Text

Proposed Changes to Enclosure 2 Volume 13, ITS Section 3.8 Electrical Power Systems, of the Improved Technical Specification Conversion License Amendment Request
	ML24291A059
Person / Time
Site:	Hope Creek
Issue date:	10/17/2024
From:	; Public Service Enterprise Group
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML24291A058	List: LR-N24-0062, Proposed Changes to Enclosure 2 Volume 13, ITS Section 3.8 Electrical Power Systems, of the Improved Technical Specification Conversion License Amendment Request; ML24291A057;
References
	LR-N24-0062, LAR H24-02
	Download: ML24291A059 (1)
	v • d • e

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES A.C. SOURCES - OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b.

Four separate and independent diesel generators, each with:

1.

A separate fuel oil day tank containing a minimum of 360 gallons of fuel,

2.

A separate fuel storage system consisting of two storage tanks containing a minimum of 44,800 gallons of fuel, and

3.

A separate fuel transfer pump for each storage tank.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

Note: LCO 3.0.4.b is not applicable to DGs.

a.

With one offsite circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the inoperable offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With one diesel generator of the above required A.C. electrical power sources inoperable,

1.

Demonstrate the OPERABILITY of the above required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.4 separately for each diesel generator within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s*

unless the absence of any potential common mode failure for the remaining diesel generators is demonstrated.

This test is required to be completed regardless of when the inoperable diesel generator is restored to OPERABILITY.

HOPE CREEK 3/4 8-1 Amendment No. 188 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 A03 A04 See ITS 3.8.1 When associated EDG is required to be OPERABLE.

Add proposed LCO 3.8.3 Applicability See ITS 3.8.1 A02 Add proposed ACTIONS Note Add proposed ACTIONS C and D Add proposed ACTIONS A and E Add proposed ACTION B Add proposed ACTION F M01 M01 L01 L02 See ITS 3.8.1 a 7 day total supply of fuel for three EDGs in MODES 1, 2, and 3, and 7 day total supply of fuel oil for required EDGs in other than MODES 1, 2, and 3.

SR 3.8.3.1 A02 See ITS 3.8.1 L01 L02 ITS A01 ITS 3.8.3 S1

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be:

a.

Determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability, and

b.

Demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program during shutdown by transferring, manually and automatically, unit power supply from the normal circuit to the alternate circuit.

4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE: *

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying the fuel level in the fuel oil day tank.

2.

Verifying the fuel level in the fuel oil storage tank.

3.

Verifying the fuel transfer pump starts and transfers fuel from the storage system to the fuel oil day tank.

4.

Verifying each diesel generator starts** from standby conditions and achieves steady state voltage 3828 and 4580 volts and frequency of 60 + 1.2 Hz.

5.

Verifying the diesel generator is synchronized, loaded to between 4000 and 4400*** kw and operates with this load for at least 60 minutes.

All engine starts and loading for the purpose of this surveillance testing may be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that mechanical stress and wear on the diesel engine is minimized.

A modified diesel generator start involving idling and gradual acceleration to synchronous speed may be used for this surveillance. When modified start procedures are not used, the time, voltage, and frequency tolerances of Surveillance Requirement 4.8.1.1.2.g must be met.

Momentary transients outside the load range do not invalidate this test.

HOPE CREEK 3/4 8-4 Amendment No. 187 See ITS 3.8.1 SR 3.8.3.1 Verify stored fuel oil inventory is 44,800 gal for each EDG, and a 7 day total supply of fuel for three EDGs in MODES 1, 2, and 3, and 7 day total supply of fuel oil for required EDGs in other than MODES 1, 2, and 3.

Add proposed SR 3.8.3.2 M01 See ITS 3.8.1 See ITS 3.8.1 ITS A01 ITS 3.8.3 A03 S1 S1

ITS 3.8.3 ITS A01 ELECTRICAL POWER SYSTEMS A.C. SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

One circuit between the offsite transmission network and the onsite Class 1E distribution system, and

b.

Two diesel generators, one of which shall be diesel generator A or diesel generator B, each with:

1.

A separate fuel oil day tank containing a minimum of 360 gallons of fuel.

2.

A fuel storage system consisting of two storage tanks containing a minimum of 44,800 gallons of fuel.

3.

A separate fuel transfer pump for each storage tank.

APPLICABILITY:

OPERATIONAL CONDITIONS 4, 5 and *.

ACTION:

a.

With less than the above required A.C. electrical power sources OPERABLE, suspend CORE ALTERATIONS, handling of recently irradiated fuel in the secondary containment, and crane operations over the spent fuel storage pool when fuel assemblies are stored therein. In addition, when in OPERATIONAL CONDITION 5 with the water level less than 22'-2" above the reactor pressure vessel flange, immediately initiate corrective action to restore the required power sources to OPERABLE status as soon as practical.

b.

The provisions of Specification 3.0.3 are not applicable.

c.

With one fuel oil transfer pump inoperable, realign the flowpath of the affected tank to the tank with the remaining operable fuel oil transfer pump within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and restore the inoperable transfer pump to OPERABLE status within 14 days, otherwise declare the affected emergency diesel generator (EDG) inoperable. This variance may be applied to only one EDG at a time.

SURVEILLANCE REQUIREMENTS 4.8.1.2 At least the above required A.C. electrical power sources shall be demonstrated OPERABLE per Surveillance Requirements 4.8.1.1.1, 4.8.1.1.2, and 4.8.1.1.3, except for the requirements of 4.8.1.1.2.a.5, 4.8.1.1.2.g, 4.8.1.1.2.h.4, 4.8.1.1.2.h.5, 4.8.1.1.2.h.6, 4.8.1.1.2.h.7, 4.8.1.1.2.h.11, 4.8.1.1.2.h.13 and 4.8.1.1.2.k.2.

When handling recently irradiated fuel in the secondary containment.

HOPE CREEK 3/4 8-11 Amendment No.227 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8 LCO 3.8.3 Add proposed LCO 3.8.3 A02 A03 See ITS 3.8.2 See ITS 3.8.2 Applicability When associated EDG is required to be OPERABLE.

Add proposed ACTIONS Note Add proposed ACTIONS C and D Add proposed ACTIONS A and E See ITS 3.8.2 Add proposed ACTION B Add proposed ACTION F A02 L01 L02 A04 M01 L01 M01 a 7 day total supply of fuel for three EDGs in MODES 1, 2, and 3, and 7 day total supply of fuel oil for required EDGs in other than MODES 1, 2, and 3.

SR 3.8.3.1 S1 S1

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 1 of 7 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications - General Electric BWR/4 Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.1 and 3.8.1.2 state the requirements for the A.C. electrical power sources during operating and shutdown conditions, respectively. These requirements are used to form the LCO and Applicability for a separate Specification; ITS 3.8.3, "Diesel Fuel Oil Storage, Lube Oil, and Starting Air."

ITS LCO 3.8.3 states that the stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency diesel generator (EDG). The Applicability for this requirement is when the associated EDG is required to be OPERABLE. This changes the CTS by combining the requirements for stored diesel fuel oil, diesel lube oil, and starting air subsystem into one Specification.

This change is acceptable because the current requirements are translated into the ITS presentation with no technical changes. Stored diesel fuel oil, lube oil, and starting air subsystem are a support system for each EDG. The CTS and ITS maintain this relationship between the EDGs and the Diesel Fuel Oil System, EDG Lube Oil System and Starting Air Subsystem. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 3.8.1.1.b.2 requires a separate fuel storage system consisting of two storage tanks containing a minimum volume of 44,800 gallons of fuel. CTS 3.8.1.2.b.2 requires a fuel storage system consisting of two storage tanks containing a minimum volume of 44,800 gallons of fuel. ITS SR 3.8.3.1 requires verifying the stored fuel oil inventory is 44,800 gallons for each EDG and a 7-day supply for three EDGs in MODES 1, 2, and 3. When not in MODE 1, 2, or 3, the 7-day supply is limited to that needed to support the required EDG(s).

This changes the CTS by clarifying the fuel storage requirement to meet the 7-day criterion.

This change is acceptable because the current requirements are translated into the ITS presentation with no technical changes. Stored diesel fuel oil is a support feature for each EDG. HCGS License Amendments 59 (ADAMS Accession No. ML011770048) and 96 (ADAMS Accession No. ML011760565) provide the current licensing bases for individual and cumulative volumes to fuel oil. The ITS maintains the fuel oil inventory requirements and the relationship between the EDGs and the fuel oil inventory. This change is designated as administrative because it does not result in a technical change to the CTS.

S1

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 2 of 7 A04 CTS 3.8.1.1 and 3.8.1.2 Actions, in part, provide requirements to be taken for each inoperable EDG. ITS 3.8.3 ACTIONS include an explicit Note that states, "Separate Condition entry is allowed for each EDG." This Note provides instructions for the proper application of the ACTIONS for ITS compliance. This changes the CTS by providing explicit direction for using the ITS 3.8.3 ACTIONS when stored diesel fuel oil, diesel lube oil, and starting air subsystem parameters for an EDG are not within limits.

This change is acceptable because the addition of the Note reflects the CTS allowance to take appropriate Actions for each EDG. This change is designated as administrative since it does not result in a technical change to the CTS.

A05 CTS 4.8.1.1.2.f states, in part, in accordance with the Diesel Fuel Oil Testing Program contained in Specification 6.8.4.e, and prior to the addition of new fuel oil to the storage tank, samples shall be taken ITS SR 3.8.3.3 states, Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program. This changes the CTS by removing the text identifying where the Diesel Fuel Oil Testing Program is addressed in Technical Specifications and removing redundant frequency information (i.e., prior to the addition of new fuel oil to the storage tank) that is already stated in the administrative controls section (CTS 6.8.4.e) of the Technical Specifications.

This change is acceptable because the Diesel Fuel Oil Testing Program requirements remain unchanged and is a presentation preference consistent with the ISTS. This change is designated as administrative because it represents a presentation preference and does not represent a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 The CTS does not provide inventory requirements for EDG lube oil. ITS LCO 3.8.3, in part, requires lube oil to be within limits for each required EDG with associated Required Actions and Completion Times when outside these limits.

ITS Surveillance Requirement (SR) 3.8.3.2 requires verification that the lube oil inventory is a 7-day supply for each EDG. ITS 3.8.3 ACTIONS B and F provide Required Actions if the required EDG lube oil inventory is not within limits. This changes the CTS by adding limits for lube oil inventory in which Surveillance Requirements verify the limits are being maintained and explicit ACTIONS for when the limits are not met.

The purpose of ITS 3.8.3 is to provide appropriate limits, ACTIONS, and Surveillances for diesel fuel oil, lube oil, and the air start subsystems because these subsystems support the operation of the standby emergency AC power sources (EDGs). The purpose of ITS SR 3.8.3.2 is to provide the appropriate limits for stored lube oil inventory. Hope Creek controls periodic Frequencies for Surveillances in accordance with the Surveillance Frequency Control Program per CTS 6.8.4.j. Therefore, SR 3.8.3.2 will be performed at a Frequency in accordance with the Surveillance Frequency Control Program with an initial Frequency of 31 days consistent with ISTS SR 3.8.3.2. The 31 day Frequency is adequate since EDG starts and run times are closely monitored by the plant staff.

S1

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 3 of 7 ITS 3.8.3 ACTION B provides an explicit Required Action and Completion Time for restoring stored lube oil inventory to within limits. If a Required Action and associated Completion Time is not met or one or more EDGs with lube oil inventory is not within limits for reasons other than addressed by Condition B, ITS 3.8.3 ACTION F requires the associated EDG to be declared inoperable immediately. This change is designated as more restrictive because explicit requirements are included in the Technical Specifications for lube oil inventory.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.8.1.1.2.h.12 states that each EDG shall be demonstrated OPERABLE by verifying that the fuel oil transfer pump transfers fuel oil from each fuel storage tank to the day tank of each diesel via the installed cross connection lines. ITS 3.8.3 does not include this SR. This changes the CTS by the removal of this SR and placing it in the Technical Requirements Manual (TRM).

The purpose of the CTS surveillance requirement is to ensure the capability to provide 7 days of stored fuel oil inventory to three EDGs. The removal of the requirement to verify that the fuel oil transfer pump transfers fuel oil from each fuel storage tank to the day tank of each diesel via the installed cross connection lines from the Technical Specifications is acceptable because this test is not necessary to be included in the Technical Specifications in order to demonstrate OPERABILITY of an EDG. The ITS retains the requirement to ensure fuel oil can be transferred from the fuel oil storage tanks to the respective EDGs day tank.

In addition, ITS SR 3.8.3.1 includes a requirement to verify, in part, EDG stored fuel oil inventory is 7 day total supply of fuel for three EDGs at a Frequency in accordance with the Surveillance Frequency Control Program, which by implication requires the capability to transfer fuel oil from each fuel storage tank to the day tank of each diesel via the installed cross connection lines. This obviates the need to explicitly require this verification. Also, this change is acceptable because verifying the capability of the fuel oil transfer system via installed cross connection lines will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a surveillance requirement is being removed from the Technical Specifications.

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 4 of 7 LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 and CTS 3.8.1.2 do not provide explicit compensatory actions if the volume of stored fuel oil or starting air pressure is less than the specified limit. Thus, if the minimum required volume of stored fuel oil or the starting air pressure limit is not met, the associated EDG must be declared inoperable and the actions of CTS 3.8.1.1 or CTS 3.8.1.2 must be entered, as appropriate. ITS 3.8.3 ACTION A allows for not declaring the associated EDG inoperable as long as the specified minimum volume is maintained and a total volume of stored fuel oil is greater than a 6 day supply. ITS 3.8.3 ACTION E allows for not declaring the associated EDG inoperable as long as the pressure in the required starting air receiver is adequate for at least one start (i.e., 290 psig). ITS 3.8.3 Required Actions A.1 and E.1 allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the stored fuel oil volume and starting air receiver pressure, respectively, to within limits. If this Required Action and associated Completion Time is not met or if the stored fuel oil volume is less than the specified individual and total volume values or required starting air receiver pressure is < 290 psig, the associated EDG must be declared inoperable immediately, as required by ITS 3.8.3 ACTION F. This changes the CTS by allowing the EDG(s) to not be declared inoperable with the fuel oil less than the minimum required volume as long as the EDGs have specified individual and total fuel oil volume values; or with the required starting air receiver pressure less than 325 psig as long as the receiver has sufficient pressure for a single EDG start.

The purpose of ITS 3.8.3 ACTIONS A and E is to allow time to restore the stored fuel oil volume and starting air receiver pressures to within the specified limit for a given EDG. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to a degraded condition in order to minimize risk associated with continued operation while providing time to restore the parameter. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The addition of ITS 3.8.3 ACTIONS A and E will allow each EDG to not be declared inoperable with the associated stored fuel oil volume or starting air pressure not within the specified Surveillance limit as long as the specified minimum volume is maintained and a total volume of stored fuel oil is greater than a 6 day supply for operation at post accident load or sufficient starting air pressure for one start. In these Conditions, 44,800 gal for the each required EDG and a 7 day total fuel oil supply for at least three EDGs or starting air pressure for five successive starts is not available. However, the Condition is restricted to fuel oil volume that maintains at least 36,300 gal of fuel oil for each EDG and a 6 day total supply for at least three EDGs and one starting air receiver pressure for each EDG sufficient for a single EDG start. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required fuel oil level, or feed and bleed operations, which may be necessary due to increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the S1 S1 S1 S1

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 5 of 7 tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume or restore starting air pressure to the required limit prior to declaring the associated EDG(s) inoperable. This period is acceptable for stored fuel oil based on the remaining capacity and for starting air pressures based on adequate air pressure for one EDG start, the fact that procedures will be initiated to obtain replenishment or recharge, and the low probability of an event during this brief period. This change is designated as less restrictive since less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 4.8.1.1.2.f requires, in part, to verify fuel oil quality of new and stored fuel oil are tested in accordance with the Diesel Fuel Oil Testing Program. CTS 6.8.4.e provides requirements for new fuel oil properties and fuel oil total particulates. CTS 3.8.1.1 and CTS 3.8.1.2 do not provide explicit compensatory actions if the new fuel oil properties or fuel oil total particulates are not within the limits specified in the Diesel Fuel Oil Testing Program. Thus, if the fuel oil properties are not met, the associated EDG must be declared inoperable and the actions of CTS 3.8.1.1 or CTS 3.8.1.2 must be entered, as appropriate. ITS SR 3.8.3.3 also requires verification that new and stored fuel oil properties are tested and maintained within limits, as specified in the Diesel Fuel Oil Testing Program. This includes a stored fuel oil total particulate limit and new fuel oil properties. ITS 3.8.3 ACTION C specifies the compensatory actions for one or more EDGs with stored fuel oil total particulates not within limits. ITS 3.8.3 ACTION D specifies the compensatory actions for one or more EDGs with new fuel oil properties not within limits. If a Required Action and associated Completion Time is not met or one or more EDGs with new or stored fuel oil properties not within limits for reasons other than addressed by Conditions C or D, ITS 3.8.3 ACTION F requires the associated EDG to be declared inoperable immediately. This changes the CTS by allowing the EDGs to not be declared inoperable with fuel oil total particulates or new fuel oil properties not within the specified Surveillance limits unless the applicable ITS 3.8.3 ACTIONS cannot be completed within the required Completion Time.

The purpose of CTS 4.8.1.1.2.f (ITS SR 3.8.3.3) is to provide the appropriate limits for stored and new fuel oil properties. ITS 3.8.3 ACTIONS C and D provide explicit Required Actions and Completion Times for restoring both total particulates and stored fuel oil properties (affected by the addition of new fuel oil whose properties are not within limits) to within limits. ITS 3.8.3 ACTION C is entered when the acceptance criterion of total particulate concentration specified in ITS 5.5.7 is not met. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability.

Poor sample procedures, contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not necessarily result in a failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated EDG inoperable. The 7 day Completion Time allows for further evaluation, re-sampling and re-analysis of the EDG fuel oil. ITS 3.8.3 ACTION D is entered because of failure to meet the requirements specified in ITS 5.5.7.b. With the new fuel oil properties defined in

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 6 of 7 the Bases for ITS SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil did not cause the stored fuel oil to be outside of the required limits, or to restore the stored fuel oil properties to within limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a EDG start and load was required during this time interval and the stored fuel oil properties were outside limits, there is a high likelihood that the EDG would still be capable of performing its intended function. ITS 3.8.3 ACTION F covers the condition when a Required Action and associated Completion Time of any ITS 3.8.3 ACTION could not be met, or if one or more EDGs with diesel fuel oil, lube oil, or starting air subsystem is not within limits for reasons other than Condition A, B, C, D, or E. The allowances are considered acceptable since a relatively short time is allowed to exist with EDG parameters not within limits.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair or restore inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident occurring during the repair period.

The fuel oil properties must be restored within limits within 30 days and the fuel oil total particulates must be restored in 7 days. In this condition, the EDG fuel oil is degraded but remains capable of supporting the EDG OPERABILITY. The ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.a.8 requires verification that EDG lube oil pressure, temperature and differential pressure across the lube oil filters are within manufacturer specifications in accordance with the Surveillance Frequency Control Program. ITS SRs do not include this requirement as part of the EDG start requirements performed to demonstrate EDG OPERABILITY. This changes the CTS by deleting the requirement to verify that EDG lube oil pressure, temperature and differential pressure across the lube oil filters are within manufacturer specifications.

The purpose of CTS 4.8.1.1.2.a.8 is to verify that the EDG following startup operates within the manufacturers specifications and limitations which is a normal operator responsibility for operating equipment. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analyses. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected and that the necessary quality of the EDGs and support components is maintained and that the LCO will be met pursuant to the requirements of 10 CFR 50.36(c)(3). In addition, these verifications are routinely addressed as procedural limitations or performance checks. This change is

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 7 of 7 designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.b requires a visual examination of a sample of lube oil from the diesel engine to verify the absence of water in accordance with the Surveillance Frequency Control Program. ITS does not include this SR to demonstrate EDG OPERABILITY. This changes the CTS by deleting the requirement to visually examine a sample of lube oil from the diesel engine to verify the absence of water.

The purpose of CTS 4.8.1.1.2.b is to verify that there has been no water accumulation with the EDG lube oil sump and is a routine check performed as part of procedural checks performed by the operator. HCGS operating procedures currently prescribe a water accumulation check for the EDG lube oil makeup tank, rocker arm sump and engine sump. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analyses. Thus, appropriate tests are performed in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected and that the necessary quality of the EDGs and support components is maintained and that the LCO will be met pursuant to the requirements of 10 CFR 50.36(c)(3).

This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.j.1 states, in part, Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or equivalent. ITS 3.8.3 does not include this surveillance. This changes the CTS by deleting the requirement to drain each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or equivalent from TSs.

The purpose of CTS 4.8.1.1.2.j.1 is to remove accumulated sediment and clean the tank as recommended by Regulatory Guide 1.137 and is typically performed in conjunction with the ASME Code,Section XI examination of the tanks. The surveillance is intended to preclude the introduction of surfactants in the fuel oil system. This change is acceptable because the requirement is retained as a routine preventative maintenance activity and was removed from the ISTS in Revision 2 as part of the adoption of TSTF-2A. This change is acceptable because the NRC has determined that the fuel oil storage tank drain and clean requirement is a maintenance activity adequately controlled under licensee controlled documents and does not meet the 10 CFR 50.36 criteria for retention in the TS. In addition, the change is consistent with Revision 5 of the ISTS. The diesel fuel oil testing requirements retained in the ITS continue to be performed in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected and that the necessary quality of the EDGs and stored fuel oil is maintained and that the LCO will be met pursuant to the requirements of 10 CFR 50.36(c)(3). This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 General Electric BWR/4 STS 3.8.3-1 Rev. 5.0 CTS Hope Creek Amendment XXX 1

3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY:

When associated DG is required to be OPERABLE.

ACTIONS

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with fuel oil level less than a

[7] day supply and greater than a [6] day supply in storage tank.

A.1 Restore fuel oil level to within limits.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months B. One or more DGs with lube oil inventory less than a [7] day supply and greater than a

[6] day supply.

B.1 Restore lube oil inventory to within limits.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months C. One or more DGs with stored fuel oil total particulates not within limit.

C.1 Restore fuel oil total particulates to within limit.

7 days D. One or more DGs with new fuel oil properties not within limits.

D.1 Restore stored fuel oil properties to within limits.

30 days 3.8.1.1 3.8.1.2 Applicability DOC L01 DOC M01 DOC L02 DOC L02 E

E E

DOC A04 E

E E

1 3

1 2

1 1

stored inventory INSERT 1 emergency

Hope Creek Insert Page 3.8.3-1 INSERT 1 A. One or more EDGs with stored fuel oil inventory

< 44,800 gal and

> 36,300 gal.

OR Total stored fuel oil inventory less than a 7 day supply and greater than a 6 day supply for three EDGs in MODE 1, 2, or 3.

OR Total stored fuel oil inventory less than a 7 day supply and greater than a 6 day supply for required EDGs in other than MODE 1, 2, or 3.

DOC L01 3

CTS ITS 3.8.3 S1

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 General Electric BWR/4 STS 3.8.3-2 Rev. 5.0 CTS Hope Creek Amendment XXX 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One or more DGs with starting air receiver pressure < [225] psig and [125] psig.

E.1 Restore starting air receiver pressure to [225] psig.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months F. Required Action and associated Completion Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.

F.1 Declare associated DG inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains a [7] day supply of fuel.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

DOC L01 DOC M01 DOC L01 DOC L02 E

325 325 4.8.1.1.2.a.2 E

E 1

2 1

2 3

Verify EDG stored fuel oil inventory is:

a.

44,800 gal of fuel for each EDG,

b.

7 day total supply of fuel for three EDGs in MODES 1, 2, and 3, and

c.

7 day total supply of fuel oil for required EDGs in other than MODES 1, 2, and 3.

290 S1 2

JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3. Hope Creek Generating Station (HCGS) was granted a deviation from the guidance in Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators, and Standard Review Plan Section 9.5.4, Paragraph I.1.d, as stated in UFSAR Section 1.8.1.137 and approved by License Amendments 59 (ADAMS Accession No. ML011770048) and 96 (ADAMS Accession No. ML011760565). ISTS SR 3.8.3.1 is revised in the ITS establishing a fuel oil inventory for each emergency diesel generator (EDG) consistent with the current technical specifications and adding a total combined onsite fuel oil storage inventory requirement to support continuous operation of three EDGs for 7 days in MODES 1, 2, and 3 and a 7 day supply for the required EDGs when not in MODE 1, 2, or 3. ISTS ACTION A is revised in the ITS to reflect the intent of the ISTS to allow operation of the EDGs with a reduced fuel oil inventory equivalent to approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to allow time to restore the required fuel oil inventory in the associated EDG following a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EDG load run and circumstances caused by events such as:

a. Full load operation required for an inadvertent start while at minimum required level; or

b. Feed and bleed operations that may be necessitated by increased particulate levels or any number of other oil quality degradations.

S1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 General Electric BWR/4 STS B 3.8.3-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES APPLICABLE SAFETY ANALYSES (continued) systems so that fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

Since diesel fuel oil, lube oil, and starting air subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Stored diesel fuel oil is required to have sufficient supply for [7] days of full load operation. It is also required to meet specific standards for quality. Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full load for [7] days. This requirement, in conjunction with an ability to obtain replacement supplies within [7] days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel oil requirements, as well as transfer capability from the storage tank to the day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown."

The starting air system is required to have a minimum capacity for five successive DG start attempts without recharging the air start receivers.

APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA.

Because stored diesel fuel oil, lube oil, and starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) governed by separate Condition entry and application of associated Required Actions.

E E

E storage and transfer onsite post accident The onsite fuel oil storage system is not sized in accordance with RG 1.137 (Ref. 2). Credit is taken for the ability to transfer fuel oil from the storage tank of a faulted EDG to the storage tanks of three operating EDGs. Therefore, to meet the LCO, the total stored inventory must support 7 days of continuous operation at full rated capacity for three EDGs in MODES 1, 2, and 3.

2 1

2 4

At least one sub s

s S1 When the unit is not in MODE 1, 2, or 3, the total stored fuel oil inventory is only required to support 7 days of operation for the required EDGs.

S1 4

Additionally, a minimum volume of 44,800 gallons is required for each EDG to ensure a sufficient fuel oil supply is available to support operation of the EDGs during the initial phases of a DBA concurrent with a loss of offsite power.

S1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 General Electric BWR/4 STS B 3.8.3-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

A.1 In this Condition, the [7] day fuel oil supply for a DG is not available.

However, the Condition is restricted to fuel oil level reductions that maintain at least a [6] day supply. The fuel oil level equivalent to a [6] day supply is [28,285] gallons. These circumstances may be caused by events such as either:

a.

Full load operation required for an inadvertent start while at minimum required level or

b.

Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

B.1 In this Condition, the [7] day lube oil inventory i.e., sufficient lube oil to support [7] days of continuous DG operation at full load conditions, is not available. However, the Condition is restricted to lube oil volume reductions that maintain at least a [6] day supply. The lube oil inventory equivalent to a [6] day supply is [425] gallons. This restriction allows sufficient time for obtaining the requisite replacement volume. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 This Condition is entered as a result of a failure to meet the acceptance criterion for particulates. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

E E

E 224 1

1 1

2 2

4 INSERT 1 makeup supply of 1

Hope Creek Insert Page B 3.8.3-3 ITS 3.8.3 INSERT 1 In this Condition, the minimum stored volume to one or more EDGs is not available. However, the Condition is restricted to fuel oil volume reductions that maintain a usable volume of at least 36,300 gallons for each EDG, which corresponds to a stored fuel oil capacity sufficient to operate the EDG at full load for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months less that the minimum required volume of 44,800 gallons. This Condition also applies when the 7 day total stored fuel oil inventory supply is not available provided a 6 day total stored fuel oil inventory supply is maintained. The fuel oil volume equivalent to a 6 day total stored fuel oil inventory supply for three EDGs in MODES 1, 2, and 3 is 152,928 gallons. When not in MODE 1, 2, or 3, the fuel oil volume equivalent to a 6 day total stored fuel oil inventory supply is the sum total of 50,976 gallons per required EDG.

These circumstances may be caused by events such as either:

4 S1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 General Electric BWR/4 STS B 3.8.3-5 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for [7] days at full load. The fuel oil level equivalent to a [7] day supply is [33,000] gallons when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, and the corresponding fuel consumption rate, the onsite fuel storage volume required for [7] days of operation can be determined.

SR 3.8.3.3 requires a new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumptions calculations. The [7] day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

[ The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

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

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory is available to support at least [7] days of full load operation for each DG.

The lube oil inventory equivalent to a [7] day supply is [500] gallons and is based on the DG manufacturer's consumption values for the run time of the DG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG, when the DG lube oil sump does not hold adequate inventory for [7] days of full load operation without the level reaching the manufacturer's recommended minimum level.

178,416 three of four E E

E E

260.4 3

2 2

4 1

2 1

1 Since the onsite stored fuel oil inventory credits a faulted EDG, three EDGs can credit the inoperable EDGs fuel oil inventory provided the combined volume of stored fuel oil supports three EDGs operating at full rated capacity while in MODES 1, 2, and 3. When not in MODE 1, 2, or 3, the combined volume of stored fuel oil must be adequate to support 7 days of operation for the required EDGs.

usable volume three EDG 2

(59,472 gallons per EDG)

Additionally, a minimum usable fuel oil volume of 44,800 gallons in the storage tanks of each EDG is required to ensure a sufficient fuel oil supply is available to support operation during the initial phases of a DBA concurrent with a loss of offsite power.

makeup supply of S1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. The Hope Creek Generating Station (HCGS) emergency diesel generator (EDG) Fuel Oil Storage and Transfer (FOST) System design utilizes two separate fuel oil storage tanks per EDG to supply the fuel oil for each individual EDG. There are two fuel oil transfer pumps associated with each storage tank to supply a single day tank for each EDG. In the event that the designated transfer pump fails to start, fuel oil can be transferred from either storage tank to the associated day tank by a single transfer pump provided both storage tanks are aligned to the single transfer pump. The EDG FOST System provides onsite storage to support at least 7 days of continuous operation for three of four EDGs. Deviations from the ISTS Bases reflect this EDG FOST System design.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

4. Changes are made to reflect changes made to the ITS to incorporate the current licensing basis information approved in Amendment 59, dated November 22, 1993, (ADAMS Accession No. ML011770048) providing relief to commitments made to the EDG fuel oil storage recommendations of Regulatory Guide 1.1.37, Revision 1 and Standard Review Plan Section 9.5.4, Paragraph I.1.d.

S1

ITS 3.8.9 ITS A01 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION:

a.

With one of the above required A.C. distribution system channels not energized, re-energize the channel within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With one of the above required 125 volt D.C. distribution system channels not energized, re-energize the division within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.

With any one of the above required 250 volt D.C. distribution systems not energized, declare the associated HPCI or RCIC system inoperable and apply the appropriate ACTION required by the applicable Specifications.

d.

With one or both inverters in one channel inoperable, energize the associated 120 volt A.C. distribution panel(s) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and restore the inverter(s) to OPERABLE status within 7 days; or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.8.3.1 Each of the above required power distribution system channels shall be determined energized in accordance with the Surveillance Frequency Control Program by verifying correct breaker/switch alignment and voltage on the busses/MCCs/panels.

HOPE CREEK 3/4 8-20 Amendment No. 215 See ITS 3.8.7 MODES or more electrical power Restore AC electrical power distribution subsystem(s) to OPERABLE status.

L02 L02 F. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

F.1 Enter LCO 3.0.3.

Immediately MODE 3 Applicability ACTION A ACTION D ACTION C or more electrical power subsystems inoperable.

Restore DC electrical power distribution subsystem(s) to OPERABLE status.

MODE 3 electrical power subsystems inoperable.

immediately ACTION E SR 3.8.9.1 s

to Class 1E AC, DC, and AC instrument electrical power distribution subsystems ACTION D A05 subsystems inoperable.

Insert Required Action D.1 NOTE L01 L01 or more ACTION B One or more AC instrument electrical power distribution subsystems Restore AC electrical power distribution subsystem(s) to OPERABLE status.

A04 MODE 3 L02 L01 supported feature(s)

L01 S1

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 1 of 5 S1 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications - General Electric BWR/4 Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.3.1 requires the power distribution system channels to be energized and lists the specific buses, including applicable nominal AC bus voltages.

CTS 3.8.3.1 Actions and CTS 4.8.3.1 also refer to distribution system "channels."

ITS Limiting Condition for Operation (LCO) 3.8.9 requires the Class 1E AC, DC, and AC instrument electrical power distribution subsystems to be OPERABLE.

The ITS 3.8.9 ACTIONS and Surveillance Requirement (SR) refer to electrical power distribution "subsystems." This changes the CTS by clarifying the applicable electrical power distribution channels are Class 1E and changing the terminology to electrical power distribution subsystems instead of channels.

This change does not alter the technical requirements and represents only a change in presentation. The HCGS Class 1E Electrical Power Distribution System design consists of four channels of AC and 125 VDC buses and two channels of 250 VDC buses. The ITS will continue to require four subsystems of AC and 125 VDC buses and two subsystems of 250 VDC buses. This change more closely aligns the ITS with the ISTS presentation. This change is designated as an administrative presentation change and does not result in technical changes to the CTS.

A03 Deleted.

A04 CTS 3.8.3.1, Action c states, "With any one of the above required 250 volt D.C.

distribution systems not energized, declare the associated HPCI or RCIC system inoperable and apply the appropriate ACTION required by the applicable Specifications." ITS LCO 3.8.9, ACTION E, for the same condition requires immediately declaring the associated supported feature(s) inoperable. This changes the CTS by requiring the associated supported feature(s) to be declared inoperable instead of specific systems to be declared inoperable, and not including specific guidance on ACTIONS.

The purpose of the CTS action is to ensure the systems supported by the inoperable 250 VDC electrical distribution subsystems are declared inoperable and the appropriate actions are taken. ITS 3.8.9, Required Action E.1, resolves a presentation problem when both of the 250 VDC buses are inoperable. With any one 250 VDC bus inoperable, the CTS actions allow declaring the associated High Pressure Coolant Injection (HPCI) or Reactor Core Isolation Cooling (RCIC) System inoperable. However, with both 250 VDC buses S1

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 2 of 5 S1 inoperable, both HPCI and RCIC Systems (i.e., supported features) must be declared inoperable. The ITS presentation more concisely requires the associated supported feature(s) be declared inoperable. This presentation is similar to other ITS plants (e.g., LaSalle Station Unit 1, ITS 3.8.7, ACTIONS F and G (ADAMS Accession No. ML052990324)). Additionally, the requirement to apply the appropriate ACTION required by the applicable Specifications is unnecessary because ITS LCO 3.0.6 states, in part, "When a support systems Required Action directs a supported system to be declared inoperable, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2."

This change is a presentation preference and designated as administrative because it does not result in technical changes to the CTS.

A05 CTS 3.8.3.1 does not contain a specific ACTION for two or more electrical power distribution subsystems inoperable that result in a loss of function. With two or more electrical power distribution subsystems inoperable that result in a loss of function, CTS 3.0.3 would be entered. ITS 3.8.9, ACTION F, directs entry into LCO 3.0.3 when two or more electrical power distribution subsystems are inoperable that result in a loss of function. This changes the CTS by specifically stating to enter LCO 3.0.3 in this System Specification.

This change is acceptable because the action taken with two or more inoperable electrical power distribution subsystems resulting in a loss of function is unchanged. Adding this ACTION is consistent with the ITS convention of directing entry into LCO 3.0.3 when multiple ACTIONS are presented in the ITS, and entry into these multiple ACTIONS could result in a loss of safety function.

This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.1 requires AC, AC instrument, and DC electrical buses to be energized and lists the specific buses, including applicable nominal AC bus voltages. ITS LCO 3.8.9 requires the Class 1E AC, DC, and AC instrument electrical power distribution subsystems to be OPERABLE. This changes the CTS by moving the specific names of the buses and the associated nominal bus

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 3 of 5 S1 voltages (i.e., 4160 V, 480 V, 120 V, 250 V DC and 125 V DC) from the CTS to the ITS Bases.

The removal of these details related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required electrical buses to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 3.8.3.1 requires AC, AC instrument, and DC electrical buses to be energized and lists the specific buses, including applicable nominal AC bus voltages. ITS LCO 3.8.9 requires the Class 1E AC, DC, and AC instrument electrical power distribution subsystems to be OPERABLE. ITS does not include the 208/120 VAC distribution panels, 120 VAC fuse panels, 125 VDC fuse boxes or the 250 V DC fuse boxes. This changes the CTS by moving these component requirements to the TRM.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the Class 1E electrical power distribution subsystems and the appropriate Condition to enter if a required subsystem becomes inoperable. ITS also retains the power supplies to these components, therefore, inoperability of the power supply would adequately address ACTIONS necessary to mitigate an inoperability of the components these electrical supplies directly support. In addition, upon loss of one of the buses proposed for relocation, the associated components specified in the Technical Specifications would be declared inoperable and appropriate ACTIONS entered in accordance with ITS LCO 3.0.2.

Also, this change is acceptable because these types of details will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1, Action a, in part, states, "With one of the above required AC distribution system channels not energized..." CTS 3.8.3.1, Action b, in part, states, "With one of the above

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 4 of 5 S1 required 125 volt D.C. distribution system channels not energized..."

CTS 3.8.3.1, Action c, in part, states, "With one of the above required 250 volt D.C. distribution systems not energized..." CTS 3.8.3.1, Action d, in part, states, "With one or both inverters in one channel inoperable, energize the associated 120 volt A.C. distribution panel(s)" ITS LCO 3.8.9, Condition A, states, "One or more AC electrical power distribution subsystems inoperable." ITS LCO 3.8.9, Condition B, states "One or more AC instrument electrical power distribution subsystems inoperable." ITS LCO 3.8.9, Condition C, states, "One or more 125 VDC electrical power distribution subsystems inoperable." ITS LCO 3.8.9, Condition E, states "One or more 250 VDC electrical power distribution subsystems inoperable." ITS LCO 3.8.9, Condition F, provides the appropriate Required Action if two or more electrical power distribution subsystems become inoperable and a loss of safety function occurs. This changes the CTS by allowing more than one electrical power distribution channel (i.e., subsystem) to be inoperable provided a loss of safety function has not occurred.

The purpose of ITS 3.8.9, Conditions A, B, C, and E, is to ensure remedial action is provided to ensure required safety features have electrical power to perform the specified safety function. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period. This change allows a short time period to restore multiple inoperable AC, DC and, AC instrument electrical power distribution subsystems to OPERABLE status. This is acceptable because there are sufficient electrical power distributions subsystems available to ensure all plant safety functions can be supported by the Class 1E Electrical Power Distribution System. ITS 3.8.9, ACTION F, provides the Required Action if two or more electrical power distribution subsystems become inoperable and a loss of safety function occurs. Required Action F.1 requires an entry into LCO 3.0.3 immediately. The combination of ITS 3.8.9, ACTIONS A, B, C, and E; and the addition of ACTION F, along with LCO 3.0.6 and the Safety Function Determination Program, ensures that with a loss of any electrical power distribution subsystem no loss of function will occur without proper action. The proposed actions are consistent with the ISTS and provide acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i). This change is designated as less restrictive because less stringent Required Actions are being applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1, Action a, requires the plant to be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one of the required AC distribution system channels cannot be re-energized within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Similarly, Action b requires the same plant shutdown when one of the required 125 VDC distribution system channels cannot be re-energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.8.3.1, Action d, also requires the same plant shutdown when one or more 120 volt A.C.

distribution panel(s) in a channel cannot be re-energized within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 5 of 5 S1 ITS 3.8.9, ACTION D, requires the unit to be placed in MODE 3 (CTS OPERATIONAL CONDITION 3) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the Required Actions and associated Completion Times of Condition A, B, or C are not met. This changes the CTS by removing the requirement to be in COLD SHUTDOWN (ITS MODE 4) within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to HOT SHUTDOWN and COLD SHUTDOWN in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ), changing the end state of CTS 3.8.3.1, Actions a, b, and d, from "COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " to "MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

The purpose of ITS 3.8.9, ACTION D, is to place the plant in a MODE in which overall plant risk is minimized. This change is acceptable because placing the plant in MODE 3 provides for a similar or lower risk than placing the plant in MODE 4, although voluntary entry into MODE 4 is acceptable. In addition, remaining in the Applicability of the LCO is acceptable because the time spent in MODE 3 to perform the necessary repairs to the restore the system to OPERABLE status will be short. ITS Required Action D.1 is modified by the addition of a Note prohibiting entry into the end state MODE within the Applicability during startup using the provisions of LCO 3.0.4.a to provide assurance that entry into the end state MODE during startup is not made without the appropriate risk assessment. The addition of ITS 3.8.9, ACTION D, is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, "Technical Specification End States, NEDC-32988-A," dated September 16, 2014 (ADAMS Accession No. ML102730688). The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No. ML102730585).

PSEG Nuclear has previously committed to assess and manage risk at HCGS in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g.,

Amendment 228 (ADAMS Accession No. ML21098A087)). PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Rev. 1, 'Technical Specifications End States, NEDC-32988-A,'" upon implementation of the end state requirements. The change is designated less restrictive because a less restrictive completion time is imposed when the specified Required Actions cannot be met.

Distribution Systems - Operating 3.8.9 General Electric BWR/4 STS 3.8.9-1 Rev. 5.0 Hope Creek Amendment XXX 1

CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9

[Division 1] and [Division 2] AC, DC, [and AC vital bus] electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical power distribution subsystems inoperable.

A.1

NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

Restore AC electrical power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

[OR In accordance with the Risk Informed Completion Time Program]

B. [ One or more AC vital buses inoperable.

B.1 Restore AC vital bus distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program] ]

instrument Applicability 3.8.3.1 DOC A02 Action a DOC L01 2

2 2

1 Class 1E 3

instrument electrical power distribution subsystems Action d DOC L01 8

instrument electrical power S1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 1 of 2 S1

1.

Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. The Hope Creek Generating Station (HCGS) Class 1E Electrical Power Distribution System design does not include separate 125 VDC electrical distribution channels (i.e.,

subsystems) for the emergency diesel generators. However, the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Systems include separate 250 VDC electrical power distribution channels (i.e., subsystems).

Therefore, ISTS 3.8.9, ACTION E, is revised in the HCGS improved Technical Specifications (ITS) to include actions for the 250 VDC electrical power distribution subsystems consistent with the plant licensing basis.

2.

The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3.

The Note to ISTS 3.8.9 Required Action A.1 is not included in the HCGS current Technical Specifications and consequently is not included in the HCGS ITS due to the redundancy of the HCGS DC electrical distribution system design. Adoption of the Note into the HCGS ITS would result in an unnecessary restriction on the time to evaluate and restore an AC bus (i.e., 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months instead of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) since the primary and backup Class 1E battery chargers for each 125 VDC subsystem are supplied by the same AC electrical power distribution subsystem. As stated in the ISTS 3.8.9 Bases, the 8-hour time limit before requiring a unit shutdown is acceptable, in part, because there is a potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected subsystem to the actions associated with taking the unit to shutdown. Unlike the standard BWR/4 DC Electrical Power Distribution System design that is comprised of two DC electrical divisions, the HCGS Class 1E 125 VDC Electrical Power Distribution System design includes four separate and independent 125 VDC electrical distribution channels (i.e., subsystems) each with two batteries and three battery chargers. As a result, a complete loss of one Class 1E DC electrical distribution subsystem in conjunction with the loss of the associated Class 1E AC electrical distribution subsystem will not result in a loss of the required safety function. The Note to ISTS 3.8.9 Required Action A.1 was added to the ISTS by Technical Specifications Task Force (TSTF) traveler TSTF-16-A, Revision 4, "Add Action to LCO 3.8.9 to require entry into LCO 3.0.3 when there is a loss of function, dated September 12, 2000 (ADAMS Accession No. ML040340481) based on a response to industry events in which it was not recognized that battery charging was lost on a loss of distribution systems and eventual inoperability of the DC systems. Current HCGS procedures and plant practice recognize the effects of a loss of an AC electrical power distribution subsystem on the Class 1E battery charging system and requires the operators to evaluate the Class 1E DC Electrical Power System safety function. This recognition and evaluation of safety function is formalized by the incorporation of LCO 3.0.6 and the Safety Function Determination Program (SFDP) into the HCGS ITS. Therefore, adoption of the Note is unnecessary. Additionally, ISTS 3.8.9 Required Action A.1 Note has not been adopted at the majority of the other BWR plants; for example:

Brunswick Nuclear Plant (ITS 3.8.7 ACTION B - NRC ADAMS Accession No. ML062900525), LaSalle County Station (ITS 3.8.7 ACTION A - NRC ADAMS S1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 2 of 2 S1 Accession No. ML052990324), and James A. Fitzpatrick Nuclear Power Plant (ITS 3.8.7 ACTION A - NRC ADAMS Accession No. ML052720287).

S1

Distribution Systems - Operating B 3.8.9 General Electric BWR/4 STS B 3.8.9-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS (continued)

a.

There is a potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.

b.

The potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP).")

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," to be entered for DC divisions made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

[ B.1 With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC vital bus must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months [or in accordance with the Risk Informed Completion Time Program] by powering the bus from the associated [inverter via inverted DC, inverter using internal AC source, or Class 1E constant voltage transformer].

Condition B represents one or more AC vital buses without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining vital buses, and restoring power to the affected AC vital buses.

2 another subsystem 1

7 instrument electrical power distribution subsystems instrument electrical power distribution subsystem 8

instrument instrument 9

subsystem 1

S1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING Hope Creek Page 1 of 1

1.

Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. The Hope Creek Generating Station (HCGS) Class 1E Electrical Power Distribution System design consists of four channels (or subsystems) of AC, AC instrument, and 125 VDC buses and two channels (or subsystems) of 250 VDC buses. Safety analyses assume worst case single failure is the loss of a 125 VDC battery in one electrical power distribution channel (subsystem). Deviations from the ISTS Bases reflect this electrical power system design.

2.

The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3.

HCGS is adopting TSTF-423-A, Technical Specification End States, consistent with ISTS 3.8.9, ACTION D. The addition of ITS 3.8.9, ACTION D, is consistent with Revision 5 of the ISTS as adopted by Technical Specifications Task Force (TSTF) traveler TSTF-423-A, Revision 1, "Technical Specification End States, NEDC-32988-A," dated September 16, 2014 (ADAMS Accession No. ML102730688).

The TSTF was approved for licensee adoption as documented in Federal Register Notice 76 FR 9614 (ADAMS Accession No. ML102730585). PSEG Nuclear has previously committed to assess and manage risk at HCGS in accordance with the guidance of NUMARC 93-01, Rev. 4F, Section 11 (e.g., Amendment 228 (ADAMS Accession No. ML21098A087)). PSEG Nuclear will also follow the guidance established in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Rev. 1, Technical Specifications End States, NEDC-32988-A," upon implementation of the end state requirements.

4.

The HCGS 1E Electrical Power Distribution System design does not include separate 125 VDC electrical distribution channels (i.e., subsystems) for the emergency diesel generators. However, the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Systems include separate 250 VDC electrical power distribution channels (i.e., subsystems). Changes are made to be consistent with changes made to the Specification.

5.

Changes made incorporate the appropriate location for limits that affect the systems in this Limiting Condition for Operation (LCO).

6.

The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

7.

The Note to ISTS 3.8.9 Required Action A.1 is not included in the HCGS current Technical Specifications and consequently is not included in the HCGS ITS.

Changes are made to be consistent with changes made to the Specification.

S1

v t e Letter Sequence Request
EPID:L-2024-LLI-0000, (Open)
Initiation Request, Request, Request Acceptance Administration Questions Answers Results Approval, Approval, Approval Other: ML25182A205, NUREG-1433, Change in Estimated Review Schedule (August 22, 2025) for Amendment Request Concerning Technical Specification Conversion to NUREG-1433, Revision 5
MONTHYEAR2025-01-07 [Table View]

LR-N24-0062, Proposed Changes to Enclosure 2 Volume 13, ITS Section 3.8 Electrical Power Systems, of the Improved Technical Specification Conversion License Amendment Request

Text

Navigation menu

Search