ML053340305

License Amendment Request Pursuant to 10 CFR 50.90 Related to Emergency Diesel Generator Surveillance Testing Voltage and Frequency Limits

ML053340305
Person / Time
Site:	Perry
Issue date:	11/21/2005
From:	Pearce L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2918L
Download: ML053340305 (20)

Text

FENOC Perry Nuclear Power Plant 10 Center Road P.O. Box 97 ForstEnergy Nuclear Operating Company Perry. Ohio 44081 November 21, 2005 PY-CEI/NRR-2918L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90 Related to Emergency Diesel Generator Surveillance Testing Voltage and Frequency Limits Ladies and Gentlemen:

Nuclear Regulatory Commission (NRC) review and approval of a License Amendment Request (LAR) is requested for the Perry Nuclear Power Plant (PNPP). The proposed LAR will revise the acceptance criteria of Technical Specification (TS) Surveillance Requirements (SRs) associated with TS 3.8.1 to modify the Emergency Diesel Generator start tests to provide minimum voltage and frequency limits and clarify other limits as steady state parameters. This change is consistent with the approved Technical Specification Task Force Traveler (TSTF) 163, Revision 2.

It is requested that the proposed LAR be approved by November 21, 2006 with a 120-day implementation period. If you have questions or require additional information, please contact Mr. Gregory A. Dunn, Manager - Fleet Licensing at (330) 315-7243.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 2 I, 2005.

ar W. Pearce Vice President-Nuclear Attachments:

1. An evaluation of the change, including a Summary, Description of the Proposed Change, Background, Technical Analysis, Regulatory Safety Analysis, Conclusion, and Environmental Consideration

2. Significant Hazards Consideration

3. Proposed Technical Specification Change (mark-up)

4. Proposed Technical Specification Bases Change (mark-up for information only) cc: NRC Project Manager NRC Resident Inspector NRC Region IlIl 4o()

State of Ohio

Attachment 1 PY-CEI/NRR-2918L Page 1 of 4

SUMMARY

1, Nuclear Regulatory Commission review and approval is requested of a License Amendment Request (LAR) to the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS) consistent with Technical Specification Task Force Traveler (TSTF) 163, Revision 2. The proposed LAR will modify the following Surveillance Requirements (SRs): SR 3.8.1.2, SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20. The acceptance criteria for the Emergency Diesel Generator (EDG) start tests will be modified by specifying the minimum voltage and frequency to be achieved during startup and also detail the currently listed voltage and frequency range as values to be achieved once "steady state" is reached.

DESCRIPTION OF THE PROPOSED CHANGE The proposed LAR will modify TS 3.8.1 by revising the acceptance criteria of SR 3.8.1.2, SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20 consistent with the changes proposed generically by TSTF-1 63, Revision 2.

Currently these SRs verify that when started from a standby condition, the Division 1 and 2 EDGs achieve a voltage between 3900 Volts and 4400 Volts and frequency between 58.8 Hertz and 61.2 Hertz in less than or equal to 10 seconds. In addition, SR 3.8.1.7.b requires the Division 3 EDG to achieve a frequency of at least 58.8 Hertz in less than or equal to 10 seconds, and a voltage between 3900 Volts and 4400 Volts, and frequency between 58.8 Hertz and 61.2 Hz in less than or equal to 13 seconds.

The EDG start test SRs (10 second test for Division I and 2 and 13 second test for Division

3) will be modified to provide minimum voltage and frequency acceptance limits and also detail the voltage and frequency ranges as usteady state."

The following details how the PNPP TS SRs will be changed.

SR 3.8.1.2 will be revised to define the currently listed voltage and frequency range as "steady state."

SR 3.8.1.7, 3.8.1.12, 3.8.1.15, and SR 3.8.1.20 will be revised to require the EDG to achieve a voltage greater than or equal to 3900 V and a frequency greater than or equal to 58.8 Hz within 10 seconds for Division 1 and Division 2, and a frequency greater than or equal to 58.8 Hz within 10 seconds and a voltage greater than or equal to 3900 V within 13 seconds for Division 3 EDG. Subsequently, each EDG (Division 1, 2 and 3) will be required to achieve a steady state voltage of greater than or equal to 3900 V and less than or equal to 4400 V, and frequency greater than or equal to 58.8 Hz and less than or equal to 61.2 Hz. provides copies of hand mark-ups that depict the proposed changes to the PNPP TS.

Also for information, Attachment 4 includes a change to the TS Bases consistent with TSTF 163, Revision 2.

Attachment 1 PY-CEI/NRR-2918L Page 2 of 4 BACKGROUND The proposed amendment will modify the acceptance criteria for the PNPP TS SRs that verify the capability of the EDGs to be ready to supply the necessary safety-related equipment within the time assumed in the safety analysis for the limiting accident.

The TS SRs that are affected by the proposed LAR specify requirements for testing the EDGs. This testing is conducted to confirm the capability of each EDG to start and achieve the minimum conditions required to accept load by starting each EDG from standby conditions to determine if the required voltage and frequency is met within the required time.

This testing helps ensure the availability of the EDGs to supply standby electrical power to mitigate Design Basis Accidents and transients and maintain the plant in a safe shutdown condition. Specifically, the PNPP TS require the Division 1 and 2 EDGs start from the standby condition and reach the required voltage and frequency within 10 seconds. Also, the PNPP TS require the Division 3 EDG starts from the standby condition and achieves a minimum required frequency within 10 seconds and required voltage and frequency within 13 seconds.

The proposed LAR revises the applicable PNPP TS 3.8.1 SRs so that the minimum acceptable limits for voltage and frequency are reached in the required time (10 seconds for Division 1 and 2, and 13 seconds for Division 3). In addition, the acceptable voltage and frequency ranges will be defined to be at steady state conditions. For the purpose of the LAR, the steady state condition is reached when the voltage and frequency limits stabilize.

From the Institute of Electrical and Electronics Engineers (IEEE) Standard 100-1996, "The IEEE Standard Dictionary of Electrical and Electronic Terms," the term "steady state value" is defined as follows, "The value of a current or voltage after all transients have decayed to a negligible value."

As the SRs are currently worded, since the minimum and maximum voltage limits and frequency are specified, it is implied that steady state conditions must be established within the required time limit (10 or 13 seconds). This is not the intent of the timed start tests. The intent of the timed start tests is to confirm the capability of each EDG to start and achieve the minimum conditions required to accept load. Therefore, the requirements for steady state operation are appropriate subsequent to the timed start test.

This change to the PNPP TS is consistent with TSTF 163, Revision 2. The industry and the NRC have reviewed and resolved this issue on a generic basis. TSTF 163, Revision 2 was submitted and approved by the NRC on April 22, 1998. TSTF-163, Revision 2 modifies the associated TS SRs to 1) eliminate the maximum voltage and frequency limits from the start test, 2) reword the SRs to clarify that each EDG is required to achieve steady state operation following the timed start, and 3) state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

These proposed changes were applied to each of the Standard Technical Specifications (NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, AND NUREG-1434).

TECHNICAL ANALYSIS Verifying that each EDG achieves the minimum voltage and frequency within 10 seconds for Divisions 1 and 2, and 13 seconds for Division 3 is sufficient to verify each EDG's capability

Attachment 1 PY-CEI/NRR-2918L Page 3 of 4 to achieve a fast start and be ready to accept load as well as to satisfy the conditions needed for the EDG output breaker to close.

When a test is performed that does not result in tying the EDG to the bus, a momentary voltage or frequency overshoot (and/or subsequent undershoot) can occur because no loads are being tied to the EDG. Loading tends to minimize the overshoot. The overshoot (or undershoot) could be such that the voltage or frequency is momentarily outside the specified limit(s) at the time limit (10 or 13 seconds). This condition is not uncommon due to the nature of the EDG governor as it seeks to control EDG speed during that fast start when the EDG is unloaded. The overshoot (or undershoot) condition does not affect the permissive for closure of the EDG output breaker, since the permissive is primarily dependent on minimum conditions being achieved - regardless of any overshoot or subsequent momentary undershoot. Thus, this condition is not indicative of an inoperable EDG, provided that steady state voltage and frequency are subsequently achieved.

A balance exists between the steady state condition of the EDG and the speed at which it accelerates to rated nominal values. With minor degradation, the EDG will not be stable enough to satisfy the existing acceptance criteria or the EDG will not provide rated voltage and frequency within the required time limit. In addition, tuning of the EDG governor system to meet steady state conditions pushes the controls to the edge of instability. By eliminating the time limit to reach steady state conditions, the governor can be set up to provide a more stable power source and meet breaker closure requirements, load rejection tests and load acceptance requirements.

The limits of the voltage and frequency tolerance specified in the current PNPP TS are more representative of steady state conditions than transient conditions. Modifying the limits of voltage and frequency to reflect steady state conditions is consistent with the recommendations in NRC Regulatory Guide 1.9, which allow a larger band for transient voltage and frequency deviations. The steady state frequency limits are not being changed.

In accordance with existing plant procedural requirements, the time for each EDG to reach steady state operation will continue to be periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. Therefore, additional monitoring does not need to be added as a regulatory commitment as recommended within TSTF 163.

There is no effect on the EDG capability to supply the minimum voltage and frequency required within the required time or to achieve the steady state voltage and frequency assumed in the accident analysis. The proposed LAR does not invalidate either the assumptions or the conclusions of the associated design calculations. Therefore, eliminating the requirement for each EDG to achieve a voltage and frequency within both minimum and maximum limits within the time limit has no impact on safety.

In addition, the Loss Of Offsite Power (LOOP) and the LOOP in conjunction with an Emergency Core Cooling System (ECCS) initiation signal tests, required by PNPP TS SR 3.8.1.1 1 and SR 3.8.1.19, will continue to verify the capability of the EDGs to provide power at a voltage and frequency adequate to start and operate the safety loads.

The NRC staff has approved this change as a part of generic changes to be incorporated into the next revision of the Improved Standard Technical Specifications (ISTS). The NRC

Attachment 1 PY-CEI/NRR-2918L Page 4 of 4 staff has previously approved this change for similar stations, such as the Grand Gulf Nuclear Station, Unit 1 on June 30, 2000 (TAC No. MA6765) and the Clinton Power Station, Unit 1 on January 20,1999 (TAC No. MA2474).

REGULATORY SAFETY ANALYSIS No Significant Hazards Consideration A No Significant Hazards Consideration has been completed and is included as .

Applicable Regulatory Requirements/Criteria The proposed change to the PNPP TS is consistent with TSTF 163, Revision 2. TSTF 163, Revision 2 was submitted and approved by the NRC on April 22, 1998. These proposed changes were applied to each of the Standard Technical Specifications (NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, AND NUREG-1434). Modifying the limits of voltage and frequency to reflect steady state conditions is consistent with the recommendations in NRC Regulatory Guide 1.9, which allow a larger band for transient voltage and frequency deviations. The proposed change to the PNPP TS is consistent with 10 CFR 50.36(c)(3), General Design Criterion (GDC)-17, "Electric Power System," of Appendix A to 10 CFR 50, and GDC-18, 'Inspection and Testing of Electric Power Systems," of Appendix A of 10 CFR 50 since there is no effect on the EDG capability to supply the minimum voltage and frequency required within the required time or to achieve the steady state voltage and frequency assumed in the accident analysis. The applicable TS Surveillances will continue to verify the capability of the EDGs to provide power at a voltage and frequency adequate to start and operate the safety loads.

CONCLUSION Revising the Emergency Diesel Generator start tests to provide minimum voltage and frequency limits and clarify other limits as steady state parameters is consistent with the approved Technical Specification Task Force Traveler (TSTF) 163, Revision 2. Eliminating the requirement for each EDG to achieve a voltage and frequency within both minimum and maximum limits within the time limit has no impact on safety.

ENVIRONMENTAL CONSIDERATION The proposed Technical Specification change request was evaluated against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not significantly increase individual or cumulative occupational radiation exposures, does not significantly change the types or significantly increase the amounts of effluents that may be released off-site and, as discussed in Attachment 2, does not involve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

Attachment 2 PY-CEI/NRR-2918L Page 1 of 2 SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Nuclear Regulatory Commission's Regulation, 10 CFR 50.92, which states that the operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any previously evaluated; or (3) involve a significant reduction in a margin of safety.

Nuclear Regulatory Commission review and approval is requested of a License Amendment Request (LAR) to the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS) to modify the acceptance criteria for TS Surveillance Requirements (SRs) that verify the capability of the Emergency Diesel Generators (EDGs) to be ready to supply the necessary safety-related equipment within the time assumed in the safety analysis for the limiting accident.

The proposed LAR will modify PNPP TS SR 3.8.1.2, SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20.

The proposed LAR revises the applicable TS 3.8.1 SRs so that the minimum acceptable limits for voltage and frequency are reached in the required time (10 seconds for Division 1 and 2, and 13 seconds for Division 3). In addition, the acceptable voltage and frequency ranges will be defined to be at steady state conditions. This change to the PNPP TS is consistent with TSTF 163, Revision 2.

The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed change does not involve a significant hazard because:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change is a LAR that modifies the acceptance criteria for the PNPP TS SRs pertaining to the EDGs. The EDGs mitigate the consequences of previously evaluated accidents involving a loss of offsite power. The EDGs are used to support mitigation of the consequences of an accident, but they are not considered as the initiator of any previously analyzed accident.

The proposed LAR does not change the manner in which the EDGs are operated and when implemented will continue to ensure the EDGs perform their function when called upon. The proposed revision to the TS SRs will continue to ensure that minimum frequency and voltage are attained within the required time. The SRs will continue to ensure that proper steady state voltage and frequency are attained consistent with proper EDG governor and voltage regulator performance.

The proposed LAR does not affect the design of the EDGs, the operational characteristics of the EDGs, the interfaces between the EDGs and other plant systems, the function, or the reliability of the EDGs. Thus, the EDGs will be capable of performing

Attachment 2 PY-CEI/NRR-291 8L Page 2 of 2 their accident mitigation function and there is no impact to the radiological consequences of any accident analysis.

As such, the proposed change continues to provide adequate assurance of operable EDGs and does not involve any increase to the probability or consequences of an accident previously evaluated.

2. The proposed change would not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed LAR introduces no new mode of plant operation and it does not involve physical modification to the plant. New equipment is not installed with the proposed LAR, nor does the proposed LAR cause existing equipment to be operated in a new or different manner.

Since the proposed changes do not involve a change to the plant design or operation, no new system interactions are created by this change. The proposed LAR does not produce any parameters or conditions that could contribute to the initiation of accidents different from those already evaluated in the Updated Safety Analysis Report.

The changes to the affected TS SRs do not affect the assumed accident performance of the EDGs, nor any plant structure, system or component previously evaluated.

Therefore, the proposed LAR does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change will not involve a significant reduction in the margin of safety.

The proposed change is a LAR that does not impact EDG performance, including the capability for each EDG to attain and maintain required voltage and frequency for accepting and supporting plant safety loads within the required time, as assumed in the plant safety analysis.

The proposed LAR does not involve a significant reduction in a margin of safety since the operability of the EDGs continues to be determined as required to support the capability of the EDGs to provide emergency power to plant equipment that mitigate the consequences of an accident.

The proposed LAR does not introduce changes to setpoints or limits established or assumed by the accident analysis. Therefore, implementation of the proposed LAR does not involve a significant reduction in a margin of safety.

Attachment 3 PY-CEI/NRR-291 8L Page 1 of 10 MARKED-UP TECHNICAL SPECIFICATION PAGES REFLECTING THE PROPOSED AMENDMENT

I . . to ;

Attachment 3 PY-CEI/NRR-291 8L Page 2 of 10 AC Sources -Operating

.: 4 . 3.8.1

' .1RFTI I AMCF., RHITUTRFMMNTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each required offsite circuit.

SR 3.8.1.2 ----------------- NOTES----

1. Performance of SR 3.8.1.7 satisfies this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.

Verify each DG starts from standby 31 days conditions and achieves:

Cs-f_eadc't' Sia+e, Voltaoe z 3900 V and s 4400 V and frequency 2 58.t Hz and s 61.2 Hz (continued)

PERRY - UNIT I 3 .8-5 Amendment No.

C.,I Attachment 3 PY-CEI/NRR-291 8L Page 3 of 10 AC Sources-Operating SURVEILLANCE REQUIREMENTS (continued) -

SURVEILLANCE FREQUENCY

• SR 3.8.1.7 -NOT -----

AllI DG starts maybe preceded by anje0gine prelube period.

Verify each DG strso standby 18t days conditions n civs 3900 V -and 4400

. R1PLArCE EV

> 588 Hz8and 61.2*6zin z _'

s 10 seconds- and / (7-4

b. For Division 3 'D:

I.

l1. Fr~qec - .8 fn .

t S £w4d;and

)2.,'tage*.2 3900 V arnd s 400<V.-nd

\ ," req .n.z58.8 Hz ,and < 61.2 Hz

\ . l 513 econds:..

SR 3.8.1.8 ---- ----OTE--------

This Surveillance.shall not he permformd in MODE 1 or 2. .. However.. credit may be .taken for unplanned events that satisfy this $SR.

Verify manual transfer of ;unit power supply i 24 months from the norimal bffsite circuit.to the alternate offsite -circuit.

(continued)

PERRY - UNIT 1 3.8-7 Amendment No.

Attachment 3 PY-CEI/NRR-291 8L Page 4 of 10 INSERT I

a. For Division 1 and 2, in < 10 seconds voltage - 3900 V and frequency 2 58.8 Hz; and

b. For Division 3, in

• 10 seconds frequency > 58.8 Hz, and in

• 13 seconds voltage Ž 3900 V; and

c. For each DG, steady state voltage Ž 3900 V and < 4400 V and frequency > 58.8 Hz and < 61.2 Hz.

' t. '-:4 v I

I t' s - ".:I . A.,

{0 '.Il.:

Attachment 3

• . '~  ::, ' ,-. . .4.

, . X

. I. ....

PY-CEI/NRR-291 8L Page 5 of 10 Ij AC Sources -Operating 3.8.1 I

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE. _ FREQUENCY SR 3.8.1.12 ------------NOTES---

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

2. This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unDlanned events that satisfy this Sk.

Verify on an actual or simulated Emerge'ncy 24 months Core Cooling System (ECCS) init1gtibn signal each OG auto-starts from standby e condtin and'

a. In s 10 seconds for Divisions and '2.

and s 13 seconds for Div tn.3after

S f71PLA/Ice-auto-start addrn-es,'achi'eves voltage a 90 4400 V; Is BOLE~T2 Al 17z14 (b. Ins5 10 d 'oDivisions 1 and 2.

and seconds for Division 3 after

-start and during tests, achieves

'frequency 2 58.8 Hz and s 61.2 Hz: and

c. Operates for k 5 minutes.

SR 3.8.1.13 ----

SR38..3-----NT------ NOTE---- ---------------

This Surveillance shall not be performed in MODE 1, 2. or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS initiation signal except:

a. Engine overspeed; and

b. Generator differential current (continued)

PFPPY - IINTT 1 OR P-in Ampndmpnt. No.,

Attachment 3 PY-CEI/NRR-291 8L Page 6 of 10 INSERT 2

a. In

• 10 seconds for Division 1 and 2 and

• 13 seconds for Division 3, after auto-start and during tests, achieves voltage Ž 3900 V and frequency Ž 58.8 Hz; and

b. Achieves steady state voltage Ž 3900 V and

• 4400 V and frequency 2 58.8 Hz and

• 61.2 Hz; and

. In . A;I Attachment 3 PY-CEI/NRR-291 8L Page 7 of 10

.r :. - I. AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) -

SURVEILLANCE FREQUENCY SR 3.8.1.15 ------------------NOTES-----

1. This Surveillance.shall be performed within 5 minutes of shutting .down the DG after the DG has operated. I hour loaded 2 5600 kW and s 7000 *kW for Division 1 and 2 DGs, and 2600 kW for Division 3 DG.

Momentary transients outtide of the load range do not invalidate this' test.

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

.Verify each DG starts and acivs.24 -months' s 13secnds for DiviinS otg 2 3900 V and S frequency -Jc_ iLh 4~Vand 2 88E-nr 12Hz. WP 7I SR .3.8.1.16 -------------------

This Surveillance shall not be performed in" MODE 1. 2. or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG:

a. Synchronizes with offsite power source 24 months while loaded with emergency loads upon a simulated restoration of offsite power:

b. Transfers loads to offsite power source: and

c. Returns to ready-to-load operation.

(continued)

PERRY - UNIT 1 3.8-12 Amendment No.

Attachment 3 PY-CEIINRR-291 8L Page 8 of 10 INSERT 3

a. In

• 10 seconds for Division 1 and 2 and

• 13 seconds for Division 3, voltage 2 3900 V and frequency Ž 58.8 Hz; and

b. Steady state voltage > 3900 V and *4400 V and frequency 2 58.8 Hz and

• 61.2 Hz.

• ,* . . . I Attachment 3 PY-CEI/NRR-291 8L Page 9 of 10 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) -

SURVEILLANCE FREQUENCY SR 3.8.1.20 -------------------NOTE--------------------

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

Verify, when started simultaneouslciii 10 years stndycondition. the Divisi~>rnh 2 St Iacive voltage ?- 3900 V fids400 V ah~d frequency 2 58.`8 H+/- ' 61.2 1n'.10 F ezpuJcE'

/seconds, and ith vison 3 DG achieves a frequency t .8Hz.in s 10 seconds. and a virrq voltag 900 V and s 4400 V and frequency 4JS~g-r q

Hzand t61L2 Hz -ih~13 secons PERRY - UNIT 1 3.8-15.. Amendment No.

Attachment 3 PY-CEI/NRR-291 8L Page 10 of 10 INSERT 4 Verify, when started simultaneously from standby condition, each DG achieves:

a. In

• 10 seconds for Division 1 and 2 and

• 13 seconds for Division 3, voltage Ž 3900 V and frequency 2 58.8 Hz; and

b. Steady state voltage Ž 3900 V and

• 4400 V and frequency > 58.8 Hz and

• 61.2 Hz.

Attachment 4 PY-CEI/NRR-291 8L Page 1 of 3 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES REFLECTING THE PROPOSED AMENDMENT (For Information Only)

X . Aftachment 4 PY-CEI/NRR-291 8L Page 2 of 3 j,, AC Sources -Operating B 3.8.

BASES

,SURVEILLANCE SR 3 8 1.2 and SR. 3.8.1.7 (continued) -

REQUIREMENTS SR 3.8.1.7 requires that, at a 184 day Frequency, the Division l and 2 DGs start from standby conditions and achieves required voltage and frequency within 10 seconds.

Also. this SR requires that the Division 3 DG starts from standby conditions and achieves a minimum required frequency within 10 seconds and required voltage and frequency within 13 seconds. The start time requirements support the assumptions in the design basis LOCA analysis (Ref. 5). The start time requirements are not applicable to SR 3.8.1.2 (see Note 3 of SR 3.8.1.2). Since SR 3.8.1.7 does require timed starts. it is more restrictive than SR 3.8.1.2. and it may be performed in lieu of SR 3.8.1.2. This procedure is the intent of Note 1 of SR 3.8.1.2. Similarly, the performance of SR 3.8.1.12 or SR 3.8.1.19 also satisfies-the

( )requirements of SR 3.8.1.2 and SR 3.8.1.7.

I1 vThe 31 day Frequency for SR 3.8.1.2 is consistent with the industry guidelines for assessment of diesel generator performance (Ref. 14). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing-consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate.

assurance of DG OPERABILITY, while minimizing degradation resulting from testing'.

SR 328&1 .

This Surveillance demonstrates that the DGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

Although no power factor requirements are established by this SR. the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value .isthe design rating of the machine, while 1.0 is an operational limitation to ensure circulating currents are minimized.

The load band for the Division 1 and 2 DGs is provided to avoid routine overloading of these DGs. While this Surveillance allows operation of the Division 1and 2 DGs in the band of 5600 kW to 7000 kW, a range of 5600 kW to 5800 kW will normally be used in order to minimize wear on (continued)

PERRY - UNIT 1 B 3.8-15 Revision No. 2

Attachment 4 PY-CEI/NRR-2918L Page 3 of 3 INSERT 1 In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.