RNP-RA/14-0051, Supplemental Submittal to H. B. Robinson, Unit No. 2 (HBRSEP2) Original Submittal and Response to NRC RAI Regarding License Amendment Request to Modify Technical Specification 3.8.1 Proposed Changes to Diesel Generator Testing Require

Supplemental Submittal to H. B. Robinson, Unit No. 2 (HBRSEP2) Original Submittal and Response to NRC RAI Regarding License Amendment Request to Modify Technical Specification 3.8.1 Proposed Changes to Diesel Generator Testing Requirements

ML14163A480
Person / Time
Site:	Robinson
Issue date:	06/01/2014
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/14-0051, TAC MF2717
Download: ML14163A480 (8)

Text

DU E W R.GIDEON H. S. Robinson Steam Electric Plant Unit 2 ENERGY, Site Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 10 CFR 50.36 Serial: RNP-RA/14-0051 JUN 0 1 2014 ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 SUPPLEMENTAL SUBMITTAL TO H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.

2 (HBRSEP2) ORIGINAL SUBMITTAL AND RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION 3.

8.1 PROPOSED CHANGE

S TO DIESEL GENERATOR TESTING REQUIREMENTS (TAC NO. MF2717)

References:

1. Letter from Sharon A. Wheeler-Peavyhouse (Duke Energy Progress, Inc.) to the U.S.

Nuclear Regulatory Commission (Serial: RA-1 3-0051), License Amendment Request to Modify Technical Specification 3.8.1 ProposedChanges to Diesel Generator Testing Requirements, dated September 10, 2013, ADAMS Accession Number ML13261A289

2. E-mail from Siva Lingam (USNRC) to Richard Hightower (Duke Energy Progress, Inc.),

H.S. Robinson, Unit 2 - RAIs for LAR Associated with Modification to TS 3.8.1 RegardingDiesel GeneratorTesting Requirements (TAC No. MF2717), dated January 8, 2014, ADAMS Accession Number ML14016A278

3. Letter from W. R. Gideon (Duke Energy Progress, Inc.) to the U.S. Nuclear Regulatory Commission (Serial RNP-RA/1 4-0010), Response to NRC Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.8.1 Proposed Changes to Diesel GeneratorTesting Requirements (TAC NO. MF2717)

ADAMS Accession Number ML14037A105 Ladies and Gentlemen:

By letter dated September 10, 2013 (Reference 1), Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company, submitted a license amendment request to modify Technical Specification 3.8.1.B.3.2.2.:"

United States Nuclear Regulatory Commission Serial: RNP-RA/14-0051 Page 2 of 2 On January 8, 2014, the NRC provided a request for additional information (RAI) (Reference 2),

concerning the referenced license amendment request. Duke Energy Progress responded to this RAI via letter dated January 30, 2014 (Reference 3).

Duke Energy Progress, Inc. is submitting this supplement to Reference 3 to inform the NRC staff of HBRSEP's intent to incorporate changes discussed with the NRC Project Manager and NRC Technical Branch staff via teleconference held on April 28, 2014 between NRC staff and HBRSEP2 staff. Updated markup and retyped Technical Specifications pages and updated markup Technical Specifications Bases pages are provided as the Enclosure to this letter.

There are no regulatory commitments made in this submittal. If you have any questions regarding this submittal, please contact Mr. R. Hightower at (843) 857-1329.

I declare under penalty of perjury that the foregoing is true and correct.

Executed On: \ J* -*(

Sincerely, W. R. Gideon Site Vice President WRG/jmw Enclosure cc: Mr. V. M. McCree, NRC, Region II Ms. Martha C. Barillas, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP, Unit No. 2

U. S. Nuclear Regulatory Commission Enclosure to Serial RNP-RA/14-0051 6 Pages (including cover sheet)

SUPPLEMENT TO HBRSEP2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION 3.

8.1 PROPOSED CHANGE

S TO DIESEL GENERATOR TESTING REQUIREMENTS (TAC NO. MF2717)

U. S. Nuclear Regulatory Commission Enclosure to Serial RNP-RA/14-0051 Page 2 of 6 Supplemental Technical Specifications Pages and Markup Technical Specifications Bases Pages The markup and retyped Technical Specifications (TS) pages as well as the markup TS Bases pages have been revised as discussed per teleconference. The revised pages are provided by means of this Enclosure and supersedes those pages conveyed via the original RAI response submittal. Please replace the pages of the original RAI response submittal as indicated below.

Original Page(s) Revised Page(s)

TS Markup: 3.8-2 TS Markup: 3.8-2 (with Insert 1)

TS Retyped: 3.8-2 TS Retyped: 3.8-2 TS Bases Markup: B 3.8-9 TS Bases Markup: B 3.8-9

AC Sources-Operating 3.8.1 ACTIONS (continued)

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

AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s) supported by discovery of the inoperable DG Condition B

- NOTE ------------------ inoperable when its concurrent with Not required to be performed if the required redundant inoperability of cause of the inoperable DG is feature(s) is inoperable. redundant required solely due to pre-planned feature(s) maintenance or Surveillance AND testing.

B.3.1 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DG OR B.3.2.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG is not inoperable due to common cause failure.

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

AND (continued)

HBRSEP Unit No. 2 3.8-2 Amendment No. -176-

AC Sources-Operating 3.8.1 ACTIONS (continued)

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

AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s) supported by discovery of the inoperable DG Condition B inoperable when its concurrent with required redundant inoperability of feature(s) is inoperable. redundant required feature(s)

AND

..--------NOTE-------

Not required to be performed if the cause of the inoperable DG is solely due to pre-planned maintenance or Surveillance testing.

B.3.1 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DG OR B.3.2.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG is not inoperable due to common cause failure.

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

AND (continued)

HBRSEP Unit No. 2 3.8-2 Amendment No.

AC Sources - Operating B 3.8.1 BASES ACTIONS B.3.1, B.3.2.1, and B.3.2.2 (continued) satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

If it is verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the OPERABLE DG is not inoperable due to common cause failure, SR 3.8.1.2 need not be performed within 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 is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 6), 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 Operation may continue in Condition B for a period that should not exceed 7 days.

In Condition B, the remaining OPERABLE DG and offsite circuit are adequate to supply electrical power to the onsite Distribution System. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet he LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been 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 (continued)

HBRSEP Unit No. 2 B 3.8-9 Revision No.-G-

INSERT 1 A NOTE has been added to take exception to perform REQUIRED ACTION B.3.1 or B.3.2 and associated COMPLETION TIME for a DG intentionally removed from service solely for the reasons of performing pre-planned maintenance or SURVEILLANCE testing because no identified DG failure has occurred and the likelihood of the OPERABLE DG having an undetected failure is low. This exception is acceptable since the cause of the inoperable DG is known and is not related to correcting a DG failure mechanism (i.e., corrective maintenance) causing the DG to be inoperable when entering CONDITION B.

If a DG failure mechanism is identified at any time during preventative maintenance, corrective maintenance or during testing, REQUIRED ACTION B.3.1 or B.3.2 must be reentered for the OPERABLE DG. If the COMPLETION TIME commencing at the time the LCO was initially not met has expired, then the COMPLETION TIME commences from the time of the discovery of any failure mechanism that is identified during maintenance or testing of the inoperable DG. This allows an exception to the normal "time zero" for beginning a new COMPLETION TIME "clock". In this instance, the COMPLETION TIME "time zero" is specified as commencing at the time the failure mechanism is identified, instead of at the time the associated CONDITION was entered. REQUIRED ACTION B.3.1 or B.3.2, performance of SR 3.8.1.2 for the OPERABLE DG, need not be performed if it has been successfully performed within the previous 24-hours, or if it is currently operating. Performance of SR 3.8.1.2 within the previous 24-hours meets the intent of REQUIRED ACTION B.3.1 or B.3.2 by providing reasonable assurance that the OPERABLE DG will perform its associated safety function.