ML032751391

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Technical Specification for Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment 164, Revising the Action Statement and Surveillance Requirement for the Emergency Diesel Generators
ML032751391
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 09/26/2003
From: Cotton K
NRC/NRR/DLPM/LPD2
To: Byrne S
South Carolina Electric & Gas Co
References
TAC MB6521
Download: ML032751391 (9)


Text

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and
b. Two separate and independent Emergency Diesel Generators (EDG), each with:
1. A separate day fuel tank containing a minimurp volume of 360 gallons of fuel,
2. A separate fuel storage system containing a minimum volume of 48,500 gallons of fuel, and
3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit of 3.8.1.1.a Inoperable:
1. Demonstrate the OPERABILITY of the remaining offsite A.C. sources by performing Surveillance Requirement 4.8.1.1.1 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, and
2. If either EDG 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 4.8.1 .1.2.a.3 separately for each such EDG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the diesel is already operating, and
3. 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 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 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 EDG of 3.8.1.1.b Inoperable:
1. Demonstrate the OPERABILITY of the A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1 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, and
2. *Ifthe EDG became Inoperable due to any cause other than preplanned preventive maintenance or testing:

a) determine the OPERABLE EDG is not inoperable due to a common cause failure within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or b) demonstrate the OPERABILITY of the remaining EDG by performing Surveillance Requirement 4.8.1.1.2.a.3 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

  • Completion of Action b.2 is required regardless of when the noperable EDG Is restored to OPERABILITY.

SUMMER - UNIT 1 314 8-1 Amendment No. 60,77, 84.98.150. 164

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION: (Continued)

3. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, verify that required systems, subsystems, trains, components and devices that depend on the remaining EDG as a source of emergency power are also OPERABLE and in MODE 1, 2, or 3, that the Turbine Driven Emergency Feed 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 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 />.
4. Restore the EDG 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 STANDY 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 />.
c. With one offsite circuit and one EDG inoperable:
1. Demonstrate the OPERABILITY of the remaining offsite A.C. source by performing Surveillance Requirement 4.8.1. 1.1 within one hour 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, and
2. *If the EDG became Inoperable due to any cause other than preplanned preventative maintenance or testing:

a) determine the OPERABLE EDG is not inoperable due to a common cause failure within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or b) demonstrate the OPERABILITY of the remaining EDG by performing Surveillance Requirement 4.8.1.1.2.a.3 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and

3. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, verify that required systems, subsystems, trains, components and devices that depend on the remaining EDG as a source of emergency power are also OPERABLE and in MODE 1, 2, or 3, that the Turbine Driven Emergency Feed 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 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 />.
4. Restore one of the Inoperable 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 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 />, and
5. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status In accordance with the provisions of Section 3.8.1.1 Action Statement a. or b., as appropriate, with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable A.C. power source.

SUMMER - UNIT 314 8-2 Amendment No. 77,98, 164

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.2 Each EDG shall be demonstrated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by:
1. Verifying the fuel level in the day tank and fuel storage tank.
2. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.
3. Verifying the diesel generator can start* and accelerate to synchronous speed (504 rpm) with generator voltage and frequency at 7200 +/- 720 volts and 60 +/- 1.2 Hz.
4. Verifying the generator is synchronized, gradually loaded* to an indicated 4150-4250 kW and operates for at least 60 minutes.
b. At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by removing accumulated water from the day tank.
c. At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks.
d. By sampling new fuel oil based on the applicable ASTM standard prior to addition to storage tanks and:
1. By verifying based on the tests specified in the applicable ASTM standard prior to addition to the storage tanks that the sample has:

a) An API Gravity of within 0.3 degrees at 600 F or a specific gravity of within 0.0016 at 60/600 F, when compared to the supplier's certificate, or an absolute specific gravity at 60/600 F of greater than or equal to 0.83 but less than or equal to 0.89, or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees; b) A kinematic viscosity at 400C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes (alternatively, Saybolt viscosity, SUS at 1000F of greater than or equal to 32.6, but less than or equal to 40.1), if gravity was not determined by comparison with the supplier's certification;

  • This test shall be conducted In accordance with the manufacturer's recommendations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations.

This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band shall not invalidate the test.

SUMMER - UNIT 1 3/4 8-3 Amendment No.77, 93, 48,12-4,139, 164

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c) A flash point equal to or greater than 1250F; and d) A clear and bright appearance when tested based on the applicable ASTM standard.

2. By verifying within 30 days of obtaining the sample that the specified properties are met when tested based on the applicable ASTM standard.
e. At least once every 31 days by obtaining a sample of fuel oil based on the applicable ASTM standard, and verifying that total contamination is less than 10 mg/liter when checked based on the applicable ASTM standard.
f. At least once per 184 days by:
1. Verify each EDG starts from standby conditions and:

a) In less than or equal to 10 seconds, achieves a voltage greater than 6480 volts (7200 - 720 volts) and a frequency greater than 58.8 Hz (60 - 1.2 He).

b) Achieve a steady state voltage greater than 6480 volts but less than 7920 volts and a steady state frequency greater than 58.8 Hz but less than 61.2 Hz.

The EDG shall be started for this test by using one of the following signals:

a) Simulated loss of offsite power by Itself.

b) Simulated loss of offsite power in conjunction with an ESF actuation test signal.

c) An ESF actuation test signal by Itself.

d) Simulated degraded offsite power by tself.

e) Manual.

2. The generator shall be manually synchronized, loaded to an indicated 4150-4250 kW** in less than or equal to 60 seconds, and operate for at least 60 minutes.
9. At least once every 18 months by:
1. Subjecting the diesel to an inspection in accordance with procedures prepared In conjunction with its manufacturer's recommendations for this class of standby service.
2. Verifying that on rejection of a load of greater than or equal to 729 kW, the voltage and frequency are maintained at 7200 +/- 720 volts and frequency at 60 +/- 1.2 Hz.
3. Verifying the generator capability to reject a load of 4250 kW without tripping. The generator voltage shall not exceed 7920 volts during and following the load rejection.

This band Is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band shall not invalidate the test.

SUMMER - UNIT 314 8-4 Amendment No. 77, 93,421-, 164

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

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

a) Verifying de-energization 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 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 of these loads, the steady-state voltage and frequency shall be maintained at 7200 +/- 720 volts and 60 +/- 1.2 Hz.

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. Verify that the EDG starts from standby conditions and In less than or equal to 10 seconds, achieves a voltage greater than 6480 volts and a frequency greater than 58.8 Hz. After steady state operation is obtained, the EDG shall be verified to have a voltage greater than 6480 volts but less than 7920 volts and a frequency greater than 58.8 Hz but less than 61.2 Hz. After 5 minutes of standby operation verify that on a simulated loss of offsite power:

a) the loads are shed from the emergency busses, b) the diesel generator does not connect to the bus for at least 5 seconds, and c) that subsequent loading of the diesel generator is in accordance with design requirements.

6. Simulating a loss of offsite power in conjunction with an ESF actuation test signal, and a) Verifying de-energization of the emergency busses and load shedding from the emergency busses.

b) Verifying the EDG starts in the emergency mode, 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 and maintains the steady state voltage and frequency at 7200 +/- 720 volts and 60 +/- 1.2 Hz.

c) Verifying that all EDG trips, except engine overspeed, generator differential and low lube oil pressure are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection actuation signal.

SUMMER - UNIT 314 8-5 Amendment No. 77, 93; 164

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

7. Verifying the EDG operates for at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

a) The EDG shall be loaded to the continuous rating (4150-4250 kW**) for the time required to reach engine temperature equilibrium, at which time the EDG shall be loaded to an indicated target value of 4676 kW (between 4600-4700 kW**) and maintained for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

b) During the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the EDG shall be loaded to an indicated 4150-4250 kW**.

c) During this test the steady state voltage and frequency shall be maintained at 7200 +/- 720 volts and 60 +/- 1.2 Hz.

8. Verifying that the auto-connected loads to each EDG do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 4548 kW.
9. Verifying the EDG's capability to:

a) Synchronize with the offsite power source while the generator Is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite power source, and c) Be restored to its standby status.

10. Verifying that with the diesel generator operating In a test mode, connected to Its bus, a simulated safety Injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.
11. Verifying that the fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the Installed cross connection lines.
12. Verifying that the automatic load sequence timer is OPERABLE with the Interval between each load block within +/- 10% of its design interval.
13. Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:

a) Barring Device b) Remote-Local-Maintenance Switch

14. Verifying that within 5 minutes of operating the diesel generator for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a load of 4150-4250 kW the diesel starts on the auto-start signal (Loss of Off-Site Power signal), energizes the emergency busses with permanently connected loads This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band shall not invalidate the test.

SUMMER - UNIT 1 3/4 86 Amendment No. 77, 9, 164

3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1. 3/4.8.2 AND 3/4.8.3 A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C.

and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix A to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation.

The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source.

The A.C. and D.C. source allowable out-of-service times are based on Regulatory Guide 1.93, "Availability of Electrical Power Sources," December 1974. When one diesel generator is inoperable, there is an additional ACTION requirement to verify that 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 that the steam-driven auxiliary feedwater pump is OPERABLE. 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 period one of the diesel generators Is inoperable. The term verify as used in this context means to administratively check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITY of the component If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generator, then Surveillance 4.8.1.1.2.a.3 does not have to be performed.

If the cause of the initial inoperable diesel generator cannot be confirmed not to exist on the redundant diesel generator, performance of Surveillance Requirement 4.8.1.1.2.a.3 suffices to provide assurance of continued OPERABILITY of that diesel generator. This allows for reduced start testing of the diesel generators, which has been shown to be a factor in engine degradation.

In the event that the Inoperable diesel generator is restored to OPERABLE status prior to completing either the evaluation of cause or performing the surveillance requirement, the CER 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 mposed.by the action statement. According to Generic Letter 84-15, Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE diesel generator Is not affected by the same problem as the Inoperable diesel generator.

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient Instrumentation and control capability Is available for monitoring and maintaining the unit status.

SUMMER - UNIT I B314 8-1 Amendment No. , 84, 189,150, 164

ELECTRICAL POWER SYSTEMS BASES A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS (Continued)

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9, "Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10, 1971, and 1.137, "Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979, as modified by the NRC's review and approval of South Carolina Electric & Gas Company's June 10, 1985, December 6, 1985, and November 10, 2000 amendment requests.

The Surveillance Requirement that assures the diesel generator Is capable of performing its design function follows the guidance of NUREG 1366 and NUREG 1431, Rev 2. The surveillance tests the capability of the diesel generator to start and close its breaker in the required 10 seconds to support the accident analysis, and carry the required electrical load while maintaining the voltage and frequency limits necessary to assure OPERABILITY of the loads.

In addition to the Surveillance Requirements, the time for the diesel generator to reach steady state operation, unless the modified start method Is utilized, is periodically monitored and the trend evaluated to Identify degradation of the governor and voltage regulator performance.

The fuel storage system minimum volume of fuel to demonstrate operability of the diesel generators was based on fuel consumption determined from the development of time dependent loads following a design basis accident and a loss of off-site power utilizing FSAR Table 8.3-3 for seven days.

All safety-related portions of the VCSNS diesel engine fuel oil storage and transfer system, are Seismic Category I, Safety Class 2b, and designed to ANSI Standard N195-1976 with the provision listed below:

VCSNS will maintain at least 2% margin above the minimum calculated seven day required volume during Modes 1-4. This is an exception to ANSI N195-1976, "Fuel Oil Systems for Standy Diesel Generators," Section 5.4, during Modes 1-4. EDG fuel replenishment is available from multiple sources, including off-site suppliers, on-site non safety storage in the Auxiliary Boiler Fuel Tank, and the ability to provide fuel from the opposite train EDG Fuel Oil Storage Tank via the fuel oil and transfer system cross-tie.

The 10% fuel margin as recommended In Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators," position C.1.c.(2) will be met during Modes 5 and 6.

The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are based on the recommendations of Regulatory Guide 1.129, Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1987, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage and float charge, connection resistance values and the performance of battery service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates and compares the battery capacity at that time with the rated capacity.

SUMMER - UNIT B 3/4 8-2 Amendment No. 7,150, 164

ELECTRICAL POWER SYSTEMS BASES A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS (Continued)

Table 4.8-2 specifies the normal limits far each designated pilot cell and each connected cell for electrolyte level, float voltage and specific gravity. The limits for the designated pilot cells float voltage and specific gravity, greater than 2.13 volts and .015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adequate capacity. The normal limits for each connected cell for float voltage and specific gravity, greater than 2.13 volts and not more than .020 below the manufacturers full charge specific gravity with an average specific gravity of all the connected cells not more than .010 below the manufacturer's full charge specific gravity, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days. During this 7 day period: (1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than .020 below the manufacturers recommended full charge specific gravity, ensures that the decrease In rating will be less than the safety margin provided In sizing; (3) the allowable value for an Individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than .040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability to perform Its design function.

3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES Containment electrical penetrations and penetration conductors are protected by either deenergizing circuits not required during reactor operation or by demonstrating the OPERABILITY of primary and backup overcurrent protection circuit breakers during periodic surveillance.

The surveillance requirements applicable to lower voltage circuit breakers provide assurance of breaker reliability by testing at least one representative sample of each manufacturers brand of circuit breaker. Each manufacturer's molded case and metal case circuit breakers are grouped into representative samples which are then tested on a rotating basis to ensure that all breakers are tested. If a wide variety exists within any manufacturers brand of circuit breakers, it is necessary to divide that manufacturer's breakers Into groups and treat each group as a separate type of breaker for surveillance purposes.

The surveillance requirements of the circuit breakers for non-Class I E cables located in trays which do not have cable tray covers and which provide protection for cables that, If faulted, could cause failure in both adjacent, redundant Class I E cables ensures that the integrity of Class I E cables is not compromised by the failure of protection devices to operate in the non-Class I E cables.

SUMMER - UNIT I B 3/4 8-3 Amendment No. 8, 116, 47- 164