B13236, Draft Ltr Forwarding Comparison Between Util 880829 Proposed Tech Specs & Westinghouse STS & Justification for Any Deviations,Per 890330 Meeting W/Nrc

Draft Ltr Forwarding Comparison Between Util 880829 Proposed Tech Specs & Westinghouse STS & Justification for Any Deviations,Per 890330 Meeting W/Nrc

ML20247H173
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/18/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B13236, TAC-66797, NUDOCS 8905310181
Download: ML20247H173 (29)

Text

_ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,

'.s .'.

• e '

NIfTIRJTIES o nor.i Ome.. . s.io n sir i, seriin Connecticut l 8 "

P.O. BOX 270 HARTFORD. CONNECTICUT 06141-0270 k

b Y, Yst E eU 5",c (203) 665-5000 May 18, 1989 ILocket No. 50-213 B13236 .

ISAP Topic No. 1.44 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

(

Gentlemen:

Haddam Neck Plant Additional Information Regarding Proposed Revision to Technical Specifications Electrical Power Systems (TAC No. 66797)

On August 29, 1988,(I) Connecticut Yankee Atomic Power Company (CYAPCO) submitted a revised license amendment request in the Westinghouse (H) Standard Technical Specification (STS) format for the degraded grid voltage protection requirements.

On March 30, 1989, CYAPC0 met with the NRC Staff to discuss this proposed license amendment and to provide justification for where the proposed Techni-cal Specification deviates from the H STS. Each justification is with the guidelines submitted to the NRC Staff on October 26,1988.(gnsistent CYAPC0 has agreed that the H STS should be adopted except when:

1. Plant-specific design considerations would dictate otherwise, or

2. Hardware, structural, or organization changes from previously approved conditions would be required to conform to the H STS, or

3. Based on past operating experience, the existing plant-specific requirement can be shown to provide an equivalent degree of protec-tion to that provided by the H STS.

(1) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission Document Control Desk, " Proposed Revision to Technical Specifications Electrical Power Systems (TAC No. 66797)," dated August 29, 1988.

(2) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission Document l

Control Desk, " Amendment Request for Sections 1.0, 3/4.2, 3/4.9, 3/4.10, 1 3/4.11, 5.0 and 6.0 of the Revised Technical Specifications," dated l October 26, 1988.

f ool

' i j $25A8 P

sam 88@es j

L

e .

U.S. Nuclear Regulatory Commission B13236/Page 2 May 18, 1989 As discussed during this meeting, the changes that CYAPC0 has proposed herein will be included in the revised Technical Specifications for the electrical section which will be tuirmitted as a supplement to the October 26, 1988, ,

letter. - '

The purpose of this submittal is to document these justifications. Attach-ment 1 provides comparison between the proposed Technical Specifications as contained in the August 29, 1988 letter and the H STS, and the justification for any deviations.

If you have any questions, please contact us.

Very truly yours, CONNECTIC'UT YANKEE ATOMIC POWER COMPANY nRAFT E. T.'Mr'5czka -

Senior Vice President cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant STATE OF CONNECTICUT)

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Connecticut Yankee Atomic Power Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the '

best of his knowledge and belief.

p g:

7.-

Notary Public

Docket No. 50-213 B13236 4AP v.:p;,.j%[\?'k

t. , ,

ih) N, 'a y,. s T?-

Attachment 1 Haddam Neck Plant ,

Justification for Deviation from the H STS i

May 1989 l

l 4

U.S. Nuclear Regulatory Commission B13236/Page 1 1

1. Proposed Technical Specification 3.12.1.1.b Two separate and independent diesel generators, each with:

1) A separate engine-mounted fuel oil day tank containing a minimum volume of 400 gallons of fuel (except during engine operation),

2) A separate underground fuel oil storage tank containing a minimum volume of 3,250 gallons of fuel, and

3) A separate fuel transfer pump.

W STS 3.8.1.1.b Two separate and independent diesel generators, each with:

1) Separate day and engine-mourned fuel tanks containing a minimum volume of gallons of fuel,  !

2) A separate Fuel Storage System containing a minimum volume of gallons of fuel,

3) A separate fuel transfer pump,

4) Lubricating oil storage containing a minimum total volume of gallons of lubricating oil, and

5) Capability to transfer lubricating oil from storage to the diesel generator unit.

Justification for Deviation This proposed Technical Specification has been worded to account for plant-specific design considerations. At the Haddam Ncck Plant, two diesel generator underground fuel oil storage tanks provide independent, safety (Class 1E) qualified, fuel oil storage for each of the diesel gen-erators. The diesel generator fuel oil transfer pumps take suction from these tanks and transfer the fuel oil to the diesel generator fuel oil day tanks (which are engine-mounted). The proposed Technical Specifica-tion provides an exception from the minimum volume of 400 gallons during engine operation because the fuel oil transfer pumps are controlled by a level switch. Thus, the pump only starts refilling the day tanks once the level drops below 292 gallons.

The proposed Technical Specifications do not include W STS requirements for lubricating oil storage or transfer capability. The diesel gener-ators do not have an automatic transfer system nor dedicated lubricating

U.S. Nuclear Regulatory Commission B13236/Page 2 ,

l i

oil storage tanks. Each engine contains approximately 400 gallons of lubricating oil. This is normally changed when major preventative maintenance is performed (usually each refueling outage). Oil level is monitored by plant operators every 30 minutes when operating end once ear.h shift when not operating. Lubricating oil that is stored on-site is added occasionally as necessary. These requirements have not been included because the operability of the diesel generator includes the availability of lubricating oil and is monitored by the maintenance program. Also, stored lubricating oil is consumed slowly with diesel generator operation and additional lubricating oil is not required for immediate diesel generator operation. This is consistent with groundrule 3 in that it provides an equivalent degree of protection to that provided by the W STS. In addition, this is consistent with Diablo Canyon, Callaway and current Commanche Peak Technical Specifications and the present g proach of the Westinghouse Owners Group (WOG) MERITS Program.

2. Prooosed Technical Specification 3.12.1.1 Action a and b:

a. With one offsite circuit inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specification 3.12.1.1.la.

within I hour and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. If either diesel generator has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance Requirement 3.12.1.1.2a.4 separately for each such diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one diesel generator inoperable, demonstrate OPERABILITY of the A.C. offsite sources by performing Surveillance Requirement 3.12.1.1.la within I hour and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter; and if the diesel generator became inoperable due to any cause other than preplanned maintenance or surveillance testing, demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Surveillance Requirement 3.12.1.1.2a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> regardless of when the inoperable diesel generator is restored to OPERABILITY; restore the diesel generator to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(3) R. A. Newton letter to U.S. Nuclear Regulatory Commission, Document l Control Desk, " Westinghouse Owners Group MERITS Program Phase II, Technical Specifications and Bases," dated March 30, 1989.

l l

U.S. Nuclear Regulatory Commission B13236/Page 3 W STS 3.8.1.1 Action a )

i

a. With either an offsite circuit or diesel generator of the above i required A.C. electrical power sources inoperable, demonstrate the {

OPERABILITY of the remaining A.C. sources by performing Specifica- 1 tions 4.8.1.1.la and 4.8.1.1.2a 4) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least two offsite circuits and  ;

two diesel generators to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at i least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The proposed Technical Specification requires less frequent verification of the operability of the remaining A.C. sources than recommended by .the M STS. The 24-hour time period between breaker alignment checks is consistent with the current Administrative Procedures. CYAPC0 believes that the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> recommended by M STS does not provide enough latitude within an 8-hour shift. In order to avoid a violation of Technical Specifications, breaker alignment checks would have to be performed at exactly the same time interval within each shift or twice per shift. A 12-hour time limit would provide for latitude within the shift to allow for normal perturbations which could affect the timing of certain activ-ities (i.e. extended shift turnovers or addiiJ. anal plant activities requiring attention.) The intent of the M STS 8-hour limit is to have the bgker alignment check performed once per shift. On October 26, 1988, CYAPC0 submitted an amendment request which proposes to change t'ne definition of once per shift to once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A 12-hour limit would provide an equivalent degree of protection as the intent of the M STS and could be successfully implemented at the Haddam Neck Plant. A 12-hour limit, rather than the proposed 24-hour limit, will be incorpo-rated into the revised Technical Specifications for the electrical section. CYAPC0 will administrative 1y ensure that this surveillance is performed once per shift. This 12-hour limit is consistent with ground-rule 3 in that it provides an equivalent degree of protection to that provided by the M STS.

The proposed Technical Specification does not require that the diesel generator be demonstrated operable if it has been successfully tested (4) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, Document Control Desk, " Amendment Request for Sections 1.0, 3/4.2, 3/4.9, 3/4.10, 3/4.11, 5.0 and 6.0 of the Revised Technical Specifications," dated October 26, 1988.

l' U.S. Nuclear Regulatory Commission l B13236/Page 4 l

i within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, the proposed Technical Specifica-tion provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which to demonstrate diesel generator opera-bility compared to one hour in the H STS. This demonstration of opera-bility 1) follows the recommendations in Generte Letter 84-15, 2) is consistent with Amendment No. 1985, for the North Anna Power Station, Unit No. 2,g) and issued

3) isApril consistent 25, with the present approach af the WOG MERITS Program.

With regard to the similarity of North Anna Power Station, Unit No. 2 to the Haddam Neck Plant, CYAPC0 has reviewed the electrical section of the North Anna Fial Safety Analysis Report and has determined that each system is sufficiently similar that the basis for the technical specifi-caticns do apply to the Haddam Neck Plant.

3. Proposed Technical Specification 3.12.1.1 Action c

c. With one offsite circuit and one diesel generator of the above required A.C. electcical power sources inoperable, demonstrate the OPERABILITY of the runaining A.C. sources by performing Specifica-tions 3.12.1.1.la wit 5in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter; and if the diesel generator became inoperable due to any cause other than preplanned maintenance or surveillance testing, demonstrate the OPERABILITY of the remaining OPERABLE diesel gene-rator by performing Surveillance Requirement 3.12.1.1.2a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least one of the inoperable sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore at least two offsite circuits and two diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of initial loss or be in at least H0T STANDBY within the next S hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

H_STS 3.8.1.1 Action b

b. With one offsite circuit and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specifica-tions 4.8.1.1.la and 4.8.1.1.2a.4) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable i sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore at least two offsite circuits and two 1

(5) L. B. Engle letter to W. L. Steward, dated April 25, 1985.

• - N u

U.S. Nuclear Regulatory Commission B13236/Page 5 N x,

\

diesel generators to OPERABLE status'within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of initial loss or be in at least liOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the 'ollowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The same discussion on groundrule 3 related to breaker alignment checks from Item 2 applies to this item.

The proposed Technical Specification does not require the operable diesel generator to be challenged if the inoperable diesel generator was rendered inoperable due to preplanned maintenance or surveillance test-ing. This is consistent with the North Anna amendment and the WOG MERITS Program.

4. Proposed Technical Specification 3.12.1.1 Action d

d. With one diesel generator inoperable, in addition to ACTION b. or c.

above, verify that the charging pump, HPSI pump, LPS1 pump and RHR pump which depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE. If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the f?lbwing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

W STS 3.8.1.1 Action c

c. With one diesel generator inoperable in addition to ACTION a. or b.

above, verify that:

1. All required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When in MODE 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.

If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The proposed Technical Specification identifies the specific equipment that must be operable rather than the general description provided in the W STS. As discussed in the bases section, this requirement is intended to provide assurance that a loss of offsite power event will not result in a complete loss of safety function of critical systems during the l

l U.S. Nuclear Regulatory Commission B13236/Page 6 period that one of the diesel generators is inoperable. This specifica-  ;

tion is consistent with groundrule ? in that it provides an equivalent i degree of protect;cn to that provided by the W STS. I The proposed Technical Specification does not require the steam-driven auxiliary feedwater pump to be operable due to plant-specific design considerations. W STS are designed for the standard y plant that has two j electrically driven auxiliary feedwater pumps and only one steam-driven '

pump. Since the Haddam Neck Plant has two steam-driven auxiliary feedwater pumps, having one diesel generator inoperable does not affect auxiliary feedwater availability.

5. Proposed Technical Specification 3.12.1.1 Action e

e. With two of the above required diesel generators inoperable, demon-strate the OPERABILITY of two offsite A.C. circuits by performing Specification 3.12.1.1.la. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore both diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of initial loss or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

W STS 3.8.1.1 Action e

e. With two of the above required diesel generators inoperable, demon-strate the OPERABILITY of two offsite A.C. circuits by performing the requirements of Specification 4.8.1.1.la. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore at least two diesel gener-ators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial loss or be in least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The same discussion on groundrule 3 related to breaker alignment checks from Item 2 applies to this item.

6. Proposed Technical Specification 3.12.1.1 Surveillance 2.a.4

4. Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm in less than or equal to 10 seconds. The

- I U.S. Nuclear Regulatory Commission B13236/Page 7 1 generator voltage and frequency shall be 4160 420 volts and 60 i 1.2 Hz within 10 seconds after the start signal,*

W STS 4.8.1.1.2.a.5 "

)

5. Verifying the diesel starts from ambient condition and accelerates )

to at least [900] rpm in less than or equal to [10] seconds.* The tenerator voltage and frequency shall be [4160] [420] volts and

[60] [1.2] Hz within [10] seconds

• after the start signal. The i diesel generator shall be started for this test by using one of the following signals: '

I a) Manual, or b) Simulated loss of offsite power by itself, or c) Simulated loss of offsite power in conjunction with an ESF Actuation test signal, or d) An ESF Actuation test signal by itself.  ;

Justification for Deviation j The proposed Technical Specification does not specify the type of start signal that may be used for this test. The method for starting the diesel generator is provided in the plant operating procedures and provides an equivalent degree of protection to that of the W STS.

7. Proposed Technical Specification 3.12.1.1 Surveillance 2.b

b. At least once per 31 days by verifying that the automatic load sequence timers are OPERABLE with the following allowable elapsed times:

E0VIPMENT ALLOWABLE ELAPSED TIME LPSI Pump 1 3 sec.

HPSI Pump s 10 sec. and 1 7 sec. ,

Service Water Pump 33 i 5 sec. >

Backup Service Water Pump 38 i 5 sec.

Containment Recirc. Fan 43 i 5 sec. t Backup containment Recirc. Fan 48 5 sec.  ;

i

)

l l

l )

l U.S. Nuclear Regulatory Commission B13236/Page 8 l

W STS 4.8.1.1.2.f.12 l

12. Verifying that the automatic load sequence timer is OPERABLE with the interval between each load block within 10% of its design interval; Justification for Deviation Consistent with groundrule 1, the proposed Technical Specification provides the exact allowable elapsed times as required by the plant design basis. j

8. Proposed Technical Specification 3.12.1.1 Surveillance 2 d

d. By obtaining a sample of new fuel oil upon delivery to the site prior to addition to storage tanks and:

1

1) Verifying in accordance with the tests specified in l ASTM-D975-81: <

a) An API gravity of greater than or equal to 30 degrees but i less than or equal to 40 degrees; and b) A water and sediment volume percentage of less than or equal to 0.05% (500 mg/L).

2) Verifying within 30 days of obtaining the sample that the other properties specified in Table 1 of ASTM-D976-81 are met when ,

tested in accordance with ASTM-0975-81 except that the analysis for sulfur may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82. 4 l

W STS 4.8.1.1.2.d l l

d. By sampling new fuel oil in accordance with ASTM-D4057 prior to )

addition to storage tanks and: l

1) By verifying in accordance with the tests specified in ASTM-D975-81 prior to addition to the storage tanks that the i sample has: I a) An API Gravity of within 0.3 degrees at 60*F, or a specific gravity of within 0.0016 at 60/60*F, when compared to the supplier's certificate, or an absolute specific gravity at 60/60*F of greater than or equal to 0.83 but less than or equal to 0.89, or an API aravity of greater than or equal to 27 degrees but less than or equal to 39 degrees; L- - - .- - ------------------------------------_--_--_i

.o U.S. Nuclear Regulatory Commission B13236/Page 9 i

b) A kinematic viscosity at 40*C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes (alternatively, Saybolt viscosity, %3 at 100*F of greater than or equal to 32.6, but not less that. or equal to 40.1), if gravity was not determined by comparison with the supplier's l

certification; c) A flash point equal to or greater than 125'F; and i d) A clear and bright appearance witn proper color when tested in accordance with ASTH-D4176-82.

2) By verifying within 30 days of obtaining the sample that the other properties specified in Table 1 of ASTM-D975-81 are met when - tested in accordance with ASTM D975-81 except that the i' analysis for sulfur may be performed in accordance with '

ASTM-D1552-79 or ASTM-D2622-82.

Justification for Deviation The proposed Technical Specification does not specify that new fuel oil f will ' be sampled in accordance with ASTM-04057. CYAPC0 disagrees with referencing specific procedures in the Technical Specifications which may be revised or replaced often. Since 1976, CYAPC0 has followed the recommendations in Regulatory Guide 1.137 which references all ASTM procedures necessary to meet the standards. Although not stated in the proposed Technical Specification, CYAPC0 will sample ~ in accordance with ASTM-D4057 and therefore, will provide an equivalent degree of protection l to that provided by the M STS. l The proposed Technical Specification specifies only one standard for measuring specific gravity. CYAPC0 does not need the option of using three different values which all correlate to one another. In addition, the values used for API gravity differ only a small amount from those in the W STS and are consistent with plant-specific data. This specification is consistent with groundrule 3, in that it provides an equivalent degree of protection to that provided by the W STS.

CYAPC0 is in the process of procuring equipment and developing a proce-dure to perform W STS 4.8.1.1.2.d.1.b and c, kinematic viscosity and flash point fuel oil tests. CYAPC0 will include these requirements in l

the revised Technical Specifications for the electrical section.

The proposed Technical Specification does not include appearance require-ments because they are subjective in nature and are contained in proce- ,

dures rather than Technical Specifications. The inclusion of these l

1

i U.S. Nuclear Regulatory Commission B13236/Page 10 requirements in procedures provides an equivalent degree of protection to that provided by the H STS.

9. Proposed Technical Specification 3.12.1.1 Surveillance 2.f.1 -

l l

1. Simulating a loss-of-offsite power coincident with a Safety Injec- l tion Actuation signal, and: l a) Verifying deenergization of the emergency busses and load shedding from the emergency busses; b) Verifying the diesel starts from normal standby conditions on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequence timers )

and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads; and c) Verify that all automatic diesel generator trips, except engine overspeed, generator differential, and engine oil pressure (2 out of 2) are bypassed.

W STS 4.8.1.1.2.f.2. 4 and 6

2. Verifying the generator capability to reject a load of greater than or equal to [ largest single emergency load] kW while maintaining voltage at [4160] [420] volts and frequency at [60] [1.2] Hz

[less than or equal to 75% of the difference between nominal speed and the Overspeed Trip Setpoint, or 15% above nominal .whichever is .

less];

4. Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and 1

b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within

[10] seconds, energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at

[4160] i [420] volts and [60] [1.2] Hz during this test.

6. Simulating a loss-of-offsite power in conjunction with an ESF Actuation test signal, and:

U.S. Nuclear Regulatory Commission B13236/Page 11 a)  : Verifying deenergization of the emergency busses and load shedding.from the emergency busses; b) Verifying the diesel starts on the auto-start signal, energizes.

. the emergency busses with permanently connected loads within-

[10] seconds, energizes the auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at

[4160] [420] volts and [60] [1.2] Hz during this test; and c) Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically -

bypassed upon loss of voltage on the emergency bus concurrent  !

with a Safety Injection Actuation signal.

Justification for Deviation During the March 30, 1989, meeting with the NRC Staff, CYAPC0 agreed to include a new surveillance which is currently performed and meets the intent of H STS 4.8.1.1.2.f.2. The 18-month test to verify diesel generator load rejection of the largest single emergency load is enveloped by CYAPC0's present 18-month partial loss of A.C. test. '

However, in lieu of rejecting the largest single emergency load, CYAPC0 rejects greater than the largest single emergency load by opening the output breaker after all accident loads have sequenced on the diesel generator. The revised Technical Specifications for the electrical section will include " Verifying the generator capability to reject a load of greater than the single load."

l The proposed Technical Specification is equivalent to H STS 4.8.1.1.2.f.4 J and 4.8.1.1.2.f.0 except that the frequency and voltage requirements are not included.

The Haddam Neck Plant does not have a solid state sequencer as does the standard H plant. The Haddam Neck Plant uses discrete time delay relays ,

for loading safety injection motors onto the electrical system. There is i no difference between the diesel start and loading logic, with or without an accident signal, and there is also no difference in loading of the safety injection loads, with or without offsite power. Therefore, due to plant-specific design considerations this proposed test is redundant to that done for H STS 4.8.1.1.2.f.4.

The voltage and frequency requirements have not been included due to plant-specific design considerations. The design of the Haddam Neck Plant on-site power system utilizes two GM/EMD 20 cylinder, turbo charged

_ _ _ . _ _ - - - . _ - - - - - - - J

. s. -

U.S. Nuclear Regulatory Commission B13236/Page12 diesel generators, with maximum dead load pickup capability. This design  ;

differs from the standard H plant in that the generator is of lower i impedance to allow for easy starting of large ' motors when operating in the isochronous mode. Power current transformers are utilized to supply the needed energy to the exciter during motor starts while the voltage is depressed to as low as 50% of rated value. This design also allows for  :

larger frequency swingc during motor starts, for the same reason. A fast start test initiated by a loss of normal power, followed by an accident signal, has been performed during every refueling outage for each of these units since they were installed. The loading, however, could not simulate the worst case loading as the safety injection pumps were in the recirculation mode and could not easily be set up to simulate their runout condition. A special test was conducted during the 1980 refueling outage, which simulated runout safety injection flow and worst case diesel generator loading. The test successfully demonstrated the on-site I power systems capability to start and run the design basis loads at the Haddam Neck Plant, without maintaining the voltage and frequency within ^

the guidelines set forth in the W STS. Consequently, inclusion of voltage and frequency limits in the Technical Specifications is not required. Successful closure of the generator breaker and starting of motor loads are adequate indication of the diesel generator's readiness.

10. Proposed Technical Specification 3.12.1.1 Surveillance 2.f.2

2. Verifying that on a Safety Injection Actuation test signal, without loss-of-offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes.

W STS 4.8.1.1.2.f.5

5. Verifying that on an ESF Actuation test signal, without loss-of-offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be [4160] [420] volts and

[60] [1.2] Hz within [10] seconds after the auto-start signal; the steady-state generator voltage and frequency shall be maintained ,

within these limits during this test;

Justification for Deviation The same discussion on groundrule I related to voltage and frequency requirements from Item 9 applies to this item.

l i

I 4

j

l

(

,, #R' l t

c. . .a. Y' b  !

U.S. Nuclear Regulatory Commission ,T B13236/Page 13

11. Proposed Technical Specification Table 3.12-1 TABLE 3.12-1 DIESEL GENERATOR TEST SCHEDULE -

NUMBER OF FAILURES IN LAST 20 VALID TESTS

• TEST FRE0VENCY

$1 At least once per 31 days 22 At least once per 7 days **

• Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the number of tests and failures is determined on a per diesel generator basis. For the purposes of this test schedule, only valid tests conducted after the completion of the preoperational test requirements of Regulatory Guide 1.108, Revision 1, August 1977, shall be included in the computation of the "Last 20 Valid Tests."

• • This test frequency shall be maintained until seven consecutive failure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one or less.

W STS Table 4.8-1 JAEE A 4.8-1 DIESEL GENERATOR TEST SCHEDULE NUMBER OF FAILURES IN LAST 100 VALID TESTS

• TEST FRE0VENCY 11 At least once per 31 days 2 At least once per 14 days 3 At least once per 7 days 24 At least once per 3 days

• Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the last 100 tests are determined on a per nuclear unit basis. For the purpose of this schedule, only valid tests conducted after the completion of the preoperational test

e ..

p , ,- .

U.S. Nuclear Regulatory Commission

• B13236/Page 14 requirements of Regulatory' Guide 1.108, Revision 1, August,1977, shall be included in the computation of the "Last 100 Valid Tests."

i Justification for Deviation .. l l  !

l The proposed Technical Specification follows the recommendations in i Generic Letter 84-15.

12. Prooosed Technical Specification 3.12.1.2 Action l

With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool. In addition, when in MODE 5 with less than two (2) steam generators OPERABLE., or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, ,

immediately initiate corrective action to restore the required sources to -

OPERABLE status as soon as possible.

W STS 3.8.1.2 Action With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement or irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a greater than or equal to square inch vent. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible.  ;

Justification for Deviation The Haddam Neck Plant relies on a separate, dedicated system, Low Temperature Overpressure Protection (LTOP), to prevent this accident scenario from occurring. The requirement for depressurizing and venting the RCS is currently covered by LC0 3.3.4.2. Thus, CYAPC0 has not included this requirement in this section.

13. Proposed Technical Specification 3.12.2.1.a and b

a. 125-volt Battery Bank No. IA, and an associated or independent full .

capacity charger, and I

b. 125-volt Battery Bank No.1B, and an associated or independent full capacity charger.

U.S. Nuclear Regulatory Commission )

B13236/Page 15 q I

J W STS 3.8.2.1.a and b-I

a. [250/125]-volt Battery Bank No.1, and its associated full capacity charger, and -  :

b. [250/125]-volt Battery Bank No. 2, and its associated full capacity charger.

Justification for Deviation When CYAPC0 submitted the proposed Technical Specifications in August 1988, the addition of an independent battery charger was contemplated as part of the new switchgear building design. Since this time, the design has been modified to provide a non-Category 1 battery charger which may only be utilized for maintenance during shutdown. The revised Technical Specification for the electrical section will strike the words "or independent."

14. Proposed Technical Specification 3.12.2.1 Surveillance a.2

2. The total battery terminal voltage is greater than or equal to 125 volts on float charge, and W STS 4.8.2.1.a.2

2) The total battery terminal voltage is greater than or equal to

[258/129] volts on float charge.

Justification for Deviation I The proposed Technical Specification specifies 125 volts based on current Administrative Procedures, however CYAPC0 will change this to 129 volts in the revised Technical Specifications for the electrical section.

15. Proposed Technical Specification 3.12.2.1 Surveillance a.3 and b

a. At least once per 7 days by verifying that:

3) The electrolyte temperature of the pilot cell is above 60*F.

l b. At least once per 92 days and within 10 days after a battery dis-charge with battery terminal voltage below 110 volts, or battery l

overcharge with battery terminal voltage above 150 volts, by verify-ing that:

1) The parameters in Table 3.12-2 meet the Quarterly limits, and

. . s.

U.S. Nuclear Regulatory Commission B13236/Page 16 W ,

2) There is no visible corrosion at either terminals or connec-tors,orgheconnectionresistanceoftheseitemsislessthan 150 x 10- ohm.

W STS 4.8.2.1.b '

b. At least once per 92 days and within 7 days after a battery dis-charge with battery terminal voltage below [220/110] volts, or battery overcharge with battery terminal voltage above [300/150]

volts, by verifying that:

1) The parameters in Table 4.8-2 meet the Category B limits,

2) There is no visible corrosion at either terminals or connec-tors,

[150 xor tg]e connection 10~ ohm, and resistance of these items is less than

3) The average electrolyte temperature of [a representative number] of connected cells is above [60*F].

Justification for Deviation The proposed Technical Specification is more conservative in that it requires a representative cell to be checked weekly rather than quarterly as recommended in the H STS.

The proposed Technical Specification requires that surveillance contained in Item b be completed within 10 days as compared to 7 days in the H STS. This is consistent with CYAPC0's current operating procedures and is more restrictive than the 31-day requirement that has been recom-mended in the WOG MERITS Program. Procedures written in accordance with the battery manufacturer's instructions state that an equalize charge may require as long as 6 days to complete. At this point, CYAPC0 usually places the batteries on a float charge for at least 3 days before perform-ing these surveillance. Performing the surveillance within 10 days provides an equivalent degree of protection to that provided in H STS ,

while considering the manufacturer's recommendations. In addition, this (

practice is in accordance with IEEE 450 recommendations. )

16. Proposed Technical Specification 3.12.2.2 i

As a minimum, one 125-volt battery bank and an associated or independent I full capacity charger shall be OPERABLE. '

e U.S. Nuclear Regulatory Commission B13236/Page 17 W STS 3.8.2.2 As a minimum, one [250/125]-volt battery bank and its associated full-capacity charger shall be OPERABLE. -

i Justification for Deviation The same discussion from Item 13 on the independent charger applies to this item.

17. Proposed Technical Specification 3.12.2.2 Action With the required battery bank or full capacity charger inoperable, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel; initiate corrective action to restore the required battery bank and full capacity charger to OPERABLE status as soon as possible.

W STS 3.8.2.2 Action With the required battery bank and/or full-capacity charger inoperable, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel; initiate corrective action to restore the required battery bank and full-capacity charger to OPERABLE status as soon as possible, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a square inch vent.

Justification for Deviation The same discussion regarding RCS overpressurization protection from Item 12 applies to this item.

18. Proposed Technical Specification 3.12.3.1 3.12.3.1 The following electrical busses shall be energized in the specified manner with tie breakers open between redundant busses except for short periods of time while locating shorts or grounds not to exceed 30 minutes:

a. Train A-A.C. Emergency Busses consisting of :

1) 4160-Volt Bus #8, and

2) 480-Volt Busses #4 and #5.

b. Train B-A.C. Emergency Busses consisting of:

l t _ _ _ _ _ _ _ _ _ _

e

.'r. '

U.S. Nuclear Regulatory Commission B13236/Page 18 j

1) 4160-Volt Bus #9, and _

i

2) 480-Volt Busses #6 and #7.

c. 120-Volt A.C. Vital Bus #A,  ;

d. 120-Volt A.C. Vital Bus #B, 1

e. 120-Volt A.C. Vital Bus #C,

f. 120-Volt A.C. Vital Bus #D,

g. 125-Volt D.C. Bus #1 energized from Battery Bank 1A, and

h. 125-Volt D.C. Bus #2 energized from Battery Bar.k 18.

W STS 3.8.3.1 3.8.3.1 The following electrical busses shall be energized in the specified manner with tie breakers open [both] between redundant busses within the unit [and between units at the same station]:

a. Division #1.A.C. Emergency Busses consistent of:  !

1) [4160]-Volt Emergency Bus # , and

2) [480]-Volt Emergency Bus # .

b. Division #2.A.C. Emergency Busses consisting of:

1) [4160]-Volt Emergency Bus # , and

2) [480]-Volt Emergency Bus # .

c. [120]-Volt A.C. Vital Bus # energized from its associated inverter connected to D.C. Bus # *,

I

d. [120]-volt A.C. Vital Bus # energized from its associated 1 inverter connected to D.C. Bus # *,

)

e. [120]-Volt A.C. Vital Bus # energized from its associated inverter connected to D.C. Bus # *, )

f. [120]-Volt A.C. Vital Bus # energized from its associated inverter connected to D.C. Bus # .

g. [250/125]-Volt D.C. Bus #1 energized from Battery Bank #1, and

h. [250/125]-Volt D.C. Bus #2 energized from Battery Bank #2.

I

U.S. Nuclear Regulatory Commission B13236/Page 19 - +

Justification for Deviation Due to plant-specific design considerations, the proposed Technical Specifications allow the electrical busses to be energized in the speci-fied manner with tie breakers closed between redundant busses for short periods of time not to exceed 30 minutes while locating shorts or grounds. It is highly desirable to isolate, identify, and remove grounds or shorts while maintaining the facility in a steady state. Bus tie breakers continue to provide adequate overcurrent protection should a fault occur while trouble shooting. This design capability in conjunc-tion with the short time limit for tie breakers to remain closed, provides assurance that train related design features are not compro- 1 mised. The single line diagrams for the Haddam Neck Plant are provided here for reference. The 11addam Neck Plant design differs from the standard W plant in that it has the capability to cross tie distribution panel s, given failure of batteries, battery chargers or inverters.

Specifically, each D.C. bus at the Haddam Neck Plant can obtain power from either battery. Therefore, should a battery fail while the unit is at power, the tie breaker is available to assist in maintaining the plant in a stable condition, while repairs are made.

In addition, to provide an added assurance against a single failure of instrumentation, an RPS channel trip condition for the affected bus has been included in Action b.2.a of the proposed Technical Specifications as compensatory measures.

The proposed Technical Specification does not specify (as recommended in the H STS) that the 120-Volt A.C. vital bus be energized from its asso-ciated inverter connected to a certain D.C. bus. CYAPC0 did not propose to designate each of the 4 RPS power supply channels in order to provide latitude for inclusion of the new switchgear building into the Technical Specifications without need for further revisions. With the addition of the new switchgear building, several dedicated spare inverters will be made available. A design feature which is under consideration is to have installed spares for the RPS inverters. The confusion which would be caused by inclusion of all possible combinations of battery, inverter and panel in the Technical Specifications would be counterproductive.

Consequently, CYAPC0 did not specify which inverter would normally power which bus. The revised Technical Specifications for the electrical section will include the following normal lineup of battery, inverter and vital panel:

c. 120-Volt A.C. Vital Bus A energized from its associated inverter connected to D.C. Bus #1,

d. 120-Volt A.C. Vital Bus B energized from its associated inverted connected to D.C. Bus #1, 1

__- _-_ O

U.S.. Nuclear Regulatory Commission B13236/Page 20

e. 120-Volt A.C. Vital Bus C energized from its associated inverter connected to D.C. Bus #2,

f. 120-Volt A.C. Vital . Bus D energized from its associated inverter connected to D.C. Bus #2.

19. Proposed Technical Specification 3.12.3 Action b

b. With one A.C. vital bus not energized from its associated inverter; i (1) return all vital busses to their normal power supply configura-tion within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, or (2)(a) energize the vital bus from its alternate inverter and place the reactor protection trip signal (s) associated with the. inoperable bus (in abnormal configuration) in the trip condition (to meet the intent of Table 3.9-1) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following -

30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, and (b) return all vital busses to their normal power supply configuration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

W STS 4.8.3.1 Action b

b. With one A.C. vital bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C.

bus: (1) reenergize the AC vital bus within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) reenergize the A.C. vital bus from its associated inverter connected to its associated D.C. bus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The Haddam Neck Plant has A.C. independent backups for the RPS power supplies. Because of the tie breakers on the vital panels in the control room, the vital bus will be reenergized well within the 2-hour time frame l in the W STS. The 8-hour requirement for each vital bus is consistent with that for the A.C. Emergency Busses (proposed Technical Specification 3.12.3.1 Action a) both at the Haddam Neck Plant and in the W STS.

- - _ - - _ _ _ . __ __ _ \

, i U.S. Nuclear Regulatory Commission B13236/Page 21 1 l

20. Proposed Technical Specification 3.12.3 Action c l

c. .

With one D.C. bus not energized from its associated battery bank,

. reenergize the D.C. bus from its associated battery bank within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

W STS 4.8.3.1 Action c

c. With one D.C. bus not energized from its associated battery bank, reenergize the D.C. bus from' its associated battery bank within  ;

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification for Deviation The basis for the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation (LCO) for battery problems is derived from the Administrative Procedures which allows time for replacement of a- failed cell or cells of the battery.

The provision to cross tie the D.C. panels allows the Haddam Neck Plant to provide power to both trains of D.C. while in this LCO. This capability is part of the Haddam Neck Plant original design and differs from the M standard design. This time allows for repairs to be made from spare cells in stock, or from other qualified suppliers. The provision to cross tie the D.C. systems, allows. control power 50 be maintained for

. all D.C. loads. If the normal power supply cannot be returned to service within this LC0 time period, an orderly shutdown will commence.

The Haddam Neck Plant's cross tie capability provides justification for an LC0 of greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, however, the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> contained in current Administrative Technical Specifications cannot be quantitatively justified at this time.

Therefore, this 72-hour LC0 will be revised to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the revised Technical Specification for the electrical section.

21. Proposed Technical Specification 3.12.3.2 3.12.3.2 As a minimum, the following electrical busses shall be ener-gized in the specified manner:

a. 4160-Volt Emergency Bus #8 or #9,

b. 480-Volt Emergency Busses #4 and #5, if Emergency Bus #8 above is energized, or Emergency Busses #6 and #7, if Emergency Bus #9 above is energized,* l

, ,/

f%

U.S. Nuclear Regulatory Commission B13236/Page22 Q

c. 120-Volt A.C Vital Busses #A and #B or Vital Busses #C - and #D

• energized from their associated inverters connected to their respec- 1

'tive D.C. busses, and'

~

d. I'25-Volt D.C. Bus #1 energized from its associated ' battery bank if Emergency Bus #8 above is energized, or 125-Volt D.C. Bus #2 ener-gized from its associated battery bank if Emergency Bus #9 above is energized.

W STS 3.8.3.2 3.8.3.2 As a minimum, the following electrical busses shall be energized in the specified manner:

a. One division of A.C. eme gency busses consisting of one [4160]-volt and one [480]-volt A.C. emergency bus,

b. Two [120]-volt A.C. vital busses energized from their associated inverters connected to their respective D.C. busses, and

c. One [250/125]-volt D.C. bus energized from its associated battery bank.

Justification for Deviation The proposed Technical Specification specifies which busses must be energized. This change fully meets the intent of the W STS and makes the Technical Specification more plant-specific. ,

22. ' Proposed Technical Specification 3.12.3.2 Action With any of the above required electrical. busses not energized in the l required manner, immediately suspend all operations involving CORE ALTERATIONS- positive reactivity changes, or movement of irradiated fuel, and initiate corrective action to energize the required electrical busses in the specified manner as soon as possible.

W STS 3.8.3.2 Action With any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE l' ALTERATIONS, positive reactivity changes, or movement of irradiated fuel, initiate corrective action to energize the required electrical busses in the specified manner as soon as possible, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressur- .

ize and vent the RCS through at least a square inch vent.  !

~

l U.S. Nuclear Regulatory Commission .

B13236/Page 23 )

Justification for Deviation The same discussion regarding RCS overpressurization protection from Item 12 applies to this item. ..

I 1

i l

1 l

l l

I l

L__ ____.

A C B L L L E E E

- _ .N N N A

nt }v A P L

nt }v PA A L

nt j vPL A

nt }v A T T

I T

I I V V V T IN T N I T NI T N I

- L A L A L A L A A M A M A M A M o

M O

O n-R n" N L MO EI O

R TT S A T

YR N .

SU O LI G C AF TN I

VO liII Ig1IIIl Il 11 Il I l Il llgi1I C C AG N

VI T 0S 2I 1 X M E

O O

R i R

A R R R E E E E G T T T H

C RA E RO R E 8 RD E

T V V -

V I

N W N N WS I I I I D

L O

C C C C D D D D V V V V 5 1 5 2 5 1 5

2S 2S 2S 2S 1U 1U 1U 1U MB MB MB M O O O O R R R R F F F F

- 'l

[

1: ,.

- e, . .

TO

" l

• g LL n s --- n

P I,3

,g lI 3-

.r. ueg L l5 I

~

la '

J XE LL[.

'H45 ha i  :

nt'b}b. g I li j%

i

-f" '

i

- 2; g

3 1 -j- r -

q s i ng;,f, ";% M yn;,$.

I -

=

l p

11 -

J 5e; mil: i 4 b"4

, l;tiAtiittiin

- ; h i!!!; l I

I mc 11 a  : ,

r-------'

t t------

r g

1 ir j .. . LT.

. c_, + ,1

, _ . -.:.u~  ;;  ;

! i=

.c *. ~ = .

• e l. '

c f'

-n. == ,

o_

$1 c .j 2',,,,,,,- a 11 c., _ .* ::r :

. ~422 c ,. .iE .

c ... I ft ( ll i 8  ?

. c ,,,

Y c_:

n j Xa. '

• C ,, . "" E s.A'.'.'E j C,,,,,, .% s

} 0  : ,.

' j et

. c g, ; '

Z- %".:: .

c ,,,, *

• C'.*:.-"::

J e

4 r

"**'""'E*".'*. jj j . _ _ .l

. **** 7

,i c, . =._ =

e

-C ,,, 1 .

. .w

. . . . . . )

. ,j . o_

e 3 .c,; ... i r.

a -

r.:

c--

. _. p ,

c, u

=_.

• i

c. , ... , ~ =f .c fi f .,

==

7 .J ,{dj,j y .

.. - .:.~.=e i.c. c. .== 3 J c . =:

euW i.

4. . W ..

, .E

, -s

. .=. .. o

.c.s tr ,n .. ._.

. e- -

c -c, ,; _

... .x .

.c .m a .

,w r  :. -.E .

..= ..

-3

.g 4 3,

.=.=

mlg,  ;

. .a.

,_n.i;g,:5; y i .._  :

IE #M CM51 ~.~.~.5E

!  !. < a* hl..e Rd el* ,y

,l ;-me { )s .... a* .w m i 3

, j l

i

' {*I*

.<*w- l ' .,/, .,3t sty B 41, t t s g.3 L--...... Jgj L..... v'.j -

5 41

.I 4

I d a

_ _ _ _ _ _ _ _ _ _ _ . _ . . - - - - - - - - - - - - - - - - - - - - - - - - -^

r

n.O , i i _ i.i ,.r mi t o .

l . .

. - . 4 .

m 3 j i ks

'- " l 1 gw l lr I ".I3 )

e, 1: ... g.

~

k, . ~4d,f) l Jj h .

>- . Ofl!

kl'$

E,

@ r' $

d t

( ,

" ,i!T'$@p ai . p' --

o J

, , ' . t.dy..u...

cap 18..J;-4. 3% Il 11 , ,

'.m g,p# . , gg ,; gj

.j al ! ,.

'-o- EE Il i

,l[i GA' i

.t) I _ st

-- 1:, , y 4.p 1

1; a

,ij g: ,e . rtu  !,!  ;

l; e 9 ja. 1

, . . -re ..

l i ,

!n d Q, j!h la ,, ri di

- pd,Q R% 81jb!4!n .V u-c4

,7 e(,o;: m i

-prwisuhmA-

. .hrb . e. r.:....nN a .-

~

L

.t.. ", ~ ~ ~ l l

'iti (. n,  :

[ n; i

a. k.!if;;

h,}jil;[r

! L q"., ' Al[d $

>-isid ,d'hil i; ij IJ l

E ,.'

f U"i it!!! -

P' e.

h  !. il "

Imb. 'i g ';Idji

.a sew L.1 e r.. .. w o nmt 4,g!si

)t%

• j i l jjg t llg l'l

, if - T...

e

. , kn,

i AeT.

ggg;; gp' a.

- fry .nij, g E i i

: y-41 p .;l;g r9 di T'g: c j!

j?"(AC fl=I j. T~ i ch' . -y l ~i  ! , g. _

g l! i.i RI,, 2- Eil . li. 'bn ti > !

pi -? g_l j h.  : l.i

- e :

' lik v?

He 7cq m f ,1 .: m.., -

, ipo

• i i9, f , j,,

1 fili. 91: g  :  ::

p,!

~

,llt ,p,h h{-h  !

~ ~ ~ ~ " ~

ig

(. !  !

4 g, r' - -

1 a,.u.....y giMl!l!!n:v"i '

ii-w;i.~g pmi..

h, ,i%.y-of '

ej y _. 3

.i. .

1..N 4

~

b .5 ); $ ~hN p 9

o Ih[e,,

I r,!.i mali b: .c yy. ...... . , r -c

..,@9 l;:

1,p.

E}l. A.9;g.4,r

--d *;--l{i S:+211 fIl!!ginylq C

q,i  ! --

l

- .,M)

,g g 3y

!!!ji

.. .+.

p fT1- g, - - - -

. nr 4e .

g ,m. ,.L =.m t s.m .am.1. .... .. ...- ly i t ib~ i i !! 11fik i$ i.NJ i: ! i hit!!!!!M Mi@! Ii b. M@ nam!d.ii, Qlj

, %lf.! i'tr la ge N P Wi p J 4 w, "

e 1%i  ! !W T f 7 7*1 d j 't'ru h-e.. .m%y.a kJ;g ,. a a.. i ;a,Lj n@ 3 , i.s 4!I ,sy n ..... . .#.

._1 ,

b,. i e f

• d . . . . . .. . .#: sf ,

,!j .6 7.

t.4f: . yJ h> . . 4 ... ..i. .... . . .. ' T' J. . l . .. . ..5

'h!.J.h=.dII..L,J...

4 g 4.. y

..g ./...2. .l'. M . , g!!ill t,'y,..-',.e1

.qt........'.'.-~.

4 4 4 f

- - - - - - - _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ , _ _ _ . _ , _