3), states:

Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Regulatory Guide 1.9, "Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants" NMP2 is committed to Revision 3 (dated July1993) of this Regulatory Guide and complies with the EDG testing requirements for Single-Load and Full-Load Rejection Tests in accordance with Table 1, "Preoperational and Surveillance Testing" requirements.

The regulations do not specify details such as special Mode restrictions or allowing the crediting of unplanned events as satisfying a Surveillance Requirement. The proposed changes are consistent with NUREG-1433, Revision 4, and will continue to meet the intent of the General Design Criteria.

4.2 Precedent Two recent plant-specific NRC approvals of the changes in TSTF-283-A are Edwin I.

Hatch Nuclear Plant, Units 1 and 2, Amendment Numbers 279/223, dated September 29, 2016 (ADAMS Accession No. ML16231A041) (Reference 2), and Joseph M. Farley Nuclear Plant, Units 1 and 2, Amendment Numbers 203/199, dated August 3, 2016 (ADAMS Accession No. ML15233A448) (Reference 3).

4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon) requests adoption of TSTF-283-A, Revision 3, "Modify Section 3.8 Mode Restriction Notes", which is an approved change to the standard technical specifications (STS), into the Nine Mile Point, Unit 2 (NMP2) Technical Specifications. The proposed changes revise NMP2 Technical Specification (TS) 3.8.1, "AC Sources - Operating," and TS 3.8.4, "DC Sources- Operating," to allow certain Surveillance Requirements (SRs) to be performed, or portions thereof, in operating Modes which are currently restricted. The proposed changes reduce the potential for a plant shutdown should corrective maintenance (planned or unplanned) performed during

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 7 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes power operation result in the need to perform certain SRs to demonstrate operability.

The proposed changes also increase operational flexibility by including provisions to allow the crediting of unplanned events that satisfy the SRs.

Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes modify Mode restriction Notes to allow performance of the Surveillance in whole or in part to reestablish Emergency Diesel Generator (EDG)

Operability, and to allow the crediting of unplanned events that satisfy the Surveillances.

The EDGs and their associated emergency loads are accident mitigating features, and are not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. To manage any increase in risk, the proposed changes require an assessment to verify that plant safety will be maintained or enhanced by performance of the Surveillance in the current prohibited Modes. The radiological consequences of an accident previously evaluated during the period that the EDG is being tested to reestablish operability are no different from the radiological consequences of an accident previously evaluated while the EDG is inoperable. As a result, the consequences of any accident previously evaluated are not increased.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

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

Response: No.

The proposed changes do not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The changes do not alter the assumptions made in the safety analysis.

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

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

Response: No.

The purpose of Surveillances is to verify that equipment is capable of performing its assumed safety function. The proposed changes will only allow the performance of the Surveillances to reestablish Operability, and the proposed changes may not be used to remove an EDG from service. In addition, the proposed changes will potentially shorten

License Amendment Request Attachment 1 Modify Section 3.8 Mode Restriction Notes Page 8 of 8 Docket Nos. 50-410 Evaluation of Proposed Changes the time that an EDG is unavailable because testing to reestablish Operability can be performed without a plant shutdown. The proposed changes also require an assessment to verify that plant safety will be maintained or enhanced by performance of the Surveillance in the normally prohibited Modes.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

4.4 Conclusions Based upon the above, Exelon concludes that the proposed amendment 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.

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.

1.0 REFERENCES

1. Technical Specification Task Force (TSTF)-283-A, Rev 3, "Modification 3.8 Mode restriction Notes," approved April 13, 2000.

2. Letter from Nuclear Regulatory Commission (M. Orenak) to Southern Nuclear Operating Company (C. Pierce), "Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 -

Issuance of Amendments Regarding Multiple Technical Specification Changes," dated September 29, 2016 (CAC NOS. MF5026 and MF5027)

3. Letter from Nuclear Regulatory Commission (S. Williams) to Southern Nuclear Operating Company (C. Pierce), "Joseph M. Farley Nuclear Plant, Units 1 and 2 -

Issuance of Amendments Adopting 21 Previously NRC-Approved TSTF Travelers and One request not Associated with TSTF Travelers," dated August 3, 2016 (CAC NOS.

MF5317 and MF5318)

ATTACHMENT 2 License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket No. 50-410 Adoption of TSTF-283-A, Revision 3, "Modify Section 3.8 Mode Restriction Notes" Markup of Proposed Technical Specifications Pages TS Pages 3.8.1-8 3.8.1-9 3.8.1-10 3.8.1-11 3.8.1-12 3.8.1-13 3.8.1-15 3.8.1-16 3.8.1-17 3.8.4-3 3.8.4-4

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY normally SR 3.8.1.7 -------------------------------NOTES-----------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, Insert 1 C credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed within the power factor limit. However if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each required DG rejects a load In accordance with greater than or equal to its associated the Surveillance single largest post-accident load, and Frequency Control following load rejection, the frequency is Program 64.5 Hz for Division 1 and 2 DGs and 66.75 Hz for Division 3 DG.

(continued)

NMP2 3.8.1-8 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY normally SR 3.8.1.8 ----------------------------- NOTES ---------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, Insert 1 C credit may be taken for unplanned events that satisfy this SR.

2. If grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each required DG operating within In accordance with the power factor limit does not trip and the Surveillance voltage is maintained: Frequency Control Program

a. 4576 V during and following a load rejection of a load 4400 kW for Division 1 and 2 DGs; and

b. 5824 V during and following a load rejection of a load 2600 kW for Division 3 DG.

(continued)

NMP2 3.8.1-9 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 ----------------------------- NOTES ---------------------------

1. All DG starts may be preceded by an engine prelube period.

normally

2. This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3 DG). Insert 2 C However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of In accordance with offsite power signal: the Surveillance Frequency Control

a. De-energization of emergency buses; Program

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in 13.20 seconds,

2. energizes auto-connected shutdown loads for Division 1 and 2 DGs only, through the associated automatic load sequence time delay relays,

3. maintains steady state voltage 3950 V and 4370 V,

4. maintains steady state frequency 58.8 Hz and 61.2 Hz, and

5. supplies permanently connected and auto-connected shutdown loads for 5 minutes for Division 1 and 2 DGs and supplies permanently connected shutdown loads for 5 minutes for Division 3 DG.

(continued)

NMP2 3.8.1-10 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10 ----------------------------- NOTES ---------------------------

1. All DG starts may be preceded by an engine prelube period. normally

2. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3 DG). However, Insert 2 C credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Emergency In accordance with Core Cooling System (ECCS) initiation the Surveillance signal each required DG auto-starts from Frequency Control standby condition and: Program

a. In 10 seconds after auto-start, achieves voltage 3950 V for Division 1 and 2 DGs and 3820 V for Division 3 DG, and frequency 58.8 Hz for Division 1 and 2 DGs and 58.0 Hz for Division 3 DG;

b. Achieves steady state voltage 3950 V and 4370 V and frequency 58.8 Hz and 61.2 Hz;

c. Operates for 5 minutes;

d. Permanently connected loads remain energized from the offsite power system for Divisions 1 and 2 only; and

e. Emergency loads are auto-connected through the associated automatic load sequence time delay relays to the offsite power system for Divisions 1 and 2 only.

(continued)

NMP2 3.8.1-11 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY normally SR 3.8.1.11 ------------------------------- NOTE ----------------------------

This Surveillance shall not be performed Insert 1 in MODE 1, 2, or 3 (not applicable to Division 3 DG). However, C credit may be taken for unplanned events that satisfy this SR.

Verify each required DG's automatic trips In accordance with are bypassed on actual or simulated loss of the Surveillance voltage signal on the emergency bus Frequency Control concurrent with an actual or simulated ECCS Program initiation signal except:

a. Engine overspeed; and

b. Generator differential current.

(continued)

NMP2 3.8.1-12 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 ----------------------------- NOTES ---------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

normally

2. This Surveillance shall not be performed in MODE 1 or 2 unless the other two DGs are OPERABLE. If either of the other two DGs become Insert 1 inoperable, this Surveillance shall be suspended. However, C credit may be taken for unplanned events that satisfy this SR.

3. If grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each required DG operating within In accordance with the power factor limit operates for the Surveillance 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: Frequency Control Program

a. For 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 4620 kW and 4840 kW for Division 1 and 2 DGs, and 2730 kW and 2860 kW for Division 3 DG; and

b. For the remaining hours of the test loaded 3960 kW and 4400 kW for Division 1 and 2 DGs, and 2340 kW and 2600 kW for Division 3 DG.

(continued)

NMP2 3.8.1-13 Amendment 91, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 ------------------------------ NOTE ----------------------------

normally This Surveillance shall not be performed in Insert 1 MODE 1, 2, or 3 (not applicable to Division 3 DG). However, C credit may be taken for unplanned events that satisfy this SR.

Verify each required DG: In accordance with the Surveillance

a. Synchronizes with offsite power source Frequency Control while loaded with emergency loads upon Program a simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation.

normally SR 3.8.1.15 ------------------------------ NOTE ----------------------------

This Surveillance shall not be performed in Insert 2 MODE 1, 2, or 3 (not applicable to Division 3 DG). However, C credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode In accordance with and connected to its bus, an actual or the Surveillance simulated ECCS initiation signal overrides Frequency Control the test mode by: Program

a. Returning DG to ready-to-load operation; and

b. Automatically energizing the emergency load from offsite power.

(continued)

NMP2 3.8.1-15 Amendment 91, 133, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY normally SR 3.8.1.16 ------------------------------ NOTE ----------------------------

This Surveillance shall not be performed in Insert 1 MODE 1, 2, or 3. However, C credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load In accordance with block, for the Division 1 and 2 DGs only, the Surveillance is 90% of the design interval for each Frequency Control automatic load sequence time delay relay. Program (continued)

NMP2 3.8.1-16 Amendment 91, 152

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.17 ----------------------------- NOTES ---------------------------

1. All DG starts may be preceded by an engine prelube period. normally

2. This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3 DG).

Insert 2 However, C credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of In accordance with offsite power signal in conjunction with an the Surveillance actual or simulated ECCS initiation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in 10 seconds,

2. for Divisions 1 and 2, energizes auto-connected emergency loads through the associated automatic load sequence time delay relays and for Division 3, energizes auto-connected emergency loads,

3. maintains steady state voltage 3950 V and 4370 V,

4. maintains steady state frequency 58.8 Hz and 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for 5 minutes.

(continued)

NMP2 3.8.1-17 Amendment 91, 133, 152

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.6 Verify each required Division 1 and 2 In accordance with battery charger supplies 300 amps and the the Surveillance required Division 3 battery charger Frequency Control supplies 40 amps at 130 V for Program 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SR 3.8.4.7 ----------------------------- NOTES ---------------------------

1. The modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7 provided the modified performance discharge test completely envelops the service test. normally

2. This Surveillance shall not be Insert 2 performed in MODE 1, 2, or 3 (not applicable to Division 3). However, C credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to In accordance with supply, and maintain in OPERABLE status, the Surveillance the required emergency loads for the design Frequency Control duty cycle when subjected to a battery Program service test.

(continued)

NMP2 3.8.4-3 Amendment 91, 136, 152

Distribution Systems - Shutdown 3.8.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY normally SR 3.8.4.8 -------------------------------- NOTE -----------------------------

This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division 3).

Insert 2 However, C credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is 80% of the In accordance with manufacturers rating when subjected to a the Surveillance performance discharge test or a modified Frequency Control performance discharge test. Program AND 12 months when battery shows degradation or has reached 85%

of expected life with capacity

< 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturers rating NMP2 3.8.4-4 Amendment 91, 152

TSTF-283, Rev. 3 INSERT 1 However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

INSERT 2 However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

ATTACHMENT 3 License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket No. 50-410 Adoption of TSTF-283-A, Revision 3, "Modify Section 3.8 Mode Restriction Notes" Markup of Proposed Technical Specifications Bases Pages TS Bases Pages B 3.8.1-22 B 3.8.1-24 B 3.8.1-25 B 3.8.1-27 B 3.8.1-28 B 3.8.1-30 B 3.8.1-31 B 3.8.1-32 B 3.8.4-7 B 3.8.4-9

AC Sources - Operating 8 3.8.1 BASES SURVEILLANCE SR 3.8.1.7 REQUIREMENTS (continued) Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load without exceeding predetermined frequency and while maintaining a specified margin to the overspeed trip. The load referenced for Division 1 DG is the 1125 kW low pressure core spray pump; for Division 2 DG, the 750 kW residual heat removal (AHR) pump; and for Division 3 DG the 2435 kW HPCS pump. The specified load values conservatively bound the expected kW rating of the single largest loads under accident conditions. This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

Consistent with Regulatory Guide 1.9 (Ref. 11 ), the load rejection test is acceptable if the diesel speed does not exceed the nominal (synchronous) speed plus 75% of the difference between nominal speed and the overspeed trip setpoint, or 115% of nominal speed, whichever is lower.

This corresponds to ~ 64.5 Hz for the Division 1 and 2 DGs and ~ 66.75 Hz for the Division 3 DG, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems (this portion of Note 1 is not applicable to the Division 3 DG). Credit may be taken for unplanned events that satisfy this SR. In order to ensure that the DG is Bases Insert 1 (continued)

NMP2 B 3.8.1-22 Revision 0, 32 (A133), 35 (A138),

44 (A152)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.8 (continued)

REQUIREMENTS representative of the actual design basis inductive loading that the DG would experience.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems (this portion of Note 1 is not applicable to the Division 3 DG).

Credit may be taken for unplanned events that satisfy this SR.

Note 2 is provided in recognition that since the offsite electrical power transmission network is not balanced, it may not be Bases Insert 1 possible to raise DG voltage sufficiently to meet the power factor limit without one phase of the DG exceeding the current limit. Therefore, to ensure the DG is not placed in an unsafe condition during this test, the power factor limit does not have to be met if the offsite grid phase imbalance does not permit the power factor limit to be met when the DG is tied to the grid.

When this occurs, the power factor should be maintained as close to the limit as practicable.

SR 3.8.1.9 Consistent with Regulatory Guide 1.9 (Ref. 11 ),

paragraph C.2.2.4, this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads (Divisions 1 and 2 only) and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG auto-start and energization of permanently connected loads time of 13.20 seconds is derived from the 3.20 second Loss of Voltage - Time Delay Function Allowable Value (LCO 3.3.8.1) and the requirements of the accident analysis for responding to a design basis large break LOCA (Ref. 14).

The Surveillance should be continued for a minimum of (continued)

NMP2 B 3.8.1-24 Revision 0, 35 (A138), 44(A152)

AC Sources - Operating 8 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued)

REQUIREMENTS 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanently connected loads and auto-connected loads (Division 1 and 2 only) is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, systems are not capable of being operated at full flow, or AHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant (Division 1 and 2 DGs only) and lube oil being continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems (this portion of Note 2 is not applicable to the Division 3 DG).

Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 2. Applicability modified to include Mode 3.

SR 3.8.1.10 Consistent with Regulatory Guide 1.9 (Ref. 11 ), paragraph C.2.2.5, this Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (1 o seconds) from the design basis actuation signal (LOCA signal). In addition, (continued)

NMP2 B 3.8.1-25 Revision 0, 32 (A133), 35 (A138),

44 (A152}

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 (continued)

REQUIREMENTS this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems (this portion of Note 2 is not applicable to the Division 3 DG). Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 2 SR 3.8.1.11 Consistent with Regulatory Guide 1.9 (Ref. 11 ), paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ECCS initiation test signal and critical protective functions (engine overspeed and generator differential current) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the OBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note. The reason for the Note is that performing the Surveillance removes a required DG from service (this portion of the Note is not applicable to the Division 3 DG).

Bases Insert 1 Credit may be taken for unplanned events that satisfy this SR.

Applicability modified to include Mode 3. SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 11 ), paragraph C.2.2.9, this Surveillance requires demonstration that the DGs can start and run continuously at full lo~d capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of which is at a load equivalent to 90% to 100% of the continuous rating of the DG and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to 105% to 110% of the continuous rating of the DG. The DG starts for this Surveillance can be performed (continued)

NMP2 B 3.8.1-27 Revision 0, 35 (A138), 44 (A 152)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 (continued)

REQUIREMENTS either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed at a power factor as close to the accident load power factor as practicable. The power factor limit is ~ 0.91 for Division 1 and 2 DGs and s 0.93 for Division 3 DG. This power factor is representative of the actual design basis inductive loading that the DG could experience.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Similarly, momentary power factor transients above the limit do not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that would challenge continued steady state operation and, as a result, plant safety systems. However, it is acceptable to perform this SR in MODES 1 and 2 provided the other two DGs are OPERABLE, since a perturbation can only affect one divisional DG. If during performance of this Surveillance one of the other DGs becomes inoperable, this Surveillance is to be suspended.

Credit may be taken for unplanned events that satisfy this SR. Note 3 is provided in recognition that since the offsite electrical power transmission network is not balanced, it may not be possible to raise DG voltage Bases Insert 1 sufficiently to meet the power factor limit without one phase of the DG exceeding the current limit. Therefore, to ensure the DG is not placed in an unsafe condition during this test, the power factor limit does not have to be met if the offsite grid phase imbalance does not permit the power factor limit to be met when the DG is tied to the grid.

(continued)

NMP2 B 3.8.1-28 Revision 0, 32 (A133), 35 (A138),

44 (A152)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS and can receive an auto-close signal on bus undervoltage, and the individual load timers are reset.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems (this portion of the Note is not applicable to the Division 3 DG). Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 1 Applicability SR 3.8.1.15 modified to include Mode 3.

Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the parallel test mode override ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation signal is received during operation in the test mode.

Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

These provisions for automatic switchover are required by IEEE-308 (Ref. 17), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.10. The intent in the requirement associated with SR 3.8.1 .15.b is to show that the emergency loading is not affected by the DG operation in parallel test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

NMP2 B 3.8.1-30 Revision 0, 32 (A133), 35 (A138),

44 (A152)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.15 (continued)

REQUIREMENTS This SR has been modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems (this portion of the Note is not applicable to the Division 3 DG).

Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 2 Applicability SR 3.8.1.16 modified to include Mode 3.

Under accident conditions loads are sequentially connected to the bus by the automatic load sequence time delay relays.

The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The -10% load sequence time interval limit ensures that a sufficient time interval exists for the DG to restore frequency and voltage prior to applying the next load. There is no upper limit for the load sequence time interval since, for a single load interval (i.e., the time between two load blocks), the capability of the DG to restore frequency and voltage prior to applying the second load is not negatively affected by a longer than designed load interval, and if there are additional load blocks (i.e., the design includes multiple load intervals), then the lower limit requirements (-10%)

will ensure that sufficient time exists for the DG to restore frequency and voltage prior to applying the remaining load blocks (i.e., all load intervals must be

90% of the design interval). Reference 2 provides a summary of the automatic loading of emergency buses. Since only the Division 1 and 2 DGs have more than one load block, this SR is only applicable to these DGs.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance during these MODES would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 1 Applicability modified to include Mode 3. (continued)

NMP2 83.8.1-31 Revision 0, 28 (A129), 35 (A138),

44 (A152)

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.17 REQUIREMENTS (continued) In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.9, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. Since the Loss of Voltage - Time Delay Functions are bypassed during an ECCS initiation signal, a 1O second DG start time applies. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant (Division 1 and 2 DGs only) and lube oil being continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems (this portion of Note 2 is not applicable to the Division 3 DG). Credit may be taken for unplanned events that satisfy this SR.

Bases Insert 2 Applicability SR 3.8.1.18 modified to include Mode 3.

This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper frequency and voltage within the specified time when the DGs are started simultaneously.

(continued)

NMP2 B 3.8.1-32 Revision 0, 28 (A129), 35 (A138),

44 (A152)

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.6 (continued)

REQUIREMENTS is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensure that these requirements can be satisfied.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.4.7 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test provided the modified performance discharge test completely envelops the service test. This substitution is acceptable because a modified performance discharge test represents a more severe test of battery capacity than SR 3.8.4.7. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages.

Credit may be taken for unplanned events that satisfy the Surveillance.

(continued)

Bases Insert 2 Applicability modified to include Mode 3.

NMP2 B 3.8.4-7 Revision O, 34 (.A.136), 44 (A 152)

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.8 (continued) in the battery size calculation. A capacity of 80% shows that the battery is getting old and capacity will decrease more rapidly, even if there is ample capacity to meet the load requirements.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity ~ 100% of the manufacturer's rating. Degradation is indicated, consistent with IEEE-450 (Ref. 9), when the battery capacity drops by more than 10% of rated capacity in the previous 72 months or when it is below 90% of the manufacturer's rating. The 12 month frequency is consistent with the recommendations in IEEE-450 (Ref. 9). The 24 month Frequency is derived from Bases Insert 2 the recommendations of IEEE-450 (Ref. 9).

Applicability modified to include Mode 3. This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages.

Credit may be taken for unplanned events that satisfy the Surveillance.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, Revision O, March 10, 1971 .

3. IEEE Standard 308, 1974.

4. USAA, Section 8.3.2.

5. USAA, Chapter 6.

6. USAA, Chapter 15 and Appendix A.

7. 10 CFR 50.36(c)(2)(ii).

(continued)

NMP2 B 3.8.4-9 Revision 0, 34 (A136), 44 (A 152)

TSTF-283, Rev. 3 BASES INSERT 1 This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, at a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment.

BASES INSERT 2 This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, at a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.