Text

License Amendment Application, Revise Technical Specification 3/4.8.1.1 to Adopt a More Recent Standard for Diesel Fuel Oil Testing and Remove the Requirement to Perform Certain Surveillance Requirements During Shutdown
	ML052100160
Person / Time
Site:	Davis Besse
Issue date:	07/27/2005
From:	Bezilla M; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	03-0015, 3158
	Download: ML052100160 (30)
	v • d • e

FENOC FEA ow 5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor Ohio 43449 Mark B. Bezifla 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 Docket Number 50-346 10 CFR 50.90 License Number NPF-3 Serial Number 3158 July 27, 2005 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

Davis-Besse Nuclear Power Station License Amendment Application to Revise Technical Specification 3/4.8.1. 1, "A. C.

Sources - Operating," to Adopt a More Recent Standard for Diesel Fuel Oil Testing and Remove the Requirement to Perform Certain Surveillance Requirements During Shutdown (License Amendment Request No. 03-0015)

Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, the following amendment is requested for the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS). The proposed change would revise Technical Specification (TS) 3/4.8.1.1, "A. C. Sources - Operating," to adopt a more recent standard for diesel fuel oil testing and remove the restriction that certain surveillance requirements be performed during shutdown. The DBNPS staff has evaluated the proposed changes to the Technical Specifications against the criteria of 10 CFR 50.92(c) and concludes that this amendment would not involve a significant hazards consideration.

Approval of the proposed amendment is requested by February 1, 2006, to have the changes available prior to the fourteenth refueling outage, which is currently scheduled to commence in March 2006. Once approved, the amendment shall be implemented within 120 days.

The proposed changes have been reviewed by the DBNPS Plant Operations Review Committee and Company Nuclear Review Board. Enclosure 1 includes an evaluation of the proposed amendment. A list of regulatory commitments made in this letter is included in Enclosure 2.

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 2 Should you have any questions or require additional information, please contact Mr. Henry L. Hegrat, Supervisor - Fleet Licensing, at (330) 315-6944.

The statements contained in this submittal, including its associated enclosures and attachments, are true and correct to the best of my knowledge and belief. I am authorized by the FirstEnergy Nuclear Operating Company to make this submittal. I declare under penalty of perjury that the foregoing is true and correct.

Executed on -( '

6X~d/S MAR Enclosures cc: Regional Administrator, NRC Region III W. A. Macon, NRC/NRR Project Manager N. Dragani, Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

C. S. Thomas, NRC Region III, DB-1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 1 DAVIS-BESSE NUCLEAR POWER STATION EVALUATION FOR LICENSE AMENDMENT REQUEST NUMBER 03-0015

Subject:

License Amendment Application to Revise Technical Specification 3/4.8.1.1, "A. C.

Sources - Operating," to Adopt a More Recent Standard for Diesel Fuel Oil Testing and Remove the Requirement to Perform Certain Surveillance Requirements During Shutdown

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration (NSHC) 5.2 Applicable Regulatory Requirements/Criteria

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

8.0 ATTACHMENTS

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 2

1.0 DESCRIPTION

This is a request to amend the Davis-Besse Nuclear Power Station, Unit Number 1 Facility Operating License Number NPF-3.

The proposed changes would revise Technical Specification (TS) 3/4.8.1.1, "A. C. Sources -

Operating," to adopt a more recent standard for diesel fuel oil testing and remove the restriction that certain surveillance requirements be performed during shutdown. Specifically, the proposed amendment would revise TS Surveillance Requirement (SR) 4.8.1.1.2.b to replace American Society for Testing and Materials (ASTM) Standard D 975-68 with more recent version ASTM D 975-98b. Additionally, the proposed change would revise SR 4.8.1.1.2.d to eliminate the requirement to perform SR 4.8.1.1.2.d.I and SR 4.8.1.1.2.d.3 during shutdown.

2.0 PROPOSED CHANGE

The proposed changes are shown in the marked-up TS pages in Attachment 1 and affect TS 3/4.8.1.1, "A. C. Sources - Operating."

The proposed amendment would revise SR 4.8.1.1.2.b to replace the existing reference to ASTM D 975-68 with a reference to ASTM D 975-98b. The revised SR 4.8.1.1.2.b would state:

At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified in Table I of ASTM D975-98b when checked for viscosity, water and sediment.

The proposed amendment would revise SR 4.8.1.1.2.d to eliminate the restriction that SR 4.8.1.1.2.d.1 and SR 4.8.1.1.2.d.3 be performed during shutdown by deleting "during shutdown" from SR 4.8.1.1.2.d. The proposed change would retain the requirement to perform SR 4.8.1.1.2.d.2 and 4.8.1.1.2.d.4 during shutdown by adding "during shutdown" to each of these SRs. SR 4.8.1.1.2.d currently states:

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

d. At least once each REFUELING INTERVAL during shutdown by:

1. Verifying the generator capability to reject a load equal to the largest single emergency load supplied by the generator without tripping.

2. Simulating a loss of offsite power in conjunction with a safety features actuation system (SFAS) test signal, and:

(a) Verifying de-energization of the essential busses and load shedding

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 3 from the essential busses.

(b) Verifying the diesel starts from ambient condition on the auto-start signal, energizes the essential busses with permanently connected loads, energizes the auto-connected essential loads through the load sequencer and operates for 2 5 minutes while its generator is loaded with the essential loads.

(c) Verifying that all diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the essential bus and/or an SFAS test signal.

3. Verifying the diesel generator operates for 2 60 minutes while loaded to >

2000 kw.

4. Verifying that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating of 2838 kw.

The proposed revised SR 4.8.1.1.2.d would state:

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

d. At least once each REFUELING INTERVAL by:

1. Verifying the generator capability to reject a load equal to the largest single emergency load supplied by the generator without tripping.

2. Simulating during shutdown a loss of offsite power in conjunction with a safety features actuation system (SFAS) test signal, and:

(a) Verifying de-energization of the essential busses and load shedding from the essential busses.

(b) Verifying the diesel starts from ambient condition on the auto-start signal, energizes the essential busses with permanently connected loads, energizes the auto-connected essential loads through the load sequencer and operates for 2 5 minutes while its generator is loaded with the essential loads.

(c) Verifying that all diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the essential bus and/or an SFAS test signal.

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 4

3. Verifying the diesel generator operates for 2 60 minutes while loaded to >

2000 kw.

4. Verifying during shutdown that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating of 2838 kw.

It is noted that by license amendment application dated August 20, 2004 (Serial Number 2957),

FENOC requested deletion of SR 4.8.1.1.2.d.4. The changes being proposed by the current application do not affect the previously submitted application. Should the August 20, 2004 amendment application be approved prior to the current application, the change to SR 4.8.1.1.2.d.4 would no longer be necessary since SR 4.8.1.1.2.d.4 would have been deleted.

In summary, the proposed changes would revise Technical Specification (TS) 3/4.8.1.1, "A. C.

Sources - Operating," to adopt a more recent standard for diesel fuel oil testing and remove the restriction that certain surveillance requirements be performed during shutdown. Specifically, the proposed amendment would revise TS Surveillance Requirement (SR) 4.8.1.1.2.b to replace American Society for Testing and Materials (ASTM) Standard D 975-68 with more recent version ASTM D 975-98b. Additionally, the proposed change would revise SR 4.8.1.1.2.d to eliminate the requirement to perform SR 4.8.1.1.2.d.1 and SR 4.8.1.1.2.d.3 during shutdown.

No associated change to the Technical Specification Bases is being made.

3.0 BACKGROUND

Emergency Diesel Generator (EDG) Fuel Oil The EDG diesel oil system includes seven days' storage of fuel oil for each emergency diesel generator. This system consists of the emergency diesel generator day tank, bulk storage (week) tank, pumps, and associated piping and valves to the respective diesel generator. TS-required surveillance testing of the fuel oil for viscosity, water, and sediment is currently performed in accordance with ASTM D 975-68, "Standard Classification of Diesel Fuel Oils." The proposed change would require use of ASTM D 975-98b, "Standard Specification for Diesel Fuel Oils,"

for testing the fuel oil for viscosity, water, and sediment. Both ASTM D 975-68 and D 975-98b require use of the same test methods for determining viscosity. ASTM D 975-68 specifies use of ASTM D 1796, "Water and Sediment in Crude Oils and Fuel Oils by Centrifuge," for measuring water and sediment. ASTM D 975-98b would require use of ASTM D 2709, "Test Method for Water and Sediment in Distillate Fuels by Centrifuge," for measuring water and sediment. The reason for the requesting the proposed change to SR 4.8.1.1.2.b is to allow use of ASTM D 2709 for measuring water and sediment. ASTM D 2709 reports water and sediment volume to the nearest 0.005% whereas ASTM D 1796 reports results to no better than the nearest 0.025%.

This would alert personnel earlier of diesel fuel degradation, enabling the plant to take corrective action prior to exceeding diesel manufacturer action limits.

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 5 Emergency Diesel Generators and Electrical Distribution System The emergency diesel generators are part of the onsite electrical power systems. The onsite power systems are described in USAR Section 8.3, "Onsite Power Systems." The onsite electrical distribution systems include the 13.8 kV, the 4160 V, and low voltage distribution systems. Two redundant emergency diesel generator units, one connected to each of two essential 4160 V busses, are provided as onsite standby power sources to supply their respective essential busses upon loss of the normal and the reserve power sources.

The EDG units are designed for testing during normal plant operations. Each EDG may be started, synchronized, and loaded without interfering with normal plant operations. However, when synchronized to the grid, the EDG could become overloaded upon receipt of a Safety Features Actuation System (SFAS) signal or in the event of a loss of offsite power. In the case of an SFAS signal without loss of offsite power, the overload condition would be caused by the EDG governor and voltage regulator shifting from the droop mode of operation to the isochronous mode of operation. In the case of a loss of offsite power, the potential overload is caused by the EDG attempting to power the 4160 V essential bus and potentially the non-essential 4160 V and 13.8 kV buses. Procedures instruct the operators to isolate the essential bus from the non-essential buses upon receipt of an SFAS signal or in the event of a loss of offsite power to mitigate the potential overload condition. Additionally, operators would have to manually return voltage and frequency (which are adjusted to provide the desired load and voltage while synchronized to the grid) back to the nominal desired values. These operator actions are not credited with maintaining the EDG functional, and therefore, the EDG is considered inoperable and unavailable when synchronized to the grid.

The proposed amendment would revise SR 4.8.1.1.2.d to allow performance of EDG load rejection testing and a 60-minute loaded run of the EDG during plant operation. The removal of the restriction to perform these tests during shutdown would allow this testing to be scheduled when the unit is online. This allows greater flexibility in outage planning by freeing up resources that would otherwise be dedicated to test performance during the outage. As an added benefit, it is expected that EDG unavailability during a short duration refueling outage in addition to overall EDG unavailability would be reduced by coordinating performance of these tests with testing that is already performed during plant operation. EDG inoperability would continue to be managed in accordance with existing TS requirements.

4.0 TECHNICAL ANALYSIS

Diesel Fuel Oil Testing The proposed amendment would revise SR 4.8.1.1.2.b to replace the existing reference to ASTM D 975-68 with a reference to ASTM D 975-98b. This change is solely an adoption of a more

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 6 recent edition of an accepted standard. Adoption of ASTM D 975-98b would allow an improvement in the detectable levels of water and sediment, which would alert personnel earlier to diesel fuel degradation. The ASTM is a recognized authority for developing standards including those for diesel fuel oil testing. Adoption of a more recent standard does not affect the capability of the diesel fuel oil to perform its required function. The proposed change would have no adverse effect on nuclear safety.

Load Rejection Testing SR 4.8.1.1.2.d.1 requires verifying the EDG can reject a load equal to the largest single emergency load supplied by the generator without tripping. Presently, this test is performed during shutdown as required by Technical Specifications. Prior to performing the load rejection test, the essential bus is powered by the EDG and isolated from offsite power sources. In performing the test, a few large loads (typically two pump motors) are simultaneously tripped, leaving the EDG breaker still closed and the EDG powering the essential bus. The proposed amendment would allow performance of the load rejection test online. In order to perform the test online without interrupting normal plant operations, a different test methodology would be used. This test methodology will be implemented for any performance of SR 4.8.1.1.2.d.1 online. The revised test methodology would involve tripping the EDG output breaker with the EDG carrying greater than or equal to its associated single largest emergency load while paralleled to offsite power. This test method is consistent with one of the methods described in the Bases of SR 3.8.1.9 of NUREG- 1430, Standard Technical Specifications - Babcock and Wilcox Plants.

An evaluation was performed to determine if performance of the load rejection test would adversely impact the electrical system reliability. The evaluation conservatively assumed the EDG was loaded to 2600 kW (substantially greater than the minimum required load to reject of 650 kW) and then the EDG output breaker was opened. The evaluation examined the voltage and current variations as a result of test performance. The evaluation determined that performance of the test would result in no abnormal voltages or currents. The evaluation concluded that the reliability of the electrical system would not be impacted by the performance of the load rejection test online.

SR 3.8.1.9 of NUREG-1430 contains a restriction on performance of load rejection testing in Modes 1 and 2. However, a reviewer's note is provided that states:

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable,

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 7

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO

[Anticipated Operational Occurrence] with attendant challenge to plant safety systems.

The first criterion specifies that performance of the SR will not render any safety system or component inoperable. As discussed above, an evaluation was performed that concluded that the reliability of the electrical system would not be impacted by the performance of the load rejection test. Therefore, loads supplied by the electrical system would remain operable during the test. An EDG is considered inoperable and unavailable when it is synchronized to the grid since the EDG may be overloaded in the event of a Safety Features Actuation System actuation or a loss of offsite power. Therefore, for the period of time the EDG is synchronized to the grid prior to the opening of the EDG output breaker, the EDG is inoperable. However, it is FENOC's intent to coordinate performance of the load rejection test with performance of other required testing so as to not increase the time that the EDG is inoperable and unavailable. For example, SR 4.8.1.1.2.a.5 requires performance of a monthly 60-minute loaded run at greater than or equal to 1000 kW. Following successful performance of this loaded run, the EDG load is reduced to approximately 300 kW and the EDG output breaker is opened. To incorporate performance of SR 4.8.1.1.2.d.1, the test procedure could be modified to at least once per refueling interval only reduce EDG load to the minimum required by SR 4.8.1.1.2.d.1 prior to opening the EDG output breaker and then verifying the EDG does not trip. By coordinating performance of the load rejection test with performance of the 60-minute loaded run, this testing could be performed online without an additional accumulation of time when the EDG is inoperable or unavailable.

The second criterion of the reviewer's note specifies that performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems. As discussed above, an evaluation was performed that concluded that performance of the test would not result in any abnormal voltages or currents and that no abnormal actuation of protective devices would occur. Therefore, performance of the SR would not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems.

The third criterion of the reviewer's note specifies that performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

Performance of the test using the methodology described above would isolate the EDG from the electrical distribution system by opening the EDG output breaker. Successful performance of the SR would result in the EDG continuing to run while isolated from the electrical distribution system. The result of a test failure would be the tripping of the EDG following opening of the output breaker. After the output breaker trips, the EDG would be isolated from the electrical distribution system, so the EDG status would not cause or result in an AOO. In the case of either

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 8 a test success or failure, the effect on the electrical distribution system would be the same. As discussed above, an evaluation concluded that performance of the test would not result in any abnormal voltages or currents and that no abnormal actuation of protective devices would occur.

Therefore, performance of the SR, or failure of the SR, would not cause, or result in, an AOO with attendant challenge to plant safety systems.

The proposed amendment would allow performance of the load rejection test online. The proposed change would not adversely impact the reliability of the electrical system. Load rejection testing could be performed online without any additional accumulation of time when the EDG is inoperable or unavailable. Therefore, the proposed change would have no adverse effect on nuclear safety.

Sixty Minute Loaded Run at Greater than or Equal to 2000 kW SR 4.8.1.1.2.d.3 requires performance of a 60-minute run of the EDG during shutdown while loaded to greater than or equal to 2000 kW. This surveillance requirement is satisfied by performance of the same test procedures that satisfy SR 4.8.1.1.2.a.5 (monthly loaded run) and SR 4.8.1.1.2.c.5 (semi-annual loaded run). Although SR 4.8.1.1.2.a.5 and SR 4.8.1.1.2.c.5 are only required to be performed at a load of greater than or equal to 1000 kW, the testing is actually performed at a load of greater than 2000 kW since operation at lower power levels may result in greater wear on the turbocharger drive train. Hence, the testing performed online to satisfy SR 4.8.1.1.2.a.5 and SR 4.8.1.1.2.c.5 would also satisfy SR 4.8.1.1.2.d.3 except for the restriction that SR 4.8.1.1.2.d.3 must be performed during shutdown.

Performance of SR 4.8.1.1.2.d.3 renders the EDG inoperable while synchronized to the grid. By eliminating the restriction to perform SR 4.8.1.1.2.d.3 during shutdown, the proposed change would allow testing performed to satisfy SR 4.8.1.1.2.a.5 and SR 4.8.1.1.2.c.5 to also satisfy SR 4.8.1.1.2.d.3. Since performance of SR 4.8.1.1.2.d.3 online would not result in any additional testing, the accumulated time that the EDG is inoperable and unavailable would not increase.

As noted above, testing that would satisfy SR 4.8.1.1.2.d.3 is already performed online as part of monthly and semi-annual testing. Loading of the EDG during monthly and semi-annual testing does not result in a significant perturbation of the electrical distribution system or an AOO. In order to minimize risk, station procedures prohibit the testing of the other EDG and Station Blackout Diesel Generator while an EDG is synched to the grid. This provides added assurance alternative power supplies are available in the event of a loss of offsite power.

In summary, the proposed change to SR 4.8.1.1.2.d.3 would not result in any new or different testing. The proposed change would not result in any additional accumulated time during which the EDG is inoperable and unavailable. Performance of SR 4.8.1.1.2.d.3 online does not impact the reliability of the electrical distribution system. Therefore, the proposed change would have no adverse effect on nuclear safety.

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 9 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration The proposed changes would revise Technical Specification (TS) 3/4.8.1.1, "A. C.

Sources - Operating," to adopt a more recent standard for diesel fuel oil testing and remove the restriction that certain surveillance requirements be performed during shutdown. Specifically, the proposed amendment would revise TS Surveillance Requirement (SR) 4.8.1.1.2.b to replace American Society for Testing and Materials (ASTM) Standard D 975-68 with more recent version ASTM D 975-98b. Additionally, the proposed change would revise SR 4.8.1.1.2.d to remove the restriction that SR 4.8.1.1.2.d.1 (load rejection testing) and SR 4.8.1.1.2.d.3 (60-minute loaded run) be performed during shutdown.

An evaluation has been performed to determine whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change to TS SR 4.8.1.1.2.b affects the testing standard for the fuel oil supply for the emergency diesel generators (EDGs). The fuel oil supply is not an initiator of any accident previously evaluated. The fuel oil supply supports the accident mitigation functions of the EDGs, which serve as the standby source for A.C. power in the event of a loss of offsite power. Adoption of a more recent standard does not affect the capability of the diesel fuel oil to perform its required function. Therefore, the proposed change to SR 4.8.1.1.2.b does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change to TS SR 4.8.1.1.2.d affects the performance of load rejection testing and the 60-minute loaded run at greater than or equal to 2000 kW. Evaluations and operating history have demonstrated that performance of these tests online will not impact electrical distribution system reliability. No anticipated operational occurrence or accident would occur as a result of performing these tests online. Although the EDGs are rendered inoperable and unavailable during performance of these tests, these tests would be performed in conjunction with testing required by other specifications; therefore, the accumulated time of EDG

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 10 inoperabilty and unavailability would not increase. The proposed change to SR 4.8.1.1.2.d does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to TS SR 4.8.1.1.2.b affects the testing standard for the fuel oil supply for EDGs. Applying the more recent standard for fuel oil testing does not create any new or different accident initiators because adoption of a more recent standard does not affect the capability of the diesel fuel oil to perform its required function.

The proposed change to TS SR 4.8.1.1.2.d affects the performance of load rejection testing and the 60-minute loaded run at greater than or equal to 2000 kW. Evaluations and operating experience have demonstrated that performance of these tests online will not impact electrical distribution system reliability. No new or different accidents could occur as a result of performing these tests online. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change to TS SR 4.8.1.1.2.b affects the testing standard for the fuel oil supply for EDGs. Adoption of a more recent standard does not affect the capability of the diesel fuel oil to perform its required function.

The proposed change to TS SR 4.8.1.1.2.d affects the performance of load rejection testing and the 60-minute loaded run at greater than or equal to 2000 kW. Evaluations and operating experience have demonstrated that performance of these tests online regardless of the test outcome will not impact electrical distribution system reliability. The required testing will continue to demonstrate acceptable EDG performance. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 11 Based on the above, it is concluded that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is acceptable.

5.2 Applicable Regulatory Requirements/Criteria The design criteria for the Emergency Diesel Generators (EDGs) and the electrical distribution system are specified in USAR Section 3D. 1.13, "Criterion 17 - Electric Power Systems," and USAR Section 3D.1.14, "Criterion 18 -

Inspection and Testing of Electric Power Systems." USAR Section 3D.1.13 states, in part:

The onsite electric distribution system arrangement minimizes the vulnerability of essential circuits to physical damage. Two onsite emergency diesel generators are provided as standby power sources. Each diesel engine is designed for an approximate starting time of 10 seconds from receipt of a starting signal to production of rated voltage and frequency. Normally, the 4160-volt essential buses are fed from the unit auxiliary transformer as the normal source. Upon loss of the normal and reserve (offsite) power sources, the two 4160-volt essential buses are energized from their respective emergency diesel-generators. The essential buses are cleared of all ties prior to application of the emergency diesel generators. This protects each emergency diesel generator system from external faults.

USAR Section 3D.1.14 states, in part:

Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connection, and switchboards, to assess the continuity of the systems and the condition of their components. The systems are designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operational sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

The proposed amendment does not alter the design of the electric power systems.

When an EDG is synchronized to the grid for testing, the test configuration differs

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 12 from the normal operating configuration described in USAR Section 3D.1.13 since the essential buses are not cleared of all ties prior to application of the emergency diesel generators. This is acceptable since the EDGs are considered inoperable when synchronized to the grid and the appropriate actions required by the Technical Specifications are followed. The revised testing requirements continue to ensure reliable performance of the EDGs and the onsite electrical power sources.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

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

7.0 REFERENCES

1. DBNPS Operating License NPF-3, Appendix A Technical Specifications through Amendment 263

2. DBNPS Updated Safety Analysis Report through Revision 24.

3. ASTM D 975-68, "Standard Classification of Diesel Fuel Oils."

4. ASTM D 975-98b, "Standard Specification for Diesel Fuel Oils."

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Page 13

5. ASTM D 1796, "Water and Sediment in Crude Oils and Fuel Oils by Centrifuge."

6. ASTM D 2709, "Test Method for Water and Sediment in Distillate Fuels by Centrifuge."

7. NUREG- 1430, StandardTechnical Specifications - Babcock and Wilcox Plants, Revision 3.

8.0 ATTACHMENTS

1. Proposed Mark-Up Of Technical Specification Pages

2. Proposed Retyped Technical Specification Pages

3. Technical Specification Bases Pages

Docket Number 50-346 License Number NPF-3 Serial Number 3158 PROPOSED MARK-UP OF TECHNICAL SPECIFICATION PAGES (5 pages follow)

£ 314.8 ELECTRICAL POWER SYSTEMS Information Only 314.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class IE A.C. electrical power distribution system, and

b. Two separate and independent diesel generators each with:

1. A separate day fuel tank containing a minimum volume of 4000 gallons of fuel,

2. A separate fuel storage system containing a minimum volume of 32,000 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILIT: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Restore at least two diesel generators to OPERABLE status within 7 days or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With one offsite circuit and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and by performing Surveillance DAVIS-BESSE, UNIT 1 3/4 8-1 Amendment No.6-4,- g, 03- 206

ELECTRICAL POWER SYSTEMS Information Only ACTION (Continued)

Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . With the inoperable offsite source restored, restore two diesel generators to OPERABLE status within 7 days from the time of the initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . With the inoperable diesel generator restored, restore two offsite power sources to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of the initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d. With two of the above required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, unless the diesel generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

e. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; restore at least one oF the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at least two diesel generators to OPERABLE status within 7 days from time of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required qualified circuits between the offsite transmission network and the onsite Class IE A.C. electrical power distribution system shall be:

a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments and indicated power availability, and

b. Demonstrated OPERABLE at least once each REFUELING INTERVAL during shutdown by transferring (manually and automatically) unit power supply to each of the offsite circuits.

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE;

a. At least once per 31 days, if Surveillance Requirement 4.8.1.1.2.c has not been performed within the previous 31 days, by:

DAVIS-BESSE, UNIT 1 3/4 8-2 Amendment No. 97,107,203,206,219

ELECTRICAL POWER SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying the fuel level in the day fuel tank.

2. Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.

4. Verifying the diesel starts and accelerates up to 900 rpm, preceded by an engine prelube and/or appropriate other warmup procedures.

5. Verifying the generator is synchronized, loaded to 2 1000 kw, and operates for

> 60 minutes.

6. Verifying the diesel generator is aligned to provide standby power to the associated essential busses.

7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10% of its required value.

b. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified in Table I of ASTM D975-6&:-9when checked for viscosity, water and sediment.

c. At least once per 184 days by:

1. Verifying the fuel level in the day fuel tank.

2. Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.

4. Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm in < 10 seconds.

5. Verifying the generator is synchronized, loaded to 2 1000 kw, and operates for 2 60 minutes.

6. Verifying the diesel generator is aligned to provide standby power to the associated essential busses.

7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within + 10% of its required value.

DAVIS-BESSE, UNIT 1 3/4 8-3 Amendment No. 75, 97, 105, 203,

ADDITIONAL CHANGES PREVIOUSLY PROPOSED BY LEHTER ELECTRICAL POWER SYSTEMS Serial No. 2957 Dated 08/20/04 SURVEILLANCE REQUIREMENTS (Continued)

d. At least once each REFUELING INTERVAL duiing shutdown-by:

1. Verifying the generator capability to reject a load equal to the largest single emergency load supplied by the generator without tripping.

2. Simulating durin sudown a loss of offsite power in conjunction with a safety features actuation system (SFAS) test signal, and:

(a) Verifying de-energization of the essential busses and load shedding from the essential busses.

(b) Verifying the diesel starts from ambient condition on the auto-start signal, energizes the essential busses with permanently connected loads, energizes the auto-connected essential loads through the load sequencer and operates for 2 5 minutes while its generator is loaded with the essential loads.

(c) Verifying that all diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the essential bus and/or an SFAS test signal.

3. Verifying the diesel generator operates for 2 60 minutes while loaded to 2 2000 kw.

4. Verifying during shutdown that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating of 2838 kw.

e. At least once per 30 months by subjecting the diesels to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendation for this class of standby service.*

The provisions of Specification 4.0.2 are not applicable.

DAVIS-BESSE, UNIT I 3/4 8-4 Amendment No. 97, 105, 141, 219,

ELECTRICAL POWER SYSTEMS Information Only A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E A.C. electrical power distribution system, and

b. One diesel generator with:

1. Day fuel tank containing a minimum volume of 4000 gallons of fuel,

2. A fuel storage system containing a minimum volume of 32,000 gallons of fuel, and

3. A fuel transfer pump.

APPLICABILITY: MODES S and 6.

ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until the minimum required A.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirements 4.8.1.1.2.a.5, 4.8.1.1.2.a.7, 4.8.1.1.2.c.5 and 4.8.1.1.2.c.7.

DAVIS-BESSE, UNIT 1 3/4 8-5 Amendment No. 75, 203

Docket Number 50-346 License Number NPF-3 Serial Number 3158 Enclosure I PROPOSED RETYPED TECHNICAL SPECIFICATION PAGES (2 pages follow)

JD ELECTRICAL POWER SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying the fuel level in the day fuel tank.

2. Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.

4. Verifying the diesel starts and accelerates up to 900 rpm, preceded by an engine prelube and/or appropriate other warmup procedures.

5. Verifying the generator is synchronized, loaded to 2 1000 kw, and operates for

> 60 minutes.

6. Verifying the diesel generator is aligned to provide standby power to the associated essential busses.

7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10% of its required value.

b. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified in Table 1 of ASTM D975-98b when checked for viscosity, water and sediment.

c. At least once per 184 days by:

1. Verifying the fuel level in the day fuel tank.

2. Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.

4. Verifying the diesel starts from ambient condition and accelerates to at least 900 rpm in

10 seconds.

5. Verifying the generator is synchronized, loaded to 2 1000 kw, and operates for 2 60 minutes.

6. Verifying the diesel generator is aligned to provide standby power to the associated essential busses.

7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10% of its required value.

DAVIS.-BESSE, UNIT 1 3/4 8-3 Amendment No. 75, 97, 105, 203,

ADDITIONAL CHANGES PREVIOUSLY PROPOSED BY LETTER ELECTRICAL POWER SYSTEMS Serial No. 2957 Dated 08/20/04 SURVEILLANCE REQUIREMENTS (Continued)