ML11214A214

License Amendment Request, Extension of the Completion Time for Inoperable Diesel Generator - Response to NRC Request for Additional Information

ML11214A214
Person / Time
Site:	Nine Mile Point
Issue date:	07/25/2011
From:	Belcher S Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME3736
Download: ML11214A214 (15)

Text

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Sam Belcher P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CENGSM a joint venture of Energy* *' eDF 0 Constellation NINE MILE POINT NUCLEAR STATION July 25, 2011 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-410 License Amendment Request Pursuant to 10 CFR 50.90: Extension of the Completion Time for an Inoperable Diesel Generator - Response to NRC Request for Additional Information (TAC No. ME3736)

REFERENCES:

(a) Letter from S. Belcher (NMPNS) to Document Control Desk (NRC), dated March 30, 2010, License Amendment Request Pursuant to 10 CFR 50.90:

Extension of the Completion Time for an Inoperable Diesel Generator -

Technical Specification 3.8. 1, AC Sources - Operating (b) Letter from T. A. Lynch (NMPNS) to Document Control Desk (NRC), dated June 1, 2010, License Amendment Request Pursuant to 10 CFR 50.90: Extension of the Completion Time for an Inoperable Diesel Generator - Response to NRC Acceptance Review Comments (TAC No. ME3736)

(c) Letter from R. V. Guzman (NRC) to S. L. Belcher (NMPNS), dated July 11, 2011, Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 - Re: Technical Specification Review for Extension of Completion Time for Inoperable Diesel Generator (TAC No. ME3736)

Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted request for amendment to Nine Mile Point Unit 2 (NMP2)

Renewed Operating License NPF-69. The initial request, dated March 30, 2010 (Reference a), as supplemented by Reference (b), proposed to modify Technical Specification (TS) 3.8.1, "AC Sources -

Operating," to extend the Completion Time for an inoperable Division I or Division 2 diesel generator

Document Control Desk July 25, 2011 Page 2 (DG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The supplemental information, provided in Attachment 1 to this letter, responds to the request for additional information (RAI) documented in the NRC's letter dated July 11, 2011 (Reference c). A revised list of regulatory commitments is provided in Attachment 2. Associated changes to the marked-up TS Bases pages are provided in Attachment 3.

This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental information to the appropriate state representative.

Should you have any questions regarding the information in this submittal, please contact John J. Dosa, Director Licensing, at (315) 349-5219.

Very truly yours, STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Sam Belcher, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this response on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of OGS4ej0 ,this 2-!S dayof ,,J't ,2011.

WITNESS my Hand and Notarial Seal: b/,oc44-/a)4w Notary Public My Commission Expires:

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i Document Control Desk July 25, 2011 Page 3 Attachments: 1. Nine Mile Point Unit 2 - Response to NRC Request for Additional Information Regarding the Proposed Extension of the Completion Time for an Inoperable Diesel Generator from 72 Hours to 14 Days

2. List of Regulatory Commitments

3. Changes to Technical Specification Bases (Mark-up) - Revised cc: Regional Administrator, Region I, NRC Project Manager, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA

ATTACHMENT 1 NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED EXTENSION OF THE COMPLETION TIME FOR AN INOPERABLE DIESEL GENERATOR FROM 72 HOURS TO 14 DAYS Nine Mile Point Nuclear Station, LLC July 25, 2011

ATTACHMENT 1 NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED EXTENSION OF THE COMPLETION TIME FOR AN INOPERABLE DIESEL GENERATOR FROM 72 HOURS TO 14 DAYS By letter dated December 29, 2010, as supplemented by letter dated April 27, 2011, Nine Mile Point Nuclear Station, LLC (NMPNS) responded to NRC Electrical Engineering Branch (EEEB) RAI-4. Also, by letter dated January 14, 2011, NMPNS responded to NRC probabilistic risk assessment (PRA) review RAI-1. Both of these RAIs were concerned with: (1) assurances that the Division 3 (High Pressure Core Spray - HPCS) diesel generator (DG) would be operable during the proposed extended Completion Time (CT) for an inoperable Division 1 or Division 2 DG; and (2) actions that would be taken if the Division 3 DG became inoperable after entering the extended CT.

The NMPNS responses to EEEB RAI-4 and PRA RAI-1 noted that, prior to utilizing the extended CT (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), operability of the HPCS system and the Division 3 DG (as required by existing Nine Mile Point Unit 2 (NMP2) Technical Specifications (TS) 3.5.1 and 3.8.1, respectively) would be confirmed, with no planned maintenance or testing activities scheduled. The NMPNS responses also described the TS-required actions that would be taken if the Division 3 DG became inoperable after entering the extended CT for the Division 1 or Division 2 DG. Based on TS 3.8.1 Condition E for two required DGs inoperable (including the associated TS Bases), NMPNS concluded that the longest time that the Division 3 DG could be inoperable prior to initiating a TS-required plant shutdown would be 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />.

NMPNS has reviewed the TS Review RAI-1, RAI-2, and RAI-3 transmitted by NRC letter dated July 11, 2011. Consistent with discussions between NRC and NMPNS staff members during a conference call on June 22, 2011, these RAIs collectively identify two basic NRC staff concerns, which can be summarized as follows:

A. Justify the propriety of: (1) declaring the HPCS system inoperable at the end of the 24-hour CT specified in TS 3.8.1 Condition E for two required DGs inoperable; and (2) utilizing the 4-hour CT of TS 3.8.1 Condition B.2 for subsequently determining that required redundant features are inoperable. [Reference NRC TS Review RAls 1.a, 1.b, 1.c, 1.d, 2, and 3]

B. The List of Regulatory Commitments associated with the proposed license amendment (described in Attachments 2 and 3 of NMPNS letter dated January 14, 2011) states: "The HPCS system is available and no planned maintenance or testing activities are scheduled." However, the NMPNS response to RAI-1 in the same January 14, 2011 letter states that "operability of the HPCS system and the Division 3 (HPCS) DG will be confirmed ... " Provide the definition for "available" and explain the difference between availability and operability as used in these statements. [Reference NRC TS Review RAI-1 .e]

NMPNS responses for each of the above two identified concerns are provided below.

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ATTACHMENT 1 NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED EXTENSION OF THE COMPLETION TIME FOR AN INOPERABLE DIESEL GENERATOR FROM 72 HOURS TO 14 DAYS

• NMPNS Response - Concern A [Reference NRC TS Review RAIs L.a, Lb1.Lc 1.A. 2. and 31 After further consideration, NMPNS is revising the response to EEEB RAI-4 (initially submitted by NMPNS letter dated December 29, 2010, and supplemented by NMPNS letter dated April 27, 2011) and PRA RAI- 1 (initially submitted by NMPNS letter dated January 14, 2011). The revised response, applicable to both of the referenced RAIs, is provided below.

Revised Response - EEEB RAI-4 and PRA RAI-1 As noted in the March 30, 2010 NMPNS submittal, prior to utilizing the extended DG CT (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), operability of the HPCS system and the Division 3 (HPCS) DG will be confirmed, with no planned maintenance or testing activities scheduled. This confirmation is a pre-requisite for entering the extended DG CT. The basis for this requirement is the technical evaluation for the proposed license amendment, which credits the capability to utilize the Division 3 DG as an alternate source of AC power as a defense-in-depth feature and credits operability of the HPCS system and the Division 3 DG in the risk assessment.

The TS operability requirements applicable to the HPCS system are contained in TS 3.5.1 for the HPCS system and in TS 3.8.1 for the Division 3 DG. Both the HPCS system and the Division 3 DG are required to be operable in Modes 1, 2, and 3. As specified in TS 3.8.1, if the Division 3 DG became inoperable during the time that the Division 1 or Division 2 DG was already inoperable, Required Action E. 1 would require that the Division 3 DG be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The NMP2 TS Bases for TS 3.8.1 Condition E (which are essentially identical to the Bases shown in the approved Standard Technical Specifications, NUREG- 1434, Revision 3), state the following regarding the 24-hour CT of TS 3.8.1 Condition E:

"At the end of this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the Division 3 system (HPCS System) could be declared inoperable (see Applicability Note) and this Condition could be exited with only one required DG remaining inoperable. However, with a Division 1 or 2 DG remaining inoperable and the HPCS declared inoperable, a redundant required feature failure exists, according to Required Action B.2."

[underlining added]

Given the operability confirmations performed prior to entering the extended CT for the Division 1 or Division 2 DG, subsequent discovery of a condition that causes the Division 3 DG to be declared inoperable is not likely. However, if such a situation were to occur, the Division 3 DG must be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with TS 3.8.1 Condition E. If the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT is not met, TS 3.8.1 Condition F would be entered requiring initiation of a plant shutdown. NMPNS has determined that it would not be appropriate to declare the HPCS system inoperable at the end of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, as indicated by the "could" statements in the TS Bases for TS 3.8.1 Condition E, since:

• Declaring the HPCS system inoperable would not resolve the condition that is causing the Division 3 DG to be inoperable.

• The cause for declaring the HPCS system inoperable (i.e., the inoperability of the Division 3 DG) is known and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would have already been used to evaluate and repair the condition.

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ATTACHMENT 1 NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED EXTENSION OF THE COMPLETION TIME FOR AN INOPERABLE DIESEL GENERATOR FROM 72 HOURS TO 14 DAYS

• It would be known ahead of time that declaring the HPCS inoperable will result in the inoperability of redundant required features, according to TS 3.8.1 Condition B, Required Action B.2, and the associated TS Bases. No additional time to make this determination would be needed or warranted.

The existing TS requirements are deemed adequate to limit the time to restore the Division 3 DG to operable status in the event it became inoperable after entering the extended CT for a Division 1 or Division 2 DG. To underscore these TS requirements, and to assure that plant operator training on these requirements occurs as part of the implementation actions for the proposed license amendment request (in accordance with existing NMPNS processes for implementing the TS and procedure changes), the List of Regulatory Commitments associated with the license amendment request is revised to include a commitment consistent with the above discussion, as shown in Attachment 2 to this letter (Commitment No. 2a). The initial sentence of Commitment No. 2 is also revised to state: "Prepare or revise appropriate procedures and training to include..." The underlined portion has been added.

0 NMPNS Response - Concern B [Reference NRC TS Review RAI Le]

The TS term "OPERABLE" is defined in TS Section 1.1 as follows:

"A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s)."

As described in the Bases for TS SR 3.0.1, systems and components are assumed to be OPERABLE when associated Surveillance Requirements specified in the TS have been met.

The term "availability" is used both in the 10 CFR 50.65 ("Maintenance Rule") monitoring process and in the performance indicator (PI) process. NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," describes an approach to meet the requirements of 10 CFR 50.65 that has been endorsed by the NRC in Regulatory Guide 1.160 (with certain provisions and clarifications). Based on the definitions contained in Appendix B of NUMARC 93-01, a structure, system, or component (SSC) is available if it is capable of performing its intended function(s).

Availability of a SSC includes consideration of established success criteria and mission times. The baseline PRA used to perform the risk evaluation for the proposed extension of the CT for an inoperable Division I or Division 2 DG uses plant operating data gathered in accordance with the requirements of 10 CFR 50.65 to establish the availability and reliability of plant SSCs that are modeled in the PRA. Since the configuration risk management controls itemized in the List of Regulatory Commitments for the proposed license amendment were derived from the risk evaluation, they were composed using the "available" term rather than OPERABLE.

Nuclear Energy Institute document NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," provides definitions and guidance for the purpose of reporting performance indicator data as 3 of 4

ATTACHMENT 1 NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED EXTENSION OF THE COMPLETION TIME FOR AN INOPERABLE DIESEL GENERATOR FROM 72 HOURS TO 14 DAYS part of the NRC power reactor licensee assessment process. NRC Inspection Manual Chapter 0608 notes that NEI 99-02 is jointly produced by the NRC and NEI. As stated in NEI 99-02, a system or component that is considered to be OPERABLE is also considered to be available; however, the opposite may not be true.

To eliminate any potential uncertainty regarding application of the configuration risk management controls, NMPNS is revising the List of Regulatory Commitments associated with the license amendment request by replacing "available" with "operable" for those systems and components that are required by the TS; i.e., the HPCS system, the reactor core isolation cooling (RCIC) system, the Division 1 and Division 2 residual heat removal (RHR) pumps, the low pressure core spray (LPCS) pump, the redundant reactivity control system, and the standby liquid control system. The revised List of Regulatory Commitments is provided in Attachment 2 to this letter. The TS Bases changes that were included in the January 14, 2011 NMPNS submittal (Attachment 3, INSERT B for TS Bases page B 3.8.1-10) are also revised in a similar manner, as shown in Attachment 3 to this letter. This change in terminology does not have any impact on the risk evaluations that have been performed to support the proposed license amendment.

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ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS Nine Mile Point Nuclear Station, LLC July 25, 2011

ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS The following table is an update to the list of regulatory commitments that was originally provided in Attachment I of the Nine Mile Point Nuclear Station, LLC (NMPNS) letter dated March 30, 2010 and subsequently revised in Attachment 2 of the NMPNS letter dated January 14, 2011. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

SCHEDULED REGULATORY COMMITMENT COMPLETION DATE

1. Complete the modification and associated implementing procedures to 90 days following provide the Division 3 diesel generator (DG) with a source of backup cooling NRC approval of the water from the fire protection water supply system and its associated diesel- license amendment driven fire water pumps. request. [Completed]

2. Prepare or revise appropriate procedures and training to include provisions 90 days following for implementing compensatory measures and configuration risk NRC approval of the management controls when entering an extended DG completion time (CT) license amendment (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), including the following: request.

a. The other two DGs are operable and no planned maintenance or testing activities are scheduled on those two DGs. Should the Division 3 DG become inoperable after entering the extended DG CT, plant shutdown will be initiated if the Division 3 DG cannot be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (unless the applicable TS Condition is exited by restoring the Division I or Division 2 DG to operable status).

b. No planned maintenance or testing activities are scheduled in Scriba Substation, the Nine Mile Point Unit 2 (NMP2) 115 kV switchyard, or on the 115 kV power supply lines and transformers which could cause a line outage or challenge offsite power availability.

c. The high pressure core spray (HPCS) system is operable and no planned maintenance or testing activities are scheduled.

d. The reactor core isolation cooling (RCIC) system is operable and no planned maintenance or testing activities are scheduled.

e. The NMP2 and Nine Mile Point Unit 1 (NMPl) diesel-driven fire pumps and the cross-tie between the NMP2 and NMP 1 fire protection water supply systems are available to provide a backup cooling water supply to the Division 3 DG and no planned maintenance or testing activities are scheduled.

f. The Division 1 and Division 2 residual heat removal (RHR) pumps and the low pressure core spray (LPCS) pump are operable and no planned maintenance or testing activities are scheduled.

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ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS SCHEDULED REGULATORY COMMITMENT COMPLETION DATE

g. Both divisions of the redundant reactivity control system and the standby I liquid control system (equipment required for mitigation of anticipated transients without scram (ATWS) events) are operable and no planned maintenance or testing activities are scheduled.

h. The stability of existing and projected grid conditions will be confirmed prior to planned entry into the extended DG CT by contacting the transmission system operator (TSO).

i. Operating crews will be briefed on the DG work plan. As a minimum, the briefing will include the following important procedural actions that could be required in the event a loss of offsite power (LOOP), station blackout (SBO), or fire condition occurs:

- Alignment of the fire protection water supply system to provide cooling water to the Division 3 DG.

- Establishing the cross-connection to allow the Division 3 DG to power either Division 1 or Division 2 loads.

- Utilizing the portable generator as a backup source of AC power to one of the Division 1 or Division 2 battery chargers.

- Utilizing the portable power supplies to maintain operability of the safety relief valves (SRVs).

- Closing containment isolation valves in the drywell floor drain and equipment drain lines.

j. The extended DG CT will not be entered for planned maintenance if severe weather conditions (high winds, tornado, or heavy snow/ice) with the potential to degrade or limit offsite power availability are present, or if official weather forecasts are predicting such conditions to occur.

k. Except for the room housing the inoperable DG, no hot work permits will be active for the control building or the normal switchgear rooms.

1. A portable generator is available as a temporary backup source of AC power to one of the Division 1 or Division 2 battery chargers and is pre-staged within the protected area near the NMP2 control building.

m. Four portable power supplies are available for use to facilitate operation of safety relief valves to maintain RPV pressure control for an extended SBO condition and are verified to be functional.

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ATTACHMENT 3 CHANGES TO TECHNICAL SPECIFICATION BASES (MARK-UP)

REVISED The mark-up for NMP2 Technical Specification Bases page B 3.8.1-10, previously provided in of the January 14, 2011 NMPNS submittal, is revised. Specifically, the list of compensatory measures and configuration risk management controls in "INSERT B" is modified. This Bases page is provided for information only.

Nine Mile Point Nuclear Station, LLC July 25, 2011

AC Sources-Operating B 3.8.1 BASES ACTIONS B.2 (continued) required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources,-reasonable time for repairs, and low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG(s), SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DGs, the other DGs are declared inoperable upon discovery, and Condition E or G of LCO 3.8.1 is entered, as applicable.

Once the failure is repaired, and the common cause failure no longer exists, Required Action B.3.1 is 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 those DG(s).

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the Deficiency Event Report 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. 9), 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable time to confirm that the OPERABLE DG(s) are not affected by the same problem as the inoperable DG.

B.4 I *ninuein ~ndi 11*B fur d period tha - Id(,-

17L

_... In6 g

• the remaining OPERABLE DGs and i 51 e circuits are adequate to supply electrical power to the onsite Class 1E distribution system. 'The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> yser 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. I,--- ( rontinued )

NMP2 B 3.8.1-10 Revision *1_3

INSERT A (for TS Bases page B 3.8.1-10) [Unchanged]

Although Condition B applies to a single inoperable DG, several Completion Times are specified for this Condition.

The first Completion Time applies to an inoperable Division 3 DG.

INSERT B (for TS Bases page B 3.8.1-10) [Revised]

This Completion Time begins only "upon discovery of an inoperable Division 3 DG" and, as such, provides an exception to the normal "time zero" for beginning the allowed outage time "clock" (i.e., for beginning the clock for an inoperable Division 3 DG when Condition B may have already been entered for another equipment inoperability and is still in effect).

The second Completion Time (14 days) applies to an inoperable Division 1 or Division 2 DG and is a risk-informed Completion Time based on a plant-specific risk analysis. The extended Completion Time would typically be used for voluntary planned maintenance or inspections but can also be used for corrective maintenance. However, use of the extended Completion Time for voluntary planned maintenance should be limited to once within an operating cycle (24 months) for each DG (Division 1 and Division 2). When utilizing an extended DG Completion Time (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), the compensatory measures and configuration risk management controls listed below shall be implemented. For planned maintenance utilizing an extended Completion Time, these measures and controls shall be implemented prior to entering Condition B. For an unplanned entry into an extended Completion Time, these measures and controls shall be implemented without delay.

1. The other two DGs are operable and no planned maintenance or testing activities are scheduled on those two DGs.

2. No planned maintenance or testing activities are scheduled in Scriba Substation, the NMP2 115 kV switchyard, or on the 115 kV power supply lines and transformers which could cause a line outage or challenge offsite power availability.

3. The HPCS system is operable and no planned maintenance or testing activities are scheduled.

4. The RCIC system is operable and no planned maintenance or testing activities are scheduled.

5. The NMP2 and NMP1 diesel-driven fire pumps and the cross-tie between the NMP2 and NMP 1 fire protection water supply systems are available to provide a backup cooling water supply to the Division 3 DG and no planned maintenance or testing activities are scheduled.

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INSERT B (continued)

6. The Division 1 and Division 2 residual heat removal (RHR) pumps and the low pressure core spray (LPCS) pump are operable and no planned maintenance or testing activities are scheduled.

7. Both divisions of the redundant reactivity control system and the standby liquid control system (equipment required for mitigation of anticipated transients without scram (ATWS) events) are operable and no planned maintenance or testing activities are scheduled.

8. The stability of existing and projected grid conditions will be confirmed prior to planned entry into the extended DG CT by contacting the transmission system operator (TSO).

9. Operating crews will be briefed on the DG work plan. As a minimum, the briefing will include the important procedural actions that could be required in the event a LOOP, SBO, or fire condition occurs.

10. The extended DG CT will not be entered for planned maintenance if severe weather conditions (high winds, tornado, or heavy snow/ice) with the potential to degrade or limit offsite power availability are present, or if official weather forecasts are predicting such conditions to occur.

11. Except for the room housing the inoperable DG, no hot work permits will be active for the control building or the normal switchgear rooms.

12. A portable generator is available as a temporary backup source of AC power to one of the Division 1 or Division 2 battery chargers and is pre-staged within the protected area near the NMP2 control building.

13. Four portable power supplies are available for use to facilitate operation of safety relief valves to maintain RPV pressure control for an extended SBO condition and are verified to be functional.

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