L-09-074, License Amendment Request to Provide Consistency in Division 3 Emergency Diesel Generator Start Time Technical Specification Surveillance Requirements
| ML091900387 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/30/2009 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-09-074 | |
| Download: ML091900387 (25) | |
Text
FENOC Perry Nuclear Power Station 10 Center Road FirstEnergyNuclear Operating Company Perry, Ohio 44081 Mark B. Bezilla 440-280-5382 Vice President Fax: 440-280-8029 June 30, 2009 L-09-074 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 License Amendment Request to Provide Consistency in Division 3 Emerqency Diesel Generator Start Time Technical Specification Surveillance Requirements Nuclear Regulatory Commission (NRC) review and approval of a license amendment is requested for the Perry Nuclear Power Plant. The proposed amendment would revise the acceptance criteria for Technical Specification (TS) Surveillance Requirement 3.8.1.7 to make the Division 3 Emergency Diesel Generator (EDG) start time requirement consistent with the time incorporated in the safety analysis for design basis events and with the time specified in the other TS 3.8.1 EDG start time surveillances. A 120-day implementation period is requested.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing at (330) 761-6071.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June 3o ,2009.
Sincerely, Mark B. Bezilla
Enclosure:
Evaluation of the Proposed License Amendment Request cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager State of Ohio (NRC Liaison)
I' UIt4
Evaluation of the Proposed License Amendment Request Page 1 of 8
Subject:
License Amendment Request to Provide Consistency in Division 3 Emergency Diesel Generator Start Time Technical Specification Surveillance Requirements
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION
- 3. TECHNICAL EVALUATION
- 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusion
- 5. ENVIRONMENTAL CONSIDERATION
- 6. REFERENCES Attachments:
- 1. Proposed Technical Specification Change (Mark Up)
- 2. Proposed Technical Specification Change (Re-typed - For Information)
- 3. Associated Technical Specification Bases Pages (Mark Up - For Information)
Evaluation of the Proposed License Amendment Request.
Page 2 of 8 1.0
SUMMARY
DESCRIPTION Nuclear Regulatory Commission (NRC) review and approval is requested for an amendment to Perry Nuclear Power Plant (PNPP) Technical Specification (TS) 3.8.1, "AC Sources - Operating." The proposed amendment will modify a Surveillance Requirement (SR) regarding the start time tests for the Division 3 Emergency Diesel Generator (EDG) to provide consistency with existing similar TS Surveillance Requirements and the time provided in the licensing basis emergency core cooling system analyses.
2.0 DETAILED DESCRIPTION The proposed amendment will modify the frequency portion of the start time acceptance criteria of SR 3.8.1.7 for the Division 3 EDG. The Division 3 EDG is dedicated to support the High Pressure Core Spray (HPCS) system. The amendment will make the Division 3 frequency start time requirement consistent with the existing 13 second voltage requirement in the same SR, and with the existing 13 second start time requirements in SR 3.8.1.11, SR 3.8,1.12, SR 3.8.1.15, SR 3.8.1.19, and SR 3.8.1.20. The 13 second time is consistent with the licensing basis emergency core cooling system analyses. The current requirement (subsequent to Amendment 142) in SR 3.8.1.7.b for frequency is <10 seconds and the voltage requirement is <13 seconds.
After achieving the minimum voltage of 3900 V and minimum frequency of 58.8 Hz within the above times, the HPCS EDG is subsequently required to achieve a steady state voltage between 3900 V and 4400 V and a steady state frequency between 58.8 Hz and 61.2 Hz per SR 3.8.1.7.c, which is being renumbered to be 3.8.1.7.b.
There is no time requirement specified to reach steady state, since this was eliminated with the implementation of Amendment 142 (Reference 1). provides a mark-up showing the proposed change to the PNPP TS, along with copies of the other relevant SRs in TS 3.8.1. Attachment 2 provides an informational copy of the re-typed TS page showing the proposed change. provides an informational copy of associated TS Bases changes to match the revised Division 3 EDG SR Requirement.
3.0 TECHNICAL EVALUATION
The EDG output breakers that close to provide power to the emergency busses have permissives that must be met. The conditions needed for the EDG output breaker to close include a minimum voltage of 3900 V and a minimum frequency of 58.8 Hz. These minimum values (rather than steady state conditions) are what must initially be met for the breaker to complete its function. This concept led to the
Evaluation of the Proposed License Amendment Request Page 3 of 8 creation of an industry-wide Technical Specification Task Force (TSTF) Traveler 163, "Minimum vs. Steady State Voltage and Frequency," which was the underlying basis for the changes that resulted in PNPP Amendment 142. The concept addressed in the TSTF was that the original TS time requirements for achieving
steady state" voltage and frequency were more appropriately identified as the times for reaching the minimum voltage and frequency values. Steady state conditions are then permitted to be subsequently achieved, with their specific TS time requirement replaced with a Bases requirement to trend the time it takes to reach steady state, in order to identify degradation of governor and voltage regulator performance. The change to SR 3.8.1.7 proposed in this current amendment request should have been included in the request that led to Amendment 142.
The PNPP Technical Specifications prior to Amendment 142 contained 13 second steady state requirements for both voltage and frequency for Division 3, by enforcing a range of values that had to be met within 13 seconds. If the intent of TSTF-163-A had been met, both of these 13 second "steady state" requirements for voltage and frequency would have been consistently converted into 13 second requirements for achieving minimum voltage and frequency values - however, this was inconsistently
-applied in the PNPP request for amendment. In all but one location (SR 3.8.1.7), the TSTF-163-A concept was correctly applied; however, SR 3.8.1.7 contained an additional frequency requirement that complicated implementation of the TSTF. The SR contained a requirement that in addition to meeting the 13 second steady state frequency requirement, the diesel should be up to a minimum frequency within 10 seconds.
Since the concept of TSTF-163 was that the former "steady state' times should now become the times to meet "minimum" values for voltage and frequency, this unnecessary Division 3 ten second time to meet a minimum frequency should have been deleted as part of the revision to SR 3.8.1.7 in Amendment 142.
The evolution of the Division 3 ten second time that is in SR 3.8.1.7 contributes to the discussion of why it is unnecessary to retain it. In the initially issued PNPP Technical Specifications in 1986, it was specified as a time applying only to the diesel portion of the EDG package, requiring the diesel to reach 882 revolutions per minute (RPM) within 10 seconds. The generator portion of the EDG package had a separate requirement; specifically, to meet the steady state ranges for voltage and frequency within 13 seconds. The 10 second diesel start time was considered to be a good-practice at the time that the original TSs were developed. It was later recognized that because the diesel and the generator are one package, the need to specify the diesel's speed in terms of RPM was unnecessary, so when the TSs were converted into the Improved Technical Specifications (ITS) format, the minimum 882 RPM value became a minimum 58.8 Hz frequency value, but it retained the 10 second time. River Bend Station personnel deleted this extra 10 second time during their conversion to ITS. That was acceptable, since the breaker cannot physically close onto the bus until the voltage requirement has also been met (which
Evaluation of the Proposed License Amendment Request Page 4 of 8 has a 13 second requirement), and because the 10 second time has no basis in the accident analysis.
As illustrated by the many other PNPP SRs that contain a 13 second TS requirement for the Division 3 EDG start (see Attachment 1 for examples),
13 seconds is the appropriate time to be applied to the PNPP Division 3 EDG. As stated in Updated Safety Analysis Report (USAR) Section 6.3.3.4, "System Performance During the Accident," an overall time of 29 seconds is assumed from the Loss of Coolant Accident (LOCA) initiation signal until the high pressure injection from the HPCS system begins. The SAFERPGESTR methodology LOCA analysis that supports this USAR statement identifies this 29 second time as one of the analysis parameters for the HPCS system response. The EDG start time is one portion of this overall 29 second time, since the analysis addresses a Loss of Offsite Power (LOOP) coincident with a Loss of Coolant Accident (LOCA). The SAFER/GESTR LOCA methodology was adopted as part of the PNPP licensing basis as reported to the NRC in June of 1999 (Reference 2), and further described to and reviewed by the NRC during a five percent power uprate in March of 2000 (References 3 and 4).
The TS SR affected by the proposed amendment specifies requirements for testing the EDGs. This testing is conducted to confirm the capability of each EDG to start'-
and achieve the minimum conditions required to accept load by starting each EDG from standby conditions to determine if the required voltage and frequency is met within the required time. This testing will continue to help ensure the availability of the EDGs to supply electrical power to safety-related equipment considered necessary to mitigate Design Basis Accidents and transients and maintain the plant in a safe shutdown condition. The HPCS EDG will continue to be maintained and monitored to be reliable, per the requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," and the Mitigating System Performance Index (MSPI) process, where the Division 3 EDG is treated as a segment within the HPCS system for MSPI purposes.
A similar change to the one currently proposed for SR 3.8.1.7 was made to SR 3.8.1.20 as part of the implementation of Amendment 142 (Reference 1). Prior to implementation of Amendment 142, SR 3.8.1.20 specified that the Division 3 EDG must achieve a minimum 58.8 Hz frequency in less than or equal to 10 seconds, with the steady state voltage and frequency requirements being 13 seconds. Upon implementation of Amendment 142, both the voltage and frequency TS time requirements are 13 seconds, consistent with the other PNPP EDG start time SRs (except for the current version of SR 3.8.1.7). Discussions with the NRC staff regarding this portion of Amendment 142 noted that this portion was not specifically justified on the docket in the submittal requesting the amendment, and therefore at the time, the change was considered to be non-conservative. However, the information provided in this current submittal that documents the basis for the currently requested change to SR 3.8.1.7 also justifies the change previously made
Evaluation of the Proposed License Amendment Request Page 5 of 8 to SR 3.8.1.20 in Amendment 142. In the interim period until NRC approval is obtained on the currently requested change, administrative controls are in place for SR 3.8.1.20 to enforce the previous 10 second frequency time. Upon implementation of this requested amendment, the administrative controls over SR 3.8.1.20 will be removed, and its wording will remain as-is.
4.0 REGULATORY EVALUATION
The proposed license amendment to the Perry Nuclear Power Plant (PNPP)
Technical Specifications (TS) would revise the acceptance criteria for Emergency Diesel Generator (EDG) Surveillance Requirement (SR) 3.8.1.7 to make the Division 3 High Pressure Core Spray (HPCS) EDG start time requirement consistent with the time incorporated in the PNPP safety analysis for design basis events and with the time specified in the other TS 3.8.1 EDG start time surveillances.
4.1 Applicable Regulatory Requirements/Criteria The proposed change to the PNPP TS is consistent with 10 CFR 50.36, "Technical Specifications," General Design Criterion (GDC)-17, "Electric power systems" of Appendix A to 10 CFR 50, and GDC-1 8, "Inspection and testing of electric power systems" of Appendix A of 10 CFR 50, since there is no effect on the EDG capability to supply the minimum voltage and frequency required within the time assumed in the safety analyses. The applicable TS Surveillance will continue to verify the capability of the Division 3 EDG to provide power at a voltage and frequency adequate to start and operate the safety loads should an EDG start signal be received.
Maintenance and monitoring of the diesel will be maintained per the Maintenance Rule and the Mitigating System Performance Index process.
4.2 Precedent The 13 second time in SR 3.8.1.7 proposed for both voltage and frequency is consistent with the 13 second time specified in PNPP SRs 3.8.1.11, 3.8.1.12, 3.8.1.15, 3.8.1.19, and 3.8.1.20. It is also consistent with the 13 second time utilized for both voltage and frequency in each of the River Bend Station EDG SRs, including equivalent SR 3.8.1.7.
4.3 Significant Hazards Consideration The FirstEnergy Nuclear Operating Company has evaluated whether or not a significant hazards consideration is involved with the proposed amendment to the PNPP TS by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:
Evaluation of the Proposed License Amendment Request Page 6 of 8
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment corrects and makes consistent the acceptance criteria for the PNPP TS SR pertaining to the Division 3 EDG. The EDGs mitigate the consequences of previously evaluated accidents involving a loss of offsite power. The EDGs are used to support mitigation of the consequences of an accident, but they are not considered as the initiator of any previously analyzed accident.
The proposed amendment will continue to ensure the EDGs perform their function when called upon to mitigate the consequences of events.
The proposed revision to the TS SRs will continue to maintain the capability of the Division 3 HPCS system to respond within the times assumed in the Emergency Core Cooling System (ECCS) analyses.
The proposed amendment does not affect the design of the EDGs, the interfaces between the EDGs and other plant systems, or the function and reliability of the EDGs. Thus, the EDGs will continue to be capable of performing their accident mitigation function and there is no impact to the radiological consequences determined in any accident analysis.
As such, the proposed amendment continues to provide adequate assurance of an operable EDG and does not involve any increase to the probability or to the consequences of any accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change is an amendment that introduces no new mode of plant operation and it does not involve physical modification to the plant.
New equipment is not installed with the proposed amendment, nor does the proposed amendment cause existing equipment to be operated in a new or different manner.
Since the proposed amendment does not involve a change to the plant design or operation, no new system interactions are created by this change. The proposed amendment does not produce any parameters or conditions that could contribute to the initiation of accidents different from those already evaluated in the Updated Safety Analysis Report.
The change to the affected TS SR does not affect the assumed accident
Evaluation of the Proposed License Amendment Request Page 7 of 8 performance of the EDG, nor any plant structure, system or component previously evaluated.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.- Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change is an amendment that does not impact EDG performance as incorporated in the design basis analyses, including the capability for the EDG to attain and maintain required voltage and frequency for accepting and supporting plant safety loads should an EDG start signal be received. The operability of the EDG continues to be determined as required to provide emergency power to plant equipment that mitigate the consequences of a transient or accident, and maintains the HPCS system's capability to respond within the time assumed in the accident analyses.
The proposed amendment does not introduce changes to setpoints or limits established in the accident analysis. As a result of the above considerations, it is concluded that implementation of the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, the FirstEnergy Nuclear Operating Company concludes that the proposed amendment to the PNPP TS does not involve a 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.
4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
The proposed amendment was evaluated against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not significantly increase
Evaluation of the Proposed License Amendment Request Page 8 of 8 individual or cumulative occupational radiation exposures, does not significantly change the types or significantly increase the amounts of effluents that may be released off-site, and does not involve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed amendment meets the criteria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.
6.0 REFERENCES
- 1. Letter from U. S. Nuclear Regulatory Commission (USNRC) to FirstEnergy Nuclear Operating Company, "Perry Nuclear Power Plant, Unit No. 1 -
Issuance of Amendment RE: Emergency Diesel Generator Surveillance Testing Voltage and Frequency Limits (TAC NO. MC8997)," dated April 30, 2007.
ADAMS Accession Number ML070960047
- 2. FirstEnergy letter from Lew W. Myers to USNRC, "Implementation of the SAFER/GESTR Loss of Coolant Accident Methodology," June 7, 1999. Public Legacy Accession Number 9906180091
- 3. Attachment 2 to a FirstEnergy letter from John K. Wood to USNRC, "Response to Request for Additional Information Related to a License Amendment Requesting a Power Uprate (TAC No. MA6459)," March 1, 2000. ADAMS Accession Number ML003690096
- 4. Letter from USNRC to FirstEnergy Nuclear Operating Company, "Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment (TAC NO. MA6459)," dated June 1, 2000. ADAMS Accession Number ML003724441
Attachment 1 PROPOSED TECHNICAL SPECIFICATION CHANGE (Mark Up)
Six pages attached
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.7 ---------------- NOTE-All DG starts may be preceded by an engine prelube period.
.Verify each DG starts from standby 184 days conditions and achieves -
- a. for ivision 1 and 2, seconds nfo - Y~:~C~3) a violtage 2 3900 V and req:uency
Ž 58.8 Hz, and
- b. For Divizi on 3, in n., V I -i
- 10n ~ ... n '
scornd* voltago Ž 300qnn\ and i.;eý-
e- D, Steadea state voltage
_ 3900 V and < 4400 V and frequency
> 58.8 Hz and _<61.2 Hz.
SR 3.8.1.8 ------------- NOTE-------------------
This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.
Verify manual transfer of unit power supply 24 months from the normal offsite circuit to the alternate offsite circuit.
(continued)
PERRY - UNIT 1 3.8-7 Amendment No. 142
AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.11 ------------------NOTES---------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1. 2, or 3.
However, credit may be taken for unplanned events that satisfy this SR.
Verify on an actual or simulated loss of 24 months offsite power signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses for Divisions I and 2: and
- c. DG auto-starts from standby condition and:
- 1. energizes permanently connected loads in
- 10 seconds for J-~
Division 1 and 2 DGs and
,< 13 seconds for Division 3,
- 2. energizes auto-connected loads for Divisions 1 and 2,
- 3. maintains steady state voltage
Ž 3900 V and
- 4400 V,
- 4. maintains steady state frequency
Ž 58..8 Hz and
- 61.2 Hz, and
- 5. supplies permanently connected and auto-connected loads for
> 5 minutes.
(continued)
PERRY - UNIT 1 3.8-9 Amendment No. 115
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.12 ---------------- NOTES--------------
1, All DG starts may be preceded by an engine prelube period.
2, This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.
Veiyon an actual or simulated Emergn 24 months
[ Core Cooling System (ECCS) initiation S signal each DG~auto-starts from standby A-0 S condition and: N ' Vk
- a. In
- 10 seconds for Division 1 and 2,
\ and 13 seconds for Division 3, after
\ auto-start and during tests, achieves
\ voltage 3900 V and frequency
- ..._*_58.8 Hz; and"
- b. Achieves steady state voltage Ž 3900 V and
- 4400 V and frequency Ž 58.8 Hz and
- 61.2 Hz: and t%
- c. Operates for Ž 5 minutes. 4r ~>V. ~
SR 3.8,1.13 --------------- NOTE----------------
This Surveillance shall not be performed in MODE 1. 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.
Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS initiation signal except:
- a. Engine overspeed; and
- b. Generator differential current (continued)
PERRY - UNIT 1 3.8-10 Amendment No. 142
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.15 ----------------- NOTES---------------
- 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated Ž 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> loaded Ž 5600 kW and ** 7000 kW for Division 1 and 2 DGs, and Ž 2600 kW for Division 3 DG.
Momentary transients outside of the load range do not invalidate this test.
- 2. All DG starts may be preceded by an engine. prelube period.
V yeach DG starts and achieves: 24 months Sa. In 10 seconds for Division 1 and 2, Cand 13 seconds for Division 3,
\ voltage ý!3900 V and frequency ~ +hW 58.8 H+/-; and 12~C~dPro&
- b. Steady state voltage Ž 3900 V and 4400 V and frequency Ž 58.8 Hz and 61.2 Hz.
SR 3.8.1.16. ----------------- NOTE----------------
This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.
Verify each DG: 24 months
- a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;
- b. Transfers loads to offsite power source; and
- c. Returns to ready-to-load operation.
(continued)
PERRY - UNIT 1 3.8-12 Amendment No. 142
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE I FREQUENCY SR 3.8.1.19 -------------------- NOTES--------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be erformed in MODE 1, 2, or 3.
owever, credit may be taken for unplanned events that satisfy this SR.
Verify, on an actual or simulated loss of 24 months offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses for Divisions I and 2; and CA,&KLs+
DG auto-starts from standby condition-and:
s 4ocy 1 energizes permanently connected 'týxz' OL- )
loads in
- 10 seconds for Divisions 1 and 2 and
- 13 seconds for Division 3, t3&+4vS-ý r
- 2. energizes auto-connected emergency loads (for Division 3, verify energization in
- 13 seconds),
- 3. achieves steady state voltage
- 3900 V and
- 4400 V,
- 4. achieves steady state frequency 58.8 Hz and
- 61.2 Hz, and
- 5. supplies permanently connected and auto-connected emergency loads for
- 5 minutes.
(continued)
PERRY - UNIT 1 3.8-14 Amendment No. 115
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.20 ------------------ NOTE----------------
All DG starts may be preceded by an engine prelube period.
Verify, when started simultaneously from**
Sstandby condition, each DG achieves:\ 10 years 0$o *k -* +,'s S a. In 10 seconds for Division 1 and 2,
\and 13 seconds for Division 3, voltage
Ž 3900 V and frequency Ž 58.8 Hz; and
- b. Steady state voltage Ž 3900 V and 5*. " -~~C~
3
- 4400 V and frequency Ž 58.8 Hz and
- 61.2 Hz.
PERRY - UNIT 1 3.8-15 Amendment No. 142
Attachment 2 PROPOSED TECHNICAL SPECIFICATION CHANGE (Re-Typed - For Information)
One page attached
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continUed)
SURVEILLANCE FREQUENCY SR 3.8.1.7 ------------------ NOTE----------------
All DG starts may be preceded by an engine prelube period.
Verify each DG starts from standby 184 days conditions and achieves:
- a. In
- 10 seconds for Division 1 and 2, and
- 13 seconds for Division 3, voltage Ž 3900 V and frequency 58.8 Hz; and
- b. Steady state voltage Ž 3900 V and
- 4400 V and frequency Ž 58.8 Hz and
- 61.2 Hz.
,SR 3.8.1.8 -------------- NOTE-------------------
This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.
Verify manual transfer of unit power supply 24 months from the normal-offsite circuit to the alternate offsite circuit.
(continued)
PERRY - UNIT 1 3.8-7 Amendment No.
Attachment 3 ASSOCIATED TECHNICAL SPECIFICATION BASES PAGES (Mark Up - For Information)
Six pages attached
AC Sources - Operating B 3.8.1 BASES (continued)
LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Distribution System, and three separate and independent DGs (Divisions 1, 2, and 3).
-ensure availability of the required power to shut down the reactor and maintain it in a safe shytdown condition after an anticipated operational occurrenc6 (AO0) or a postulated DBA.
Qualified offsite circuits are those that are described in the USAR and are part of the licensing basis for the unit.
Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses. One offsite circuit consists of the Unit 1 startup transformer through the Unit 1 interbus-transformer, to the Class 1E 4.16 kV ESF buses through source feeder breakers for each division. The second offsite circuit consists of the Unit 2 startup transformer through the Unit 2 interbus transformer, to the Class 1E 4.16 kV ESF buses through source feeder breakers for each division. Several additional paths from the transmission system to the Class 1E system are available as alternate offsite power sources if lops of a startup transformer occurs. For example, for Unit 1, this includes feeding 13.8 kV bus LIO from bus L1i or L12. via the unit auxiliary transformer. A motor-operated disconnect switch is provided to facilitate the availability of this path within the time required for operator action. In all cases.
there are at .least two separate paths, with sufficient capacity provided from the transmission network to the standby power distribution system, available in sufficient time, in accordance with GDC-17.
ac DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. This sequence must be accomplished within 10 seconds for the Division 1 and 2 DGs:
r-v% a-to i' and 13 seconds for the Division 3 DG. mus a tapa e o accep ing requi e o ithin the assumed-loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot and DG in standby with engine at ambient conditions. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.
(continued)
PERRY - UNIT 1 B 3.8-3 Revision No. 1
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued)
REQUIREMENTS SR 3.8.1.7 requires that, at a 184 day Frequency, the Division 1,anjd 2 DGs start from standby conditions and achieveo required voltage and frequency within 10 seconds.
Also, this SR requires that the Division 3 DG starts from standby conditions and achieves alm .inimu rqir fr ...
- ithin 1 required voltage and frequency within 13 seconds. The start time requirements support the assumptions in the design basis LOCA analysis (Ref. 5). The start time requirements are not applicable to SR 3.8.1.2 (see Note 3 of SR 3.8.1.2). Since SR 3.8.1.7 does require timed starts, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This procedure is the intent of Note 1 of SR 3.8.1.2. Similarly, the performance of SR 3.8.1.12 or SR 3.8.1.19 also satisfies the requirements of SR 3.8.1.2 and SR 3.8.1.7.
In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The 31 day Frequency for SR 3.8.1.2 is consistent with the industry guidelines for assessment of diesel generator performance (Ref. 14). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
SR 3.8.1.3 This Surveillance demonstrates that the DGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
(continued)
PFRRY - 1JNTT 1 B 3.8-15 Revision No. 6.
AC Sources -Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)
REQUIREMENTS The reason for Note 2 is that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
- 1) Unexpected operational events which cause the
,equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
- 2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
SR 3.8.1.15
'This
/ r ureillance restart from a hot demonstrates condition, suchthat asthesubsequent diesel engined adn to shutdown normal Suredltonpero thevei conditifrom the required Divisions 1 and voltage 2 andhu and frequency within 10 seconds for S13 seconds for Division 3. The times are derived from the
- r**. *e-*r equirements basis of theLOCA.
large break accident analysis to respond to a design 24WThe monthrequired conditions Frequency to takes performinto the consideration surveillance, unitand is consistent with the C.2.a.
(Ref. 9) paragraph intent of Regulatory Guide 1.108 an 2SRDshasisbeen This provde toCaodruieoelaigo modified by two Notes. Note 1 ensures hs that the test is that requirement performed withthe the diesel has diesel operatedsufficiently hot.I hour for~at least The at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. The load band for the Division I and 2 DGs is provided to avoid routine overloading of these DGs. While this Surveillance allows operation of the Division 1 and 2 DGs in the band of 5600 kW to 7000 kW, a range of 5600 kW to 5800 kW will normally be used in order to minimizewear on the DGs. This is the load range (continued)
PERRY - UNIT 1 B 3.8-26 Revision No. 3
AC Sources -Operating B 3.8.1 BASES (continued)-
REFERENCES 1. 10 CFR 50. Appendix A, GDC 17.
- 2. USAR, Chapter 8.
- 3. Regulatory Guide'l.9. No c&k'ýi
- 4. USAR. Chapter 6. ' Pol
- 5. USAR, Chapter 15. Vi e4~~-cC~
- 7. Generic Letter 84-15, July 2, 1984.
- 11. ANSI C84.1, 1982.
- 12. ASME, Boiler and Pressure Vessel Code,Section XI.
- 13. IEEE Standard 308.
- 14. NUMARC 87-00, Revision 1. August 1991.
PERRY - UNIT 1 B 3.8-33 Revision No. 2
ECCS Instrumentation B 3.3.5.1 BASES BACKGROUND Automatic Depressurization System (continued)
Either ADS trip system A or trip system B will cause all the ADS relief valves to open. Once the ADS initiation signal is present, it is sealed in until manually reset.
There are two manual initiation push buttons in each trip system. Actuating both push buttons in either trip system will cause all ADS valves to open if at least one of the two low pressure ECCS pumps is running. Manual initiation can also be accomplished by operating the individual control switch for each safety/relief valve (S/RV) associated with the ADS. Manual inhibit switches are provided in the control room for ADS; however, their function is not required for ADS OPERABILITY (provided ADS is not inhibited when required to be OPERABLE).
DieselGenerators The Division 1, 2, and 3 DGs may be initiated by either automatic or manual means. Automatic initiation occurs for conditions of Reactor Vessel Water Level -Low Low Low, Level 1 or Drywell Pressure-High for Division 1 and 2 DGs, and Reactor Vessel Water Level -Low Low, Level 2 or Drywell Pressure- High for Division 3 DG. The DGs are also initiated upon loss of voltage signals. (Refer to Bases for LCO 3.3.8.1, "Loss of Power (LOP) Instrumentation," for a discussion of these signals.) Each of these diverse variables is monitored by two redundant transmitters per DG, which are, in turn, connected to two trip units. The outputs of the four divisionalized trip units (two trip units from each of the two variables) are connected to relays whose contacts are connected to a one-out-of-two taken twice logic. The DGs receive their initiation signals from the associated Divisions' ECCS logic (i.e., Division 1 DG receives an initiation signal from Division 1 ECCS (LPCS and LPCI A); Division 2 DG receives an initiation signal from Division 2 ECCS (LPCI B and LPCI C); and Division 3 DG receives an initiation signal from Division 3 ECCS (HPCS)). The DGs can also be started manually from the control room and locally in the associated DG room. The DG initiation signal is a sealed in signal and must be manually reset. The DG initiation logic is reset by resetting the associated ECCS initiation logic. Upon receipt of a LOCA initiation signal. each DG is automatically started, is ready to load in approximately 10 second..st, and will run in PERRY - UNIT 1 B 3.3-93
ECCS Instrumentation B 3.3.5.1 BASES BACKGROUND Diesel Generators (continued) standby conditions (rated voltage and speed, with the DG output breaker open). The DGs will only energize their
-0LV&CI\. respective Engineered Safety Feature (ESF) buses if a loss of offsite power occurs. (Refer to Bases for LCO 3.3.8.1.)
r r, "- AEGTs LThe AEGT subsystems may be initiated by either automatic or manual means. Automatic initiation occurs for conditions of Reactor Vessel Water Level-Low Low Low, Level 1 or Drywell Pressure-High. Each of these diverse variables is monitored by two redundant transmitters per AEGT subsystem which are.
in turn, connected to two trip units, The outputs of the four divisionalized trip units (two trip units from each of the two variables) are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic. The AEGT subsystems receive their initiation signals from the associated Divisions' ECCS logic (i.e.. Division 1 AEGT subsystem receives an initiation signal from Division 1 ECCS (LPCS and LPCI A), and Division 2 AEGT subsystem receives an initiation signal from Division 2 ECCS (LPCI B and LPCI C)).
The AEGT subsystems can also be started manually from the control room. The AEGT initiation logic is reset by resetting the associated ECCS initiation logic.
APPLICABLE The actions of the ECCS are explicitly assumed in the safety SAFETY ANALYSES analyses of References 1, 2. and 3. The ECCS is initiated LCO, and to preserve the integrity of the fuel cladding by limiting APPLICABILITY the post LOCA peak cladding temperature to less than the 10 CFR 50.46 limits.
ECCS instrumentation satisfies Criterion 3 of the NRC Policy Statement. Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.
The OPERABILITY of the ECCS instrumentation is dependent upon the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.5.1-1. Each (continued)
PERRY - UNIT 1 B 3.3-94 Revision No. 0