ML19276G313

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Draft Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source
ML19276G313
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 10/02/2019
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Lee S
References
L-2019-LLA-0214
Download: ML19276G313 (52)
v • d • e


Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.91(a)(6)

October 2, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. NPF-59 NRC Docket No. 50-333

SUBJECT:

T Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source AF 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-59 for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed changes are being requested on an exigent basis pursuant to 10 CFR 50.91(a)(6).

The proposed change modifies the completion time for JAF TS 3.8.1, "AC Sources-Operating," Action A.3 from 7 days to 14 days.

D TS 3.8.1 will be entered at 0300 on October 3, 2019 to facilitate repair, and replacement if necessary, of the 71T-3 Reserve Station Service Transformer that is one of the station's R

qualified offsite circuits. The station has identified a degrading trend in the Total Dissolved Combustible Gas concentration (TDCG) indicating an elevated internal temperature. The source of the trend cannot be confirmed with the transformer in service. The total time to complete a replacement of the 71T-3 transformer is expected to take fourteen (14) days, including post-maintenance testing. This results in the Completion Time ending no later than 0259 on October 17, 2019. Without approval of the extension, JAF would need to shutdown based on the current Completion Time on October 10, 2019.

At this time, the most likely cause of the degrading trend is an overheating condition due to a high resistance mechanical connection internal to the transformer. A bounding schedule for a transformer replacement has been developed should discovery determine the extent of repairs warrant a complete replacement. The ability to replace the Reserve Station Service Transformer and perform acceptance testing results in the estimated October 17, 2019 return to service.

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

Emergency License Amendment Request One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source October 2, 2019 Page 2 The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon has reviewed the guidance provided in Branch Technical Position 8-8 of NUREG-0800, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions. This request follows that guidance with the exception that JAF does not have an alternate AC source. This is addressed in Section 4.0, Technical Evaluation. provides the evaluation of the proposed changes and justification for the need for the exigent LAR per 10 CFR 50.91(a)(6). Attachment 2 provides a copy of the marked-up TS pages that reflect the proposed changes.

Exelon requests approval of this exigent LAR by October 9, 2019 to support the currently planned repairs and restoration of the offsite source to Operable status.

T 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.

AF If you have any questions or require additional information, please contact Christian Williams at (610) 765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of October 2019.

Respectfully, DR David T. Gudger Acting Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1.

2.

3.

4.

Evaluation of Proposed Changes Markup of Proposed Technical Specifications Pages List of Affected Surveillance Requirements Assessment of Equipment affected by Surveillance Suspension cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - NMP "

NRC Project Manager, NRR - NMP "

A.L. Peterson, NYSERDA "

Emergency License Amendment Request One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source October 2, 2019 Page 3 bcc: Senior Vice President - Mid-Atlantic Operations w/o attachments Site Vice President - JAF "

Vice President, Licensing and Regulated "

Plant Manager - JAF "

Director, Operations - JAF "

Director, Site Engineering - JAF "

Director, Site Training - JAF "

Manager, Regulatory Assurance - JAF w/ attachments Senior Manager, Licensing, KSA "

Manager, Fuels, KSA "

C. Williams, KSA "

Commitment Coordinator - KSA "

Correspondence Control Desk - KSA "

T AF DR

ATTACHMENT 1 Emergency License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 EVALUATION OF PROPOSED CHANGES

Subject:

Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source 1.0

SUMMARY

DESCRIPTION 2.0 3.0 DETAILED DESCRIPTION TECHNICAL EVALUATION T 4.0 4.2 4.3 AF REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Precedent No Significant Hazards Consideration D

5.0 R

6.0 4.4 Conclusions ENVIRONMENTAL CONSIDERATION REFERENCES

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 1 of 13 Action A.3 Completion Time for an Inoperable Offsite Source 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-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes are being requested on an exigent basis pursuant to 10 CFR 50.91(a)(6). The reason that this License Amendment Request (LAR) is being submitted on an exigent basis and the justification why this situation could not be avoided is further discussed in Section 2 below.

The proposed change provides for a one-time modification of the completion time for JAF T

TS 3.8.1, "AC Sources-Operating," Action A.3 from 7 days to 14 days. This one-time extension is requested to facilitate replacement of the 71T-3 transformer due to a degrading trend in Total Dissolved Combustible Gas concentration (TDCG). The change also includes a one-time change the affected surveillances associated with protected equipment.

2.0 AF Exelon requests approval of this exigent LAR by October 9, 2019 to support the currently planned repairs and restoration of the offsite source to Operable status.

DETAILED DESCRIPTION The JAF Reserve Station Service Transformers 71T-2 and 71T-3 are the preferred independent offsite power sources to the redundant emergency buses 10600 and 10500 respectively. Each Reserve Station Service Transformer (RSST) is fed from the cross-tied DR 115 KV power lines Lighthouse Hill Line #3 and Nine Mile Point Line #4. Each of these offsite 115KV sources are capable of providing power to either division 1 or 2 busses through the respective RSST. The RSSTs are classified as non-safety related equipment.

While connected to the emergency buses, each of these offsite AC sources must be capable of maintaining rated frequency and voltage and accepting required loads during an accident.

Loss or degradation of normal AC power at the 4 KV level results in an automatic fast transfer or automatic residual transfer to the offsite AC power sources through the RSSTs 71T-2 and 71T-3. These transformers contain an On-Load Tap Changer to maintain the 4KV Bus voltages under various analyzed scenarios.

Upon loss of offsite power or failure of an RSST, the emergency bus undervoltage signal will start the Emergency Diesel Generators (EDGs) and the redundant EDG subsystems would automatically energize their respective emergency buses. Each of the EDGs have a continuous rating of 2600 kW and each of the diesel engines have a continuous brake horsepower rating of 3600 hp. Each diesel generator unit has an independent fuel oil system capable of providing fuel for seven (7) days of continuous operations.

The proposed change addresses a condition related to one of JAFs two offsite AC power sources. On 9/27/2019, it was identified that one of the Reserve Station Service

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 2 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes Transformers, 71T-3, was exhibiting elevated Total Dissolved Combustible Gas levels.

Both the installed Kelman Gas Analyzer and laboratory analysis of transformer oil samples have confirmed the elevated TDCG levels are rising. Entry into JAF TS 3.8.1 Required Action A.3 is anticipated in the near future to either repair or replace the degraded offsite AC power source 71T-3.

Implementation of this one-time TS change will support the expected duration of 14 days to repair the degraded RSST 71T-3.

Description of Events The 71T-3 Reserve Station Service Transformer is used for outage and accident scenarios to supply power to safety related loads. This can feed the 10100,10300, and on loss of offsite power.

T 10500 bus. If this transformer were to fail, while loaded the A and C EDGs would start On 09/27/2019, the 71T-3 Reserve Station Service Transformers Kelman Gas Analyzer indicated abnormal gas parameters. This is captured in the site Corrective Action Program AF under condition report (IR) 04282868. Subsequent to feedback received from the vendor, external temperatures on 71T-3 were obtained using an FLIR camera for comparison to the external temperatures on the opposite transformer, 71T-2. No obvious difference in temperatures were noted between the two transformers and no apparent thermal abnormalities existed.

An oil sample was taken on 9/27/2019 and analyzed on 9/28/2019 which confirmed an elevated TDCG level of 615 ppm, which is within the IEEE C57.104 Standards for Condition 1 TDCG parameters of less than or equal to 720 ppm. For comparison, TDCG DR in June of 2019 was 46 ppm. As of 1300 on 10/2/2019, TDCG is 2066 ppm.

Reason the Amendment is Requested on an Exigent Basis Elevated combustible gas presents two significant threats to a power transformer. The gas presents a combustion concern in that as concentration increases, the potential for combustion increases. It should be noted that the Headspace Flammability as of 1300 on October 2 is 15.9%.

The station action level to take the transformer out of service is based on minimizing the potential for combustion and this catastrophic failure. The second threat is the degradation itself. Elevated gas in transformer oil is due to an extreme temperature condition inside the transformer (arcing or a high resistance connection). The longer this condition exists, the greater the potential for significant damage. Exelon will proactively take this transformer out of service in order to eliminate the potential for catastrophic failure or further degradation.

Reason Exigent Situation Has Occurred A degrading trend (increasing concentration of TDCG) was first identified on September 27, 2019 and confirmed on September 28, 2019. There are no other indications of the

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 3 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes gassing or the apparent cause. Thus, the degrading trend is the first and only indication of a degrading condition with the transformer in service. The ability to repair or replace the damaged transformer results in the estimated October 19, 2019 return to service.

Reason the Situation Could Not Have Been Avoided This transformer has been in service since 2012. There has been no indication during testing or maintenance to indicate that a degrading gas trend would occur. Gas trending has been identified as a leading performance monitoring predictor of transformer failure.

Current TS:

Technical Specification (TS) Limiting Condition for Operation (LCO) 3.8.1 requires two (2)

T qualified circuits between the offsite transmission network and the plant Class 1E electrical power distribution system and two (2) emergency diesel generator (EDG) subsystems. Action Statement A.3 requires that if an offsite source is lost, it shall be returned to service within seven (7) days AND 21 days from discovery of failure to meet LCO.

AF Proposed TS Changes:

Exelon is requesting a one-time extension of the A.3 Required Action to restore the offsite source from seven (7) days AND 21 days from discovery of failure to meet LCO to fourteen (14) days AND 21 days from failure to meet LCO. This will be reflected as a footnote to TS LCO 3.8.1 A.3 Required Action.

The proposed footnote will read as follows:

DR

  • For the Division 1 offsite circuit only, the Completion Time that the subsystem can be inoperable as specified by Required Action A.3 may be extended beyond 7 days AND 21 days from discovery of failure to meet LCO to 14 days AND 21 days from discovery of failure to meet LCO to support repair and restoration of 71T-3 RSST. Upon completion of the repair and restoration, this footnote is no longer applicable and will expire at 0259 on October 17, 2019 In addition, affected Surveillance Requirements (SRs) associated with other in-service but protected equipment are requested to be suspended until completion of the required repairs. The specific surveillances as well as an assessment of the equipment is documented in attachments 3 and 4. The affected SRs will be annotated by a footnote as follows:

4.0 TECHNICAL EVALUATION

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 4 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes The AC Sources for the plant Class 1E AC Electrical Power Distribution System consist of the Main Generator (normal), 115 kV transmission network (reserve), 345 kV transmission network (backfeed, which is only available with the main generator offline and the links removed), and emergency diesel generators (EDGs) A, B, C, and D (onsite). As required by JAFNPP design criteria, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safeguards systems.

The offsite power source consists of two qualified circuits between the transmission network and the plant class 1E distribution system. 71T-3, Reserve Station Service Transformer T3 is a non-safety-related element of one of these circuits which allows connection of either incoming 115 kV transmission line with the safety-related 10500 4 kV emergency bus. The 10500 bus is one of two emergency buses, either of which will T

power all equipment required for safe shutdown of the plant or mitigation of an accident up to and including the design basis loss of coolant accident. The lines connecting the RSSTs to the 115kV transmission lines are arranged so that a failure of either line does not result in the loss of the other line. If the offsite sources were providing power to the emergency busses and were to fail, the EDG subsystems would automatically energize AF their respective buses. A qualified offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the 115 kV transmission network source to the plant Class 1E emergency bus or buses.

With 71T-3 out of service for maintenance, redundancy of the emergency power system is reduced, and compliance with the intent of General Design Criteria requiring demonstration of the ability to maintain certain safety functions solely with offsite power and accommodating a single failure of safety-related equipment is not assured.

DR The limiting analyzed Loss of Coolant Accident for JAF is a double-ended guillotine break of a Reactor Water Recirculation system suction line with a passive failure of a Station Battery (Design Basis Accident Loss of Coolant Accident, DBA LOCA). For a DBA LOCA with only offsite power available through the remaining transformer, 71T-2, Reserve Station Service Transformer T2, the LOCA analysis is dependent on the full complement of equipment served by the 10600 bus. Therefore, the intent of GDCs which include both a power source dependence (offsite or onsite) and accommodation of single failure are not satisfied. This configuration exists any time that condition A or B of LCO 3.8.1 is in effect. With these conditions, a single failure of the other offsite circuit or the other EDG subsystem results in an inability to satisfy the GDC requirement that certain functions be maintained by the offsite power source acting alone or the onsite power source acting alone. The requirements for electric power sources within these criteria are independent of the requirement for single-failure. Although the GDC intent are not met, there is significant redundancy in the plant design. With 71T-3 out of service, the 10500 bus may be supplied by the pair of 93EDG-A and 93EDG-C and the 10600 bus may be supplied by either the pair of 93EDG-B and 93EDG-D or by either offsite 115kV source through 71T-2.

For an event other than a LOCA, there is additional redundancy since only a single Residual Heat Removal (RHR) pump is required for Reactor Pressure Vessel (RPV) injection after the vessel is depressurized and a single RHR Service Water pump

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 5 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes required to transfer decay heat to the Ultimate Heat Sink as a limiting case with a substantial reduction in loading of the emergency buses and manual, rather than automatic sequencing of loads. In this case any of the four EDGs may supply the loads necessary for RPV injection and decay heat removal along with associated supporting system loads (cooling for safety related pumps and Standby Gas Treatment system operation to control Secondary Containment parameters). Prior to RPV depressurization, the Reactor Core Isolation Cooling (RCIC) system or the High Pressure Core Injection system may be used for RPV water level control, and RHR for decay heat removal as heat from the fuel is transferred to the suppression pool by the HPCI or RCIC exhaust and operation of Main Steam Safety Relief Valves (SRVs).

With the plant in power operation, electrical loads are normally supplied from the Main Generator through 71T-4, Normal Station Service Transformer T4. In the event of plant T

shutdown with 71T-3 out of service, loads will be manually or automatically transferred to 71T-2, and if the transfer fails, select loads will be placed on the EDGs. A similar sequence occurs for a LOCA, except in this instance, the EDGs automatically start on the LOCA signal in anticipation of being loaded if the bus transfer to the reserve transformers fails. With the plant is out of service and 71T-3 de-energized, only half of the normal AF buses are energized (the 10100 and 10300 buses are powered from 71T-3 and will also be out of service). While no manual or automatic transfer to offsite power is required since available electrical buses will already be shifted to an offsite supply through 71T-2, the emergency power system will be in an abnormal lineup. In this case, the 10500 bus must either be supplied by the associated EDGs or maintained de-energized. If energized by the EDGs, safety-related 10500 bus loads would require operation to ensure reliable engine operation. This abnormal operating condition may be precluded by maintaining the plant on-line with power supplied through 71T-4 during the period that 71T-3 is maintained.

DR Plant response to a Station Blackout (SBO) is not significantly affected by removal of 71T-3 from service. JAF does not credit any offsite power source or the EDGs for maintaining plant safety during its four-hour coping time. The only effect is the number of potential sources of AC power available at the end of the coping period. With 71T-3 out of service, 71T-2 is required to restore AC power from either of the 115 kV lines serving the station. There is no impact on any of the four EDGs that may be available to restore power to required safe shutdown loads. If the SBO was caused by a fault in 71T-2, restoration of an EDG is required to restore power to the station. The EDGs and their supporting equipment will be protected during the extended completion time, further assuring their availability to mitigate this event.

A completion time of 14 days to restore 71T-3 to service following maintenance is analogous to the currently permitted completion time for restoration of one pair of EDGs (TS 3.8.1 Required Action B.4) with the exceptions that the reserve transformer is not a safety-related component and power from the transformer is passed through an additional bus (10300) prior to reaching the emergency bus and thus marginally less resilient.

Status of 71T-2, Reserve Station Service Transformer:

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 6 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes A review of all past, present and future Work Orders (WOs) associated with the 71T-2 RSST as listed in Passport was conducted. The results show that all WOs that were not Cancelled or Closed were either associated with installation of a Station Modification or a Preventive Maintenance Activity. These results support there are no outstanding Corrective Maintenance Work Orders to resolve a deficiency with 71T-2 and there is no adverse trend in prior maintenance history for 71T-2.

A review of the Corrective Action Program database was performed over the past 2 years and there were no conditions adverse to quality identified.

A review of PDS data for the 71T-2 Kelman Gas Analyzer was conducted and identified that there are no adverse trends. There have been no indications that are in alarm or alert range and all the oil-immersed gases are well below IEEE C57.104 standard levels of concern and are stable.

T Based upon the review of maintenance history, corrective action program and available trending there is reasonable assurance of the health of 71T-2.

AF Summary of Surveillances affected:

During the extended period of the TS 3.8.1, Required Action A.3, there are ten (10) surveillance test procedures that would be required to be performed on protected equipment per the current frequency. Exelon is requesting that these surveillances be suspended during the extended period. Attachment 2 contains a markup of the TS Surveillance Requirement (SR) Pages, annotated with a note stating when the past due Surveillances will be completed.

DR A review of the test procedures was conducted, looking back at two (2) years of data.

Several tests will use the provisions of TS SR 3.0.2 for applying 25% grace to schedule testing outside of the extended duration, when needed. A number of these surveillance tests do not affect the operability of the equipment during the performance of the testing.

Other scheduled surveillance tests will require declaring the tested Structure, System, and Component (SSC) inoperable during performance of the tests. All of the surveillance tests required to be completed during this extended duration have applied the 25% grace period allowed by SR 3.0.2.

A list of the affected SRs is provided in Attachment 3.

A review of IRs written in the past 24 months was performed to assess the overall health of the protected equipment. This assessment is documented in Attachment 4.

RISK INSIGHTS:

This license amendment request is not a risk-informed request and, therefore, a risk evaluation is not required. However, to provide additional information, EGC is providing risk insights related to the proposed change.

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 7 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes Although this technical analysis is based on a deterministic evaluation, a risk analysis was performed that demonstrated with reasonable assurance that the proposed TS changes are within the current risk acceptance guidelines in RG 1.177 for one-time changes with substantial margin. This ensures that the TS change meets the intent of the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) acceptance guidelines of 1.0E-05 and 1.0E-06 established for compatibility with the ICCDP and ICLERP limits of RG 1.177, which is applicable for configuration changes that require normal work controls. This acceptance guideline requires compensatory measures be implemented during the extended CT, which are discussed below. The risk analysis was based on the ICCDP and ICLERPs for the unavailability of the 71T-3 Reserve Station Service Transformer, which represents the plant configuration during the repair and/or replacement of the transformer. No credit for additional proposed risk management actions (RMAs) was given in the risk analysis. All T

work will be performed within normal Work Control risk activities.

The identification of the RMAs was derived from a detailed review of the results of the risk assessment. None of the RMAs were credited in the base risk analysis; the identified compensatory actions would further lessen the overall risk incurred during the extended AF periods. The additional compensatory actions that are outlined below provide additional assurance that the risk during the extended allowed outage time will be minimized.

COMPENSATORY MEASURES:

The following Compensatory Measures have been put in place to provide additional defense in depth during the extended out of service time:

  • off-site power lines Lighthouse Hill Line #3 and Nine Mile Point Line #4 and associated cross-tie disconnect will be protected The NORMAL STATION SERVICE TRANSFORMER 71T-4 will be protected The A, B, C and D Emergency Diesel Generator subsystems and their associated cooling water pumps with their respective power supplies will be protected.

The 4160V emergency buses 10500 and 10600 will be protected.

HPCI and RCIC will be protected.

  • Both trains of RHR and CSP will be protected.
  • 125 VDC station batteries and associated battery chargers will be protected
  • A and B LPCI batteries will be protected
  • The on-shift operating crew will review the following procedures:

o 115KV Grid Loss, Instability, or Degradation including plant shutdown with no off-site power available (AOP-72)

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 8 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes o Station Blackout (AOP-49)

  • Non-essential switchyard and transformer yard activities will be deferred.
  • Non-essential surveillances or other maintenance activities on other risk significant equipment, such as the EDGs, the ECCS systems, HPCI, and RCIC will be deferred.
  • The grid operator has been requested to restrict maintenance and switching operations on the following lines to emergency operations only:

o o

o T

115kV Lighthouse Hill Line #3 115kV Nine Mile Point Lines #1 and #4 345kV lines #1 and #10 AF Risk Significant Fire Zones will be toured by plant operators a minimum of three times per shift (once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) to ensure adequate controls are in place for transient combustibles, hotwork, and ignition sources. Additionally, operators will review readiness and accessibility of fixed fire suppression systems, fire barriers including fire doors and dampers, and manual fire suppression features.

Risk Significant Fire Zones:

DR CS-1 RR-1 CR-1 RB-1B Fire Zone EG-1, EG-2, EG-5 RB-1E Cable Spreading Room Relay Room Description Main control room or control room Reactor building westside (elevation 272) and southwest quadrant (elevation 300)

Trains A and C EDG switchgear room south (elevation 272)

Reactor building east crescent (elevations 227 and 242)

CT-1 West cable tunnel TB-1 Turbine building/relay room EG-3, EG-4, EG-6 Trains B and D EDG switchgear room north (elevation 272)

CT-3 South cable tunnel/relay room

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 9 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements from following current applicable regulatory requirements, which were reviewed in making this determination:

10 CFR 50.36, Technical Specifications:

10 CFR, Section 50.36, "Technical specifications," in which the Commission established T

its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility."

The proposed change does not affect compliance with these regulations.

AF 10 CFR 50.63. Loss of all alternating current:

10 CFR 50.63 requires that light-water-cooled nuclear power plants licensed to operate be able to withstand for a specified duration and recover from an SBO. The proposed changes do not alter JAFs duration (coping time) nor affect its compliance with the intent of 10 CFR 50.63.

10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants:

DR 10 CFR 50.65 requires that performing maintenance activities (including but not limited to surveillance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structured, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety. The proposed maintenance activities associated with this project will be assessed and the increased risk will be managed in accordance with 10 CFR 50.65 (a)(4). The proposed changes do not affect JAFs compliance with the intent of 10 CFR 50.65.

10 CFR 50 Appendix A:

The applicable 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," was considered as follows:

General Design Criterion 17 - Electric Power Systems:

GDC 17 requires an onsite electric power system and an offsite electric power system shall be provided to permit the functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 10 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes 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 T

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 AF 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.

The impact of this change on the intent of GDC-17 is discussed in the Technical DR 5.2 Evaluation of this document.

Precedent

1. Letter from NRC to Palo Verde Nuclear Generating Station, Unit 3, Issuance of Amendment Regarding Revision to Technical Specification 3.8.1, "AC [Alternating Current] Sources - Operating" (Emergency Circumstances), dated December 23, 2016, (ADAMS Accession Number ML16358A676)
2. Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements (ADAMS accession number ML17326B619) 5.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon) requests a one-time change to the Completion Time for TS 3.8.1, Action A.3. The proposed change increases the Completion Time from 7 days to 14 days to allow for required repairs to the JAF 71T-3

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 11 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes Reserve Transformer.

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 involve a one-time extension to the Completion Time for Technical Specification 3.8.1, Action.A.3 to allow necessary time to repair Reserve T

Station Service Transformer (RSST) 71T-3.

With 71T-3 out of service for non-elective maintenance as an initial condition, the only accident with a changed probability of occurrence is the Loss of Power to Auxiliaries.

In this case, a single fault in the remaining RSST (71T-2) will result in a loss of offsite AF power (LOOP). The use of compensatory measures such as protecting 71T-2 and the 115 kV switchyard will preclude a significant increase in the probability of total loss of the offsite power source. The proposed amendment has no effect on the consequences of a LOOP, since the emergency diesel generators (EDGs) provide power to safety related equipment following a LOOP. The design and function of the EDGs are not affected by the proposed change.

The probability of other previously evaluated accidents is not affected, since initiation of these events is not dependent on changes in status of the electrical power supply DR (these are events such as positive reactivity insertion or breaks in the Reactor Coolant Pressure Boundary). As discussed previously, 71T-3 maintenance eliminates redundancy in the emergency power system when it is supplied from offsite sources.

Sufficient capacity is available in the redundant 10600 bus supplied by 71T-2 to mitigate the consequences of all analyzed accidents.

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 amendment involves maintenance of an electrical transformer that provides offsite power to safety-related equipment for accident mitigation. The proposed change does not alter the design, physical configuration, or mode of operation of any other plant structure, system, or component. No physical changes are being made to any other portion of the plant, so no new accident causal mechanisms are being introduced. The proposed change to the completion time for 71T-3 maintenance does not result in any new mechanisms that could initiate damage to the reactor or its principal safety barriers (i.e., fuel cladding, reactor coolant system, or primary containment).

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 12 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes 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 proposed amendment increasing the completion time for 71T-3 maintenance reduces the margin of safety for accident mitigation by removing redundancy in the offsite power source (i.e., only one emergency power bus may be supplied from offsite sources during this maintenance window). There is no reduction in margin available in each power supply since they are not altered by this change. As stated previously the reduction in margin is not significant due to compensatory measures T

that will be in place during the extended completion time.

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

5.4 6.0 Conclusions AF 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.

ENVIRONMENTAL CONSIDERATION DR 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.

7.0 REFERENCES

1. FE-1F 4160V One Line Diagram Bus 10300
2. FE-1G 4160V One Line Diagram Bus 10400
3. JAF Drawing 1.22-101 Reserve Station Service Transformer Nameplate 71T-2 Drawing
4. JAF Drawing 1.22-106 Reserve Station Service Transformer Schematic Output Signals

Emergency License Amendment Request Attachment 1 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 13 of 13 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes

5. JAF Drawing 1.22-117 Reserve Station Service Transformer Nameplate 71T-3 Drawing
6. JAF Drawing 1.22-118 Reserve Station Service Transformer Bill of Material Drawing
7. Siemens Instruction Manual S838-0001 Vendor Manual for JAF Reserve Station Service Transformers
8. JAF Operating Procedure OP-44 115kV System
9. JAF Operating Procedure OP-46A 4160V and 600V Normal AC Power Distribution
10. JAF Technical Specifications Bases
11. JAF Technical Specifications
12. IEEE C57.104 IEEE Guide for the Interpretation of Gases Generated in Oil-Immersed Transformers T

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ATTACHMENT 2 Emergency License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source Markup of Proposed Technical Specifications Pages T

TS LCO Page 3.8.1-2 TS SR Pages AF 3.3.5.1-7 3.4.7-2 3.4.8-1 3.5.1-3 3.5.1-4 3.5.1-5 3.5.1-6 3.5.2-5 DR 3.5.2-6 3.5.3-2 3.6.1.3-8 3.6.1.9-2 3.6.2.1-3 3.6.2.3-2 3.7.1-2 3.7.2-4 3.8.1-5 3.8.1-6 3.8.3-2 3.8.3-3 3.8.4-3 3.8.4-4 3.8.5-2 3.8.6-2 3.9.7-2 3.9.8-2

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  • For the division 1 offsite circuit only, the Completion Time that the subsystem can be inoperable as specified by Required Action A.3 may be extended beyond the 7 days to 14 days to support repair and restoration of the 71T-3 RSST. Upon completion of the repair and restoration, this footnote is no longer applicable and will expire on October 19, 2019.

T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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T AF Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window DR

T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window R

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T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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T AF DR Following return to service of 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional Window

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Emergency License Amendment Request Attachment 3 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 1 of 4 Action A.3 Completion Time for an Inoperable Offsite Source List of Affected Surveillance Requirements ATTACHMENT 3 Emergency License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 T

Action A.3 Completion Time for an Inoperable Offsite Source List of Affected Surveillance Requirements AF For the following surveillance tests and associated surveillance requirements coming due that require testing or declaring protected SSCs inoperable, Exelon requests a suspension beyond their required surveillance interval:

Procedures Impacted:

ISP-6A RHR/LPCI POMP DISCHARGE PRESSURE INTERLOCK INSTRUMENT CHANNEL A FUNCTIONAL TEST/CALIBRATION D

R ST-9BA EDG A AND C FULL LOAD TEST AND ESW PUMP OPERABILITY TEST ST-9AA EDG SYSTEM A FUEL/LUBE OIL MONTHLY TEST ST-24A RCIC MONTHLY OPERABILITY TEST ST-3AA CORE SPRAY LOOP A MONTHLY OPERABILITY TEST ST-2AM RHR LOOP B QUARTERLY OPERABILITY TEST ST-2AN RHR LOOP A MONTHLY OPERABILITY TEST ST-4N HPCI QUICK-START, INSERVICE, AND TRANSIENT MONITORING TEST MST-071.10 LPCI BATTERY SURVEILLANCE TEST MST-071.12 125VDC STATION BATTERY AND CHARGER WEEKLY SURVEILLANCE TEST Technical Specification (TS) Surveillance Requirements (SRs) Impacted:

  • SR 3.4.7.1 (ST-2AN) Verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.

Emergency License Amendment Request Attachment 3 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 2 of 4 Action A.3 Completion Time for an Inoperable Offsite Source List of Affected Surveillance Requirements

  • SR 3.4.8.1 (ST-2AN) Verify each RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.
  • SR 3.5.1.2 (ST-3AA, ST-2AN, ST-4N(HPCI), ST-2AM) Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

T SR 3.5.1.8 (ST-4N) Verify, with reactor pressure < 1040 psig and > 970 psig, the HPCI pump can develop a flow rate > 3400 gpm against a system head corresponding to reactor pressure.

SR 3.5.1.9 (ST-4N) Verify, with reactor pressure < 165 psig, the HPCI pump can develop a AF flow rate > 3400 gpm against a system head corresponding to reactor pressure.

SR 3.5.2.4 (ST-3AA, ST-2AN, ST-2AM) Verify, for the required ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.5 (ST-3AA, ST-2AN, ST-2AM) Verify, for the required ECCS injection/spray subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed or otherwise secured in position, is in the correct position.

SR 3.5.2.6 (ST-2AM) Operate the required ECCS injection/spray subsystem through the D

  • R recirculation line for > 10 minutes SR 3.5.3.1 (ST-24A) Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.3.2 (ST-24A) Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.6.1.3.5 (ST-2AM, ST-4N(HPCI)) Verify the isolation time of each power operated, automatic PCIV, except for MSIVs, is within limits.

  • SR 3.6.1.9.1 (ST-2AN) Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
  • SR 3.6.1.9.2 (ST-2AM) Verify each required RHR pump develops a flow rate of > 7750 gpm through the associated heat exchanger while operating in the suppression pool cooling mode.
  • SR 3.6.2.1.1 (ST-4N) Verify suppression pool average temperature is within the applicable limits.

Emergency License Amendment Request Attachment 3 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 3 of 4 Action A.3 Completion Time for an Inoperable Offsite Source List of Affected Surveillance Requirements

  • SR 3.6.2.3.1 (ST-2AN, ST-2AM) Verify each RHR suppression pool cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
  • SR 3.6.2.3.2 (ST-2AM) Verify each required RHR pump develops a flow rate > 7700 gpm through the associated heat exchanger while operating in the suppression pool cooling mode.
  • SR 3.7.1.1 (ST-2AN) Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
  • SR 3.7.2.7 (ST-9BA) Verify each ESW subsystem actuates on an actual or simulated initiation signal.

T SR 3.8.1.2 (ST-9BA) Verify each EDG subsystem starts from standby conditions, force parallels, and achieves:

kW and < 2600 kW. AF o In < 10 seconds, voltage > 3900 V and frequency > 58.8 Hz; and o Steady state voltage > 3900 V and < 4400 V and frequency > 58.8 Hz and < 61.2 Hz.

SR 3.8.1.3 (ST-9BA) Verify each EDG subsystem is paralleled with normal, reserve, or backfeed power and each EDG is loaded and operates for > 60 minutes at a load > 2340 SR 3.8.1.4 (ST-9AA) Verify each day tank contains >/= 327 gal of fuel oil.

SR 3.8.1.5 (ST-9AA) Check for and remove accumulated water from each day tank SR 3.8.1.6 (ST-9BA) Verify that each EDG fuel oil transfer system operates to automatically transfer fuel oil from its storage tank to the associated day tank.

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SR 3.8.3.1 (ST-9AA) (for EDG Fuel Oil Storage Volume) Verify each fuel oil storage tank contains > a 7-day supply of fuel.

SR 3.8.3.2 (ST-9AA) Verify lube oil inventory of each EDG is > a 7-day supply.

SR 3.8.3.4 (ST-9BA) Verify Each EDG required air start receiver pressure is > 150 psig.

SR 3.8.4.1 (MST-071.10, MST-071.12) Verify battery terminal voltage on float charge is:

a. >127 .8 VDC for 125 VDC batteries, and
b. > 396.2 VDC for 419 VDC LPCI MOV independent power supply batteries.

128 VDC for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. OR Verify each 125 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

  • SR 3.8.4.3 (MST-071.12) Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test or a modified performance discharge test.

Emergency License Amendment Request Attachment 3 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 4 of 4 Action A.3 Completion Time for an Inoperable Offsite Source List of Affected Surveillance Requirements subjected to a performance discharge test or a modified performance discharge test.SR 3.8.5.1 (MST-071.12) For DC electrical power subsystem required to be OPERABLE the following SRs are applicable: SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4

  • SR 3.9.7.1 (ST-2AN) Verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.

secured in position, is in the correct position, or can be aligned to the correct position.

AF DR

Emergency License Amendment Request Attachment 4 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 1 of 3 Action A.3 Completion Time for an Inoperable Offsite Source Assessment of Equipment affected by Surveillance Suspension ATTACHMENT 4 Emergency License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source T

Assessment of Equipment affected by Surveillance Suspension ISP-6A: No IRs written in the past 24 months and no adjustments required.

AF ST-9BA: One IR written for one for no reading displayed for 93PYRO-1A IR 4222368. This equipment is not required for OPERABILITY or to meet a required Tech Spec surveillance.

One IR written 4/18/19 for C EDG Cylinder exhaust Temp Differential Reading out of spec IR 4241252 The condition described has no adverse effect on the safety-related design function of the C-EDG. This temperature indicator provides indication only. There are no automatic actions or protective features provided by this indicator. Per the vendor manual, the maximum allowed cylinder temperature is 1256F, and that value was not approached. The maximum values for channels 12, 13, and 14 have not risen since the previous IR4162122 was initiated. The D

differential limit of 200F is a combination of Channel 12 at 1058F and Channel 5 at 844 F (Nominal Range 800F-1000F; Max= 1075F). Proper C-EDG operation was noted for the R

duration of the one hour, fully loaded EDG run during performance of ST-9BA. The surveillance met all Level 1 and Level 2 Acceptance Criteria. This does not impact the reasonable assurance to meet the requested extension for SR 3.8.1.2, 3.8.1.3, 3.8.1.6, 3.8.3.4, or 3.7.2.7.

One IR 4207510 written 1/2/19 During performance of ST-9BA EDG A and C full load test.

Annunciator HV-9A-09 supply fan FN-1C trouble, alarmed numerous times. Operators verified that 92FN-1C was in-service and EDG room temperature was <120 degF. Actual room temp was 78 deg F. Repeat occurrence reference IR 03997501, 4098281, 4072267 and CR-JAF-2016-5255. Acceptance Criteria step 10.1.8 were met based on the following description: the ventilation system remains operable even upon receipt of a ventilation trouble alarm as long as the white vibration light for the supply fan remains clear, the associated room temperature remains below 120 deg F, and Air was flowing into the EDG room from the associated supply fan. These conditions remained met throughout the performance of the test. The 'C' EDG Ventilation system performed its design function to support the 'C' EDG Subsystem. This does not impact the reasonable assurance to meet the requested extension for SR 3.8.1.2, 3.8.1.3, 3.8.1.6, 3.8.3.4, or 3.7.2.7.

Emergency License Amendment Request Attachment 4 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 2 of 3 Action A.3 Completion Time for an Inoperable Offsite Source Assessment of Equipment affected by Surveillance Suspension One IR 4171161 written 9/9/18 Upstream flange of 46RO-102A EMERGENCY DIESEL GENERATOR A JACKET WATER COOLER ESW OUTLET RESTRICT Orifice west side bolt has a 5 drop per minute leak when the system is in operation. The deficiency described, 5 dpm leak on ESW to A EDG, does not render the EDG or ESW inoperable as the leak is small relative to the normal pump and system capacity. The leak is on a mechanical joint, not a through wall leak, thereby ensuring that a rapid degradation is unlikely. This does not impact the reasonable assurance to meet the requested extension for SR 3.8.1.2, 3.8.1.3, 3.8.1.6, 3.8.3.4, or 3.7.2.7.

ST-9AA: One IR written to document A EDG lube oil sump level not meeting level 2 acceptance criteria. On 3/18/19 during ST-9AA A EDG lube oil sump level was discovered to be -1.5". level 2 acceptance criteria require greater than or equal to -1". IR 4230569 This was following a one hour loaded run. Lube oil levels are monitored during runs and lube oil can be added to a extension for SR 3.8.3.2.

T running EDG if required. This does not impact the reasonable assurance to meet the requested One IR written to document A EDG lube oil sump level not meeting level 2 acceptance criteria.

AF On 10/11/18 during ST-9AA C EDG lube oil sump level was discovered to be -1.5". level 2 acceptance criteria require greater than or equal to -1". IR 4182558. This was following a one hour loaded run. Lube oil levels are monitored during runs and lube oil can be added to a running EDG if required. This does not impact the reasonable assurance to meet the requested extension for SR 3.8.3.2.

ST-24A: One IR written when credited to ST-24J under WO 4652731 for unable to obtain vibration data due to failure of test equipment that does not impact the ability to meet SR 3.5.3.1 or SR 3.5.3.2.

D One IR written when credited to ST-24J under WO 4753562 for unable to obtain vibration data due to failure of test equipment that does not impact the ability to meet SR 3.5.3.1 or SR R

3.5.3.2.

One IR written when credited to ST-24J under WO 4680827 for discharge piping vent per section 8.1.6 a vent time of 4.0 seconds was recorded as stated in IR 4082609. The vented volume was mostly water and the time reflects intermittent bubbles until a clear continuous flow was observed. The 4 seconds of air venting identified is less than both Level 1 Acceptance Criteria (11.3 sec.) and Level 2 Acceptance Criteria (9.0 sec.); therefore, no degraded condition exists. This IR was initiated for trending only and does not impact the reasonable assurance to meet for the requested extension for SR 3.5.3.1 or SR 3.5.3.2.

ST-3AA: Only one IR documented in 24 months when credited to ST-3PA for not completing section 8.3 for the hold pump. Section 8.3 does not impact SR 3.5.1.1, 3.5.1.2, 3.5.2.4, or 3.5.2.5. and failure to perform that section only impact level 2 acceptance criteria for ST-3PA only.

MST-071.10: IR 4166504 was written on August 22, 2018 to document that equalizing charges were not working. It was determined that the equalizing charge setpoint was below the lower limit for equalizing voltage. Procedure was lacking in clarity on what to set equalizing voltage.

Emergency License Amendment Request Attachment 4 Exigent License Amendment Request - One Time Extension to the TS 3.8.1 Page 3 of 3 Action A.3 Completion Time for an Inoperable Offsite Source Assessment of Equipment affected by Surveillance Suspension MST-071.12: IR 4248526 was written on May 12, 2019 to document a particle in station battery B, cell #59. Based on review of particle it was determined to be sulfation which was a normal process that occurs in battery based on vendor input.

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