Text

Improved Technical Specifications, Volume 13, Revision 0, ITS Section 3.8, Electrical Power Systems.
	ML051990459
Person / Time
Site:	Monticello
Issue date:	06/29/2005
From:	; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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IMPROVED TECHNICAL SPECIFICATIONS MONTICELLO NUCLEAR GENERATING PLANT I VOLUME 13 ITS Section 3.8, Electrical Power Systems Committed to NudearExceO7

Attachment 1, Volume 13, Rev. 0, Page 1 of 294 ATTACHMENT 1 VOLUME 13 MONTICELLO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 0 Attachment 1, Volume 13, Rev. 0, Page 1 of 294

Attachment 1, Volume 13, Rev. 0, Page 2 of 294 LIST OF ATTACHMENTS

1. ITS 3.8.1

2. ITS 3.8.2

3. ITS 3.8.3

4. ITS 3.8.4

5. ITS 3.8.5

6. ITS 3.8.6

7. ITS 3.8.7

8. ITS 3.8.8

9. Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 13, Rev. 0, Page 2 of 294

, Volume 13, Rev. 0, Page 3 of 294 ATTACHMENT I ITS 3.8.1, AC Sources - Operating , Volume 13, Rev. 0, Page 3 of 294

Attachment 1, Volume 13, Rev. 0, Page 4 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 4 of 294

C C C ITS 3.8.1 ITS 3.0 UMING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.8.1 3.9 AUXILIARY ELECTRICAL SYSTEM 4.9 AUXILIARY ELECTRICAL SYSTEMS ID A) 0 Applies to the aurdlif power system. ApplIes to the periodic testing requirements aewdllery 0 electlucl systemn.I Obiedlve /b/lIe a3 Tosure ar adequate supply of electrical during o~ant operatbon. /Verify the operabilie awdilary electrical system.

0D pedfiato Applicability er s . 0)

LCO 3.8.1 A he reador shall not be made unless all the A. Surveillance testing shall be performed as follows: D aollwing requirements are satisfe:i -U

- 1. Substation Batt fwtchyard LCO 3.8.1.a 1. t least two U21NSI transmIssion lies, associated ;'

I.ea9and at least twoloftsre nosmsiuo a. E 9weekthe gravity and voltag plotcelland perature of adjacent li 0 F

0 overall battevolage shall be ured.

-o t-e ro M

t)

Every three mo'ths the measurem shall be

/made of ot each cel tone 0.01 4P 0la

b. CRlA1sstrEnCfEectica / volt spe@ gravlty oteach cell,n -h to

/tempera breeof every fifth cell./

0 CD

-9 KD Add proposed SR 3.8.1.1 and SR 3.8.1.6 M.2 3.9/4.9 ualifieddircuits between the offsite transmission 199 10/16/87 network and the onsite Amendment No. 51 Class 1 E AC Electrical Power Distribution System Page 1 of 5

ITS 3.8.1 ITS 3.0 LIMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS LCO 3.8.1.b 2. Both diesel enerators are operableia dd able otf Ifew~m ter desianated 44 60 volt busedl.)

3. (a) 4160VBusesa#5and)R8areenergized.

3 . See ITS 3.8.7 CD (b) 480VLoadCenters#103andR104are CD energized.

4. Aiislatlon 24/48, 125, and 250volt baterles areIr Ocharged and In servlee, and associated battery .See ITS 3.8.4, ITS 3.8.6.

0 chargers are operable. an .r 3.8 0>

< adgooed ACTIONS Note E, CD B. When the rnode switch is in Run. the avil-ability otf e electric power shall to as specified In 3 . 9.A.d WexAcetIO LI l eef' ACTION F. sejh2&IWS9.or thie reactor shallbe pla the Iq~n C#)Iv jACTION G - -- od shutdowncondhtion wihlinm ours.(g);1

< ~~~~~~~~~~~1.

Transrmiss nUe OE3 ii 2hnrdl~

O ~~~~~~~~~From daflrtedty~tIemn oe s t aa5bl fromol nliaredroealns _ L.n

~disbholy s dui9 h rce gsyndy _D t nssan adhoaDnh soonr plae tnsercet tD / rvdng bot mrec islgfrrtr r D Cfi CD operable. / /1C O 0 3.9/4.9 200 08/27/02 Arnendrnent No. 6,14. 129 Page 2of 5

C c C 0 ITS 3.8.1 ITS ITS 3.0 UMMNG CONDIONS FOR OPERATION 0C)

ACTION A If offslte power sources are made or found to be

0) inoperable for any reason such that Specification M 0

3.9.A.1 is not met, reactor operation Is pernissibk CD only during the succeeding 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sntess such 3 0 CD a

-L 0 0

ACrTION A -

I a. 1) From and after the date that one of the 0 diesel generators Is made or found to be ID En Inoperable, reactor operation is pemisik!ble only during the succeeding 7 days provided 0 V

t . that the operable diesel generator Is Add demonstrated to be operable within A Sam CD _L (0 I CD (a) Verify de-energization of the 0At CD emergency busses and load shedding CD from the emergency busses.

The oper lirty o he erdiesel (b) Verifying diesel starts from ambient pad eAdd steady state

0) conditionson the auto-start signal and lo M.6 generqjfr need not demonstrated he haandU diesgenerator perability was e to Is ready to accept emergency loads -.1 to

-4 planned pr"ntatlve maint co or within ten seconds, energizes the 0CD

,0ostmn. // emergency busses with permanent CD connected loads nergizes the CD I _LPlboth diesel generators become Add proposed auto-connected emergency loads in ACTION E RequinedAction E.1

[Lnoperable during power operatlo e proper time sequence, and operates reaorssal beplaced intecol for greater than five minutes while is ACTION F _ shutdown condition. adil Sin L.4 generator Is loaded with emergency loads.

tlim36 I ouxrs 3.914.9

>0 201 08/27/02 Amendment No. 25, 51, 77, 129 Page 3 of 5

C C C 0 ITS 3.8.1 ITS 3.0 LIMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

b. For the diesel generators to be considered

0) operable, there shall be a minimum of l 38,300 gallons of diesel fuel (7 days supply 0) 0 for I diesel generator at full load @ 2500 CD KW) In the diesel oil storage tank. 3 CD 0 0

c. When a diesel generator [a required to be operable, maintain air pressure for both 0 associated air starting receivers

! 165 psig.

0

-o 1) With one diesel generator starting air 5 receiver pressure <165 psig, restore both L I.J starting air receivers pressure to co 0

2 165 psig within 7 days. or declare the :0

.P associated diesel generator Inoperable.

2) With both diesel generator starting air Co receivers pressure <165 psig but X 0)

- 125 psig, restore one starting air receiver to 165 psig and enter TS LCO CD to 3.9.9.3.c1, or restore both starting air 0 receivers pressure to 2 165 psig within 0 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If neither action can be accomplished within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , declare the CD CD. associated diesel generator inoperable.

3) With both diesel generator starting air receivers pressure < 125 psig, immediately declare the associated diesel generator Inoperable.

3.914.9 202 08/27/02 Amendment No. ,75-850, 129 Page 4 of 5

( C C 0 ITS 3.8.1 ITS 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for proposed Require'ron A-2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for proposed RequiredAAcinB2L5 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for proposed Require Action CA1 When a system, subsystem, train, component or device Is determined to be Inoperable soley because its emergency power Required Actions source Is Inoperable, or soley because Rs normal power source Is Inoperable. It may be considered operable for the purpose of A.1, B.2, and C.1 satisfying the requirements of Rs applicable Uriiting Condition for Operation provided: (1) Is corresponding normal or S

emergency power source Is operable; and (2) aeof its redundant system(s), subsystem(s), trains(s), component(s) and device(s) are Operable, or likewise satisfy the requirements of this paragraph. _

to 0 0 M. Operating OperatIng meantsthat asystem or componentIs performing Its spe educions.I D 0

OC N. Operating Cycle - Interval between the end of one refueling outage and the end of the next subsequent refueling outage. See ITS Chapter 1.0 0

0. PawerfOperation - Power Operation Is any operation with the mode switch In the Start-Up or Run position with the reactor 2 critical and above 1% rated thermal power.

P. Pr-mary ary Containment Integrity means that the drywell and pressure suppression c-Fauiier are Intact and an of the following conditions are satisfied. o 1; Al manual containment Isolation valves on lines connecting to the reactor coolant system or containment which are not 0

'A required to be open during accident conditions are closed. See ITS Chapter 1.0, E, ITS3.6.1.1, ITS 3.6.1.2, and 0 a 2. At least one door In the airlock Is closed and sealed.

ITS3.6.1.3 0 3. All automatic containment Isolation valves are operable or are deactivated In the closed position or at least one valve In CD each line having an Inoperable valve Is closed

4. All blind flanges and manways are dosed. In 0

D

-o 0. Protective Instrumentation Logic Definitions

1. tm en - An lnstrnment channel means an arrangement of a sensor and auxillary equipment required to CD generate and transmit to a trip system, a single trip signal related to the plant parameter monitored by that Instrument M channel. to CD

(%

2. Udp ystem - A trip system means an arrangement of Instrument channel trip signals and auxiliary equipment required to to Initiate a protection action. A trip system may require one or more Instrument channel trip signals related to one or more See ITS Chapter 1.0 }

plant parameters to Initiate trip system action. Initiation of the protective function may require tripping of a single trip system rDb (e.g., HPCI system Isolation, off-gas system Isolation, reactor building Isolation and standby gas treatment Initiation, and rod CD block), or the coincident trpping of two trip systems (e.g., Inflation of scram, reactor Isolation, and primary containment Isolation).

3. Protective Action - An action initiated by the protection system when a limit is exceeded. A protective action can be at channel or system level.

3 1/23/84 Amendment No. 21 Page 5 of 5

Attachment 1, Volume 13, Rev. 0, Page 10 of 294

- DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etcd.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 The ITS 3.8.1 ACTIONS include a Note that states LCO 3.0.4.b is not applicable to the emergency diesel generators (EDGs). The CTS does not include this Note. This changes the CTS by including the ACTION Note.

The purpose of the ITS 3.8.1 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.8.1 with an inoperable EDG. Currently, CTS 3.9.A precludes making the reactor critical when the EDG is inoperable. ITS LCO 3.0.4 has been added in accordance with the Discussion of Changes for ITS Section 3.0, DOC L.1. Changes to the Applicability are discussed in DOC M.1.

This LCO allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable. ITS LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability of a Specification if a risk assessment is performed, that determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. The addition of this restriction (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable EDG, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because the CTS 3.9.A does not currently allow this option. This change is considered administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.9.B.3.a.1) requires, in part, a manual start of the EDGs while CTS 4.9.B.3.a.2) requires verification of EDG performance when simulating a loss of offsite power in conjunction with an Emergency Core Cooling System (ECCS) actuation test signal. ITS SR 3.8.1.2 also requires the EDGs to be started similar to CTS 4.9.B.3.a.1), however it includes a Note (Note 1) that states all EDG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. ITS SR 3.8.1.12 requires verification of EDG performance during the actual or simulated conditions of a loss of coolant accident (LOCA) and loss of offsite power, however it includes a Note (Note 1) that states all EDG starts may be preceded by an engine prelube period. This changes the CTS by adding Notes allowing a prelube period and a Note allowing a warmup period to the applicable Surveillance Requirements.

The purpose of the CTS Surveillances is to ensure the EDGs can perform their required function. A Note has been added to various Surveillance Requirements to allow EDG starts to be preceded by an engine prelube period to minimize wear and tear on the EDGs during testing. The addition of the Note is considered Monticello Page 1 of 15 Attachment 1, Volume 13, Rev. 0, Page 10 of 294

Attachment 1, Volume 13, Rev. 0, Page 11 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING administrative since the EDGs at Monticello run in a continuous prelube mode of operation. In addition, the Note to ITS SR 3.8.1.2 allows a warmup period prior to loading. The addition of this part of the Note is considered administrative because the EDGs are not required by the CTS to be immediately loaded upon startup. No specific time to perform the loading is specified in CTS 4.9.B.3.a.1),

and normally the EDGs are allowed to warmup for a short time after startup while the operations staff performs post startup EDG checks. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.4 CTS 4.9.B.3.a.1) requires, in part, a manual start of the EDGs. ITS SR 3.8.1.2 also requires the EDGs to be started, however it includes a Note (Note 2) that states the a modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. This changes the CTS by adding the Note to the Surveillance Requirement.

The purpose of CTS 4.9.B.3.a.1), in part, is to ensure each EDG can be started from standby conditions: This change adds a specific Note that states a modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. This change is consistent with current practice and is not precluded by the CTS. The change is acceptable since it is consistent with manufacturers recommendations. This change is designated as administrative because it does not result in a technical change to the CTS.

A.5 CTS 4.9.B.3.a.1) requires, in part, that each EDG be loaded for 2 60 minutes.

ITS SR 3.8.1.3 requires a similar test, however it includes a Note (Note 1) that states the EDG loading may include gradual loading as recommended by the manufacturer, and a Note (Note 4) that states this SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.

This changes the CTS by adding Notes to allow gradual loading and require the EDG loading test to immediately follow the EDG start test.

The purpose of CTS 4.9.B.3.a.1) is to ensure each EDG can operate at approximately rated load. This change adds a specific Note that allows gradual loading of the diesel. This change is consistent with current practice and is not precluded by the CTS. The change is also consistent with manufacturers recommendations. This change is acceptable because Note 1 to SR 3.8.1.3 simply clarifies how the EDG can be loaded prior to entering the load range for the test. CTS 4.9.B.3.a.1) is started from standby conditions and then loaded.

ITS SR 3.8.1.3 Note 4 has been added and states that this SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2. The Note simply reflects current practice and is therefore acceptable. This change is designated as administrative because it does not result in a technical change to the CTS.

A.6 CTS 4.9.B.3.a.2) requires the simulation of a loss of offsite power in conjunction with an ECCS actuation signal test to be performed once each operating cycle.

ITS SR 3.8.1.12 requires a similar test every "24 months." This changes the CTS by changing the Frequency from once per "Operating Cycle" to "24 months."

Monticello Page 2 of 15 Attachment 1, Volume 13, Rev. 0, Page 11 of 294

Attachment 1, Volume 13, Rev. 0, Page 12 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING This change is acceptable because the current "operating cycle" is "24 months."

In letter L-MT-04-036, from Thomas J. Palmisano (NMC) to the USNRC, dated June 30, 2004, NMC has proposed to extend the fuel cycle from 18 months to 24 months and the same time has performed an evaluation in accordance with Generic Letter 91-04 to extend the unit Surveillance Requirements from 18 months to 24 months. CTS 4.9.b.3.a.2) was included in this evaluation. This change is designated as administrative because it does not result in any technical changes to the CTS.

MORE RESTRICTIVE CHANGES MA CTS 3.9.A requires the AC sources to be OPERABLE when the reactor is critical.

ITS LCO 3.8.1 requires the AC sources to be OPERABLE in MODES 1, 2, and 3.

This changes the CTS by requiring the AC sources to be OPERABLE in MODE 3 and in MODE 2 when the reactor is not critical.

The purpose of CTS 3.9.A, in part, is to ensure the AC sources are OPERABLE to mitigate the consequences of a transient or design basis accident. The AC sources are required to be OPERABLE in MODES 1, 2, and 3 when a design basis accident (e.g., loss of coolant accident) may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 the reactor is not critical, however the reactor coolant temperature is always above 2120 F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a design basis loss of coolant accident. Therefore, it is necessary and acceptable to require the AC sources to be OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M.2 ITS SR 3.8.1.1 requires verification that each required offsite source is correctly aligned and indicated power is available every 7 days. ITS SR 3.8.1.4 requires that each day tank and base tank be checked for accumulated water and to remove it every 31 days. ITS SR 3.8.1.6 requires verification of automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit every 24 months on a STAGGERED TEST BASIS for each division. ITS SR 3.8.1.7 requires that the frequency of each EDG does not go above the specified limit during the rejection of the largest post-accident load every 24 months. ITS SR 3.8.1.8 requires the performance of an ECCS initiation signal test every 24 months. ITS SR 3.8.1.9 requires each EDG to be loaded at the specified loads for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months every 24 months. ITS SR 3.8.1.10 requires an EDG hot restart test every 24 months. ITS SR 3.8.1.11 requires verification that each EDG can synchronize with an offsite power source while loaded with emergency loads upon a simulated restoration of offsite power, and return to the ready-to-load operation every 24 months. This changes the CTS by adding these Surveillance Requirements to the Technical Specifications.

The purpose of these additional Surveillance Requirements is to ensure the EDGs and the qualified circuits are OPERABLE. This change is acceptable because it provides additional assurance that the EDGs and the qualified circuits Monticello Page 3 of 15 Attachment 1, Volume 13, Rev. 0, Page 12 of 294

Attachment 1, Volume 13, Rev. 0, Page 13 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING remain OPERABLE to perform their safety function. This change is designated as more restrictive because it adds Surveillance Requirements to the CTS.

M.3 CTS 3.9.B states that under certain conditions (i.e., requirements of CTS 3.9.A and CTS 3.9.1 not met), the reactor shall be placed in the cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Thus, when the restoration times of CTS 3.9.8.2 or CTS 3.9.B.3.a are not met, or for any other combination of AC source inoperabilities other than both EDGs inoperable (i.e., two offsite circuits), the CTS 3.9.B requirement would apply. However, the AC sources are only required to be OPERABLE when critical, as stated in CTS 3.9.A. Thus, the plant is only required to be subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In addition, CTS 3.9.B.3.a.2) states that if both EDGs are inoperable, the reactor shall be placed in the cold shutdown condition. No time is specified to reach the cold shutdown condition. However, as stated above, since the AC Sources are only required to be OPERABLE when critical, the plant is only required to be subcritical. ITS 3.8.1 ACTION F provides the shutdown requirements when any Required Action and associated Completion Time of Condition A, B, C, D, or E is not met, and requires the unit to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS 3.8.1 ACTION G provides the shutdown requirements when three or more required AC sources are inoperable, and requires the unit to enter LCO 3.0.3. ITS LCO 3.0.3 will require the unit to initiate action within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . This changes the CTS by requiring the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown (MODE 4) in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , in lieu of being subcritical for CTS 3.9.B.3.a.2) and in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for CTS 3.9.B, if any Required Action and associated Completion Time of Condition A, B, C, D, or E is not met. In addition, this changes the CTS by requiring the plant to initiate a plant shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in MODE 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , to be in MODE 3 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and to be in MODE 4 in 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months , in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if three or more required AC sources are inoperable.

The purpose of CTS 3.9.8 and CTS 3.9.B.3.a.2) is to place the plant outside the Applicability of the Specification. CTS 3.9.A requires the AC sources to be OPERABLE only when critical (MODE 1 and a portion of MODE 2). Thus, while the CTS 3.9.B and CTS 3.9.B.3.a.2) Actions require a shutdown to MODE 4, in actuality, only a shutdown to subcritical conditions is required. Once subcriticality is achieved, continuation to MODE 4 is not required since the AC sources are not required to be OPERABLE when subcritical. However, since the requirement that the AC sources be OPERABLE in MODE 2 when subcritical and in MODE 3 has been added (DOC M.1), ITS 3.8.1 ACTION F and LCO 3.0.3 (via ITS 3.8.1 ACTION G) include a shutdown to MODE 3 and to MODE 4. The allowed Completion Times are reasonable, based on operating experience, to reach required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This change is acceptable because it requires the unit to be in an intermediate condition (MODE 3) sooner than is currently required (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months versus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or no specified time). This portion of the change reduces the time the unit would be allowed to continue to operate in MODE 1 and MODE 2 while critical once the condition is identified. The consequences of a loss of coolant accident are reduced when the reactor is shutdown and a controlled cooldown is already in progress. This change is Monticello Page 4 of 15 Attachment 1, Volume 13, Rev. 0, Page 13 of 294

Attachment 1, Volume 13, Rev. 0, Page 14 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING designated as more restrictive because less time is allowed to shut down the plant in the ITS than in the CTS.

M.4 CTS 3.9.B.2 allows one offsite circuit to be inoperable for 7 days provided one offsite circuit is OPERABLE, but does not provide any specific requirement to determine how the other offsite circuit is OPERABLE nor how often to perform the determination. CTS 3.9.B.3.a covers the condition for one inoperable EDG but does not provide any requirement to determine whether the offsite circuits are OPERABLE. ITS 3.8.1 Required Action A.1 requires the performance of SR 3.8.1.1 (the offsite circuit verification) for the OPERABLE required offsite circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter when a required offsite circuit is inoperable. ITS 3.8.1 Required Action B.1 also requires the performance of SR 3.8.1.1 for the OPERABLE required offsite circuit(s) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter when an EDG is inoperable. This changes the CTS by adding a specific method and time to perform the offsite circuit verification when an offsite circuit is inoperable and a verification of offsite circuit OPERABILITY when an EDG is inoperable.

The purpose of ITS 3.8.1 Required Actions A.1 and B.1 is to ensure availability and proper circuit continuity of the OPERABLE offsite circuit(s) when the applicable AC source is inoperable. This change is acceptable because it provides additional assurance that the OPERABLE offsite circuit(s) are capable of performing their function. This change is designated as more restrictive because it adds new Required Actions to the CTS.

M.5 CTS 3.9.B.2 allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable required offsite circuit, and CTS 3.9.B.3.a.1) allows 7 days to restore an inoperable EDG. The CTS does not provide a limit on the total time AC sources may be inoperable over a continuous period. ITS 3.8.1 ACTION A covers the condition when one required offsite circuit is inoperable and ITS 3.8.1 ACTION B covers the condition when one EDG is inoperable. The second Completion Time for ITS 3.8.1 Required Actions A.3 and B.4 requires the offsite circuit(s) to be restored to OPERABLE status and the EDG(s) to be restored to OPERABLE status, respectively, within "10 days from discovery of failure to meet LCO." This changes the CTS by limiting the maximum time any combination of required offsite circuit(s) or EDG(s) may be inoperable during any contiguous occurrence of failing to meet the LCO.

The purpose of CTS 3.9.B.2 is to cover inoperabilities associated with an inoperable required offsite circuit while the purpose of CTS 3.9.B.3.a.1) is to cover inoperabilities associated with an inoperable EDG. This change limits the maximum time allowed (10 days) for any combination of inoperable required offsite circuit(s)*or EDG(s) during any contiguous occurrence of failing to meet the LCO. The change is acceptable since the 10 day Completion Time is an appropriate limitation for failure to meet the AC source LCO. This change is designated as more restrictive because it limits the time the AC Source -

Operating ACTIONS can be entered during any contiguous occurrence of failing to meet the LCO.

M.6 CTS 4.9.B.3.a.1), in part, requires a manual start of the EDGs while CTS 4.9.B.3.a.2) requires verification of EDG performance when simulating a loss of offsite power in conjunction with an ECCS actuation test signal. These Monticello Page 5 of 15 Attachment 1, Volume 13, Rev. 0, Page 14 of 294

Attachment 1, Volume 13, Rev. 0, Page 15 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Surveillance Requirements do not specify the steady state voltage and frequency that must be achieved by the EDG. ITS SR 3.8.1.2 and ITS SR 3.8.1.12 require, in part, that each EDG achieve a steady state voltage of 2 3975 V and

4400 V and a frequency of 2 58.8 Hz and

61.2 Hz. This changes the CTS by providing explicit steady state voltage and frequency limits.

The purpose of CTS 4.9.B.3.a.1) and CTS 4.9.B.3.a.2), in part, is to ensure that each EDG can achieve steady state voltage and frequency conditions so that they can supply the emergency loads. This change is acceptable because the added steady state values for voltage and frequency help to ensure the EDGs will be capable of supplying the emergency loads when required. This change is designated as more restrictive because it adds specific limits to the CTS where none previously existed.

M.7 CTS 4.9.B.3.a.1) requires each EDG to be loaded and operated for > 60 minutes.

ITS SR 3.8.1.3 requires a similar test, however a Note has been added that places restrictions on the test. ITS SR 3.8.1.3 Note 3 states that the SR shall be conducted on only one EDG at a time. This changes the CTS by adding a restriction when performing this test.

The purpose of the Note is to preclude testing both EDGs concurrently in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Thus, adding the Note is acceptable since it will preclude this type of common mode failure. In addition, currently CTS 4.9.B.3.a.1) is normally conducted on one EDG at a time. This change isdesignated as more restrictive because explicit restrictions are added to the EDG load test.

M.8 CTS 4.9.B.3.b.2) requires verification that the diesel fuel oil transfer pump and diesel oil service pump are operated. This test verifies the fuel oil transfer system capability to transfer fuel oil from the storage tank to the day tank. The CTS does not specify any requirements to verify the transfer capability of the fuel oil transfer system to transfer fuel oil from each EDG day tank to the associated base tank. ITS SR 3.8.1.5 requires verification that the fuel oil transfer system operates to transfer fuel oil from the storage tank to the day tanks and from each day tank to the associated base tank. This changes the CTS by adding an explicit Surveillance to verify the fuel oil transfer system capability between each EDG day tank to the associated base tank.

The purpose of CTS 4.9.B.3.b.2) is to help ensure that each EDG has the capability to operate continuously for a 7 day period at rated EDG load.

CTS 4.9.B.3.b.2) does not verify the complete capability of the fuel oil transfer system, since it does not cover the transfer capability of the system from each EDG day tank to its associated base tank. This change is acceptable because ITS SR 3.8.1.5 will require the verification of the complete transfer capability of the fuel oil transfer system. This change is designated as more restrictive because an additional portion of the fuel oil transfer system will be required to be tested.

M.9 CTS 3.9.B.1 allows the plant to operate 7 days with one inoperable EDG while CTS 3.9.8.2 allows the unit to operate 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with one required offsite source inoperable. ITS 3.8.1 ACTION D covers the condition of one required offsite Monticello Page 6 of 15 Attachment 1, Volume 13, Rev. 0, Page 15 of 294

Attachment 1, Volume 13, Rev. 0, Page 16 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING circuit and one EDG inoperable and requires the restoration of either the required offsite circuit or the EDG to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In addition, a Note is included that requires entry into the Conditions and Required Actions of LCO 3.8.7, "Distribution Systems - Operating," when Condition D is entered with no AC power source to any division. This changes the CTS by reducing the time the plant can operate with one required offsite source and one EDG inoperable.

The purpose of CTS 3.9.B.1) is to allow the plant to operate 7 days to restore an inoperable EDG while the purpose of CTS 3.9.8.2 Is to allow the plant to operate 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable required offsite source before commencing a reactor shutdown. This change reduces the time to restore the inoperable required offsite circuit or the EDG from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 7 days, respectively to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Experience has shown that the proposed restoration time is appropriate, as long as the associated 4.16 kV essential bus has AC power. This is ensured by the Note to ITS 3.8.1 ACTION D,which requires entry into applicable Conditions and Required Actions of LCO 3.8.7, "Distribution Systems -

Operating," if the 4.16 kV essential bus is de-energized. During the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period, the 4.16 kV essential bus is energized and can perform its design function during a LOCA event, assuming no loss' of offsite power. If the associated 4.16 kV essential bus is de-energized, ITS 3.8.7 ACTION A will require it to be re-energized within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This change is designated as more restrictive because less time is allowed to operate when both a required offsite source and an EDG'is inoperable.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, USAR, ODCM, OQAP, IST Program, or lIP) CTS 3.9.A.1 states, in part, that two NSP transmission lines and associated switchgear must be fully operational.

Furthermore, a parenthetical phrase in CTS 3.9.A.1.c states that one of the sources to the required offsite circuits isthe "source from 10 transformer."

CTS 3.9.8.1 provides actions to be taken when one of the two required NSP transmission lines are found to be inoperable. CTS 4.9.A.1 specifies Surveillances for the substation switchyard battery that provides control power for the NSP transmission line breakers. ITS 3.8.1 does not include any requirements for the NSP transmission lines and associated switchgear and batteries. This changes the CTS by relocating the LCO, Actions, and Surveillance Requirements for the NSP transmission lines and associated switchgear and batteries to the Technical Requirements Manual (TRM).

The removal of this LCO, Action, and Surveillances from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.1 still retains requirements for the OPERABILITY of the two qualified circuits between the offsite transmission Monticello Page 7 of 15 Attachment 1, Volume 13, Rev. 0, Page 16 of 294

Attachment 1, Volume 13, Rev. 0, Page 17 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING network and the onsite Class 1E AC Electrical Power Distribution System. This will ensure adequate offsite power is available to the Class 1E Electrical Power Distribution System. Also, this change is acceptable because the LCO, Action, and Surveillance Requirements will be adequately controlled in the TRM. The TRM is incorporated by reference into the USAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LA.2 (Type 1- Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.A.1 requires two offsite power sources to be fully operational and energized to carry power to the plant 4160 V AC buses and provides details of what constitutes an offsite power source. ITS 3.8.1 requires two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System to be OPERABLE, but the details of what constitutes an OPERABLE qualified circuit is contained in the ITS Bases. This changes the CTS by moving the details of what constitutes an OPERABLE qualified circuit to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.1 still retains the requirement for two qualified circuits to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.3 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.A.2 specifies both diesel generators be operable and "capable of feeding their designated 4160 volt buses." ITS 3.8.1 requires both diesel generators to be OPERABLE, but the details of what constitutes an OPERABLE diesel generator is moved to the ITS Bases. This changes the CTS by moving the details of what constitutes an OPERABLE diesel generator to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.1 still retains the requirement for both diesel generators to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

Monticello Page 8 of 15 Attachment 1, Volume 13, Rev. 0, Page 17 of 294

Attachment 1, Volume 13, Rev. 0, Page 18 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING LA.4 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.9.B.3.b.2) requires the diesel fuel oil transfer pump and diesel oil service pump to be operated. ITS SR 3.8.1.5 requires verification that the fuel oil transfer system operates to transfer fuel oil from the storage tank to the day tanks and from the day tanks to the associated base tanks. The details of what constitutes an OPERABLE diesel fuel oil transfer system is moved to the ITS Bases. This changes the CTS by moving the details of what constitutes an OPERABLE diesel generator to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.8.1.5 still retains the requirement to verify that the fuel oil transfer system operates to transfer fuel oil from the storage tank to the day tanks and from the day tank to the associated base tank.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.9.B requires a plant shutdown when two required offsite circuits are inoperable. ITS 3.8.1 ACTION C covers the condition of two required offsite circuits inoperable and requires the restoration of one required offsite circuit to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , This changes the CTS by providing some time to restore inoperable AC Sources prior to requiring a plant shutdown when two required offsite circuits are inoperable.

The purpose of CTS 3.9.B is to limit the time the unit can remain operating with two inoperable required offsite circuits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore one of two inoperable required offsite circuits to OPERABLE status when both are inoperable. With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits Monticello Page 9 of 15 Attachment 1, Volume 13, Rev. 0, Page 18 of 294

Attachment 1, Volume 13, Rev. 0, Page 19 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.9.B.2 allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable AC source. However, this 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time is only allowed if transformer 1R or 2R is OPERABLE. ITS 3.8.1 ACTION A allows the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time regardless of which transformer is OPERABLE (i.e.,

trandsformer 1AR may be the only OPERABLE transformer). This changes the CTS by allowing a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for an inoperable required offsite circuit regardless of which transformer remains OPERABLE.

The purpose of CTS 3.9.B.2 is to allow a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time for an inoperable offsite circuit as long 1R or 2R transformer is OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for an inoperable offsite circuit regardless of which transformer remains OPERABLE. The offsite circuits that utilize transformers 1R or 2R supply equipment needed for the normal operation of the unit (i.e., the reactor recirculation pumps and feedwater pumps). The offsite circuit that utilizes transformer 1AR does not supply these loads required for normal operation. Therefore, to maintain the plant at power conditions, either 1R or 2R transformers must be OPERABLE and supplying power to the components needed during normal operations. In the CTS and ITS, the qualified circuits must be able to supply the essential buses. It may be possible that the offsite circuit (1R or 2R) has the capability to supply the n6rmal plant loads (i.e., the reactor recirculation pumps and feedwater pumps) and not be able to supply the essential bus. Inthis case, both circuits (i.e., I R and 2R) are inoperable by Technical Specifications since they are not capable of supplying the essential bus. Inthis situation (i.e., 1AR supplying essential buses and either 1R or 2R supplying the non-essential buses), the plant should not be required to be shut down. In other situations, when there is no power available to support the normal plant loads, the plant will either automatically scram or plant procedures will require the plant to be shut down. This change is acceptable because the plant may be able to operate safely with both 1R and 2R inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 4 - Relaxation of Required Action) When an EDG is found to be inoperable, CTS 3.9.B.3.a.1) requires a demonstration that the remaining EDG is OPERABLE within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.9.B.3.a.1) also states that the test is required to be completed regardless of when the inoperable EDG is restored to OPERABILITY. CTS 3.9.B.3.a.1) further states that the OPERABILITY of the other EDG need not be demonstrated if the EDG inoperability was due to Monticello Page 10 of 15 Attachment 1, Volume 13, Rev. 0, Page 19 of 294

Attachment 1, Volume 13, Rev. 0, Page 20 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING preplanned preventative maintenance or testing. ITS 3.8.1 Required Action B.3.2 includes a requirement to perform SR 3.8.1.2, which requires the verification that the EDG starts from standby conditions and achieves steady state voltage and frequency. In addition, ITS 3.8.1 Required Action B.3.1 has been added and provides the option to determine OPERABLE EDG(s) are not inoperable due to a common cause failure. This changes the CTS by providing an allowance to not start an OPERABLE EDG as long as it can be shown that there is no common mode failure for any reason, not just due to preplanned preventative maintenance or testing, and deletes the requirement to perform the OPERABILITY demonstration within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months even if the other EDG is restored to OPERABLE status.

The purpose of CTS 3.9.B.3.a.1) is to demonstrate that the remaining EDG is £ OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

The CTS requires a test of the remaining EDG to demonstrate OPERABILITY when it is determined that an EDG is inoperable. This change adds an option to determine the OPERABLE EDG is not inoperable due to a common cause failure rather than to perform a demonstration of OPERABILITY, even if the inoperability of the EDG is not due to preplanned preventative maintenance or testing. This is acceptable because it avoids unnecessary testing of the EDG while at the same time ensures the EDG is OPERABLE. The change also deletes the requirement to test the EDG within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months regardless of when the inoperable EDG is restored to OPERABILITY. This is acceptable because ITS 3.8.1 Required Actions B.3.1 and B.3.2 Bases states that in the event the inoperable EDG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the plant corrective action program will continue to evaluate the common cause possibility.

However, this continued evaluation is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in ITS 3.8.1 Condition B. This change also deletes the statement that the OPERABILITY of the other EDG need not be demonstrated if the EDG inoperability was due to preplanned preventative maintenance or testing. This statement is no longer necessary because optional allowances in ITS 3.8.1 Required Action B.3.1 will effectively not require the testing to be performed (i.e.,

preplanned preventative maintenance or testing does not constitute a common mode failure mechanism). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 3 - Relaxation of Completion Time) CTS 3.9.B.3.a.2) requires the plant to be placed in cold shutdown when both EDGs are inoperable. ITS 3.8.1 ACTION E covers the condition when two EDGs are inoperable and allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore one EDG to OPERABLE status prior to requiring a plant shutdown per ITS 3.8.1 ACTION F. This changes the CTS by providing 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore one EDG to OPERABLE status when it is discovered that both EDG subsystems are inoperable prior to requiring a unit shutdown.

Monticello Page 11 of 15 Attachment 1, Volume 13, Rev. 0, Page 20 of 294

Attachment 1, Volume 13, Rev. 0, Page 21 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of CTS 3.9.B.3.a.2) is to shut down the unit when both EDGs are inoperable. ITS 3.8.1 ACTION E will now allow 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore one inoperable EDG prior to requiring a plant shutdown. This change is acceptable because the Completion Time is consistent with safe operation under the specified condition, considering the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a design basis accident occurring during the allowed Completion Time. The ITS 3.8.1 Required Action E.1 Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is considered acceptable to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation. According to Regulatory Guide 1.93 (Ref. 6), with both EDGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This change is designated as less restrictive because time is allowed to restore an EDG to OPERABLE status prior to requiring a plant shutdown.

L.5 (Category 3 - Relaxation of Completion Time) CTS 1.0.L allows a system, subsystem, train, component, or device to be considered OPERABLE with an inoperable emergency or normal power source, provided its corresponding normal or emergency power source is OPERABLE and its redundant system(s),

subsystem(s), train(s), component(s), and device(s) are OPERABLE. CTS 1.O.L requires the equipment to be declared inoperable immediately when these requirements are not met. ITS 3.8.1 Required Action A.2 (which applies when one required offsite source is inoperable) requires the declaration of required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable. The Completion Time for ITS 3.8.1 Required Action A.2 is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one division concurrent with inoperability of redundant required feature(s). ITS 3.8.1 Required Action B.2 (which applies when one required EDG is inoperable) requires the declaration of required feature(s), supported by the inoperable EDG, inoperable when the required redundant feature(s) are inoperable. The Completion Time allowed for ITS 3.8.1 Required Action B.2 is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s). ITS 3.8.1 Required Action C.1 (which applies when two required offsite circuits are inoperable) requires the declaration of required feature(s) inoperable when the redundant required feature(s) are inoperable. The Completion Time for ITS 3.8.1 Required Action C.1 is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required feature(s). This changes the CTS by allowing more time to restore inoperable equipment.

The purpose of CTS 1.O.L is to ensure adequate power is available to required equipment so that the equipment can perform its safety function(s) during DBAs and transients. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This change allows more time to restore inoperable equipment when required AC Sources are inoperable concurrent with inoperabilities of redundant required features. By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specifications ACTIONS of the affected supported equipment, unit operation is Monticello Page 12 of 15 Attachment 1, Volume 13, Rev. 0, Page 21 of 294

Attachment 1, Volume 13, Rev. 0, Page 22 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC Sources support the OPERABILITY of the affected equipment, it is appropriate that the proper action, in this condition, would be to declare that affected supported equipment inoperable. CTS 1.0.L is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is sometimes provided, in other CTS sections. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time when one required offsite circuit is inoperable is acceptable because: a) the redundant counterpart to the inoperable required feature is still OPERABLE although single failure protection may have been lost; b) the capacity and capability of the remaining AC Sources is still available; c) a reasonable time for repairs is provided for restoration before the unit is subjected to transients associated with a shutdown; and d) the low probability of a DBA occurring during this period. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time when two required offsite circuits are inoperable is acceptable because Regulatory Guide 1.93 allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable. When a concurrent redundant required function is inoperable, a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time with one required EDG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shutdown. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC Sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status.

L.6 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.B.3.a.1) requires, in part, a verification that each EDG is capable of operating at "approximately rated load" for at least 60 minutes. ITS SR 3.8.1.3 requires the same verification, however the test is allowed to be performed at a load of 2250 kW to 2500 kW, which corresponds to 90% and 100% of rated load.

In addition, Note 2 to SR 3.8.1.3 states that momentary transients outside the load range do not invalidate this test. This changes the CTS by allowing the EDGs to be tested at a slightly lower load during this Surveillance.

The purpose of CTS 4.9.B.3.a.1), in part, is to ensure the EDGs can operate at the rated load. This change allows the EDGs to be tested at a lower load during this Surveillance. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The proposed minimum value is consistent with Regulatory Guide 1.9, Rev. 3 (paragraph C.2.2.2), which recommends a load range of 90% to 100% for the load-run test. The proposed values are 90% to 100% of the continuous load rating and therefore are considered to be consistent with the recommendations of Regulatory Guide 1.9, Rev. 3. The values will preclude routine overloading of the EDG and the lower value will still ensure the EDG is at operating temperatures and that the maximum loads assumed in the safety analyses can be supported.

The addition of the Note is considered administrative because CTS 4.9.B.3.a.1) only requires the load to be "approximately" rated load, not at rated load. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Monticello Page 13 of 15 Attachment 1, Volume 13, Rev. 0, Page 22 of 294

Attachment 1, Volume 13, Rev. 0, Page 23 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L.7 (Category 9 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.9.B.3.a.2) contains a requirement to simulate a loss of offsite power in conjunction with an ECCS actuation test signal "during shutdown." ITS SR 3.8.1.12 requires a similar test, and includes a Note (Note 2) that states the Surveillance shall not normally be performed in MODE 1, 2, or 3.

The Note also states that portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. It further states that credit may be taken for unplanned events that satisfy this SR. This changes the CTS by allowing the Surveillances to be performed in the operating MODES, provided the Surveillance is performed to reestablish OPERABILITY and an assessment is performed to determine plant safety is maintained or enhanced, or provided that it is an unplanned event that satisfies the requirements of the SR.

The purpose of CTS 4.9.B.3.a.2) is to ensure that the EDG operates correctly upon receipt of an actuation signal. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions at all times. The control of the unit conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed during plant conditions other than shutdown.

L.8 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.B.3.a.2) requires verification of EDG performance following a "simulated" loss of offsite power in conjunction with an ECCS actuation "test" signal. ITS SR 3.8.1.12 performs a similar test, but specifies that each signal may be from either an "actual" or "simulated" (i.e., test) signal. This changes the CTS by explicitly allowing the use of an actual signal for the test.

The purpose of CTS 4.9.B.3.a.2) is to ensure that the EDG operates correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.9 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.B.3.b.2) requires the diesel fuel oil transfer system to be tested "during the monthly generator test." ITS SR 3.8.1.5, which requires the same Surveillance to be performed once per 31 days, does not include the requirement that it be performed "during the monthly generator test." This Monticello Page 14 of 15 Attachment 1, Volume 13, Rev. 0, Page 23 of 294

Attachment 1, Volume 13, Rev. 0, Page 24 of 294 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING changes the CTS by deleting the requirement to test the diesel fuel oil transfer system during the monthly generator test, and allowing it to be tested any time during the 31 day period.

The purpose of CTS 4.9.B.3.b.2) is to provide assurance that the diesel fuel oil transfer system is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The test will continue to be performed on a 31 day Frequency (i.e., monthly). The OPERABILITY of the diesel fuel oil transfer system is independent of EDG operation. Although the system will start during the EDG monthly test and it is convenient to perform the test during EDG operation, it is not absolutely necessary. This change is designated as less restrictive because the explicit requirement to perform the test during the monthly generator test has been deleted.

Monticello Page 15 of 15 Attachment 1, Volume 13, Rev. 0, Page 24 of 294

Attachment 1, Volume 13, Rev. 0, Page 25 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 25 of 294

Attachment 1, Volume 13, Rev. 0, Page 26 of 294 AC Sources - Operating 3.8.1 K-) CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.9.A LCO 3.8 .1 The following AC electrical power sources shall be OPERABLE:

3.9.A.1 a. Two qualified circuits between the offsite transmission network and the onsite Class I E AC Electrical Power Distribution Syste 0 3.9A2 b. iesel generators (i 00 e 0k i

c. ee auo- -eu 0 3.9.A APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

-NOTE-DOCA.2 LCO 3.0.4.b is not applicable to DGs. 0 CONDITION REQUIRED ACTION COMPLETION TIME 3.9.B.2, 1.0.L A. One requirecfloffsite circuM inoperable.

A.1 Perform SR 3.8.1.1 for OPERABLEgrequirec offsite circuit.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND

} (0 Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one division the redundant required concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)

AND BWR/4 STS 3.8.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 26 of 294

Attachment 1, Volume 13, Rev. 0, Page 27 of 294 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.9.B.2 A.3 Restoregrequirecd offsite circuit to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 0 status. AND 9dy f~r discovery (

of failure to meet LCO I4.

3.9.B.3.a.1), B. One B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1.O.L inoperable. OPERABLE-equireca offsite circuit(s). AND 0

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s), 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from MTsupported by the inoperable discovery of

'DG, inoperable when the redundant required Condition B concurrent with 0

feature(s) are inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [241 hours

DG(s) are not inoperable Codue to common cause 00 failure.

OR B.3.2 Perform SR 3.8.1.2 for M24]4 hours OPERABLE+DG(s).

AND L9 BWR/4 STS 3.8.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 27 of 294

Attachment 1, Volume 13, Rev. 0, Page 28 of 294 AC Sources - Operating 3.8.1 K-H CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.9.B.3.a.1) B.4 Restore [re red DG to OPERABLE status.

AND Cdays fr~omdiscovery (D of failure to meet LCO 1- t 3.9.B DOC L.1.

C. Two pequirecd offsite circuits inoperable.

C.1 Declare required feature(s) inoperable when the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of 0

1.0.L Condition C redundant required feature(s) are inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one Trequirecj offsite circuit to OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 0D status.

I D. One~requiredEoffsite ---- NOTE--

3.9.B circuit inoperable. Enter applicable Conditions and-o *(

Required Actions of LCO 3.8 AND Hi "Distribution Systems - Operating,"

when Condition D is entered with no OnerdlDG AC power source to any division. 00 inoperable.

D.1 RestorefDequiredc offsite circuit to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 0

status.

OR m D.2 Restorel Ie OPERABLE status.

d]DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (D00 3.9.B.3.a.2) E. Twol [or thre equired] E.1 Restore one rrerDG 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0 0 0 ,DGs inoperable. to OPERABLE status.

0 BWR/4 STS 3.8.1-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 28 of 294

Attachment 1, Volume 13, Rev. 0, Page 29 of 294 1 -

AC Sources - Operating

3.8.1 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 4 4 F. [One [required] ---- REVIEWER'S OTE--

[automatic load / This Condition may deleted if the sequencer] ope be. unit design is such at any sequencer failur ode will only affect the abilit of the associated DG to power. s respective safety loads follo *ng a loss of offsite power in pendent of, or coincident 0

with, a esign Basis Event.

Restore [required] ]hours ]

[automatic load sequencer]

to OPERABLE status.

I 3 . Required Action and Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3.9.B. associated Completion Time of Condition A, B, FCyE9 not met. El 0)

Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 1 1 b Three or more~requirecflj 18.1 Enter LCO 3.0.3. Immediately (DO 3.9.B AC sources inoperable

[for reas a l 00 iCoi ion El.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M2 Verify correct breaker alignment and Indicated 7 days SR 3.8.1.1 power availability for each grequired] offsite circuit. 0 BWR/4 STS 3.8.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 29 of 294

Attachment 1, Volume 13, Rev. 0, Page 30 of 294 AC Sources - Operating 3.8.1 K)J CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.9.B.3.a.1) SR 3.8.1.2 ----- NOTES---

1. All OG starts may be preceded by an engine prelube period and followed by a warmup period 'or to loading.

[2. A modifiSeDG start involving idling and gradual ED ()

acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.Wh,emodified start p cedures are not used, the yre, voltage, and/requency tolerances of SP/3.8.1.7 must be et E Verify eachG starts from standby conditions and 31 days E) achieves steady state voltage 2E3 V and V40 V and frequency 2Žf58.8niHz andd 3 gl65 1 .2FH Z.

(,>4.9.B.3.a.1) SR 3.8.1.3 ---- NOTES-----

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only

_?e+DG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.21or S .8.1. .

Verify eachbG is synchronized and loaded and 31 days (i operates for 2 60 minutes at a load 2t kW andi l~kW.

SR 3.8.1.4 Verify each day tank [and engine mounted ta 31 days contain[s] 2 [900] gal of fuel oil.

BWR/4 STS 3.8.1-5 - Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 30 of 294

Attachment 1, Volume 13, Rev. 0, Page 31 of 294 AC Sources - Operating 3.8.1 k<) CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M.2 SR 3.8.1 Check for and remove accumulated water from each day tJen inp ountedl tanl M31] days 00 fthe 4.9.B.3.b.2), Verify the fuel oil transfer system oper DOC M.8 lfaumicallDtransfer fuel oil fromr1 SR 3.8.1. hrOTP.

All DG starts may be pIeceded by an engine prelube period.

)

Verify each DG start from standby condition and 184 days achieves:

a. In * [12] secon, voltage 2 [3740] V and frequency 2 [58 8] Hz and

b. Steady state v Itage 2 [3740] V and < [4580] V and frequency Ž [58.8] Hz and 1[61.2] Hz. /

DOC M.2 SR 3.8.1 ~~NOTE----

[flThis Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.M WMVerifyfautomaticgancM manuag transfer ofijunit power supplyg from the~normal offsite circuit to the d monthsA on a STAGGERED 0i alternate] offsite circuit. TEST BASIS for 14

_each division BWR/4 STS 3.8.1-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 31 of 294

Attachment 1, Volume 13, Rev. 0, Page 32 of 294 AC Sources - Operating 3.8.1

_ CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M.2 SR 358.1 ------------

KI J TU^

I r- n -- _ _ _ ==

[Wil. This Surveillance shall not normally be performed in MODE 1 or 2. However, this (0 Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite 0

_Rower, it shall be performed at a power factor 1 9I However, if grid conditions do not permit, the power factor limit is not required to 0

be met. Under this condition the power factor shall be maintained as close to the limit as practicable.[lf 0D Verify eachbG rejects a load greater than or equal to its associated single largest post-accident load, months 00 andMa i~Il /ollowinq load rejection, the frequency is 00

b. Within Wseconds folio g load rejection, t volta is 2 [3740] V d * [4580] V, and 0

[c. thin [6] seco sfollowing load rejion, the frequency is 58.8] Hz and S [61] Hz.[]

BWR/4 STS 3.8.1-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 32 of 294

Attachment 1, Volume 13, Rev. 0, Page 33 of 294 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4-I SR 3.8.1.1 0 ---- NOTES

[1. his Surveillance shall not rmrally be performed in MODE 1 or . However, this Surveillance may be perf rmed to reestablish OPERABILITY provide an assessment determines the safety f the plant is maintained or enhanced. Credit pay be taken for unplanned events t it satisfy this SR.

2. If performed with G synchronized with offsite 0

power, it shall bperformed at a power factor

/ [0.9]. Howev r, if grid conditions do not permit, the po er factor limit is not required to be met. Undr this condition the power factor j shall be m jntained as close to the limit as practicabl./

Verify eac DG does not trip and voltage is [18] months

/maintaini [4800] V during and following a Iad rejectio of2 [1710] kW and * [2000] kW.

/ / ,

BWR/4 STS 3.8.1-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 33 of 294

Attachment 1, Volume 13, Rev. 0, Page 34 of 294 AC Sources - Operating 3.8.1 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY qp ?RA1 11 I 1

1. I DG starts may be preced d by an engine relube period.

2. This Surveillance shall not ormally be performed in MODE 1, 2, r 3. However, 111 portions of the Surveillan e may be performed to reestablish OPERABI ITY provided an assessment determines the safety of the plant is maintained or enhan ed. Credit may be taken for unplanned e ents that satisfy this SR.

Verify on an actual or si ulated loss of offsite power [18]

signal:

a. De-energization o emergency buses,

b. Load shedding f m emergency buses, and

c. DG auto-starts rom standby condition and:

1. Energi s permanently connected loads in [1I 1 seconds,

2. Ener izes auto-connected shutdown load through [automatic load sequencer /

3. M ntains steady state voltage

/ 740] V and < [4580] V,

4. aintains steady state frequency

[58.8] Hz and * [61.2] Hz, and

5. Supplies permanently connected a d auto-connected shutdown loads fog

/ [5] minutes. /

BWR/4 STS 3.8.1-9 Rev. 3.0, 03131/04 Attachment 1, Volume 13, Rev. 0, Page 34 of 294

Attachment 1, Volume 13, Rev. 0, Page 35 of 294 AC Sources - Operating 3.8.1 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M2 SR 38 11 19 .MrlTFcS-

1. MAll OG starts may be preceded by an engine 00 prelube period.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, portions I of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Emergenc Core Cooling System (ECCS) initiation signa each DG DE monthsj 0 auto-starts from tandby condition nd:

a. In * [12] s conds after auto- art and during tests, ach ves voltage 2 [37 0] V and I frequenc 2 [58.8] Hz,

b. Achiev steady state volt ge > [3740] V and

[458 V and frequency [58.8] Hz and

[61. Hz,

c. Oper tes for 2 [5] minut s, g Permanently connected loads remain energized from the offsite power systerrm ande e0mergency loads are lenergeed for auto-connected through the au orc oad relays er]m the offsite power system.

BWRI4 STS 3.8.1-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 35 of 294

Attachment 1, Volume 13, Rev. 0, Page 36 of 294 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.13 ------ I -NOTE--- I

[ This urveillance shall not normall be performed in M DE 1, 2, or 3. However, this urveillance may be erformed to reestablish OPE BILITY provided a assessment determines the afetybof the plant is aintained or enhanced. Cre t may be taken for nplanned events that satisfy his SR. ]

Verify each DG's automat' rips are bypassed on [18] mon

.[actual or simulated loss/f voltage signal on the emergency bus concurr nt with an actual or 0 simulated ECCS initia on signal] except:

a. Engine oversp d,

b. Generator di erential current,

[ c. Low lube I pressure,

d. High cr kcase pressure, and

e. Star) ilure relay. ]

BWR/4 STS 3.8.1-11 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 36 of 294

Attachment 1, Volume 13, Rev. 0, Page 37 of 294 AC Sources - Operating 3.8.1 K-) CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M.2 SR 3.8.1.j ----- NOTES-S- 2) k

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

3. If performed withfOG synchronized with offsite . 0 E g g it shall be performed at a power factor EM. However, if grid conditions do not permit, the power factor limit is not required to 0

be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each'DG operates for 2 hours: [ ] months GIXID

a. For 2M4 hours loaded 2 kWkand kWand 0

b. For the remaining hours of the test loaded F25-2 kW and < W 250 0

BWR/4 STS 3.8.1-12 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 37 of 294

Attachment 1, Volume 13, Rev. 0, Page 38 of 294 AC Sources - Operating 3.8.1 K,) CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOCM.2 SR 3.8.1.g ------- NOTES------a

1. This Surveillance shall be perfrme ith 5 minutes of shutting down theDG after thDG has operated 52Mhours loaded and k Momentary transients outside of load range do not invalidate this test.

2. AlrDG starts may be preceded by an engine prelube period.

0 Verify eachIDG starts and achieves: i months 00 seconds, voltage Ž(( M4q V and

a. In4:

frequency Ž058.j H., andi 0

b. Steady state voltage 34 V and *[f4080jV and frequency Ž058.j Hz and *]61.2 Hz. 0 DOC M.2 SR 3.8.1 = -- i-NJ I t -- _____

This Surveillance shall not normally be performed in 0

MODE 1, 2, or 3. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each*DG: FAlmonths 00

a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite powere

b. Transfers loads to offsite power sourcn

c. Returns to ready-to-load operation.

BWR/4 STS 3.8.1-13 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 38 of 294

Attachment 1, Volume 13, Rev. 0, Page 39 of 294 AC Sources - Operating 3.8.1 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY I

QD 'I A 1 17 ___J________NX

/ &I I ITS l

[This S ejillance shall not normally be performed in MO 1, 2, or 3. However, portions of the Surv lance may be performed to reestablish OP BILITY provided an assessment determine th safety of the plant is maintained or enhanced.

edit may be taken for unplanned events that 0 I atisfy this SR.

Verify with a DG operating in test mode and [l 8] months]

connected to its bus, an actual or simulated OCS initiation signal overrides the test mode by

a. Returning DG to ready-to-load oper tion and

[b. Automatically energizing the eme ency load from offsite power. ]

+/-_ _ _ _ _ _ _ _ _ _ _ __I SR 3.8.1.1 8 -- A ------ NOTE------

[ This S rveillance shall not normally be performed in M E 1, 2, or 3. However, this Surveillance may/

be erformed to reestablish OPERABILITY provid assessment determines the safety of the plan s maintained or enhanced. Credit may be taken r unplanned events that satisfy this SR. ]

[Verify interval between each sequence load block [18] months ]

is within i [10% of design interval] [for ach load sequencer timer].

BWR/4 STS 3.8.1-14 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 39 of 294

Attachment 1, Volume 13, Rev. 0, Page 40 of 294 AC Sources - Operating 3.8.1 K>) CTS SURVEILLANCE REQUIREMENTS (continued) __

SURVEILLANCE FREQUENCY 3.9..3.a.2) SR 3.8.1. DJ

1. All DG starts may be preceded by an engine prelube period.

0

2. This Surveillance shall not normally be performed in MODE 1, 2, or 3. However, I portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or months (0 simulated ECCS initiation signal:

a. De-energization of emergency busesz...

b. ,.Load shedding from emergency buses and

c. DG auto-starts from standby condition and: A(D 0

1. Energizes permanently connected loads

2. ner i s asecond-

2. Energizes auto-connected emergency loads through [load %eoe ncer I

3. Achieves steady state voltage 4[74V and :5I[4%80J V& RM . 0 2(

4400

4. Achieves steady state frequency A00(

2Ž158.1 Hz and s161.1H<1-jnd

5. Supplies permanently connected and J

auto-connected emergency loads for 2]5M minutes.

BWR/4 STS 3.8.1-15 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 40 of 294

Attachment 1, Volume 13, Rev. 0, Page 41 of 294 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 -- ---- NOT/-

DG starts may be prece ed by an engine prelube eriod.

Verify, when starte simultanec,usly from standby 10 years condition, [each] A and 2C] D'G achieves:

a. In s (12] conds, voltage'. 2 [3740] V and freque y 2 [58.8] Hz and

b. Ste dy state voltage 2 [37440] V and 4580] V a d frequency 2 [58.8] Hz <and * [61 Hz.

1 BWR/4 STS 3.8.1-16 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 41 of 294

Attachment 1, Volume 13, Rev. 0, Page 42 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

1. The brackets are removed and the proper plant specific information/value is provided.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

3. Changes are made (additions, deletions, and/or changes) to the ISTS, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. The bracketed items specified in ISTS LCO 3.8.1.c and ISTS 3.8.1 ACTION F have been deleted since the Monticello design does not include automatic sequencers.

The LCO has been modified and subsequent Conditions and Required Actions have been renumbered, as applicable.

5. The ISTS 3.8.1 Required Action B.4 first Completion Time of "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " has been extended to "7 days," consistent with the Monticello current licensing basis, which allows 7 days to restore an inoperable EDG (CTS 3.9.B.3.a.1)). Due to this change, the second Completion Time for ITS 3.8.1 Required Actions A.3 and B.4 has been changed to reflect the sum of the Completion Times for an inoperable offsite circuit (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) and emergency diesel generator (7 days) and is consistent with the intent of ISTS.

6. The reference to ISTS LCO 3.8.9 is changed to LCO 3.8.7 as a result of the renumbering of Specifications.

7. The ISTS SR 3.8.1.9.b and c limits imposed on return to steady state frequency and voltage following a single load rejection are to be controlled by plant procedures and are not presented as specific TS requirements in ITS SR 3.8.1.7. The specific criteria referenced would not be appropriate for certain methods of performing this test, e.g., if performed while the EDG was loaded only with the single largest load.

Furthermore, this criteria is not included in the Monticello current licensing basis. In addition, due to this deletion, the load reject maximum frequency requirement has been made part of the first paragraph, instead of leaving it as part a. This change was previously approved in the ITS conversion for the James A. FitzPatrick Nuclear Power Plant.

8. As stated in the ISTS SR 3.8.1.10 Bases, ISTS SR 3.8.1.10 is based upon the recommendations of Regulatory Guide 1.108. Monticello has not committed to fully implement this Regulatory Guide, but has used its guidance where appropriate consistent with the Monticello design and licensing basis, and the recommendations of the EDG manufacturer for testing of the Monticello EDGs. ISTS SR 3.8.1.10 has not been included in the Monticello ITS since it is not consistent with current testing practices for the EDGs and tests a design feature (EDG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits) that is not credited in the Monticello accident analysis. No postulated design basis event results in a full load rejection, and the potential consequences of any postulated single active component failure or single operator failure (such as tripping open the EDG output circuit breaker) that results in full load rejection, are bounded by the potential consequences that would result from an immediate failure of the EDG subsystem itself. Furthermore, if the EDG rejects the full load, operator action would Monticello Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 42 of 294

Attachment 1, Volume 13, Rev. 0, Page 43 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING be required to re-establish these loads, regardless of whether or not the EDG overspeeds. Since the accident analysis assumes no operator actions take place in the first 10 minutes following an accident, verification of this design feature does not materially contribute to the demonstration of EDG OPERABILITY.

9. ISTS SR 3.8.1.13 has not been included in the Monticello ITS since it is not applicable to the Monticello EDG design. The Monticello EDG design does not include emergency diesel generator trips that are bypassed on a loss of voltage signal on the emergency bus concurrent with an ECCS initiation signal. Subsequent Surveillances have been renumbered, as applicable.

10. ISTS SR 3.8.1.14 requires each EDG to operate for 2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS SR 3.8.1.9, which is a new requirement (see DOC M.2), requires each EDG to operate for 2 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months duration for this test is considered sufficient to demonstrate EDG OPERABILITY. This change is based on the requirements of IEEE Standard 387-1995, "IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations." IEEE Standard 387-1995, Section 7.5.9 and Table 3 for the endurance and load test conducted during shutdown/refueling once every two years, state to demonstrate the load carrying capability for an interval of not less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , of which 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months should be at a load equivalent to the short time rating of the diesel generator and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at a load equivalent to the 90%-1 00% of the continuous rating.

11. ISTS SR 3.8.1.17 is not included in the Monticello ITS since this feature was not included in the Monticello design. This SR demonstrates that with an EDG operating in the test mode and connected to its bus, an ECCS initiation signal overrides the test mode and returns the EDG to ready-to-load operation. At Monticello, with an EDG connected to. its bus, if an ECCS initiation signal were received, the EDG would stay connected to its bus. Furthermore, the EDGs do not perform any safety-related function for a LOCA event (e.g., ECCS initiation) since the offsite circuits remain available. Therefore, this SR is not applicable.

12. ISTS SR 3.8.1.18 has not been included in the Monticello ITS since the load timers are verified as part of ISTS SR 3.8.1.12.e (ITS SR 3.8.1.8) and ISTS SR 3.8.1.19.c.2 (ITS SR 3.8.1.12.c.2). Subsequent Surveillances have been renumbered, as applicable.

13. ISTS SR 3.8.1.20 is not included in the Monticello ITS. This SR is intended to periodically verify acceptable electrical and physical -independence of the EDGs and associated electrical distribution systems. Adequate independence (both electrical and physical) of the EDGs and associated electrical distribution systems was a requirement (and has been established in) the original plant design. Furthermore, existing maintenance practices and configuration control practices are judged to be sufficient to ensure continued acceptable separation and independence. Thus, there is no need to periodically perform this SR to demonstrate continued acceptable independence or simultaneous start capability.

14. ISTS SR 3.8.1.8 requires verification of automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit at a Frequency of 18 months. The Frequency of 18 months is bracketed. ITS SR 3.8.1.6 requires a Monticello Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 43 of 294

Attachment 1, Volume 13, Rev. 0, Page 44 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING similar Surveillance, however the Frequency has been changed to 24 months on a STAGGERED TEST BASIS for each division. This Surveillance is not currently required by the CTS, however testing is performed periodically to test these features and all features perform as required. Furthermore, the current Frequency for these tests are no more frequent than every second outage. Thus, the Frequency of 24 months on a STAGGERED BASIS for each division maintains this current Frequency. The proposed Frequency of 24 months on a STAGGERED TEST BASIS for each division is considered to be appropriate based on the reliability of the equipment.

15. ISTS SR 3.8.1.4 requires verification that the fuel oil level in the day tank and engine mounted tank is within a specified limit. This Surveillance has not been adopted in the Monticello ITS. At Monticello, the fuel oil in the day tank and the base tank (i.e.,

the engine mounted tank) is not necessary to meet the 7 day fuel oil requirement.

Only the fuel oil in the common storage tank is used to meet the 7 day fuel oil requirement. This 7 day limit is verified in ISTS SR 3.8.3.1 (ITS SR 3.8.3.1). The fuel oil transfer system includes two pumps that are capable of transferring fuel oil from the common storage tank to each day tank, and two pumps per EDG that are capable of transferring fuel oil from the associated day tank to the associated base tank. ISTS SR 3.8.1.6 (ITS SR 3.8.1.5) verifies that the fuel oil transfer system can operate as designed at the same Frequency as ISTS SR 3.8.1.4. Provided the fuel oil transfer pumps are properly operating, the fuel oil level in each day tank and base tank will be adequately maintained to support EDG OPERABILITY. In addition, an alarm is provided to alert the operator to a problem with the fuel oil transfer pumps associated with the common storage tank. Therefore, ISTS SR 3.8.1.4 is redundant to the fuel oil transfer pumps Surveillance (ISTS SR 3.8.1.6) and is not necessary to be included in the Monticello ITS. This is also consistent with the current licensing basis, since this Surveillance is not included in the CTS. Subsequent Surveillances have been renumbered, as applicable.

16. ISTS SR 3.8.1.7 requires verification each EDG starts from standby conditions and achieves minimum voltage and frequency within the specified time and then achieves steady state frequency and voltage. The Surveillance Frequency is 184 days. This Surveillance has not been adopted in the Monticello ITS and all references to it have been deleted. ISTS 3.8.1.19, the LOOP-LOCA Surveillance (ITS SR 3.8.1.12), verifies each requirement specified in ISTS SR 3.8.1.7 at a 24 month Frequency. Performance of the test provides no additional or unique insights into EDG OPERABILITY other than performing the fast start portion at a more frequent basis. Both EDGs at Monticello have demonstrated excellent performance at the current EDG fast start Frequency (i.e., each refueling cycle) and increasing the test Frequency would pose an unnecessary requirement with limited benefit. The Surveillance test history shows that both EDGs started and accepted loads within the 10 second Surveillance Requirement in the last 5 tests. Finally, performing this test is contrary to the goal of minimizing unnecessary wear and tear that can result from fast starts. This is also consistent with the current licensing basis, since this Surveillance is not included in the CTS. Subsequent Surveillances have been renumbered, as applicable.

17. ISTS SR 3.8.1.11 requires verification of proper performance of the emergency buses and the EDGs on an actual or simulated loss of offsite power (LOOP) signal every 24 months. This Surveillance has not been adopted in the Monticello ITS.

Monticello Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 44 of 294

Attachment 1, Volume 13, Rev. 0, Page 45 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING ISTS SR 3.8.1.19, the LOCA-LOOP Surveillance (ITS SR 3.8.1.12), verifies each aspect of the requirements specified in ISTS SR 3.8.1.11 at a 24 month Frequency.

Thus, there is no need to periodically perform this SR to demonstrate the proper operation of the emergency buses and EDGs on a LOOP signal. This is also consistent with the current licensing basis, since this Surveillance is not included in the CTS. Subsequent Surveillances have been renumbered, as applicable.

18. ISTS SR 3.8.1.12 requires verification that on an actual or simulated Emergency Core Cooling System initiation signal each EDG auto-starts from standby conditions and achieves the specified voltage and frequency at the required time, achieves steady state voltage and frequency, operates for > 5 minutes, permanently connected loads remain energized from the offsite power system, and the I emergency loads are powered from the offsite power system. ITS SR 3.8.1.8 does not include the requirements associated with the EDG, since similar requirements are verified in ISTS SR 3.8.1.19 (ITS SR 3.8.1.12). Thus, these ISTS SR 3.8.1.12 requirements are redundant to the requirement of ISTS SR 3.8.1.19 (ITS SR 3.8.1.12) and are not necessary to be included in ITS SR 3.8.1.8. This is also consistent with the current licensing basis, since this Surveillance is not included in the CTS.

Monticello Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 45 of 294

Attachment 1, Volume 13, Rev. 0, Page 46 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup*

and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 46 of 294

Attachment 1, Volume 13, Rev. 0, Page 47 of 294 AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating IC soucsto te primary station auxiliary (2R), reserve (1R), and reserve auxiliary (1AR) transformers I BASES Jowl

~ArI'~r1~ tkfl1~

~ L' I ~ ~AO~

L~fl* C~~Ief~lf~I fl~IL.L It4,S ~AIrV~t* l;~,'hi~.~~n IJI *~flItlJ*SI /*

o~is of the offsite power sources ('breferrecowTer sources, noriland E-::

I ali _,and the onsite standby powe ore ile mrec 03gneaorPGs3F2fY'-Wad U As reqirdyblpC

, ,.ApprA, GUWF71 (Ref. 1), the desig'nof the AC electrical power USAR, Section 1.2.6 system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

divisions The Class 1 E AC distributior system i divided into redundantF1l Fthree (Divisions 1 h*r , so loss of any one K doe ot prevent the minimum safety functions from being performed. Each loadro has connections too 1pre redl offsite power and a singleiD._[3 Offsite power is supplied to the 230 kVaw 0 V switchyardso the transmissi~zewr by eight transmsinle. From te2,k switchyas tw lcrically and phscly eaaed cir ,;f provide AC power~hog auirv transfo ers 2C and 2 , to 4.k ESF bus 2E, 2F, and 2G A detailed description of the offsite ower network and circuits to the onsite Class 1E F buses is found in t1 Sectiong8.2 (Ref. 2). 416eail 3 ---

Ab offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E E F bus r se NEdRT 4.16 kV esse,,

rtup auxiliary tragsformer (SAT) 2D pr ides the normal source of ver to the ESF uses 2E, 2F, and 2 If any 4.16 kV ESF bus los s ver, an auto atic transfer from S 2D to SAT 2C occurs. At t '5 a, 4.16 kV iuses 2A and 2B an upply breakers from SAT 2 also open, connecting all none ential loads from SAT 2C to reclude 3rloadg of the transformer.

r,2C and 2D are sized o accommodate the simulta eous starting of

.SF loads on receipt an accident signal without e need for load luencing.

BWR/4 STS B 3.8.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 47 of 294

Attachment 1, Volume 13, Rev. 0, Page 48 of 294 B 3.8.1 0 INSERT I Monticello switchyard via two 345 kV and three 115 kV transmission line connections.

From the switchyard, independent and redundant circuits provide AC power to the 4.16 kV auxiliary buses and essential buses. The 4.16 kV essential buses 15 and 16 are capable of being supplied from the 345 kV bus via transformer 2R, from the 115 kV substation via transformer I R, and from either the 345 kV or 115 kV system via transformer 1AR.

0 INSERT 2 Transformer 2R provides the normal source of power to the 4.16 kV auxiliary buses and essential buses 15 and 16. If normal power from transformer 2R is lost, transformer 1R will automatically energize all plant buses, including 4.16 kV essential buses 15 and 16.

If power from transformer 1R is lost, transformer 1AR will automatically energize only the 4.16 kV essential buses 15 and 16.

Insert Page B 3.8.1-1 Attachment 1, Volume 13, Rev. 0, Page 48 of 294

Attachment 1, Volume 13, Rev. 0, Page 49 of 294 AC Sources - Operating B 3.8.1 BASES BA CKGROUND (continued) F 4.16kVessental The onsite standby power source .16 kV riFbuse andz c IsGs. "G and are dedicated to buses[1*-Q9

[

J rsecivl. DG1B s hi rsourcesuppl ei either bs F. SF bus 2F] AG starts automatically on a loss of coolant accident (LOCA) signal (i.e., low rea r er level I t Isinal or hirp ell Qsigal signal) or on ah ESF b earade NSERT voltage oervoltaqq signal. After the*DG has started, it automatically S ties to its respective bus after offsite power is tripped as a consequence

/rm of EtE85Fuln-de-ps6tagelowregraded Poltage, independent of orTLoss &Voltage a4.16 kV Essential j -Jcoincident with aLOCA signal. ThetDGs also start and ope~rate in theR standby mode without tying to theM bus on a LOCA signal alone.

I transfer relays l Following the trip of offsite power? seqancerlstrips nonpermanent 4.16 kVessenllal a loads from th y bus. When the.D is tied to h E bus, loads are then sequentiall connected to its respective bus bylthe a tatic delay relays I ne. The eue o iccontrol thel permi e an starting signals to motor breakers to prevent overloading theDG.

In the event of a loss of re re power, the ESF electrical loads are Jautomaticaliy connected to the*DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a LOCA.

r!9.~nce Certain required plant loads are returned to service in a predetermined in order to prevent overloading of the'DGs in the process.

0 Withinu seconds after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service.

E1-f._-anc istent with Ratings for the*DGs the requirements of Regulatory Guide 1.9 (Ref. 3). DGs 2F and have the following ratings:

a. 11 kW - continuou (4

b. kW - 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months fic. 3250J ~00 hours, I Ej-'¶1Z kW- 30minutes.

DG I Beas the owing ratin

a. /850 kW continuous 3250 - 168 ho s INSERT 3 BWR/4 STS B 3.8.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 49 of 294

Attachment 1, Volume 13, Rev. 0, Page 50 of 294 B 3.8.1 O INSERT2A a Core Spray System Reactor Vessel Water Level - Low low or Drywell Pressure - High

INSERT 21 4.16 kV Essential Bus Loss of Voltage or 4.16 kV Essential Bus Degraded Voltage I.

Q INSERT3 Each EDG has its own day tank and base tank. Both EDGs utilize a common fuel oil storage tank. The fuel oil transfer system, which includes a fuel oil transfer pump and a fuel oil service pump, is capable of transferring fuel oil from the fuel oil storage tank to both day tanks. Both the fuel oil transfer pump and the fuel oil service pump are individually capable of maintaining the level in the day tank when both EDGs are operating at full load. The fuel oil transfer system also includes two day tank fuel oil transfer subsystems. Each day tank fuel oil transfer subsystem is capable of automatically transferring fuel oil from the day tank to the associated base tank. Each day tank fuel oil transfer subsystem includes two pumps, and each pump starts automatically on a level signal from one the base tank level switch. One pump starts when the level in the base tank drops below the normal level and the second pump starts when the base tank level drops to the low level.

Insert Page B 3.8.1-2 Attachment 1, Volume 13, Rev. 0, Page 50 of 294

Attachment 1, Volume 13, Rev. 0, Page 51 of 294 AC Sources - Operating B 3.8.1 BASES 21)

APPLICABLE L The mia conditions of DBA an ransient analyses int [SA 0 SAFETY ANALYSES LW Chapterl(Ref. 4) and Chapterm (Ref. 5), assume ESF systems are OPERABLE. The AC electrical power sources are designed to provide 0

sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, L Power Distribution Limits; Section h and Section 3.6, Containment Systems.

r ys 0D f Emergency Core Cooling System (ECCS) and Reactor Core solation Cooling (RCIC) System The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the onsite or offsite AC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC poweLand (

0

b. A worst case single failure.

4 ,u fCitg AC~dourcessaif Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 LCO fl1Two qualified circuits between the offsite transmission network and the erClasst IE Distribution System andj Cl and separate and independent ensure availability of the required power to shut 0

down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified site circuits are tthat are describeM-the FSAR, and arel IPartoffhe licensing basis-r the unity [In additionieffe required l autog ti load sequencer per us shall OPERABLE. 1 0D Each offsite circuit must be capable of maintaining rated frequency and 4.16 kv essentia volta e and accepting required loads during an accident, while connected to they buses. [Each offsite circuit consists of coming breaker and disconnect to e respective 2C and 2D SA the 2C and 2D transformers, the respective circuit path cluding feeder breakers to 4.16 k SF buses. Feeder breake rom each circuit are required to thFESF bus; however, i CSt scnnected to ESF bus 2E (or ) and 2D SAT is connecte o2G (or 2E), the remaining 0

Ibreak to2E and 2G are not reaui INSERT 3Al>

BWR/4 STS B 3.8.1-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 51 of 294

Attachment 1, Volume 13, Rev. 0, Page 52 of 294 B 3.8.1 Q INSERT3A One offsite circuit consists of incoming disconnects to the 2R transformer, associated 2R transformer, and the respective circuit path including buses and feeder breakers to both 4.16 kV essential buses. The second circuit consists of Incoming disconnects to the 1R transformer, associated 1Rtransformer, and the respective circuit path including buses and feeder breakers to both 4.16 kV essential buses. The third qualified offsite circuit consists of incoming disconnects to the IAR transformer (source from transformer 10),

associated IAR transformer, and the respective circuit path including feeder breakers to both 4.16 kV essential buses.

Insert Page B 3.8.1-3 Attachment 1, Volume 13, Rev. 0, Page 52 of 294

Attachment 1, Volume 13, Rev. 0, Page 53 of 294 AC Sources - Operating B 3.8.1 BASES LCO (continued) E 4 Each OG must be capable of startin accelerating to rated speed and voltage, and connecting to its respectiv e bus on detection qofbs b undervoltage. This sequence must be accomplished within seconds.

Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until m offsite power can be restored to thef buses. These capabilities are required to be met from a variety of initial conditions, such as*DG in standby with the engine hot andcDDG in standby with the engine at ambient condition. AdditionaF'DG capabilities must be demonstrated to meet reject the single largest '_required Surveillances, e.g., capability of the+DG tolrevert to s5Ad`6-ylF-maixctdntaining a s s atus qnan ECCS signal while oeing in parallel test njrer margin to the overspeedm Proper sequencing of loads, including tripping of nonessential loads, is a*

required function foriDG OPERABILITY.

IEThe AC sources must be separate and independent (to the extent possible) of other AC sources. For theiDGs, the separation and independence are complete. For the offsite AC sources, the separation 4.16 kV essential and indeendence are to the extent practical. A circuit may be connected to more than one bus, with stransfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is no connected to a5n bus is required to have OPERABLE ransfer interlock mechanisms to W least tw it; buses to support OPERABILITY of that circuit.t I APPLICABILITY The AC _ encers]are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and Tho

b. Adequate core cooling is provided and containment OPERABILITY and other a functions are maintained in the event of a postulated 0 DBA. I ]

The AC power requirements for MODES 4 and Care covered in LCO 3.8.2, "AC Sources - Shutdown." andotherconditions Ini which AC sources are R TBu1red BWR/4 STS B 3.8.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 53 of 294

Attachment 1, Volume 13, Rev. 0, Page 54 of 294 B 3.8.1 0 INSERT 4 In addition, fuel oil level in the day tank and base tank must be met for each EDG. The portion of the fuel oil transfer system that transfers fuel oil from the fuel oil storage tank to the day tanks must have two OPERABLE pumps for both EDGs to be considered OPERABLE. If either the fuel oil transfer pump or fuel oil service pump is inoperable, one EDG is considered inoperable. For each day tank fuel oil transfer subsystem, only one of the two transfer pumps must be capable of transferring fuel from the day tank to the associated base tank.

Insert Page B 3.8.1-4 Attachment 1, Volume 13, Rev. 0, Page 54 of 294

Attachment 1, Volume 13, Rev. 0, Page 55 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperableiDG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 required To ensure a highIv reliable power source remains with on offsite circuit inoperable, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria (

does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the seconq offsite circuit is inoperable, S

and Condition C, for twc offsite circuits inoperable, is entered.

A.2 Required Action A.2, which only applies if the division cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated'DG does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features associated with a division redundant to the division that has no offsite power.

The Completion Time for Required Action A.2 is intended to allow time for the operator to evaluate and repair any discovered inoperabilities. This Completion Time also allows an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. The division has no offsite power supplying its loadand 0

b. A required feature on the other division is inoperable.

BWR/4 STS B 3.8.1-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 55 of 294

Attachment 1, Volume 13, Rev. 0, Page 56 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) rFequiedI f any time during the existence of thisgondition (one offsite circuit 0,0 inoperable) atrequired feature subsequently becomes inoperable, this Completion Time would begin to be tracked. 0

( 416Vessenfala1~

Discovering no offsite power to oneK416WESF bus of the onsite Class IE Power Distribution System coincident with one or more 0

n support or supported features, or both, that are associated witLbany ethr ESFI bus that has offsite power, results in starting the Completion Timed for the Required Action. Twenty-four hours 00 is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown.

ra g The remaining OPERABLE offsite circuit and DGs are adequate to supply 80 electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 Ac -In Regulatory Guide 1.93 (Ref. 6), operation may continue in A)

Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one rue s offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant cpotenttial fora challenge to the plant safety systems. In this condition, required however, the remaining OPERABL-offsite circuit and'DGs are adequate 0 to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a

[*DG is inoperable, and thafDG is subsequently returned OPERABLE, the (D 7dad 1LCO may already have been not met for up tdVZZhbmd. This situation dacould lead to a total of144our. since initial failure to meet the LCO, to restore the offsite circuit. At this time, a'DG could again become re~r0d SO BWR/4 STS B 3.8.1-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 56 of 294

Attachment 1, Volume 13, Rev. 0, Page 57 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) required offsite e circuit restored OPERABLE, and an additional 72ur (for a total oTdays) allowed prior to complete, restoration of the LCO.

0 10 TheE day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are 0.

entered concurrently. The "AND" connector between the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

As in Required Action A.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition A was entered.

B.1 To ensure a highly reliable power source remains with one DG 0 inoperable, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only I Ispecifies perform," a failure of SR 3.8.1.1 acceptance criteria does not requiredoffsite result in a Required Action being not met. However, if alcircuit fails to 05 I required Ipass SR 3.8.1.1, it is inoperable. Uporoffsite circuit inoperability, additional Conditions must then be entered.

05 B.2 Required Action B.2 is intended to provide assurance that a loss of offsite 3power, during the period that aDG is inoperable, does not result in a complete loss of safety function of critical systems. These features are 0

designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features associated with a division redundant to the division 3 tha hasan inoperable^DG. 0 The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. An inoperable DG exists and

b. A required feature on the other division (Division 1 or 2) is inoperable. 0 BWR/4 STS B 3.8.1-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 57 of 294

Attachment 1, Volume 13, Rev. 0, Page 58 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

If at any time during the existence of this ¢ondition (one DG inoperable), ( i a~v~equired feature subsequently becomes inoperable, this Completion' Time begins to be tracked. ro

_ D one G inoperable coincident with one or more ()(

,_inoperablrequired support or supported features, or both, that are (

associated with the OPERABLE5DGnresults in starting the Completion 000 Time for the Required Action. Four Nholrs from the discovery of trieseEJ events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE DQI an offsite circuits are adequate to (T )

s e I powder tthe onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

B.3.1 and B.3.2 ReauiredlAction 8.3.1 provides an allowance to avoid unnecessary testing ot*OPERABL GD. If it can be determined that the cause of the inoperable*DG does not exist on the OPERABLE*DG, SR 3.8.1.2 doe not have to be erformed. If the cause of inoperability exists orhother

--*DG9,1t eclared inoperable upon discovery, and Condition E of LCO 3.8.1 is entered. Once the failure is repaired, and the commonI itis l 0 cause failure no longer exists, Required Action B.3.1 is satisfied. If the cause of the initial inoperablePDG cannot be confirmed not to exist on the remaining gW, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of hDG.)

In the event the inoperable4DG is restored to OPERABLE status prior to 0 completing either B.3.1 or B.3.2, thezplant corrective action progranrg will 0 continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7),R24j hours is a reasonable 0 L time to confirm that the OPERABLE%~9 G 3not affected by the same problem as the inoperable*DG. is BWRI4 STS B 3.8.1-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 58 of 294

Attachment 1, Volume 13, Rev. 0, Page 59 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.4 According egulatory Guide 1.9fRef. 6), operation ycontinue in I periodthat sho6d not excee In Condition B, the remaining OPERABLE DGS andoffsite circuits are adequate to (i) 1 day upply electrical power to the onsite Class 1E Distribution System. The Completion Time takes into account the capacity and capability of C) the remaining AC sources`reasonable time for repairs, and low E (i probability of a DBA occurring during this period.

The second Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of rquird failing to meet the LCO. If Condition B is entered while, for instance, all]

offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This- situation could lead to a total of4Xu, since initial failure of the'

[ At this time, ampffsite circuit could again [, equired

_become inoperable, theDG restored OPERABLE, and an additional A hours fdays) allowed prior to complete restoration of the LCO Th day Completion Time provides a limit on the time allowed in C) a specified condition after discovery of failure to meet the LCO. This limit 7day1 is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the,'2noun and E<, day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.

Ht [ of Required Action B. h Fsin Required Action B.2, the Completion Time allows for an exception 0 to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time that the LCO was initially not met, instead of the time that Condition B was entered.

C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of f noprability of redundant required features concurrent with inoperability o ffsite circuits. Required Action C.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced BWR14 STS B 3.8.1-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 59 of 294

Attachment 1, Volume 13, Rev. 0, Page 60 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed with one division without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are designed with redundant safety related divisions, (i.e., single division systems are not included in the list). Redundant required features failures consist of any of these features that are inoperable because any inoperability is on a division redundant to a division with inoperable offsite circuits.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable nd

b. A required feature is inoperable.

If at an time during the existence of this Condition (two offsite circuits inoperable), a'required feature subsequently becomes inoperable, this (,)

Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level ai of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable. (i However, two factors tend to decrease the severity of this degradation level:

BWR/4 STS B 3.8.1-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 60 of 294

Attachment 1, Volume 13, Rev. 0, Page 61 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failur ard 0

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Regulatory Guide 1.93 (Ref. 6), with the available offsite AC sources two less than required by the LCO, operation may continue for

.If sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted ffsite source is restored within 0 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition A.

D.1 and D.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition D are 4.16 kVessential modified by a Note to indicate that when Condition D is entered with no _

Ieez AC source to anyT bu; ACTIONS for LCO 3.8, "Distribution i J (Th Systems - Operating," must be immediately entered. This allows l required I Condition Dto provide requirements for the loss of the'offsite circuit and without regard to whether a division is de-energized. LCO 3.8 provides the appropriate restrictions for a de-energized division.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In Condition D, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than BWR/4 STS B 3.8.1-1 1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 61 of 294

Attachment 1, Volume 13, Rev. 0, Page 62 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) that in Condition C (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

I E.1 With two DGs inoperable, there is j remaining standby AC source. (E G2 Thus, with an assumed loss of offs ectrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation. According to - m Regulatory Guide 1.93 (Ref. 6), with bothlDGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

[F.1 The sequencer( is an essential supp system to [both the offsite cui and the DG a ociated with a given F bus.] [Furthermore, the sequencer(s is on the primary sucess path for most major AC electrically owered safety syste s powered from the associat ESF bus.] Th refore, loss of an [ES buss sequencer] affects ev major 0 ESF S tem in the [division, he [12] hour Completion Ti provides a perio of time to correct the roblem commensurate with t'e importance of intaining sequencer gPERABILITY. This time perked also ensures th t the probability of an ccident requiring sequencerpPERABILITY ccurring during perio when the sequencer is ino able is minimal.

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Attachment 1, Volume 13, Rev. 0, Page 63 of 294 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

This Condition is preceded by a Note that lows the Condition to be deleted if the unit esign is such that an sequencer failure mode onl affects the abili of the associated D to power its respective safe loads under iy conditions. Implici n this Note is the concept th the Condition ust be retained if any equencer failure mode resul in the inability start all or part of th afety loads when required rgardless of 0

power vailability, or results ioverloading the offsite pow circuit to a safe bus during an event ereby causing its failure. A o implicit in the N e is that the Conditio is not applicable to any divis n that does not ave a sequencer.

'!.1~ an'd .2 0 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

0 Conditionsa corresponds to a level of degradation in which all redundancy 0 in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS important areas and features, especially those that have a standby I USARChapter8 function, in accordance with 10 CFR5DC 1(Ref. 8). Periodic component tests are supplemented by extensive functional tests during 0

refueling outages (under simulated accident conditions). The SRs for (EDdermonstrating the OPERABILITY of the"DGs ar~lin accefdancelwith the recommendations of Regulatory Guide 1.9 (Re . 3), Regulatory 0

Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10)5 laddresse he FSA .

0D BWR/4 STS B 3.8.1-13 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 63 of 294

Attachment 1, Volume 13, Rev. 0, Page 64 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Where the SRs discussed herein specify voltage and frequency g thefollowing summary is applicable. The minimum steady tolerances, state output voltage o~lam0] V isI90%/ of the nomina 4160 V output \ z

.basd n the voltage. this value, which is specified in ANSI C4 (Ref. I1), allowswsoro voeltage sepitvoltage d fp to the terminals 3f4000 V motors woeminimum onrtinq vol age iSspecified as 90% of 3600 V,/ It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plateE4400 rating. The specified maximum steady state output voltage ofF[4 76]1 is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of theDG (i are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.

SR 3.8.1.21and S".8.1.71 0 Th&A SFRW helg#oesure the availability of the standby electrical power Q supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

as To minimize the wear on moving part hat do not get lubricated when the engine is not running, to SR% h been modified by a Note Note I E

- ,for SR 3.8.1. etd SR 3.8.1. ) to indicate that al ifor or 0}0 SurveillanceN may be preceded by an engine prelube period and followed by a warmup prior to loading.

BWR/4 STS B 3.8.1-14 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 64 of 294

Attachment 1, Volume 13, Rev. 0, Page 65 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) v For the purposes of this testing, the"DGs are started from standby conditions. Standby conditions for d'DG mean that the diesel engine 0

coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.

has r to reduce stress wear on diesel engines,

[3 manfacturereecommen a modified start in which the starting speed of

DGs is limited, warmup is limited to this lower speed, and the'DGs are (1 gradually accelerated to synchronous speed prior to loading. These start 0 procedures are the intent of Note which is only

,/ abten such mod iiesar recoDendedn the manufacture .I3 SR 3.8.1.7 requires <<at, at a 184 day Fre ency, the DG starts from standby conditions nd achieves required oltage and frequency within 12 seconds. The 2 second start requir ment supports the assumpti s in the design ba is LOCA analysis of F AR, Section [6.3] (Ref. 12). he 12 second sta requirement is not ap licable to SR 3.8.1.2 (see N e 2 of SR 3.8.1.2), en a modified start p ocedure as described aboves used.

If a modifie start is not used, the second start requirement of SR 3.8.1.7 pplies. 0 Since 5 3.8.1.7 does require 12 second start, it is more r strictive than SR 3.8 1.2, and it may be pe ormed in lieu of SR 3.8.1.2.

In a dition to the SR requir ments, the time for the DG t reach steady st e operation, unless th modified DG start method is employed, is p riodically monitored a d the trend evaluated to iden ify degradation of overnor and voltage r gulator performance.

The 31 day Frequency for S .8.1. is consistent with Regulatory Guide 1.9 (Ref. 3). IThe 149ay Frequency for 7R 3.8.1.7 is a reductions I Fr uc ngponsisd th Generic Letter 84 15 (Ref. 7). Thgg*-CE

[pnovideadequate assurance of JG OPERABILITY, while (i minimizing degraation resulting from testing-f-0 s sent Regulatory Guide SR 3.8.1.3 nE1 ID 1.9 (Ref. 3), histhe DGs are capable of synchronizing and (13 Surveillance verifies that acceptinggraeA n o-r eqauaFXbo the equivalent -ofthe-maximurIf the to ratin tofthe EDO .

ex ec e accid t loads .A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is

( 0 connected to the offsite source.

BWR/4 STS B 3.8.1-15 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 65 of 294

Attachment 1, Volume 13, Rev. 0, Page 66 of 294 AC Sources - Operating B 3.8.1 BASES SIURIIVFI

__. I ANN=

\ w_.__ CE REQUIRPFMFENTS {continitprul pwrfactor valuel E Although no power factor requirements are established by this SR, the/

- DG is normally operated at a power factor between TQ.8 laggingM and l1. . Thego.value is the design rating of the machine, while 1 is anMl e a ationt ensure circulating currents are minimi l;J e2 load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections accordance with vendor recommendations in order to maintaingG OPERABILITY.

The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3).

Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.

Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test.

Note 3 indicates that this Surveillance should be conducted on only one E~DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.

0D (3

Note 4 stipulates a prerequisite requirement for performance of this SR.

A successful G start must precede this test to credit satisfactory performance.

SR 3.8.1.4 This SR provid s verification that the vel of fuel oil in the day tan and 0D engine moun d tank] is at or above he level at which fuel oil is automaticas added. The level is xpressed as an equivalent v ume in gallons, a d is selected to ensur adequate fuel oil for a mini m of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months o OG operation at full Igd plus 10%.

The ji ay Frequency is a euate to ensure that aufficin supply of feolis available, sic M ee lrsaepovided, td facility o erators would be awF o any large uses of fueloluring this period.

BWR/4 STS B 3.8.1-16 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 66 of 294

Attachment 1, Volume 13, Rev. 0, Page 67 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 0D Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must bas e awaer environment in order to survive. Removal of water from the

'fuel oil dayuandlin ouriTeM tanks once everyM31M days eliminates 0 the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In additionLE eliminates the potential for water entrainment in the fuel oil during DG 0 operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 10). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

q qa .4IRJ4-4-51 0D This Surveillance demonstrates that ich uire fuel oil transfer um eand the fuel oil service pump perateE and transfers fuel oil from assciated storage tank to of k lf.

Ž Ts Surveillance also demonstrates that each day tank UlJsJ I day tank! It is required to support continuous operation fuel oil transfer subsystem can rnstandby Power sources. This Surveillance provides assurance that the transfer fuel oil from Its associated day tank to Its Ifuel oil transfer pum OPERABLE, the fuel oil piping system is intact, associated base tank with one the fuel delivery piping is not obstructed, and the controls and control pump.

systems for automatic fuel transfer systems are OPERABLE. required The Frequency for this SR is variable, depending on individual system consistent with the Frequency for I design, with up to a [92] dginterval. The [92] day Frleqr_,ncy testing the EDGs In SR 3.8.12.,

. J- corresponds to the testi requirements for pumps as cn ained in the ASME Boiler and Pre ure Vessel Code, Section Xl ( ef. 13); however, the design of fuel tr sfer systems is such that pumns operate automratically or rost be started manually in order j6maintain an adequate volu e of fuel oil in the day [and engin mounted] tanks during 0

or following testing. In such a case, a 31 d Frequency is appropriate Since proper operation of fuel tra sfer systems is an inheren art of DG OPERABILITY, the Freq ency of this SR should be modi d to reflect individual designs. ]

5o 3.81/7 i 0

See,/R 3.8/

BWR/4 STS B 3.8.1-17 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 67 of 294

Attachment 1, Volume 13, Rev. 0, Page 68 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Az

ei(Ihe.reitherrtransformerfmRorlAR) 00 or eRansraser of each1k bu power supply from the normal offsite (

rcui to the alternate offsite circu emonstrates the OPERABILITY of 0 a STAGGERED e alternate circuit distribution network to power the shutdown loads.

hon ITEST BASISifor mon n T Frequency of the Surveillance is based on engineering

}

earhdivision j men taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed on thet month 0

(!)

Frequency. Therefore, the Frequency was concluded to be acceptable\

from a reliability standpoint. f on aSTAGGERED TEST BASIS for each division This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

.. 3.SB.C Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might ME result in a trip of the engine. This Surveillance demonstrates theaDG lo-ad response characteristics and capability to reject the largest single load 0 w t cin P m -voltaqe aarn d while E maintaining a specified margin to the overspeed trip. The largest single core I load for eachiDG is r ea al servine pump g,5Ahp). This Surveillance may be accomplished by either: -

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Attachment 1, Volume 13, Rev. 0, Page 69 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

a. Tripping the4DG output breaker with the4DG carrying greater than or (I equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the busorU

b. Tripping its associated single largest post-accident load with the*DG 0 solely supplying the bus. I,7 h l the nominal (synchronous) speed plus consistent with Regulatory Guide 1.9 t E ED l (Ref. Mb, the load ejection test is acceptable if noia the diesel speed does not exceed 75% of the difference nominalnbetween L np- speed and the overspeed trip setpoint, or b=v r speed, whichever is lower. For Gs a 67.5 lthis represent 6 Hz, equivalent to 75% of the difference between noiap ped and the overspeed trip setpoint.

The time, voltage, an frequency toleran s specified in this S are derived from Regul tory Guide 1.9 (Ref 3) recommendations or response during lo d sequence interv s. The [6] seconds s ecified is equal to 60% oft e 10 second load quence interval asso iated with sequencing thefesidual heat remov I (RHR) pumps durinanI undervoltage n the bus concurre with a LOCA. The vo age and frequency s cified are consiste with the design rangef the equipment powered b te DG. SR 3.8.1. ~a corresponds to the mxmu frequenc/excursion, while S 3.8.1.9.b and SR 3.8.1. .c are steady state voltage and frequenc alues to which the sVste must recover follow~ingload reiection} The&montilglFrequency isLcongi-stenrwite s

based on engineering judgment, lr~edbnGie1 taking into consideration plant _J1 c onditions required to perform the _

Surveillance and Is Intended to be This SR is modified by two Notes. The reason4iforNTfe1 is that, during lengths. Operating expenence operation with the reactor critical, performance of this SR could cause has shown thatthese components perturbations to the electrical distribution systems that could challenge usually pass the SR when performed at the 24 month continued steady state operation and, as a result, plant safety systems.

Frequency. Therefore. the Frequencyls acceptable from This restriction from normally performing the Surveillance in MODE 1 or 2 rliability standpoint. is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the BWR/4 STS B 3.8.1-19 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 69 of 294

Attachment 1, Volume 13, Rev. 0, Page 70 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE I or 2. Risk insights or deterministic methods may be used for this assessment.

,,-Credit mbe aken for unplanned events that satisfy this SR. Note 2 ensures that the*DG is tested under load conditions that are as close to (i design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of Sff This (E power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor Ef~ oother thn' i9. These conditions occur when grid voltage is high, and Ad the additional field excitation needed to get the power factor to s E{ .:

busses that are too high. Under (

. these conditions, the power factor should be maintained as close as prh ssettie while still maintaining acceptable voltage limits on the @

FV G Wbusses. In other circumstances, the grid voltage mabe such ()

~tatntcas excitation levels needed to obtain a power factor of [may12 cause unacceptable voltages oni but tuss I se~lrAdnot excitation levels are in excess of those recommended for thel)DG. In 0 cases, the power factor shall be maintained as close as practicable to without exceedingp DG excitation limits. (D 1

-REVIEWER'S N E------/

The above MODE strictions may be del ed if it can be demonstrated t the staff, on a pla t specific basis, that p orming the SR with the reac r in any of the res icted MODES can sat' fy the following criteria, as applicable:

a. Perfo nce of the SR will not ender any safety system or comp nent inoperable,

b. Perormance of the SR wil not cause perturbations to any of the eMctrical distribution systms that could result in a chal nge to eady state operation to plant safety systems, and

c. Performance of the , or failure of the SR, will no cause, or result in, an AOO with aft ndant challenge to plant safe systems.

BWR/4 STS B 3.8.1-20 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 70 of 294

Attachment 1, Volume 13, Rev. 0, Page 71 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.10 This Surveillance de onstrates the DG cap bility to reject a full load without overspeed t pping or exceeding th predetermined voltage limits.

The DG full load rej ction may occur beca se of a system fault or inadvertent breake tripping. This Surveill nce ensures proper engine generator load res onse under the simul ed test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifie that the DG does not trip upo loss of the load. hese acceptance crit ria provide DG damage protection. Whil the DG is not expected to experience this transient /

during an event and continues to be a ailable, this response ensure that the DG is not d graded for future appl cation, including reconnection to the bus if the t ip initiator can be corr cted or isolated.

The [18 mont ] Frequency is consis nt with the recommendation f Regulatory uide 1.108 (Ref. 9) an is intended to be consistent ith expected fu I cycle lengths.

This SR is odified by two Notes. The reason for Note 1 is that uring operation ith the reactor critical, erformance of this SR could use perturbati ns to the electrical dis ibution systems that would ch Ilenge continue steady state operatio and,-as a result, plant safety ystems.

This restriction from normally p orming the Surveillance in M DE 1 or 2 is further amplified to allow the urveillance to be performed f r the purpos of reestablishing OPE ABILITY (e.g., post work test ng following correcti e maintenance, corre tive modification, deficient or i complete surveil ance testing, and othe unanticipated OPERABILITY oncerns) providpd an assessment det rmines plant safety is maintai ed or enhadced. This assessmen shall, as a minimum, conside the potential outc mes and transients as ociated with a failed Surveilla ce, a suc ssful Surveillance, an a perturbation of the offsite o onsite system wh they are tied togethe or operated independently fo the Su /eillance; as well as th operator procedures availabl to cope with th se outcomes. These s all be measured against the voided risk of a plnt shutdown and start0p to determine that plant safe is maintained or e hanced when the Su illance is performed in MOD 1 or 2. Risk sights or deterministic ethods may be used for this ssessment.

redit may be taken for unplanned events that satisfy his SR. Note 2 nsures that the DG is ested under load conditions t at are as close to design basis condition as possible. When synchron ed with offsite BWR/4 STS B 3.8.1-21 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 71 of 294

Attachment 1, Volume 13, Rev. 0, Page 72 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) power, testing shoy/d be performed at a p er factor of s [0.9]. This power factor is re resentative of the actu I inductive loading a DG wou see under desi basis accident conditi ns. Under certain conditions however, Note allows the surveillane to be conducted at a power actor other than < .9]. These conditions ccur when grid voltage is hig -and the additioI field excitation need to get the power factor to s .9]

results in oltages on the emerge cy busses that are too high. nder 0 these co ditions, the power fac r should be maintained as cl e as practi le to [0.9] while still intaining acceptable voltage *mits on the emer ency busses. In other ircumstances, the grid voltag may be such that e DG excitation level needed to obtain a power fa or of [0.9] may no cause unacceptable v Itages on the emergency bus es, but the citation levels are in e cess of those recommended r the DG. In such ses, the power facto shall be maintained as close s practicable to

[0.9] without exceedi the DG excitation limits.

REVIEWER'S N E---------------

The above MODE strictions may be del ed if it can be demonstrated t the staff, on a pla t specific basis, that p rforming the SR with the reac r in any of the res icted MODES can sat' fy the following criteria, as applicable: 0

a. Perfor ance of the SR will no ender any safety system or/

component inoperable,

b. Pe ormance of the SR wil not cause perturbations to an of the e ctrical distribution systms that could result in a chal nge to teady state operation to plant safety systems, and c.Performance of the , or failure of the SR, will no cause, or result in, an AOO with att ndant challenge to plant safe systems.

SR 3.8.1.11 As required by egulatory Guide 1.10 (Ref. 9), paragraph 2.a.(1), t s Surveillance emonstrates the as d igned operation of the stand

.0 power so ces during loss of the site source. This test verifie all actions countered from the Ins of offsite power, including s edding of the n essential loads and eprgization of the emergency b ses and respctive loads from the Doe. It further demonstrates the pability of th DG to automatically ieve the required voltage a frequency within e specified time. /

BWR/4 STS B 3.8.1-22 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 72 of 294

Attachment 1, Volume 13, Rev. 0, Page 73 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The DG auto-start (me of 12 seconds is deived from requirements of the accident analysis fsbr responding to a design basis large break LOCA.

The Surveillance hould be continued for minimum of 5 minutes in ord r to demonstrate that all starting transients ave decayed and stability ha been achieved. /

The requireme to verify the connectio and power supply of perman nt and auto-conn cted loads is intended t satisfactorily show the relationship of hese loads to the DG I ading logic. In certain circumstance , many of these loads nnot actually be connected or loaded witho t undue hardship or potential for undesired operation. or instance, E rgency Core, Cooling stems (ECCS) injection valve are not desired be stroked open, or s stems are not capable of bein(

operated at ull flow, or RHR systes performing a decay heat reoval function ar not desired to be reali ned to the ECCS mode of ope ation.

In lieu of a tual demonstration of t e connection and loading of th se loads, tes ng that adequately sho s the capability of the DG sys em to perform t ese functions is accept ble. This testing may include ny series of Sequential, overlapping or total steps so that the entir connecti'n and loading sequen is verified. o The Fr quency of [18 months]i consistent with the recomme dations of Regul ory Guide 1.108 (Ref. ), paragraph 2.a.(1), takes int consi eration plant conditions required to perform the Surveil ance, and is inten ed to be consistent wit expected fuel cycle lengths.

This R is modified by two otes. The reason for Note 1 is to minimize we and tear on the DGs d ring testing. For the purpose f this testing, the Gs shall be started fr standby conditions, that is, ith the engine co lant and oil being conti uously circulated and tempera ure maintained co sistent with manufacturer recommendations. The reason for Note 2 is t t performing the Surve lance would remove a require offsite circuit f m service, perturb the lectrical distribution system, a d challenge afety systems. This re riction from normally performig the urveillance in MODE /or 2 is further amplified to allo portions of the Surveillance to beperfrmed for the purpose of reest lishing OPERABILITY (e.g., p st work testing following corre tive maintenance, corrective modificatio , deficient or incomplete survei ance testing, and other unanticipated 0 ERABILITY concerns) provid d an assessment determines plant safdty is maintained or enhanced. his assessment shall, as a minimum, consider the potential outcomrs and transients BWR/4 STS B 3.8.1-23 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 73 of 294

Attachment 1, Volume 13, Rev. 0, Page 74 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) associated with a iled partial Surveillan, a successful partial Surveillance, a a perturbation of the site or onsite system when tey are tied togeter or operated indepe ently for the partial Surveillace; as well as the perator procedures a ilable to cope with these out mes.

These s IIbe measured again the avoided risk of a plant s tdown and st up to determine that ant safety is maintained or e anced wh portions of the Surve ance are performed in MOD or 2. Risk 1 f igrghts or deterministic ethods may be used for this sessment.

Credit may be taken f unplanned events that satis his SR.

Consistent with Regulatory Guide 1.9 (Ref. 3) paragraph c.2.2.5, his Surveillance demonstrates thatdthe DG automati Ily starts and achieves the required oltage and frequency within Ie specified time

([12] seconds) frorq e design basis actuation sigol (LOCA signal) and operates for 2 [5minutes. The [5] minute period rovides sufficient time to demonstrat stability. SR 3.8.1.12.d and SR $.8.1.12.e ensure that

'remain energized permanently connected loads and emergency loads ar en ize from (i) (7 from the offste e offsite electrical power system on a LOCA signal without loss of offsite upower. uto-connected through Lthe time delay relays The requirement to verify the connection and power supply of permanent and7autconnected loads is intended to satisfactorily show the (

relationship of these loads to the loading logic for loading onto offsite power. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of the connection and loading of these (

loads, testing that adequately shows the capability of the#DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of M months am e into consideration plant conditions ( ) 0 required to perform the Surveillance and is intended to be consistent with ray the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at th" monttf i Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

BWR/4 STS B 3.8.1-24 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 74 of 294

Attachment 1, Volume 13, Rev. 0, Page 75 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by two Notes. The reason for Note 1 is to minimize ear and tear on the^DGs during testing. For the purpose of this testing, (i)

J.nst be started from standby conditions, that is, with the engine

'coolant andoil being continuously circulated and temperature maintained Q consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could potentially cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or

2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.[JE 0 SR 3.8.1.13 This Surveilla e demonstrates that non-critical protective funct' s (e.g., high j ket water temperatur are bypassed on an ECCS i 'iation test signa.The non-critical trips re bypassed during DBAs an provide an alar on an abnormal engi condition. This alarm provid the oper r with sufficient time t react appropriately. The DG vailability to mitigate the DBA is more cwiical than protecting the engi against minor p blems that are not im ediately detrimental to emer ncy operation of BR4e DG. / /

BWRI4 STS B 3.8.1 -25 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 75 of 294

Attachment 1, Volume 13, Rev. 0, Page 76 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The [18 month] Freq ency is based on engi eering judgment, takes into consideration plant onditions required to p rform the Surveillance, and I intended to be con istent with expected fu I cycle lengths. Operating experience has s wn that these compo nts usually pass the SR whe performed at the 18 month] Frequency. herefore, the Frequency wa concluded to be cceptable from a relia ility standpoint.

The SR is mo fled by a Note. The re son for the Note is that perfo ing the Surveillan e would remove a req ired DG from service. This restriction fr normally performing he Surveillance in MODE 1 o 2 is further amp led to allow the Surve lance to be performed for the urpose of reestabli hing OPERABILITY ( .g., post work testing followin corrective aintenance, correctiv modification, deficient or inc mplete surveilla e testing, and other u anticipated OPERABILITY co cerns) 0 provide fan assessment dete ines plant safety is maintaine or enhanc d. This assessment s all, as a minimum, consider the potential outco es and transients ass iated with a failed Surveillan , a succ sful Surveillance, and perturbation of the offsite or nsite system whe they are tied together r operated independently for e SuOeillance; as well as th operator procedures availabi to cope with the e outcomes. These s all be measured against the oided risk of a p1 nt shutdown and start p to determine that plant safe is maintained or ehanced when the Su eillance is performed in MOD 1 or 2. Risk sights or deterministi methods may be used for thi assessment.

Credit may be taken f unplanned events that satis this SR.

- -REVIEWER'S NO E-- - -

The above MODE r strictions may be dele d if it can be demonstrated to the staff, on a plarr specific basis, that pe orming the SR with the react in any of the rest cted MODES can sati the following criteria, as applicable:

a. Perform nce of the SR will not r nder any safety system or compo ent inoperable,

b. Perf rmance of the SR will t cause perturbations to any f the ele rical distribution syste s that could result in a challe ge to

.0 St ady state operation or o plant safety systems, and

c. erformance of the S ,or failure of the SR, will not use, or result in, an AOO with atten ant challenge to plant safety stems.

BWR/4 STS B 3.8.1-26 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 76 of 294

-1 Attachment 1, Volume 13, Rev. 0, Page 77 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[Th'isuSureilance SR 3.8.1.w 0 (90%tofO othe EDG Regulatory ide 1.108 (Ref. 9), p*graph 2.a.(3). re quires l E-1 Icontnuous rating) l demonstr ion once per F18 months] that thei Gs can start and rung...j8T'-

90% to 1i5Fh or 1 continuously atful load capabilittifor an interval of not less than Rhours R hours of which is at a load equivalent to the continuous rating of the r aDG, and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of which is at a load equivalent to0i10% of the ELI andthe load ranges and G. t Hatch has tak on t duration are consiste3 9 tis r Irement an rms the 2 hou e000 hour rating

,,Ref. 13). 1(-°k)i e&DG starts for this Surveillance can be performed either insanb or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in Laccordance with vendor recommendations in order to maintainrDG OPERABILITY.OPERAILITY on engineening judgment, taking ba~sed J o lRegulatory montlhmo G

Frequency is onsistent

$ S aarp .. 3); takesit ti o 00, consideration plant conditions required to perform the Surveillance@ and is Operating experience h.a shown that these Intended to be consistent with expected fuel cycle lengths..

components usually pas si the SR when performed the 24 month Frequency it This Surveillance has been modified by three Notes. Note 1 states that Therefore. the Frequenc vy momentary transients due to changing bus loads do not invalidate this Is acceptable from a reliability standpoint. test. Similarly, momentary power factor transients above the limit do not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that would challenge continued steady state operation and, as a result, plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the BWR/4 STS B 3.8.1-27 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 77 of 294

Attachment 1, Volume 13, Rev. 0, Page 78 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

rj .. Credit mav be taken for unplanned events that satisfy this SR. Note 3 ensures that thetG is tested under load conditions that are as close to ()

design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of .9. This Em power factor is representative of the actual inductive loading aiDG would (0

see under design basis accident conditions. Under certain conditions, 0.95 however Note 3 allows the surveillance to be conducted at a power factor oh tThese conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to *-

results in voltages on thelemerencmA busses that are too high. Under these conditions, the power factor should be maintained as close as while still maintaining acceptable voltage limits on the

busses. In other circumstances, the grid voltage ma be such(.

essential D at thOG excitation levels needed to obtain a power factor of may not cause unacceptable voltages on thelemerrency busses, but the .

r, excitation levels are in excess of those recommended for thrDG. In such (

cases, the power factor shall be maintained as close as practicable to 0.9*Mwithout exceeding IEDG excitation limits. ( i SR 3.8. 1.0 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances. and achieve the required voltage and frequency within

.M second~s. TMe USsecond time is derived from the requirements of(

accdent analysis to respond to a design basis large break LOCA.

Thef1mont Frequency is consisten mt ecodm-eontofnI as(edon engineering judgment, G uigs,pDaragraph 2.a.(5) qujieulatorY UJ taklr ig into consideration plant p conclitons required to perform the SurNveillance, and Is Intended to be This SR is modified by two Notes. Note I ensures that the test is corm.

cycle3lengths. Operating performed with the diesel sufficiently hot. The requirement that the diesel exp( paience corn Eponentshas shownattheses has operated for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months atfull load conditions prior to,(

usually pass the SR ..

whe nperformed at the 24 month performance of this Surveillance is based on manufacturer I approximately Frec Buency T the Therefore, Frecpuency Is acceptable fo Dbilitystandpoint.

BWR/4 STS B 3.8.1-28 Rev. 3.0, 03131/04 Attachment 1, Volume 13, Rev. 0, Page 78 of 294

Attachment 1, Volume 13, Rev. 0, Page 79 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) recommendations for achieving hot conditions. The load band is provided l to avoid routine overloading of theiDG. Routine overloads may result in frequent teardown inspections in accordance with vendor imore 0

e mmendations in order to maintain4DG OPERABILITY. Momentary transients due to changing bus loads do not invalidate this test. Note 2 0

allows all'DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

0 SR 3.8.1.M 0 l Consists.7 3hJ _1 A.1 Em Is refged bWA Regulatory Guidet1. (Ref.@, paragraph 1 , this Surveillance ensures that the manual synchronization and Eatnai load

/ transfer from the'*DG to the offsite source can be made and that the+DG can be returned to ready-to-load status when offsite power is restored. It E also ensures that the auto-start logic is reset to allow thDG to reload if a 0 subsequent loss of offsite power occurs. ThebDGis considered to be in ready-to-load status when thevDG Is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus sscated undervoltage, and thelload se1ience timoa3rereset. ee

[ idvdual

, and Is Intended to be consistent The Frequencyrofa

,tRegulatory P~uide 1.1 R monthQis requsistento 8e f. )

vith the recommendationsofI and takes into

,prgah2.(6),

0D0 with the expected fuel cycle lengths. Operating experience h cosdrto plni cnitose euie to perform the Surveillancg 0D J

shown that these components usually pass the SR when This SR is modified by a Note. The reason for the Note is that performing performed at the 24 month Frequency. Therefore. the the Surveillance would remove a required offsite circuit from service, I3 Frequency Is acceptable from a perturb the electrical distribution system, and challenge safety systems.

reliability standpoint.

This restriction from normally performing the Surveillance in MODE 1A3 2 is further amplified to allow the Surveillance to be performed for the T.4j

©5 purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained r enhanced when the Surveillance is performed in MODE R221isk or3 1 insights or deterministic methods may be used for this aessmentsU Credit may be taken for unplanned events that satisfy this SR.

BWR/4 STS B 3.8.1-29 Rev. 3.0, 03/31104 Attachment 1, Volume 13, Rev. 0, Page 79 of 294

Attachment 1, Volume 13, Rev. 0, Page 80 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.17 Demonstration of th test mode override e ures that the DG availability under accident con itions is not compromi ed as the result of testing.

Interlocks to the L CA sensing circuits ca se the DG to automatically reset to ready-to-I ad operation if an EC initiation signal is received during operation i the test mode. Read -to-load operation is defined a the DG running rated speed and volta e with the DG output breaker open. These pr visions for automatic s itchover are required by IEEE-308 (Ref./4), paragraph 6.2.6(2)

The requireme t to automatically ener ize the emergency loads with offsite power i essentially identical to that of SR 3.8.1.12. The inte in the requirem nts associated with SR .8.1.17.b is to show that the emergency I ading is not affected b the DG operation in test mod . In lieu of actua demonstration of conn ction and loading of loads, te, ing that adequ ely shows the capabili of the emergency loads to peform these functons is acceptable. This testing may include any serie of sequential/overlapping, or total st so that the entire connecti n and loading s uence is verified.

The [18 onth] Frequency is co sistent with the recommendati ns of 0 Regulat ry Guide 1.108 (Ref. 9 , paragraph 2.a.(8); takes into conside ation plant conditions required to perform the Surveill nce; and is intend to be consistent with xpected fuel cycle lengths.

This is modified by a Not . The reason for the Note is t t performing the S rveillance would remo e a required offsite circuit fro service, pert b the electrical distribu ion system, and challenge saf ty systems.

This/restriction from normall performing the Surveillance i MODE 1 or 2 is f her amplified to allow ortions of the Surveillance to e performed for he purpose of reestabli hing OPERABILITY (e.g., po work testing fol wing corrective maint nance, corrective modification deficient or in omplete surveillance t sting, and other unanticipated PERABILITY cc ncerns) provided an a sessment determines plant safety is maintained enhanced. This asse sment shall, as a minimum, c nsider the otential outcomes and ransients associated with a faj d partial urveillance, a succesful partial Surveillance, and a erturbation of the offsite or onsite systerwhen they are tied together o operated independently for the Partial Surveillance; as well as he operator BWR/4 STS B 3.8.1-30 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 80 of 294

Attachment 1, Volume 13, Rev. 0, Page 81 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) procedures avail to cope with these tcomes. These shall be measured a st the avoided risk o plant shutdown and startup determine at plant safety is ma ained or enhanced when po *ons of 0 the SuKeillance are perform in MODE I or 2. Risk insig or de ministic methods ma e used for the assessment redit may be ken for unplanned e nts that satisfy this SR.

SR 3.8.1.18 Under accident con itions [and loss of offs'e power] loads are sequentially conne ted to the bus by the tomatic load sequencer. Th sequencing logic ntrols the permissive nd starting signals to motor breakers to preve t overloading of the D s due to high motor starting currents. The [I]% load sequence time interval tolerance ensures th t sufficient time e ists for the DG to resto/e frequency and voltage prior/o applying the ne:t load and that safety Analysis assumptions regardin ESF equipmenytime delays are not vi lated. Reference 2 provides summary of th automatic loading of SF buses.

The Frequen y of [18 months] is co istent with the recommendat ns of Regulatory uide 1.108 (Ref. 9), pa agraph 2.a.(2); takes into consideratio plant conditions requi ed to perform the Surveillanc and is 0 intended to e consistent with exp cted fuel cycle lengths.

This SR is/modified by a Note. T e reason for the Note is that erforming the Surve Ilance would remove a required offsite circuit from s ice, perturb t e electrical distribution system, and challenge safety ystems.

This res ction from normally p rforming the Surveillance in ODE 1 or 2 is furth amplified to allow the urveillance to be performed or the purpos of reestablishing OP RABILITY (e.g., post work te ing following correcive maintenance, corrltive modification, deficient or/incomplete surve' lance testing, and othqr unanticipated OPERABILI concerns) provi ed an assessment dee rmines plant safety is maintarned or enh nced. This assessme. t shall, as a minimum, considdr the potential outq mes and transients associated with a failed Surveillance, a suoessful Surveillance, a d a perturbation of the offsite r onsite system wl n they are tied togeth r or operated independently f r the S rveillance; as well as te operator procedures availa le to cope with t ese outcomes. These hall be measured against th avoided risk of a ant shutdown and sta up to determine that plant saf ty is maintained or nhanced when the Su eillance is performed in MO E 1 or 2. Risk insights or deterministi methods may be used for thV assessment.

/Credi may be taken f r unplanned events that satis this SR.

BWR/4 STS B 3.8.1-31 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 81 of 294

Attachment 1, Volume 13, Rev. 0, Page 82 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWER'S N TE------------

The above MOD restrictions may be de ted if it can be demonstrated o the staff, on a plnt specific basis, that rforming the SR with the rea or in any of the re tricted MODES can s sfy the following criteria, as applicable:

a. Perfor ance of the SR will n render any safety system or (E) comp nent inoperable,

b. P ormance of the SR w not cause perturbations to a of the ectrical distribution sy ems that could result in a cha enge to teady state operation r to plant safety systems, an Performance of the R, or failure of the SR, will n cause, or result in, an AOO with a ndant challenge to plant saf y systems.

SR 3.8.1.0 0

In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, 0 RCS, and containment design limits are not exceeded.

Iverifies all actions ) This Surv -illance demosrrti D eaia discussed in teBss enconteed rom for SR 3.8/1.1 1, durnn a loss of offsite power actuation test signal in conjunction with an ECCS initiation signals n lieu of actual demonstration of connection and loading of loads, testing that adequately shows the iINSERT 5 cailitiyof ti; G system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

A isbased on engineering judgment, taking ,

Operating expe rine The Frequency of M monthEjit e! into consideration plant conditions (E) A) has shown that these n required to perform the Surveillance~and is intended to be consistent with components us D~n s -- -elvrztr

-*- -1 2 I n - 4 II1VI.J at the 24 month

[ll!J1UIAIJJV LVU 1UU1 I..YL.I I1V.~L L yJ Q)

Frequency. Therefore,.

the Frequency Is This SR is modified by two Notes. The reason for Note 1 is to minimize acceptable from a reliability standpoint. wear and tear on t e DGs during testing. For the purpose of this testing, 0 the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge BWR/4 STS B 3.8.1-32 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 82 of 294

Attachment 1, Volume 13, Rev. 0, Page 83 of 294 B 3.8.1 0 INSERT 5

, including de-energization of emergency buses, load shedding from emergency buses, and energization of the emergency buses and respective loads from the EDG. It further demonstrates the capability of the EDG to automatically achieve the required voltage and frequency within the specified time.

The EDG auto-start and energization of permanently connected loads time of 10 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA (Ref. 12). The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the EDG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

Insert Page B 3.8.1-32 Attachment 1, Volume 13, Rev. 0, Page 83 of 294

Attachment 1, Volume 13, Rev. 0, Page 84 of 294 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) safety systems. This restriction from normally performing the

,Surveillance in MODE 11Il 2 s further amplified to allow portions of the LJsurveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced or3 when portions of the Surveillance are performed in MODE 16E3 2A`RiskL insights or deterministic methods may be used for the asseshffiWtf.-

Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 This Surveillan demonstrates that th DG starting independence h not been comr omised. Also, this Su eillance demonstrates that e ch engine can hieve proper speed wj in the specified time when t DGs are started imultaneously.

The 10 ar Frequency is cons' tent with the recommendatio Regul ory Guide 1.108 (Ref. ).

of 0 Thi SR is modified by a N e. The reason for the Note into minimize w r on the DG during te ing. For the purpose of this sting, the DGs ust be started from st dby conditions, that is, with t e engine coolant nd oil continuously ci ulated and temperature mai ained consistent with manufacturer re ommendations.

BWR/4 STS B 3.8.1-33 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 84 of 294

Attachment 1, Volume 13, Rev. 0, Page 85 of 294 AC Sources - Operating B 3.8.1 BASES REFERENCES 1. l1 0 ndix A uSRetn 0 ES-lSSAR, Section8.4 (0 (0

3. Regulatory Guide 1.9.

0E7'ASAR, Chapter jI 0 0 (D)

D SAR, ChapterFhT

.7'E 0 (!0

6. Regulatory Guide 1.93.

7. Generic Letter 84-15.

8. 00 dix A .- ti0

9. Regulatory Guide 1.108.

10. Regulatory Guide 1.137.

11. ANSI C84.1, 1982.

127)SAR, Section 0 0 1t13 S 1 e~rs essel CgderSectrdlX 5 l13. IEEE Standard 387-1995.l )

BWR/4 STS B 3.8.1-34 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 85 of 294

Attachment 1, Volume 13, Rev. 0, Page 86 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, systemi description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific information/value is provided.

3. This change has been made since Section 3.5, "ECCS and RCIC System" provides the appropriate limits that are affected by the systems in this LCO.

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

5. This change is made to be consistent with the Applicability of LCO 3.8.2.

6. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

7. Changes are made to the Bases that reflect changes made to the Specification.

8. The reference to ISTS LCO 3.8.9 is changed to LCO 3.8.7 as a result of the renumbering of Specifications.

9. The Reviewer's Note is deleted because it is not intended to be included in the plant specific ITS submittal.

10. Changes are made to be consistent with the Specification.

11. Changes are made to be consistent with the name of the Specification.

12. Typographical/grammatical error corrected.

13. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the third paragraph of the LCO Section.

14. Changes are made to be consistent with Regulatory Guide 1.9, Rev. 3 recommendations.

Monticello Page 1 of I Attachment 1, Volume 13, Rev. 0, Page 86 of 294

Attachment 1, Volume 13, Rev. 0, Page 87 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 87 of 294

Attachment 1, Volume 13, Rev. 0, Page 88 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING There are no specific NSHC discussions for this Specification.

Monticello Page 1 of I Attachment 1, Volume 13, Rev. 0, Page 88 of 294

, Volume 13, Rev. 0, Page 89 of 294 ATTACHMENT 2 ITS 3.8.2, AC Sources - Shutdown , Volume 13, Rev. 0, Page 89 of 294

Attachment 1, Volume 13, Rev. 0, Page 90 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1,Volume 13, Rev. 0, Page 90 of 294

, Volume 13, Rev. 0, Page 91 of 294 ITS 3.8.2 Add proposed ITS LCO 3.8.2

<5 M.1 Add proposed ACTIONS A and B

---pooe S3.8~

Page 1 of 1 , Volume 13, Rev. 0, Page 91 of 294

Attachment 1, Volume 13, Rev. 0, Page 92 of 294 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 CTS 3.9 does not contain any explicit Action requirements for qualified circuits and emergency diesel generators (EDGs) when these AC Sources are inoperable but are required to be OPERABLE. However, the CTS 1.0.W definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessary attendant ... normal and emergency electrical power sources... that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s)." Furthermore, the definition states that if the normal or emergency power source is inoperable, the system, subsystem, train, component or device may be considered OPERABLE provided the corresponding normal or emergency power source is OPERABLE and all of its redundant system(s),

subsystem(s), train(s), component(s) and device(s) are OPERABLE. ITS 3.8.2 ACTIONS A and B have been added to cover the situation when the qualified offsite circuit or EDG is inoperable, respectively. If the required offsite circuit is inoperable, ITS 3.8.2 ACTION A requires either the declaration that affected required feature(s), with no offsite power available, inoperable, or to suspend certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and operations with a potential for draining the reactor vessel (OPDRVs)) and to initiate action to restore required offsite power circuit to OPERABLE status. If the required EDG is inoperable, ITS 3.8.2 ACTION B requires the immediate suspension of certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs) and to initiate action to restore required EDG to OPERABLE status. In addition, a Note that states LCO 3.0.3 in not applicable has been added. This change adds compensatory actions for the inoperable required AC Source.

The purpose of ITS 3.8.2 ACTIONS A and B are to limit the time the unit can perform certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs) with an inoperable AC Source. CTS 1.0.W would allow continuous operation with an inoperable AC source as long as its corresponding normal or emergency power source is OPERABLE and all redundant required features are OPERABLE. The proposed change is acceptable because ITS 3.8.2 will require immediate action to be taken when the required AC source is inoperable regardless of the status of the other source (qualified offsite circuit or EDG) or status of the redundant equipment. If the required offsite circuit is inoperable, ITS 3.8.2 ACTION A requires either the declaration that affected required feature(s), with no offsite power available, inoperable, or to suspend certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs) and to initiate action to restore required offsite power circuit to OPERABLE status. If the required EDG is inoperable, ITS 3.8.2 ACTION B requires the immediate suspension of certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs) and to initiate Monticello Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 92 of 294

Attachment 1, Volume 13, Rev. 0, Page 93 of 294 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN action to restore required EDG to OPERABLE status. These ACTIONS are more restrictive than the current requirement, however it ensures measures are taken to limit the time the certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs) are allowed to take place with any required AC source inoperable. This change also adds a Note that states LCO 3.0.3 is not applicable. This Note has been added because ITS LCO 3.0.3 has been added to ITS Section 3.0 in accordance with ITS Section 3.0 DOC M.1. This Note is necessary because if moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. Since ITS LCO 3.0.3 is not currently included in the CTS, this portion of the change is considered administrative. However, it is discussed here for convenience. This change is designated as more restrictive because when a required AC source is inoperable, immediate action must be taken instead of allowing an AC source to be inoperable indefinitely as long as the corresponding normal or emergency power source is OPERABLE and all redundant required features are OPERABLE.

M.2 CTS 4.9 does not contain any specific Surveillance Requirements for qualified circuits and EDGs when these AC Sources are required to support equipment required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. ITS SR 3.8.2.1 requires the SRs of Specification 3.8.1, except SR 3.8.1.6 to be applicable. The Surveillance includes a Note allowing certain Surveillances to not be performed to preclude requiring the OPERABLE EDG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of the SR, or to preclude de-energizing a required 4.16 kV essential bus or disconnecting a required offsite circuit during performance of the SR. In addition, Surveillances associated with an ECCS automatic initiation signal are not required when ECCS is not required to be OPERABLE. This changes the CTS by adding explicit Surveillances for the AC Sources required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment.

The purpose of ITS SR 3.8.2.1 is to ensure the AC Sources are OPERABLE.

The proposed Surveillances are consistent with those requirements that apply while the unit is operating, except for the requirement to transfer from the normal offsite circuit to the alternate offsite circuit (SR 3.8.1.6). The Surveillance includes a Note allowing certain Surveillances to not be performed to preclude requiring the OPERABLE EDG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of the SR, and to preclude de-energizing a required 4.16 kV essential bus or disconnecting a required offsite circuit during performance of the SR. In addition, Surveillances associated with an ECCS automatic initiation signal are not required when ECCS is not required to be OPERABLE. The change is acceptable because the proposed Surveillance Requirements will help ensure the AC Sources are OPERABLE. This change is designated as more restrictive because some operating AC Sources Surveillances have been made applicable during shutdown conditions.

Monticello Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 93 of 294

Attachment 1, Volume 13, Rev. 0, Page 94 of 294 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1- Relaxation of LCO Requirements) CTS 3/4.9 does not contain any specific OPERABILITY requirements for the qualified offsite circuits and EDGs during shutdown conditions. However, the CTS 1.0.W definition of OPERABLE requires that, for all equipment required to be OPERABLE, 'all necessary attendant ... normal and emergency electrical power sources... that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s)." Furthermore, the definition states that if the normal or emergency power source is inoperable, the system, subsystem, train, component or device may be considered OPERABLE provided the corresponding normal or emergency power source is OPERABLE and all of its redundant system(s), subsystem(s), train(s),

component(s) and device(s) are OPERABLE. New requirements were added as ITS LCO 3.8.2.a and LCO 3.8.2.b. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems -

Shutdown," and ITS LCO 3.8.2.b requires one EDG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8. ITS 3.8.2 is required in MODES 4 and 5 and during the movement of irradiated fuel assemblies in the secondary containment. This changes the CTS by adding an explicit LCO for an offsite circuit and emergency source during shutdown conditions (i.e., MODES 4 and 5 and during the movement of irradiated fuel assemblies in the secondary containment).

The purpose of ITS LCO 3.8.2 is to ensure that all required equipment has a source of normal power and at least one division has an emergency source of power (i.e., EDGs). This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses. However, unlike the CTS 1.0.W definition, which could require both EDGs to be OPERABLE (depending upon what equipment is required OPERABLE), the ITS only requires one EDG to be OPERABLE as long as it supplies required equipment in one division. This requirement is less restrictive since it eliminates the requirement to declare supported equipment inoperable when its associated EDG is inoperable and redundant equipment is inoperable. In other words, when all required equipment of a given safety function is powered from a single electrical power distribution subsystem (i.e., the same division), the ITS does not necessarily require an EDG to be OPERABLE to supply power to this required equipment. The OPERABLE EDG may be the EDG that is supplying power to the other division, provided equipment powered from the other division is required OPERABLE. As long as a Monticello Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 94 of 294

Attachment 1, Volume 13, Rev. 0, Page 95 of 294 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN source of AC power is available, the equipment is considered OPERABLE. This change is acceptable since, in general, when the unit is shut down the Technical Specification requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required, as stated in the ISTS 3.8.2 Bases. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are therefore allowed by this LCO. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

Monticello Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 95 of 294

Attachment 1, Volume 13, Rev. 0, Page 96 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 96 of 294

Attachment 1, Volume 13, Rev. 0, Page 97 of 294 AC Sources - Shutdown 3.8.2 CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown DOC LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

LA

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8 D on Systems - Shutdow nd fE-g=m - ~

b. OnGdiesel generator DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8. 0 DOC APPLICABILITY: MODES 4 and 5, LA During movement of [re IsecondarV containment.

tly irradiated fuel assemblies in the 0

ACTIONS Ci pNO r - _ __ _ _ _

K , DOC LCO 3.0.3 is not applicable.

M.1 CONDITION REQUIRED ACTION COMPLETION TIME DO~C A. One required offsite -NOTE--- --

M* circuit inoperable. Enter applicable Condition and Required Actions of LCO 3.8.k.

with one required division de-0D energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s), with no offsite power available, inoperable.

OR BWR/4 STS 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 97 of 294

Attachment 1, Volume 13, Rev. 0, Page 98 of 294 AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC M.1 A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately

[nlirradiated fuel assemblies in the (I~

0 Tsecondaryl containment.

AND A.2.3 Initiate action to suspend Immediately operations with a potential for draining the reactor vessel (OPDRVs).

AND A.2.4 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

t B.1 Suspend CORE t DOC M.1 B. One requireqDG inoperable.

B.1 Suspend CORE ALTERATIONS.

Immediately 0 AND B.2 Suspend movement Immediately I[re ntly]I irradiated i assem ies i r secot lndarvM containment.}

0 AND 0

B.3 Initiate action to suspend Immediately OPDRVs.

AND BWR/4 STS 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 98 of 294

Attachment 1, Volume 13, Rev. 0, Page 99 of 294 AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Initiate action to restore Immediately DOC M.1 require dDG to OPERABLE status.

0D SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.8.2.1 IN t Y M.2 YIK I&fI1. 1'SR 3.8.1.dt1hrough\SR 3.8U1~Y 8 R .8 1.SR 3.8.1. 0D

.. and SR 3.8.1 . not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown."

For AC sources required to be OPERABLE the SRs In accordance of Specification 3.8.1, except SR 3.8.1.6*11-9 with applicable SR 3.8.1.17,d R 3.8.1.20 are applicable. SRs BWR/4 STS 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 99 of 294

Attachment 1, Volume 13, Rev. 0, Page 100 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

1. ISTS 3.8.10 is renumbered as ITS 3.8.8 since ISTS 3.8.7, "Inverters - Operating,"

and ISTS 3.8.8, "Inverters - Shutdown," are not included in the Monticello ITS.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specificatiohs, NEI 01-03, Section 5.1.3.

3. The brackets have been removed and the proper plant specific information/value has been provided.

4. The proper SR numbers have been used, based on changes made in ITS 3.8.1.

5. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

6. Typographical/grammatical error corrected.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 100 of 294

Attachment 1, Volume 13, Rev. 0, Page 101 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 101 of 294

Attachment 1, Volume 13, Rev. 0, Page 102 of 294 AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 4 and 5 SAFETY ANALYSES and during movement of re that:

irradiated fuel assemblies ensures I Inte secondary containment 00O

a. The facility can be maintained in the shutdown or refueling condition for extended periods

b. Sufficient instrumentation and control capability is available for l 0

monitoring and maintaining the unit status

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident involving handlingaIrc1i required~tmitigate fuel handln 9ccidents involving hang rec nX irradiated fuel (i.e. fu~at has occupied part,0 a critical J reefo core within the previoX [X1 days)]./

In general, when the unit is shut down the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, and 3, various deviations from the analysis assumptions and design requirements are allowed within the ACTIONS.

This allowance is in recognition that certain testing and BWR/4 STS B 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 102 of 294

Attachment 1, Volume 13, Rev. 0, Page 103 of 294 AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued) maintenance activities must be conducted, provided an acceptable level of risk is not exceeded. During MODES 4 and 5, performance of a significant number of required testing and maintenance activities is also required. In MODES 4 and 5, the activities are generally planned and administratively controlled. Relaxations from typical MODES 1, 2, and 3 LCO requirements are acceptable during shutdown MODES, based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operation MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODES 1, 2, and 3 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability of supporting systems necessary for avoiding immediate emrgen difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator'G)) power.

MACource isfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1 E power distribution subsystem(s) of LCO 3.8.ftr"Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a Distribution System 0 4.6 k essentiat ature bus required OPERABLE by LCO 3.1 ensures that a diverse power source is available for pvidg electrical power support assuming a loss of the offsite circuit.

Together, OPERABILITY of the required offsite circuit and+DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidentsRinvolving handling re irradiated fuev and reactor vessel draindown). Automatic initiation of the brDire-DG during shutdown conditions is specified in LCO 3.3.5.1, 0 "ECCS Instrumentation," and LCO 3.3.8.1, "LOP Instrumentation."

BWR/4 STS B 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 103 of 294

Attachment 1, Volume 13, Rev. 0, Page 104 of 294 AC Sources - Shutdown B 3.8.2 BASES LCO (continued) 4.16 kV essental The qualified offsite circuit(s) must be capable of maintaining rated9 frequency and voltage while connected to their respectiveMZ usw, and of accepting required loads during an accident. /qualified ffsite circuits are, those that are d~escribed in the FSA and /are part of the

{licensing basis for t~he ~unit /[The offsite cicpcnits of incoming B breaker and dsonct to the 2C or 2D str uiiary transformerm (SAT), asso c or 2D SAT, and itd2 t path incluing1E h epciecircuit feeder breakers to all 4.16 kV ESF buses r uired b LCO 3.8.10. ;

3 l14.16 kV essentall

~Therequire1'DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respectiveLE,86tus on detection of bus 0 undervoltage, and accepting required loads. This sequence must be u"co ;pflshed withirifj21 seconds. Each4DG must also be capable of 46V accepting required loads within the assumed loading sequence intervals, essental and must continue to operate until offsite power can be restored to the buses. These capabilities are required to be met from a variety of reject a bad initial conditions such a OG in standby with engine hot an&DG in with engine at ambient conditions. AdditionatWDGcapabilitieses equvaentoIt\standby ascae must be demonstrated to meet required Surveillances, e.g., capability of (e postxccisit mode.

nProper sequencing of loads, including tripping of nonessential loads, is a required function fo DG OPERABILITY. [Dln addition, proper sequence (

operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.5 0 0 It is acceptable for div es to be cross tied during shutdown itions, permitting a sin .,,site power circuit to supply all re d divisions. No t INSERT 2 fast trans pability is required for offsite circe be considered OPEBLE.

APPLICABILITY The AC sources are required to be OPERABLE in MODES 4 and 5 and during movement offtegefitl irradiated fuel assemblies in the secondary containment to provide assurance that:

0

a. Systems providing adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel

b. Systems needed to mitigate a fuel handling accident involving handling re nt irradiated fuel i.e., fu l that has occupie part of a 3 critical re ctor core within the previous/[)q days)] are availb

' >)

BWR/4 STS B 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 104 of 294

Attachment 1, Volume 13, Rev. 0, Page 105 of 294 B 3.8.2 O

i INSERT I The primary AC electrical power distribution subsystem for each division consists of a 4.16 kV essential bus (essential bus 15 for Division 1 and essential bus 16 for Division 2) having several offsite sources of power available. One offsite circuit consists of incoming disconnects to the 2R transformer, associated 2R transformer, and the respective circuit path including buses and feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8. The second circuit consists of incoming disconnects to the 1R transformer, associated I R transformer, and the respective circuit path including buses and feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8. The third qualified offsite circuit consists of incoming disconnects to the 1AR transformer (source from transformer 10), associated 1AR transformer, and the respective circuit path including feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8.

O_ INSERT2 The necessary portions of the Emergency Diesel Generator - Emergency Service Water System capable of providing cooling to the required EDG are also required.

Insert Page B 3.8.2-3 Attachment 1, Volume 13, Rev. 0, Page 105 of 294

Attachment 1, Volume 13, Rev. 0, Page 106 of 294 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are avaiialbblVe,

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, or 3 would require the unit to be shutdown unnecessarily.

A.1 t essential An offsite circuit is considered inoperable if it is not available to one requiredE, division. If two or moreM 4.16 kV;buses are required per LCO 3. one division with offsite power available may be capable of (

supporting sufficient required features to allow continuation of CORE ALTERATIONS, [re tly irradiated fuel movement, and operations with 0 a potential for draining the reactor vessel. By the allowance of the option to declare required features inoperable with no offsite power available, appropriate restrictions can be implemented in accordance with the affected required feature(s) LCOs' ACTIONS.

A.2.1. A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 With the offsite circuit not available to all required divisions, the option still exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently onservative actions is made. With the requiredsDG inoperable, the 0 minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of I [re ntlyl irradiated fuel assemblies in thelsecondar4 containment, and O activities that could result in inadvertent draining of the reactor vessel.

BWR/4 STS B 3.8.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 106 of 294

Attachment 1, Volume 13, Rev. 0, Page 107 of 294 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to CD continue this action until restoration isaccomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sourceE should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been 41kV modified b a Note to indicate that when Condition A is entered with no power to any required bus, ACTIONS for LCO 3.8. u be (-)(

immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a division is

[i de-energized. LCO 3.8X provides the appropriate restrictions for the situation involvingga de-energized division.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. ISR3.811.17 is not required to be met\

becaus the required OPERABLE G(s) is not require to undergo\

periods/of being synchronized to thy offsite circuit. SR 8.1.20 i excepted because starting indepen ence is not require Iwith the D (s) that is not required to be OPERAB E. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

SR is modified by two Notes. The reason for Note 1 is to preclude r dEThis requiring the OPERABL DGg from being paralleled with the offsite 0Q) power network or otherwise rendered inoperable during the performance of SRs, and to preclude deenergizing a required 16o disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and theODG. It is the intent that these SRs must still be 4.16kV capable of being met, but actual performance is not required during essential BWR/4 STS B 3.8.2-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 107 of 294

Attachment 1,Volume 13, Rev. 0, Page 108 of 294 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued) 12 E*,

periods whe tDG and offsite circuit is reqired to be OPERABLE.

Note 2 states that SRs 3.8.1.4g and 3.8.1 4are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE. These SRs demonstrate thevDG response to an ECCS signal (&ther alone or in conjunction with a loss-of-power signal). This is consistent with the ECCS instrumentation requirements that do not -

00 require the ECCS signals when the ECCS System is not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown."

REFERENCES None.

BWR/4 STS B 3.8.2-6 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 108 of 294

Attachment 1, Volume 13, Rev. 0, Page 109 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

1. The brackets are removed and the proper plant specific information/value is provided.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

3. Changes are made to be consistent with the name of the Specification.

4. Typographical error corrected.

5. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

6. This statement is discussing the cross-tieing of distribution buses and is not applicable to this AC Sources Specification. Therefore it has been deleted. This allowance has been described in the Bases for ITS LCO 3.8.8, "Distribution Systems - Shutdown."

7. Changes made to be consistent with the Specification.

8. Changes made to be consistent with changes made to the Specifications.

9. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the remaining sentences of the paragraph.

Monticello Page 1 of I Attachment 1, Volume 13, Rev. 0, Page 109 of 294

Attachment 1, Volume 13, Rev. 0, Page 110 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 110 of 294

Attachment 1, Volume 13, Rev. 0, Page 111 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

Monticello Page 1 of I Attachment 1, Volume 13, Rev. 0, Page 111 of 294

Attachment 1, Volume 13, Rev. 0, Page 112 of 294 ATTACHMENT 3 ITS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air Attachment 1,Volume 13, Rev. 0, Page 112 of 294

Attachment 1, Volume 13, Rev. 0, Page 113 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. O Page 113 of 294

( C ITS 3.8.3 ITS ITS IAdppse LEO 3.8.3 .

f I 3.0 UMING CONDIONS FOR OPERATION / 4.0 SURVEILLANCE REQUIREMENTS

1) Once a month the quantity of diesel fuel

-- I APIICASItY For tho diesel generator to be considered b. 1) Once a month the quantity of diesel fuel I 4See 0

3 SR 3.8.3.1 tpperable, t ore shall be a minimum of of Inthe diesel oil storage tank ays sup SR 3.8.3.1 available shall be logged.

2) DurIng the monthly generator test, the ITS 3.8.1 I C, CD lAdpnzpoliq ACTIONS Nc )teL3. .A.3 service pump shall be operated. 0

<4 ropsedACTONS A andG Aid 3 CD 0 APPLICAsILrIY c. When a diesel generator Is required to be

-- erable,maIntain air pressure for both Verify each required operable diesel C,,

SR3.8.3.4 assoated air starting receivers SR 3.8.3.3 c generator air start receiver pressure Is 12 165 psig. z 165 psig once per month. I CDh

1) Wih one diesel generator starting air 0 0 ACTION E receiver pressure t165 psig, restore both

-U starting air receivers pressure to 165 psig within 7 diysor declare the CD ACTION G silgenerator Inoperable.

0I ACTION F 2) With both diesel generator starting air a) receivers pressure < 165 psig but CD z 125 psig. restore one starting air receiver to z165 psig and enter TS LCO 3.9.9.3.c.1, or restore both starting air receivers ressure to 2 165 psig within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Ineither action can be 0 (0 ACTION G accomppshed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , dedare the to associated diesel generator inoperable.

4, ACTION G 3) Wlth both diesel generator starting air receivers pressure < 125 psig, irrnrediately j Add pmposed declare the associated diesel generator Inoperable. . / I4 Add Proposed ACTIONS C and D

.4 , ---

3.914.9 ;22 0M/27I02 Amendment No. 35-Z, 0,129 Page 1 of 1

Attachment 1, Volume 13, Rev. 0, Page 115 of 294 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.9.B.3.b specifies requirements for diesel oil stored in the diesel oil storage tank. CTS 3.9.B.3.c specified requirements for the emergency diesel generator (EDG) air starting receivers. CTS 3.9.B.3.b and CTS 3.9.B.3.c state that these requirements are required to consider the associated EDG to be OPERABLE.

ITS LCO 3.8.3 states, in part, that the stored diesel fuel oil and starting air' subsystems shall be within limits for each required EDG. The Applicability for this requirement is when associated EDG is required to be OPERABLE. This changes the CTS by combining the requirements for diesel fuel oil and starting air into one Specification.

This change is acceptable because the current requirements are translated into ITS form with no technical changes. Diesel fuel oil and starting air is a support system for each EDG. The CTS and ITS maintain this relationship between the EDGs and the diesel fuel oil and starting air systems without any changes in the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.9.B.3.c.1), CTS 3.9.B.3.c.2), and CTS 3.9.B.c.3) specify the compensatory actions to take when the starting air pressure is not within limits for the associated EDG. ITS ACTIONS E, F, and G specify similar compensatory actions under the same condition. However, ITS 3.8.3 ACTIONS Note has been added and allows separate Condition entry for each EDG. This changes the CTS by explicitly stating that the Actions are to be taken separately for each required EDG.

The purpose of the Note is to provide explicit instructions for proper application of the ACTION for Technical Specification compliance. In conjunction with proposed Specification 1.3, "Completion Times," this Note provides direction consistent with the intent of the existing Action for starting air subsystems not within limit. The CTS intent is to allow the CTS Actions to apply to each EDG starting air receiver, therefore this change is acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.9.B.3.b.3) specifies a requirement to sample the diesel fuel and check for quality once a month. ITS SR 3.8.3.3 requires the verification that fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program. This changes CTS by requiring testing in accordance with the Diesel Fuel Oil Testing Program, whose requirements are being moved to ITS 5.5.8.

Monticello Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 115 of 294

Attachment 1, Volume 13, Rev. 0, Page 116 of 294 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR This change is acceptable because Diesel Fuel Oil Testing Program requirements are being moved to the Diesel Fuel Oil Testing Program as part of ITS 5.5.8 and ITS SR 3.8.3.3 references the Diesel Fuel Oil Testing Program for performing these tests. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 While CTS 4.9.B.3.b.3) specifies a requirement to sample the diesel fuel and check for quality once a month, the CTS does not provide any specific testing requirements to check for and remove accumulated water from the fuel oil storage tank. ITS SR 3.8.3.5 requires this verification very 31 days. This changes the CTS by requiring a new Surveillance Requirement to check for and remove accumulated water from the fuel oil storage tank.

The purpose of ITS SR 3.8.3.5 is to ensure that the environment for microbiological fouling does not exist. This change is acceptable because it provides additional assurance that accumulated water is removed on a regular basis to ensure an environment does not exist for microbiological fouling. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

M.2 CTS 4.9.B.3.b.3) specifies a requirement to sample the stored diesel fuel oil and check.for quality once a month. The CTS does not provide any specific guidance for when the plant specific quality requirements are not met. Furthermore, the CTS does not contain any requirements concerning the acceptance criteria limits for new fuel oil, which is sampled prior to its addition to the fuel oil storage tank, but the results of the sample are not known until after the new fuel oil is added to the fuel oil storage tank. ITS 3.8.3 ACTION C specifies the compensatory actions for stored fuel oil total particulates not within limits, and requires the restoration of the fuel oil total particulates to within limits in 7 days. ITS 3.8.3 ACTION D specifies the compensatory actions for new fuel oil properties not within limits, and requires the restoration of the stored fuel oil properties to within limits within 30 days. If these new ACTIONS are not met, ITS 3.8.3 ACTION G requires both EDGs to be declared inoperable (and the ACTIONS of ITS 3.8.1 taken). In addition, ITS SR 3.8.3.3 requires a verification that the fuel oil properties of new fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Storage Program. This changes the CTS by providing an explicit ACTION for when the fuel oil total particulates limit is not met, a new Surveillance Requirement to verify new fuel oil limits are met, and an ACTION if they are not met.

The purpose of 4.9.B.3.b.3) is to provide the appropriate property limits for stored fuel. ITS 3.8.3 ACTION C is entered as a result of a stored fuel oil total particulates not within limit. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling), contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, particulate concentration is Monticello Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 116 of 294

Attachment 1, Volume 13, Rev. 0, Page 117 of 294 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated EDG inoperable.

The 7 day Completion Time allows for further evaluation, re-sampling and re-analysis of the EDG fuel oil. ITS SR 3.8.3.3 requires a verification that the fuel oil properties of new fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Storage Program. This ensures that new fuel oil, once added to the fuel oil storage tank, does not result in out of specification fuel oil limits. ITS 3.8.3 ACTION D is entered as a result of failure to meet the new fuel oil property limits. With the new fuel oil properties not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties.

This period provides sufficient time to test the stored fuel oil to determine that the added new fuel oil did not cause the stored fuel oil to be outside of the required limits, or to restore the stored fuel oil properties to within limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a EDG start and load was required during this time interval and the stored fuel oil properties were outside limits, there is a high likelihood that the EDG would still be capable of performing its intended function. This change is designated as more restrictive because explicit Required Actions and Completion Times for stored fuel oil total particulates and new fuel oil properties not within limits and a new Surveillance Requirement to verify new fuel oil properties are within limits have been added.

M.3 The CTS does not provide any EDG lube oil requirements. ITS LCO 3.8.3, in part, requires the lube oil inventory to be within limits for each required EDG.

The Applicability for this requirement iswhen the associated EDG is required to be OPERABLE. ITS SR 3.8.3.2 requires a verification that the lube oil inventory is > 165 gallons for each EDG. ITS 3.8.3 ACTION B provides an ACTION if the limit of ITS SR 3.8.3.2 is not met. This changes the CTS by adding a lube oil inventory requirement, and an appropriate ACTIONS and Surveillance Requirement.

The purpose of the lube oil inventory requirement in ITS LCO 3.8.3 and SR 3.8.3.2 is to ensure a 7 day lube oil inventory for each EDG is on site. The proposed ITS SR 3.8.3.2 value, 165 gallons, will ensure the 7 day inventory requirement is met. In addition, ITS 3.8.3 ACTION B will allow the 7 day limit to not be met for each EDG for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , provided sufficient lube oil inventory is available for 6 days. If the lube oil inventory is not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if the 6 day limit is not met, then the associated EDG is required to be declared inoperable immediately. Furthermore, as stated In the ITS 3.8.3 ACTIONS Note, ITS 3.8.3 ACTION B is allowed to be separately entered for each EDG.

Therefore, this change is acceptable. This change is considered more restrictive because it adds a new requirement to maintain a 7 day lube oil inventory for each EDG.

RELOCATED SPECIFICATIONS None Monticello Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 117 of 294

Attachment 1, Volume 13, Rev. 0, Page 118 of 294 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.B.3.b states that the minimum specified diesel fuel volume in the diesel oil storage tank is adequate to supply 7 days of operation for one EDG at full load (2500 kW). ITS 3.8.3 does not include this statement. This changes the CTS by relocating the details of the system design ITS Bases.

The removal of this detail, which is related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.8.3 retains the requirement for stored diesel fuel oil to be within limit and ITS SR 3.8.3.1 retains the requirement that the fuel oil storage tank contains > 38,300 gallons of fuel. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) The CTS 3.9.B.3.b does not provide explicit compensatory actions if the volume of fuel oil in the storage tank is less than the specified limit. Thus, if the minimum indicated volume is not met, both EDGs must be declared inoperable and CTS 3.9.B.3.a.2), which requires a plant shutdown, must be entered. ITS 3.8.3 ACTION A allows the unit to not declare the EDGs inoperable provided the volume of stored fuel oil is greater than that needed to operate a EDG for 6 days at full load (i.e., > 33,600 gallons).

In this situation, ITS 3.8.3 Required Action A.1 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the fuel oil volume to within limits. If this Required Action and associated Completion Time is not met or if the EDG fuel oil storage tank volume is < 33,600 gallons, both EDGs must be declared inoperable immediately and appropriate ACTIONS taken per ITS 3.8.1 (ITS 3.8.3 ACTION G). Any changes to the Actions taken after the EDGs are declared inoperable are discussed in the Discussion of Changes in ITS 3.8.1.

The purpose of ITS 3.8.3 ACTION A isto allow time to restore the stored diesel fuel oil volume to within the specified limit. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The addition of ITS 3.8.3 ACTION A will allow the EDGs not to be declared inoperable with the stored diesel fuel oil volume not within the specified Surveillance limit as long as one EDG has Monticello Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 118 of 294

Attachment 1, Volume 13, Rev. 0, Page 119 of 294 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR enough fuel oil for 6 days operation at full load. In this Condition, the 7 day fuel oil supply is not available. However, the Condition is restricted to fuel oil volume reductions that maintain at least a 6 day supply. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of diesel fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring both EDGs inoperable. This period is acceptable based on the remaining capacity

(> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Monticello Page 5 of 5 Attachment 1, Volume 13, Rev. 0, Page 119 of 294

Attachment 1,Volume 13, Rev. 0, Page 120 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 120 of 294

Attachment 1, Volume 13, Rev. 0, Page 121 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 CIS 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.9.B.3.b, LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be 4 3.92.3.c within limits for each required diesel generator (DG).

3.9.B.3.b. APPLICABILITY: When associate DG is required to be OPERABLE.

3.9.B.3.c ACTIONS SeparateConditionentryisalo ec 0 EG DOC A.3 0

Separate Condition entry is allowed for each DG. 0 CONDITION REQUIRED ACTION COMPLETION TIME DOC Li A. lOne or rD fuel oil level Gs with I 3

A.1 Restore fuel oil level to within limits.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 0

)DJ'll and

[2885 gal in storage* 0D tank. 33,600 DOC M.3 B. One or mores-Gs with lube oil inventory B.1 Restore lube oil inventory to within limits.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 0D

> al 0 DOC M2 C. One or re-Gs with Stored fuel oil total C.1 Restore fuel oil total particulates to within limit.

7 days 0 particulates not within limit.

DOC M2 D. 19ne or GrGs with Sew fuel oil properties 0.1 Restore stored fuel oil properties to within limits.

30 days 0 not within limits.

BWR/4 STS 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 121 of 294

Attachment 1, Volume 13, Rev. 0, Page 122 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 I

CONDITION REQUIRED ACTION COMPLETION TIME

________________________________________________ I 3.9.B.3.c.2)X. One or morei 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months starting air ret inboth starting prssr airsubsystems 3.9.B.3.C.24 an m 2~p 1* *1 3.9B 3.C.2) I Required Acti on and u.1 Declare associated*DG Immediately DOC M.2 associated C( ompletion G inoperable.

Time not met.

OR E 3.9.B.3.c.3), One or more DGs with 0D DOC LI diesel fuel oil, lube oil, or starting air subsystem not within limits for D 0

reasons other than Condition A, B, C, D, go Ed.~ 0 SURVEILLANCE REQUIREMENTS _

SURVEILLANCE FREQUENCY 3.9.B3.b, 4.9.B.3.b.1)

SR 3.8.3.1 Verifyga'fuel oil storage tank contains 31 days 0 gal of fuel.

42TM[30 w3~~

0D DOC M.3 SR 3.8.3.2 Veri lube oil inventory is Ž M5gal. 31 days 00 4.9.B.3.b.3), SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance DOC M.2 are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program 3.9.B3.c, SR 3.8.3.4 V~erieach DG air start receiver pressure is 31 days 4.9.B.3.c 2A sig.___

3L 0 BWR/4 STS 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 122 of 294

Attachment 1, Volume 13, Rev. 0, Page 123 of 294 3.8.3 INSERT 1 3.9.B.3.c.1) E. One or more EDGs with starting E.1 Restore starting air receiver 7 days air receiver pressure in one pressure to > 165 psig.

starting air subsystem

< 165 psig.

Insert Page 3.8.3-2 Attachment 1, Volume 13, Rev. 0, Page 123 of 294

Attachment 1, Volume 13, Rev. 0, Page 124 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOCM.1 SR 3.8.3.5 Check for and remove accumulated water from fuel oil storage tank.

i3 B311days 00 BWR/4 STS 3.8.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 124 of 294

Attachment 1, Volume 13, Rev. 0, Page 125 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. Changes are made (additions, deletions, and/or changes) to the ISTS, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific information/value is provided.

3. ITS 3.8.3 ACTION E has been added and ISTS 3.8.3 ACTION E (ITS 3.8.3 ACTION F) has been modified in accordance with the current licensing basis. These requirements were approved by the NRC in License Amendment 129, dated August 27, 2002. Subsequent ACTIONS have also been renumbered.

4. Each EDG at Monticello has two starting air subsystems. In addition, Monticello has a common fuel oil storage tank for both EDGs. Therefore, ISTS LCO 3.8.3, ISTS 3.8.3 ACTIONS A, C, D, and F, ISTS SR 3.8.3.1, and ISTS SR 3.8.3.5 have been modified to account for these design differences.

5. Changes have been made to be consistent with the Specification and ACTIONS.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 125 of 294

Attachment 1, Volume 13, Rev. 0, Page 126 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 126 of 294

Attachment 1, Volume 13, Rev. 0, Page 127 of 294

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air rThe BASES (i!e~eJ m,,T BACKGROUND diesel generaoI.~,provie with a storage tank having a fuel oe icapacity sufficient to opera t a G for a period of 7 days while the a) DIG is supplying [maximumn post los-s-Leani-ccident (LOUA oasJ iscussed in9SAR, Section 9X.22]l!. 1). maximum Ioads (20kWa Id~lemand i§,taiculated sig the assumptio thta etwo DGsar I availab6. IThis onsite fuel oil capacity is sufficient to operate the f longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from storage tank to day tang by eitherl lv bedise transfer pumpS associated P i storage tan K. Redundancy of pump~ or pumps and piping precludes the failure of one pump, or the rupture of any valveo to result in the loss of more than one DG. I outsid tan and piping are located underground.,

The pumps are located In the pump house. . storage For proper operation of the standbyADGs, it is necessary to ensure the a proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, tihe kinematic vyi , pecific gravity (0or API gravity, A and impurity level.

The4DG lubrication system is designed to provide sufficient lubrication to 0 permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of supporting a minimum of 73 days of operation.l [TTh~nsite storage in l 0 operati6.l This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Ea. EDG 01 I airstartsubs;stem I R th air-receiver pressure at 1165 psLg ,

independent *EachrDGhas tan air sta stem withladequate capacitjfor3igej air start successive start attempts on tkh3fnG without recharging the air start subsystems. receiveE E L w APPLICABLE The initial conditions of Design Basis Accident (DBA) anransiejnt SAFETY CD-analyses ijESAR, IChapter e. , an Chapter (Ref.1L,0 0 ANALYSES Oq assume Engineered Safety Feature (ESF) systems are OPERABLE. The

DGs are designed to provide sufficient capacity, capability, redundancy, (3 and reliability to ensure the availability of necessary power to ESF BWR/4 STS B 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 127 of 294

Attachment 1, Volume 13, Rev. 0, Page 128 of 294 B 3.8.3 Q) INSERT 1 Each EDG air start subsystem includes three starting air receivers. The automatic start logic for each EDG will provide a cranking sequence to ensure two start attempts from each subsystem staggered such that there are a total of three start attempts on the EDG. The first attempt will use the selected air start subsystem, the second attempt will use both air start subsystems, while the third attempt will use the air start subsystem that is not selected or not used on the first attempt. The third start attempt may not occur within enough time for the engine to be ready to accept load within 10 seconds of a demand requirement.

4 Insert Page B 3.8.3-1 Attachment 1, Volume 13, Rev. 0, Page 128 of 294

Attachment 1, Volume 13, Rev. 0, Page 129 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE SAFETY ANALYSES (continued) systems so that fuel, Reactor Coolant System, and containment design Emergency Core Cooling limits are not exceeded. These limits are discussed in mored etail in the Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System Bases for Section 3.2, Power Distribution Limits; Section 3 , e o oo ant m and Section 3.6, Containment Systems.

0 Since 4esel/uel. l,)be 4i,and4artingir u e support operation of the standby AC power sources, m satis Criterion 3 of l

r 0 10 CFR 50.36(c)(2)(ii). % V -

LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full nEDG load operatior It is also required to meet specific standards for quality.

Additionally, sufficient lube oil supply must be available to ensure the bothEDs cabilityitoperate'at full load for 7 days. This requirement, in conjunction with an ability to obtain replacement supplies within 7 days, supports the availability okDGs required to shut down the reactor and to E 2 an tefo maintain it in a safe condition for an anticipated operational occurrenceF-T-:-

tnk theYae (AOO) or apostulated DBA with loss of offsite power.~D IdaG 1)fie

-loreqlre.as

_ ellaflrnsfr cpability from the storage tank to the ay tang are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown."

nstarting air ystem is required to have a minimum capacity formacy

] successiv'uDG start attempts without recharging the air start receivers. C)

APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA.

Because stored diesel fuel oil, lube oil, and starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associatecUDG is required to be OPERABLE.

0D ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each*DG. This is acceptable, since them Required Actions for each Condition provide appropriate compensatory E actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable*DG subsystem may allow for continued operation, and subsequent inoperable;OG subsystem(s) governed byL J 0 separate Condition entry and application of associated Required Actions.

BWR/4 STS B 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 129 of 294

Attachment 1, Volume 13, Rev. 0, Page 130 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

A.1 In this Condition, the 7 day fuel oil supply forf a tavaia(ble However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply. These circumstances may be caused by events such as either:

a. Full load operation required for an inadvertent start while at minimum required leve%qo

b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered tto complete restoration of the required level prior to declaring This period is acceptable based on the remaining acity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

B.1 With lube oil inventory < gal, sufficient lube oil to support 7 days of continuous DG operation at full load conditions may not be available.

However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. This restriction allows sufficient time for obtaining the requisite replacement volume. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 This Condition is entered as a result of a failure to meet the acceptance criterion for particulates. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

BWRI4 STS B 3.8.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 130 of 294

Attachment 1, Volume 13, Rev. 0, Page 131 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associatedd Ad inoperable. The 7 day Completion Time allows for further evaluation, 0 resampling, and re-analysis of the DG fuel oil. 0 D.1 With the new fuel oil properties defined in the Bases for SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combination of these procedures. Even if a4DG start and load- (

was required during this time interval and the fuel oil properties were outside limits, there is high likelihood that the OG would still be capable of performing its intended function.

< NET2 ( 0 in at least one starting air Wih subsystem. rsuecpc'7~

th t ree (D With star ing air receive essure < psig sufficient capacity fo& D3 nE successiveaDG start attempt does not exist. However, as long as the (2 receiver pressure is >1125 ps there is adequate capacity for at least ( 3 one start attempt, and the~DG can be considered OPERABLE while them 0 air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration to the required pressure prior to declaring thekDG inoperable. This period is acceptable based on,_

the remaining air start capacity, the fact that mostADG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

BWR/4 STS B 3.8.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 131 of 294

Attachment 1, Volume 13, Rev. 0, Page 132 of 294 B 3.8.3 0 INSERT 2 E.1 With starting air receiver pressure < 165 psig in one air starting subsystem, sufficient capacity for three successive EDG start attempts does not exist. However, as long as the other starting air receiver subsystem pressure is > 165 psig, there is adequate capacity for two start attempts, and the EDG can be considered OPERABLE while the air receiver pressure is restored to the required limit. A period of 7 days is considered sufficient to complete restoration to the required pressure prior to declaring the EDG inoperable. This period is acceptable based on the remaining air start capacity in the other starting air subsystem, the fact that most EDG starts are accomplished on the first attempt, and the low probability of an event during the 7day period.

Insert Page B 3.8.3-4 Attachment 1, Volume 13, Rev. 0, Page 132 of 294

Attachment 1, Volume 13, Rev. 0, Page 133 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

With a Required Action and associated Completion Time not met, or the stored diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through lthe associated Q3 (3 111*DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tankg to suppor leacfIJG's operation for 7 days at full load. (

The 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory is available to support at least 7 days of full load operation for eac G 15Thej[f] gal requirement is based on theD0G manufacturer's E GIXID consumption values for the run time of the*DG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to theWDG~fl~~ the1 DG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer's recommended minimum level.

A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the plant (

staff. L3 S R 3.8.3.3 .[of new fuel oil piorto addition to the storage tank The testsl liste elow are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for BWR/4 STS B 3.8.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 133 of 294

Attachment 1, Volume 13, Rev. 0, Page 134 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) (itat is.in edieseloil receing tnk contaminating the entire volume of fuel oil in the storage tang. These tests are to be conducted prior to adding the new fue o the storage wterandiut i case mno is the time lmtswen tesein accorance Failurtingme tests to exceed 31 is cautestse limits, and appucabe ASTM Standards are as followsu

a. Sample the new fuel oil in accordance with ASTM D4057-

b. accordance with theests specified AST in a ASTMRef. D lthat the sample hametrnew fsolute sowenteste 2 3 aPI gravity at 60eF of t anlysis fho tested in accordance with ASTM D22L-M i552)-(A) whntsedinhiscosity at 40'C of a-1-9 b~ s and 5 a4 cntistokea,, and (IRacViflas p5)fsybi visc o i 2

t t I 00 y Fof 2:3Z6 and S 40.1 seods;7vraw.

-s ccorda f. ith ASTM D445-96 dRef 5

) t)-~ i c.ceptblehatcthe new fuel oil has a/clear and brignt appearanie wihI y n opet cws or when tested in acerdance with AoTM D4176 f oil water and sediment content within limits when tested in accordance wt TM(Ref. Eq. (i) 0 Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

[otown 3 dadysonf {WthriW fad~ollowing the initial new fuel oil sample, the fuel oil is } (

hee new to fuel oil establish do that the other properties whnalze specified in Table1of storage tuellcl ankca(Ref fulge met for new fuel oilwhen tested eip nt whichhAT(Ref.

however, can ce engine fir WT4 B3.8.36Rev..0,0/ce with ASTM D115/

gASTM D262 rS M D4294-[ ill (Ref. g).._The 3 apeidsm patiultelmstyiuetooxdaio.dheprseceofpatiultedos acceptable because the fuel oil properties of Interest, even if they w o e e not within stated limits, would not have an immediate effect orgDG operation. This Surveillance ensures the availability of high quua%'[Felfoiloi for theJDGs. - 1E Fuel oil degradation during long term storage shows up as an increase in particulate, mostly due to oxidation. The presence of particulate does not mean that the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

BWR/4 STS B 3.8.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 134 of 294

Attachment 1, Volume 13, Rev. 0, Page 135 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) 6217-98 articulate concentrations should be determined in accordance with R ASTM 54 -[ (Ref. g. This method involves a gravimetric ( j) (

determination o total particulate concentration in the fuel oil and has a limit of 10 mg/I. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. [For those/dsins in which the total volume Of stored fuel oil is contained in two o more interconnecte tanks, each tank must be considered and tested ieaaev-l The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.4 three This Surveillance ensures that, without t e aid of the refill compressor, sufficient air start capacity for each G is available. The system design requirements provide for a minimum of flelrngine start cycles without recharging. RA start cycle is defined by theIn~r, but usually is measure s of time seconds of cranking) or eneranKing Ihre J lspieg The pressure specified in this SR is intended to reflect the lowest J value at which thel starts can be accomplished.

TheR31T day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure.

SR 3.8.3.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel storage tanks once every31Jdays eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. Inaddition, it eliminates the potential for water entrainment in the fuel oil durinDG operation. Water may3 (

come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by BWR/4 STS B 3.8.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 135 of 294

Attachment 1, Volume 13, Rev. 0, Page 136 of 294 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance.

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance.

REFERENCES 41.S AR, SectionUJ [3 00

2. Regulatory Guide 1.137.

3. ANSI N195, 1976.

14. FSA lapter [6]. (

SAR, Chapterf D87-92; 0445-96;D93797; 0D (9

ASTM Standards: D405217P97;D L D129- ;D4176 ; 00E l D1796-90 J2 17-0975-91;l BWR/4 STS B 3.8.3-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 136 of 294

Attachment 1, Volume 13, Rev. 0, Page 137 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. Changes are made to the Bases that reflect changes made to the Specifications.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. The brackets are removed and the proper plant specific information/value is provided.

4. This change has been made since Section 3.5, "ECCS and RCIC System" provides the appropriate limits that are affected by the systems in this LCO.

5. Changes are made to be consistent with the name of the Specification.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

7. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

8. Changes are made to be consistent with the Specification.

9. Typographical error corrected.

10. The bracketed requirement/information has been deleted because it is not applicable to Monticello.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 137 of 294

Attachment 1, Volume 13, Rev. 0, Page 138 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 138 of 294

Attachment 1, Volume 13, Rev. 0, Page 139 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 139 of 294

, Volume 13, Rev. 0, Page 140 of 294 ATTACHMENT 4 ITS 3.8.4, DC Sources - Operating , Volume 13, Rev. 0, Page 140 of 294

Attachment 1, Volume 13, Rev. 0, Page 141 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 141 of 294

C C C ITS 3.8.4 ITS 3.0 UMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.9 AUXIUA i IRICAL SYSTEMS 4.9 AUXILARY ELE A~p~abin~ / /Applcab~v 0)

Applies 20to atzdllaM electrical power system. Apples to the perlytetn requirements of the au~dlar electrical system. I 0 0

- 7 /Objetive a To ass re an adequate supply of electrical r during a plant peration. Verify the ope Ulty of the awdilary electrical system.

0

3.8.4 Specification

I1 A. Surveillance testing shal be performed as follows:

Applicability A. The reactor shall not be madelcrltlcal~unless all the 0 following requirernents are satisfied: *0 v 1. Substatbon Switchyard Battery

1. At least two (2)NSP transmission llnes, associated

-o switchgear, and at least two offsite power sources a. Every week the specific gravity and voltage of are fully operational and energtzed to carry power to the pilot cell and temperature of adjacent cells the plant 4160V AC buses as follows: and overall battery voltage shall be measured. See ITS 3.8.1 } N, CD

a. 2R and I R transformers, or b. Every three months the measurements shall be made of voltage of each cell to nearest 0.01 10 b. lRandlARtransformersor volt specf gravity ofeach cell, and W*

temperature of every fifth cen.

to c. 2R and IAR transformers (source from 10 transformer) 3.914.9 199 10/16/87 Amendment No. 51 Page 1 of 3

C C C ITS 3.8.4 ITS 0

3.0 UMITING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS I See ITS 3.8.1 }

2. Both diesel generators are operable and capable o

0) f.feeding their designated 4160 volt buses. _ 0) s S

l ~3.(a) 41 60V Buses #15 nd 1118are energezed.

3 t I See ITS 3.8.7 } CD

\ (b) 480V Load Centers #103and1#104 are 3 0

0 rD 0

LCO 3.8.4

\energized.

station 25 and 250 vo a eFsa 9 0 tD

-7 3

B.

Ichar ~ers are operable.

Wh~n the mode switql Is in Run, the ay/obility of electrical power subsystems I

-8 0

U CD LCO 3.0.3 elqktric power shallte as specified In i.9.A, except as syedifed In 3.9.B of the reactor shallke placed In the 0 skbd shutdown co dthn within 24 h urs.

1. Transmission Uines 0

-U 101 A)

From and after the date that Incoming power Is available from only one lne, reactor operation Is ( See ITS 3.8.1 } 0 to permissible only during the succeeding seven days CD unless an additional line Is sooner placed In service providing both the emergency diesel generators are -4' 0 operable. CD Ca) CA) 0 to

-Pb (D

3.9/4.9 200 08/27/02 Amendment No. 14I4-O4,129 Page 2 of 3

C c ITS 3.8.4 ITS ITS 3.0 LIMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

4. Station Battery System 4. Station Battery System 03 0)

S Ifone of thetwo 125V1 SR 3.8.4.1 a.

lhe two 250 V battery sj 3 3 0

.4-

.I, 0

C)

(D 0 0 3

. D

5. 24V Battery Systems :0 3

DX

a. Every week the/spedlfi gravity and voltage of CD tD 24V Battery ems the pilot cell a d temperature of adjacent cells 0 and overal b ery voltage shall be measured.

CD From and alt rthedate that one of the two 24V I.

battery syst Is made or found to be Inoperab b. Every thre months the measurements shall be for any re on, refer to Specification 3.2 for made of iege of each cell to nearest 0.01

-9' appropa aton. volt, s gravity of each cell, and CD temper re of every fifth cell.

(0 3.914.9 203 3124/86 Amendment No. 3,41 Page 3 of 3

Attachment 1, Volume 13, Rev. 0, Page 145 of 294 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A.1 Inthe conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.A requires the station batteries specified in CTS 3.9.A.4 to be OPERABLE when the reactor is critical. ITS LCO 3.8.4 requires the station batteries to be OPERABLE in MODES 1, 2, and 3. This changes the CTS by requiring the batteries to be OPERABLE in MODE 3 and in MODE 2 when the reactor is not critical.

The purpose of CTS 3.9.A, in part, is to ensure the station batteries are OPERABLE to mitigate the consequences of a transient or design basis accident. The station batteries are required to be OPERABLE in MODES 1, 2, and 3 when a design basis accident (e.g., loss of coolant accident) may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 the reactor is not critical, however the reactor coolant temperature is always above 212 0F and there is considerable energy in the reactor core and the station batteries must be available to support equipment necessary to mitigate the consequences of a pipe break. Therefore, it is necessary and acceptable to require the batteries to be OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M.2 CTS 3.9.B.4 states that when one of the two 125 VDC battery systems or one of the two 250 V battery systems is made or found to be inoperable for any reason, an orderly shutdown of the reactor shall be initiated and the reactor water temperature shall be reduced to less than 2120F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless such battery system are sooner made OPERABLE. CTS 3.9.B states that when the reactor mode switch is in Run, the availability of electric power shall be as specified In CTS 3.9.A, except as specified in CTS 3.9.B or the reactor shall be placed in the cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Thus, when more than one 125V or 250V battery systems are inoperable, the CTS 3.9.B requirement would apply. However, the CTS 3.9.A.4 125V and 250V battery systems are only required to be OPERABLE when critical, as stated in CTS 3.9.A. Thus, the plant is only required to be subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.4 ACTION C provides the shutdown requirement when one 125V or 250V battery system is inoperable and requires the unit to be in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If there are inoperable DC Sources in both Division 1 and Division 2, entry into ITS LCO 3.0.3 is required since a Condition does not exist for this condition in ITS 3.8.4. ITS LCO 3.0.3 will require the unit to initiate action within Monticello Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 145 of 294

Attachment 1, Volume 13, Rev. 0, Page 146 of 294 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . This changes the CTS by requiring the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown (MODE 4) in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if one 125V or 250V battery system is inoperable. In addition, this changes the CTS by requiring the plant to initiate a plant shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in MODE 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , to be in MODE 3 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and to be in MODE 4 in 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months , in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if more than one 125V or 250V battery system is inoperable.

The purpose of CTS 3.9.B and CTS 3.9.B.4 is to place the plant outside the Applicability of the Specification. CTS 3.9.A requires the 125V and 250V battery systems to be OPERABLE only when critical (MODE I and a portion of MODE 2). Thus, while the CTS 3.9.B and 3.9.B.4 Actions require a shutdown to MODE 4, in actuality, only a shutdown to subcritical conditions is required. Once subcriticality is achieved, continuation to MODE 4 is not required since the 125V and 250V battery systems are not required to be OPERABLE when subcritical.

However, since the requirement that the 125V and 250V battery systems be OPERABLE in MODE 2 when subcritical and in MODE 3 has been added (DOC M.1), ITS 3.8.4 ACTION C and LCO 3.0.3 include a shutdown to MODE 3 and to MODE 4. The allowed Completion Times are reasonable, based on operating experience, to reach required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This change is acceptable because it requires the unit to be in an intermediate condition sooner than is currently required (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months versus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). This portion of the change reduces the time the unit would be allowed to continue to operate in MODE 1 and MODE 2 while critical once the condition is identified. The consequences of a loss of coolant accident are reduced when the reactor is shutdown and a controlled cooldown is already in progress. This change is designated as more restrictive because less time is allowed to shut down the plant in the ITS than is allowed in the CTS.

M.3 CTS 4.9.B.4 does not provide any specific testing requirements for the Division 1 and 2 250 VDC and 125 VDC battery chargers. ITS SR 3.8.4.2 requires verification, every 24 months, each required battery charger can supply

> 150 amps for the station 250 VDC subsystem and > 50 amps for station 125 VDC subsystems at greater than or equal to the minimum established float voltage for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or to verify each required battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for 250 VDC subsystems and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for 125 VDC subsystems while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis discharge state. This changes the CTS by requiring a new Surveillance Requirement for verifying the OPERABILITY of the required battery chargers associated with the Division I and Division 2 125 VDC and 250 VDC electrical power subsystems.

The purpose of ITS SR 3.8.4.2 is to ensure that the battery chargers associated with the Division I and Division 2 125 VDC and 250 VDC electrical power subsystems are OPERABLE. This change is acceptable because it provides additional assurance that the battery chargers associated with the Division 1 and Monticello Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 146 of 294

Attachment 1, Volume 13, Rev. 0, Page 147 of 294 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Division 2 125 VDC and 250 VDC electrical power subsystems are OPERABLE.

This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

M.4 CTS 4.9.B.4 does not provide any specific testing requirements to perform a battery service test for the Division I and Division 2 125 VDC and 250 VDC batteries. ITS SR 3.8.4.3 requires the verification that battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test every 24 months. ITS SR 3.8.4.3 includes an allowance (Note 1) to perform a modified performance discharge test (ITS SR 3.8.6.6) in lieu of the battery service test. In addition, Note 2 includes a restriction that the Surveillance shall not normally be performed in MODE 1, 2, or 3, but allows credit to be taken for unplanned events that satisfy the SR. This changes the CTS by requiring a new Surveillance Requirement for verifying the OPERABILITY of the Division 1 and Division 2 125 VDC and 250 VDC batteries.

The purpose of ITS SR 3.8.4.3 is to ensure the batteries can satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements to satisfy the design basis duty cycle. This change is acceptable because it provides additional assurance the batteries associated with the Division 1 and Division 2 125 VDC and 250 VDC electrical power subsystems are OPERABLE.

This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, USAR, ODCM, OQAP, IST Program, or I1P) CTS 3.9.A.4 states that the 24/48 volt batteries must be charged and inservice and the associated battery chargers must be OPERABLE. CTS 3.9.B.5 provides the Actions to take when one of the two 24 V battery systems are found to be inoperable and CTS 4.9.B.5 includes Surveillance Requirements for the station 24 volt batteries. ITS 3.8.4 does not include any requirements for the station 24/48 VDC batteries or chargers. This changes the CTS by relocating the LCO, Actions, and Surveillances Requirements to the Technical Requirements Manual (TRM).

The removal of this LCO and associated Actions and Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The only Technical Specification equipment these batteries support is the SRMs, IRMs, and the PCIV indication in the H2/02 monitors penetration flow paths. ITS 3.3 still retains requirements for the OPERABILITY requirements associated with the equipment supported by the Monticello Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 147 of 294

Attachment 1, Volume 13, Rev. 0, Page 148 of 294 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING 24/48 VDC batteries and chargers. Also, this change is acceptable because the LCO, Actions, and Surveillance Requirements will be adequately controlled in the TRM. The TRM is incorporated by reference into the USAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.A.4, in part, requires the 125 V and 250 V batteries to be charged and in service, and the associated battery chargers to be OPERABLE.

ITS LCO 3.8.4 requires the Division I and Division 2 125 VDC and 250 VDC electrical power subsystems to be OPERABLE. This changes the CTS by relocating the details of the system design (i.e., batteries are charged and in service and the batteries chargers are OPERABLE) ITS Bases.

The removal of this detail, which is related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.8.4 still retains the requirement that the Division 1 and Division 2 125 VDC and 250 VDC electrical power subsystems to be OPERABLE. In addition, ITS 3.8.4 includes Surveillance Requirements to test both the chargers and batteries. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) When one of the two 125 VDC battery systems or one of the two 250 V battery systems is made or found to be inoperable, CTS 3.9.B.4 requires a plant shutdown; no time is provided to restore the inoperable battery systems. ITS 3.8.4 ACTION A covers the condition for one or more Division 1 or Division 2 required battery chargers inoperable and requires the restoration of battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the verification that battery float current is < 2 amps for 250 VDC batteries and < 1 amp for 125 VDC batteries once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and the restoration of the inoperable battery charger(s) to OPERABLE status within 7 days. If one Division I or Division 2 DC electrical power subsystem is inoperable for reasons other than those specified in ITS 3.8.4 ACTION A, ITS 3.8.4 ACTION B requires the restoration of the inoperable DC electrical power subsystem within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by providing a restoration time for inoperable Division I or Division 2 battery chargers and inoperable Division 1 or Division 2 battery subsystem for reasons other than for inoperable chargers (i.e., an inoperable battery or batteries) prior to requiring a plant shutdown.

Monticello Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 148 of 294

Attachment 1, Volume 13, Rev. 0, Page 149 of 294 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING The purpose of CTS 3.9.B.4 is to place the plant in a condition where the DC electrical power subsystem is no longer required. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. Proposed ITS 3.8.4 ACTION A provides a 7 day restoration time for one or more required battery chargers inoperable on Division 1 or Division 2. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The first priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (ITS 3.8.4 Required Action A.1).

Presuming that the battery discharge (if occurring) can be terminated and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit. The second tiered action proposes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 7 day restoration period, this appears to be an acceptable relaxation. Since the focus of this allowance is that battery capacity be preserved and assured, the means of accomplishing this may be to utilize the spare battery charger that could be employed within the initial 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , while in other cases it may be the degraded inservice charger that can continue to float the battery. Proposed ITS 3.8.4 ACTION B provides a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time for a Division 1 or Division 2 DC electrical power subsystem inoperable for reasons other than Condition A. This ACTION covers the inoperabilities associated with one or more batteries associated with Division 1 or Division 2 and any combination of batteries or charges associated with one division. If one of the required DC electrical power subsystems is inoperable, the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess plant status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Monticello Page 5 of 5 Attachment 1, Volume 13, Rev. 0, Page 149 of 294

Attachment 1, Volume 13, Rev. 0, Page 150 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 150 of 294

Attachment 1, Volume 13, Rev. 0, Page 151 of 294 DC Sources - Operating 3.8.4 Q1$ 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating [ 125 VDC and 250 VDCl 3.9A.4 LCO 3.8.4 The MDivision 1 and Division 2Istation serviceari EIelectrical power subsystems shall be OPERABLE.

IFB. 2A. and= (0 3.9A APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME (more required _

DOC L A. Oner orbattery A.1 Restore battery terminal chargeas onoel Idivxson inoperable.

voltage to greater than or equal to the minimum 0

established float voltage.

AND A.2 Verify battery float current S 121 ams .fr 250 VDC Once per M12j hours (0 ibatteriesand fj 1 am p or f AND 25VDbes/

I Divsion 1 or DivIsion 2 Restor biattery charger 7 days 4 [ eurd{to OPERABLE status.

[B. One [or two] batter y]ies. <.i Restore batter[y][ies] to j [2] hours]

on one divisions OPERAB(

inoperjagle,- ^

DOC Li ne;C electrical power l1?Restore DC electrical 1:j hours (

subsystem inoperable power subsystem to for reasons other than OPERABLE status.

Condition AR[ERB. 0 I

Divsion 1or Divisio BWRI4 STS 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 151 of 294

Attachment 1, Volume 13, Rev. 0, Page 152 of 294 DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.9.B.4 E:-Req~uired Action and I N.1 1Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 03 f(ssociated Completion IAND 0 imelof Co oCC~not me for tonl Al, B.

v~~

4

-L0

[service USbsysterij. Be in MODE 4.

4 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 0D E. [ Required Action and .1 Declare associated DG mediately]

inoperable.

associated Completio Time of Conditio , B, 0 or C] not or DGDC subs I/I ___ I h L SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4

4.9.B.4.a SR 3.8.4.1 Verify battery terminal voltage is greater than or 7 days equal to the minimum established float voltage.

250 VDC 4 DOCM.3 SR 3.8.4.2 Verify each required battery charger supplies MP-onthsm amps fog tntio-rvr subsystems, and amps foHQJsubsystemrs at greater than or (D equal to the minimum established float voltage for 204J hours.

OR Verify eachkattery charger can recharge the battery to the fully charged state within324 hour h whe (D0 supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. [for 250 VDC subsystems and 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months for 125 VDC subsystems]

BWR/4 STS 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 152 of 294

Attachment 1, Volume 13, Rev. 0, Page 153 of 294 DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY L g1 tr DOC M.4 SR 3.8.4.3 ~------NU I t ti- ---- _____

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

2. This Surveillance shall not normally be performed in MODE 1, 2, or 3. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and MI months maintain in OPERABLE status, the required emergency loads for the design duty cycle when EE~ 0 subjected to a battery service test.

BWR/4 STS 3.8.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 153 of 294

Attachment 1, Volume 13, Rev. 0, Page 154 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

1. The brackets have been removed and the proper plant specific information/value has been provided.

2. The term 'required" has been added since each 250 VDC subsystem has two battery chargers and a spare, but only two are required to be OPERABLE in each 250 VDC subsystem. In addition, each 125 VDC subsystem has one battery charger, with a spare battery charger that is common to both 125 VDC subsystems.

3. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been modified and renumbered, as necessary.

4. Changes are made (additions, deletions, and/or changes) to the ISTS, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

5. ISTS 3.8.4 ACTION E covers the default condition for an inoperable DG DC subsystem. The Monticello design does not include the DG DC subsystem, therefore the bracketed requirement has been deleted. In addition, due to this deletion, ISTS 3.8.4 Condition D (ITS 3.8.4 Condition C) has been modified accordingly. Specifically, the words "of Condition A, [B, or C]" have been deleted since the ACTION applies to all previous ACTIONS and there are no subsequent ACTIONS, and the words "for station service DC subsystem" has been deleted since the ACTION applies to all DC subsystem required by the LCO.

6. Typographical error corrected.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 154 of 294

Attachment 1, Volume 13, Rev. 0, Page 155 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 155 of 294

Attachment 1, Volume 13, Rev. 0, Page 156 of 294 DC Sources - Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating BASES BACKGROUND The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related equipment. Also, these DC subsystems provide DC electrical power to inverters, which in turn power the A C es As required by 10 CFR 50, A d. GDC 17 (Ref.1 , the KID SeAtiRonS1.2.10,ond6USAR -e eCtricalpower system is designed to have sufficient independenceand Section 1.2.11 (Refs. 1. 2, and redundanc addabil to perform its safety functions, assuming a 3 single failure. The DCjle trical power system also confor fo the recommen ationso egulatory Guide 1.6 (Ref. 2 adEE-308

-T'NERfT 1r The station Irvice DC power sou ces provide both motite and control power to sel cted safety related e uipment, as well as rcuit breaker control pow r for the nonsafety rqated 4160 V, and all 00 V and lower, AC distributon systems. Each D subsystem is energi ed by one 125/250 V tation service batte and three 125 V batt ry chargers (two normally i ervice chargers and ne spare charger). ach battery is exclusivel associated with a si gle 125/250 VDC bus Each set of battery ch rgers exclusively as ociated with a 125/255 VDC subsystem cannot b interconnected with ny other 125/250 VD subsystem. The 0 normal a d backup chargers ae supplied from the s me AC load groups for whicthe associated DC s bsystem supplies the control power. The loads b een the redundant 25/250 VDC subsyst m are not transfer ble except for the A omatic Depressuriza on System, the logic circuits nd valves of which re normally fed from the Division 1 DC syste The diesel g nerator (DG) DC po er sources provide c trol and instrumentation power for their re pective DG. In additi n, DG 2A and 2C DC power ources provide circul breaker control pow r for the loads on the 4160 2E, 2F, and 2G em rgency buses. Each G DC subsystem 0 is energi ed by one 125 V batery and one 125 V b ery charger.

Provisi hs exist for connectio a portable alternate attery charger.

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC loads are automatically powered from the station batteries.

BWR/4 STS B 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 156 of 294

Attachment 1, Volume 13, Rev. 0, Page 157 of 294 B 3.8.4 Q3 INSERT I The Division 1 and Division 2 250 VDC electrical power subsystems provide power to the associated uninterruptible AC power supply (UPS). The Division 1 electrical power subsystem also provides power to support the Reactor Core Isolation Cooling (RCIC) System motor operated valves, the RCIC turbine pumps, and other non-critical loads. The Division 2 electrical power subsystem supplies power for the High Pressure Coolant Injection (HPCI) System motor operated valves, the HPCI auxiliary oil pumps, and the Control Room Ventilation System control circuits. Each 250 VDC electrical power subsystem consists of two in series 125 VDC batteries, two normally inservice 125 VDC chargers, a spare 125 VDC charger, and all of the control equipment and interconnecting cabling to the associated distribution cabinet. Each battery is exclusively associated with a single division. Each set of battery chargers exclusively associated with a 250 VDC electrical power subsystem cannot be interconnected with the other 250 VDC electrical power subsystem. The inservice and spare chargers are supplied from the associated AC load group.

Division 1 and Division 2 125 VDC electrical power subsystems provide control power to the associated 4.16 kV essential bus and for each of the two 480 VAC essential load centers. Each 125 VDC electrical power subsystem consists of a battery, a charger, and all the control equipment and interconnecting cabling up to the associated distribution panels. The inservice chargers are supplied from the associated AC load group. The design includes a spare charger that can be used for either the Division 1 or Division 2 125 VDC electrical power subsystem.

However, the spare charger is supplied from the Division 2 AC load group. The two battery buses can be connected to each other only by manually operating two disconnect switches in series; one switch is located at each battery bus.

When two independent divisions of 125 VDC power are required, the two battery buses are not operated in a cross-connected configuration.

Insert Page B 3.8.4-1 Attachment 1, Volume 13, Rev. 0, Page 157 of 294

Attachment 1, Volume 13, Rev. 0, Page 158 of 294 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

The DC power distribution system is described in more detail in Bases for "Distribution System - Operating," and LCO 3.8.J, "Distribution System - Shutdown."

Each DC battery subsystem is separately housed in a ventilated room aPart from its chiastribution center .*Each subsystem ii located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems such as batteries, battery chargers, or distribution panelsK ,except the common standby 125VDC baterychargermaybe shared (79-

[Diision I and Diision 2 between the Division 1 end Division 2 125 VDC electrical power subsystems l1 \

[250 VDC a 4battery has adequate storage capacity to meet the duty cycle(s) discussed in SAR, a r (Ref 4). The battery is designed withJ additional capacity m a oe t at required by th design duty cycle to allow for temperature variations and other factors. storage Each Division 1 and Division 2 125 VDC battery has adequate capacity to meet the duty cycle(s) discussed In USAR, Section 8.5.2.1 (Ref 5).

The batteries for DC electrical power subsystems are sized to produce 0 red ca at8yo E3\1re naeplte atng, corresponoitci to warranted W Capcit atendof~~r~ycls ad te 10%design denfand:! The minimum design voltage limit is 105/210 V.

The battery cells are of flooded lead acid construction with a nominal 2 specific gravity of 1. /;hsspecific gravity corresponst Opn IcrutbteyvlaeproXimately 120 V for a [581 cgaterY(~.

vltae f [2. ,vo ts per cell (Vpc))FThe open circuit voltage is the Icel voltage maintained when there is no charging or discharging. Once fully

_ chgedlwith its open c tage 2 [2.065] Vd, the battery cell will - m m maintain~ capacity forgi30 days without further charging per I " J manufacturers instructions. Optimal long term performance however, is obtained by maintaining a float voltage 2.20 to 2.2j Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self discharge. The nomi oat voltage of [2.22] Vpc corresrs to a total float voltage outp f [128.8] V for a [58] cell battery liscussed in the ILMER.C~ha tf1 (Ref. )

Each battery charger of DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each station service battery charger has sufficient (

excess capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads J.

BWR/4 STS B 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 158 of 294

-. Tv.. -

Attachment 1, Volume 13, Rev. 0, Page 159 of 294 B 3.8.4 0 INSERT 1A The common standby 125 VDC battery charger is located in a room separate from the other 125 VDC battery chargers electrical power subsystems.

0 INSERT lB greater than required for a design basis accident and monitored to ensure battery capacity will remain > 90% during the operating cycle.

Insert Page B 3.8.4-2 Attachment 1, Volume 13, Rev. 0, Page 159 of 294

Attachment 1, Volume 13, Rev. 0, Page 160 of 294 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.

The initial conditions of Design Basis Accident (DBA) and trapsient 14 APPLICABLE SAFETY Enlses in M-"SAR, pter fief.5)and ChapteWRe.f6), 0 0 ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power and 0D

b. A worst case single failure.

The DCtources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0D oeting BWR14 STS B 3.8.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 160 of 294

Attachment 1, Volume 13, Rev. 0, Page 161 of 294 DC Sources - Operating B 3.8.4 BASES 7Divison 1 and -l LCO The DC electrical power subsystems - with: 1) each statio ervice DC 0 subsystem consisting of two 125 V batteries in series o batt(

ivsl 1 and chargers and the corresponding control equipment and mt rconnectin Division 2125 V cabling supplying power to the associated busnd2) eachl[DC J (i) A) subsystem consisting of one battery bn one attery charger, and the supp control euiment and interconnecting cabling are required-v to be OPERABLE to ensure the availability of the required pdwer to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref.t). A9 (i)

APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transientsA and . k

b. Adequate core cooling is provided, and containment integrity and other a functions are maintained in the event of a postulated DBA. 0 The DC electrical power requirements for MODES 4 and 5 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

ACTIONS A.1. A.2, and A.3 Condition A represents one division with onelor t/attery chargers (i) (D inoperable (e.g., the voltage limit of SR 3.8.4.1 is no maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within M1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

BWR/4 STS B 3.8.44 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 161 of 294

Attachment 1, Volume 13, Rev. 0, Page 162 of 294 B 3.8.4 Q INSERT 2 While the spare Division 2 125 VDC battery charger can be used to supply either the Division I or Division 2 125 VDC subsystem, it can be used to meet the LCO requirements only for the Division 2 125 VDC subsystem. If it is supplying the Division 1 125 VDC subsystem, the Division 1 125 VDC subsystem is inoperable.

Insert Page B 3.8.4-4 Attachment 1, Volume 13, Rev. 0, Page 162 of 294

Attachment 1, Volume 13, Rev. 0, Page 163 of 294 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

REVIE ER'S NOTE-----

A plant that cannot meet the 12 our Completion Time ue to an inherent battery c rging characteristic n propose an altema eitime equal to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months us the time experien ed to accomplish the xponential charging current ortion of the battery arge profile following/he service test (SR 3. .4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 11:4 hours, avoiding a premature shutdown 0 with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within I14 hours (Required Action A.2).

batteries and less Required Action A.2 requires that the battery float current be verified as 1 amp for125cO less than or equal tol4 amp This indicates that, if the battery had been

. 0 batteries discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial 121hour period the battery float current is not less than or equal tonj amp his indicates 0 there may be additional battery problems and the battery must be declared inoperable.

BWR/4 STS B 3.8.4-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 163 of 294

Attachment 1, Volume 13, Rev. 0, Page 164 of 294 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

Required Action A.3 limits the restoration time for the inoperable battery charger to 7 days. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 7 day Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1

4 --- REVIE VER'S NOT-- - -

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ompletion Times of equired Actions B.1 nd C.1 are in brackets. ny licensee wishing t request a longer Co pletion Time will need to de onstrate that the Ion er Completion Time i appropriate for the plant i accordance with the uidance in Regulato Guide (RG) 1.177, "An Approach for Plant-S ecific, Risk-Informed ecisionmaking:

Technical pecifications."

Condition B represents one divi ion with one [or two] atter[y][ies]

inoperably. With one [or two] tter[y][ies] inoperabl , the DC bus is being su plied by the OPERA LE battery charger[s]. Any event that 0 results i a loss of the AC bus upporting the battery harger[s] will also result in oss of DC to that divi ion. Recovery of the C bus, especially if it is due o a loss of offsite po0er, will be hampered y the fact that many of the c mponents necessary or the recovery (e.g., iesel generator control nd field flash, AC loa shed and diesel gen rator output circuit breaker , etc.) likely rely upo the batter[y][ies]. In ddition the energiz tion transients of an DC loads that are be ond the capability of the ba ry charger[s] and no mally require the assi tance of the batter[ [ies] will not be able o be brought online. he [2] hour limit allows ufficient time to effe restoration of an inoerable battery given that th majority of the cond ions that lead to batte inoperability (e.g.,

loss o battery charger, batt ry cell voltage less th n [2.07] V, etc.) are identi d in Specifications 3 8.4, 3.8.5, and 3.8.6 t gether with additional speci c completion times. l BWR/4 STS B 3.8.4-6 Rev. 3.0, 03/31104 Attachment 1, Volume 13, Rev. 0, Page 164 of 294

Attachment 1, Volume 13, Rev. 0, Page 165 of 294 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) 0 Condition E represents one division with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized 0

during normal operation. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC Distribution System division.

If one of the required DC electrical power subsystems is inoperable for Ereasons other than Condition Atl (e.g., inoperable battery charger and @

associated inoperable baetry), the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on m Regulatory Guide 1.93 (Ref.jgfand reflects a reasonable time to assess (ID unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

i.1 5andVD.25 If the inoperable statioervic DC electrical power subsystem cannot be 0

restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required 0 plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. I 1 BWR/4 STS B 3.8.4-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 165 of 294

Attachment 1, Volume 13, Rev. 0, Page 166 of 294 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

E.1 If the DG DC electrical p er subsystem cannot be restored OPERABLE status inhe associated Completion Time, th ssociated DG may be incap e of performing its intended functi and must be 0D immediately de ared inoperable. This declaration o requires entry into applicable C ditions and Required Actions for a inoperable DG, LCO 3.8. "AC Sources - Operating."

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a r(freach 250 fully charged state while supplying the continuous steady state loads of VDC subsystem the associated DC subsystem. On float charge, battery cells will receive 127.6 V (for adequate current to optimally charge the battery. The voltage each 125 VDC requirements are based on the nominal design voltage of the battery and subsystem are consistent with the minimum float voltage established by the battery 132 manufacturer a2.2cg Vpc o vo ager ai an tery plates

,at the battery terminals). This in a condition that supports 0

maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency isl IEEE-450 (Ref. ). t fenilwith manufacturer recommendations and .

C eoneivawhn I 0 SR 3.8.4.2 This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref.Mt the battery charger supply is recommended to be based on the largest combined demands of the 0

various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensures that these requirements can be satisfied.

BWR/4 STS B 3.8.4-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 166 of 294

Attachment 1, Volume 13, Rev. 0, Page 167 of 294 DC Sources - Operating B 3.8.4 BASES nrser~ 11mr-Mar-SAse{o_+ +

SURVEILLANCE : tUI¶mtNiV;I l kwUilifIUlU) for the 250 VDC subsystems and >50 amps 150 for the 125 VDC subsystems This SR provides two options. One option requires that each batte charger be capable of supplying [40] amps at the minimum established (

floatvoltage for hours. The ampere requirements are based on the output rating o the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at leastg2M hours. 0 The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is 1;] amps.

for 250 VDC batteries and < 1 amp for 125 VDC bateres 0

The Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during theseE snonttfintervals. In addition, this Frequency is intended to be consistent with expected tuel M

0 cycle lengths.

rfor the 250 VDC electrical power I system and Reference S for the 125 SR 3.8.4.3 LVDC electrical power system A battery service test is a special test of the battery's capability, as found to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 4. i Th rqecy of it h eom toso Rglor ud1.2(e.9aReguegltr Guide 1.2 (e 0),

which St ht th evc etsod Iatrbe pefrd duin refueln oprtion oatsm ote ua ihinrvlbteen tests not tok e [8 months].l This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

acceptable, given plant conditions required to perform the test and the other requirements existing to ensure adequate battery performance during the 24 months Intervals. In addition, this Frequency 0D Is Intended to be consistent with expected fuel cycle lengths.

BWR/4 STS B 3.8.4-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 167 of 294

Attachment 1, Volume 13, Rev. 0, Page 168 of 294 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES 1. 10 CFR 50, AppendA, GDC 17. , 1. USAR. Section 1.2.6.

2. Regulatory Gu 1.6, March 10,1971.

2. USAR, Section 1.2.10. 0D

3. USAR. Section 1.2.1 1.,

3. IEEE Sta ard 308, 1978.

'D-.S

-4 AR, 7e =:81+-- ~--~

5. USAm, Section I t.5.1. o001 l 5. FSh-apter [6].l-r 7. USAR, Section 14.7.2.3.2.

I'A6.SAR, Chapter[J.* 14

<30 rn-i Regulatory Guide 1.93. 00 IEEE Standard 450, 1995.

He001 Regulatory Guide 1.32, February 1977.

ho. Regulatorvm.gue129. December 1974. 1 0D BWR/4 STS B 3.8.4-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 168 of 294

Attachment 1, Volume 13, Rev. 0, Page 169 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific information/value is provided.

3. Changes are made to reflect changes made to the Specifications.

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

5. The Reviewer's Note is deleted as it is not part of the plant-specific ITS.

6. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.

7. Typographical error corrected.

8. Changes are made to be consistent with the name of the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 169 of 294

Attachment 1, Volume 13, Rev. 0, Page 170 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 170 of 294

Attachment 1, Volume 13, Rev. 0, Page 171 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume'13, Rev. 0, Page 171 of 294

, Volume 13, Rev. 0, Page 172 of 294 ATTACHMENT 5 ITS 3.8.5, DC Sources - Shutdown , Volume 13, Rev. 0, Page 172 of 294

Attachment 1, Volume 13, Rev. 0, Page 173 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 173 of 294

, Volume 13, Rev. 0, Page 174 of 294 ITS 3.8.5 Page 1 of 1 , Volume 13, Rev. 0, Page 174 of 294

Attachment 1, Volume 13, Rev. 0, Page 175 of 294 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 The CTS does not have any requirements for the DC Sources in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. ITS LCO 3.8.5 requires Division 1 or Division 2 125 VDC electrical power subsystem to be OPERABLE. An appropriate ACTION and a Surveillance Requirement are also provided. This changes the CTS by incorporating the requirements of ITS 3.8.5.

The DC electrical power system provides emergency DC electrical power to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident involving movement of irradiated fuel in the secondary containment. This change is acceptable since the DC Sources -

Shutdown satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). This change is designated as more restrictive because it adds new requirements to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 175 of 294

Attachment 1, Volume 13, Rev. 0, Page 176 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 176 of 294

Attachment 1, Volume 13, Rev. 0, Page 177 of 294 DC Sources - Shutdown 3.8.5 CIS 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown DOC M1 L.CO 3.8.5 [DC ele cal power subsyste shall be OPERABL , 4 o support the DC electric power distribution s system(s) required VLCO 3.8.10, "Dist$ ution Systems - Shr~own."]

0D Division 1 or Division 2 125 V k-4 DC electrical power subsystem shall be OPERABL4_i l 0

-REVI OWER'S NOTE----

This sec d option above applieg for plants having a pr -ITS licensing basis (C 5) for electrical power requirements during s utdown conditions that req ired only one DC elec rical power subsystem o be OPERABLE.

Action and the bracketed o ional wording in Cond'ion B are also elimin ted for this case. The irst option above is adopted for plants that

/(S) have CTS requiring the sa e level of DC electri power subsystem supp rt as is required for p wer operating conditio s.

-- ~

[torequired support one division of the DC Electrical Power Distribution System by LCO 3.8.8, 'Distribution Systems - Shutdown.'

DOC M APPLICABILITY: MODES 4 and 5, During movement of Isecondaryl containment.

irradiated fuel assemblies in the 0 ACTIONS

~------NOTE--------

DOC M1 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

[A. One [ortw battery A.1 Re tore battery terminal hours charger[s n one v tage to greater than or division] operable. e ual to the minimum stablished float voltage. 03 AND AND The r dundant division batte and chargeris]

OP BLE.

BWR/4 STS 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 177 of 294

Attachment 1, Volume 13, Rev. 0, Page 178 of 294 DC Sources - Shutdown 3.8.5 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Verify battery flob current Once per [12] hours

< [2] amps.

AN A. Restore batt charger[s] 7 ays]

to OPERAB status. .(D DOC MA1 fIOnermore] fequired DC electrical power B.1 ,eclare affecto requi feature(s) in71 erable.

0 subsystems inoperable Rtq reason o ter a OR lC~onditionk" 3.1 Suspend CORE Immediately (3 (D ALTERATIONS. -I. -0

-0 equire Action nd ssocia d Corn letion 4 AN ime of onditi n A not 6.2' S'uspend movement of Immediately et.] I [re~nty irradiated fuel assemblies in the >. i

_00 RsecondarA containment.

-0 AND OZ2.3 Initiate action to suspend Immediately operations with a potentia for draining the reactor vessel. 00

[X.4iA Initiate action to restore Immediately 0D required DC electrical power subsystemsr to 00 OPERABLE status.

L &

BWR/4 STS 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 178 of 294

Attachment 1, Volume 13, Rev. 0, Page 179 of 294 DC Sources - Shutdown 3.8.5 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

+

SR 3.8.5.1 -- k--Nut t- - -__

DOC M.1 The following SFK not required to be performed:

ISR 3 . .2 and SR 3.8.4.3.

0D For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.3 0

BWR/4 STS 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 179 of 294

Attachment 1, Volume 13, Rev. 0, Page 180 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.5 and "Reviewer's Note" have been deleted since the current licensing basis-does not specify any requirements for the DC electrical power subsystems to be OPERABLE in MODES 4 and 5 or during movement of irradiated fuel assemblies in the secondary containment. Therefore, the option to require one complete DC electrical power subsystem will be added, consistent with the AC Sources requirements of ITS 3.8.2. ISTS 3.8.5 ACTION A and the bracketed optional wording in Condition B have also been deleted. The subsequent Condition and Required Actions have been renumbered, as applicable.

2. The second option of ISTS LCO 3.8.5 is not specific as to what the DC electrical power subsystem must be powering. The LCO has been modified to require the Division 1 or 2 125 VDC electrical power subsystem to be powering a DC train required OPERABLE by LCO 3.8.8. This is consistent with a similar change approved by the NRC in the DC Cook Units I and 2, Quad Cities 1 and 2, Dresden Units 2 and 3, and LaSalle Units 1 and 2 ITS conversions.

3. The brackets have been removed and the proper plant specific information/value has been provided.

4. ISTS 3.8.5 Required Action B.1 provides an option to declare affected required feature(s) inoperable with one or more required DC electrical power subsystems inoperable. The ISTS Bases states that this is acceptable because the remaining train with DC power available may be capable of supporting sufficient features to allow continuation of CORE ALTERATIONS and fuel movement. Thus, this Required Action assumes two DC power sources are required by the LCO. This option has been deleted since only Division 1 or Division 2 125 VDC electrical power subsystem is required to be OPERABLE by the LCO. Subsequent Required Actions have been renumbered and modified, as applicable.

5. Change made to be consistent with the Writers Guide for the Improved Standard Technical Specifications, NEI 01-03.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 180 of 294

Attachment 1, Volume 13, Rev. 0, Page 181 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 181 of 294

Attachment 1, Volume 13, Rev. 0, Page 182 of 294 DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE 2_The initial conditions of Design Basis Accident and ransient anal ses in SAFETY gTo SAR, Chapter ef. 1) and Chapter (Ref. ,assume that )

ANALYSES Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 4 and 5 and during movement of [re~jtly irradiated fuel assemblies ensures that:

0

a. The facility can be maintained in the shutdown or refueling condition for extended period

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statu nd

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the Yessel or a fuel handling accidentRinvolving handlin r irradiated fuel. P ue to radioactiv ecay, DC electrical powr is onil 0

requT o miigate fuel handl accidents involving ha ling rcently irradiated fuel (i.e., el that has occupied pa of a critical 03 eactor core within the prvious WX1 days). / 0D In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained BWR/4 STS B 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 182 of 294

Attachment 1, Volume 13, Rev. 0, Page 183 of 294 DC Sources - Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYSES (continued) within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

-Shudsw The DC $ourcesfsatisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 LCO required to De UOP-EABLE to supporrilreauireal I neJppC-istrID.utIo subsyste required OPERABLE by LCO 3.8.R "Distribution S s en

- Sh-uldo-wri This requirement ensures the availityo sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents jinvolving handlingrct irradiated fueU and inadvertent reactor vessel draindown).

BWR/4 STS B 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 183 of 294

Attachment 1, Volume 13, Rev. 0, Page 184 of 294 DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of [r-ently irradiated fuel assemblies in the secondary containment provide assurance that:

0D

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel I;I)

b. Required features needed to mitigate a fuel handling accident

[~involving handling re irradiated fuel[(i7Le-., fuel that hg~

0

~a_

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are availableijand

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, or 3 would require the unit to be shutdown unnecessarily.

A.1 A.2 dnd A.3

-- -REV W ER'S NOTE---

ACTION A is included only whe n plant-specific imple entation of LCO 3.8.5 intludes the potential to equire both divisions o the DC System to 0 be OP RABLE. If plant-spe fic implementation res ts in LCO 3.8.5 requiL'g only one division of/the DC System to be PERABLE, then ACTI N A is omitted and A TION B is renumbere as ACTION A.

BWR/4 STS B 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 184 of 294

Attachment 1, Volume 13, Rev. 0, Page 185 of 294 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Conditio A represents one divi ion with one [or two] b tery chargers inoperab (e.g., the voltage limof SR 3.8.4.1 is not m aintained). The ACTION provide a tiered respnse that focuses on re urning the battery to the fuly charged state and re toring a fully qualified harger to OPERA LE status in a reason ble time period. Requied Action A.1 requires hat the battery termin I voltage be restored t greater than or equal to he minimum establish d float voltage within hours. This time provide for returning the inop rable charger to OPER BLE status or providin an alternate means restoring battery term al voltage to greater han or equal to the mi imum established floa voltage. Restoring the batt ry terminal voltage to reater than or equal to the minimum establilied float voltage provi es good assurance th within [12] hours, the batery will be restored to i s fully charged conditin (Required Action A.2) fr m any discharge that ight have occurred du to the charger inoper bility.

RE IEWER'S NOTE---

A plan that cannot meet the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Ti e due to an inherent batte charging characteristi can propose an altern te time equal to 2 hou plus the time experie ced to accomplish the exponential charging curret portion of the battery harge profile following the service test (SR 3 8.4.3).

A dis harged battery havingterminal voltage of at I ast the minimum esta ished float voltage Ind cates that the battery i on the exponential char ing current portion (th second part) of its rec arge cycle. The time to re urn a battery to its full charged state under th s condition is simply a func ion of the amount of th previous discharge a d the recharge char cteristic of the battery Thus there is good a urance of fully rech rging the battery withi [12] hours, avoiding premature shutdown with its own attendant risk.

If e tablished battery termi al float voltage cannot e restored to greater tha or equal to the minim m established float vol age within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the harger is not operating in the current-limiting ode, a faulty charger is i dicated. A faulty char er that is incapable of aintaining established ba ery terminal float volta e does not provide as urance that it can revert to nd operate properly in the current limit mode at is necessary during th recovery period follow ng a battery discharge vent that the DC sy tem is designed for.

BWR/4 STS B 3.8.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 185 of 294

Attachment 1, Volume 13, Rev. 0, Page 186 of 294 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

If the char er is operating in the rrent limit mode after hours that is an indication hat the battery is parti Ily discharged and its apacity margins will be red ced. The time to retu n the battery to its full charged condition n this case is a functio of the battery charger capacity, the amount o loads on the associatd DC system, the amo nt of the previous ischarge, and the rec arge characteristic of e battery. The charge ti e can be extensive, d there is not adequa assurance that it can be r charged within [12] h rs (Required Action A ).

Require Action A.2 requires t at the battery float curr nt be verified as less tha or equal to [2] amps. This indicates that, if toe battery had been discha ed as the result of the noperable battery cha ger, it has nrow been f ly recharged. If at thelexpiration of the initial 12] hour period the 0

battery oat current is not les than or equal to [2] a ps this indicates there ay be additional batte: problems and the ba ery must be declard inoperable.

Requi d Action A.3 limits th restoration time for th inoperable battery charg r to 7 days. This actin is applicable if an alt mate means of resto ing battery terminal voItage to greater than or qual to the minimum esta lished float voltage ha been used (e.g., bala ce of plant non-Class 1E battery charger). The 7 ay Completion Time r flects a reasonable time o effect restoration of he qualified battery ch rger to OPERABLE stat s.

qire required o Division or Division 2125 VDC 1g n te y 1[I.22. * ** .

electrical power subsystem Isinoperable and34required t he minimum DC power sources are not available.

Threfore, suspension of 0

iifnpmore than one p distribution subsystem ented according to the a3.8.10,fthed D subsystems remaining OPmAny one or more oteth DC powerl ns ered inoperable may be capable e aownsufficient required features~t allow continuationi of CORE ATfTINS,

[recently] irradiat fuel movement, and operateot d draining the ea or vessel.] By allowance of the opti to declare ing o tential for 0 required reuinoperable with associated DC powrr sources inoperable, apprpriate restrictions are implemrented In accordance with the affected system LCOs' ACTIONS. In many inst hces, this option may involve unde ird administrative efforts. Therefore, te allowance for sufficiently c nservative actions is made (i.e., to su ipent$C`ORE ALTERATIONS, movemrent of l[resehntly irradiated fuel assemblies, and any activities that could result in inadvertent draining of the reactor 0

vessels 0 BWR/4 STS B 3.8.5-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 186 of 294

Attachment 1, Volume 13, Rev. 0, Page 187 of 294 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsysterrMff and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety 0

systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may 0

be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

'(v1)

REFERENCES I 1. FSA, chapter [61.1 aEls SAR, Chapter[W 00 BWRI4 STS B 3.8.5-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 187 of 294

Attachment 1, Volume 13, Rev. 0, Page 188 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific information/value is provided.

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

4. Changes are made to the Bases which reflect changes made to the Specifications.

5. Changes are made to be consistent with the name of the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 188 of 294

Attachment 1, Volume 13, Rev. 0, Page 189 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 189 of 294

Attachment 1, Volume 13, Rev. 0, Page 190 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 190 of 294

, Volume 13, Rev. 0, Page 191 of 294 ATTACHMENT 6 ITS 3.8.6, Battery Parameters Attachment 1, Volume 13, Rev. 0, Page 191 of 294

Attachment 1, Volume 13, Rev. 0, Page 192 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 192 of 294

( C C ITS 3.8.6 ITS 3.0 LIMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.9 4.9 AMILARY ELECIR C, Ir/ Appffeabilitz 0-9 ADD 0

Applies to awdaty electrical power system. Applies to the perad testing requirements of the audilary electrical system. 0)

Objectves / bjectfl: / 0 To ass an adequate supply of electrical durng CD~ plant ro n. Verify the ope inty of the auxilIary electrical system. CD) 01 3.8.6 Spegfatlon: .:

Applicability A. The reactor shall not be mad criticalrunless all the A. Surveillance testing shall be performed as follows:

0 followino requirements are satisfied: 0

1. Substation Switchyard Battery -U

0) 1. At least two (2)NSP transmission lines, associated a) switchgear, and at least two offshte power sources a. Every week the specifc gravity and voltage of CD CD are fully operational and enMrgized to carry power to the pilot cell and temperature of adjacent cells 0 PD the plant 4160V AC buses as follows: and overall battery voltage shall be measured. See ITS 3.8.1 } CD 0 a. 2R and 1R tmnsformers, or b. Every three months the measurements shall be made of voltage of each cell to nearest 0.01 0

b. 1R and lAR transformers, or volt, specific gravity of each cell, and temperature of every fifth cell.

to c. 2R and IAR transformers (source from 10 CD transfomer) 3.914.9 199 10/16/87 Amendment No. 51 Page 1 of 3

C. C ITS 3.8.6 3.0 UMING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS I r

2. Both diesel generators are operabl 5ee ITS 3.8.1 }

0) feeding their designated 4160 volt I! D}

0 5 3. (a) 4160V Buses #15 and #16 are energized. L'See ITS 3.8.7 }

C, CD CD (b) 480V Load Centers #103 and #104 are energized.

-I 0 0 te.

CD See ITS 3.8.4 and ITS 3.8.7 l I.

B. When the mode switch Is In Run, the availablity of L J CD electric power shall be as specified In 3.9.A, except as _

CD specified In 3.9.B or the reactor shall be placed In the See ITS 3.8.1, p.r1..

cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.4, and >

0 ITS 3.8.7 0 CD

1. Transrnisslon Unes

)

CD From and after the date that Incoming power Is to available from only one Une. reactor operation Is ( See ITS 3.8.1} 0) pemissible only during the succeeding seven days to CD unless an additional line Is sooner placed in service providing both the emergency diesel generators are to CD operable.

0 (0:1 Co

-4' CD I 3.914.9 200 08/27/02 Amendment No. 1, 104, 129 Page 2 of 3

ITS 3.8.b ITS 3.0 UMING CONDIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

4. Station Battery System 4. Station Battery System ys C If oneofthetwo125Vbatterysystemsor oneof SR3.8.6.2 a. Every and a Seel384 0 the two 250 V battery systems is made or found to SR 3.8.6.4 the pErot cell and terperature th of C be Inoperable for any reason, an orderly shutdown .nd cSlls rall baplot Naesll o4eae o_h of the reactor shall be Initiated and the reactor water meawred. Cd temperature shae be reduced to less than 212°F 4 [Add proposed 3.8.L33 M2 -

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless such battery systems are SR 3.8.6.5 b. Every three months the measurements shall be volage llmit -

__sooner made aoperabl_ / made of voita eaC O r a [ay" eacn cell] i' Ad r ITS 3..64 dd proposed Note .

3 ACTIONS Note p _ A3 CD and ACTIONS A. SR 3.8.6.6 c. Everyreein the station batteries proqused S 6 B,C,D,E,andF _ L shallbesub t a is ar n;. ,a n ~ty ana voitage ot ilies W (D X 5 . 24V Battery Systems o Add proposed battety0

a. Every week the specific gravity and voltage of capacty lmit < )M.3

5. 24V Battery Systems the piot cell and temperature of adjacent calls to From and after thedate that one of the two 24V and overall battery voltage shall be measured. to (D battery systems Ismade or found to be Inoperable b. Every three months the measurements shall be to for any reason, refer to Specificaton 3.2 for made of voltage of each cell to nearest 0.01 C Un appropriate action. volt, specific gravity of each cell, and all O temperature of every fifth cell. 0 Ah 3.8.4}

IeeTS 0 3.9,4.9 203 3124/86 Amendment No. 3,41 Page 3 of 3

Attachment 1, Volume 13, Rev. 0, Page 196 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 .CTS 3.9.A does not allow the reactor to be made critical unless the requirements in CTS 3.9.A.4 are met. CTS 3.9.A.4, in part, requires the 125 VDC and 250 VDC batteries to be charged and in service and the associated battery chargers to be OPERABLE. Thus, the battery parameter requirements are covered by this LCO statement. ITS 3.8.6 requires the battery parameters associated with the 125 VDC and 250 VDC batteries to be within limits whenever the associated DC electrical power subsystems are required to be OPERABLE.

The requirements for the batteries and chargers are included in ITS 3.8.4 and ITS 3.8.5. This changes the CTS by dividing the requirements for the battery and the requirements for battery parameters into two separate Specifications, and specifies the Applicability of the Battery Parameter requirements to be the same as the DC Sources they support.

The purpose of ITS 3.8.6 is to cover the battery parameter requirements for the Division 1 and Division 2 250 VDC and 125 VDC batteries. There are no technical changes as a result of this change since it simply converts the CTS into the format of the ITS. Any technical changes to the battery parameters are discussed below. Any changes related to the Applicability of the Division 1 and Division 2 250 VDC and 125 VDC batteries (and hence, the Applicability of the Battery Parameter requirements) are discussed in the Discussion of Changes for ITS 3.8.4 and ITS 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.9.B.4.c requires the "rated load discharge test" (i.e., a "performance discharge test" in the ITS) to be performed, but it does not provide any restrictions for when the test may be performed. ITS SR 3.8.6.6 requires the same test, however a Note to SR 3.8.6.6 specifies that this Surveillance shall not normally be performed in MODE 1, 2, or 3. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. In addition, the Note further states that credit may be taken for unplanned events that satisfy the SR. This changes the CTS by adding a specific restriction as to when the Surveillance can be performed.

Currently, this Surveillance would not normally be performed while operating (i.e.,

MODES 1, 2, and 3), since performing this Surveillance would result in the inoperability of the associated battery, and the Actions require a plant shutdown if the battery is inoperable. The ITS Note clearly presents the current practice on when the test may be performed and the allowance of the current practice of taking credit for unplanned events, provided the necessary data is obtained. This Monticello Page 1 of 8 Attachment 1, Volume 13, Rev. 0, Page 196 of 294

Attachment 1, Volume 13, Rev. 0, Page 197 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS change is designated as administrative because it does not result in technical changes to the CTS.

A.4 This change to CTS 4.9.B.4.c is provided in the Monticello ITS consistent with the Technical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to USNRC, dated June 30, 2004. As such, this change is administrative.

MORE RESTRICTIVE CHANGES M.1 ITS SR 3.8.6.1 requires the verification every 7 days that each battery float current is < 2 amps for the 250 VDC batteries and < 1 amp for the 125 VDC batteries. However, as Noted, this requirement is not required to be met when battery terminal voltage is less than the limit of SR 3.8.4.1. ITS SR 3.8.6.3 requires the verification every 31 days that each battery connected cell electrolyte level is greater than or equal to the minimum established design limits.

CTS 4.9.B.4, which specifies the Surveillances for the Division 1 and Division 2 125 VDC and 250 VDC batteries, does not require these Surveillances. This changes the CTS by adding explicit Surveillances for battery float current and battery connected cell electrolyte level.

The purpose of SR 3.8.6.1 is to assist in the determination of the state of charge of the battery while the purpose of ITS SR 3.8.6.3 is to ensure the battery connected cell electrolyte level is greater than or equal to the minimum established design limits to ensure the batteries can provide the required current and voltage to meet the design requirements. The specified float current is based on the float current that is indicative of a charged battery and the required electrolyte level maintains adequate electron transfer capability. These Surveillances are consistent with IEEE 450-1995. This change is acceptable since the Surveillances are necessary to help ensure the batteries remain OPERABLE. This change is designated as more restrictive because explicit Surveillance Requirements have been added.

M.2 CTS 4.9.B.4.a requires the pilot cell voltage to be measured every week and CTS 4.9.B.4.b requires each cell voltage to be measured every 3 months.

However, no voltage limit is provided in the CTS. ITS SR 3.8.6.2 requires monthly verification that each battery pilot cell voltage is > 2.07 V and ITS SR 3.8.6.5 requires quarterly verification that each battery connected cell voltage is > 2.07 V. This changes the CTS by specifying an acceptance criteria for pilot cell and battery connected cell voltage limits. The change in the Frequency for CTS 4.9.B.4.a is discussed in DOC L.2.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 and SR 3.8.6.5 is to ensure the cell voltages are greater than or equal to the short term absolute minimum voltage. This change is acceptable because a limit is specified for cell voltage where one was not previously specified. This change is designated as more restrictive because more stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Monticello Page 2 of 8 Attachment 1, Volume 13, Rev. 0, Page 197 of 294

Attachment 1, Volume 13, Rev. 0, Page 198 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS M.3 CTS 4.9.B.4.c requires the "rated load discharge test" (i.e., a "performance discharge test" in the ITS) to be performed, but it does not provide a capacity limit. ITS SR 3.8.6.6 requires the same test, but provides a limit of > 90% of the manufacturer's rating. This changes the CTS by specifying the battery capacity limit.

The purpose of CTS 4.9.B.4.c is to verify the capacities of the batteries are acceptable. The proposed limit is consistent with a commitment in a letter from the Northern States Power Company to the NRC dated November 22, 1991 in a letter concerning the Monticello Station Blackout Evaluation. Since the proposed limit is consistent with current practice and with the letter the change is considered acceptable. This change is designated as more restrictive because it adds a specific limit to the CTS where non previously existed.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.9.B.4.b requires each cell voltage to be measured "to the nearest 0.01 volt." ITS SR 3.8.6.5 requires verification that each battery connected cell voltage is within a specified limit. This changes the CTS by relocating the details that the cell voltage measurement be "to the nearest 0.01 volt" to the ITS Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the cell voltage be measured. The details of how the cell voltages are measured does not need to appear in the Specification in order for the requirement to apply.

Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.9.B.4 requires a reactor shutdown if one of the two 125 VDC battery systems or 250 VDC battery systems is inoperable. In addition, when more than one 125 VDC or 250 VDC battery system is inoperable, CTS 3.9.B also requires a reactor shutdown.

These Actions are applicable when the battery systems are inoperable due to Monticello Page 3 of 8 Attachment 1, Volume 13, Rev. 0, Page 198 of 294

Attachment 1, Volume 13, Rev. 0, Page 199 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS battery parameters not within limits. In lieu of requiring an reactor shutdown under these conditions, the ITS 3.8.6 ACTIONS provide compensatory actions, when battery parameters are not within limits, to be taken prior to declaring the associated battery inoperable. This changes the CTS by adding compensatory actions for battery parameters not within limits.

The purpose of the ITS 3.8.6 ACTIONS is to allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

ACTIONS have been added to allow a short time period to restore parameters to within limits. ITS 3.8.6 ACTION A covers the condition of one or more batteries with one or more battery cells float voltage less than the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the performance of SR 3.8.6.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restoration of the affected cell voltage to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.6 ACTION B covers the condition of one or more batteries with float current not within the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and restoration of the battery float current to within limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.8.6 ACTION C covers the condition of one or more batteries with one or more cells electrolyte level less than minimum established design limits, and requires the restoration of electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , verification that there is no evidence of leakage within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6 ACTION D covers the condition of one or more batteries with pilot cell electrolyte temperature less than the minimum established design limits, and requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.8.6 ACTION E covers the condition of batteries in redundant divisions with battery parameters not within limits, and requires restoration of the battery parameters for batteries in one division to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.8.6 ACTION F covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS could not be met, if one or more batteries with one or more battery cells float voltage and float current are not within limits, or if ITS SR 3.8.6.6 is not met, and requires the immediate declaration that the associated battery is inoperable. ITS 3.8.4 ACTIONS Note is also included and allows separate Condition entry for each battery. The allowances are considered acceptable since only a short time is allowed to exist with battery parameters not within limits. In addition, when redundant batteries have battery parameters not within limit, only 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to restore at least one redundant division before declaring the battery inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Monticello Page 4 of 8 Attachment 1, Volume 13, Rev. 0, Page 199 of 294

Attachment 1, Volume 13, Rev. 0, Page 200 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L.2 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.B.4.a requires the verification that the pilot cell voltage and temperature of the adjacent cells are within limits. ITS SR 3.8.6.2 requires verification of battery pilot cell voltage every 31 days while ITS SR 3.8.6.4 requires verification of the battery pilot cell temperature every 31 days. This changes the CTS by extending the Surveillance interval for verification of pilot cell voltage and temperature from 7 days to 31 days. The change to measure the battery pilot cell temperature instead of the adjacent cells to the pilot cells is discussed in DOC L.4.

The purpose of ITS 3.8.6.2 is to ensure the cell float voltages are equal to or greater than the short term absolute minimum voltage. The purpose of ITS SR 3.8.6.4 is to ensure the pilot cell temperature is greater than or equal to the established limit of the battery sizing calculations. This change extends the Surveillance Frequency from 7 days to 31 days for verification of pilot cell voltage -

and temperature. This change isacceptable since ITS 5.5.12, "Battery Monitoring and Maintenance Program," has been added which requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the ITS SR 3.8.6.2 limit of 2.07 V.

In addition, the Frequencies are consistent with IEEE-450-1995. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.9.B.4.a requires verification of pilot cell specific gravity every week and CTS 4.9.B.4.b requires verification of each cell specific gravity every 3 months. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting these Surveillances.

The purpose of CTS 4.9.B.4.a and CTS 4.9.B.4.b, the specific gravity verifications, are to ensure the state of charge of each cell. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. While the specified Surveillances have been deleted, other Surveillances are included which help to ensure the batteries will function as designed. ITS SR 3.8.6.1 (discussed in DOC M.1) requires the verification that each battery float current is < 2 amps for the 250 VDC batteries and < 1 amp for the 125 VDC batteries every 7 days and ITS SR 3.8.6.3 requires the verification that each battery connected cell electrolyte level is greater than or equal to minimum established design limits every 31 days. IEEE 450-1995, Section 4.5 states that the most accurate indicator of return to full charge is a stabilized charging or float current. Specific gravity readings may not be accurate when the battery is on charge following a discharge. These Surveillances give a better indication of the overall battery conditions. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.4 (Category6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.B.4.a requires verification of electrolyte temperature of all cells adjacent Monticello Page 5 of 8 Attachment 1, Volume 13, Rev. 0, Page 200 of 294

Attachment 1, Volume 13, Rev. 0, Page 201 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS to the pilot cells. ITS SR 3.8.6.4 requires verification of each pilot cell temperature. This changes the CTS by reducing the number of cells that must be monitored for electrolyte temperature.

The purpose of CTS 4.9.B.4, in part, is to ensure a representative sample of cells are monitored to ensure the temperature of the battery cells are within acceptable levels. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by reducing the number of cells that must be monitored for electrolyte temperature. Monitoring only the pilot cell electrolyte temperature is sufficient to ensure the battery will be able to provide the required current and voltage to meet the design requirements. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.5 (Category 5- Deletion of Surveillance Requirement) CTS 4.9.B.4.b requires verification of the temperature of every fifth cell every 3 months. ITS 3.8.6 does not include this Surveillance. This changes the CTS by deleting this Surveillance.

The purpose of the temperature verification portion of CTS 4.9.B.4.b is to ensure the battery will be able to provide the required current and voltage to meet the design requirements. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions; other Surveillances ensure the equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform Its assumed safety function.

While the specified Surveillances have been deleted, other Surveillances are included which help to ensure the batteries will function as designed. ITS SR 3.8.6.4 requires verification of each battery pilot cell temperature is within limit.

This Surveillance is sufficient to ensure the electrolyte temperature throughout the battery is acceptable to provide the required current and voltage to meet the design requirements. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.6 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.B.4.c requires the "rated load discharge test" (i.e., a "performance discharge test" in the ITS) to be performed every refueling interval.

ITS SR 3.8.6.6 is performed every 60 months, every 12 months when the battery shows degradation or has reached 85% if the expected life with capacity < 100%

of manufacturer's rating, and every 24 months when the battery has reached 85% of the expected life with capacity > 100% of manufacturer's rating. This changes the CTS by extending the Frequency from every refueling interval to 60 months, provided the battery has not reached 85% of expected life. If the battery has reached 85% of expected life, then the Frequency is maintained at the current 24 months (the term "refueling interval" is changed to "24 months"),

provided the battery capacity is > 100% of the manufacturer's rating. The CTS is also changed by adding an accelerated Frequency of 12 months if the battery has reached 85% of expected life and the capacity is < 100% of manufacturer's rating.

Monticello Page 6 of 8 Attachment 1, Volume 13, Rev. 0, Page 201 of 294

Attachment 1, Volume 13, Rev. 0, Page 202 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The purpose of CTS 4.9.B.4.c is to ensure the battery capacity is > 90% of the manufacturer's rating. ITS SR 3.8.6.6 extends the Frequency of the performance discharge test to 60 months. However, an accelerated Frequency has been added for when the battery shows signs of degradation or when the battery has reached 85% of the expected life. The accelerated Frequency is every 12 months when the battery show degradation, or has reached 85% of the expected life with capacity < 100% of manufacturer's rating and 24 months when the battery has reached 85% of the expected life with capacity > 100% of manufacturer's rating. This change is acceptable since a battery service test has been added (ITS SR 3.8.4.3), which will ensure the batteries has enough capacity to meet the requirements of the design duty cycle every 24 months.

Currently, Monticello has a commitment to change a battery that is at a battery age that is less than 85% of rated service life, or if it's capacity has dropped by more than 10% of rated capacity over the past three operating cycles, or if the battery capacity has reached 90% of rated capacity. The change retains the requirement to change the battery when it has reached 90% of manufacturer's rating. However, when the battery show signs of degradation or when it has reached 85% of its expected life the battery capacity test will be determined more often to ensure it's capacity does not go below 90% of the capacity. These changes are consistent with IEEE-450-1995. In addition, the current "refueling interval" is "24 months." In letter L-MT-04-036, from Thomas J. Palmisano (NMC) to the USNRC, dated June 30, 2004, NMC has proposed to extend the fuel cycle from 18 months to 24 months and the same time has performed an evaluation in accordance with Generic Letter 91-04 to extend the unit Surveillance Requirements from 18 months to 24 months. CTS 4.9.B.4.c was included in this evaluation. Thus this portion of the change (the use of 24 months in lieu of refueling interval) is considered administrative. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.7 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.B.4.c requires the performance of a "rated load discharge" test of the Division 1 and Division 2 250 VDC and 125 VDC batteries. ITS SR 3.8.6.6 requires the performance of a "performance discharge" test or a "modified performance discharge" test. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test (equivalent to the rated load discharge test).

The purpose of CTS 4.9.B.4.c is to verify the capacities of the batteries are acceptable. This change is acceptable because it has been determined, as described below, that the relaxed Surveillance Requirement test method for verification that the equipment used to meet the LCO can perform its required functions is acceptable. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test. The modified performance discharge test is performed by simulating the duty cycle consisting of two rates: 1 min rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test. Since the ampere-hours removed by a rated 1 min discharge represent a very small portion of the battery's capacity, the test rate can be changed to that for the performance test without compromising the results of the performance test. This change is designated as less restrictive Monticello Page 7 of 8 Attachment 1, Volume 13, Rev. 0, Page 202 of 294

Attachment 1, Volume 13, Rev. 0, Page 203 of 294 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.8 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.B.4.c requires the performance of a rated load discharge test of the Division I and Division 2 250 VDC and 125 VDC batteries. At the completion of this test, the CTS requires the determination of specific gravity and voltage of each cell. ITS SR 3.8.6.6 does not require this verification. This changes the CTS by deleting the requirement to determine specific gravity and voltage at the completion of the test.

The purpose of ITS SR 3.8.6.6 is to ensure the battery capacity is > 90% of the manufacturer's rating. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by deleting the requirement to determine specific gravity and voltage during the discharge test. ITS SR 3.8.6.6 is performed to ensure the battery capacity is within the specified limit. The determination of battery capacity does not require the values of specific gravity and voltage of each cell for this evaluation. This change is acceptable because these parameters are monitored for trending purposes and are not specifically required to determine the capacity of a battery. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Monticello Page 8 of 8 Attachment 1, Volume 13, Rev. 0, Page 203 of 294

Attachment 1, Volume 13, Rev. 0, Page 204 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 204 of 294

Attachment 1, Volume 13, Rev. 0, Page 205 of 294 Battery Parameters 3.8.6 CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters IEWER'S NOTE- -------

Licensees must implement a pro m, as specified in Specification 5.5.14, onitor battery parameters that is based a e recommendations of IEEE Standard Recommended Practieor Maintenance, Testing, And Repla nt Of Vented Lead-Acid 1995, IEEE 0D Batteries For Sta ary Applications."

l Division and Division 2 125 VDC and 250 VDC 3.9A.4 LCO 3.8.6 Battery parameters for the 1station st within limits.

and DG] batteries shall be 0D 3.9A, 3.9.A.4 APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

___ -- M

-_ -- ----- ____NOT_________

_ __ _-is allowed for each battery. ,~~~

DOC LA Separate Condition entry CONDITION REQUIRED ACTION COMPLETION TIME DOCL.1 A. Onefprabatter[Jies

[on on ivisio~nwith one A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0 or more battery cells AND float voltage <g2.07- V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0

AND A.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months voltage i12.071 V. 0

-4 l DOCLI B. One orabatter[Mlies Ion o rivision with B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0

float current > M amps, AND 0 for 250 VDC batteies or> 1 amp B.2 Restore battery float current 012 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lfor 125 VDC batteries to Soj amps. 0

_ for 250 VOC batteries or I amp or 250 VDC batteries or: I amp) for 125 VDC batteries BWR/4 STS 3.8.6-1 Rev. 3.0, 03131/04 Attachment 1, Volume 13, Rev. 0, Page 205 of 294

Attachment 1, Volume 13, Rev. 0, Page 206 of 294 Battery Parameters 3.8.6 GTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE----- ------ NOTE------ -

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

DOC L.A C. One or i batterfJies on olivision6 with one C.1 Restore electrolyte level to above top of plates.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 0

or more cells electrolyte level less than minimum AND established design limits. C.2 Verify no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakage.

AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

more DOG Li D. One [or gfbattertnies Ion odae ivisionril with D.1 Restore battery pilot cell temperature to greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 0 pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

4-DOC LI E. IOnezf moreloatteries in redundant divisions with E.1 Restore battery parameters for batteries in one division 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0 battery parameters not to within limits.

within limits.

BWR/4 STS 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 206 of 294

Attachment 1, Volume 13, Rev. 0, Page 207 of 294 Battery Parameters 3.8.6 CTs ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC LI F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B.

C, D, or E not met.

OR One lor IhIon batteff ies one 0

or more battery cells float voltage < .07MV and float current > l 0 ampsp 4d I

.1. A 0

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOCM.1 SR 3.8.6.1 sl Nt

'I ITC Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. [for 250 VDC batteries and 1 amp for 125 VOC (batteries Verify each battery float current is S14 amps</ 7 days 0

4.9.B.A.a SR 3.8.6.2 Verify each battery pilot cell voltage is 2j2.071 V. 31 days 0D DOC M.1 SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

4.9.BA.a SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

BWR/4 STS 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 207 of 294

Attachment 1, Volume 13, Rev. 0, Page 208 of 294 Battery Parameters 3.8.6 CTS SURVEILLANCE REQUIREMENTS (continued)_

SURVEILLANCE FREQUENCY 4.9.B.4.b SR 3.8.6.5 Verify each battery connected cell voltage is 92 days

Ž12.07IV. 0 4.9.B.4.c SR 3.8.6.6 -------- NOTE------

This Surveillance shall not normally be performed in MODE 1, 2, or 3. However, portion of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is 2 60 months (D manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation, or has reached M85(/o of the expected life with capacity < 100%

of manufacturer's rating AND 24 months when battery has reached /8%

of 0 the expected life with capacity 2 100% of manufacturer's rating BWR/4 STS 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 208 of 294

Attachment 1, Volume 13, Rev. 0, Page 209 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6, BATTERY PARAMETERS

1. The "Reviewer Note" has been deleted since it is not intended to be retained in the plant specific ITS submittal.

2. ISTS LCO 3.8.6 has been modified to be consistent with the requirements specified in ITS LCO 3.8.4. The Monticello design includes three batteries per division (two for the 250 VDC electrical power subsystem and one for the 125 VDC electrical power subsystem). In addition, due to the addition of these DC Sources, ISTS 3.8.6 Conditions A, B, C, D, and F have been modified to allow batteries in two trains to havie battery parameters not within limits. ITS 3.8.6 ACTION E will ensure that if batteries in redundant trains have battery parameters not within limits, the restoration time is properly limited consistent with the intent of the ISTS 3.8.6 ACTIONS.

3. The brackets have been removed and the proper plant specific information/value has been provided.

4. ISTS SR 3.8.6.6 requires a battery performance discharge or modified performance discharge test to be performed and provides acceptance criteria. However, no ACTION is provided in the ISTS 3.8.6 ACTIONS for when this SR is not met. Thus in the ISTS, LCO 3.0.3 would have to be entered. To preclude an LCO 3.0.3 entry, ISTS 3.8.6 Condition F has been modified to cover the case when SR 3.8.6.6 is not met. ACTION F will require the associated battery to be declared inoperable. This change has previously been approved by the NRC during the ITS conversion for DC Cook Units 1 and 2.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 209 of 294

Attachment 1, Volume 13, Rev. 0, Page 210 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 210 of 294

Attachment 1, Volume 13, Rev. 0, Page 211 of 294 Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGRO JND This LCO delineates the limits on battery float current as well as electrolyte temperature, level, and float voltage for the DC electrical C(

power subsystems batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." In addition to the limitations of this Specification, thel licenseeontrolled C2) r grams also implements a program specified in Specification 5.5t for monitoring various battery parameters that is based on the H (

recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications" (Ref. 1). [Battery Monitoring and Maintenance Program The battery cells are of flooded lead acid construction with a nominal specific gravity o 1.21.c specific gravity corresponds to open Icircuit batteryv~oltaigae Xpr !imately 120 V for [581 cell bafery (i.e., cellr

[voltage of [2.065]y s per cell (VpcDT. The open circuit voltage is the b voltage maintained when there is no charging or discharging. Once fully chae wi io e. ,the battery cell will maintaing capacity forW301 days without further charging per TOO manufacturer's instructions. Optimal long term performance however, is obtained by maintaining a float voltage j2.20 to 2.21J Vpc. This provides 2 adequate over-potential which limits the formation of lead sulfate and self dischaarge. Fhe nomi oat voltage of [2.22] Vpc correspords to a total oa voltage outp f [128.8] V for a [58] cell batteryiscussed in the kI LESAR, Chap8 (Ref. 2)./

APPLICABLE The initial conditions of Design Basis Accident (DBA) and i 14 SAFETY O a-n-alyses inlSA[, Chapter W ef. 3) and ChapterrTRef.W \ 0 ( 0 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of DC subsystems is consistent with tnitial assumptions of the cident analyses and is based upon eeting the design basis of unit. This includes maintaining atst one division o 0 DC source PERABLE during accident conditi in the event of:

a. nassumed loss of all offsite AC or onsite AC power and

{The specific Apptlcbte Safety Analyses for the DC Electrical Power System are provided In the Bases of LCO 3.8.4 and LCO 3.8.5.

BWR/4 STS B 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 211 of 294

Attachment 1, Volume 13, Rev. 0, Page 212 of 294 Battery Parameters B 3.8.6 BASES APPLICABLE SAFETY ANALYSES (continued) b._ s case sin re.

Sincetattery Parameters support the operation of the DC electrical power subsystems, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testing, and Batery monitoring performed in accordance with thei licensecontrolledr Monitonng and proam- is conducted as specified in Specification 5.5. .Pwgram APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical power subsystem. Therefore, battery parameter limits are only required when the DCpower e required to be I eledrct1i m(

OPERABLE. Refer to the Applicability discussions in Bases for Jo LCO 3.8.4 and LCO 3.8.5.

ACTIONS A.1, A.2, and A.3 With one or more cells in one or more batteries in on <2.071 V,OO

<vision the battery cell is degraded. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries < J2.07@ V, Q and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

.Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is not assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

BWR/4 STS B 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 212 of 294

Attachment 1, Volume 13, Rev. 0, Page 213 of 294 Battery Parameters B 3.8.6 BASES ACTIONS (continued lfor 250 VDC batteries or > 1 amp for 125 VDC betteries PI if I

B.1 and B.2 One or more batteries in on visioj with floa > 1 amp indicates that a partial discharge of the battery capacity has occurred. This may be due

-(0 to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity.

Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage 00 is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is operating in the current limit mode. l Condition A adrse rger inoperabilityl If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the 0

amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within ~14J hours (Required Action B.2). The battery must therefore be declared inoperable.

If the float voltage is found to be satisfactorylbut there are ?ne gdore battfery cells with floa~Wbltage less than [2.07] V, the assoc~ MOR" statement in Coycifon F is applicable and the battery be declared 0

inoperable ipnfediately. If float voltage is satisfa le and there aen cells les an [2.071 \there is good assurance that, within 142 hours0.00164 days 0.0394 hours 2.347884e-4 weeks 5.4031e-5 months , the battery will be restored to its fully charged condition (Required Action B.2) 0 from any discharge that might have occurred due to a temporary loss of the battery charger.

- tEVIEWER'S NOTE--------

A plant that cannot t the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time due an inherent battery charging c racteristic can propose an altemate Te equal to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus t ime experienced to accomplish the ponential charging 0

current po n of the battery charge profile follow g the service test (SR 3.8 .3)./

BWR/4 STS B 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 213 of 294

Attachment 1, Volume 13, Rev. 0, Page 214 of 294 Battery Parameters B 3.8.6 2

BASES ACTIONS (continued)

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 12] hours, avoiding a premature shutdown with its own attendant 0 risk.

If the condition is due to one or more cells in a low voltage condition but still greater thang2.01 V and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and E1; hours is afT reasonable time prior to declaring the battery inoperable.

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

2 C.1, C.2. and C.3 With one or more batteries in on ivision with one or more cells electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this 1 potential (as well as provisions in Specification 5.5Mattery Monitoring 8)

L and Maintenance Progra". They are modified by a Note that indicatesl12 they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months level is required to be restored to above the top of the plates. The Required Action C.2 requirement to verify that there is n requirment leakage by visual inspection and the Specification 5.5. ibL to initiate 06 08 action to equalize and test in accordance with manufactr rs 1 recommendation are taken from Annex D of IEEE Standard 450-1995.

They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batte Aiej may have to be declared lA inoperable and the affected cel replaced. J BWR/4 STS B 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 214 of 294

Attachment 1, Volume 13, Rev. 0, Page 215 of 294 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

D.1 With one or more batteries in on ivision with pilot cell temperature less than the minimum established design limits, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

E.1 With one more batteries in redundant divisions with battery parameters not within limits there is not sufficient assurance that battery capacity has 0

not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one division within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

F.1 orfajre ofSR When any battery parameter is outside the allowances of the Required Actis for Condition A, B, C, D, or e sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding battery must be declared inoperable. Additionally, a) for 250 VDC discovering one or more batteries in one division with one or more battery batteries or greater cells float voltage less thanl2.071 V and float current greater than L than 1 ampfories ampindicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

BWR/4 STS B 3.8.6-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 215 of 294

Attachment 1, Volume 13, Rev. 0, Page 216 of 294 Battery Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

more conservative bhan the The float current requirements are based on the float current indicative of recommendatons a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). The 7 day Frequency is consi wi IEEE-450 (Ref. 1). 0 This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage

. is not maintained the Required Actions of LCO 3.8.4 ACTION A are being batteries and taken, which provide the necessary and appropriate verifications of the 1amp for batteries. F the float current limitof [20amps is established based on the nominal float voltage value and is not directly 0

applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5

[ 132 V for a 60 cell battery and 127.6 V for a58 cell battery Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits C()0 provided by the battery manufacturer, which corresponds to [13,.5] at the battery terminas [ Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in C6 0 this range or less, but greater thanJ2.071 Vpc, are addressed in Specification5. i.. SRs 3.8.6.2 and 3.8.6.5 require verification that the

, with cell voltage cell float voltages are equal to or greater than the short term absolute measured to the minimum voltage of I2.071 Y. The Frequency for cell voltage verification C Inearest 0.0 1 volt every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1).

0) 0D SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

The Frequency is consistent with IEEE-450 (Ref. 1).

BWR/4 STS B 3.8.6-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 216 of 294

Attachment 1, Volume 13, Rev. 0, Page 217 of 294 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or\

equal to the minimum established design limit (i.e.,MF). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provided the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Frequency is consistent with IEEE-450 (Ref. 1).

SR 3.8.6.6 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.3.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of ity. Initial conditions for the modified performance discharge discharge Itest should be identical to those specified for ase ice test. (i) las specified In IEEE450 (Ref. 17)l It may consist of just two rates; for instance, the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a onel discharge ed inute discharge represents a very small portion of the battery ca acit tnbe changed to that for thperformanc itest without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

BWR/4 STS B 3.8.6-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 217 of 294

Attachment 1, Volume 13, Rev. 0, Page 218 of 294 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1)1and IEEE5 (Ref. 5.1 Th references recommend'h-a3t the-(7D NE ate be replaced if its capacity is below 80% of the manufacturer's ratinig~A capacity of 80% shows that the batt #y rate of deterioration is\

INSERT 2 ncreasin , yven if there is ample capacity to eet the load requirements r125-vaDc and Furthermore, th batte Esized to meet the assumed duty cycle loads 4 250 vDC w en the battery desig ~capacity reaches thi % limit. '-(9)

The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity a 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Re.a), when the battery capacity drops by more than 10%

relative to its capacity on the previous erformance test or when it is n/0 belo the manufacturer's rating. All es requencies are consistent with the recommendations in IEEE-450 (R month

[The 24 month Frequency Is derived from the recommendations of IEEE-450 (Ref. 1) anl--ot This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge 2.or3 lsafety systems. This restriction from normally performing the SbeillnceinMis further amplified to allow portions of the (j)

Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE I1 3 Risk 0 insights or deterministic methods may be used for the assessme-Ri r Credit may be taken for unplanned events that satisfy this Surveillance.

BWR/4 STS B 3.8.6-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 218 of 294

Attachment 1, Volume 13, Rev. 0, Page 219 of 294 B 3.8.6 0 INSERT I if the battery was sized using a 1.25 aging factor. If a lesser aging factor was used, battery replacement will be required before 80% capacity is reached to ensure that the load can be served.

0 INSERT 2 The 250 VDC batteries were sized using a 1.11 aging factor, therefore a 90% capacity limit was chosen. While the 125 VDC batteries were sized using a 1.25 aging factor, a similar 90% capacity limit was chosen for conservatism.

/

Insert Page B 3.8.6-8 Attachment 1, Volume 13, Rev. 0, Page 219 of 294

Attachment 1, Volume 13, Rev. 0, Page 220 of 294 Battery Parameters B 3.8.6 BASES REFERENC 'ES 1. IEEE Standard 450,1995.

1.FSAR,,5 pter [8]-

0 E 3.FSAR Chapter [61.

SAR, Chapter 00D

15. IF==;= nt 485. 1983.1

=

BWR/4 STS B 3.8.6-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 220 of 294

Attachment 1, Volume 13, Rev. 0, Page 221 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6 BASES, BATTERY PARAMETERS

1. Changes are made to reflect the Specification.

2. The brackets have been removed and the proper plant specific information/value has been provided.

3. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.

4. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

5. ISTS 3.8.6 is applicable when associated DC electrical power subsystems are required to be OPERABLE. The DC electrical power subsystems are required to be OPERABLE in MODES 1, 2, and 3 (ITS 3.8.4) and in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment (ITS 3.8.5).

The Applicable Safety Analyses Bases only discusses accident analyses related to MODES 1, 2, and 3; it does not discuss events in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. Therefore, for completeness, the Applicable Safety Analyses for MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment needs to be discussed. However, in lieu of adding this large description from the ITS 3.8.5 Bases, the MODES 1, 2, and 3 description has been deleted and in its place a statement has been added referencing the Applicable Safety Analyses Bases for ITS 3.8.4 and ITS 3.8.5. This is consistent with the manner in which similar information in one ISTS Bases is referenced in another ISTS Bases (e.g., the ISTS 3.8.5 Background Bases references ISTS 3.8.4 Background Bases).

6. Changes are made to reflect those changes made to the Specifications.

7. The "Reviewer's Note" has been deleted since it is not intended to be included in the plant specific ITS submittals.

8. Grammatical/editorial/spelling error corrected.

Monticello Page 1 of I Attachment 1, Volume 13, Rev. 0, Page 221 of 294

Attachment 1, Volume 13, Rev. 0, Page 222 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 222 of 294

Attachment 1, Volume 13, Rev. 0, Page 223 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 223 of 294

, Volume 13, Rev. 0, Page 224 of 294 ATTACHMENT 7 ITS 3.8.7, Distribution Systems - Operating Attachment 1, Volume 13, Rev. 0, Page 224 of 294

Attachment 1, Volume 13, Rev. 0, Page 225 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 225 of 294

C C ITS 3.C8.

0 ITS 3.0 UMmNG CONMMONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.9 AUXIUA HICAL SYSTEMS 4.9 AUXWRY ELE Ms a)

Ang / AppliCabmV/

0 Applies tot auIiliary electrical power system. Applies to the period testing requirements of the auxilary electrical system. I 0 / ~Oblectlve: 0

/ -A To ass e ranadequate supply of electrical during plant ration. Verify the operality of the auxiliary electrical system.

CD) E, 0 3.8.7 Spe~i;atiCton: 3

-I CD Applicability A. The reactor shall not be made critical unless all the A. Surveillance testing shall be performed as follows: 0

-A followino requirements are satisfied: S4

-4 - - -

1. Substatlon Switcltyard Battery ;U

1. At least two (2) NSP transmission lines, associated switchgear, and at least two offisite power sources a. Every week the specific gravity and voltage of are fully operational and energlzed to carry power to the pilot cell and temperature of adjacent celts the plant 4160V AC buses as follows: and overall battery voltage shall be measured. See ITS 3.8.1 }

-4'

-u

b. Every three months the measurements shall be a)

a. 2R and 1R transformers, or CO made of voltage of each cel to nearest 0.01 CD

b. 1R and lAR transformers, or volt, specific gravity of each cell, and temperature of every fifth cell.

to C. 2R and IAR transformers (source from 10 0 transformer 4

-Ph 3.914.9 199 10/16187 Amendment No. 51 Page 1 of 3

C C CI ITS 3.8.7 0

ITS 0) 0)

su 0 0

CD 0 3 LCO 3.8.7

.3 0 3 0

-U 0

E, ACTION C.

0 ACTION D 0) 0 -4

-4 0 0 CD t)

}

-0 Co Mu See ITS 3.8.1 0 lu

-I re3 to 13.9/4.9 200 08/27/02 Amendment No. 612414, 129 Page 2 of 3

( C 0 ITS 3.8.7 ITS Q

3.0 UMING CONDIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

[7'

4. Station Battery System 4. Sta tion Battery System Di 0)

Itfone of the twol125 Vbattery systems or one of Everyweek the specific gravity and voleof I the two 250 V battery system, Is made or found toc the plot cell and temperature of theadjacent ITS 3.8.4 and IS 3.8.6 a, bh opeable for env re sonll orderly shutabwn cells and overall battery voltage shall be I ofthe reactor shall beinitiratRednd thereactor water measured. CD 0 ACTION C emperature shaglbleue ~shn2 g -, . . .__ _. __.

batery systems are -

withn nblours untless sduuched b. Every three months the measurements shall be soet midei lal made of voltage of each cell to nearest 0.01 CD in MODE 3 volt. specific gravity of each cell, and 0

-A) In 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months temperature of every fifth cell. See ITS 3.8.6}

and MODE i

c. Every refueling outage, the station batteries shall be subjected to a rated load discharge 0 test. Determine specific gravity and voltage of each cell after the discharge.

CD 5. 24V Battery Systems,

-U CD a. Every week the specific gravity and voltage of CD

5. 24V Battery Systems the pilot cell and temperature of adjacent cell and overal battery voltage shalt be measured.

From and after the date that one of the two 24V

-0 battery systems Is made or found to be Inoperable b. Every three months the measurements shall be -0 for any reason, refer to Specification 3.2 for made of voltage of each cell to nearest 0.01 approordate action.

volt, specific gravity of each cell, and temperature of every fifth cell.

(0 I (0 See ITS 3.8.4 3.914.9 203 3124186 Amendment No. 3.41 Page 3 of 3

Attachment 1, Volume 13, Rev. 0, Page 229 of 294 DISCUSSION OF CHANGES ITS 3.8.7, DISTRIBUTION SYSTEMS ; OPERATING ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.9.A.4 requires the station 125 VDC and 250 VDC batteries to be charged and "in service," however the CTS does not explicitly require the associated DC distribution panels to be to be OPERABLE. ITS LCO 3.8.7, in part, requires the Division 1 and Division 2 DC electrical power distribution subsystems to be OPERABLE. This changes the CTS by specifying the requirements for DC distribution buses.

The purpose of CTS 3.9.A.4, in part, is to ensure the DC buses associated with the 125 VDC and 250 VDC batteries are OPERABLE. This is implicitly required since CTS 3.9.A.4 requires the 125 VDC and 250 VDC batteries to be "in service," and the only way they can be in service is to be connected to the associated DC distribution bus. The proposed change explicitly requires the Division 1 and Division 2 DC electrical power distribution subsystems to be OPERABLE. The details of which buses or distribution panels are covered by this LCO are discussed in the Bases. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.A requires the Division 1 and Division 2 AC and DC electrical power distribution subsystems to be OPERABLE when the reactor is critical. ITS LCO 3.8.7 requires the Division 1 and Division 2 AC and DC electrical power distribution subsystems to be OPERABLE in MODES 1, 2, and 3. This changes the CTS by requiring the Division 1 and Division 2 AC and DC electrical power distribution subsystems to be OPERABLE in MODE 3 and in MODE 2 when the reactor is not critical.

The purpose of CTS 3.9.A, in part, is to ensure the Division 1 and Division 2 AC and DC electrical power distribution subsystems are OPERABLE to mitigate the consequences of a transient or design basis accident. The Division 1 and Division 2 AC and DC electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, and 3 when a design basis accident (e.g. loss of coolant accident) may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 the reactor is 0

not critical, however the reactor coolant temperature is always above 212 F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a pipe break. Therefore, it is necessary and acceptable to require the AC and DC electrical power distribution subsystems to Monticello Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 229 of 294

Attachment 1, Volume 13, Rev. 0, Page 230 of 294 DISCUSSION OF CHANGES ITS 3.8.7, DISTRIBUTION SYSTEMS - OPERATING be OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M.2 CTS 4.9.A and CTS 4.9.B do not provide any specific testing requirements for the Division I and Division 2 AC and DC electrical power distribution subsystems. ITS SR 3.8.7.1 requires verification of correct breaker alignments and voltage to required AC and DC electrical power distribution subsystems. This changes the CTS by requiring a new Surveillance Requirement for verifying the OPERABILITY of the required Division 1 and Division 2 AC and DC electrical power distribution subsystems.

The purpose of ITS SR 3.8.7.1 is to ensure that the buses associated with the Division 1 and Division 2 AC and DC electrical power distribution subsystems are OPERABLE. This change is acceptable because it provides additional assurance that the buses associated with the Division 1 and Division 2 AC and DC electrical power distribution subsystems are OPERABLE. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

M.3 CTS 3.9.B.4 states that when one of the two 125V battery systems or one of the two 250V battery systems is made or found to be inoperable for any reason an orderly shutdown of the reactor shall be initiated and the reactor water temperature shall be reduced to less than 2120 F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless such battery system is sooner made OPERABLE. This Action applies when a 125V or 250V electrical power distribution subsystem is inoperable. CTS 3.9.B states that when the reactor mode switch is in Run, the availability of electric power shall be as specified in CTS 3.9.A, except as specified in CTS 3.9.B or the reactor shall be placed in the cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Thus, when more than one 125V or 250V battery systems are inoperable, the CTS 3.9.B requirement would apply. This Action (CTS 3.9.B) also applies when one or more AC electrical power distribution buses required by CTS 3.9.A.3 are inoperable. However, the CTS 3.9.A.3 AC electrical power distribution subsystems and the CTS 3.9.A.4 125 VDC and 250 VDC electrical power distribution subsystems are only required to be OPERABLE when critical, as stated in CTS 3.9.A. Thus, the plant is only required to be subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS 3.8.7 ACTION C provides the shutdown requirements when one or more AC electrical power distribution subsystems or one or more 125 VDC or 250 VDC electrical power distribution subsystems are inoperable and a loss of function has not occurred, and requires the unit to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if any Required Action and associated Completion Time of Condition A or B are not met. ITS 3.8.7 ACTION D provides the shutdown requirements when two or more electrical power distribution subsystems are inoperable that result in a loss of function, and requires the unit to enter LCO 3.0.3. ITS LCO 3.0.3 will require the unit to initiate action within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

This changes the CTS by requiring the plant to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown (MODE 4) in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if one or more AC electrical power distribution subsystems or one or more 125 VDC or 250 VDC electrical power distribution subsystems are inoperable and a loss of function has not occurred and any Required Action and associated Completion Time of Condition A or B are not met. In addition, this changes the Monticello Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 230 of 294

Attachment 1, Volume 13, Rev. 0, Page 231 of 294 DISCUSSION OF CHANGES ITS 3.8.7, DISTRIBUTION SYSTEMS - OPERATING CTS by requiring the plant to initiate a plant shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in MODE 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , to be in MODE 3 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and to be in MODE 4 in 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months , in lieu of being subcritical in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if more than one AC or 125 VDC or 250 VDC electrical power distribution subsystems are inoperable and a loss of function has occurred.

The purpose of CTS 3.9.B and CTS 3.9.B.4 is to place the plant outside the Applicability of the Specification. CTS 3.9.A requires the AC and the 125V and 250V electrical power distribution subsystems to be OPERABLE only when critical (MODE 1 and a portion of MODE 2). Thus, while the CTS 3.9.B and 3.9.B.4 Actions require a shutdown to MODE 4, in actuality, only a shutdown to subcritical conditions is required. Once subcriticality is achieved, continuation to MODE 4 is not required since the AC and the 125V and 250V electrical power distribution subsystems are not required to be OPERABLE when subcritical.

However, since the requirement that the AC and the 125V and 250V electrical power distribution subsystems be OPERABLE in MODE 2 when subcritical and in MODE 3 has been added (DOC M.1), ITS 3.8.7 ACTION C and LCO 3.0.3 (via ITS 3.8.7 ACTION D) include a shutdown to MODE 3 and to MODE 4. The allowed Completion Times are reasonable, based on operating experience, to reach required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This change is acceptable because it requires the unit to be in an intermediate condition (MODE 3) sooner than is currently required (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months versus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). This portion of the change reduces the time the unit would be allowed to continue to operate in MODE 1 and MODE 2 while critical once the condition is identified. The consequences of a loss of coolant accident are reduced when the reactor is shutdown and a controlled cooldown is already in progress. This change is designated as more restrictive because less time is allowed to shut down the plant.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.A.3.(a) requires the 4160V Buses #15 and #16 to be energized. CTS 3.9.A.3.(b) requires the 480V Buses #103 and #104 to be energized. ITS LCO 3.8.7, in part, requires the Division 1 and Division 2 AC electrical power distribution subsystems to be OPERABLE. This changes the CTS by moving the specific names of the buses, the associated nominal bus voltages (i.e., 4160 V and 480 V), and that the buses must be energized from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the Division I and Division 2 AC electrical power distribution Monticello Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 231 of 294

Attachment 1, Volume 13, Rev. 0, Page 232 of 294 DISCUSSION OF CHANGES ITS 3.8.7, DISTRIBUTION SYSTEMS - OPERATING subsystems to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC electrical power distribution subsystems.

Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.9.B.4 requires a plant shutdown when one of the two 125V battery systems or one of the two 250V battery systems is made or found to be inoperable for any reason. CTS 3.9.B requires a plant shutdown when any AC electrical power distribution subsystem or more than one 125 V or 250 V DC battery system is inoperable. ITS 3.8.7 ACTION A covers the condition for one or more AC electrical power distribution subsystems inoperable, and requires the restoration of the AC electrical power distribution subsystem(s) to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. A Note to the ACTION also requires entry into LCO 3.8.4, "DC Source - Operating," for DC divisions made inoperable by the inoperable AC power distribution subsystems. ITS 3.8.7 ACTION B covers the condition for one or more DC electrical power distribution subsystems inoperable, and requires the restoration of the DC electrical power distribution subsystem(s) to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. This changes the CTS by providing some time to restore inoperable AC or DC electrical power distribution subsystems prior to requiring a plant shutdown, provided a loss of function has not occurred.

The purpose of CTS 3.9.B and 3.9.B.4 is to place the plant in a condition where AC electrical power distribution subsystems or DC battery systems are no longer required. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

This change allows a short time period to restore inoperable AC and DC electrical power distribution subsystems to OPERABLE status. This is acceptable because there are sufficient electrical power distributions subsystems available to ensure all plant safety functions can be supported by the Division I or Division 2 electrical power distribution subsystems. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Monticello Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 232 of 294

Attachment 1, Volume 13, Rev. 0, Page 233 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 233 of 294

Attachment 1, Volume 13, Rev. 0, Page 234 of 294 Distribution Systems - Operating -I 3.8MG CTS 3.8 ELECTRICAL POWER SYSTEMS 39A3 J8j 1 Distribution Systems - Operating 0D 3.9A.3, 3.9A4 LCO 3.8 [Division 11 and jDivisi on 2lACODCI [and Final lusj electrical power distribution subsystem s shall be OPERABLE. 00 APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION J COMPLETION TIME 3.9.B. A. One or more AC A---------NOTE-----

DOC LI electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC divisions made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO B. [ One or ore AC vital B.1 store AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses in perable. istribution subsystem(s) to OPERABLE status. AND 0 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 1 BWR/4 STS 3.8.9-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 234 of 294

Attachment 1, Volume 13, Rev. 0, Page 235 of 294 Distribution Systems - Operating 3.8 (O)

K-) CTS ACTIONS (continued)

CONDITION J REQUIRED ACTION COMPLETION TIME

DOC . One or more stion [e Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0 LI s ice DC electrical power distribution power distribution subsystem(s) to AND 0D subsystems inoperable. OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO I

3.9.B a~1Required Action and associated Completion Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 0)

Time of Condition ACE orip not met.

AND 0D

.9-Et12 Be in MODE 4.

t 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 0D E. [One or ore E electric power )

distrib tion subs inop rable.

+ 4 3 .9 .B.

3.9.B.4 at. Two or more electrical power distribution ffli Enter LCO 3.0.3. Immediately 0D subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.8. 1 Verify corre breaker alignments and voltage to 7 days

[JgequireqdljACt D and ital bus electrical power distribution subsystems.

00 BWR/4 STS 3.8.9-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 235 of 294

Attachment 1, Volume 13, Rev. 0, Page 236 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, DISTRIBUTION SYSTEMS - OPERATING

1. ISTS 3.8.9 is renumbered as ITS 3.8.7 since ISTS 3.8.7, "Inverters - Operating," and ISTS 3.8.8, "Inverters - Shutdown," are not included in the Monticello ITS.

2. The brackets have been removed and the proper plant specific information/value has been provided.

3. The bracketed AC vital bus requirements have not been adopted in the Monticello ITS. The change is consistent with the current requirements in the current licensing basis. Subsequent ACTIONS have been renumbered, as necessary.

4. The requirements for the DG DC electrical power distribution subsystems in ISTS 3.8.9 ACTION E has been deleted since Monticello does not have an equivalent system. The DC loads for the Diesel Generators are powered from the Division 1 and Division 2 DC electrical power distribution subsystems. The subsequent ACTION has been renumbered, as necessary.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 236 of 294

Attachment 1, Volume 13, Rev. 0, Page 237 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 237 of 294

Attachment 1, Volume 13, Rev. 0, Page 238 of 294 Distribution Systems - Operating B 3.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8kDistribution Systems - Operating 0 BASES [I BACKGROUND The onsite Class 1E AC and DC electrica\ ower distribution system is divided into redundant and independent A D, and a uVit electrical power distribution subsystems. (essential bus 15 for Division 1 and r-e-t L essential bus 16 for Division 2) l The primary AC electrical power distributio ubsystem for\each division consists of a 4.16 k Enaineere ature (ESF) bushavingNP 3l Aoffsite sourceof powe as well as a dedicated onsite4diesel generatoriemersencYi E PG) source. Each 4.16 kV\lEltus is normally connected toEan~fl source sa aomer. During a loss of the normal oer sourcQ to the 4.16 kV[Itbuses, the al ernaae essental 28transformer supply breakeafr 2 attempillto close. If all offsite sources are

[3 unavailabVle.Cto nsitelemegenMDGssuppl power to the 4.16 kV useT1A 4 EaCih e seoa an distribution subsyste includes 6VAC emencyl

[AC I buses 2C a n associate load center c6trorcters I distr~utwon pahs, End tafffreb, 7dl-0-4 INSERT l The 120 VA vital buses 2YV, 2V , 2YV3, and 2YV4are arranged in four load g ups and are normal powered from DC. the alternate power su ly for the vital buse is a Class 1E constart voltage source transfor er powered from the ame division as the asociated inverter, and its se is governed by L 3.8.7, "Inverters - erating." Each consta t voltage source tran former is powered fr AC.

Engineered There are two independent 125/250 VDCIstatoie-rvice electrical power Featue ditruto subsystems Land thelt infdPpenrsft 125 Uncr-Fr Ple-rtricnl lag ESF) ePower distrigglion subsst-emsthat support the necessary power f bus g EI T1C, functions. Each subsystem consists of al ZbV and-aV Iasgciated stributif pane distribution subsystem buses, load centers,moto6ntro 2 Iceulrsd, and distribution panels is presented in Table B 3.8 (1 MR S3n8bution 91binets 30 0 4 0 BWRI4 STS B 3.8.9-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 238 of 294

Attachment 1, Volume 13, Rev. 0, Page 239 of 294 B 3.8.7 Q

0INSERT I the primary station auxiliary transformer, 2R, via its associated plant auxiliary 4.16 kV bus.

INSERT 1A In the event the 1R transformer is unable to accept the load, the essential buses are automatically transferred to the reserve auxiliary transformer, 1 AR. The IAR transformer supplies power directly to the essential buses.

Q INSERT IB Each load center is supplied from the associated 4.16 kV essential bus via a transformer.

Q INSERT IC Each 125/250 VDC electrical power distribution subsystem is supplied by a Division 1 or Division 2 250 VDC electrical power subsystem.

Q INSERT 1D There are two independent 125 VDC electrical power distribution subsystems that support the necessary power for safety functions. A Division 1 or Division 2 125 VDC electrical power subsystem supplies the associated 125 VDC electrical power distribution subsystem. Each subsystem consists of a 125 VDC distribution panel.

Insert Page B 3.8.9-1 Attachment 1, Volume 13, Rev. 0, Page 239 of 294

Attachment 1, Volume 13, Rev. 0, Page 240 of 294 Distribution Systems - Operating B 3.8&x(i BASES APPLICABLE The initial conddtions of Design Basis Accident (DBA) and transient 14 SAFETY analyses in SAR, Chapter ef. 1) and Chapte j I(Ref. ( 0 ?)

ANALYSES assume ESF systems are OPERABLE. The AC and DReectrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment Emergency Core design limits are not exceeded. These limits are discussed in more detail (ECCS) and Reactor in the Bases for Section 3.2, Power Distribution Limits; Section 3 (i9 Core Isolation Cooling -o Reactor C olatstem (RCS; and Section 3containment Systems.

The OPERABILITY Lof the A D ita u electrical power distribution subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.

This includes maintaining distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical powes and ,jj 0

b. A worst case'isngle failure. E 0 Thel AC and lcrical rowea of 10 CFR 50.36(c)(2)(ii).

istribution yste 4atisfies Criterion 3 0)

LCO 7 The required electrical power distribution subs ystems listed in end IDivision 1 and Division 2 ITable B 3. -1 ensure the availability of ACf and Digital bu3 electrical power for the systems required to shut down the reactor and 0D As nioted inTable B3.6.7.1\ maintain it in a safe condition after an anticipated operational occurrence each division of theACand (AOO) or a postulated DBA. The7AOJJI nd ita bu electrical end 0 I~Sbytem.

DElectiyical Power Distributon Systems Isa I

power distribution subsystems are required to be OPERABLE. 0 0

.4 Maintaining the [Division 1 andA4 an u electical power distribution subsystems OPERABLE ensures that the redundancy 0

incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

The AC electrical power distribution subsystems require the associated buses and electrical circuits, including any load centers; motorol l 1 centers, an si ution panel, to be energized to their proper voltagesj 0 OPERABLE DC electrical power distribution subsystems require the BWR/4 STS B 3.8.9-2 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 240 of 294

Attachment 1,Volume 13, Rev. 0, Page 241 of 294 Distribution Systems - Operating B 3.8t )

BASES LCO (continued) associated us an distribution panels to be energized to their proper 0 voltage from either the associated battery or charger. ERABLE vital bus electrical p wer distribution subsystems require th' associated buses to be energize to their proper voltage from the assocated [inverter via 0 inverted DC yoltage, inverter using interval AC sourc , or Class 1E constant volfa e transfornmer In addition, tie breakers between redundant safety related ACfD an1j between redundant safety'related AC C power distribution subsystems it thfelexisT, must be open.

or DC electrical power disttnbution This prevents any electrical malfunction in any power distribution subsystems subsystem from propagating to the redundant subsystem, which could that is not being power cause the failure of a redundant subsystem and a loss of essential safety normal source (i.e., it hs being function(s). If any tie breakers are closed, thelattecteendant powered from Its redur electrical power distrib ut electrical power distribution subsyste inoperable. This Tconsidered subsystem) Is appies o e onsite, safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant E0i CasE 4.16 kVWF buses from being powered from the same offsiteO (D circuit. -s APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and I 0

b. Adqute core cooling is provided, and containment OPERABILITY safety and other' afunctions are maintained in the event of a postulated DBA. {and other conditions In which AC and DC electrical 0

power distnbuton subsystems are required Electrical power distribution subsystem requirements for MODES 4 and 5' 0) are covered in the Bases for LCO 3.8,;, "Distribution Systems -

Shutdown."*

0D ACTIONS A.1 With one or more Division 1 2 required AC rsesload centers, motor control centers, ors ie ( s except vita uses), in l XD I onetisonl inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single BWR/4 STS B 3.8.9-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 241 of 294

Attachment 1, Volume 13, Rev. 0, Page 242 of 294 B 3.8.7 Q INSERT 2 Based on the number of safety significant electrical loads associated with each bus listed in Table B 3.8.7-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LCO 3.8.7 is required. Some buses, such as motor control centers or panels, which help comprise the AC and DC distribution systems, are not listed in Table B 3.8.7-1. The loss of electrical loads associated with these buses may.

not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., a breaker supplying a single distribution panel fails open), the individual loads on the bus would be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., loss of 4.16 kV essential bus, which results in de-energization of all buses powered from the 4.16 kV essential bus), then although the individual loads are still considered inoperable, the Conditions and Required Actions of the LCO for the individual loads are not required to be entered, since LCO 3.0.6 allows this exception (i.e., the loads are inoperable due to the inoperability of a support system governed by a Technical Specification; the 4.16 kV essential bus).

Insert Page B 3.8.9-3 Attachment 1, Volume 13, Rev. 0, Page 242 of 294

Attachment 1, Volume 13, Rev. 0, Page 243 of 294 Distribution Systems - Operating B 3.8 BASES ACTIONS (continued) failure in the remainingpower distribution subsystems could result in the dminimum required ESF functions not being supported. Therefore, the l'arequiredACbusesl load centers motor contraLcetersand distributionI 0

[prl must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . 0 The Condition A worst scenario is one divisioiwithout AC power (i.e., no stI onffsite power to the division and the associate DG inoperable). In this

-IC5zif, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unitoand[o3 restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is 0

acceptable becaus e, 0

a. ThugIapotential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to 0

restore power to the affected division to the actions associated with taking the unit to shutdown within this time limite and 0

b. T potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant 0D component is verified OPERABLE in accordance with Specification 5.5.q, "Safety Function Determination Program (SFDP).") 2 0 The second Completion Time tor Required Action A.1 establishes a limit

'eletria power on the maximum time allowed for any combination of required distributior I t subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a

\ is inoperable and subsequently returned OPERABLE, this LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This situation could 0

lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time a DClcir ui could again eandOrdistributiond could be restored OPERABLE. 00 This could continue indefi-nit1ye L it This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This results in establishing the "time zero" at the time this LCO was initially not met, instead of at the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

BWR/4 STS B 3.8.9-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 243 of 294

Attachment 1,Volume 13, Rev. 0, Page 244 of 294 Distribution Systems - Operating B 3.8 (in BASES ACTIONS (continued)

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC divisions made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

[B.1l With onor more AC vital bus s inoperable, and a 1o of function has not yet ccurred, the remainin OPERABLE AC vital uses are capable of supp rting the minimum saf ty functions necessa to shut down the unit an maintain it in the safe shutdown condition. verall reliability is reduce however, since an a ditional single failure uld result in the minimu required ESF functi ns not being supporte. Therefore, the require AC vital bus must be restored to OPERABL status within 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus rom the associated [in erter via inverted DC, in erter using internal A source, or Class 1E c nstant voltage transf rmer].

Condi on B represents one r more AC vital buses ithout power; poten ally both the DC sour e and the associated C source are nonfu ctioning. In this situa ion the plant is signifi ntly more vulnerable to a mplete loss of all no nterruptible power. It s,therefore, impe ative that the operato s attention focus on stabilizing the plant, 0D mini izing the potential for oss of power to the re naining vital buses, and estoring power to the ffected AC vital buses This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more c nservative than Compl tion Times allow for the ajority of component that are without adeq ate vital AC power.

Tak ng exception to LCO .0.2 for components w thout adequate vital AC p er, that would have R quired Action Comple on Times shorter than 2 h urs if declared inope ble, is acceptable bec use of:

[ a The potential for dec ased safety when re uiring a change in plant conditions (i.e., requ ing a shutdown) while ot allowing stable operations to contin e, BWR14 STS B 3.8.9-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 244 of 294

Attachment 1, Volume 13, Rev. 0, Page 245 of 294 Distribution Systems - Operatina B 3.8 (L)

BASES ACTIONS (continued)

b. The p ential for decreased fety when requiring entry into numer us applicable Conditi ns and Required Acti ns for comp nents without adequa e vital AC power, whil not providing suffici nt time for the operat rs to perform the nece sary evaluations and a tions to restore powe to the affected divisio and

c. The tential for an event i conjunction with a sin le failure of a redu dant component.

The 2 ho yr Completion Time ta es into account the im ortance to safety of restori g the AC vital bus to PERABLE status, thredundant capabilit afforded by the other OPERABLE vital buse , and the low probabili of a DBA occurring uring this period.

The se nd Completion Time r Required Action B.1 establishes a limit on the niaximum time allowed or any combination of required distribution .e subsyst ms to be inoperable uring any single conti uous occurrence of failing t meet the LCO. If Coadition B is entered whle, for instance, an AC bus is inoperable and sub equently returned O RABLE, the LCO may al ady have been not et for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . T is situation could lead to a total duration of 10 ours, since initial failur of the LCO, to restor the vital bus distributi n system. At this tim an AC division could again ecome inoperable, a d vital bus distribution ould be restored OPER BLE. This could con inue indefinitely.]

This ompletion Time allow for an exception th normal "time zero" for be inning the allowed o age time "clock." Thi allowance results in estab ishing the "time zero" t the time that the L was initially not met, inste d of at the time that C ndition B was entere . The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Cor letion Time is an acc ptable limitation on thi potential to fail to mee the LCO indefinitely.

L_ _ El With one or more statio-ervicl DC bor distribution paneiinoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystem is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical electrical power-) power distribution subsystem could result in the minimum required ESF Lubsysternues) functions not being supported. Therefore, the required DCIbssad i Idistrib ane must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

BWR/4 STS B 3.8.9-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 245 of 294

Attachment 1, Volume 13, Rev. 0, Page 246 of 294 Distribution Systems - Operating B 3.8 0

- BASES ACTIONS (continued) B i2lon en one or more UC teSIbriution panels I CWConditionYrepr D tout aduate DC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power.

It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continuq

b. The potential for decreased safety when requiring entry into 0

numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected divisions a 0

c. The potential for an event in conjunction with a single failure of a redundant component. _icerdistnbuon l The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC gulatory Guide 1.93 (Ref. p. i The second Completion Time for Required Actionl.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of

~ faing to meet the LCO. If ConditiorffM is entered while, for instance, an (

[ is inoperable and subsequently restored OPERABLE, the LCO 02 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could Isb lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to ssributionsystem. At this time, an AC io ould) am become inoperable, and DCqdistributior could be restoreddeectical '

aowr OPERABLE. This could continue indefinitely. LpfySt ower subsystem BWR/4 STS B 3.8.9-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 246 of 294

Attachment 1, Volume 13, Rev. 0, Page 247 of 294 Distribution Systems - Operating B 3.8 BASES ACTIONS (continued)

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time 'clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time ConditionM was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion (

Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

.1 andi02 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With one more DG DC buses noperable, the assocated DG(s) may be incapableof performing their in ended functions. In t is situation the DG(s) m st be immediately ddlared inoperable. T s action also require entry into applicable onditions and Requi ed Actions of LCO 3 .1, "AC Sources - 0 eratin ."

Inoperablity Condition corresponds to a level of degradation in the elecca t ()

Of _ uinsse htcue eurdsft function to be lost./

Wher more ~n on AC or DC electrical power distribution subsyste i results in the loss of a required function, the plant is in a E8 condition outside the accident analysis. Therefore, no additional time is Justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.* INEA BWR/4 STS B 3.8.9-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 247 of 294

Attachment 1, Volume 13, Rev. 0, Page 248 of 294 B 3.8.7 INSERT 2A The term "combination" means that the loss of function must result from the inoperability of two or more AC and DC electrical power distribution subsystems; a loss of function solely due to a single AC or DC electrical power distribution subsystem inoperability even with another AC or DC electrical power distribution subsystem concurrently inoperable does not require entry in Condition D.

Insert Page B 3.8.9-8 Attachment 1, Volume 13, Rev. 0, Page 248 of 294

Attachment 1, Volume 13, Rev. 0, Page 249 of 294 Distribution Systems - Operating B 3.8 BASES So SURVEILLANCE l , load center, or distribution panel REQUIREMENTS This Surveillance verifies that the AC and DCw electrical power distribution systems are functioning properly, with the correct circuit breaker I )

alignment. The correct breaker alignment ensures the appropriate

° S i separation and independence of the electricall b l are maintained and the appropriate voltage is available to each required busThe verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency in t the redundant capability of the AQ DCL andJ vitaI electrical power distribution subsystems, and other indications 0

available in the control room that alert the operator to subsystem malfunctions.

REFERENCES I 1. FSARrChapter [61.

0 E

(! *ASAR, Chapterer[' 00 Mn Regulatory Guide 1.93, December 1974 0D BWR/4 STS B 3.8.9-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 249 of 294

Attachment 1, Volume 13, Rev. 0, Page 250 of 294 Distribution Systems - Operating W B 3.8 I.,

I :2 TYPE

/ Table B 3. .9-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems l VOLTAGE [DIVISION 1]* [DIVISION 2]*

AC safety uses [4160 V] [ESF Bus] [NB01] [ESF Bus] [NB02]

[480 V] Load Centers Load Centers

[NG01, NG03] [NG02, NG04]

[480 V] Motor Control Motor Control Centers Centers

[NG01A, NG011, [NG02A, NG021, NG01B, NG03C, NG02B, NG04C, NG031, NG03D] NG041, NG04D]

[120 V] Distribution Panels Distribution Panels

[NP01; NP03] [NP02, NP04]

DC uses [125 VI] Bus [NK01] Bus [NK02]

Bus [NK03] Bus [NK04]

Distribution Panel Distribution Panels

[NK41, NK43, NK5 ] [NK42, NK44, NK52]

AC ital buses [120 Bus [NN01] Bus [NN02]

Bus [NN03] Bus [NN04]

Each of the AC and DC electrc al power distribution system[ is a subsystem.

iraln BWR/4 STS B 3.8.9-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 250 of 294

Attachment 1, Volume 13, Rev. 0, Page 251 of 294 B 3.8.7 O INSERT3 Table B 3.8.7-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE DIVISION 1(a) DIVISION 2(a)

AC Buses 4.16 kV Essential Bus 15 Essential Bus 16 480 V Load Center 103 Load Center 104 DC Buses 125/250 V Distribution Panel D31 Distribution Panel D100 125 V Distribution Panel D11 Distribution Panel D21 (a) Each division of the AC and DC Electrical Power Distribution Systems is a subsystem.

Insert Page B 3.8.9-10 Attachment 1, Volume 13, Rev. 0, Page 251 of 294

Attachment 1, Volume 13, Rev. 0, Page 252 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, DISTRIBUTION SYSTEMS - OPERATING

1. Changes have been made to reflect those changes made to the Specification.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. The brackets are removed and the proper plant specific information/value is provided.

4. This change has been made since Section 3.5, "ECCS and RCIC System" provides the appropriate limits that are affected by the systems in this LCO.

5. Typographical/grammatical error corrected.

6. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

7. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

8. This change has made to be consistent with the Applicability of LCO 3.8.8.

9. The LCO Bases implies that both the electrical power distribution subsystem powering the redundant subsystem and the redundant subsystem must be declared inoperable if the associated tie breakers are closed. This action would require entry in LCO 3.0.3. In this situation, the single failure criteria may not be met since independence is not maintained, however the safety criteria may not be met since independence is no maintained, however the safety function is maintained since both subsystems are being powered. The Bases have been revised such that, when a tie breaker between redundant buses is closed, only the electrical power distribution subsystem not being powered from is normal source is declared inoperable. This adequately limits the time the plant may operate with redundant subsystems connected to each other to the time currently allowed for one inoperable subsystem.

Since these two conditions are essentially equivalent, this change is acceptable.

10. Changes have been made to match the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 252 of 294

Attachment 1, Volume 13, Rev. 0, Page 253 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 253 of 294

Attachment 1, Volume 13, Rev. 0, Page 254 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, DISTRIBUTION SYSTEMS - OPERATING There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 254 of 294

, Volume 13, Rev. 0, Page 255 of 294 ATTACHMENT 8 ITS 3.8.8, Distribution Systems - Shutdown Attachment 1, Volume 13, Rev. 0, Page 255 of 294

Attachment 1, Volume 13, Rev. 0, Page 256 of 294 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 13, Rev. 0, Page 256 of 294

, Volume 13, Rev. 0, Page 257 of 294 ITS 3.8.8

-< Add proposed ITS LCO 3.8.8 and ITS 3.8.8 ACTION A OA Add proposed ITS SR 3.8.8.1 l(i Page 1 of 1 , Volume 13, Rev. 0, Page 257 of 294

Attachment 1, Volume 13, Rev. 0, Page 258 of 294 DISCUSSION OF CHANGES ITS 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A.1 The CTS does not contain any specific OPERABILITY requirements for the Distribution Systems during shutdown conditions. However, the CTS 1.0.W definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessary attendant ... normal and emergency electrical power sources ... that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s)." ITS LCO 3.8.8 requires the necessary portions of the AC and DC electrical power distribution subsystem to be OPERABLE to support equipment required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. If one or more required AC or DC electrical power distribution subsystems are inoperable, ITS 3.8.8 ACTION A must be entered and the associated supported required features(s) must be declared inoperable or certain activities must be suspended (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and operations with a potential for draining the reactor vessel (OPDRVs)), action must be initiated to restore the inoperable distribution subsystem, and the required shutdown cooling subsystem(s) must be declared inoperable and not in operation. This changes the CTS by adding the explicit requirements of ITS LCO 3.8.8 and ITS 3.8.8 ACTION A.

The purpose of ITS 3.8.8 is to ensure the necessary AC and DC electrical power distribution subsystems are available to provide emergency electrical power to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident. The change is acceptable since it is consistent with the requirements in CTS 1.0.W that all attendant equipment must be OPERABLE to support a required feature. In addition, the Required Action that allows the supported features to be declared inoperable is also acceptable because this declaration will require entry into all other Technical Specifications associated with inoperable features. This change is also consistent with the CTS since electrical power distribution system inoperabilities are currently covered by the supported system type LCOs (e.g., Control Room Ventilation System, Control Room Emergency Filtration System). ITS 3.8.8 ACTION A includes an option to the requirement to declare supported features inoperable. The option is to suspend certain activities (CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and OPDRVs), to immediately initiate action to restore the inoperable distribution subsystem(s) to OPERABLE status, and to declare the required shutdown cooling subsystem(s) inoperable and not in operation. The option to suspend the specified activities is consistent with the Required Actions in CTS 3.17.A.2 for the Control Room Ventilation System and CTS 3.17.B.1 for the Control Room Emergency Filtration System. The requirement to declare the affected shutdown cooling subsystem inoperable has

been added because Shutdown Cooling System LCOs have been added to the ITS (see Discussion of Changes for ITS 3.4.7, ITS 3.4.8, ITS 3.9.7, and ITS 3.9.8) and this change ensures the proper Actions are entered if the second action is taken. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power. Although not explicitly stated this action is always applied due to the importance of the equipment. This change is Monticello Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 258 of 294

Attachment 1, Volume 13, Rev. 0, Page 259 of 294 DISCUSSION OF CHANGES ITS 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.l CTS 4.9 does not have any specific Surveillance Requirements for the Distribution Systems when they are required to be OPERABLE to support equipment required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. ITS SR 3.8.8.1 requires verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems every 7 days. This changes the CTS by adding the explicit Surveillance for the portions of the electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment.

The purpose of ITS SR 3.8.8.1 isto ensure the AC and DC electrical power distribution subsystems are OPERABLE to provide emergency electrical power to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident involving handling irradiated fuel. This change is acceptable because the proposed Surveillance helps to ensure the required portions of the electrical power distribution subsystems are OPERABLE.

This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Monticello Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 259 of 294

Attachment 1, Volume 13, Rev. 0, Page 260 of 294 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 260 of 294

Attachment 1, Volume 13, Rev. 0, Page 261 of 294 Distribution Systems - Shutdown 3.8.

CTS 3.8 ELECTRICAL POWER SYSTEMS 3.81 R Distribution Systems - Shutdown 02 4

DOC A.1 LCO 3.8.M The necessary portions of the A Dc [anH distribution subsystems shall be OPERABLE to support equipment lIbs electrical power 0

required to be OPERABLE.

APPLICABILITY: MODES 4 and 5, During movement of rec t y irradiated fuel assemblies in the EsecondaryM containment. 0 ACTIONS i c a b le. ___________

- - - - - - -- M C 1TrTF L C O _3 . 0 . 3_isn o-t a DOC A.1 LCO 3.0.3 isnot applicable...

CONDITION REQUIRED ACTION COMPLETION TIME DOC A. One or more required A.1 Declare associated Immediately A.1 lH~J DC;[or A alus supported required electrical power feature(s) inoperable.

distribution subsystems inoperable. OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend handling of Immediately r adirradiated fuel assemblies in the (0 TsecondarA containment.

AND BWR/4 STS 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 261 of 294

Attachment 1, Volume 13, Rev. 0, Page 262 of 294 Distribution Systems - Shutdown 3.8. h()

.I. ACTIONS (continued)_

CONDITION REQUIRED ACTION COMPLETION TIME DOC A.2.3 Initiate action to suspend Immediately A.1 operations with a potential for draining the reactor vessel.

AND A.2.4 Initiate actions to restore Immediately ET;I required AODCOaA vitausl electrical power 0 distribution subsystems to OPERABLE status.

AND A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

./)

DOC M.1 SR 3.8.ID1 r

Ven correct breaker alignments and voltage to equired A D and ital bus electrical power 7 days 0 distribution subsystems. 0 BWR/4 STS 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1,Volume 13, Rev. 0, Page 262 of 294

Attachment 1, Volume 13, Rev. 0, Page 263 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN

1. ISTS 3.8.10 is renumbered as ITS 3.8.8 since ISTS 3.8.7, "Inverters - Operating,"

and ISTS 3.8.8, "Inverters - Shutdown," are not included in the Monticello ITS.

2. The bracketed requirements for the AC vital buses in ISTS LCO 3.8.10 (ITS LCO 3.8.8), ISTS 3.8.10 (ITS 3.8.8) ACTION A, and ISTS SR 3.8.10.1 (ITS SR 3.8.8.1) have been deleted. The change is consistent with the current licensing basis.

3. The brackets have been removed and the proper plant specific information/value has been provided.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 263 of 294

Attachment 1, Volume 13, Rev. 0, Page 264 of 294 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 264 of 294

Attachment 1, Volume 13, Rev. 0, Page 265 of 294 Distribution Systems - Shutdown B3.8-.,x(0i B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.A~stribution Systems - Shutdown BASES r{3 BACKGROUND A description of the AC<< 0 an ita u electrical power distribution system is provided in the Bases for LCO 3.8g,"Distribution Systems - (0 Operating." 1f

1) B APP'LICABLE The initial conditions of Design Basis Accident a d transient analyses in' SAF ETY , us (JSAR, ChapteRef. 1)andlChapter [Ref.7, 00assume ANA&LYSES ineered Safety Feature (ESF) systems are OPERABLE. The ACf DCo IiandAial busJelectrical power distribution systems are designed toadJ Emergency Core provide sufficient capacity, capability, redundancy, and reliability to Cooling System and ReactorCore enssure the availabilit of necessary power to ESF systems so that the fuen,ReactorCant Systemi and containment design limits are not Isolation Cooling System exceeded. 0 The OPERABILITY of the ACt and M talu electrical power distribution system is consistent with the initial assumptions of the 0D accident analyses and the requirements for the supported systems'

~nDnDAnII

'.FnJDIL

TIV I. and The OPERABILITY of the minimum AC(D6 a electrical 0 power sources and associated power distribution subsystems during MODES 4 and 5, and during movement assemblies in the secondary containment o fre ensures ntly irradiated that:

fuel 0

a. The facility can be maintained in the shutdown or refueling condition for extended periodsoQ 0

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statusan

c. Adequate power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accidentjinvolving handling ct irradiated fuel. e to radioactive decay, AC and DC eiectcial power isdoly requ .e to miigtfulhandling accidents SKolving handling rery irradiates fulpt. ulthat has occi withi

( days)1. /

xipevos (71e-s ThelAC and rical poweAistri e ati ICriterion 3 of 10 CFR 50.36(c)(2)(ii). y 1-Shutdowni BWR/4 STS B 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 265 of 294

Attachment 1, Volume 13, Rev. 0, Page 266 of 294 Distribution Systems - Shutdown B 3.8ov BASES LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of Technical Specifications required systems, equipment, and components - both specifically addressed by their own LCO, and implicitly required by the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidentsTinvolving handling tirradiated fueu and inadvertent reactor vessel draindown).

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement o re t irradiated fuel assemblies in thelsecondaryl containment provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core in case of an inadvertent draindown of the reactor vessels

b. Systems needed to mitigate a fuel handling accident involving 0 handling rcntvirradiated fuelfefel that has occupipbd part of a L FZcntIca core Wthin the previoup [X] days)] are avdilableL eor

c. Systems necessary to mitigate the effects of events that can lead core damage during shutdown are availableen

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The ACDC and Metal bu electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LCO 3.8 (if)

ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, or 3 would require the unit to be shutdown unnecessarily.

BWR/4 STS B 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 266 of 294

Attachment 1, Volume 13, Rev. 0, Page 267 of 294 Distribution Systems - Shutdown B 3.8.RL (iD BASES ACTIONS (continued)

A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, re ti irradiated fuel movement, and operations with a potential for draining the reactor vessel. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made, (i.e., to suspend CORE ALTERATIONS, movement of re tI irradiated fuel assemblies in thefsecondarA containment, and any activities that could result in inadvertent draining of the reactor vessel).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal-shutdown cooling (RHR-SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR-SDC ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR-SDC inoperable, which results in taking the appropriate RHR-SDC ACTIONS.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power.

BWR/4 STS B 3.8.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 267 of 294

Attachment 1, Volume 13, Rev. 0, Page 268 of 294 Distribution Systems - Shutdown B 3.8.RkQ3 BASES W SURVEILLANCE REQUIREMENTS SR 3.8.6.1 0D This Surveillance verifies that the A D and a u electrical power distribution subsystem is functioning properly, with the buses 0

energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the electrical power distribution subsystems, as well as other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES I 1. FSRr-hapter [6].1 0 0Qj SAR, ChapterrAeD _(~DO BWR/4 STS B 3.8.10-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 268 of 294

Attachment 1, Volume 13, Rev. 0, Page 269 of 294 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Changes are made to the Bases that reflect changes made to the Specifications.

2. The brackets are removed and the proper plant specific information/value is provided.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

5. Changes are made to be consistent with the name of the Specification.

6. This change has been made since Section 3.5, "ECCS and RCIC System," provides the appropriate limits that are affected by the systems of this LCO.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 269 of 294

Attachment 1,Volume 13, Rev. 0, Page 270 of 294 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 270 of 294

Attachment 1, Volume 13, Rev. 0, Page 271 of 294 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 271 of 294

Attachment 1, Volume 13, Rev. 0, Page 272 of 294 ATTACHMENT 9 Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 13, Rev. 0, Page 272 of 294

, Volume 13, Rev. 0, Page 273 of 294 ISTS 3.8.7, Inverters - Operating , Volume 13, Rev. 0, Page 273 of 294

Attachment 1, Volume 13, Rev. 0, Page 274 of 294 ISTS 3.8.7 Markup and Justification for beviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 274 of 294

Attachment 1, Volume 13, Rev. 0, Page 275 of 294 Inverters- - Operating 3.8.7 3.8 ELECTRI AL POWER YSTEMS 3.8.7 Inv rters - Operating LCO 3.8.7 The [Division 1] aind Division 2] inverters shall be PERABLE.

._4%

MfBrr 1 ",-- - _ -- -------- ----- _

[One/two] inverte rs may be disconnected from [i s/their] associated DC bus for < [24] hou rs o perform an equalizing char e on [its/their]

associated [comrr io ] battery, provided:

a. The associate AC vital bus[es] [is/are] ene gized from [its/their]

[Class 1E cc tn ant voltage transformers] [iverter using internal AC source] and

b. All other AC Vtal buses are energized from their associated OPERABLE i verters.]

APPLICABI ITY: MODES 1, 2, and (0 ACTIONS 40NDITION REQUIRED ACTION COMPLETION TIME A. One required] inverter A.1 ------ NOTE---

inop rable. Enter applicable Condition and Required Actions of LCO 3.8.9, "Distribution l Systems - Operating" with any AC vital bus de-energized.

Restore inverter to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

B. Re uired Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months as ociated Completion Ti e not met. AN B.21 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWR/4/TS I 3.8.7-1 Attachment 1, Volume 13, Rev. 0, Page 275 of 294 I Rev. 3.0, 03/31/04

, Volume 13, Rev. 0, Page 276 of 294 0D , Volume 13, Rev. 0, Page 276 of 294

Attachment 1, Volume 13, Rev. 0, Page 277 of 294 JUSTIFICATION FOR DEVIATIONS ISTS 3.8.7, INVERTERS - OPERATING

1. ISTS 3.8.7, "Inverters - Operating," has been deleted since the current licensing basis does not require the inverter to supply the associated loads. In addition, if the associated distribution panels are energized by the alternate source for extended periods, there will be no long term degradation of equipment. Therefore, this Specification is not proposed for the Monticello.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 277 of 294

Attachment 1, Volume 13, Rev. 0, Page 278 of 294 ISTS 3.8.7 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 278 of 294

Attachment 1, Volume 13, Rev. 0, Page 279 of 294 nverters - Operating B 3.8.7 B 3.8 ELECTRI AL POWER SYSTEMS B 3.8.7 Inverte - Operating BASESl BACKGROUN Th inverters are the G source of power for eered H uses eA ia because of the stabilt an eiblity they achieve. Thr soeinverter per AC vital bus, makig a total of four inverters. T e function of the inverter is to provide C electrical power to the vita buses. The inverter can be powered from n internal AC source/rectifie or from the station battery. The station attery provides an uninterrup ible power source for the instrumentation a d controls for the Reactor Pr tection System (RPS) and the Emergency ore Cooling Systems (ECCS initiation.

l Specific details on in rters and their operating ch racteristics are found l in FSAR, Chapter [8 (Ref. 1).l APPLICABLE The initial conditions of Design Basis Accident (D A) and transient SAFETY l analyses in the FSAA hpe [6] (Ref. 2) andCatr[5 (Ref. 3),

ANALYSES assume Engineered Safety Feature systems are PERABLE. The inverters are design d to provide the required caacity, capability, (0 redundancy, and reability to ensure the availabil y of necessary power to the RPS and ECC instrumentation and controls o that the fuel, Reactor Coolant System, aT containment design limits ate not exceeded. These limits are discussein moredetail in the Bases f r Section 3.2, Power Distribution Limits; ection 3.4, Reactor Coolant ystem (RCS); and Section 3.6, Contai ment Systems.

The OPERABILI of the inverters is consistent with the initial assumptions of th accident analyses and is ba ed on meeting the design basis of the unit. his includes maintaining elec rical power sources OPERABLE durinn accident conditions in the e ent of:

a. An assumed I ss of all offsite AC electrical ower or all onsite AC electrical po r and

b. A worst case single failure.

The inverters are a part of the distribution systm and, as such, satisfy Criterion 3 of 10 FR 50.36(c)(2)(ii).

LCO The inverters en ure the availability of AC ele trical power for the instrumentation r the systems required to sht down the reactor and maintain it in a s fe condition after an anticipa ed operational occurrence (AOO) or a post lated DBA.

BWRI4 4TS B 3.8.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 279 of 294

Attachment 1, Volume 13, Rev. 0, Page 280 of 294 I I I verters - Operating

/ B3.8.7 BASES LCO (continued Maintaining the require inverters OPERABLE ensur s that the redundancy incorporat d into the design of the RPS nd ECCS instrumentation and co trols is maintained. The fou battery powered inverters ensure an uni terruptible supply of AC ele rical power to the AC vital buses even if he 4.16 kV safety buses are e-energized.

OPERABLE inverters equire the associated vital b to be powered by the inverter with outpu voltage and frequency withi tolerances, and power input to the nv rter from a [125 VDC] statin battery.

Alternatively, power s pply may be from an internal AC source via rectifier as long as th station battery is available a the uninterruptible power supply.

This LCO is modified y a Note allowing [two] inve er[s] to be disconnected from thir associated DC busesSl24 for hours. This allowance is provide to perform an equalizing ch rge on one battery. If the inverters were n disconnected, the resulting oltage condition might damage the inverter energized from their associa ed DC bus.

Disconnecting the in erters is allowed provided th t the associated AC vital buses are enerized from their [Class 1E con tant voltage source 0 transformer or inve r using an internal AC sour e] and that the AC vital buses for the other ivision(s) are energized from he associated inverters connected to their buses. These provisions inimize the loss of equipment that occurs in the event of a loss of o ite power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period for the Ilowance minimizes the time uring which a loss of offsite power could result in the loss of equipmen energized from the affected AC vital b while it takes into consider ion the time required to perform an equalizi g charge on the batteries.

The intent of the N te is to limit the number of in erters that may be disconnected. On those inverters associated ith the single battery undergoing an eq lizing charge may be discon ected. All other inverters must be ligned to their associated ba eries, regardless of the number of inverter or plant design.

BWR/4 S$S l B 3.8.7-2 Rev. 3.0, 03/31/04 I

Attachment 1, Volume 13, Rev. 0, Page 280 of 294

Attachment 1, Volume 13, Rev. 0, Page 281 of 294 I I nverters - Operating B 3.8.7 BASES APPLICABILI The inverters are requl ed to be OPERABLE in MO ES 1, 2, and 3 to ensure that:

a. Acceptable fuel d sign limits and reactor coolat pressure boundary limits are not exc eded as a result of AOOs or bnormal transients and

b. Adequate core c oling is provided, and contai ment OPERABILITY and other vital fuctions are maintained in the vent of a postulated DBA.

Inverter requirement or MODES 4 and 5 are cove d in the Bases for LCO 3.8.8, "Inverter - Shutdown."

ACTIONS A.1 With a required inve er inoperable, its associated C vital bus becomes inoperable until it is anually re-energized from it [Class I E constant voltage source tran former or inverter using an in ernal AC source].

LCO 3.8.9 addresses this action; however, pursu nt to LCO 3.0.6, these actions would not b entered even if the AC vital us were de-energized.

Therefore, the ACT ONS are modified by a Note o require the ACTIONS for LCO 3.8.9 be e tered immediately. This ens res the vital bus is re- 0D energized within 2 ours.

Required Action A. allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to fix the in perable inverter and return it to service. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit is based u on engineering judgment and takes into con ideration the time required t repair an inverter and the additional risk o which the unit is exposed b cause of the inverter inoperability. This risk has to be balanced agai st the risk of an immediate shutdo n, along with the potential challenges to safety systems that suc a shutdown might entail. When the AC vital bus is powered from its onstant voltage source, it is lying upon interruptible AC electrical pow r sources (offsite and onsiteJ. Similarly, the uninterruptible in erter source to the AC vital buses is the preferred source for poweri g instrumentation trip setpoi t devices.

B.1 and B.2 If the inoperable evices or components cann t be restored to OPERABLE stat s within the associated Completion Time, the unit must be brought to a ODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least ODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 withln 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Cor ipletion Times are reasonable, ba ed on operating experience, to reach the required plant conditions from ull power conditions in an or erly manner and without challenging uni systems.

BWR/4 4TS I B3.8.7-3 I' Rev. 3.0, 03131/04 Attachment 1, Volume 13, Rev. 0, Page 281 of 294

Attachment 1, Volume 13, Rev. 0, Page 282 of 294 I I nverters - Operating

/ B3.8.7 BASES SURVEILLANC SR 3.8.7.1 REQUIREMEN S This Surveillance verifi s that the inverters are funct ning properly with all required circuit bre ers closed and AC vital bus s energized from the inverter. The verificati n of proper voltage and freq ency output ensures that the required pow is readily available for instru entation connected to the AC vital buses. The 7 day Frequency takes i to account the redundant capability the inverters and other indi tions available in the control room that ale the operator to inverter malf nctions.

I

1. FSAR, Chapter [I].

2. FSAR, Chapter ri.

3. FSAR, Chapter l15].

0D BWRI4 T B 3.8.7-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 282 of 294

Attachment 1, Volume 13, Rev. 0, Page 283 of 294 JUSTIFICATION FOR DEVIATIONS ISTS 3.8.7 BASES, INVERTERS - OPERATING

1. Changes have been made to reflect those changes made to the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 283 of 294

, Volume 13, Rev. 0, Page 284 of 294 ISTS 3.8.8, Inverters - Shutdown , Volume 13, Rev. 0, Page 284 of 294

Attachment 1, Volume 13, Rev. 0, Page 285 of 294 ISTS 3.8.8 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 285 of 294

Attachment 1, Volume 13, Rev. 0, Page 286 of 294 Inverters - Shutdo wn 3.E8.8 3.8 ELECTRI AL POWER SYSTEMS 3.8.8 Inv rters - Shutdown LCO 3.8.8 [Inverter(s) shall t be PERABLE to support the on ite Class 1E AC vital bus electrical pow 'eristribution subsystem(s) req ired by LCO 3.8.10, "Distribution SystEem - Shutdown."]

[One] inverter[s] s haI be OPERABLE.]

bU\l~AIO~: I-TU This second optio n l bbove applies for plants havir a pre-ITS licensing basis (CTS) for eli eqtrical power requirements du ng shutdown conditions that required only [qne] inverter to be OPERABL . The "[or more]"

optional wording i n ondition A is also eliminate for this case. The first option above is acd pted for plants that have a C S requiring the same level of DC electri cI power subsystemlinverter upport as is required for power operating c nditions.

APPLICABI ITY: MODES 4 and 5, During movement of [recently] irradiated fuel as emblies in the

[secondary] c ontainment.

0D ACTIONS

___ ________------1----IN LCO 3.0.3Iis not applicable.

I I

I I ONDITION REQUIRED ACTION COMPLETION TIME

. A. On [or more] [required] Declare affected required Immediately inv er[s] inoperable. feature(s) inoperable.

I Suspend CORE Immediately ALTERATIONS. -

AND I I l _

BWR/4/STS 3.8.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 286 of 294

Attachment 1, Volume 13, Rev. 0, Page 287 of 294 ACTIONS (con/nued)

CON ITION I

RE UIRED ACTION

/I Inverters - Shutdown OMPLETION TIME 3.8.8 A.2.2 S spend handling of I mediately

[r cently] irradiated fuel a semblies in the

[ condary] containment.

AND A.2.3 I itiate action to suspend Immediately perations with a potential f r draining the reactor essel.

AND 0 A.2.4 nitiate action to restore Immediately

[required] inverters to l pPERABLE status.

SURVEIL NCE REQUIREMENTS _ _ _

SURVEIL NCE FREQUENCY SR 3.8.8 1 Verify correct inve rer voltage, [frequency,] and 7 days alignments to [req ired] AC vital buses.

BWR/4 TS 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 287 of 294

Attachment 1, Volume 13, Rev. 0, Page 288 of 294 JUSTIFICATION FOR DEVIATIONS ISTS 3.8.8, INVERTERS - SHUTDOWN

1. ISTS 3.8.8, "Shutdown - Shutdown," has been deleted since the current licensing basis does not require the inverter to supply the associated loads. In addition, if the associated distribution panels are energized by the alternate source for extended periods, there will be no long term degradation of equipment. Therefore, this Specification is not proposed for the Monticello.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 288 of 294

Attachment 1, Volume 13, Rev. 0, Page 289 of 294 ISTS 3.8.8 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 289 of 294

Attachment 1, Volume 13, Rev. 0, Page 290 of 294 Inverters - Shutdown B 3.8.8 B 3.8 ELECT ICAL POWER SYSTEMS B 3.8.8 Invert rs - Shutdown BASES BACKGROU D A description of the itverters is provided in the Bakes for LCO 3.8.7, "Inverters - Operatin ."[

APPLICABL The initial condition of Design Basis Accident (D A) and transient SAFETY analyses in the FS R, Chapter [6] (Ref. 1) and C apter [15] (Ref. 2),

ANALYSES assume Engineere Safety Feature systems are PERABLE. The DC to AC inverters are de igned to provide the require capacity, capability, redundancy, and re iability to ensure the availabil ty of necessary power to the Reactor Protec on System and Emergency ore Cooling Systems instrumentation an controls so that the fuel, Re ctor Coolant System, and containment d sign limits are not exceeded.

The OPERABILI of the inverters is consistent with the initial assumptions of th accident analyses and the r quirements for the supported system 'OPERABILITY.

0 The OPERABILI of the minimum inverters to ach AC vital bus during MODES 4 and 5 nsures that:

a. The facility c n be maintained in the shutd wn or refueling condition for extended eriods,

b. Sufficient ins rumentation and control cap bility are available for monitoring a d maintaining the unit status and

c. Adequate p wer is available to mitigate e ents postulated during shutdown, s ch as an inadvertent draind n of the vessel or a fuel handling ac ident [involving handling rec ntly irradiated fuel. Due to radioactive ecay, the AC and DC invert s are only required to mitigate fue handling accidents involving handling recently irradiated fuel (i.e., fu I that has occupied part of a ritical reactor core within the previou [X] days)].

In general, whe the unit is shut down, the T chnical Specifications requirements elsure that the unit has the ca ability to mitigate the consequences f postulated accidents. Ho ver, assuming a single failure and con urrent loss of all offsite or all nsite power is not required.

The rationale f r this is based on the fact th many Design Basis BWPJ4ISTS I B 3.8.8-1 I Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 290 of 294

Attachment 1, Volume 13, Rev. 0, Page 291 of 294 I verters - Shutdown B 3.8.8 BASES APPLICABLE S FETY ANALYSES (continu d)

Accidents (DBAs) that re analyzed in MODES 1, 2, nd 3 have no specific analyses in M DES 4 and 5. Worst case b unding events are deemed not credible i MODES 4 and 5 because th energy contained within the reactor presure boundary, reactor coola t temperature and pressure, and the corr sponding stresses result in tle probabilities of occurrence being sign ficantly reduced or eliminate , and in minimal consequences. Thes deviations from DBA analys assumptions and design requirements uring shutdown conditions ar allowed by the LCO for required systems.

The shutdown Techn al Specification requirement are designed to ensure that the unit h s the capability to mitigate t e consequences of certain postulated ac idents. Worst case DBA whi h are analyzed for operating MODES a generally viewed not to be significant concern during shutdown MO ES due to the lower energi involved. The Technical Specificati ns therefore require a lesse complement of Telectrical equipment o be available during shutdo n than is required during operating M DES. More recent work com leted on the potential risks associated wit shutdown, however, have fo nd significant risk associated with cert in shutdown evolutions. As result, in addition to the requirements es ablished in the Technical Sp cifications, the industry has adopted NUMA C 91-06, "Guidelines for Ind stry Actions to Assess Shutdown Manage ent," as an Industry initiative to manage shutdown tasks and associatd electrical support to maintanrisk at an acceptable low level. This ma require the availability of ad itional equipment beyond that requird by the shutdown Technical pecifications.

The inverters were previously identified as part f the Distribution System and, as such, satis Criterion 3 of 10 CFR 50.3 (c)(2)(ii).

LCO The inverter[s] en ure the availability of electri I power for the instrumentation fosystems required to shut d n the reactor and maintain it in a sa condition after an anticipatd operational occurrence or postulated DB . The battery powered invert r[s] provide[s]

uninterruptible su ply of AC electrical power to e AC vital bus[es] even if the 4.16 kV saty buses are de-energized. PERABLE inverter[s]

require the AC vit I bus be powered by the iv rter through inverted DC voltage. This en ures the availability of suffici t inverter power sources to operate the pl nt in a safe manner and to m igate the consequences of postulated event during shutdown (e.g., fuel andling accidents

[involving handli g recently irradiated fuel] an inadvertent reactor vessel draindown).

BWR/4 S B 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 291 of 294

Attachment 1, Volume 13, Rev. 0, Page 292 of 294 I I nverters - Shutdown B 3.8.8 BASES APPLICABILI The inverter[s] require to be OPERABLE in MODE 4 and 5 and also any time during move ent of [recently] irradiated fu assemblies in the

[primary or secondary] containment provide assuran e that:

a. Systems to provi adequate coolant inventory makeup are available for the irradiated el in the core in case of an i advertent draindown of the reactor ves el,

b. Systems needed o mitigate a fuel handling ac dent [involving handling recently irradiated fuel (i.e., fuel that as occupied part of a critical reactor c e within the previous [X] day )] are available,

c. Systems necess ryto mitigate the effects of e ents that can lead to core damage du ing shutdown are available, nd

d. Instrumentation nd control capability is avail ble for monitoring and maintaining the nit in a cold shutdown condi on or refueling condition.

Inverter requirements for MODES 1, 2, and 3 are overed in LCO 3.8.7.

0 ACTIONS LCO 3.0.3 is not ap Ilicable while in MODE 4 or 5 However, since irradiated fuel assehbly movement can occur in ODE 1, 2, or 3, the ACTIONS have be n modified by a Note stating hat LCO 3.0.3 is not applicable. If movi g irradiated fuel assemblies hile in MODE 4 or 5, LCO 3.0.3 would n t specify any action. If movi g irradiated fuel assemblies while i MODE 1, 2, or 3, the fuel m vement is independent of reactor operatio s. Entering LCO 3.0.3, whilein MODE 1, 2, or 3 would require the nit to be shutdown unnecess rily.

A.1. A.2.1. A.2.2. .2.3. and A.2.4

[If two divisions a required by LCO 3.8.10, "D tribution Systems -

Shutdown," the r aining OPERABLE inverter may be capable of supporting suffici nt required feature(s) to allo continuation of CORE ALTERATIONS, recently] irradiated fuel move ent, and operations with a potential for dr ining the reactor vessel.] By he allowance of the option to declare requir d feature(s) inoperable with te associated inverter(s) inoperable, appr priate restrictions are imple ented in accordance with the affected requred feature(s) of the LCOs' TIONS. In many instances, this o tion may involve undesired aministrative efforts.

Therefore, the al owance for sufficiently cons ative actions is made (i.e., to suspend CORE ALTERATIONS, moment of [recently] irradiated fuel assemblies n the [primary or secondary] ontainment, and any activities that co Id result in inadvertent drain g of the reactor vessel).

BWR/4 4TS I B 3.8.8-3 I Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 292 of 294

Attachment 1, Volume 13, Rev. 0, Page 293 of 294 I I Inverters - Shutdown B 3.8.8 BASES ACTIONS (con inued)

Suspension of these ctivities shall not preclude co pletion of actions to establish a safe cons rvative condition. These acti ns minimize the probability of the occ rrence of postulated events. t is further required to immediately initiate a tion to restore the required i erter[s] and to continue this action u til restoration is accomplishe in order to provide the necessary invert r power to the plant safety sy tems.

The Completion Tim of immediately is consistent ith the required times for actions requiring rompt attention. The restora ion of the required inverters should be mpleted as quickly as possi le in order to minimize the timethe plant sa ty may be without ower or powered from systems ta constant voltage s aurce transformer.

SURVEILLA CE SR 3.8.8.1 REQUIREM ETS ThisSurveillance ifieshat theinverters arefuctioningproperly with l all required circuit beakers closed and AC vital b ses energized from the inverter. The venifiq ation of proper voltage and frquency output ensures that the required p wr is readily available for t isrmnation 0D connected to the A vital buses. The 7 day Fredec ae into account l the redundant cap bility of the inverters and othe niain available in l the control room th it alert the operator to invertf mlucins.

REFEREN jES 1. FSAR, Chapt r [6].l l2. FSAR, Chapt r [1 5].!

BWRI4 TS B 3.8.8-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 293 of 294

Attachment 1, Volume 13, Rev. 0, Page 294 of 294 JUSTIFICATION FOR DEVIATIONS ISTS 3.8.8 BASES, INVERTERS - SHUTDOWN

1. Changes have been made to reflect those changes made to the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 294 of 294

ML051990459

Text

3.8.4 Specification

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