BVY 08-069, Transmittal of Technical Specifications Proposed Change No. 281, Revision to Battery Systems

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Transmittal of Technical Specifications Proposed Change No. 281, Revision to Battery Systems
ML082700457
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 09/22/2008
From: Ted Sullivan
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 08-069
Download: ML082700457 (17)
v • d • e


Text

Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0250 Entergy Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 September 22, 2008 BVY 08-069 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

(1) NUREG-1433, Rev. 3, Standard Technical Specifications, General Electric Plants, BWR/4, Published June 2004

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Technical Specifications Proposed Change No. 281 Revision to Battery Systems

Dear Sir or Madam,

Pursuant to 10CFR50.90, Entergy Nuclear Operations, Inc. (ENO) is proposing to amend the Operating License (DPR-28) for Vermont Yankee Nuclear Power Station (VY). The proposed changes would revise the Operating License Technical Specifications (TS) to change requirements related to Battery Systems specified in TS Section 3.10. Specifically, the proposed change would remove the Limiting Condition for Operation (LCO) pertaining to 345 kV switchyard batteries, chargers and associated DC distribution panels. to this letter provides a detailed description and evaluation of the proposed change. contains a markup of the current TS and Bases pages. Attachment 3 contains the retyped TS and Bases pages. TS Bases pages are provided for information only.

ENO has reviewed the proposed amendment in accordance with 10CFR50.92 and concludes it does not involve a significant hazards consideration.

In accordance with 10CFR50.91, a copy of this application, with attachments, is being provided to the State of Vermont, Department of Public Service.

ENO requests approval of the proposed amendment by March 1, 2009 with a 60 day implementation.

There are no new regulatory commitments made in this letter.

Amo tuf_

I i I If you have any questions on this transmittal, please contact Mr. David Mannai at (802) 451-3304.

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

Executed on September 22, 2008.

Sincerely, Site Vid'e President Vermont Yankee Nuclear Power Station Attachment 1: Description and Evaluation of Proposed Change Attachment 2: Markup of the Current Technical Specification and Bases Pages Attachment 3: Retyped Technical Specification and Bases Pages cc: Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

Docket No. 50-271 BVY 08-069 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Change 281 Revision to Battery Systems Description and Evaluation of Proposed Change C

BVY 08-069 / Attachment 1 / page 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGE

1. Description of Proposed Change Entergy Nuclear Operations, Inc. (ENO) is requesting to amend Operating License DPR-28 for the Vermont Yankee Nuclear Power Station (VY). The proposed change will remove the Operating License Technical Specifications (TS) Section 3.10.A.2.c and 3.10.B.2.f Limiting Condition for Operation (LCO) requirements for switchyard batteries, chargers and associated DC distribution panels. The specific wording to be removed on pages 213 and

'217 is as follows:

3. 10.A.2.c "Two Switchyard Batteries each with one associated charger and its associatedDC distribution panel."
3. 10.B.2.f "Fromand after the date one of the two 125 volt Switchyard battery systems is found or made inoperable for any reason, continued reactoroperation is permissible provided that the other 125 volt Switchyard battery system is operable."

Associated wording in the VY TS Bases (pages 221b and 223) will also be removed after approval of this change, under our TS Bases Control Program specified in VY TS 6.7.E.

Changes to TS Bases are provided for information only.

2. Background The 345 kV distribution switchyard at VY has a 125 V DC system consisting of two 59-cell batteries, three battery chargers and associated distribution panels. Each battery powers its own independent DC distribution panel. Each battery has its own charger and a third (swing) charger is provided as an installed spare. The 345 kV switchyard DC system provides power for operation, control circuitry, monitoring, logic and indication of the switchyard circuit breakers.

The VY Updated Final Safety Evaluation Report (UFSAR) in Section 8.6, 125 V DC System, reads as follows:

8.6.5 Additional DC Systems "In addition to the above dc systems, there exists two 125 VDC Systems in the 345 kV switchyard and two 125V DC systems in the 115 kV switchyard which provide power for breakeroperation and control and protective relaying circuitry."

The 345 kV switchyard DC systems have no safety related function.

The 115 kV switchyard DC systems are not listed in the VY Technical Specifications and have no safety related function.

BVY 08-069 / Attachment 1 / page 2

3. Technical Analysis Regulatory requirements related to the content of TSs are set forth in 10CFR50.36, Technical Specifications. LCOs and related requirements that fall within or satisfy any of the criteria in the 10CFR50.36 regulation must be retained in the TSs, while those requirements that do not fall within or satisfy these criteria may be removed. For Limiting Conditions for Operation (LCOs), 10CFR50.36(c)(2)(ii) specifies four criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:

(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Switchyard batteries and associated components do not impact instrumentation used to detect degradation of the reactor pressure boundary.

(2) A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Switch'yard batteries and associated components are not credited in any design basis accident or transient.

(3) A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Switchyard batteries and associated components are not assumed or credited in any mitigation role for design basis accidents or transients.

(4) A structure, system or component which operating experience or probabilistic risk

/ assessment has shown to be significant to public health and safety.

Switchyard batteries and associated) components will only be removed from TS as part of this change. No change of installed equipment, operation or function is being proposed by this amendment request. Off-site power can be risk significant, but separate requirements exist in the TS for off-site power availability. Individual components within the switchyard are not modeled in the VY probabilistic risk assessment and do not need to be individually specified in the TS.

The VY 345 kV switchyard DC systems do not meet any of the four 10CFR50.36 criteria for inclusion as a TS LCO. The similar 115 kV switchyard DC systems are not included in the VY TS. Removal of the LCO does not result in the introduction or removal of any plant equipment, as the current installed configuration and functions for this system will remain in place. The proposed amendment does not involve any changes in the operation or function of any component or system. The proposed change, in accordance with the criteria specified in 10CFR50.36, only involves removal of unnecessary equipment being specified in the VY TS.

BVY 08-069 / Attachment 1 / page 3

4. Comparison to Standard Technical Specifications There is no similar or corresponding reference in the Standard Technical Specifications (STS) for switchyard batteries, chargers and associated distribution panels. Generically, this type of equipment is not necessary (per 10CFR50.36 criteria) to be included and is thus not included in STS.
5. Environmental Consideration This proposed change involves no significant increase in the amounts, and no significant changes in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, ENO concludes that the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51,22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6. Regulatory Safety Analysis No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (ENO) is proposing to modify the Vermont Yankee (VY) Technical Specification (TS) 3.10.A.2.c and 3.10.B.2.f requirements related to Battery Systems. Specifically, the proposed change removes the Limiting Condition for Operation (LCO) for 345 kV switchyard battery systems from the VY TS.

Pursuant to 10CFR50.92, Entergy has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration in accordance with the criteria specified in 10CFR50.92(c). These criteria require thatoperation of the facility in accordance with the proposed amendment will not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The change does not impact the function of any Structure, System or Component (SSC) that affects the probability of an accident or that supports mitigation or consequences of an accident previously evaluated. The proposed change removes unnecessary information from the Technical Specifications that is not required in accordance with 10CFR50.36.' The proposed change does not affect any plant equipment operation or accident analysis and has no radiological consequences. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. The proposed change does not involve any physical alteration of plant equipment and does not change the method by which any safety related

BVY 08-069 / Attachment 1 / page 4 systems perform their function. The proposed change removes unnecessary information from the Technical Specifications that is not required in accordance with 10CFR50.36. As such, no new or different types of equipment will be installed or removed from the facility. Operation of existing installed equipment is unchanged. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed change involve a significant reduction in a margin of safety?

Response: No. This change does not change any existing design or operational requirements and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings that would adversely affect plant operation as a result of the proposed change. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Docket 50-271 BVY 08-069 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Change 281 Revision to Battery Systems Markup of the Current Technical Specification and Bases Pages

VYNPS 3.10 LIMITING CONDITIONS FOR 4.10 SURVEILLANCE REQUIREMENTS OPERATION C. Th lS tc ar c. Once per operating Bat ie ea wo h cycle each cia ed Alternate Shutdown

/ass charge an it AS-2 battery, and 8 e\ asoc .ate DC Main Station ibuion pan 1. battery shall be subjected to a

d. Deleted. Service (Load Profile) discharge
e. The Alternate test. The specific Shutdown AS-2 gravity and voltage battery, one of the of each cell shall two associated be measured after chargers, and DC the recharge at the Distribution panel end of the DC-2AS. discharge test and logged.
f. Both UPS batteries, assdciated d. Once every five Uninterruptible years, each UPS, Power Supplies and AS-2, and Main MCC 89A and B. Station Battery shall be subjected to a Performance (capacity)

Discharge Test.

This test will be performed in lieu of the Service Test requirements of 4.10.A.2.c above.

e. Each 480 V Uninterruptible Power System shall be checked daily.
f. 480 V Motor Control Centers 89A and 89B shall be checked daily.
g. Once per operating cycle, the actual conditions under which the 480 V Uninterruptible Power Systems are required will be simulated and a test conducted to demonstrate equipment performance.

Amendment No. a,-2-1, 26 213

VYNPS 3.10 LIMITING CONDITIONS FOR 4.10 SURVEILLANCE REQUIREMENTS I OPERATION

e. From and after the date that one of the two 24 Volt Neutron Monitoring and Process Radiation Monitoring battery systems is found or made to be inoperable for any reason, continued reactor operation is permissible providing the minimum channel requirements of Sections 3.1 and 3.2 for the Neutron Monitoring and Process Radiation Monitoring systems are met.
f. From and Ifter the date t one of the o 125 volt Swi chyard batte stems is fo d or made to inoperab for any reason continued rea r operation i permissible rovided that t other 125 vo Switchyard attery K

system '

opera e.

3. Off-Site Power 3. Off-Site Power
a. From and after the a. When one off-site date one off-site power source is power source is unavailable, the made or found to be remaining power inoperable for any reason, reactor source shall be verified operable I

operation may within one hour and continue for seven once per eight days provided the hours thereafter.

remaining off-site power source and both diesel generators are operable, and either:

Amendment No. 4 - -&, 4Q-S 1521, 217

VYNPS BASES: 3.10 (Cont'd) the operable diesel generator are inoperable, the redundant required feature(s) with no off-site power available and the redundant required feature(s) supported by the inoperable diesel generator are required to be immediately declared inoperable and the applicable Technical Specification action(s) taken. These provisional requirements ensure that, during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time, a loss of off-site power does not'result in a loss of safety function of critical systems.

Required features are systems, subsystems, trains, components and devices supported by the off-site power sources and diesel generators and are required to be operable by the Technical Specifications in the existing plant mode or condition.

Either of the two main station batteries is sized to supply its assigned emergency load for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> without recharging, which provides margin relative to design requirements.

The main station battery duty cycle is defined as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based upon plant design which postulates the time required to restore AC power to the auxiliary systems, including the battery chargers.

Due to the high reliability of battery systems, one of the two batteries may be out of service for up to three days provided all required systems, subsystems, trains, components and devices supported by the operable 125 volt Station Battery System are operable. The provisional requirement ensures that, during the three day allowed outage time, a loss of safety function of critical systems does not exist. Required systems, subsystems, trains, components and devices are those supported by 125 volt Station Battery System and are required to be operable by the Technical Specifications in the existing plant mode or condition.

This minimizes the probability of unwarranted shutdown by providing adequate time for reasonable repairs. A station battery or an Uninterruptible Power System battery is considered inoperable if one cell is out of service. A cell will be considered out of service if its float voltage is below 2.13 volts and the specific gravity is below 1.190 at 77 0 F.

The Battery Room is ventilated to prevent accumulation of hydrogen gas.

With a complete loss of the ventilation system, the accumulation of hydrogen would not exceed 4 percent concentration in 2 1/2 days.

Therefore, on loss of Battery Room ventilation, the use of portable ventilation equipment and daily sampling provide assurance that potentially hazardous quantities of hydrogen gas will not accumulate.

ire~ets o**CO * .Aicappy to* tw 45kv/ ic~~

C. The minimum diesel fuel supply of 36,000 gallons will supply one diesel generator for a minimum of seven days of operation at its continuous duty rating of 2750kW. Additional fuel can be obtained and delivered to the site from nearby sources within the seven-day period.

Amendment No. 8Y-O-4&,

0 4, -,-BVY 86-&8 221b

VYNPS BASES: 4.10 (Cont'd) for the associated batteries. The results of these tests will be logged and compared with the manufacturer's recommendations of acceptability.

( phiqie~nts k4*fkvswitchyard bi/teries, of 4.10.A .a and S 4.l0.A

-4A and *SA. ---

b aplto the/wa

/p The Service Disch~arge Test (4.10.A.2.c) is a test of the batteries, ability to satisfy the design requirements of the associated dc system. This test will be performed using simulated or actual loads at the rates and for the durations specified in the design load profile (battery duty cycle).

Assurance that the diesels will meet their intended function is obtained by periodic surveillance testing and the results obtained from the pump and valve testing performed in accordance with the requirements of Specification 4.6.E. Specification 4.10.B.l.a provides an allowance to avoid unnecessary testing of the operable emergency diesel generator (EDG). If it can be determined that the cause of the inoperable EDG (e.g., removal from service to perform routine maintenance or testing) does not exist on the operable EDG, demonstration of operability of the remaining EDG does not have to be performed. If the cause of inoperability exists on the remaining EDG, it is declared inoperable upon discovery, and Limiting Condition for Operation 3.10.B.1 requires reactor shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />., Once the failure is repaired, and the common cause failure no longer exists, Specification 4.10.B.l.a is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG, performance of Surveillance Requirement (SR) 4.10.B.l.b suffices to provide assurance of continued operability of that EDG.

In the event the inoperable EDG is restored to operable status prior to completing either SR 4.10.B.l.a or SR 4.10.B.l.b, the plant correct-ive action program will continue to evaluate the common cause possibility. This. continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in the condition of SR 4.10.B.1 or SR 4.10.B.3.b.2.

According to NRC Generic\Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time to confirm that the operable EDG is not affecte'd by the same problem as the inoperable EDG.

Verification of operability of an off-site power source within one hour and once per eight hours thereafter as required by 4.10.B.3.b.l

,may be performed as an administrative check by examining logs and other information to determine that required equipment is available and not out of service for maintenance or other reasons. It does not require performing the surveillance needed to demonstrate the operability of the equipment.

C. Logging the diesel fuel supply weekly and after each operation assures that the minimum fuel supply requirements will be maintained.

During the monthly test for quality of the diesel fuel oil, a viscosity test and water and sediment test will be performed as described in ASTM D975-02. The quality of the diesel fuel oil will be acceptable if the results of the tests are within the limiting requirements for diesel fuel oils shown on Table 1 of ASTM D975-02.

Aendiment No. -28,4-54, &B;-0914--, 2-94, ~--q. 4, 2-24, E' 63 223 2

Docket 50-271 BVY 08-069 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Change 281 Revision to Battery Systems Retyped Technical Specification and Bases Pages

VYNPS 3.10 LIMITING CONDITIONS FOR 4.10 SURVEILLANCE REQUIREMENTS OPERATION

c. Deleted. c. Once per operating cycle each Alternate Shutdown AS-2 battery, and Main Station battery shall be subjected to a Service (Load Profile) discharge test. The specific
d. Deleted. gravity and voltage of each cell shall
e. The Alternate Shutdown be measured after AS-2 battery, one of the recharge at the the two associated end of the chargers, and DC discharge test and Distribution panel logged.

DC-2AS.

d. Once every five
f. Both UPS batteries, years, each UPS, associated AS-2, and Main Uninterruptible Power Station Battery Supplies and MCC 89A shall be subjected and B. to a Performance (capacity)

Discharge Test.

This test will be performed in lieu of the Service Test requirements of 4.10.A.2.c above.

e. Each 480 V Uninterruptible Power System shall be checked daily.
f. 480 V Motor Control Centers 89A and 89B shall be checked daily.
g. Once per operating cycle, the actual conditions under which the 480 V Uninterruptible Power Systems are required will be simulated and a test conducted to demonstrate equipment performance.

Amendment No. -2, 8-5, 4-1, - 213

VYNPS 3.10 LIMITING CONDITIONS FOR 4.10 SURVEILLANCE REQUIREMENTS OPERATION

e. From and after the date that one of the two 24 Volt Neutron Monitoring and Process Radiation Monitoring battery systems is found or made to be inoperable for any reason, continued.

reactor operation is permissible providing the minimum channel requirements of Sections 3.1 and 3.2 for the Neutron Monitoring and

  • Process Radiation Monitoring systems are met.
f. Deleted
3. Off-Site Power 3. Off-Site Power
a. From and after the a. When one off-site date one off-site power source is power source is unavailable, the made or found to be remaining power inoperable for any source shall be reason, reactor verified operable operation may within one hour and continue for seven once per eight days provided the hours thereafter.

remaining off-site power source and both diesel generators are operable, and either:

Amendment No. 24, 4-, 4-24, -32 217

VYNPS BASES: 3.10 (Cont'd) the operable diesel generator are inoperable, the redundant required feature(s) with no off-site power available and the redundant required feature(s) supported by the inoperable diesel generator are required to be immediately declared inoperable and the applicable Technical Specification action(s) taken. These provisional requirements ensure that, during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time, a loss of off-site power does not result in a loss of safety function of critical systems.

Required features are systems, subsystems, trains, components and devices supported by the off-site power sources and diesel generators and are required to be operable by the Technical Specifications in the existing plant mode or condition.

Either of the two main station batteries is sized to supply its assigned emergency load for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> without recharging, which provides margin relative to design requirements.

The main station battery duty cycle is defined as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based upon plant design which postulates the time required to restore AC power to the auxiliary systems, including the battery chargers.

Due to the high reliability of battery systems, one of the two batteries may be out of service for up to three days provided all required systems, subsystems, trains, components and devices supported by the operable 125 volt Station Battery System are operable. The provisional requirement ensures that, during the three day allowed outage time, a loss of safety function of critical systems does not exist. Required systems, subsystems, trains, components and devices are those supported by 125 volt Station Battery System and are required to be operable by the Technical Specifications in the existing plant mode or condition. This minimizes the probability of unwarranted shutdown by providing adequate time for reasonable repairs. A station battery or an Uninterruptible Power System battery is considered inoperable if one cell is out of service. A cell will be considered out of service if its float voltage is below 2.13 volts and the specific gravity is below 1.190 at 77'F.

The Battery Room is ventilated to prevent accumulation of hydrogen gas.

With a complete loss of the ventilation system, the accumulation of hydrogen would not exceed 4 percent concentration in 2 1/2 days.

Therefore, on loss of Battery Room ventilation, the use of portable ventilation equipment and daily sampling provide assurance that potentially hazardous quantities of hydrogen gas will not accumulate.

C. The minimum diesel fuel supply of 36,000 gallons will supply one diesel generator for a minimum of seven days of operation at its continuous duty rating of 2750kW. Additional fuel can be obtained and delivered to the site from nearby sources within the seven-day period.

Amendment No. BVY 01 40, 213, BV-9--985 221b

VYNPS BASES: 4.10 (Cont'd) for the associated batteries. The results of these tests will be logged and compared with the manufacturer's recommendations of acceptability.

The Service Discharge Test (4.10.A.2.c) is a test of the batteries ability to satisfy the design requirements of the associated dc system. This test will be performed using simulated or actual loads at the rates and for the durations specified in the design load profile (battery duty cycle).

Assurance that the diesels will meet their intended function is obtained by periodic surveillance testing and the results obtained from the pump and valve testing performed in accordance with the requirements of Specification 4.6.E. Specification 4.10.B.l.a provides an allowance to avoid unnecessary testing of the operable emergency diesel generator (EDG). If it can be determined that the cause of the inoperable EDG (e.g., removal from service to perform routine maintenance or testing) does not exist on the operable EDG, demonstration of operability of the remaining EDG does not have to be performed. If the cause of inoperability exists on the remaining EDG, it is declared inoperable upon discovery, and Limiting Condition for Operation 3.10.B.1 requires reactor shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Once the failure is repaired, and the common cause failure no longer exists, Specification 4.10.B.l.a is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG, performance of Surveillance Requirement (SR) 4.10.B.l.b suffices to provide assurance of continued operability of that EDG.

In the event the inoperable EDG is restored to operable status prior to completing either SR 4.10.B.l.a or SR 4.10.B.l.b, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in the condition of SR 4.10.B.1 or SR 4.10.B.3.b.2.

According to NRC Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time to confirm that the operable EDG is not affected by the same problem as the inoperable EDG.

Verification of operability of an off-site power source within one hour and once per eight hours thereafter as required by 4.10.B.3.b.l may be performed as an administrative check by examining logs and other information to determine that required equipment is available and not out of service for maintenance or other reasons. It does not require performing the surveillance needed to demonstrate the operability of the equipment.

C. Logging the diesel fuel supply weekly and after each operation assures that the minimum fuel supply requirements will be maintained.

During the monthly test for quality of the diesel fuel oil, a viscosity test and water and sediment test will be performed as described in ASTM D975-02. The quality of the diesel fuel oil will be acceptable if the results of the tests are within the limiting requirements for diesel fuel oils shown on Table 1 of ASTM D975-02.

Amendment No. 4-2-&, 4-5-, BVY 014G, 244, -I4-, 24-4, 2-2-, RVY 96 982 223

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