RA-13-0051, License Amendment Request to Modify Technical Specification 3.8.1 Proposed Changes to Diesel Generator Testing Requirements

License Amendment Request to Modify Technical Specification 3.8.1 Proposed Changes to Diesel Generator Testing Requirements

ML13261A289
Person / Time
Site:	Robinson
Issue date:	09/10/2013
From:	Wheeler-Peavyhouse S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA-13-0051
Download: ML13261A289 (17)

Text

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Serial: RNP-R/13-0051 10 Cm 50,90 SEP 1 0 2013 ATM: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20558-0001 H. 8. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 60-281/RENEWED UCENSE NO. DPR-23 LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION 3.8.A B%)PO=E CUANGE IQ DIESE GENERATO ILEQIRME

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Duke Eneqy Proars, Inc. birm" knon as Carln Power an Light Company, hereby mquests an waendment to the It. 1. Robinsim Steam Electric PIant, Unit No. 2 (HBRSEP) renewsd facty n license OPR-23, Appendix A,Tecnical Specifications.

The proposed licee aendment wil modify ft cuent HBRSEP Technical Speicaton (TS)

Limiting Condition for Operation (LCO) 3.8.1. Required Acon (RA) &.3.2.Z "One 00 Inoeble - Pefom~ SR 3.8.1.2 for OPERASLE D0 within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />" by a NOTE cladfyn RA B.3.22 which steNs -- Not required to be pef when the cause of the inoperable OG Is pre-planned nmintnae and lesting."

The Enclosure provides the basis for the prposed chang, Inudkng a deta descton, technical and regulatory evaluations, enVRo4nmentav consIderatlons. and the Duke Energy Progress, Inc. deminatn that the prooe chm does not veiva a s f hamrds considertion. The pxoposed marked-up and retyped TS piages we provided In Attachments I and 2 to the Enclosure respec*vivly. Mwked.up TS Bases ae included In A#t nt 3 to the Enclosure for infornation Apoval of the popo"d amendment Isrequested by August 29.2014. Once pproved, fhe amendment shall be', Iprented wihn 120 das

United States Nuclear Regulatory Commission Serial: RNP-RAI13-0051 Page 2 of 2 This proposed change has been reviewed by the HBRSEP Plant Nuclear Safety Committee.

This letter contains no new Regulatory Commitments.

In accordance with 10 CFR 50.91(b), a copy of this application is being provided to the State of South Carolina. If you should have any questions regarding this submittal, please contact Mr.

Richard Hightower, Supervisor - Regulatory Affairs at (843) 857-1 329. -

I declare under penalty of perjury that the foregoing is true and correct. Executed On: Se *-fml,-r lot 2013 Sincerely, .

Sharon A. Wheeler-Peavyhouse Manager - Support Services - Nucle~r SWP/sc - ,

Enclosure cc: Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

Mr. V. M. McCree, NRC Region II Mr. S. P. Lingam, NRC Project Manager,'NRR NRC Resident Inspectors, HBRSEP Mr. A. Wilson, Attorney General (SC) h.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0051 Page I of 9 ENCLOSURE Evaluation of Proposed Change to Technical Specification Proposed Changes to Diesel Generator Testing Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 *StDcon 2.2 Nbc Generic Guidanoe 3.0 TECHNICAL EVALUTION

4.0 REGULATORY EVALUATION

4.1 Anlimble R eta Reauiemrf_

42 4.3 Ng -fnl~canl~ "=Wars Consideration DeUMrIon 4.4 ,Congsions

6.0 REFERENCES

ATTACHMENTS:

I Proposed Technical Specifications Changes (Mark-Up) 2 Revised and Retyped Technical Specifications Pages 3 Marked-Up Technical Specifications Bases Pages (For Information)

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0061 Page 2 of 9 1.0

SUMMARY

DESCRIPI1ON Pursuantto 10 CFR 50.90, Duke Energy Progress, Inc. formerly known as Carolina Power and Light Company, Is requesting an amendment to the H. B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP) renewed facility operating license DPR-23, Appendix A, Technical Specifications (TS) Umiting Condition for Operation (LCO) 3.8.1, Required Action (RA) 8.3.2.2 with One DG Inoperable.

The proposed amendment would modify the current LCO 3.8.1. A new Note will be added to RA 1.3.2.2, the conditional surveillance on the alternate, Operable DG, that requires the performance of Surveiance Requirement (SR) 3.8.1.2 within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The Note wi exempt performance of tn conditional survollace when the cause of the inifti Inopeabiuity of the inoperable D Is proanned maintenance an testing. Thet xn1ptiorr wilN not apply whenever the cause of the inoperabilty Iscorrective maintenance, even if the problem requiring correcve maintenance Is discovered during the execution of the original pre-ptanned maintenance ad testing.

The exin requiremet causes the Operable 00 to be made o by the oditional surveillarn requirement of RA BL3.2.2 whenver the prientive maintenm and testin on the altemte division DG is not ompleted and reture toOperb sas within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />;.even When It has been detemined that no common mode faiure pulantie ei* wit1hin the flWu 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period by RA 8,3.2.1. This leads to the situation whre both 0Gs are inoperable simultaneously for the dumrton of the of SR S.1..2, typically 2 ,umr. .

Duke Energy Progress Inc., believes that this conditional swuveftanae requirement unnecessarily makes the plant v to a test-caused failure mubi in both DGs being unavailable, for onl a slight Irese inconfidene by actively onySmong the Operbty of the DG not undergoing maintnancr every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (oding the regular monthly demonstration of Operability by the perkofwne of SR 3.8.1.2).

2.0 0ETAM.Q DESCRIP!IoN The proposed license amendment wouw modify Appendlix AX Technwa $pedfletions. by modifying current LCO U.11, RA W.3.2.2 to add aNOTE in front of RA 8.3.2.2 that stats that it is "Not required to be peWormed when the cause of the inoperable OG is pe-.palnd maintenance and tesWng."

2.1 DAUM %Mgdpfo The EDG system provides an emergency source of AC electcal power to the On-site Emergency AC Power subsystem, as required, for those events Where off-fst power Is assumed not to be available.

Each EDG Unit hall auto strt upon detection of undvolta"e on OWat WG's eospective emergency bus, except when the Local/Remot control switch IsInthe LOCAL position. Once the EDG reches design speed, the system will tmen ck th MDG output bmaerMW assum" the load on its respectiv bu.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0051 Page 3 of 9 Both EDGs shal auto start upon Initiation of SI, except when the LocalfRimote control switch is Inthe LOCAL position. Once the EDG reaches design speed, the system will run but not pickup load unless power Is lost to its respective bus.

The EDG system shal provide adequate mhpwdenc, redundancy, capacity, and tetabiity to permit the functioning of the ESFs and protection systems required to avoid undue risk to the health and safety of the public. The ECG system shall provide this Capacity assuming a single failure of a single activ component.

2.2 N G iG e MC Genet L*ttr 94-14, ""PpoedM Agtlo" to Impro Md E Vabl eosel Generator ReiaWUtf' InJuly *984, the NRC Issued Gerternc Letter (GL) 84"6, -Proposed Staff Actons to Improve and Manrtain Diesel Generator Relbility." The puopse of OL 8415 was to propose actions that would Improve the nelabmIty of ED*s. An example of a performance TS to support desired EDOG relabmilty goals was provided InEnclosure 3 to the GL This G0.provided two actions awmi the condition of on Inoperable EDO, which wow. (1) verffy corriet breaker algnment and power avablity of oftft power, and (2) v*iy the opposite train E. starts from ambient conditions an achieves rated fequency end voltage. The WnvA here im to demonstrate Opeability and no common mode problems exist. Accrding to GL 84-15,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Operable wasLOG Identiied as aeffected was not renableby thamount same of time to peform prol~ems. the inoperabl confirm that the Ot *-to EDO.*

eUlrMMM rod*

In May 1992, the NRC complefed a comprahowio wxamintlion of TS $

requirements tha require testim at power. This evaluation was docmented InNUREG-1386, which was published in Decembe 1092. In this guidance document, the staff reommended,

...the requirement to test the remaing diesel enwet s) he one diesel generator is inoperable due to any cause other than pre-planned preventr mtinveaec or testing be limited to those situations where the cau of inopembmity has not been conclusiely demonstrated to preclude the potentia for a common mode filure. However, "hen such lestin is required, itshould be performed within 8 ,**rs of having detrmined that the diesel generator is Inoperable.,

I

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13.0051 Page 4 of 9 NRC Genetic Letter 93-05, "Une4tem Technical tpecfcatiom Imrovi m-9 to Reduce Survellance Requirme for Testing Ow"g Power Operations" Based on the evaluation results that were documented In NUREG-1 366, the NRC issued Generic Letter 93-06, 'Une-item Technical Specifications Improvements to Reduce Surveillanoe Requirements for Testing During Power Operations," dated September 27, 193. Item 10.1 of GL 93-05 Includes recommendations for TS changes associated with EDG surveillance requirements. Recommendation number I under Item 10.1 states, "When

• EDO itself is inoperable (not Including a sopport system or Independently testable component), the other EOG should be tested only once (Mot every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unlss the absence of any potential common mode failure can be demonstrated Proposed TS wording acceptable to the NRC was also providad for licensees to Incorporate the above recomenedation Inft thaer TS as follows:

If the diesel generator becams Inoperable due to any cause other than i M. blt sW~rt sysem 1n Mnde l* *le coMMMLGE replanned preventive.

maintenance or teoting, demonsbate the OPERAOIRIY of the remaining OPERABLE diesel generator by performing Surveillance Requirements 4.8.1..2.a.5 and 4.8.1.1.2.a.6 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, uDJM fteAtuceSoIAM M! DM falure (The underiiedwodbg was added to the StandardTS by GL*)3-M)

It should be noted that the abov TS acknowledges that pr ned preventive maintenance or testing Is cause to not peftm the conditional surveillance of the alternate Operable EDO.

NUREG-1431, " *tno TochlnbW 8-a 1-0n- WS4t809ho l00 Plats NUREG-1433, Revision 0, was formally Issued on September 28. 1992 and contained the NUREG-1 366 recommendations for either demonstrating that a comron mode failure does not exist on the remaining EDO or testing the remaining ED0. Howee, the completion time for testing or demonstrating that a common mode failure does not exist on the remabnng EDG was relaxed from 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, consistent with the earlier L 84-15 recommendations.

30 TECHNICAL EVALUATION The HBRSEP curent TS (LO4 3.8.1, RA 9.3.2.Z) requires a conditional surveillance of the Operable EDG any time the alternate ED0 Isout of service for greet than 98 hours0.00113 days <br />0.0272 hours <br />1.62037e-4 weeks <br />3.7289e-5 months <br />. even when RA B.3.2.1, to ensure a common cause failure does not exist between the two machines, has been satisfactorily completed witin the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Such additional tUsting results in unnecessary out of service ti (i.e., unaeallab*lity) of the otherwise Operable EOG.

Consequently, Duke Energy Progress, I, seeks to revise tf H. B. Robinson TS criterion to be consistent with that of NRC guidance pulhe InGL 93-05 and NUREG-1366 to mInImize such unavailabilty and wear and tear due to testing whenever a common caue failure potential does not exist Bcfcl, a Not will be added to exempt RA 8.3.2.2 whenever the cause of inoperability of the alternate EG is re-ptened maintenM e end testing. Use Of the proposed exclusionary Note to RA 8.3.2.2 will still ensure the Operable EDG meets Its intended safety function in a highly reliable manner by taking mredit for the satifactoey performance of its required SRs, speciflolly SR 3.8.1.2 and 3.8.1.3, the 31 day (i.e., monthly) start and load tests,

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0051 Page 5 of 9 but without Introducing unnecessary testing and associated unavailability that would otherwise be needed to continue to meet the current TS RA for the cond-Monal surveilu*e. That is, regular performance of these SRs is otthrwise sufficient to demonstrate continued Operabiity of an EDG, so It should not be necessary to perform them on an acclred basis when no common caus problem exists between an EDOG and the a mrte EDG which has been taken out of service for preplanned mairdenance and tating.

During the pefomane of the codiltional survillance of RA 8.3.2.2 on thothe.wise Operable EDG, it, too, become inoperable. resulting In both EDGs being Inopeabfe'duMrl thI time it takes to perform SR 3.8.1.2 and return the EDG to Opebstatus (aproIIa"Tly 2 houm).

This makes the plant vulnerable to a loss of all AC power If a random problem develop In fth offe*te power source (i.e., a grod dsurbnce beyond the SwohyWd), which could cause a os of offste power (LOOP) and could also negvely Mpt the EDO under est, as Itattemopt to connect to its essential bus due to the loss of offte powr. While the pmr-plnedm Is diligently schedul to minimize the risk of los"g ofte power, tte risk cannwo be completely discounted or precluded. It also makes theEOG being tested vulnerable to a tet-caused failure which would also make tfe EDO unavailabe.

Inconclusion, Itis Duke EneW Pogrs, Inc. Jud et hat the added sMurano of Operability by performing the ntonal survftnce of RA 0.3.2.2 beyond Mat nomally afford by te satisfactory perfomance of the regularly schedule $R, absent a concem for a common cause problem (Le., RA B.32.1 Is met), dos not offet fte knte n ruailability of an otherwise Operable EDO and ttec p nt fo o ing a test-cused faike or a problem introduced by being conmected pamr to offt power by perforrmens of this condi0xial suivefance. b ft Isd a o t to exdcue uch amondonal survillances when th In case of Inoperabiity isfor rsaed preventive maintennc and esng.

The proposed Note will not apply and the conditional SUvellMe of RA 8.32.2 win still be performed every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> when the caus of the altenmt EDG I*erabfity Is for conctive maintenance to repair a problem. This is consist*e with the Stafs original requimen for the conditional mvellane for ansunng EDG Operability In ft aftrnt division O.

4.0 RUEtILTMt WMUALION" 4.1 Acg~igal BMW=aon &Wurmnt/~d By submittal of fthLicese Amvendment Request Duke Energ Progress. Irmo Ishereby requestng to modify the Technical Specfsmb f ". WRobnion Stem e PIOK Unit No. 2. The proposed amendment modifieS t Required Actions (RA) In Limiting Condition for Operation (LCO) 3.8.1 (AC Sources- Operting) for ofe nperble ODes enerator (00).

A new Note will be added to RA 9.3.2.2, the candition surveilln on the alternate, Opeable OG that require the peftmance of Surveilanc Reqtmn (SR) 3A 12 wUi 96 houm Te Note will.xewpt perfomance of thisW Inoperability of the DO ispre-planned mainktenanc ad testing.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RN13-0051 Page 6 of 9 Evaluation:

The proposed change is consistent with the ounent regulations and thus, an exemption pwsuant to 10 CFR 60.12 Is not required. The curre regulations (e.g, 560.36) do not diclte the specific actions to be taken when an EDOG is iperable; only that Limiting C4dt for Operability (LCO) are included In the TS that.. are the lowest funcions) capabitity or performance levels of equipment required for safe operation, of the facility. WO a Mft MOMdi, 19E-92RMto o o a ndW MIM eAto MA MA fet. MOM INsht OM down "* rfaww rat"(emphasis added) The pmposed change oe TS Actons for one oxpeW EWO continues to demonstra thosw CFR quiremerft a the RA for the 200 will cotinue to provide the necessary reoedial actions until the LCO Is again met.

The General Design Crite (GOC) in existence at the time HOR 2 was licensed (July, 1970) for operation were contained InProposed Appendix Ato 10 OMR 0, General Design CrOit fbr Nuclear Pow Plants, published in the Feder Regaster oln July 111, 1967.

GDOC 39 req that an emergecy power source se be prOe ad designed *dh dequ eem ,redundncy, aV , and tetbility to peMttefundon of ft engineered safety fet end4sprotection systems mruired to svold undue is Wthe heallh and safety of the publct This power somm 0 r Oft acity assuming a filure of a this single active component. The proposed change does not affec te des~rt of he omis or offite power systms. thus GOC 39 is not lnacted by t cMage GDCs 38, 47 and 48, a co*ntain provisions for testn of key safet systems (othe than the Electrical Pow Systems) The proposed chan InEDO coNmdit lo n test n does not impact this capablity, as fth inoiul, EDO wakospeclftsely SR, 3.8.12, alon with the various system simulated automatic aftuato Surveillnces, l tontinue to demostrmte that these GOCs are met.

The resed RA is om te with Improved Standa TS (UIEG44311). The *SES for RA 8.3.1 and 9,3.2 to LCO 3.8.1 stae.

Required Action 8.3.1 piovides an allowance to avoid unnoessay testng of OPERABLE D0s. IfItcan be detrmin tt the cause of the inoperable DO does not exist on fte OPERABLE D, SR 3.8.12 does not have to be pedoumed Because the proposed Note to RA 1&3.2.2 only applies whe~ pre-pl,'ed maintenance d testing are being conducted, the determination for no common cause ho already been saftfied by RA 8.3. 1; terlbre. it should not be necessary to perform SR 3U..1.2 asa conditfonal surveillance every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

Inconclusio based on the conskdehtns dius above, (1) thew is reasonable assurance that the health and safety of the public wilt not be endange by opwation in the pporsd manner, (2) such acvties will be conducted In complifnce with the Commisskoft mgulations.

and (3) the Issuance of the amendment will not be Inimca to the comon defse and secur or to. fe health and safet of the pubk. Therefor, we have cmckaded that the proposed revision to the H. B. Robinson Unit No. 2 Technical Spedfcadons Is acceptabl.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0051 Page 7 of 9 4.2 The NRC Issued a similar amendment for the Duane Arnold Energy Center in a le dated September 9, 2008, Agencywide Documents Accss ard Managemen System (ADAMS)

Accession No. ML082260116.

4-3 Ng SjWMgWjUWWg Poo=

Duke Energy Progress, Inc. has evaluated whethlr or not a significant hazards coeindatio Is involved with the proposed anmedment by focusing on the three standards st forth in 10 CFR 50.92, "lssuance of arnendment," as discussed below.

1. Does the proposed amendment involve a signifant Inrasein the probability or, consequences of an accident previously evaklatd?*

Responsc No.

The proposed ceg eoliminaets a conditional su tncea of the Operable EDG whenever the alternate dvision WOD Is out of service for prlanned malntenrnie and testing. The EDO are not an initiator of any accident previously evaluted. As a reu, the probability of any accident prebs evaluated Is not algnificantly Inwreased.

The consequences of any accident peviously evaluated are not increased, as the EDO wIlt continue to meet Its safety function to supply backup AC powm as spec~ied In the accident analysis, In a highly relable manner, as a cornmon cause problem between the two EMGs will have been precluded, fto atetnate division EDG will no bonger tlhen out of service ae for testing, and Its normally scheduled sumiftnce wi be met Therefore, the proposed chnge does not *nvole a sWig ft inrease Inthe probabli*ty or consequences of an acdent pr*voy eva d.

2. Does the proposed aeondment create to posWbit of a new or difent kind of accident from any accident previously evaluated?

Response: No, No new or different accidents result from utilizing #Ie propommt change. The change do not involve a physiW alteration of ft plant (I.e., no new of different type of equipment will be installed) or a change In the methods governing normal plant operation. The changes do not alter assumptions made in the safety andyi for EDO peformance.

Therefore, the proposed change does not rareat the posslit of a now or different kind of accident from any previously evaluated.

3. Does the proposedamendmentInvole a gnifiant reduon inf MarinfsIty .

Response: No.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/1 3-0051 Page S of 9 The proposed change eliminates a conditional surveillance of the Operable EDG whenever the alternate division EDOG Is out of service for pre-planned maintenance and testing. The EDG will continue to meet its specified safety function In the safety analysis to provide backup AC power, In a highly reliable manner, as a common cause problem betmen the two EDGs will have been precluded, the eftrne division EDG will n longer be taken out of service for testing, and its nrmally schedule evelllarnces will be met.

Therefore, the proposed change doesnot involve a significant redction In a margin of safety.

4.4 Based on the preceding 10 CFR 50.92 evalation Duke Energy Progrm onctkus that the proposed amendment presents no significant hazards co ai under "Wards 9M forth In10 CPR 50.92(c aWnd, accordinly, a finding of"no s c hazards consideration" Is fiW Justified.

&o Ml NMNT4YAL CONOIEM~ATIOM 10 CFR Section 51 .2(cX9) iderntfs certain Hicnsing and regulatory actions which are erqigble for categodcal exclusion from the requirement to perform an environmental assesunt A proposed amendment to an operetg loen for a falty requires no enVironmental sswmenIf operation of the facility in ecoordance with the proposed amendment would not (1) Involve a significant hazards conslieration; (2)reo Ina significant c ge inthypes or sinficant increase in the amounts of any effunts that may be reeased olfflte and (3) result in a significant increase In individual or cumulative occupational radiation exposure. Duke Energy, Progress has reviewed this request and determined tha the proposed amendment meets the eligibilitycriteria for cateorical exclusion set forth in 10 CFR Section $1 2(cX9). PuRmuat to 10 CFR Section 51.22(b). no environmental impact statament or enionmental assessment needs to be prepared in connec*ion with the Issuance of the amendment. The basis for this determination follOws.

Basis The change meets the eligibility criteria for vategoftM exclusion set fkith in 10 CFR Section 51.22(cX9) for the fowing reasons:

1. As demonstmted In the 10 CFR 50.92 evaation included in this exhibit, th pposed amendment does not Involve a si c hazards c ns.

2. The proposed changes do not result In an incmse In power leve, do not Increase the production, nor alter the flow path or method of disposa of radioactive waste or byproducts. There is no signifcnt chang in the types or significn Inrease In the amounts of any efftuents that may be released Offt.

3. The proposed changes do not result in canges In the level of control or methodology used for processing of radioactive effluents or handfg of soMlid rdioactive waste nor will the poposal result In any change in the normnal radlation levIs within the pknt. There Is no significant increase In Irdividual or cumulative occupational radiation exposure.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA4I3-0051 Page 9 of 9

6.0 REFERENCES

I. Duane Arnold Energy Center Technial 4 Change Request (T$CR-101):

"OE*mkuftn of Emergency Diesel Generator Conditional Surveillance Requirement for Pro-planned Preventive Maintenance and Tes"ng," dated February 19,2008.

AgencyMde Documents Ace and Management System (ADAMS) Accession No. ML080730143.

2. NRC Letter to Duane Arnold Energy Center - lssuace of Amendment lcense Amendment Request to Remove fht Emergency Diesel Generator Surveillance Requiem for Pm-lanned Prntie Maintnc OWd Tesli.dated September 9.

2008, ADAMS Accession No. ML0 01 16.

Enclosure to Serial: RNP-RA/1 3-0051 2 Pages (Including cover page)

ATTACHMENT I H8.9. R0004SON STEAM ELECTRC PLANT. UNIT NO. 2 PROPOSED TECHNICAL SPECIFCATIONS CHANGES (MARK-UP)

AC SO 3.8.1 C-ON121TION I REUIRED A-CT-IN ICOMPLETIN TIME S. One OG Inoperable 0,1 Perform SR 3.8.1.1 for the oftsft circult once Uhou wo 8.2 Declr raqpured 4 how, feokmss) suppoited ffnB Condff concur reuredfdundant biyof

%aturs)Is radund

%awe 8.3.1 Pedorm SR 3.8.1.2 24 houim for OPERABLE DG QB 0.3.2t1 Derm*i OPERABLE 0(G Isnot ftpwaW 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Due to common camse fmg 8.32.2 Peform SR 3.8.1.2 so hours for OPERALE D0.

HSRSEP Unit No. 2 3.8-2 AndmenT No. 4M

Enclosure to Serial: RNP-RAJ13-0051 2 Pages (Including cover page)

ATTACHMENT 2 H.S. RO.* ,sON STEAM ELECTRC PLtANT, UNIT NO. 2 REVISED AND RETYPED TECHNfAL SPECIFICATIO PAGES

AC Sources-Operating 3.8.1 ACTIONS (continued)

U I

,!.mfII*U TI ("

• *U j * 'N t F B

• I Tnf HEWS B. One DG Inoperable. B.1 Perform SR 3.8.1.1 1hour for the offsite circuit.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Decdare feti.s) reqt#md suppoited 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of by the Inoperable 00 Conditon B Inoperable when its concurrent with required redundant.. ".!4ý i.loperbility of feature(s) Is inoperable. requred feature(s)

Peform SR 301.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Aw OPERALS I)G 6.3.2.1 Detenmae OPERABLE OG 24 ttmut is not Inoperable due to corrmn cause failure.

-. ~-.----NOTE Not required to be peftmed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the caum of the nopWable D0 is eplann*d mairnenance andtesti.

6.3.2.2 Peorfom SR3.8.1.2 for OPERABLE DO.

(confimmed HORSEP Unit No. 2 Amentiment No.

Enclosure to Serial: RNP-RA/1 3-0051 2 Pages (including cover page)

ATTACHMENT 3 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGES (Provided for lnftmatn Only)

AC Soure-O"m" BASES ACTIONS B.3.1. B.3.2j. and .3,.2 (continued) satisfied. If the cause of the iniil inoperable DG cannot be confimed not to exist on the rmain WG(s) performance of SR 3.8.1.2 suffices to provide assurance of conftnued OPERABILITY of that DG.

If it is verified n 24 houm that the OPERABLE DG Is not inoperable due to common cause failure, SR 3.8.1.2 need not be performed withn 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, it is still necessary to verify the OPERABILITY of the OPERABLE DG within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Testing the OPERABLE DG more than once during the 7 day Completion Time Is not required.

In the event the inoperable DG Isrestored to OPERABLE status prior to completing either B93.1 or 8.3.Z the plant oective action program wiD continue to evaluate the common cause possibility. This conlinued evakltion. however, Isno onger under ft 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint impse while in Condition 8.

Accortlng to Generic Leiter 84-18 (Ref. 6), 24 hor Is reamonable to confirm thaOthe OPERABLE DG(s) is not affected by the same problem as the noperable DG.

Operation may continue in Condition 8 for a peiod that should not eceed 7days.

in Corndti 6, the rman OPERALE DOG and offeite circu are adequate to supply ecrical power to the onste DiWtb n Sysem.

The 7 day Conmpetion T ekes mino acount the apacity and capability of the remaining AC souroms, a mmonable time for repaim, and the low probebit of a DBA mori during Ot period.

The second Completon Time for Reqired Action BA establishes a limt on the maximum time alowed for any mombinadon of required AC power sources to be inoperable durn any Ong contioums occurrence of faWting to omet the LCO. IfConditon 8 is ntermd Wile, for IrMarne, an offe orcult Is ope e and th ccuit is subsequently restored OPERABLE, ft CO may already have bn not met for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This could lead to a total MBRSEP Unit No. 2 B 3.8-