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Volume 13, Revision 0, Davis-Besse, Unit 1 - Improved Technical Specifications Conversion, ITS Section 3.8 Electrical Power System.
	ML072200479
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Site:	Davis Besse
Issue date:	08/03/2007
From:	; FirstEnergy Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
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{{#Wiki_filter:Attachment 1, Volume 13, Rev. 0, Page 1 of 323 ATTACHMENT 1 VOLUME 13 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 0 Attachment 1, Volume 13, Rev. 0, Page 1 of 323

Attachment 1, Volume 13, Rev. 0, Page 2 of 323 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 3.5.5

6. ITS 3.8.6

7. ITS 3.8.7

8. ITS 3.8.8

9. ITS 3.8.9

10. ITS 3.8.10 Attachment 1, Volume 13, Rev. 0, Page 2 of 323

, Volume 13, Rev. 0, Page 3 of 323 ATTACHMENT 1 ITS 3.8.1, AC SOURCES - OPERATING , Volume 13, Rev. 0, Page 3 of 323
, Volume 13, Rev. 0, Page 4 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 4 of 323

Attachment 1, Volume 13, Rev. 0, Page 5 of 323 ITS 3.8.1 ITS

3/4,8 ELECTRICAL POWER SYSTEMS 3/4.8,1 A.C. SOURCES OPERAT ING LIMITING CONDITION FOR OPERATION LCO3.8.1 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offslte transmission network and the onsite Class IE A.C. electrical power distribution system, and _ LAO1

b. Two ep nd indedendentdiesel generators each with:

SR 3.8.1.4 1. A sea- ate day fuel tank containing'a minimum volume of 4000 gallons of fuel,

2. A separate fuel storage system containing a minimum volume See.

of 32,000 gallons of fuel, and ITS 3.8.3

13. A/seoarate fuel transfer pumD. I APPLICABILITY: MODES 1, 2, 3 and 4. eAO ACTION: ._ - Add proposed ACTIONS Note} A2

a. With one offstte circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the ACTION A remaining A.C.

J4.8.1.1.1.a sources within one by hourperforming and at least once per 8Requirement Surveillance hours - [thereafter land bf performing Surveillande Requirementi L0 [14.8.1-.1.2.1a.4 wi hin 24 hoursJ. Restore at lea4~_two offsite

                            .circuits to OPFPBLF status within 72 hours orl be in at least HOT ACTION F                     [STANDBY within the next 6 hours and in COLD SHUTDOWN within the Lftllowing 30 hours.                                                                          gL2

b. _With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the Add proposed Rei ACTION B remaining A.C. sources by performing Surveillance Requirement Action 1.3.1 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter and by performing Serveillanc Reouirement 4.8-1.1.2.a.4 within 24 hours.* Restore at least two diesel

                             'generators to OPERABLE status within 7 da s or be in HOT STANDBY ACTION F                       within the next 6 hours and In COLD SHUTDOWN within the following 3 hours.                                                   [LAd~d proposedýACTIOtND=No.1.3--(

ACTION D iWth one offsite circuit and one diesel generator of the above W.

                             -required A.C. electrical Power sources inoperable. demonstrate the OPERABILITY of the remaining A.C. sources by performing Required Action A.1 -          Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter*an        by performing Surveillance Required Action D.3.2 DAVIS-BESSE, UNIT I                        3/4 8-1              Amendment No.     .6.9-..g3.,206 Page 1 of 10 Attachment 1, Volume 13, Rev. 0, Page 5 of 323

Attachment 1, Volume 13, Rev. 0, Page 6 of 323 ITS 3.8.1 ITS ELECTRICAL POWER SYSTEMS ACTION (Continued) ____ ,_____Addproposed Required Action B.3.2- ------ a uirement 4.8.1.1.2.a.4 within, hoursf. Restore at least one of Required Action 8.3.1 ACTIOND [.he inoperable sources to OPERABLE status within 12 hours -or be in

                             .at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN ACTIONF                         within the following 30 hours.           With the inoperable offsite source Required Action B.4             restored, restore two diesel generators to OPERABLE status within da s from the time of the initial loss o-r be in at least HOT ACTIONF                         STANDBY within the next 6 hours and in COLD SHUTDOWN within the ollowing 30 hours. [With the inoperable diesel generator Required Action A.3   __        restored, restore two offsite power sources to OPERABLE status Lenithin 72 hours from the time of the initial loss or be in at ACeast HUI SIANDBY within the next 6 hours and in COLD SHUTDOWN ACTIONF                        Lwithin the following 30 hours.

ACTION C d. With two of the above required offsite A.C. circuits inoperable, demonstrate the qPERABILITY of two diesel generators by performing L01 Surveillance Reoirement 4.8.1.1.2.a.4 within/8 hours and at leasti once per 8 hour thereafter unless the die-M generators are lae orati l- restore at least one of the inoperable offsite ACTIONC -_urces to OPERABLE status within 24 hours o[rbe in at least HOT ACTIONF _ANDBY within the next 6 hours. With only one offsite source R r c Arestored, restore at least two offsite circuits to OPERABLE status RequredActionA.3 within 72 hours from time of initial loss or be in at least HOT LSTANDBY within the next 6 hours and in COLD SHUTDOWN within the ACTIONSFfollowing 30 hours. ACTIONE e. With two of the above required diesel generators inoperable, emonstrate the OPERABILITY of two offsite A.C. circuits by Required Action B.1 performing Surveillance Requirement 4.8.1.1.1.a within one hour d at least once per 8 hours thereafter; rwrestore at least one or ACTIONE - e inoperable diesel generators to OPERABLE status within 2 hours orrbe in at least HOT STANDBY within the next 6 hours and in COLD ACTIONF IHUTDOWN within the following 30 hours. Restore at least two RequiredActionB.An _ diesel

                               . itial generators loss or be toin OPERABLE    status    within at least HOT STANDBY within   7 days from time of the next 6 hours ACTION F                      Fand in COLD SHUTDOWN within the following 30 hours.

SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required qualified circuits between the offsite transmission network and the onsite Class 1E A.C. electrical power distribution system shall be: SR3.8.1.1 a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments and indicated Power availability,.and [-ý Add proposed Not 1 to S .8 . A10 SR 3.8.1.9 b. Demonstrated OPERABLE at lea nce each REFUEL khu bywtransferring (manually and utaialyuni NG INTERVAL Iduring 'ow'r L08 Ispp ýy toeach of the offsite circuitsy 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE: Li0 SR 3.8.1.2. SR3.8.1.3. 2a. -At least once per OW day s urveillance Requirement 4.8.1.1.2.c SR 3.8.1.4. ]has not been Per/formed within the previous 311daw. by: SR 3.8.1.6. SR 3.8.1.7 DAVIS-BESSE, UNIT 1 3/4 8-2 Amendment No. 97,107,2*3,2065,219 Page 2 of 10 Attachment 1, Volume 13, Rev. 0, Page 6 of 323

Attachment 1, Volume 13, Rev. 0, Page 7 of 323 ITS 3.8.1 ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continuedl I m SR 3.8.1.4 1. 12-Verifying the fuel level in the day fuel tank. Verifying the fuel level in the fuel storage tank. [ ITSSee 3.8.3 jI SR 3.8.1.7 3. Verifying the fuel transfer pump can be started and trans- Add proposed steady state MOl fers fuel from the storage system to the day tank. voltage and frequency SR 3.8.1.2 4. Verifying the diesel starts andjaccelerates r z o to rNtl A08 _preceded by an engine prelube and/or appropriate ot~her / Notes 1 and 2) SR 3.8.1.2 Note -w-armup pPro°c ed ures. f * /M " 1ý'erifyinq the generator is synchronized, loaded to >_ 0 0 No tes 38aln3 4

SR 3.8.1.3 S.

and operates for > 60 minutes. * .....

6. Verifying t e diesel generator is alI gned to provide_j 2340kW _

standby poqer to the associated essential busses. SR 3.8.1.6 7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10' of its required S a sample of diesel

b. At least once per 92 days by verifying that fuel from the fuel storage tank is within the acceptable limits Ae.e specified in Table I o'f-ASTM D975-68 when checked for viscosity,

                         )water and sediment,                               -*      _

L:LD 92A05

c. At least once per [8 days by: F.

SR 3.8.1.4 1. Verifying the fuel level in the day fuel tank. L10

2. Verifying the fuel level in the fuel storage tank.- ITS3.8.3]

SR 3.8.1.7 3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.A0 SR 3.8.1.8 4. Verifying the diesel starts-from ambient condition and laccelerates to K Ileast 900 rpmI in

10 seconds. Add proposed voltage and frequency M0l SR 3.8.1.3 5.ýý Verifying the generator is synchronized,

loaded to > 10P0_ \ (M0yI I .fl ~n. '. ____ ___

6. standby Verifyingpowert~e to the associated diesel generator isessential al gned bussesI to provide) -

SR 3.8.1.6 7. Verifying'that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10% of its required value. DAVIS-BESSE, UNIT I 3/4 8-3 Amendment No. -?5, 9* ...1 , 203 Add proposed SIR3.8.1.3 Notes 1 and2 A08 Add proposed SIR3.8.1.3 Notes 3 and 4 Notes 31 and 42 I proposed SR 3.8.1.3 Add proposed (L Add Page 3 of 10 Attachment 1, Volume 13, Rev. 0, Page 7 of 323

Attachment 1, Volume 13, Rev. 0, Page 8 of 323 ITS 3.8.1 ITS E-LF.CTRICAI_ POWER SYSTEMIS SURVEILLANCE REQUIR.EMENTS (Continued) [ rpsdS ... 0Nt* /

d. At least once each REFUELIN-G INTERVALdrn shtonbYAd SR 3.8.1.10 1. ýVerifying the generator capability to reject a load equal to the largest single emergency load supplied by the generator without tripin I_ , [ Add proposed SR SR 3.8.1.15 2. Simulating a loss of offsite power in conjunction with a safety features actuation 3.8.1.15 Note 1

[system (SIFA S) test signal, and: acu lo (a) V.erifying dc-energization of the essential busses and load shedding front the '" L3 essential busses. (b) Verifyine 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 Add proposed start

                             > 5 minutes while its- generator is loaded with the essential loads,                          ~statelimitvoltage
                                                                                                                       ] time           and steady and    M07)

(c) Verifying that all diesel generator trips, except engine overspeed and generator frequency limits SR 3.8.1.12 differential, are automatically bypassed upon loss of voltage on the essential bus and/or an SFAS test signal. SR 3.8.1.13 3.!V~\"erifying h.t' e diesel generator operates for >P60 minutes while loaded to>. 0CM06t A Note 1 and Note 3 4 Delete.UIT Add proposed c.p least cucAt onceprprder30 rn~nthsil c~jn~by s.ubjecting the diesels to an insp -tion[in accordance with class of standby servi c. [Add proposed SR 3.8.1.5, SR 3.8.1.11, =andS=R3.8=.1.141 M0 4Pagel4tof.10 "The provision of Specification 4.0.2 arI not applicbe 2@ DAVIS-BESSE. UNIT 1 3/4 8-4 .-Amendment No. 97, 105, 14 1, 2)19, 273 Page 4 of 10 Attachment 1, Volume 13, Rev. 0, Page 8 of 323

Attachment 1, Volume 13, Rev. 0, Page 9 of 323 ITS 3.8.1 ITS 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREIENTS 3/4.0 APPLICABILITY LIMITING CONDrTTON FOR OPERATION 3.0.i Limiting Conditions for Operation and ACTION requirements shall be applicable during the OPERATIONAL HODES or other conditions specified for each specification. 3.0.2 Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, ACTION statement is not required. completion of the 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, action shall be initiated within I hour to place the unit In a MODE in which the Specification does not apply by placing it, as applicable, in: See

1. At least HOT STANDBY within the next 6 hours, ITS 3.0

2. At least HOT SHUTDOWN within the following 6 hours, and

3. At least COLD SHUTDOWN within the subsequent 24 hours.

Where corrective measures aFe completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet' the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications. 3.0.4 Entry into an OPERATIONAL MODE or other specified applicability condition shall-notbe made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted. This. provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION

tat~m~nt*_
statements Required I ctions 3.0.5 When a system, subsystem. train, co*ponent or device is determined to A.2. B.2, a nd C.1 be Inoperable solely because its emergency power source is inoperable' or solely because its normal power source is' inoperable, it ma~ybe considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s).

subsystem s). train(s), compone t(s) and device(s) are OPERABLE, or likewise satisfy the. requirements of this secification. Unless both conditions 1 and (2) are satisfied. within 2 u act on sall 'be Initiated to place tne unit In a MODE in t e ap icale Limiting Condilon for iperatlon doese not a~nl Ybnac!/It as appi1-hl-enL '"

1. At least HOT STANDBY within the ne~t 6 hours. O.O.4

2. At least HO7 SHUTDOWN within-the f llowing 6 hours, and 1* i1c rnn Rwiri1wN thLj the a thp ý hhnnPnnt ?4 hours i rTkT, r1-i1NAfinn is not a licaMn 4 MODES 5 or 61 3.0.6 Equipment removed from service or declared inoperable to comply with J

ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of See other equipment. This is an exception to Specification 3.0.2 for the system ITS 3.0 returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. DAVIS-BESSE, UNIT I 3/4 0-1 Amendment No. ;224 Declare required features inoperable. ) 24 hours for 4 hours for proposed proposed Required Required Action Action B.2 A.2 L04 12 hours for Required Action C.1 Page 5 of 10 Attachment 1, Volume 13, Rev. 0, Page 9 of 323

Attachment 1, Volume 13, Rev. 0, Page 10 of 323 ITS 3.8.1 ITS INSTRUMENTATION 3/4.3.2 SA.FETY SYSTEM rINSTRUMENTATION, SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION LCO 3.8.1 3.3.2.1 The Safety Features Actuation System (SFAS) functional units shown in Table 3.3-3 shall be OPERABLE with their trip setpoints set consistent with the Allowable Value column of Table 3.3-4. APPLICABILITY: As shown in Table 3.3-3. ACTION:

a. With a SFAS functional unit trip setpoint less conservative than the value shown in the lITSSee3.3.51 Allowable Values column of Table 3.3-4, declare the functional unit inoperable and apply the and applicable ACTION requirement of Table 3.3-3, until the functional unit is restored to ITS 3.3.8)

OPERABLE status with the trip setpoint adjusted consistent with Table 3.3-4.

b. With a SFAS functional unit inoperable, take the action shown in Table 3.3-3. See ITS 3.3.5,/

ITS 3.3.6,l SURVEILLANCE REQUIREMENTS ITS 3.3.7, and 4.3.2.1.1 Each SFAS functional unit shall be demonstrated OPERABLE by the performance of the ITS 3.3.8_) CHAN`NEL CHECK. CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST during the MODES and at the frequencies shown in Table 4.3-2. 4.3.2.1.2 The logic for the RCS pressure operating bypasses shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of functional units affected by the RCS pressure See operating bypass operation. This RCS pressure operating bypass function shall be demonstrated ITS 3.3.55 OPERABLE at least once per REFUELING INTERVAL during CHANNEL CALIBRATION testing of each functional unit affected by the RCS pressure operating bypass operation. 4.3.2.1.3 The SAFETY FEATURES RESPONSE TIME of each SFAS function shall be demonstrated to be within the limit at least once per REFUELING INTERVAL. Each test shall include at least one See functional unit per function such that all functional units are tested at least once every N times the ITS 3.3.5] REFUELING INTERVAL where N is the total number of redundant functional units in a specific SFAS and (.ITS 3.3.8) function as shown in the "Total No. of Units" Column of Table 3.3-3.

         .The response times (except for manual initiation) include diesel generator starting and sequence loading delays, when applicable. The response time limit (except for manual initiation) includes movement of valves and attainment of pump or blower discharge pressure.                                                    H L   See ITS 3.3.5 DAVIS-BESSE, UNIT I                             3/4 3-9              Amendment No.          "2,, 241. 243, 259,275

.S, Page 6 of 10 Attachment 1, Volume 13, Rev. 0, Page 10 of 323

Attachment 1, Volume 13, Rev. 0, Page 11 of 323 C Cq-CO) CD 0_ p.- r) 0

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                                      -J) y Attachment 1, Volume 13, Rev. 0, Page 11 of 323

Attachment 1, Volume 13, Rev. 0, Page 12 of 323 ITS 3.8.1 TABLE 3.3-3 (Continued) TABLE NOTATION

Trip function may be bypassed in this MODE with RCS pressure below 1800 psig. Bypass shall be automatically removed when RCS pressure exceeds 1800 psi8 . r See ITS 3.3.5 J

        "" Trip function may be bypassed in this MODE with RCS pressure below 660 psig. Bypass shall be automatically removed when RCS pressure exceeds 660 psig.

DELETED DELETED r See All functional units may be bypassed for up to one minute when starting each Reactor Coolant ITS 3.3.8II Pump or Circulating Water Pump. See 1 1.'0=** When either Decay Heat Isolation Valve is open. 1- ITS 3.3.5 J I # The provisiof(s of Specification 3.0.4 jrc not applicable. A009 ACTION STATEMENTS See ACTION 10 - With the number of OPERABLE functional units one less than the Total Number of Units, STARTUP and/or POWER OPERATION may proceed provided, within one ITS 3.3 .5 J hour (except as noted below), the inoperable functional unit is placed in the tripped condition. When one functional unit is placed in an inoperable status solely for performance of a CHANNEL FUNCTIONAL TEST, a declaration of inoperability and associated entry into this ACTION statement may be delayed for up to 8 hours, provided at least two other corresponding functional units are OPERABLE. ACTION I1- With any component in the Output Logic inoperable, trip-the associatedecomponents within one hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. see ITS 3.3 .7 I DAVIS-BESSE, UNIT I 3/4 3-12 Amendment No. 28,37,52,102,135, 159,186,211,218,221, 259 Corrected by letter dated 6/2/98 0-Page 8 of 10 Attachment 1, Volume 13, Rev. 0, Page 12 of 323

Attachment 1, Volume 13, Rev. 0, Page 13 of 323 ITS 3.8.1 ITS TABLE 3.3-3 (Continued) ACTION 12 - With the number of OPERABLE Units one less than the Total Number of Units, restore the inoperable functional unit .to OPERABLE See status within 48 hours or be in at least HOT STANDBY within the ITS 3.3.6 next 6 hours and in COLD SHUTDOWN within.the following 30 hours. ACTION 13 - a. With less than the Minimum Units OPERABLE and indicated reactor coolant pressure a 328 psig, both Decay Heat Isolation Valves (DH1! and DH12) shall be verified closed. I

b. With Less than the Minimum Units OPERABLE and indicated See reactor coolant pressure < 328 psig operation may continue; ITS 3.3.14 however, the functional unit shall be OPERABLE.prior to increasing indicated reactor coolant pressure above 328 psig.

With less than the Minimum Units OPERABLE and indicated reactor coolant pressure < 328 psig, operation may continue; however, the. functional unit shall be OPERABLE prior to'increasing indicated reactor coolant pressure above 328 psig, or the inoperable functional unit shall be placed in the tripped state. See ITS3.3.5 I ACTION G ACTION 15 - a. With the number of OPERABLE units one less than'the-Minimum Units Operable per Bus, place the inoperable unit in the tripped condition within one hour. For functional unit 4.a the sequencer shall be placed in the tripped condition by physical functionalremoval of the sequencerfo~rmodule. e noperablel unit may be bypassed -u~p-to2 h hours for see [TS--3.3 (surveillance testing per Specification 4.3.2.1.1..:... ACTION H b. 4 With the number of OPERABLE units two less than the Minimum Units Operable per Bus, declare inoperable the Emergency .AddproposedActonH Diesel Generator associated with the functional units not (first*Condition) meeting the required minimum units OPERABLE and take the ACTION required of Specification 3.8.1.1. DAVIS-BESSE, UNIT 1 3/4 3-12a Amendment No. 28,62,12,136r4,2 , 218 Page 9 of 10 Attachment 1, Volume 13, Rev. 0, Page 13 of 323

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Attachment 1, Volume 13, Rev. 0, Page 15 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS). These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 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 3.8.1.1 precludes entering MODES 1, 2, 3, and 4 when the EDG is inoperable. ITS LCO 3.0.4 has been added in accordance with the Discussion for Changes for ITS Section 3.0, DOC L01. 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 ifa risk assessment is performed, that determines it is acceptable to enter the Applicability, and appropriate risk management action are established. This 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 3.8.1.1 does not currently allow this option. This change is considered administrative because it does not result in technical changes to the CTS. A03 CTS 3.8.1.1 Action c applies when one offsite circuit and one EDG are inoperable. In this condition, an essential bus may be de-energized. CTS 3.8.2.1 provides an Action for an essential bus that is de-energized. A Note to ITS 3.8.1 ACTION D in the Required Actions column states, "Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating," when Condition D is entered with no AC power source to any train." This change is acceptable because no changes are made to CTS requirements. The change in format from the CTS to the ITS maintains all technical requirements. The addition of the Note only acts as a reminder to enter all appropriate ACTIONS if any essential bus becomes de-energized. In the event AC Sources are inoperable such that a distribution subsystem were inoperable, ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in this event (an entire train may be without power), specific direction to take appropriate ACTIONS for the Distribution System is added (ITS 3.8.1, Note to ACTION D) when there is not power for a train. This format and construction implements the existing Davis-Besse Page 1 of 16 Attachment 1, Volume 13, Rev. 0, Page 15 of 323

Attachment 1, Volume 13, Rev. 0, Page 16 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING treatment of this condition within the framework of the Davis Besse ITS methods. This change is designated as administrative because it does not result in a technical change to the CTS. A04 CTS 3.8.1.1 does not contain an Action for more than two sources of either offsite circuits or EDGs inoperable. Having more than two sources inoperable requires entering CTS LCO 3.0.3. ITS 3.8.1 ACTION I requires entering LCO 3.0.3 immediately ifthree or more AC Sources are inoperable. This changes the CTS by adding a specific ACTION requiring entry into LCO 3.0.3. The change is acceptable because the CTS Actions for more than two sources inoperable are the same as the ITS ACTIONS. The change is necessary due to the format of the ITS. This change is designated as administrative because it does not result in a technical change to the CTS. A05 CTS 4.8.1.1.2.a requires performance of 4.8.1.1.2.a.1, 4.8.1.1.2.a.3, 4.8.1.1.2.a.5, and 4.8.1.1.2.a.7 every 31 days, while CTS 4.8.1.1.2.c requires performance of similar Surveillances (CTS 4.8.1.1.2.c.1, 4.8.1.1.2.c.3, 4.8.1.1.1.2.c.5, and 4.8.1.1.2.c.7) every 184 days. In addition, CTS 4.8.1.1.2.a includes a statement that the Surveillances of CTS 4.8.1.1.2.a are only required if the Surveillances of CTS 4.8.1.1.2.c have not been performed within the previous 31 days. ITS SR 3.8.1.3, SR 3.8.1.4 and SR 3.8.1.6 perform the same Surveillances on a 31 day Frequency and ITS SR 3.8.1.7 is performed on a 92 day Frequency. This changes the CTS by combining the two similar Surveillances (one from CTS 4.8.1.1.2.a and the other from CTS 4.8.1.1.2.c) into a single Surveillance with a Frequency of 31 days or 92 days, as applicable. The change to allow 92 days for CTS 4.8.1.1.2.a.3 and CTS 4.8.1.1.2.c.3 is discussed in DOC L10. This change is acceptable because CTS 4.8.1.1.2.c.1, 4.8.1.1.2.c.3, 4.8.1.1.2.c.5, and 4.8.1.1.2.c.7 are duplicative of CTS 4.8.1.1.2.a.1, 4.8.1.1.2.a.3, 4.8.1.1.2.a.5, and 4.8.1.1.2.a.7, respectively. Based on the 31 day requirement of CTS 4.8.1.1.2.a, the tests would be performed at a 31 day interval, not the 184 day interval of CTS 4.8.1.1.2.c. This change is designated as administrative because. it does not result in a technical change to the CTS. A06 CTS 4.8.1.1.2.a.4, CTS 4.8.1.1.2.c.4, and CTS 4.8.1.1.2.d.2 require the EDGs to be started. ITS SR 3.8.1.2, SR 3.8.1.8, and SR 3.8.1.15 also require the EDGs to be started. However, each of the ITS Surveillances include a Note concerning prelube. ITS SR 3.8.1.2 and SR 3.8.1.15 Note 1, and the Note to SR 3.8.1.8 state that all EDG starts may be preceded by an engine prelube period and followed by a warm-up period prior to loading. This changes the CTS by adding the Notes to the applicable Surveillance Requirements. A Note has been added to various Surveillances which allow all 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 administrative since the EDGs at Davis Besse run in a continuous prelube mode of operation. In addition the Note to ITS SR 3.8.1.2 allows a warm-up period prior to loading. The addition of this Note is considered administrative because the EDGs are not immediately loaded upon startup, but are allowed to warm-up for a short time Davis-Besse Page 2 of 16 Attachment 1, Volume 13, Rev. 0, Page 16 of 323

Attachment 1, Volume 13, Rev. 0, Page 17 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING after startup while the operations staff performs post startup EDG checks. This change is considered administrative because it does not result in a technical change to the CTS. A07 CTS 4.8.1.1.2.a.4, 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 that a modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. The purpose of CTS 4.8.1.1.2.a.4, 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 manufacturer's recommendations. This change is designated as administrative because it does not result in a technical change to the CTS. A08 CTS 4.8.1.1.2.a.5 and 4.8.1.1.2.c.5 require the EDG to be synchronized and loaded for> 60 minutes. ITS SR 3.8.1.3 Notes 1 and 2 have been added. Note 1 states that EDG loading may include gradual loading as recommended by the manufacturer. Note 2 states that momentary transients outside the load range do not invalidate this test. This changes the CTS by adding explicit Notes that state EDG loadings may include gradual loading as recommended by the manufacturer and momentary transients outside the load range do not invalidate this test. CTS 4.8.1.1.2.a.5 and 4.8.1.1.2.c.5 require the load to be at a specific value for

     > 60 minutes. (DOC M03 discusses the load changes.) The Note 1 allowance simply states that prior to entering the load range of the test, the EDG can be gradually loaded. This is currently allowed by the CTS since there is no explicit requirement precluding this operation. This change is acceptable because Note 1 to SR 3.8.3.1 simply clarifies how the EDG can be loaded prior to entering the load range for the test. The addition of Note 2 is considered administrative because CTS 4.8.1.1.2.a.5 and 4.8.1.1.2.c.5 do not require the load to be at rated load. (See M02 for further discussion on load changes.) This change is designated as administrative because it does not result in a technical change to the CTS.

A09 CTS Table 3.3-3 Functional Unit 4 includes a Note # that states the provisions of Specification 3.0.4 are not applicable. ITS 3.8.1 does not include this Note for the sequencers. This changes the CTS by deleting the specific exception to Specification 3.0.4. This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Davis-Besse Page 3 of 16 Attachment 1, Volume 13, Rev. 0, Page 17 of 323

Attachment 1, Volume 13, Rev. 0, Page 18 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Applicability for an unlimited period of time. ITS 3.8.1 ACTION G requires the plant to remove the inoperable load sequencer and allows operation to continue for an unlimited period of time. Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances. This change is designated as administrative because it does not result in a technical change to the CTS. A10 CTS 4.8.1.1.1.b requires the offsite circuits be demonstrated OPERABLE by transferring (manually and automatically) unit power supply to each of the offsite circuits. ITS SR 3.8.1.9 requires the same Surveillance, broken into two parts - transfer from the unit auxiliary source to the pre-selected offsite circuit and from the normal offsite circuit to the alternate offsite circuit. However a Note is added that states the transfer from the unit auxiliary source to the pre-selected offsite circuit is only required to be met when the unit auxiliary source is supplying the electrical power distribution subsystem. This changes the CTS by clarifying that the Surveillance checks both the transfer from the unit auxiliary source (i.e., the main generator) to the pre-selected offsite circuit and the transfer from one offsite circuit to the other offsite circuit, and by adding a clarification Note to the Surveillance (Note 1 to ITS SR 3.8.1.9). This change to the Surveillance test is acceptable since both types of transfers are checked due to the design and operation of the Davis-Besse switchyard. The change adding the Note is acceptable since the unit auxiliary source (main generator) automatic transfer scheme is not required for OPERABILITY when it is not supplying power; the normal offsite circuit would be in a configuration to perform its safety function. This change is designated as administrative because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 4.8.1.1.2.a.4, the normal EDG start test, requires that each EDG accelerates up to 900 rpm. CTS 4.8.1.1.2.c.4, the quickstart test, requires that each EDG accelerates up to 900 rpm in less than or equal to 10 seconds. ITS SR 3.8.1.2 requires that each EDG start from standby conditions and achieves steady state voltage > 3744 V and < 4400 V and frequency > 59.5 Hz and

     < 60.5 Hz. ITS SR 3.8.1.8, the 184 day quickstart test, requires each EDG to achieve a voltage > 4031 V and a frequency > 58.8 Hz in < 10 seconds and achieves a steady state voltage > 3744 V and < 4400 V and frequency > 59.5 Hz and < 60.5 Hz. This changes the CTS by providing specific steady state voltage and frequency limits for both Surveillances and a minimum voltage limit to be achieved within 10 seconds for the 184 day Surveillance. The change in the speed requirement for the 184 day Surveillance is discussed in DOC LI 1.

The purpose of the CTS 4.8.1.1.2.a.4 and CTS 4.8.1.1.2.c.4 is to ensure that each EDG can properly startup so that they can supply the emergency loads. This change is acceptable because the added steady state values for voltage and frequency and the added minimum voltage limit help to ensure the EDGs will be capable of supplying the emergency loads when required. This change is Davis-Besse Page 4 of 16 Attachment 1, Volume 13, Rev. 0, Page 18 of 323

Attachment 1, Volume 13, Rev. 0, Page 19 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING designated as more restrictive because it adds specific limits to the CTS where none previously existed. M02 CTS 4.8.1.1.2.a.5 and CTS 4.8.1.1.2.c.5 require each EDG to be synchronized and loaded for > 60 minutes. ITS SR 3.8.1.3 requires the same test, however two additional Notes have been added which place restrictions on the test. Notes 3 and 4 modify the CTS requirements by stating that the SR shall be conducted on only one EDG at a time, and the SR shall be preceded by and immediately follow, without a shutdown of the EDG, a successful performance of ITS SR 3.8.1.2 or ITS SR 3.8.1.8. This changes the CTS by adding restrictions when performing this test. The purpose of CTS 4.8.1.1.2.a.5 and CTS 4.8.1.1.2.c.5 is to ensure the EDGs can supply the emergency loads. This change is acceptable because CTS 4.8.1.1.2.a.5 and CTS 4.8.1.1.2.c.5 are normally conducted on one EDG at a time. In addition, the loading of a EDG is usually conducted without shutdown after a successful start during performance of CTS 4.8.1.1.2.a.4 or CTS 4.8.1.1.2.c.4. This change is designated as more restrictive because explicit restrictions are added to the EDG load test. M03 CTS 4.8.1.1.2.a.5 and CTS 4.8.1.1.2.c.5 require, in part, verification that each EDG is loaded to > 1000 kW. ITS 3.8.1.3 requires the same verification, however the test is performed at 2340 to 2600 KW, which corresponds to 90% and 100% of rated load. This changes the CTS by requiring the EDGs to be tested at a higher load during this Surveillance. The purpose of CTS 4.8.1.1.2.a.5 and CTS 4.8.1.1.2.c.5, in part, is to ensure the EDGs can supply the emergency loads. This change requires the EDGs to be tested at a higher load during this Surveillance. This change is acceptable because the proposed Surveillance Requirement acceptance criteria are necessary for verification that the equipment used to meet the LCO can perform its required functions. The proposed 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 upper value (100%) will preclude routine overloading of the EDG. This change is considered more restrictive because more stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. M04 ITS SR 3.8.1.5 requires that each day tank be checked for accumulated water and to remove it every 31 days. ITS SR 3.8.1.11 requires that all actions encountered from the loss of offsite power, including shedding of the non-essential loads and energization of the essential buses and respective loads from the EDG. It also demonstrates the capability of the EDG to automatically achieve the required voltage and frequency with a specific time. ITS SR 3.8.1.14 requires that the diesel engine can restart from a hot condition and achieve the required voltage and frequency with a specific time. This changes the CTS by adding these Surveillance Requirements. The purpose of these additional Surveillance Requirements is to ensure the EDGs are OPERABLE. This change is acceptable because it provides additional assurance that the EDGs remain OPERABLE to perform their safety function. Davis-Besse Page 5 of 16 Attachment 1, Volume 13, Rev. 0, Page 19 of 323

Attachment 1, Volume 13, Rev. 0, Page 20 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING This change is designated as more restrictive because it adds Surveillance Requirements to the CTS. M05 CTS 4.8.1.1.2.d.1 requires the verifying that the EDG is capable of rejecting a load equal to the largest single emergency load supplied by the generator without tripping. This surveillance does not specify that a EDG shall be tested at a specific power factor. ITS SR 3.8.1.10 requires the verification that each EDG can reject a load equal to or greater than its associated single largest post-accident load. The SR additionally states in Note 2 "Ifperformed with the EDG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable." This changes the CTS requirement by specifying a power factor limit ifthe testing is conducted by synchronizing with the offsite sources. Other changes to CTS 4.8.1.1.2.d.1 are discussed in DOC M01. The purpose of CTS 4.8.1.1.2.d.1 is to ensure the EDG will continue to supply the emergency loads if the single largest load is tripped. This change is acceptable because the testing should be conducted as close as possible to the conditions that would be experienced by an EDG following an accident. Loading the EDG solely with the inductive characteristics of a large motor will create a power factor less than unity. The design of the EDG is set for full operation with a power factor of > 0.8. Therefore, testing of the EDG for a loss of the single largest load within the power factor limit, if applicable, is acceptable. This change is designated as more restrictive because the testing required by the CTS does not currently contain the limitation. M06 CTS 4.8.1.1.2.d.3 requires verification that the diesel generator operates for

      > 60 minutes while loaded to > 2000 kW. ITS SR 3.8.1.13 requires an endurance and load test for each EDG. The endurance and load test requires that the EDGs be operated for > 8 hours, with > 2 hours loaded at > 2730 kW and < 2860 kW and the remaining 6 hours loaded at > 2340 kW and < 2600 kW. This Surveillance is modified by Note 1 and Note 3. Note 1 states that "momentary transients outside the load and power factor ranges do not invalidate this test."

Note 3 states "Ifpart b is performed with EDG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable." This changes the CTS by requiring the emergency diesel generators to be tested for a longer duration, at a high loading, and within a power factor limit, with an allowance to not meet the load or power factor requirements due to momentary transients. The purpose of CTS 4.8.1.1.2.d.3 is to ensure the EDG can supply the emergency loads. This change requires the EDGs to be tested at a load range of 105% to 110% for 2 continuous hours and a load range of 90% to 100% within the power factor limit, if applicable, for 6 hours, consistent with the recommendations of IEEE Standard 387-1995. The change is acceptable because it provides additional assurance that the EDGs remain OPERABLE to Davis-Besse Page 6 of 16 Attachment 1, Volume 13, Rev. 0, Page 20 of 323

Attachment 1, Volume 13, Rev. 0, Page 21 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING perform their safety function. This change is designated as more restrictive because it adds more stringent testing requirements to the CTS. M07 CTS 4.8.1.1.2.d.2.(b) requires, in part, verification that the diesel starts on auto-start signal, energizes the essential buses with permanently connected loads, energizes the auto-connected essential loads, and operates for > 5 minutes. ITS SR 3.8.1.15 contains the same verification; however the Surveillance also requires verifying that the EDG starts and energizes the permanently connected loads in < 10 seconds and the EDG achieves steady-state voltage and steady-state frequency. This changes the CTS by requiring the EDGs to startup within a certain time limit and to be operated at a specific steady-state voltage and frequency. The purpose of CTS 4.8.1.1.2.d.2.(b), in part, is ensure that the EDGs can operate when loaded to the essential buses after a loss of offsite power signal concurrent with an SFAS actuation signal. This change allows the EDGs to be tested at the required voltage and frequency. This change is acceptable because it allows the EDGs to achieve the required steady-state voltage and frequency. The proposed requirements are consistent with Regulatory Guide 1.9, Rev. 3 (paragraph 0.2.2.6), which recommends, in part, that the EDGs starts on an autostart signal, and attain the required voltage and frequency. The proposed values are the required steady-state voltage and frequency and therefore are considered to be consistent with the recommendations of Regulatory Guide 1.9, Rev. 3. This change is considered more restrictive because more stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. M08 CTS 4.8.1.1.2.d.1 requires verification that each EDG can reject a load equivalent to the largest single emergency load without tripping the EDG. ITS SR 3.8.1.10 also requires verification that each EDG can reject a load equivalent to the largest single emergency load, except the acceptance criterion is that the EDG frequency is maintained < 66.75 Hz following the load reject, which is below the EDG overspeed trip setpoint. This changes the CTS by requiring the EDG to maintain a frequency < 66.75 Hz following the load reject instead of not tripping the EDG. The purpose of CTS 4.8.1.1.2.d.1 is to ensure the EDG will continue to supply the emergency loads if the single largest load is tripped. The change is acceptable since the new acceptance criterion is more limiting than the current criterion and will ensure margin to the overspeed trip setpoint is maintained. The 66.75 Hz value represents 75% of the difference between the synchronous speed and the overspeed trip setpoint. The new criterion is consistent with Safety Guide 9, which is the Safety Guide the Davis-Besse EDGs were originally designed to meet. This change is designated as more restrictive because it adds a more stringent testing criterion in the ITS than is in the CTS. RELOCATED SPECIFICATIONS None Davis-Besse Page 7 of 16 Attachment 1, Volume 13, Rev. 0, Page 21 of 323

Attachment 1, Volume 13, Rev. 0, Page 22 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.1.1.b requires two "separate and independent" EDGs to be OPERABLE, each with a "separate" day fuel tank and a "separate fuel transfer pump." ITS LCO 3.8.1 requires two qualified circuits between the offsite transmission network and the onsite Class 1 E distribution system and two EDGs capable of supplying the onsite Class 1 E distribution subsystem to be OPERABLE. This changes the CTS by moving the details that the EDGs are "separate and independent" from the CTS to the 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. The ITS still retains the requirements for OPERABLE offsite sources and EDGs and that the fuel oil transfer system operated automatically to transfer fuel oil from the storage tank to the day 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 Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes. LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.a.6 and 4.8.1.1.2.c.6 require the verification that each EDG is aligned to provide standby power to the associated essential buses. ITS 3.8.1 SRs do not contain this requirement. This changes the CTS by moving the detail that each EDG is aligned to provide standby power to the associated emergency buses from the CTS 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. The ITS still requires the EDGs to be OPERABLE. An OPERABLE EDG must be capable of providing power to the associated essential buses as indicated in the Bases. The details of what an OPERABLE EDG must be capable of performing do not need to appear in the Specification in order for the requirement to apply. 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. LA03 (Type 4 - Relocation of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, IST Program,or liP) CTS 4.8.1.1.2.e requires each EDG to be subjected to an inspection every 30 months (as modified by footnote *) in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service. The ITS does not include this EDG inspection requirement. This changes the CTS by moving the explicit EDG Davis-Besse Page 8 of 16 Attachment 1, Volume 13, Rev. 0, Page 22 of 323

Attachment 1, Volume 13, Rev. 0, Page 23 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING inspection Surveillance from the Technical Specifications to the Technical Requirements Manual (TRM). The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 4.8.1.1.2.e is to ensure that each EDG is inspected in accordance with procedures performed in conjunction with the manufacturer's recommendations. The other EDG Surveillances will ensure the EDG is capable of performing its safety function. This requirement is proposed to be relocated to the TRM since the requirement is not needed to ensure that the EDG remains OPERABLE. This change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus 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. LA04 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-3 for Functional Unit 4 has three columns stating various requirements for each instrument string. These columns are labeled, "TOTAL NO. OF UNITS," "UNITS TO TRIP," and "MINIMUM UNITS OPERABLE." ITS 3.8.1 does not retain the "TOTAL NO. OF UNITS" or "UNITS TO TRIP" columns. This changes the CTS by moving the information of the "TOTAL NO. OF UNITS" and "UNITS TO TRIP" columns to the 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. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. 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 L01 (Category 4 - Relaxation of RequiredAction) CTS 3.8.1.1 Action a states, in part, with one offsite circuit inoperable perform CTS 4.8.1.1.2.a.4 within 24 hours. CTS 3.8.1.1 Action d states, in part, with two offsite circuits inoperable perform CTS 4.8.1.1.2.a.4 within 8 hours and once per 8 hours thereafter, unless the EDGs are already operating. CTS 4.8.1.1.2.a.4 requires verification that the diesel starts and accelerates up to 900 rpm, preceded by an engine prelube and/or appropriate other warm-up procedure. ITS 3.8.1 ACTIONS A and C do not contain these requirements. This changes the CTS by deleting the requirement to test the diesel when one or both offsite circuits are inoperable. Davis-Besse Page 9 of 16 Attachment 1, Volume 13, Rev. 0, Page 23 of 323

Attachment 1, Volume 13, Rev. 0, Page 24 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of the CTS 4.8.1.1.2.a.4 requirement in CTS 3.8.1.1 Actions a and c is to ensure that the EDGs are OPERABLE in case a loss of offsite power were to occur. Since the EDGs are tested on monthly basis, there is no reason to believe that they will not perform their intended safety function. Furthermore, the inoperability of one or more offsite circuits does not affect the OPERABILITY of the EDGs, since the EDGs are independent of the offsite circuits. Therefore, there is no need to put the EDGs through unnecessary testing. This change is designated as less restrictive because the requirement to perform testing on the associated EDG is not being retained. L02 (Category4 - Relaxation of RequiredAction) When an EDG is found inoperable, CTS 3.8.1.1 Action b, requires a demonstration that the remaining EDG is OPERABLE within 24 hours. When an EDG and an offsite circuit are concurrently inoperable, CTS 3.8.1.1 Action c requires a similar demonstration within 8 hours. (Note: The time to perform the EDG test in CTS 3.8.1.1 Action c has been changed to 24 hours as described in DOC L05.) 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 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. The purpose of the CTS 4.8.1.1.2.a.4 requirement in CTS 3.8.1.1 Actions b and c 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 capacity and capability of remaining systems or features, and 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. This is acceptable because it avoids unnecessary testing of the EDG while at the same time ensures the EDG is OPERABLE. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.8.1.1.2.d.2 requires verification of EDG performance following a "simulated safety features actuation system (SFAS) test signal." ITS SR 3.8.1.15 specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either and actual or simulated signal for the test. Davis-Besse Page 10 of 16 Attachment 1, Volume 13, Rev. 0, Page 24 of 323

Attachment 1, Volume 13, Rev. 0, Page 25 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of CTS 4.8.1.1.2.d.2 is to ensure that the AC Sources operate 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, 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. The change also allows a simulated signal to be used if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. L04 (Category3 - Relaxation of Completion Time) CTS 3.0.5 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 3.0.5 requires a unit shutdown to start within two hours with these requirements not met. CTS 3.0.5 also provides an explicit time period to be in HOT STANDBY (MODE 3), HOT SHUTDOWN (MODE 4), and COLD SHUTDOWN (MODE 5). ITS 3.8.1 ACTION A (one required offsite source inoperable) requires the declaration of required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action A.2 is 24 hours from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION B (one required EDG inoperable) requires the declaration of required feature(s) supported by the inoperable EDG inoperable when its required redundant feature(s) is inoperable. The Completion Time allowed by the Required Action B.2 is 4 hours from discovery of Condition B concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION C (two required offsite circuits inoperable) requires the declaration of required feature(s) inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action C.1 is 12 hours from discovery of Condition C concurrent with inoperability of redundant required features. This changes the CTS by allowing more time to restore inoperable equipment and replaces the explicit times to be in MODE 3, MODE 4, and MODE 5 with a requirement to declare the affected features inoperable (and thus to take the ACTIONS required by the individual system LCO, including possible shutdown of the unit). 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 and deletes the explicit times to be in MODE 3, MODE 4, and MODE 5. By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specifications ACTIONS of the affected supported equipment, unit Davis-Besse Page 11 of 16 Attachment 1, Volume 13, Rev. 0, Page 25 of 323

Attachment 1, Volume 13, Rev. 0, Page 26 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING operation is 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 3.0.5 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 hour 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 shutdown; and d) the low probability of a DBA occurring during this period. The 12 hour Completion Time when two required offsite circuits are inoperable is acceptable because Regulatory Guide 1.93 allows a Completion Time of 24 hours for two required offsite circuits inoperable. When a concurrent redundant required function is inoperable, a shorter Completion Time of 12 hours is appropriate. The 4 hour 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 hour 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. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status and the change deletes the explicit times to reach MODE 3, MODE 4, and MODE 5. L05 (Category3 - Relaxation of Completion Time) CTS 3.8.1.1 Action c specifies the compensatory actions for one inoperable offsite circuit and one inoperable DG. The Actions include a requirement to demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours. ITS 3.8.1 Required Action B.3.2 allows 24 hours to perform a similar check on the remaining OPERABLE EDG. This changes the CTS by extending the time to perform this check from 8 hours to 24 hours. The purpose of the CTS Action c requirement to perform CTS 4.8.1.1.2.a.4 is to ensure that the other EDG is not inoperable as a result of a similar, yet undetected, failure (i.e., due to a common mode failure). This change is acceptable because the proposed 24 hour time limit to perform CTS 4.8.1.1.2.a.4 when equipment is inoperable has already been approved by the NRC. CTS 3.8.1.1 Action b includes a similar requirement to perform CTS 4.8.1.1.2.a.4 when only an EDG is inoperable, but allows 24 hours to perform the verification. When both an offsite circuit and an EDG are inoperable, the AC Sources are in a more degraded state. The focus of the operations personnel should be in restoring the inoperable AC Sources, not in attempting to perform a routine Surveillance is a shorter amount of time. The proposed 24 hour time limit is considered a reasonable time to complete the DG start tests on two DGs. Generic Letter 84-15 identified that a 24 hour time limit was acceptable to perform these common mode failure checks. In addition, the change is considered acceptable since the vast majority of DG start tests demonstrate that Davis-Besse Page 12 of 16 Attachment 1, Volume 13, Rev. 0, Page 26 of 323

Attachment 1, Volume 13, Rev. 0, Page 27 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING the DG is in fact OPERABLE. This change is designated as less restrictive because more time will be allowed to complete a Required Action in the ITS than is allowed in the CTS. L06 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS Table 4.3-2 Functional Unit 4.a requires a CHANNEL FUNCTIONAL TEST of the Sequencer every month. ITS 3.8.1 does not include this CHANNEL FUNCTIONAL TEST; instead ITS SR 3.8.1.6 requires verification that the interval between each sequenced load block is within 10% of design interval for each load sequencer. This changes the CTS by not requiring a CHANNEL FUNCTIONAL TEST. The purpose of the CTS monthly CHANNEL FUNCTIONAL TEST is to verify that the sequencer is operating correctly. ITS SR 3.8.1.6 will verify that the sequencer is operating correctly by verifying that sufficient time exists for the EDG to restore frequency and voltage prior to applying the next load and that the safety analysis assumptions regarding ESF equipment time delays are not violated. This change is acceptable because ITS SR 3.8.1.6 performs a similar function to the CTS monthly CHANNEL FUNCTIONAL TEST. This change is designated as less restrictive because the requirement to perform a CHANNEL FUNCTIONAL TEST has been deleted. L07 (Category 5 - Deletion of Surveillance Requirement) CTS 4.3-2 Functional Unit 4 requires a CHANNEL CHECK of the sequencer. ITS 3.8.1 does not require a CHANNEL CHECK. This changes the CTS by not requiring a CHANNEL CHECK of the sequencer. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analysis. The purpose of performing a CHANNEL CHECK, as described in ITS Section 1.0, is to qualitatively assess, by observation, channel behavior during operation. It should include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameters. The load sequencers provide signals to individual loads in order to start the loads under accident (SFAS coincident with loss of offsite power) conditions. However, the sequencers do not provide any "indication" to the operators that can be used to determine channel behavior. The indication provided is a status light, which indicates that the sequencer has not received any signals from the SFAS logic or the loss of voltage logic. Thus, the CHANNEL CHECK requirement provides no qualitative information that the sequencers will work properly. Since the operators routinely monitor the status of SFAS or loss of voltage signals, and alarms would be received in the control room if these conditions existed, there is no need to specify a CHANNEL CHECK for these instruments. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analysis. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. Each load sequencer will continue to be tested by ITS SR 3.8.1.6 (the load sequencer functional test) to ensure the safety analyses Davis-Besse Page 13 of 16 Attachment 1, Volume 13, Rev. 0, Page 27 of 323

Attachment 1, Volume 13, Rev. 0, Page 28 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING assumptions will be met. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS. L08 (Category 10 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.1.1.1 .b and CTS 4.8.1.1.2.d contains a requirement to perform various tests "during shutdown." These tests have been incorporated in ITS SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.15. ITS SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.12, and SR 3.8.1.13 include a Note which states that the Surveillance (for SR 3.8.1.9, part b of the Surveillance only) shall not normally be performed in MODE 1 or 2. ITS SR 3.8.1.15 includes a Note which states that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. The Notes also state that the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. The Notes further state that credit may be taken for unplanned events that satisfy the SR. This changes the CTS by allowing the Surveillance to be performed in the operating MODES as long as the associated assessment is performed or provided that it is an unplanned event that satisfies the requirements of the SR. The purpose of CTS 4.8.1.1.1 .b and 4.8.1.1.2.d is to confirm the OPERABILITY of the offsite circuits and EDGs. This change is acceptable because the proposed Surveillance Frequency provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions at all times. It allows the unit to perform the Surveillances to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced and it allows the unit to credit an unplanned event for satisfying the Surveillances, provided the necessary data is obtained. Furthermore, the proposed Surveillance Note still restricts planned performance of the Surveillance to MODES other than MODES 1, 2, 3, and 4. 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 Surveillances may be performed at plant conditions other than shutdown. L09 (Category4 - Relaxation of RequiredAction) CTS Table 3.3-3 Action 15a requires, with the number of OPERABLE sequencers one less than the minimum number of sequencers OPERABLE per bus, that the inoperable sequencer module be removed within 1 hour. If this action is not accomplished, the shutdown requirements of CTS 3.0.3 would apply. ITS 3.8.1 ACTION G also requires the inoperable sequencer to be removed within 1 hour when one of the two sequencers per bus is inoperable. However, ITS 3.8.1 ACTION H allows the associated EDG to be declared inoperable immediately when the Required Action and associated Completion Time of Condition G are not met. This changes the CTS by allowing the associated EDG to be immediately declared inoperable instead of entering CTS 3.0.3 and shutting down the unit. The purpose of CTS Table 3.3-3 Action 15a is to provide appropriate actions when one of the two sequencers is inoperable. Required Actions are used to Davis-Besse Page 14 of 16 Attachment 1, Volume 13, Rev. 0, Page 28 of 323

Attachment 1, Volume 13, Rev. 0, Page 29 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING 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. This change is acceptable because 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. These sequencers ensure proper loading of the EDGs under an accident (SFAS) conditions (i.e., it supports EDG OPERABILITY) and the appropriate action for this condition is to declare the EDG inoperable. The current requirements are overly restrictive. For example, if an EDG were inoperable for other reasons, then a 7 day allowed outage time is provided. However, if one sequencer is inoperable and untripped, but the EDG is otherwise fully OPERABLE, then an immediate shutdown is required. Furthermore, CTS Table 3.3-3 Action 15b requires the EDG to be declared inoperable when both sequencers on one bus are inoperable. Thus, the allowance to declare the EDG inoperable due to load sequencer inoperability has already been approved by the NRC. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L10 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a.3 and CTS 4.8.1.1.2.c.3 require that the fuel transfer pump can be started and that it transfers fuel from the storage system to the day tank. The test Frequency for these Surveillances 31 days and 184 days, respectively. However, as discussed in DOC A05, since the Frequency for CTS 4.8.1.1.2.a.3 is 31 days, the 184 day Frequency for CTS 4.8.1.1.2.c.3 is limited to 31 days. ITS SR 3.8.1.7 requires the verification that the fuel oil transfer system operates to transfer fuel oil from the fuel oil storage tank to the day tank every 92 days. This changes the CTS by changing the test Frequency from 31 days to 92 days. The purpose of CTS 4.8.1.1.2.a.3 and CTS 4.8.1.1.2.c.3 is to ensure the fuel oil transfer system can function properly. The ISTS allows a nominal 92 day Frequency for this test (ISTS SR 3.8.1.6), and states that in the ISTS Bases that this is consistent with the ASME OM Code. However, the ISTS Bases also provides words for why a 31 day Frequency is appropriate under certain conditions. The ISTS Bases state that: "if the design of fuel transfer systems is such that pumps will operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs." Thus, the ISTS Bases is stating that a 92 day Frequency is allowed if the fuel oil pumps do not normally need to run to refill the day tank after every EDG monthly test. The Davis-Besse EDG day tank capacity is approximately 5400 gallons, and the transfer pump automatically shuts off at a day tank level of approximately 5250 gallons. The minimum day tank fuel oil volume required by CTS and ITS is 4000 gallons (ITS SR 3.8.1.4). Thus, the difference between the level when the fuel oil transfer pumps automatically stops on high level and the minimum level required by the ITS is in excess of Davis-Besse Page 15 of 16 Attachment 1, Volume 13, Rev. 0, Page 29 of 323

Attachment 1, Volume 13, Rev. 0, Page 30 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING 1000 gallons. The EDG burns approximately 200 gallons/hr of fuel oil at full load, and ITS SR 3.8.1.3 requires a 1 hour run at full load every month. Thus, the fuel oil transfer pumps are not required to automatically start to maintain fuel oil level in the day tank above the minimum required ITS value of 4000 gallons after every EDG monthly run test. A detailed review of the test history for the fuel oil transfer pumps since 2004 indicates no failures that were considered Maintenance Rule Functional Failures for the EDG System. In addition, the proposed 92 day fuel oil transfer pump test Frequency is consistent with the requirements of ASME Operation and Maintenance Standards and Guides (OM Codes) for similar pumps. Therefore, this change in the test Frequency is acceptable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. L11 (Category6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.8.1.1.2.c.4, the quickstart test, requires that each EDG starts from ambient conditions and accelerates.to at least 900 rpm in less than or equal to 10 seconds. ITS SR 3.8.1.8, in part, requires each EDG start from standby conditions and achieves voltage > 4031 V and frequency > 58.8 Hz in

      < 10 seconds. This changes the CTS by decreasing the speed (i.e., frequency) requirement from 900 rpm (60 Hz) to 58.8 Hz.

The purpose of the CTS 4.8.1.1.2.c.4 is to ensure that each EDG can properly startup so that they can supply the emergency loads. This change is acceptable because the relaxed Surveillance Requirement acceptance criterion is not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change decreases the minimum frequency requirement for the EDG during a quickstart test. This change is acceptable because the value is consistent with the minimum steady state frequency proposed in other Surveillances (e.g., ITS SR 3.8.1.2) and continues to ensure that the EDG can be started to sufficient speed to accept required emergency loads. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. Davis-Besse Page 16 of 16 Attachment 1, Volume 13, Rev. 0, Page 30 of 323

Attachment 1, Volume 13, Rev. 0, Page 31 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 31 of 323

Attachment 1, Volume 13, Rev. 0, Page 32 of 323 CTS AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE: LCO 3.8.1.1.a a. Two qualified circuits between the-offsite transmission network and the onsite Class 1E AC Electrical Power Distribution SystemI-' 0 LCO 3.8.1.1.b eeren b. Twodiesel generators (ýDGs) each capable of supplying one train of 0 the onsite Class 1E AC Electrical Power Distribution SNste c.Au aioad sequencers for Train a ndT rain and

                                                                                                                 -- [I 0

3.3.2.1 Table 3.3-3 0 two load sequencers for APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS E DOC A02 LCO 3.0.4.b is not applicable to Gs. 0 CONDITION REQUIRED ACTION COMPLETION TIME Action a, LCO 3.0.5 A. One [reqjred] offsite circuit inopera le. A.1 Perform SR 3.8.1.1 for OPERABLE [reqied] 1 hour 0 offsite circuit. AND Once per 8 hours thereafter AND A.2 Declare required feature(s) 24 hours from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s) AND BWOG STS 3.8.1-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 32 of 323

Attachment 1, Volume 13, Rev. 0, Page 33 of 323 CTS AC Sources - Operating 3;8.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Action a, LCO 3.0.5 A.3 'Restore [req ed] offsite circuit to OPERABLE 72 hours 0 status. Action b, LCO 3.0.5 B. One [req 'red] G inoperable.I B.1 Perform SR 3.8.1.1 for OPERABLE [req ed] 1 hour

                                                                                                   }00 offsite circuit(s).          AND Once per 8 hours thereafter AND B.2       Declare required feature(s) 4 hours from supported by the inoperable  discovery of

[E , DG inoperable when its Condition B redundant required concurrent with 0 feature(s) is inoperable. inoperability of redundant required feature(s) 0 AND [E B.3.1 Determine OPERABLE

DG. is not inoperable due M24M hours 03 to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for M24M hours OPERABLEtDGM. AND B.4 Restore OPERABLE status. ed DG to 72 urs 000 BWOG STS 3.8.1-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 33 of 323

Attachment 1, Volume 13, Rev. 0, Page 34 of 323 CTS AC Sources - Operating 3.8.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Action d, LCO 3.0.5 C. Two [req ed] offsite circuits inoperable, C.1 Declare required feature(s) inoperable when its 12 hours from discovery of 0 redundant required Condition C feature(s) is inoperable, concurrent with inoperability of redundant required feature(s) AND C.2 Restore one req ed] offsite circuit to OPERABLE 24 hours 0 status. Action c, LCO 3.0.5 D. One req edoffsite circuit inoperable.

                                         ------------- NOTE          ----------

Enter applicable Conditions and 0 Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating," when Condition D is entered with no One ino p e ra b le . edDG I[req AC power source to any train. 00 L--- D. 1 Restore req e offsite 12 hours 0 circuit to OPERABLE status. OR D.2 Restore [req* e]G to 12 hours 00 OPERABLE status. Action e E. Two req edDGs E.1 Restore one req e DG 2 hours 00 inoperable. L.

to OPERABLE status.L E BWOG STS 3.8.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 34 of 323

Attachment 1, Volume 13, Rev. 0, Page 35 of 323 CTS AC Sources - Operating 3.8.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME

                   -----REVIitWER'S NOTE----.

[This C ndition may be. F .1 Restorq [required] / [automptic load seq encer] 00 delete if the unit design ' to OPqRABLE stat s. [ hour:7 such Oat any sequencer failur mode will only a ct the/bility of the assoc ted Remove inoperable load sequencer. D to power its resp ive s fety loads followin a loss f offsite power ind pendeni of, or coincident h, a Design Basis Ev nt. 4. ~T1 0

                       ;*nen *req ied]I     One or more trains with Table 3.3-3 Action 15a auo aicload sequenceQ inoperable.

Required Action and Associated Completion _*lBe in MODE 3. q hours 00 Time of Condition A, B, AND Actiona a, b, c, d,and e C, DtE-M not met. T Be in MODE 5. 36 hours 00 DOC A04 DMThree or more [reufd)) AC sources inoperable. Enter LCO 3.0.3. Immediately 00 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.1.a SR 3.8.1 .1 Verify correct breaker alignment and indicated 7 days power availability for each req e offsite circuit. 0 BWOG STS 3.8.i-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 35 of 323

Attachment 1, Volume 13, Rev. 0, Page 36 of 323 3.8.1 0 INSERT 1

                   ----------NOTE ----------

Separate Condition entry is allowed for each train. 0 INSERT 2 DOC L09, H. - --------- NOTE ---------- H.1 Declare associated Immediately Table 3.3-3 Action 15b Separate Condition EDG inoperable. entry is allowed for each train. Required Action and associated Completion Time of Condition G not met. OR One or more trains with two sequencers inoperable. Insert Page 3.8.1-4 Attachment 1, Volume 13, Rev. 0, Page 36 of 323

Attachment 1, Volume 13, Rev. 0, Page 37 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY i 4.8.1.1.2.a.4 SR 3.8.1.2 --------------- NOTES ----------------

1. AIItDG starts may be preceded by an engine prelube period and followed by a warmup 0 period prior to loading.

00 1]2. A modified'DG start involving idling angradual acceleration to synchronous speed may be 0D used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1 Tmust be met. M S Verify each G starts from standby conditions and 31 days achieves steady state voltage > N374M*V and - 440 [- V, and frequency >!ppj -Hzand 3 --------------------- NOTES --------------- S4.8.1.1.2.a.5 SR 3.8.1.: 1. DG loadings may include gradual loading as [E "recommended by the manufacturer. 0

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

3. This Surveillance shall be conducted on only oneG at a time. 0

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1_ 0 Verify eachDG is synchronized and loaded and 31 days 0

operates for Ž>60 minutes at a load _>[45-0 kWand (( kWý. g234 LCO3.8.1.1.b.1, SR 3.8.1.. 4 Verify each day tank 1[and engine jcited tank]l 31 days 4.8.1.1.2.a.1 contains >: " gal of fuel oil. BWOG STS 3.8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 37 of 323

Attachment 1, Volume 13, Rev. 0, Page 38 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY DOC M04 SR 3.8.1.5 Check for'and remove accumulated water from each 13I1jdays day tank 1[and engineq nted tank] 4.8.1.1.2.a.3 SR 3.8.1.T Verify the fuel oil transfer system operates to f ý92Edays 10 Move SR 3.8.1.6 J[autorifcally, transfer fuel oil fro storage tankEf to here from pagel to the day tank 1[and engine nted tank][ 3.8.1-14 00 4.8.1.1.2.c.4 SR 3.8.1.1j NOTE ------ ---------------- All----G starts may be preceded by an engine prelube period. Verify eac DG starts from standby condition and 184 days achieves: 4~031, 0

a. ln*<[lcfseconds, voltage _>3 ---Vand frequency > J58.8] Hz and t=_0 'E 4400

b. Steady state voltage >13740 Vand and frequýncy - Hz and _<_

40V,

SR 3.8.1. "-"'* ---------------------- NOTEETi-- - -- 1002 4.8.1.1.1.b

                                  //'--**]((Is             Iu ellance   s~hall -notnormally be performed 20 INSERT 3
                                      ,2.1i-n MODE 1 or 2 However, Mhis SuPifllancel ýmay be it
                                                                                                           --m 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 Mautomatic land[j manuaIl]transfer of AC power mo nhs sources Tro e normal offsite circuit to ] alternate req edoffsite circuit. BWOG STS 3.8.1-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 38 of 323

Attachment 1, Volume 13, Rev. 0, Page 39 of 323 3.8.1 (O INSERT 3

1. SR 3.8.1.9.a is only required to be met when the unit auxiliary source is supplying the electrical power distribution subsystem.

0 INSERT 4 a) The unit auxiliary source to the pre-selected offsite circuit; and b) Insert Page 3.8.1-6 Attachment 1, Volume 13, Rev. 0, Page 39 of 323

Attachment 1, Volume 13, Rev. 0, Page 40 of 323 CTS AC Sources - Operating 3;8.1 SURVEILLANCE !REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1 4.8.1.1.2.d.1 -NOTES 1.. This Surveillance shall not normally be 0 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. L 2. If performed with the4 DG synchronized with offsite power, it shall be performedi w e-w, 0 E factor . However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as -0 practicable. j Verify each DG rejects a load greater than or equal to its associated single largest post-accident load, emonths 00 an

                                     ]g       load rejection, the frequency is

b. Within [3] seconds following ad rejection, the 03 voltage is > [3740] V and 4580] V, and

c. Within [3] seconds fowing load rejection, the frequency is > [5 .1] Hz and < [61.2] Hz.

BWOG STS 3.8.1-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 40 of 323

Attachment 1, Volume 13, Rev. 0, Page 41 of 323 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY

.SR 3.8.1.10     --------

S3..10 -------- NOTES-------- ----- [1. Thi Surveillance shall not normally be pe ormed in MODE 1 or 2. However, this S rveillance may be performed to reestablis ERABILITY provided an assessment termines the safety of the plant is maintai ed r enhanced. Credit may be taken for nplanned events that satisfy this SR.

2. If performed with the DG synchronized wi offsite power, it shall be performed at a p wer factor < [0.9]. However, if grid condition do not 0

permit, the power factor limit is not requi ed to be met. Under this condition the power actor shall be maintained as close to the limi as practicable. ] [18] months maintained _ [5000] V during and followi a load rejection of _>[4500] kW and _<[5000] kW/ i BWOG STS 3.8.1-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 41 of 323

Attachment 1, Volume 13, Rev. 0, Page 42 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY i DOC M04 SR 3.8.1.11 []E....................---- NOTES--

1. Al DG starts may be preceded by an engine prelube period. 0

2. This Surveillance shall not normally be performed in MODE 1,2, 3, or 4. 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 on an actual or simulated loss of offsite power signal: 0 mns

a. De-energization of buses]__,

0 b. l. Load shedding from emer nybuses vand DG auto-starts from standby condition and: 0 0o

1. Energizes permanently connected loads in <* 111 secondI

2. Energizes auto-connected shutdown load4' E __ 6 through l[automatic Io5sequenceqr (individual time delay relays] *'

3. Maintains steady-state voltage _>3741V F4400V 0(

4. 5. Maintains steady-state frequency

8] Hzand

                                                           -.                Hz dand Supplies permanently connected and auto-connected shutdown loads for I   j
                                                     > 5 minutes.

BWOG STS 3.8.1-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 42 of 323

Attachment 1, Volume 13, Rev. 0, Page 43 of 323 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.12 SR--.8----------------- NOTES --------------

1. All DG tarts may be preceded by an engine prelub period.

2. This S rveillance shall not normally be perfor ed in MODE 1 or 2. However, portions of the urveillance may be performed to reesta lish OPERABILITY provided an asses ment determines the safety of the plant is mai tained or enhanced. Credit may be taken or unplanned events that satisfy this S Verify on n actual or simulated [Engineered Safet ((18] months ]

Feature ( SF)] actuation signal each DG auto-sta s from stan by condition and:

a. In < [ 2] seconds after auto-start and during tests achieves voltage > [3740] V and frequ ncy > [58.8] Hz,

b. Achi ves steady state voltage _>[3740] V and [4580] V and frequency > [58.8] Hz and

                     < [61.2] Hz,

c. Ope ates for > 5 minutes,

d. Per anently connected loads remain energi ed fro the offsite power system, and

e. Em rgency loads are energized [or auto-con ected through the automatic load seq encer] from the offsite power system.

BWG STS 3.8.1-10 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 43 of 323

Attachment 1, Volume 13, Rev. 0, Page 44 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3. NOTE ---------- -------- 4.8.1.1.2.d.2.c MThis Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be 0 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 0 Verify each G's noncritical automatic trips are bypassed on dual or simulated loss of voltage 0 sgtnal orn tsh imuate bauaS Ico nciugnai ths actual or simulated F51 actuation signall

                                                        '7-Safety Features Actuation System (SFAS)

BWtOG STS 3.8.1-11 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 44 of 323

Attachment 1, Volume 13, Rev. 0, Page 45 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4.8.1.1.2.d.3 SR 3~ 1 i ------------- -NOTES ---------------

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 s]1 unplanned events that satisfy this SR.

parts erformed with FD'D]synchronized with offsite hitHE] power, it shall be performeda-power factor

                                        . However, if grid conditions do not permit, the power factor limit is not required to 08 be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each G operates for >2hours: 00

a. For >!2[hours loaded >P,]kWand (De months

b. For the remaining hours of the test loaded

                                       Ž      k d an    PZ1kW.

BWOG STS 3.8.1-12 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 45 of 323

Attachment 1, Volume 13, Rev. 0, Page 46 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY DOC M04 SR 3.8.1. ------------------------------- NOTES ---------------

1. This Surveillance shall be performed within 0 5 minutes of shutting down the4fG after the4DG has operated > houri loaded > kW mn 0 3

and < F*--.C _ Momentary transients outside of load range do not invalidate this test. E

2. All'OG starts may be preceded by an engine prelube period. 0 E]

Verify each DG starts and achieves: 17months a. b. In_<VCR1seconds, voltage > frequency _>158.8 Hz and V and Steady state voltage >_ 374] V and < [4- 0]V, 01 and fre . ency ýM[5.8 t-I :ý dHz. [60-5 < SR 3.8.1.16 SR--3-8---------------------NOTE --------------- This Survei lance shall not normally be performed i MODE 1, 2 3, or 4. However, this Surveillance ma be perform d to reestablish OPERABILITY provide an assess nt determines the safety of the plant i maintaine or enhanced. Credit may be taken for unplanned events that satisfy this SR. Verify ea DG: [18] months -7

a. Sync ronizes with offsite power source while load d with emergency loads upon a simulat d restoration of offsite power,

b. Tra fers loads to offsite power source, and

c. Ret ms to ready-to-load operation.

I -~_________________ BVOG STS 3.8.1-13 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 46 of 323

Attachment 1, Volume 13, Rev. 0, Page 47 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.17 NOTE -- --------------- [ This Surv illance shall not normally be performed in MODE 1, 2, or 3. However, portions of the Surveillan e may be performed to reestablish OPERABI ITY provided an assessment determine. the safety f the plant is maintained or enhanced. Credit ma be taken for unplanned events that satisfy thi SR.

                                                                                                                              -18 Verify, wi h a DG operating in test mode and                      [18] months ]

connecte to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

a. Ret ming DG to ready-to-load operation and

[b. Aut matically energizing the emergency Ioa fro offsite power. ] 04.8.1.1.2.a.7 SR 3.8.1. -NOTE --------------- [ This Surveilla ce shall not normall be performed 0 in MODE 1 2,3, or 4. However, ths Surveillance may be perfor 'ed to reestablish 0 ERABILITY 0 provided an sessment determin s the safety of the plant is aintained or enhanc d. Credit may be Move to after SR 3.8.1.5 on - taken for un lanned events that tisfy this SR.] 0 Page 3.8.1-6 Verify interval between each sequenced load block is within +/-+ 0% of design intervalJfor each j[1 8] 9)6'nths 0 emergency 11and showload sequencer. Lt=] I Iand each emergency time delay relay . BWOG STS 3.8.1-14 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 47 of 323

Attachment 1, Volume 13, Rev. 0, Page 48 of 323 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4.8.1.1.d.2.a, SR 3.8.1.[M -NOTES-- 4.8.1 .1.d.2.b

1. All4G starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE 1,2, 3, or 4. 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 on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated 0

                      ý              actuation signal:                                  T    months                   0

a. De-energization of =mer nc b Ses sn (00

b. Load shedding from mer nc buses_

C. DG auto-starts from standby condition and:

1. Energizes permanently connected loads 0

in <l1C secondsl ©D

2. Energizes auto-connected emergency and individual time loads through Mload sequence delay relays FT

3. Achieves steady-state voltage > M374-V and <0

4. Achieves steady-state frequency 03

                                                 ý![ zad:5 M.        .2Hz and

5. Supplies permanently connected and auto-connected emergency loads for

                                          > PM minutes.                                                             J BWOG STS                                  3.8.1-15                          Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 48 of 323

Attachment 1, Volume 13, Rev. 0, Page 49 of 323 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.20 ------------------- NOTE -------- All DG sta s may be preceded by an engine prelub period.

                                                                                            -1 Verify, w   en started simultaneously from standby    10 years condition   each DG achieves, in < [10] seconds, voltage    [3740] V and < [4580] V, and frequency

[58.8] z*and < [61.2] Hz. BWOG STS 3.8.1-16 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 49 of 323

Attachment 1, Volume 13, Rev. 0, Page 50 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

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

4. ISTS 3.8.1 Required Action B.4 Completion Time has been changed to reflect the current Davis Besse licensing bases duration for returning the EDG to OPERABLE status when one EDG is inoperable. The 7 day Completion Time was approved by the NRC as documented in the Safety Evaluation for Amendment 206, dated February 26, 1996.

5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

6. Typographical error.

7. ISTS 3.8.1 ACTION F (ITS 3.8.1 ACTION G) has been modified consistent with the Davis Besse current licensing basis. The Davis-Besse design includes two load sequencers per train. CTS Table 3.3-3 Action 15a provides the Actions for when one load sequencer per bus is inoperable and requires the sequencer be removed within 1 hour. This Action is taken on a per bus basis. CTS Table 3.3-3 Action 15b provides the Actions when both load sequencers for a bus are inoperable and requires immediately declaring the associated EDG inoperable. This Action is reflected in proposed ITS 3.8.1 ACTION H and is also taken on a per bus basis.

These Actions were approved by the NRC as documented in the Safety Evaluation for Amendment 211, dated April 23, 1996. Due to this change, ISTS 3.8.1 ACTION G, which provides the default actions for ITS 3.8.1 ACTIONS A, B, C, D, and E, but not the two load sequencer ACTIONS, has been changed to ITS 3.8.1 ACTION F to follow the ACTIONS to which it applies.

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. Davis-Besse has not committed to fully implement this Regulatory Guide, but has used its guidance where appropriate consistent with the Davis-Besse design and licensing basis, and the recommendations of the EDG manufacturer for testing of the Davis-Besse EDGs.

ISTS SR 3.8.1.10 has not been included in the Davis-Besse 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 Davis-Besse 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 be required to re-establish these loads, regardless of whether or not the EDG overspeeds. Since the accident analysis Davis Besse Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 50 of 323

Attachment 1, Volume 13, Rev. 0, Page 51 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING assumes no operator actions associated with ECCS 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 3.8.1.18 Note has been deleted. The frequency of the ISTS 3.8.1.18 has been changed from 18 months to 31 days. Therefore, the Note does not apply.

10. ISTS SR 3.8.1.18 Frequency has been changed to 31 days to match the current Davis Besse licensing basis. Additionally, the Surveillance has been renumbered to ITS SR 3.8.1.6 to reflect the proper place where the 31 day Surveillance Frequency should be. Also, subsequent SRs have been renumbered, as necessary, to reflect the numbering change.

11. Editorial error corrected.

12. Typographical error corrected. The standard time to reach MODE 3 is 6 hours, not 12 hours.

13. 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 not presented as specific TS requirements in ITS SR 3.8.1.10. 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, the Davis-Besse EDGs were designed to meet Safety Guide 9, dated March 10, 1971. This NRC Safety Guide did not include these criteria. 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 and the Monticello Nuclear Generating Plant.

14. ISTS SR 3.8.1.9 (ITS SR 3.8.1.10) requires the load rejection of the single largest post-accident load for each EDG while ISTS SR 3.8.1.14 (ITS SR 3.8.1.13) requires an endurance and load test for each EDG. The endurance and load test is performed at two different load ranges; part a is performed between 105% and 110% of the continuous rating and part b is performed between 90% and 100% of the continuous rating. Note 2 of ISTS SR 3.8.1.9 and Note 3 ISTS SR 3.8.1.14 require the testing to be performed at a specific power factor value. Note 2 to ISTS SR 3.8.1.9 (Note 2 to ITS SR 3.8.1.10) has been modified to only require testing "within the power factor limit" and Note 3 to ISTS SR 3.8.1.14 (ITS SR 3.8.1.13) has been modified to only require testing "within the power factor limit" during the load ranges required in part b of the SR (i.e., 90% to 100% of the continuous rating).

Currently, neither ISTS SR 3.8.1.9 nor ISTS SR 3.8.1.14 are required in the CTS, and there are no power factor limit requirements in the CTS. The ITS will include the requirement to test at a power factor limit (Note 2 to SR 3.8.1.10 and Note 3 to SR 3.8.1.13), but it will not specify a specific power factor value (e.g., 0.9) in the Notes to the Surveillances. The specific power factor value is included in the ITS Bases for the two Surveillances and will therefore be controlled under ITS 5.5.13, the Technical Specifications Bases Control Program. This program provides for the evaluation of changes to ensure the Bases are properly controlled. Several plants that have converted to the ITS did not include a specific power factor value in the ITS. This type of change was previously approved in the ITS conversion for Davis Besse Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 51 of 323

Attachment 1, Volume 13, Rev. 0, Page 52 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING Monticello Nuclear Generating Plant, James A. FitzPatrick Nuclear Power Plant, Quad Cities Unit 1 and 2, Dresden Units 1 and 2, and LaSalle Units 1 and 2. In addition, testing at a power factor limit has not been included for part a of ITS SR 3.8.1.10. During EDG testing at a load equivalent to 105% to 110% of the EDG continuous rating the power factor limit does not have to be met since this part of the test is testing the EDGs at a load in excess of that assumed in the accident analysis.

15. ISTS SR 3.8.1.12 requires verification of proper performance of the offsite circuits and the EDGs on an actual or simulated engineered safety feature (ESF) actuation signal. This Surveillance has not been adopted in the Davis-Besse ITS. ISTS SR 3.8.1.19, the SFAS/loss of offsite power Surveillance (ITS SR 3.8.1.15), verifies each aspect of the requirements specified in ISTS SR 3.8.1.12 at a 24 month Frequency. Thus, there is no need to periodically perform this SR to demonstrate the proper operation of the offsite circuits and EDGs on a Safety Features Actuation System (SFAS) actuation signal. When only an SFAS actuation signal is present, the Emergency Core Cooling Systems (ECCS) loads start immediately and the essential buses are not de-energized. These ECCS pump starts are adequately tested in the various Surveillances for the individual pumps and the SFAS logic is adequately tested as part of the SFAS instrumentation Specifications. 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 3.8.1.14 requires each EDG to operate for Ž 24 hours. ITS SR 3.8.1.13 requires each EDG to operate for _Ž8 hours. The 8 hour 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 hours, of which 2 hours should be at a load equivalent to the short time rating of the diesel generator and 6 hours at a load equivalent to the 90%-100% of the continuous rating.

17. ISTS SR 3.8.1.16 requires each EDG to be synchronized with offsite power while loaded with the emergency loads upon a simulated restoration of offsite power and to transfer the loads to the offsite power source. The Davis-Besse design of the EDGs is such that when an emergency start signal is received by the EDGs, the EDG governor cannot be shifted back to the droop mode until the EDG is secured.

Thus, this Surveillance would require Davis-Besse to synchronize the EDG to the offsite source with no droop set into the EDG governor. Any perturbation in voltage or frequency during this time could result in an overpower or reverse power event of the EDG, and could potentially damage the EDG. Therefore, this Surveillance is not being adopted by Davis-Besse, consistent with current licensing basis.

18. ISTS SR 3.8.1.17 is not included in the Davis-Besse ITS since this feature was not included in the Davis-Besse design. This SR demonstrates that with an EDG operating in the test mode and connected to its bus, an ESF actuation signal overrides the test mode and returns the EDG to ready-to-load operation. At Davis-Besse, with an EDG connected to its bus, if an SFAS actuation signal were Davis Besse Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 52 of 323

Attachment 1, Volume 13, Rev. 0, Page 53 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING received, the EDG would stay connected to its bus. Furthermore, the EDGs do not perform any safety-related function for a LOCA-only event since the offsite circuits remain available. Therefore, this SR is not applicable.

19. ISTS SR 3.8.1.20 is not included in the Davis-Besse 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. This is also consistent with the current licensing basis.

20. ISTS SR 3.8.1.8 (ITS SR 3.8.1.9) has been revised to include two parts consisting of: a) an automatic and manual transfer from the unit auxiliary source (i.e., main generator) to the pre-selected offsite circuit; and b) an automatic and manual transfer from the normal offsite circuit to the alternate offsite circuit. These changes were made consistent with the manner in which the CTS Surveillance is performed.

However, a Note has also been added to ISTS SR 3.8.1.8 (ITS SR 3.8.1.9) that states SR 3.8.1.9.a is only required to be met when the unit auxiliary source is supplying the electrical power distribution subsystem. This change is necessary since the automatic and manual transfer from the unit auxiliary source to the pre-selected offsite circuit is not necessary when the offsite circuit is supplying onsite power. In this situation, the offsite circuit is performing its function by supplying the onsite power. Also, due to the Note addition, the remaining Note has been renumbered. Furthermore, since the unit auxiliary source is normally placed in service when in MODE 1, the Note restriction has only been applied to the transfer from the normal offsite circuit to the alternate offsite circuit. Davis Besse Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 53 of 323

Attachment 1, Volume 13, Rev. 0, Page 54 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 54 of 323

Attachment 1, Volume 13, Rev. 0, Page 55 of 323 I All changes are AC Sources - Operating u unless otherwise noted B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1 E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and Fi~ency alternately and the onsite standby power sources rain and Triin B diesel generators PflGs)). As required by 10 CFR 50, Appendix A, Q GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to 0 the Engineered Safety Feature_(ESF) Pystems. The onsite Class 1E AC Distribution System is divided into redundant load groups .(trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has E connections to two preferred offsite power sources and a singleDG.F Offsite power is supplied to the unit switchyardf)l from the transmission network by o]r smission lines. From the swi c yard(s), two INSERT 1

                             ,electrically and ph /sically separated circuits provi le AC power, throug~h

[step down statio anuxilir rnsfrestote,1 kV ESF buses. A detailed description of the offsite power network and the circuits to the Class 1 E F buses is found in the *SAR, Chaptr [8] (Ref. 2). An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from essential ( the offsite transmission network to the onsite Class 1E[Eus(es). When a. Salety

          ... F-eatures~         ~-,

Crti.equired .. uni* !-a's are returned to service in predetermined Actuation System (SFAS) sequence in order t/ prevent overloading the transf me r supplying offslite [ actuation ) power to the onsit 'Class 1 E Distribution System. Wirthin [11minute] after lthe initiating Isignal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are Fretur[:Td service Ivia the logLequencer. essetia The onsite standby power sourc for each 4.16 kVE F bus is a C e dedicated+DG. DOGs an and-are dedicated to [EF uses

                                        , respectively. A*DG starts automatically on la Rea (D

oolant 2 SFAS Incident ys em-mACS) pressqre signa or on anjg us degraded voltage or Level,2 ac X Underyztage signael (refer to LCO 3.3.5, ngirerSafety Featurclii I0 loss f voltage ctuation System (gSFAS) Instrumentation" P nd LCO 3.3.8, "Emergency Diesel Generator (EDG) Loss of Power Startg (LOPS)'". After theZ4bG has started, it will automatically tie to its respective bus after offsite power 10 3 is tripped as a consequence of F bus junderyVlagej or degraded

                                                                    ~tta     J[loss-             of voltage]

BWOG STS B 3.8.1-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 55 of 323

Attachment 1, Volume 13, Rev. 0, Page 56 of 323 B 3.8.1 O INSERT 1 345 kV substations at Bay Shore, Lemoyne, and Ohio Edison - Beaver substations. During normal operation of the station, the unit auxiliary power transformer, connected to the generator isolated phase bus, provides the normal source of electrical power for station auxiliaries. Two startup transformers are supplied from different 345 kV switchyard bus sections. Each startup transformer provides power for startup, shutdown, and post-shutdown requirements. Normally, each startup transformer is the reserve power source for one 13.8 kV bus. In event of failure of the unit auxiliary transformer supply, each 13.8 kV bus is provided with a fast transfer scheme that will automatically transfer to the pre-selected startup transformer. When power is being supplied to a 13.8 kV bus by a startup transformer, the fast transfer scheme will automatically transfer to the alternate startup transformer (if pre-selected). Reserve source selector switches are provided to pre-select the alignment. Power supply to the 4.16 kV system is from two bus tie transformers. Each bus tie transformer normally supplies one essential and one non-essential 4.16 kV bus and is available as a reserve source for the other two 4.16 kV buses. Each essential 4.16 kV bus is provided with a fast transfer scheme that will transfer the bus from the normal source to an alternate source of power. Two 4.16 kV essential buses, C1 and D1, provide power to ESF equipment for safe station shutdown. Insert Page B 3.8.1-1 Attachment 1, Volume 13, Rev. 0, Page 56 of 323

Attachment 1, Volume 13, Rev. 0, Page 57 of 323 I All changes are unless otherwise noted P AC Sources - Operating B 3.8.1 BASES BACKGROUND (continued) BcoAntiCK ued)an GOUND SFAS Incide ntLeve l2a ctuation] voltage, independent of or coincident withla saf injecti n SI)signal. SFAS Incident DEJ -ýe-DGswill also start and operate in the standby mode without tying to/ Level 2 actuation bus on an S nal ias lone. Following the trip of offsite power,[W F se cran undervoltage signalstrips nonpermanent loads from the es L-F- E bus. When theDG is tied to the EFus loads are then _ . [::talsequentially connected to its respective MEFus by the automatic load individual 10relays, as applicable sequencer. q e c .loThe sequencing Iogii ontroll the permissive and starting a signals to motor breakers to prevent overloading the DG by automatic E load application. [and individual time delay relays e ial In the event of a loss of preferred power, the IE--Flelectrical loads are [-- automatically 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 loss of coolant accident (LOCA). Certain required unit loads are returned to service in a predetermined fW Dds sequence in order to prevent overloading the*DG in the process. Within D

                            -after                the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service.

Ratings for and ITrainB DGs 0sti the requirements of

                  -          Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG k" with 1lC/ overload permissible for up to 2 hours in anyt--f 24 hour period. The ESF loads that are powered from the 4.16 kV                            E        tial 0

buses are listed in Reference 2. INSERT 1A APPLICABLE SAFETY The initial conditions of DBA and transient analyses in the'rF-A, a er 6T (Ref. 4) and Fhaer [.J(Ref. 5), assume ESF %ystems are 07 ANALYSES OPERABLE. The AC electrical power sources are designed to provide Seo sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF $ystems so that the fuel, RCS, and containment design limits are not exceeded. These limits are discussed 0 in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems. 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 results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during accident conditions in the event of: BVWOG STS B 3.8.1-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 57 of 323

Attachment 1, Volume 13, Rev. 0, Page 58 of 323 B 3.8.1 O INSERT 1A Each EDG has its own day tank and fuel oil transfer system. The fuel oil transfer system, which includes one transfer pump, is capable of transferring fuel oil from the associated fuel oil storage tank to the day tank. Each transfer pump is capable of maintaining the level in the day tank when the associated EDG is operating a full load. Insert Page B 3.8.1-2 Attachment 1, Volume 13, Rev. 0, Page 58 of 323

Attachment 1, Volume 13, Rev. 0, Page 59 of 323 AC Sources - Operating B 3.8.1 BASES APPLICABLE SAFETY ANALYSES (continued)

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

b. Aworst-case single failure.

The Asatis terion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two qualified circuits between the offsite transmission network and the onsite Class 1 E Electrical Power Distribution System and separate and independent+DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA. Qualified offsite circiets are those that are described ithe SAR and are part of the licensingtbasis for the unit. - Move to Page B 3.8.1-4 after first paragraph MIn L additionone PE AB E. re uir utomatic load sequencer per train must be OPERABLE.M tI Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the [L uses. e Q [Offsite circuit #1 cons sts of Safeguards Transformer , which is supplied from Switchyard BusB, and is fed through breaker 5/ -3 powering the ESF transformer XN 01, which, in turn, powers the #1 ESF bus through its normal feeder br aker. Offsite circuit #2 consists f the Startup Transformer, which s normally fed from the Switchy rd Bus A, and is fed through breaker P 0201 powering the ESF transfo0mer, which, in turn, powers the #2 ES bus through its normal feeder b eaker.] ('7i-hvDG must be capable of starting, accelerating to rated speed and essential voltage, and connecting to its respective []fDus on detection of bus_- undervoltage. This will be accomplished within C]Thseconds. Eachý;_G" must also be capable of accepting required loads within the assumed 0j times oa ing se are-interval, and continue to operate until offsite power [ can De restored to tn E buses. These capabilities are required to be met from a variety of initial conditions, such asADG in standby with the engine hot and DG in standby with the engine at ambient conditions.

                       *AdditionalDG capabilities must be demonstrated to meet required              E)

Surveillances, e.g., capability of the44DG to revert to stagdby status on an GECCS signal while perating in parallel test mode. BWVOG STS B 3.8.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 59 of 323

Attachment 1, Volume 13, Rev. 0, Page 60 of 323 B 3.8.1 O INSERT 2 A qualified offsite to onsite circuit consists of one 345 - 13.8 kV startup transformer, one 13.8 kV bus, one 13.8 -4.16 kV tie transformer, and the respective circuit paths, including the nonessential bus and feeder breakers, to one 4.16 kV essential bus. Furthermore, analysis has shown that the impedances of the 345 - 13.8 kV startup transformers and the 13.8 - 4.16 kV tie transformers are such that acceptable voltage levels cannot be guaranteed for all accident scenarios and the entire station emergency loads (i.e., the essential buses) being simultaneously supplied through a single 345 - 13.8 kV startup transformer and a single 13.8 - 4.16 kV tie transformer. Thus, if both essential buses are being powered in this manner, both offsite circuits are inoperable. In addition, in MODES 3 and 4, in lieu of one of the 345 - 13.8kV startup transformers, one main transformer and one unit auxiliary transformer with the generator links removed (i.e., a backfeed alignment) may be used. O INSERT2A In addition, day tank fuel oil level and fuel oil transfer system requirements must be met for each EDG. Insert Page B 3.8.1-3 Attachment 1, Volume 13, Rev. 0, Page 60 of 323

Attachment 1, Volume 13, Rev. 0, Page 61 of 323 I All changes are AC Sources- Operating unless otherwise noted 9 B 3.8.1 BASES (which include all required" LCO (ontiued) individual time delay relays) Insert paragraph from E Proper sequencing of loads Ijncluding tripping of non-essential Ioadsm]is a required function for DG OPERABILITY. 0 Page B 3.8.1-3 The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For thebGs, separation and independence are complete. For the offsite AC sources, separation and independence are to the An offsite extent practica circuit may be connected to more than one E F bus, vwith fast-transfer capability to the other circuit OPERABLE, and not esenia 0 violate separation criteria.-Mcircuit that is not connected to an E Fus is ( required to have OPERABLE fast-transfer interlock mechanisms to

aw bus- to support OPERABILITY of that circuit] ( APPLICABILITY/* The AC sources bna cers]are required to be OPERABLE in 0v MODES 1, 2, 3, and 4 to ensure that: Tranreserve source selector switches are used to ensure this capability is available. cicuTh (ie.,tesm Therefore, tru if both reserve a. Acceptable fuel design limits and reactor coolant pressure boundary source selector switches are selected to the same offsitel circuit (i.e., the same startup/ limits are not exceeded as a result of AOOs or abnormal transientsL, and 0 transformer), the non-selected

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

0 The AC power requirements for MODES 5 and 6tare covered in LCO 3.8.2, "AC Sources - Shutdown." [ and other conditions inwhich AC sources are required 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 E(E specified condition in the Applicability with an inoperable G 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. BWOG STS B 3.8.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 61 of 323

Attachment 1, Volume 13, Rev. 0, Page 62 of 323 All changes are AC Sources - Operating B 3.8.1 unless otherwise noted 9 BASES ACTIONS :(continued) A.1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is .necessary to verify the OPERABILITY 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 second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.

                                                  --- REVIEWER'S     -----       NOTE                       ------------------

The turbine driven auxi iary feedwater pump is only requir d to be considered a redunda t required feature, and, therefore, r quired to be determined OPERAB E by this Required Action, if the de ign is such that the remaining OPER/BLE motor or turbine driven auxilia feedwater pump(s) is not by its f capable (without any reliance on he motor driven 0 auxiliary feedwater p mp powered by the emergency bu associated with the inoperable diese generator) of providing 100% of th auxiliary feedwater flow ass ed in the safety analysis. A.2 Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associatedrDG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. This includes motqr driven emergency feedv)tater pumps. Single train systems, such as Aurbine driven emergencyfeedwater pumps, may not be Iincluded. ( The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This exception to the normal "time zero"r Completion Time also allows for an for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both: C7

a. The train has no offsite power supplying itjoajdsand 0@

                  "b. A~required feature on the other train is inoperable.
                   "a          11    These redundant required features are those assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core CoolingI
                                 /System. These redundant required features do not include monitoring requirements, such as post]

accident monitoring instrumentation and remote shutdown monitoring instrumentation. BWOG STS B 3.8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 62 of 323

Attachment 1, Volume 13, Rev. 0, Page 63 of 323 r All changes are O*" AC Sources - Operating unless otherwise noted B 3.8.1 BASES ACTIONS (continued) If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be trackedl]} (D Discovering no offsite power to one train of the onsite Class 1E Electrical redundant Power Distribution System coincident with one or more inoperable ÷ d required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Time[gfor the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. o essential bus Cl The remaining OPERABLE offsite circuit and,6Is adequate to supply essential bus D1 electrical power to and mrai_._B!f the onsite Class 1 E Distribution System. The 24 hour Completion Time takes into account the component 2 OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour 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 Regulatory Guide 1.93 (Ref. 6), operation may continue in 0 Condition A for a period that should not exceed 72 hours. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate E] to supply electrical power to the onsite Class 1 E Distribution System. The 72 hour 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. B.1 To ensure a highly reliable power source remains with an inoperableUG,-- it is necessary to verify the availability of the offsite circuits 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 being not met. However, if RJcircuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered. BVVOG STS B 3.8.1-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 63 of 323

Attachment 1, Volume 13, Rev. 0, Page 64 of 323 All changes are AC Sources - Operating unless otherwise noted . B 3.8.1 BASES ACTIONS (continued)

                        ...........           -- - ..... REVIEWER'S NOTE                  ------------------

The turbine driven au iliary feedwater pump is only re ired to be considered a redund nt required feature, and, therefor, required to be determined OPERA LE by this Required Action, if th design is such that the remaining OPE ABLE motor or turbine driven au iliary feedwater pump(s) is not by it elf capable (without any reliance on the motor driven 0 auxiliary feedwater pump powered by the emergen bus associated with the inoperable die el generator) of providing 100% f the auxiliary feedwater flow as umed in the safety analysis. B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a required * -designed wi redundant safety related trai ;*. /Tis inc lues m o tor driven C required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable+DG. The Completion Time for Required Action B.2 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 inoperableDG existfand 0 Fre-dundantT- -

b. A required feature on the other train is inoperable. 0 (one4DG inoperable) a If at any time during the existence of this ,ondition required feature subsequently becomes inoperable, this Completion Time begins icvrn to be tracked. n ,___nprbecicdn ihoeo oeE rDu Discovering one Irqpte* in-operableirequired supportGorinoperable supported coincident with features, or onethat both, or more are * " associated with the OPERABLE4DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. BWVOG STS B 3.8.1-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 64 of 323

Attachment 1, Volume 13, Rev. 0, Page 65 of 323 S All changes are ( ' rnle I. unless chesware otherwise noted K )BB3.8.1 AC Sources - Operating B3. 1 BASES ACTIONS :(continued) In this Condition, the remaining OPERABLE*G and offsite circuits are adequate to supply electrical power to the onsite Class 1 E 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 hour Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour 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. B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testin of OPERABLEbG(s). If it can be determined that the cause of the inoperable+DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other G(s), the other G(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists and E 4 Required Action B.3.1 is satisfied. If the cause of the 4initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), erformance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG. In the event the inoperableýDG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the Dlant corrective action prograrrmwill continue to evaluate the common cause possibility. This continued 0 evaluation, however, is no longer under the 24 hour constraint imposed while in Condition B. F According to Generic Letter 84-15 (Ref. 7), 24M hours is reasonable to []"\ confirm that the OPERABLEIDG(s) is not affected by the same problem 0 as the inoperable G. BVVOG STS B 3.8.1-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 65 of 323

Attachment 1, Volume 13, Rev. 0, Page 66 of 323 K All changes are AC Sources - Operating unless otherwise noted B 3:8.1 BASES ACTIONS (continued) B.4 According to Reoulatory Guide 1.93 (Ref. 6), operatio may continue in Condition B for Aperiod that should not exceed 72 ho rs. In Condition B, the remaining OPERABLE FDG and offsite circuits are adequate to supply electrical power to the onsite Class 1 E Distribution System. Th ' 2 u Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, 0 and the low probability of a DBA occurring during this period. f The 7 day Completion Time is also acceptable as described in Reference 8. J C.1 and C.2 Required Action C.1, which applies when two offsite circuits are Tfeatures inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant These redundant required require safety fWctions]. he Completion Time for this failure of features are those redundant required features is reduced to 12 hours from that allowed for mitigate an accident, one train without offsite power (Required Action A.2). The rationale for coincident with a loss of the reduction to 12 hours is that Regulatory Guide 1.93 (Ref. 6) allows a offsite power, in the safety Completion Time of 24 hours for two required offsite circuits inoperable, analyses, such as theTierqrdinpab, Emergency Core Cooling based upon the assumption that two complete safety trains are System. These redundant OPERABLE. When a concurrent redundant required feature failure required features do not include monitoring exists, this assumption is not the case, and a shorter Completion Time of requirements, such as post 12 hours is approprate. These features are owered from redundant AC accident monitoring instrumentation and remote Isafety trains. is inc udes motor driven auxiliary fee water pumps.i shutdown monitoring instumenatio, j Single included train eat in the -st.- such as turbine driven auxiliary 7res, umps, are not0 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 and Fredundant

b. Atrequired feature is inoperable.

If at any time during the existence of Condition C (two offsite circuits inoperable) and a-required feature becomes inoperable, this Completion Time begins to be tracked. BVWOG STS B 3.8.1-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 66 of 323

Attachment 1, Volume 13, Rev. 0, Page 67 of 323 All changes are AC Sources - Operating K unless otherwise noted B 3.8.1 BASES ACTIONS (continued) According to Regulatory:Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours. 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 of degradation may appear to be more severe than other combinations of E two AC sources inoperable that involve one or moreiDGs inoperable. However, two factors tend to decrease the severity of this level of degradation:

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

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 hour Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an FL .AC electrical power system capable of meeting its design criteria. SRegulatory Guide 1.93 (Ref.I According to ef n with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours. If two offsite sources are restored within 24 hours, unrestricted operation may continue. If only one offsite source is restored within 24 hours, power operation would continue in accordance with Condition A. BWOG STS B 3.8.1-10 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 67 of 323

Attachment 1, Volume 13, Rev. 0, Page 68 of 323 All changes are AC Sources - Operating unless otherwise noted 9 B 3.8.1 BASES ACTIONS (continued) D.1 and D.2 - s- Operating 0 Pursuant to LCO 3.0.6, the Distribution SysterrACTIONS 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 modified by a Note to indicate that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition D to provide requirements for the loss of E one offsite circuit and one4DG without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train. According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D for a period that should not exceed 12 hours. 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 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 hour 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. E.1 With rrain A gpcrain DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical 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 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 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. BVWOG STS B 3.8.1-11 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 0, Page 68 of 323

Attachment 1, Volume 13, Rev. 0; Page 69 of 323 All changes are AC Sources - Operating unless otherwise noted P B 3.8.1 BASES Regulatory Guide f. ACTIONS :(continued) 0 According to efe~e nce`6,with bothEDGs inoperable, operation may continue for a period that should not exceed 2 hours. G 0 The sequencer(s) i an essential support system to both the offsite circuit and the DG associ ted with a given ESF bus]. [Fu hermore, the 0 sequencer is on th primary success path for mos major AC electrically powered safety s tems powered from the associ ted ESF bus.] Therefore, loss of an [ESF bus sequencer] affect every major ESF system in the [di ision]. The [12] hour Completio Time provides a period of time to correc the problem commensurate wit the importance of maintaining seq encer OPERABILITY. This ti e period also ensures that the probabi ity of an accident (requiring se uencer OPERABILITY) occurring durin periods when the sequencer i inoperable is minimal. This Conditio is preceded by a Note that allo the Condition to be deleted if the nit design is such that any se encer failure mode will only affect the abi ty of the associated DG to po er its respective safety loads under any c nditions. Implicit in this Note i the concept that the Condition m st be retained if any sequenc failure mode results in the inability to s art all or part of the safety Ioa when required., regardless of power availl bility, or results in overloadin the offsite power circuit to a safety bus uring an event thereby causi g its failure. Also implicit in the Note is th t the Condition is not applicabl to any train that does not have a sequen er. ] T

           /I 2                                                                  0 If the inoperable AC electrical power sources cannot be 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 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

BWOG STS B 3.8.1-12 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 69 of 323

Attachment 1, Volume 13, Rev. 0, Page 70 of 323 B 3.8.1 O INSERT 3 One of the SFAS actions during an Incident Level 2 is to start the EDG. In the event of a loss of offsite power concurrent with an SFAS trip, the SFAS sequencer will apply emergency loads to the essential bus in accordance with the sequencer load program. Each SFAS actuation channel has two sequencer modules. With one or more trains with one sequencer inoperable, the 1 hour Completion Time provides a period of time to remove the inoperable module from the SFAS cabinet. As noted, since each train is independent from the other train, separate Condition entry is allowed for inoperable sequencers in each train. H.-1 With one or more trains with two sequencers inoperable, the EDG cannot be loaded in the proper sequence and therefore, cannot meet its safety function. Therefore, the EDG must be immediately declared inoperable. As noted, since each train is independent from the other train, separate Condition entry is allowed for inoperable sequencers in each train. Insert Page B 3.8.1-12 Attachment 1, Volume 13, Rev. 0, Page 70 of 323

Attachment 1, Volume 13, Rev. 0, Page 71 of 323 All changes are AC Sources - Operating unless otherwise noted 9 B 3.8.1 BASES ACTIONS (continued) Condition A corresponds to a level of degradation in which all redundancy 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 UFSAR, Section 8 function, in accordance with10 CFR ?0, Appendix A, PDC 187(Ref. L) Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs E[ for demonstrating the OPERABILITY of the+DGs ar in acc,oancel with

       ~stent                 the recommendations of Regulatory Guide 1.9 (Ref. 3) Regto JGuide 1.l       Ref. 9) and Regulatory Guide 1.137 (Ref. 10)--]

laddressed.inwttie FSAR! Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output Tvotage sp e V is 90% of the nominal 4160 V output fhisvoltageo hvalue, frwhich l pi ioed in ANSI C84.1 s em a, for voltage drop and isconsistent to the terminals of4000 V motors whose minimum operating voltage is Safety Guide 9 Rwith S(Ref. 11). specified as 900or 3600bV. It also allows for voltag dropstomotors and oher quipment down through the 120 V level yhere minimum operating voltfige is also usually specified as 90% f name plate ratiIng. The specified maximum steady state output voltage of Fý-).s equal, to the maximum operating voltage specified for 4000 V motors. It-ensues *( that for a lightly loaded distribution system, the voltage at the terminals, of 4000 V motors is noia more than the maximum rated operating voltag Es- [ seay tat }Th secified rinimum and maximumn afrequencies y si va u e. of the,*DG are

                                                                                               )
                         ý5nýHz,              respectively. These values are lequal/to               1 +/- 2%Y of the 60 Hz nominal freque0w* and are derived from the recgnmendations given in Regulatory*"-*ide 1.9 (Ref. 3).

based on plant-specific analysis values. BVWOG STS B 3.8.1-13 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 71 of 323

Attachment 1, Volume 13, Rev. 0, Page 72 of 323 All changes are tp AC Sources- Operating unless otherwise noted 9 B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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. 8 SR 3.8.1.2 and SR 3.8.1. These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition. To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 1 for - SR 3.8.1.2 and Note for SR 3.8.1.F) to indicate that aIlIDG starts for these *KJK Cb: }- aSurveillances mayprior warm up period be precededoan to loading ]by engine an engine prelube

                                                                                -. period-p-e-rio-dj(

pretu-be and followed by 07 For the purposes of SR 3.8.1.2 and SR 3.8.1 . esting, the#)Gs are started from standby conditions. Standby conditions forWG means that the diesel engine coolant and oil are being continuously circulated and (D temperature is being maintained consistent with manufacturer recommendations. I[In order to reduce stress and wear on diesel engines, some () manufacturers recommend a modified start in which the starting speed of IIV.DGs is limited, warmup is limited to this lower speed, and the4DGs are gradually accelerated to synchronous speed prior to loading. This is the intent of Note 2, which is only applicable when such modified start 8 procedures are recommended by the manufacturer. [] 0D SR 3.8.1.M requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the! SAR, Chap [15] (Ref. 5) The minimum voltage limit is based on the voltage required1 based on the recommendations of Safety Guide 9 (Ref. 11). BWVOG STS B 3.8.1-14 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 72 of 323

Attachment 1, Volume 13, Rev. 0, Page 73 of 323 r All changes are unless otherwise noted AC Sources - Operating B 3:8.1 B BASES SURVEILLANCE REQUIREMENTS (continued) The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described .above is used. If a modified start is -not used, the 10 second start requirement of SR 3.8.1. applies. 8-- Since SR 3.8.1.requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. In addition to the SR requirements, the time for the DG to reach steady 19 state operation, unless the modifiedFDG start method is employed, is erio a monitored land the trevaluated to identify degradation of governor and voltage regulator performance. The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1. s a reduction 8} in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance ofFDG OPERABILITY, while minimizing degradation resulting from testing. SR 3.8.1.3 4T-..1 his Surveillance verifies that theGs are apable of synchronizing with6 the offsite electrical system and accepting loads LI-eaLi tQi-IoVeqal o 5 the equivalent of the iaximum expected accident loa lsF A

run Sensures the engin~e- time of 60 minuteslis required to stabl.e temperatures while temperatures are stabilized minimizing the time that the DG is connected to the offsite source.

laggin Although no power factor requirements are established by this SR, the DG is normally operated at a~power factor between M0.8 ang ,n

                            *~.         The jM0.8Mvalue is the design rating of the machine, while the Is0is anlimitation per                     1[to ensure circulatin -s   are minimizedf   t ahe                        load band is provided to avoid routine overloading of the+DG.

Routine overloading may result in more frequent teardown inspectionsin*

             ~accordance                      with ver~dor recommendations in ordpr to maintain DG I OPERABILITYF.

The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3). BWAOG STS B 3.8.1-15 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 73 of 323

Attachment 1, Volume 13, Rev. 0, Page 74 of 323 B 3.8.1 0 INSERT 4 Consistent with Regulatory Guide 1.9 (Ref. 3), O INSERT 5 90% to 100% of the continuous rating of the EDG INSERT 6 being required in order to maintain EDG reliability Insert Page B 3.8.1-15 Attachment 1, Volume 13, Rev. 0, Page 74 of 323

Attachment 1, Volume 13, Rev. 0, Page 75 of 323 All changes are unless otherwise noted I AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modified by four Notes. Note 1 indicates 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 states that momentary transients because of changing bus loads do not invalidate this test. imi rly., momentary power factrfansients above the limit will not invalidAte the test./ Note 3 indicates that this Surveillance shoul be conducted on onay one4Ga" ta time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. 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 provides verification that the level of fuel oil in the day tank ad Swithin-the lengine mmted tank isIator ove ee ic ue 0i is required limit automaia aed The level is expressed as an equivalent volume in

                         ~gallons, and is sele                 to ensure dequate fuel oil forl a minimo-
                                    *h[*our        peration at full load plus'X00      s                   approximately The 31 day Frequency is adequate to assure that a sufficient supply of This volume is also credited (in  fuel oil is available, since low level alarms are provided and unit operators the associated conjunction withn                would be aware of any large uses of fuel oil during this period.

storage tank) to support 7 days] of EDG operation at full load. 1 SR 3.8.1.5 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[e4- f -h fuel oil day 1and engiro- lounted ltank[g once every[J31MJdays eliminates 0 the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during4DGL[J operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from 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 Frequenc*J.t* (D) isconsistent are esta e Regulatory Guide 1.137 (Ref. 10). This SR is for with preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance. BWOG STS B 3.8.1-16 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 75 of 323

Attachment 1, Volume 13, Rev. 0, Page 76 of 323 I All changes are AC Sources.- Operating unless otherwise noted P B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) Move SR 3.8.1.6 -7 to here from Page B 3.8.1-31syste) SR 3.8.1. F(one-per fu il tr This Surveillance demonstrates that each reqied fuel oil transfer pumpý operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for auto atic fuel transfer systems are OPERABLE. s 0 IThe Frequency for this SR islvariable, depending on individ al systeml design, v uto a P2da nt al The M921 day Frequency 0 corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 12); however, the design of fuel trapsfer systems is 80 such that pumps wil operate automatically or must b started manually in order to maintain ar adequate volume of fuel oil in tle day [and engine mounted] tanks dueing or following DG testing. In s ch a case, a 31 day Frequency is appropriate. Since proper operation f fuel transfer systems is an inherent pa of DG OPERABILITY, the Freq enc of this SR should 0 be modified to ref ect individual design. M 0 SR .8.1.2. See $4/.8.1.2 0 INER B SR 3.8.1. esetial' te btwenTransfer of each Mj4.16 kV[E4F busM powe r supply from the normal offsite as tanfe (vi 0 tewsaup transformers) circuit to the alternate ottsite circuit'demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. Ti-1iMmonthM Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform 09 the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually Spass the SR when performed at thej monthf Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. BWVOG STS B 3.8.1-17 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 76 of 323

Attachment 1, Volume 13, Rev. 0, Page 77 of 323 B 3.8.1 O* INSERT 6A Transfer of each 4.16 kV essential bus power supply from the unit auxiliary source (i.e., the main generator) to the pre-selected offsite circuit (i.e., pre-selected startup transformer) demonstrates that if the unit auxiliary source is supplying power, the transfer circuitry to the qualified offsite circuits is OPERABLE. This ensures the capability of the offsite circuits to be properly aligned, since the unit auxiliary source is not a qualified offsite circuit. As noted (Note 1), the transfer capability is only required to be met ifthe unit auxiliary source is supplying the electrical power distribution subsystem. Insert Page B 3.8.1-17 Attachment 1, Volume 13, Rev. 0, Page 77 of 323

Attachment 1, Volume 13, Rev. 0, Page 78 of 323 I All changes are unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modified by a Note The reason for the Note is that during operation with the reactor critical, performance of 05R-SR*could cause 4 9. J perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. 39.- This restriction from normally performing the Supi efllance 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 SRI] 0 SR 3.8.1.j S SEachDG 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 result in a trip of the engine. This Surveillance demonstrates the*DG load response characteristics and capability to reject the largest single load without=exceedin redetermined voltage and fr.ceq4=,ry and wile im11ainltainlipeieu margin to the overspeed trip. II-or the UK-ý leegec Gs, agstsnl odIS6516 kY (HPI pump). ýAfer ( D5 pe f r a c H 1 ,t e d e s l l a s r d c e a T p p-*a ro xim a t e ly -1 120k n loe then reduced to 616 orna hsla o is kW and the DGs output break o5minut s. The load is I K ) opened. IVerification that t/h DG did not trip is madeI T-h-is Surveillance may be accomplished by either:

a. Tripping thE7G output breaker with theDG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bu 0

BWOG STS B 3.8.1-18 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 78 of 323

Attachment 1, Volume 13, Rev. 0, Page 79 of 323 B 3.8.1 O INSERT 7 (the high pressure injection pumps - approximately 540 kW) Insert Page B 3.8.1-18 Attachment 1, Volume 13, Rev. 0, Page 79 of 323

Attachment 1, Volume 13, Rev. 0, Page 80 of 323 All changes are a unless otherwise noted AC Sources - Operating I B 138.1 BASES SURVEILLANCE REQUIREMENTS (continued) or its equivalentE

b. Tripping its associated single largest post-accident Ioa-dwith theODG solely supplying the bus.

As requ ed by :IEEE-30 (Ref. 13), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower. INSERT8A 0 The time, voltage, and fr quency tolerances specified in this SR ar derived from Regulato Guide 1.9 (Ref. 3) recommendations for response during load/ equence intervals. The [3] seconds spe ified is equal to 60% of a ty1ical 5 second load sequence interval as ciated with sequencing of the rgest load. The voltage and frequency pecified are 0 consistent with t design range of the equipment powere by the DG. SR 3.8.1.9.a coresponds to the maximum frequency ex ursion, while SR 3.8.1.9.b nd SR 3.8.1.9.c are steady state voltag and frequency values to wlch the system must recover to followin oad reiection. FThe I 2J d mont Frequency h is consistent with the recommendatlon o f ........ , IRegulatory Guipe 1.108 (Ref. 9). takes into consideration unit conditions required to perform the Surveillance,

                                  /'This SR is modified by two Notes.        The reason for Note 1 is that during and is intended to be consistent with expected operation with the reactor critical, performance of this SR could cause fuel cycle lengths         perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit 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. Note 2 BWOG STS B 3.8.1-19 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 80 of 323

Attachment 1, Volume 13, Rev. 0, Page 81 of 323 B 3.8.1 ( INSERT 8 Consistent with Safety Guide 9 (Ref. 11), O INSERT8A This corresponds to 66.75 Hz, which is 75% of the difference between synchronous speed and the overspeed trip setpoint. Insert Page B 3.8.1-19 Attachment 1, Volume 13, Rev. 0, Page 81 of 323

Attachment 1, Volume 13, Rev. 0, Page 82 of 323 All changes are Q.) I unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) ensures that the G is tested under load conditions that are as close to design basis conditions as possible. When synchronized with ofs power, testing should be performed a a power factorlof--5 . This 10E

          / s power factor The                 limit] power factor is representative of the actual inductive loading a4DG would          '-0 5-0.85
                        'oD land < 0.86  for EDG 2. see under design basis accident conditions.; Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a wer outside the power factor limit       factor otheqjban __[0.9] These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to

[wthnthe li nit - 9 results in voltages on the eus es that are too high. [ stial tlmit Under these conditions, the power factor should be maintained as close as practicable to- [ ] while still maintaining acceptable voltage limits on 10 ethermenc busges. In other circumstances, the grid voltage may be wtni s that the excitation levels needed to obtain a power factor of 9 esna EDGeseta may not cause unacceptable voltages on the merncy usges, the -but excitation levels are in excess of those recommended for the ISuch [L_. cases, the power factor shall be maintained as close as practicable to the power factor limit without exceeding the*DG excitation limits.

                                     --------------                     REVIEWER'S NOTE-          -----------------

The above MODE rest ictions may be deleted if it can be d monstrated to the staff, on a plant sp cific basis, that performing the SR ith the reactor in any of the restricte MODES can satisfy the following cr' eria, as applicable:

a. Performance of he SR will not render any safety sys em or component ino rable,

b. Performance o the SR will not cause perturbations o any of the (

electrical distrii ution systems that could result in a *hallenge to steady state operation or to plant safety systems, nd

c. Performance f the SR, or failure of the SR, will n t cause, or result in, an AOO 'th attendant challenge to plant safer systems.

BV\WG STS B 3.8.1-20 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 82 of 323

Attachment 1, Volume 13, Rev. 0, Page 83 of 323 I All changes are 1 unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.1.10 This Surveillance demonstrat s the DG capability to reject a f 1iload without overspeed tripping o exceeding the predetermined v Itage limits. The DG full load rejection m y occur because of a system fal It or inadvertent breaker tripping This Surveillance ensures pro r engine generator load response u der the simulated test conditions. This test simulates the loss of the to al connected load that the DG e periences following a full load rejecti n and verifies that the DG will n t trip upon loss of the load. These a ceptance criteria provide DG da ge protection. While the DG is not expected to experience th s transient during an event and contnues to be available, this respo se ensures that the DG is not degraded for future application, including r connection to the bus if the trip initiato can be corrected or isolated. The [18 month] Freq ency is consistent with the r commendation of Regulatory Guide 1.1 8 (Ref. 9) and is intended to e consistent with expected fuel cycle le gths. I This SR is modified y two Notes. The reason for No e 1 is that during operation with the reactor critical, performance of thi SR could cause perturbation to the lectrical distribution systems tha could challenge continued steady s te operation and, as a result, u it safety systems. This restriction fro normally performing the Surveil lance in MODE 1 or 2 is further amplifie to allow the Surveillance to be rformed for the purpose of reesta lishing OPERABILITY (e.g., po t work testing following corrective mainte ance, corrective modification, d ficient or incomplete surveillance testi g, and other unanticipated OP EABILITY concerns) provided an ass ssment determines plant safety is maintained or enhanced. Thi assessment shall, as a minimu , consider the potential outcomes and ansients associated with a faile Surveillance, a successful Su eillance, and a perturbation of t e offsite or onsite system when they are tied together or operated indepe dently for the Surveillance; s well as the operator procedur s available to cope with these outco es. These shall be measured a ainst the avoided risk of a plant shutdo and startup to determine that lant safety is maintained or enhanced en the Surveillance is performe in MODE 1 or 2. Risk insights or eterministic methods may be us d for this assessment. Credit may e taken for unplanned events t at satisfy this SR. BWOG STS B 3.8.1-21 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 83 of 323

Attachment 1, Volume 13, Rev. 0, Page 84 of 323 I All changes are unless otherwise noted AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) Note 2 ensures that the G is tested under load conditions hat are as close to design basis c nditions as possible. When synch onized with offsite power, testing ould be performed at a power fa r of <- [0.9]. This power factor is r presentative of the actual inductiv loading a DG would see under de ign basis accident conditions. Und r certain conditions, howeve , Note 2 allows the Surveillance to e conducted at a power factor otherthan 5 [0.9]. These conditions occ r when grid voltage is high, and the a ditional field excitation needed to g t the power factor to 5 [0.9] results n voltages on the emergency buss s that are too high. 0 Under these co ditions, the power factor should be intained as close as practicable o [0:9] while still maintaining accept ble voltage limits on the emergen busses. In other circumstances, t e grid voltage may be such that th DC excitation levels needed to obta n a power factor of [0:9] may not ca se unacceptable voltages on the e rgency busses, but the excitation I vels are in excess of those recomm nded for the DC. In such

               *cases, th power factor shall be maintained as close as practicable to

[0.9] wit ut exceeding the DG excitation limit .

                                            ..... REVIEWER'S     NOTE         ------------------

The above MODE r strictions may be deleted if it can be emonstrated to the staff, on a plan specific basis, that performing the SR ith the reactor in any of the restri ted MODES can satisfy the following riteria, as applicable:

a. Performanc of the SR will not render any safety s stem or componen inoperable,

b. Performa ce of the SR will not cause perturbatio s to any of the electrical distribution systems that could result i a challenge to 0 steady ate operation or to plant safety syste , and

c. Perfor nce of the SR, or failure of the SR, wI not cause, or result in, an 00 with attendant challenge to plant afety systems.

SR 3.8.1.11 C,2,2.4 nt Regulatory Guide (Ref.lb paragraph . . , this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of E the non-essential loads and energization of the erncYrou sesand respective loads from the 4OG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time. BWOG STS B 3.8.1-22 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 84 of 323

1 Attachment 1, Volume 13, Rev. 0, Page 85 of 323 f All changes are unless otherwise noted 9 AC 'Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

                                     '                                     MJ The. G auto-start time of* dseconds is derived from requirements of the accident analysis to respond to a design basis large break LOCA.

0 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 (i.e., the individual time delay

and auto-connected loads is intended to satisfactorily show the (ire.,yfotheindividuimp e colig relationship of these loads to the4tDG loading logi In certain water, service water, and makeup circumstances, of these loads can not actually be connected or pumps) [o loaded Without undue hardship or potential for undesired operation. For instance, E m r nc Core Cooling Systems (ECCS) injection valves areI not desired to btgtroked open, high pressure inje 'ionsystems are not capable of beinoj operated at full flow, or decay he /t removal (DHR)l 0 systems perforrfling a DHR function are not desirel to be realigned to the ECCS mode of/operation.Fi n lieu-of actual demonstration of connection

_and loading of loads, testing that adequately shows the capability of the JDG 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[ monthsq is consistent witl7 the recommendations ofI lRegulatory Guide 1.1,08 (Ref. 9), paragraph 2.#.(1),Ftakes into 0 consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the4DGs during testing. For the purpose of this testing, ThiDGs must be started from standby conditions, that is, with the engine coolant and oil 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 safety systems. This restriction from normally performing the t Surveillance in MODE 11 24 is further amplified to allow portions of the LI 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 BVWOG STS B 3.8.1-23 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 85 of 323

Attachment 1, Volume 13, Rev. 0, Page 86 of 323 I All changes are unless otherwise noted P AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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 1f Risk H'Or 2 [] insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR. SR 3.8.1.12 This Surveillance dem nstrates that the DG automatically starts and achieves the required oltage and frequency within the s ecified time ([10] seconds) from t design basis actuation signal (L A signal) and operates for > 5 minu es. The 5 minute period provides ufficient time to demonstrate stability/ SR 3.8.1.12.d and SR 3.8.1.12.eensure that permanently conne ed loads and emergency loads are1 energized from the offsite electrical/power system on an ESF signal wi out loss of offsite power. The requirement t verify the connection of permane and auto-connected loads i intended to satisfactorily show the relationship of these loads to th DG loading logic. In certain circu tances, many of these loads can ot actually be connected or loaded without undue hardship or pot ntial for undesired operation. For i tance, ECCS injection valves are not desired to be stroked open, high pressure injection syste s are not capable of being operate at full flow, or DHR systems perfo ming a DHR function are not desire to be realigned to the ECCS mode f operation. In lieu of actual demon. tration of connection and loading loads, testing that adequately sho the capability of the DG system t perform these functions is accepta le. This testing may include any eries of sequential, overlapping, or otal steps so that the entire conn ction and loading sequence is verifi d. ] The Frequ ncy of [18 months] takes into consi eration unit conditions required t perform the Surveillance and is inte ded to be consistent with the expe ed fuel cycle lengths. Operating ex erience has shown that these co ponents usually pass the SR when erformed at the [18 month] Frequen . Therefore, the Frequency was ncluded to be acceptable from a r liability standpoint. BWOG STS B 3.8.1-24 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 86 of 323

L Attachment 1, Volume 13, Rev. 0, Page 87 of 323 All changes are Sunless otherwise noted AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modified by o Notes. The reason for Note 1 i to minimize wear and tear on the D s during testing. For the purpose f this testing, the DGs must be starte from standby conditions, that is, ith the engine coolant and oil continu usly circulated and temperature aintained consistent with manu cturer recommendations. The re on for Note 2 is that during operation ith the reactor critical, performan of this Surveillance could use perturbations to the electrical istribution systems that could hallenge continued steady state o ration and, as a result, unit safety s stems. This restriction from norm ly performing the Surveillance in M E 1 or 2 is further amplified to all portions of the Surveillance to be performed for the purpose of reest blishing OPERABILITY (e.g., post work testing following corr ctive maintenance, 10-ý corrective modiffi tion, deficient or incomplete surve llance testing, and other unanticipa ed OPERABILITY concerns) provi d an assessment determines pla t safety is maintained or enhanced. This assessment shall, as a min,* um, consider the potential outco s and transients associated wit a failed partial Surveillance, a su essful partial Surveillance,and a perturbation of the offsite or o site system when they are tied togelher or operated independently for t partial Surveillance; as well as the perator procedures available to cop with these outcomes. These shal be measured against the avoided ri k of a plant shutdown and startu to determine that plant safety is maintained or enhanced when portfons of the Surveillance are performe in MODE 1 or 2. Risk insights o" deterministic methods may be use for the assessment. Credit m y be taken for unplanned events tha satisfy this SR.] SR 3.8.1A 0 This Surveillance demonstrates that G noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signa concuriet wi an F - actuation test signal: Noncritical automatic 0 SFS trips are all automatic trips except:

a. Engine overspeed;FI

b. Generator differential currentf}

[c. Low lube oil pres re; 0

d. High crankcae pressure; and

e. Start failue relay.]

The noncritical trips are bypassed during DBAs and provide 5 alarm n1 g]abnormal engine conditih. Thalarmprovidegthe operator with BWAOG STS B 3.8.1-25 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 87 of 323

Attachment 1, Volume 13, Rev. 0, Page 88 of 323 All changes are 1 I unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) sufficient time to react appropriately. TheZG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of theMDG. Thel -monthrjFrequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance2j 0 intended to be c/onsistent with expected fuel cycle lengths. Operating Z experience has shown that these components usually pass the SR when performed at th4ýJmonthM Frequency. Therefore, the Frequency was 0 concluded to be acceptable from a reliability standpoint. The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required4 DG from service. 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.

                                            -----REVIEWER'S-    NOTE        ------------------

The above MODE re trictions may be deleted if it can be demonstrated to the staff, on a plant s ecific basis, that performing the S with the reactor in any of the restrict d MODES can satisfy the following riteria, as applicable:

a. Performance o the SR will not render any safety s stem or component ino era ble,

b. Performance f the SR will not cause perturbation to any of the electrical distr bution systems that could result in challenge to 0

steady state peration or to plant safety systems, and

c. Performanc of the SR, or failure of the SR, will ot cause, or result in, an AOO 'th attendant challenge to plant saf ty systems.

BVWOG STS B 3.8.1-26 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 88 of 323

Attachment 1, Volume 13, Rev. 0, Page 89 of 323 All changes are c '0 unless otherwise noted AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8. 1. 1 Consistent with IEEE 387-1995 (Ref. 13),.. Regulatory Guid/ 1.108 (Ref. 9), paragraph 2/a (3), requires Survell c this dem onstration ýnce per 18 m onths that the +DGs can start and run 8 10 to1010 ____ h D (90% to 100% of the EDG continuously at full load capability4for an interval of not less than &rhours, ___-_ Scontinuous rating) -Jf>->ours of which is at a load equivalent toW1 10% of the continuous 10 [cont uoting and the remainder of the time at a load equivalent totthe continuous (D (j )

                                                    -d*'rating of the4 DG. The4 DG starts for this Surveillance can be                         90% to 100% of performed either from standby or hot conditions. The provisions for                                     0) prelubricating 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.

The load band is provided to avoid routine overloading of the JIG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations, in order to maintain4IIG OPERABILITY. Ibase, on engineering judgment, taking I~~~egulatory~~~jugmnt Gudt/.0aRe.7,kaarah2a.ntaeg The monthFrequency is consisten wi e r commendations o consideration unit conditions required to perform the Surveillance and is intended to be consistent with expected fuel cycle lengths. t This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor at a load equivalent to limit will not invalidate the test. The reason for Note 2 is that during 90% to 100% of the operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could i[nsert Noe 2, challenge continued steady state operation and, as a result, unit safety fro pag sems..Note 3 ensures that the 4blG is tested under load conditions that are as close to design basis conditions as possible. When synchronized within the 10 l with offsite power, testing should be performed a-a ower factor []

                                                        . This power factor is representative of the actual inductive loading
                                             *  ~     uG would see under design basis accident conditions.1 Under certain                      outdethe The power factor Imit     conditions, however, Note 3 allows the Surveillance to be conducted a a                         lipoiw at is_ 0.85 for EDG 1 and < 0.86 for EDG2j      power factor o rhan _ [0.9]ý These conditions occur when grid voltage wt  "'is               high, and the additional field excitation needed to get the power factor'tial                              1 results in voltages on the        Teme rn      us]s that are too high.                               CO tUnder       these conditions, the power factor should be maintained as close e         as practicable t [0 1while still maintaining acceptable voltage limits on emer          buses. In other circumstances, the grid voltage may be                             l Lasuch          t         DG excitation levels needed to obtain a power factor of may not cause unacceptable voltages on the femerencybusses, but the M.9]ý  rt           )

excitation levels are in excess of those recommended for the DG. In such BWOG STS B 3.8.1-27 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 89 of 323

Attachment 1, Volume 13, Rev. 0, Page 90 of 323 B 3.8.1 ( INSERT 9 Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. Insert Page B 3.8.1-27 Attachment 1, Volume 13, Rev. 0, Page 90 of 323

Attachment 1, Volume 13, Rev. 0, Page 91 of 323 I All changes are unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) cases, the power factor shall be maintained as close as practicable to

                               ,0    ] without exceeding the4DG excitation limits. *his restriction from E--.-/ normally performing the Surveillance in MODE *or 2 is further amplified the power factor limit 0

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 M ove to Page determines plant safety is maintained or enhanced. This assessment 7-B M.8oe7 as shall, as a minimum, consider the potential outcomes and transients INote 2 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.1 The minimum voltage limit is based on the SR 3.8.1. 0 voltage required for EDG This Surveillance demonstrates that the diesel engine can restart from a breaker closure and the hot condition, such as subsequent to shutdown from normal minimum frequency limit is based on the recommendations of afety Guide g (Ref. 11). Surveillances, and achieve the required voltage and frequency within Mj10 secondE The M10 seconcd]time is derived from the requirements of 0 the accident analysis to respond to a design basis large break LOCA.

74-ST 10 SThe is consistent with the ýrecommendations ofl month Frequency Regulatory Guide 1/108 (Ref. 9), paragraph 2.a. 5).I 0

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the4fG. Routine overloads may result in more frequent teardown inspections, in accordance with vendor recommendations, in order to maintain+DG OPERABILITY. The 1-( requirement that the diesel has operated for at least our@ at,f ull load (-) conditions prior to performance of this Surveillance is based on [approximately Imanufacturer re endations or achieving hot on itions. Momentary stbl transients due to changing bus loads do not invalidate this test. Note 2 stabilized Jalo aG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing. BWOG STS B 3.8.1-28 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 91 of 323

Attachment 1, Volume 13, Rev. 0, Page 92 of 323 B 3.8.1 (D INSERT 10 based on engineering judgment and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. Insert Page B 3.8.1-28 Attachment 1, Volume 13, Rev. 0, Page 92 of 323

Attachment 1, Volume 13, Rev. 0, Page 93 of 323 I All changes are unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.1.16 As required by Regula ry Guide 1.108 (Ref. 9), paragrap 2.a.(6), this Surveillance ensures t at the manual synchronization an automatic load transfer from the DG t the offsite source can be made a d the DG can be returned to ready load status when offsite power is estored. It also ensures that the aut -start logic is reset to allow the DG o reload if a subsequent loss of site power occurs. The DG is con idered to be in ready to load status when the DG is at rated speed and oltage, the output breaker is o en and can receive and auto-close ignal on bus undervoltage, and he load sequence timers are reset. The Frequency of [18 months] is consistent with the r commendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), a d takes into consideration uni conditions required to perform the urveillance. This SR is modi ied by a Note. The reason for the N te is that performing the Surveillan would remove a required offsite cir uit from service, perturb the ele trical distribution system, and challe ge safety systems. This restriction from normally performing the Surveilance in MODE 1 or 2 is further amp fied to allow the Surveillance to be erformed for the purpose of re stablishing OPERABILITY (e.g., po t work testing following I corrective m intenance, corrective modification, d ficient or incomplete surveillance esting, and other unanticipated OPE ABILITY concerns) provided an ssessment determines plant safety maintained or enhanced. his assessment shall, as a minimu , consider the potential outcomes nd transients associated with a faile Surveillance, a successful Surveillance, and a perturbation of t offsite or onsite system when they are tied together or operated indepe dently for the Surveillan e; as well as the operator procedur available to cope with these out omes. These shall be measured ag inst the avoided risk of a plant sh down and startup to determine that lant safety is maintained or enhanc d when the Surveillance is performe in MODE 1 or 2. Risk insights or deterministic methods 'may be use for this assessment. Credit ay be taken for unplanned events th t satisfy this SR. I SR 3.8.1.177 Demonstration of t test mode override ensures that e DG availability under accident c ditions will not be compromised a the result of testing and the DG will utomatically reset to ready to load peration if a LOCA actuation sig I is received during operation in th test mode. Ready to load operati n is defined as the DG running at r ed speed and voltage with the D output breaker open. These provi ions for automatic switchov r are required by IEEE-308 (Ref. 1 , paragraph 6.2.6(2). 0 BVWOG STS B 3.8.1-29 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 93 of 323

Attachment 1, Volume 13, Rev. 0, Page 94 of 323 I AC Sources - Operating All changes are a unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) The requirement to auto atically energize the emergency lo ds with offsite power is essential identical to that of SR 3.8.1.12. he intent in the requirement associa ed with SR 3.8.1.17.b is to show th t the emergency loading was not affected by the DG operation i test mode. In lieu of actual demonstr tion of connection and loading of I ds, testing that adequately shows he capability of the emergency Ioa s to perform these functions is acc ptable. This testing may include a y series of sequential, overlappinr, or total steps so that the entire c nnection and loading sequence is erified. The [18 month] Freq ency is consistent with the recom endations of Regulatory Guide 1 08 (Ref. 9), paragraph 2.a.(8), tak s into consideration unit c nditions required to perform the Su eillance, and is intended to be con istent with expected fuel cycle leng s. This SR is modifi by a Note. The reason for the No is that performing the Surveillance ould remove a required offsite circut from service, perturb the electr cal distribution system, and challen e safety systems. This restriction fr im normally performing the Surveill nce in MODE 1 or 2 is further amplifi d to allow portions of the Surveillan e to be performed for the purpose f reestablishing OPERABILITY (e. ., post work testing following correc tive maintenance, corrective modific tion, deficient or 0 incomplete su eillance testing, and other unanticip ted OPERABILITY concerns) pro ided an assessment determines pla t safety is maintained or enhanced. This assessment shall, as a minimu , consider the potential out mes and transients associated with a failed partial Surveillance a successful partial Surveillance, an a perturbation of the offsite or on ite system when they are tied togeth r or operated independen ly for the partial Surveillance; as wel as the operator procedures available to cope with these outcom s. These shall be measured gainst the avoided risk of a plant sh tdown and startup to determine hat plant safety is maintained or enh nced when portions of the Surveillance are performed in MODE 1 or 2 Risk insights or determini tic methods may be used for the ass ssment. Credit may be taken for unplanned events that satisfy this SP. ] BVVOG STS B 3.8.1-30 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 94 of 323

Attachment 1, Volume 13, Rev. 0, Page 95 of 323 I All changes are unless otherwise noted 9 AC 'Sources - Operating B 3.8.1 BASES SURVEILLANC E REQUIREMENTS (continued) and emergency time delay relays 6 (i.e., the makeup 10

                                       ,SR   3.8.1.wi,__th                                                                   pump relays)
                                      'Under accident F[a_*loss of offsite poweajconditions loads are                  D7                   (D sequentially connected to the bus by the atati                     load sequence          The      J sequencing logic controls the permissive and starting signals to motor Sbreakers to prevent overloading of the4DGs due to high motor starting currents. The r10d/o load sequence time interval tolerance ensures that                               (D

[ sufficient time exists for the4DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of[F buses. lays ~-.---- esseniiitial J--* The Ibsd nenierigudmnt aing consid atory Guide eguFrequency of 1.1 d18 ithsi paragraph wtoe (Ref. 9,is consisrend 2a/.(2),. recommendations the takes Fin-Surveillance Fa-f otJ KU) ove to aer- to perform the SR 3.8.1.5 on, consideration unit conditions required Page B 3.8.1-17 Iintended to be co/nsistent with expected/fuel cycle lengthsl This SR is modified by a Note. The reason for the Notý is that performing the Surveillance woul remove a required offsite circuit from service, perturb the electrical istribution system, and challeng/ safety systems. This restriction from ormally performing the Surveillqhce in MODE 1 or 2 is further amplified to allow the Surveillance to be peýormed for the purpose of reestabli hing OPERABILITY (e.g., post ,ork testing following corrective maintena ce, corrective modification, def ient or incomplete surveillance testing, and other unanticipated OPER BILITY concerns) provided an asses ent determines plant safety is maintained or enhanced. This a essment shall, as a minimum, consider the potential 0 outcomes and trarý ients associated with a failed urveillance, a successful Surveil ance, and a perturbation of the offsite or onsite system when they are tie together or operated indepen ently for the Surveillance; as ell as the operator procedures available to cope with these outcomes. These shall be measured agai st the .avoided risk of a plant shutdown nd startup to determine that pl nt safety is maintained or enhanced when the Surveillance is performed' MODE 1 or 2. Risk insights or dete ministic methods may be used for this assessment. Credit may be t ken for unplanned events thaf satisfy this SR. BWVOG STS B 3.8.1-31 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 95 of 323

Attachment 1, Volume 13, Rev. 0, Page 96 of 323 B 3.8.1 (O INSERT 11 Operating experience has shown that these components usually pass the SR when performed at the 31 day Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. Insert Page B 3.8.1-31 Attachment 1, Volume 13, Rev. 0, Page 96 of 323

Attachment 1, Volume 13, Rev. 0, Page 97 of 323 I All changes are unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

                                                                       -REVIEWER'S NOTE The above MODE res rictions may be deleted if it can be emonstrated to the staff, on a plant s ecific basis, that performing the SR with the reactor in any of the restricte MODES can satisfy the following riteria, as applicable:

a. Performance of he SR will not render any safety sy. ter or component ino erable, 0

b. Performance o the SR will not cause perturbation to any of the electrical distri ution systems that could result in a challenge to steady state o eration or to plant safety systems, nd

c. Performance of the SR, or failure of the SR, will n t cause, or result in, an AOO ith attendant challenge to plant safe systems.

SR 3.8.1A 0 In the event of a DBA coincident with a loss of offsite power, theDGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded. This Surveillance demonstrates thebDG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with aht'M actuation signal. In lieu of actual For this test, the EDG demonstration of connection and loading of loads, testing that adequately loading logic includes shows the capability of the;OG system to perform these functions is [] both the load sequencerI and the individual time acceptable. This testing may include any series of sequential, delay relays for the overlapping, or total steps so that the entire connection and loading makeup pumps. sequence is verified. The Frequency ofM monthsl]takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with 0 an expected fuel cycle length of monthe 0 This SR is modified by two Notes. The reason for Note 1 is to minimize E wear and tear smson e rthe*sFrh Gs during testing. For the purpose offti this testing, the Gs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained BWOG STS B 3.8.1-32 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 97 of 323

Attachment 1, Volume 13, Rev. 0, Page 98 of 323 K All changes are unless otherwise noted 9 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) consistent with manufacturer recommendations fol4DGs. 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 safety systems. This restriction from normally performing the Surveillance in MODE 1,a 2Fis further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing                   D    .

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 enhance 3or4 when portions of the Surveillance are performed in MODE l- 2.K Risk insights or deterministic methods may be used for the assessment. 0 Credit may be taken for unplanned events that satisfy this SR. SR 3.8.1.20 This Surveillance de rinstrates that the DG starting id endence has not been compromis d. Also, this Surveillance demon rates that each engine can achieve roper speed within the specified 'me when the DGs are started simulta eously. The 10 year Fre uency is consistent with the reco endations of Regulatory Gui e 1.108 (Ref. 9). This SR is m dified by a Note. The reason for th Note is to minimize wear on the G during testing. For the purpose of this testing, the DGs must be st rted from standby conditions, that i , with the engine coolant and oil co tinuously circulated, and temperatu e maintained consistent with ma facturer recommendations. BWOG STS B 3.8.1-33 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 98 of 323

Attachment 1, Volume 13, Rev. 0, Page 99 of 323 AC Sources - Operating B 3.8.1 BASES REFERENCE* S 1. 10 CFR 50, Appendix A, GDC 17. [] 2.- FSAR, tSection 8.3.1.1 00

3. Regulatory Guide 1.9, Rev. 3.

I4..

             Ž5. i
                        ,FSAR, FSAR, haPer ater 1                                                                                  }00 6;      Regulatory Guide 1.93, Rev.                J   [e                                                      0 December 1I73 7       C'*n~rir' I ,ff*r RA._1

8. 10 CFR 5b. Appendix A. )DC

                                                         -NRC    Safety Evaluation for Amendment 206, dated February 26, 1996.

18.1 0 9.S l~eglatrySection 8.

9. IRegulatory G~Ade 1.108, Rev. [1], [i9*Jgust 1977].1 0

10. Regulatory Guide 1.137, Rev.*]

111. ANSI C84.1,41982.1 J L- tr1 9 7 9 0

12. ASME Code for Operation and Maintenance of Nuclear Power 0 Plants.

113. IEVE Standard 3qB-[1978].j

                     ý 11. Safety Guide 9, March 10. 1971. 1         --    13. IEEE 387-1995.

BWOG STS B 3.8.1-34 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 99 of 323

Attachment 1, Volume 13, Rev. 0, Page 100 of 323 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, system description, analysis, or licensing basis description.

2. Changes are made to reflect the Specification.

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

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

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

6. Changes have been made to be consistent with similar phrases in other Bases.

7. Grammatical/editorial error corrected.

8. Changes are made to indicate the correct reference rather than to refer to the Reference number only.

9. The proper title is provided for ITS 3.8.9, "Distribution Systems - Operating."

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

11. The qualified offsite circuit is described in this LCO section. Therefore, a reference to a description in the FSAR is not needed.

12. Editorial clarification consistent with TSTF-402T.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 100 of 323

Attachment 1, Volume 13, Rev. 0, Page 101 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 101 of 323

Attachment 1, Volume 13, Rev. 0, Page 102 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 102 of 323

, Volume 13, Rev. 0, Page 103 of 323 ATTACHMENT 2 ITS 3.8.2, AC SOURCES - SHUTDOWN , Volume 13, Rev. 0, Page 103 of 323
, Volume 13, Rev. 0, Page 104 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 104 of 323

Attachment 1, Volume 13, Rev. 0, Page 105 of 323 ITS 3.8.2 ITS ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERA'TION LCO 3.8.2 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 I E AC. electrical power distribution system.] and M02

b. 10n deselgenerator 'ich:

SIR 3.8.2.1 I. Day fuel tank containing a minimum volume of4000 gallons of fuel,

12. A fuel storagesystem containing a minimum volume of 32.000 gallons of fuel, and See ITS ]

APPLICABILITY: MODES 5 and 6. D Ac rAdd proposed Add proposed ACTION A Note 'Add proposed Required Action A.1 ACTIONS A With less than the above minimum required AC. electical power sources OPERABLE, suspe and B all operations involving RAoste reacttvty chaniesLuntil the minimum required A.C. electrical power sources are restored to OPERABLE status. Add proposed Required Actions A.2.3 and B.3 S URVEI LLANCE REQUIREMENTS ________________________________M04 SR 3.8.2.1 4.8.1.2 The above required A.C. electrical power sources shall be the performance of each of the Surveillance Requirements orf M.- requirements 4.8. 1. 1.1 .b, 4.8.1.1.2.a.5, 4.8.1.1 .2.a.7, 4.8.1.1 .2.c.5, DAVIS-BESSE, UNITi 3/4 8-5 Amendment No. 75, 203, 273 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 105 of 323

Attachment 1, Volume 13, Rev. 0, Page 106 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS). These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.8.1.2 does not address the situation when an essential bus is de-energized as a result of the loss of an AC Source to an essential bus. A Note has been added to the Required Actions for an inoperable offsite circuit (ITS ACTION A) which requires entry into the applicable Conditions and Required Actions of LCO 3.8.10 when one required train (essential bus) is de-energized as a result of an inoperable offsite circuit. This changes the CTS by directing entry into LCO 3.8.10. AC Sources are considered a support system to the AC distribution System (ITS 3.8.10) If AC Sources are inoperable such that a distribution subsystem is made inoperable, then ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the AC Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in the event, specific direction to take appropriate ACTIONS for the Distribution System is added (proposed Note to ITS 3.8.2 ACTION A). This format and construction implements the existing treatment of this condition within the framework of the Davis Besse CTS methods. This change is designated as administrative because it does not result in a technical change to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2.a requires one qualified circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown," to be OPERABLE. This changes the CTS by being specific as to what the required circuit must be capable of powering. The purpose of CTS 3.8.1.2.a is to ensure the offsite circuit is OPERABLE in order to supply the equipment supported by the onsite Class 1 E distribution system. The existing requirement of CTS LCO 3.8.1.2.a for one qualified offsite circuit to be OPERABLE during shutdown conditions is not specific as to what that circuit must be powering. The requirement in ITS LCO 3.8.2.a specifies that the circuit must be available to supply power to all equipment required to be OPERABLE in the current plant conditions. This change is acceptable since the added restriction conservatively assures the needed offsite circuit is powering all AC loads required to be OPERABLE. This change is designated as more restrictive because more explicit offsite circuit requirements have been added. Davis-Besse Page 1 of 7 Attachment 1, Volume 13, Rev. 0, Page 106 of 323

Attachment 1, Volume 13, Rev. 0, Page 107 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN M02 CTS 3.8.1.2.b requires one EDG to be OPERABLE. ITS LCO 3.8.2.b requires one EDG capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. This changes the CTS by being specific as to what the required EDG must be capable of powering. The purpose of CTS 3.8.1.2.b is to ensure the EDG is OPERABLE. This change provides an explicit requirement as to what the required EDG must be capable of powering. Similar to the added restrictions for an OPERABLE offsite circuit (refer to DOC M01 above), the single unit EDG required OPERABLE during shutdown conditions by CTS 3.8.1.2.b is not specific as to what train that EDG must be associated with. The requirements in ITS LCO 3.8.2.b will ensure the OPERABLE EDG is associated with one or more systems, subsystems, or components required to be OPERABLE. This added restriction enforces a level of Technical Specification control which currently is enforced only by administrative procedures. This change is designated as more restrictive because more explicit EDG requirements have been added. M03 CTS 3.8.1.2 is applicable during MODES 5 and 6. ITS 3.8.2 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies. In addition, a Note has been added to the ACTIONS of ITS 3.8.2 which states that LCO 3.0.3 is not applicable. This changes the CTS by requiring the AC Sources to be OPERABLE under more conditions than is currently required. The purpose of CTS 3.8.1.2 is to ensure that sufficient AC Sources are available to mitigate the consequences of an analyzed event during shutdown modes. This change provides an explicit requirement that the AC Sources must be OPERABLE during the movement of irradiated fuel assemblies. The movement of irradiated fuel assemblies may occur during MODE 5 or 6, however the operations could also occur while the unit is operating if moving fuel only in the spent fuel pool. CTS 3.8.1.1 (ITS 3.8.1) and CTS 3.8.1.2 do not provide the appropriate compensatory actions under this condition. The activity should be suspended immediately when the AC Sources are not available consistent with the immediate actions for CORE ALTERATIONS in the CTS 3.8.1.2 Action; that is the actions in LCO 3.0.3 will not place the unit in a safe condition. This change is acceptable because the proposed Applicability is consistent with the Applicability in the AC Distribution System - Shutdown Specification (CTS 3.8.2.2 and ITS 3.8.10). AC Sources provides the power for the AC Distribution System. This change is designated as more restrictive because the Applicability of the Specification has been expanded. M04 The CTS 3.8.1.2 Action requires the suspension of CORE ALTERATIONS and positive reactivity changes when a required AC Source is inoperable. It does not include an action to restore the inoperable AC Source. ITS 3.8.2 Required Actions A.2.3 and B.3 require the immediate initiation of action to restore the required AC Sources to OPERABLE status. This changes the CTS by adding explicit requirements to restore the inoperable AC Sources to OPERABLE status. The purpose of ITS 3.8.1.2 Required Actions A.2.3 and B.3 is to place the unit within the requirements of the LCO. When a required offsite circuit or a required EDG is inoperable, the actions imposed by the CTS 3.8.1.2 Action do not Davis-Besse Page 2 of 7 Attachment 1, Volume 13, Rev. 0, Page 107 of 323

Attachment 1, Volume 13, Rev. 0, Page 108 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN necessarily place the unit in a MODE or other specified condition in which CTS LCO 3.8.1.2 is not applicable. Therefore, proposed ITS 3.8.2 Required Actions A.2.3 and B.3 are being added. These Required Actions implement a requirement to immediately initiate action to restore the required AC Sources to an OPERABLE status. These additional restrictions are consistent with implicit assumptions and will ensure action is immediately taken to restore compliance with the LCO requirements. This change is designated as more restrictive because the Required Actions do not exist in the CTS. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Category 1 - Removing Details of System Design and System Description Including Design Limits) CTS LCO 3.8.1.2.b specifies that an EDG be OPERABLE with a fuel transfer pump. ITS LCO 3.8.2.b requires an OPERABLE EDG capable of supplying one train of the onsite Class 1 E power distribution subsystem(s). This changes the CTS by moving the details that an OPERABLE EDG requires "a fuel transfer pump" from the CTS to the 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. The ITS still retains the requirements for an OPERABLE EDG and that the fuel oil transfer system operates automatically to transfer fuel oil from the storage tank to the day 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 Specifications 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 L01 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 Action requires the suspension of certain activities when the required AC Source is inoperable. ITS 3.8.2 provides an alternate Required Action (ITS 3.8.2 Required Action A.1) that allows the declaration of affected required feature(s) with no offsite power available inoperable instead of requiring the specified activities to be suspended. This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending the specified activities. The purpose of CTS 3.8.1.2 is to ensure the appropriate offsite circuit is OPERABLE. This change is acceptable because the Required Actions are used Davis-Besse Page 3 of 7 Attachment 1, Volume 13, Rev. 0, Page 108 of 323

Attachment 1, Volume 13, Rev. 0, Page 109 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN to establish remedial measure 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 loss of offsite power occurring during the repair period. This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending specified activities (i.e., movement of irradiated fuel assemblies). Since the ITS 3.8.2 circuit OPERABILITY requirements are proposed to require supplying power to all required electrical power distribution subsystems, if one or more subsystems are not powered by an offsite circuit, that circuit is inoperable. Conservative actions can be assured if all required equipment with offsite power is declared inoperable and the associated ACTIONS of the individual equipment taken (ITS 3.8.2 Required Action A.1). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L02 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 Action specifies the compensatory action for an inoperable required AC Source. One of the compensatory actions is the suspension of CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 does not require suspension of CORE ALTERATIONS. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when a required AC source is inoperable. The purpose of the CTS 3.8.1.2 Action to suspend CORE ALTERATIONS is to minimize the possibility of an event that may need the AC source to mitigate the consequences of the event. CORE ALTERATION is defined in CTS 1.12, in part, as "the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed - it only applies in MODE 6. There is only one accident considered during MODE 6 that involves a CORE ALTERATION: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.2 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.2 Required Action A.2.1 (for an inoperable required offsite circuit) and Required Action B.1 (for an inoperable required EDG). Therefore, since the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of a AC source is covered by the ITS Required Actions, deletion of the term "CORE ALTERATIONS" is acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L03 (Category 4 - Relaxation of RequiredAction) The CTS 3.8.1.2 Action specifies the compensatory action for an inoperable required AC Source. One of the compensatory actions is the suspension of positive reactivity "changes." ITS 3.8.2 Required Action A.2.2 (for an inoperable required offsite circuit) and Davis-Besse Page 4 of 7 Attachment 1, Volume 13, Rev. 0, Page 109 of 323

Attachment 1, Volume 13, Rev. 0, Page 110 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN Required Action B.2 (for an inoperable required DG) require the immediate suspension of operations involving positive reactivity "additions that could result in loss of required SDM or boron concentration." This changes the CTS compensatory actions by allowing positive reactivity changes as long as SDM and boron concentration limitations are met. The purpose of the CTS 3.8.1.2 Action is to suspend any positive reactivity additions that could affect the SDM of the reactor core. 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 affected 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 requirements for SDM are specified in ITS LCO 3.1.1 while the requirements for boron concentration are specified in ITS LCO 3.9.1. The proposed actions may result in an overall reduction in SDM or RCS boron concentration, but provide acceptable margin to maintaining subcritical operation. The proposed Required Action is to suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. These limitations are considered acceptable. The ITS 3.8.2 Bases also state that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must be evaluated to ensure the temperature change does not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L04 (Category 7- Relaxation of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.2 requires the AC electrical power sources to 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 4.8.1.1.1 .b, 4.8.1.1.2.a.5, 4.8.1.1.2.a.7, 4.8.1.1.2.c.5, 4.8.1.1.2.c.7, and 4.8.1.1.2.d.2. ITS SR 3.8.2.1 has included a similar allowance in the Note to SR 3.8.2.1. However, additional ITS SRs are exempt from being required to be performed. ITS SR 3.8.2.1 states the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.14. This changes the CTS by not requiring the performance of CTS 4.8.1.1.2.d.1 (ITS SR 3.8.1.10) and CTS 4.8.1.1.2.d.3 (ITS SR 3.8.1.13). The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. Currently CTS 4.8.1.1.1 .b, 4.8.1.1.2.a.5, 4.8.1.1.2.a.7, 4.8.1.1.2.c.5, 4.8.1.1.2.c.7, and 4.8.1.1.2.d.2 are not required to be performed (however they must be met). CTS 4.8.1.1.2.d.1 (ITS SR 3.8.1.10) is the EDG single largest load reject test and CTS 4.8.1.1.2.d.3 (ITS SR 3.8.1.13) is the EDG 8 hour run test. These two tests normally require the EDG to be paralleled with offsite power. This condition (the only required EDG and the only required offsite source connected) presents a significant risk of a single fault resulting in station blackout. The NRC has Davis-Besse Page 5 of 7 Attachment 1, Volume 13, Rev. 0, Page 110 of 323

Attachment 1, Volume 13, Rev. 0, Page 111 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN previously recognized this in the exception stated in CTS 4.8.1.2. In an effort to consistently address this concern and to avoid potential conflicting Technical Specifications, the Surveillances that would require the EDG to be connected to the offsite source or would require disconnection of the required offsite circuit and deenergization of required buses are excepted from performance requirements. The exception does not take the requirement for the EDG to be capable of performing the particular function, just to the requirement to demonstrate it while that source of power is being relied on to meet the supporting LCO. This change is acceptable since it is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the EDG and the offsite circuit are required to be OPERABLE. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. L05 (Category5 - Deletion of Surveillance Requirements) CTS 4.8.1.2 requires the AC electrical power sources to 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 4.8.1.1.1 .b, 4.8.1.1.2.a.5, 4.8.1.1.2.a.7, 4.8.1.1.2.c.5, 4.8.1.1.2.c.7, and 4.8.1.1.2.d.2. ITS SR 3.8.2.1 has included a similar allowance in the Note to SR 3.8.2.1. However, the ITS is exempting SRs from being required to be met, not just exempting them from being performed. ITS SR 3.8.2.1 states the following SRs are not required to be met: SR 3.8.1.7, SR 3.8.1.9, and SR 3.8.1.15. This changes the CTS by not requiring CTS 4.8.1.1.1.b (ITS SR 3.8.1.9), CTS 4.8.1.1.2.a.7 and 4.8.1.1.2.c.7 (ITS SR 3.8.1.7), and CTS 4.8.1.1.2.d.2, including parts (a) and (b) (ITS SR 3.8.1.15) to be met. The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated OPERABLE. 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. This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.1.b (ITS SR 3.8.1.9), the offsite source transfer verification test, CTS 4.8.1.1.2.a.7 and 4.8.1.1.2.c.7 (ITS SR 3.8.1.7), the load sequencer test, and CTS 4.8.1.1.2.d.2, including parts (a) and (b) (ITS SR 3.8.1.15), the SFAS/loss of offsite power signal test. ITS SR 3.8.1.9 is not required to be met since only one offsite circuit is required to be OPERABLE by ITS 3.8.2. Therefore, requiring the automatic and manual transfer capability from one offsite circuit to the other offsite circuit to be OPERABLE is not applicable. ITS SR 3.8.1.7 and ITS SR 3.8.1.15 are not required to be met since the SFAS signal is not required to be OPERABLE in the MODES or other specified conditions listed in the Applicability of ITS 3.8.2 (as shown in ITS 3.3.5). The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODE 5 and 6. The EDGs are required to support the equipment powered from the essential buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the EDG to autostart on an SFAS actuation signal. In addition, the SFAS actuation signal is only an anticipatory start signal; the EDGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The EDGs are also required to start if a loss of offsite power occurs. The requirement to autostart the required EDG(s) on a Davis-Besse Page 6 of 7 Attachment 1, Volume 13, Rev. 0, Page 111 of 323

Attachment 1, Volume 13, Rev. 0, Page 112 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.11). Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the EDGs to be capable of automatically starting on an SFAS actuation signal (either by itself or concurrent with a loss of offsite power signal). This change is designated as less restrictive because Surveillance which are required in CTS will not be required in the ITS. Davis-Besse Page 7 of 7 Attachment 1, Volume 13, Rev. 0, Page 112 of 323

Attachment 1, Volume 13, Rev. 0, Page 113 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 113 of 323

Attachment 1, Volume 13, Rev. 0, Page 114 of 323 CTS AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - .Shutdown LCO 3.8.1.2 LCO 3.8.2 The following AC electrical.power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1 E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown " and 0

0

b. One diesel generator "G) cpable of supplying one train of the onsite Class 1 E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of [rectly] irradiated fuel assemblies. 0 ACTIONS

           -----------------------------------------------------------      NO DOC M03   LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME Action A. One required offsite ---------------- NOTE ---------- circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A. A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable. OR BWOG STS 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 114 of 323

Attachment 1, Volume 13, Rev. 0, Page 115 of 323 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Action A.2 .L1 Suspe d CORE ALTERATIONS. AND / Suspend movement of Immediately ©TT~ VA.2.1 [ assemblies. irradiated fuel 0 AN D A.2. Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration. AND A.2. Initiate action to restore Immediately required offsite o er circuit to OPERABLE 0 status.

                                                                                                   -4712TF Action EZh B. One required4DG       B.1       Suspe Id CORE                                                   0 inoperable.

AND ALTE /ATIONS. D B. Suspend movement of Immediately [iec ly] irradiated fuel a lies. 0 AND Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration. AND BWVOG STS 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 115 of 323

Attachment 1, Volume 13, Rev. 0, Page 116 of 323 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued) CONDITION 'REQUIRED ACTION COMPLETION TIME Action

                                                                                                               -41ýTSTF~
                                                   'Initiate action to restore       Immediately Bý        requiredOG_.to OPERABLE status. L{LJ SURVEILLANCE REQUIREMENTS SURVEILLANCE                                          FREQUENCY 4.8.1.2  SR 3.8.2.1                                   NOTE------------------------

The following SRs are not required to be performed: 12, 3.8. 1. SRýiý ý

SR3.8. 1.*q:

R 3.8.1.3, SR 3.8.1 t r u R 3.8.1.11, 10, I[SR 3..118 T-s .13 and1 For AC sources required to be OPERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources - Operating," with applicable except R 3.8.1w SR .. 1.17,1 SRs SR38 F are applicable. t I

}0

15 D BWVOG STS 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 116 of 323

Attachment 1, Volume 13, Rev. 0, Page 117 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

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

4. The SRs have been changed to be consistent with the changes made to the Surveillance Requirements in ITS 3.8.1. In addition, ISTS SR 3.8.1.18 (ITS SR 3.8.1.6) has been deleted from the Note to SR 3.8.2.1 and added to those Surveillances not required to be met. ISTS SR 3.8.1.18 (ITS SR 3.8.1.6) is the verification that the interval between each sequenced load block is within + 10% of design interval for each load sequencer and emergency time delay relay. The load sequencers actuate under a Safety Features Actuation System (SFAS) signal coincident with a loss of offsite power. The SFAS signal is not required to be OPERABLE in the MODES or other specified conditions listed in the Applicability of ITS 3.8.2 (as shown in ITS 3.3.5).

5. Change made to be consistent with the nomenclature in ISTS LCO 3.8.2 and Condition A.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 117 of 323

Attachment 1, Volume 13, Rev. 0, Page 118 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 118 of 323

Attachment 1, Volume 13, Rev. 0, Page 119 of 323 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 5 and 6 SAFETY and during movement of rec ty irradiated fuel assemblies ensures ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended period 0

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statu*]ad0

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to/Iradioactive decay, AC electrical powet is only required to mitigate fu I handling accidents involvino handling recently irradiated f Lel (i.e., fuel that has 0 occupied part of a/critical reactor core within the brevious [x] 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 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, 3, and 4 have no specific analyses in MODES 5 and 6. Worst-case bounding events are deemed not credible in MODES 5 and 6 because the energy contained 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. BWOG STS B 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 119 of 323

Attachment 1, Volume 13, Rev. 0, Page 120 of 323 AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued) During MODES 1, 2, 3, and 4 various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 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 -consideratio1ý 0

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 operating MODE analyses, or botlI.ýt

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

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, emergency assuming either a loss of all offsite power or a loss of all onsite~iesel TO generator DG) power. TH AC ýources satisfýrtin 3 of 10 CFR 50.36(c)(2)(ii). LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems - Shutdown ,"ensures that all required loads are powered from offsite power. An OPERABLEýDG, associated with a distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and- G ensures the availability of sufficient AC sources to operate the unit in a safe manner and to mitigate the consequences of postulated 0 events during shutdown (e.g., fuel handling accidents [involvin andling Irecently iTB382ted fuel]v. BWVOG STS B 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 120 of 323

Attachment 1, Volume 13, Rev. 0, Page 121 of 323 AC Sources - Shutdown B 3.8.2 BASES LCO (continued) The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Sa eature (ESF) bus(es). aualified offsite circuits are those that ar i-*ed in the FSAR and are art of the licensing basis for t Offsite circuit #1 co sists of Safeguards Transformer , which is supplied from Switchyard Bu B, and is fed through breaker 54 -3 powering the ESF transformer X B01, which, in turn, powers the 1IESF bus through its normal feeder b eaker. The second offsite circuit consists of the I ( Startup Transform r, which is normally fed from the witchyard Bus A, and is fed through breaker PA 0201 powering the SF transformer, which, in turn, po ers the #2 ESF bus through its n rmal feeder breaker.] The DG must be capable of starting, acceleratin to rated speed and (loss of voltage or voltage, and connecting to its respective E F us on detection of bus degraded voltage) undervoltagL4. This sequence must be accomplished within 101d]seconds. (shutdown loadssow 1

                                        -    TheDG must be capable of accepting required joads wthin th                  sumed are started                               loadin se            e intervals, and must continue to operate until offsite through tim edelayindividual relays)               essetia  power can be restored to th. E.. F buses. These capabilities are required timea        ry)                    ea        to be met from a variety of initial conditions such as+DG in standby with            L-the engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of non-essential loads, is a required function fortDG OPERABILITY. 0 [In addition, proper *equencer operation is an integral part of offsite circuit OPERABILITY sin e its inoperability impacts on the bility to start and maintain energiz/ loads required OPERABLE by ICO 3.8.10.] 0 It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains. APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of re ty irradiated fuel assemblies provide 0 assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblie 0 BVWOG STS B 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 121 of 323

Attachment 1, Volume 13, Rev. 0, Page 122 of 323 B 3.8.2 INSERT 1 A qualified offsite to onsite circuit consists of either one 345 - 13.8 kV startup transformer or one main transformer and one unit auxiliary transformer with the generator links removed (i.e., in backfeed alignment), one 13.8 kV bus, one 13.8 - 4.16 kV tie transformer, and the respective circuit path, including the non-essential bus and feeder breakers, to one 4.16 kV essential bus. Insert Page B 3.8.2-3 Attachment 1, Volume 13, Rev. 0, Page 122 of 323

Attachment 1, Volume 13, Rev. 0, Page 123 of 323 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

b. Systems needed to mitigate a fuel handling accident [involving handling recently ifradiated fuel (i.e., fuel thqt has,occupied part of a ý 0 critical reactor coro within the previous [X] ays)] are availabler 0

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are availabl~and J

I 0

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

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1. ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, 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 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily. A.1 if An oneoffsite circuit required would be co~nsidered rE77-train. t two inoperable if it wereby trains are required notLCO available 3.8.10,to 3" the one train with offsite power available may be capable of supporting 0 TSTF sufficient required features to allow continuation of CORE AL ATIONS -471 an r enty irradiated fuel movement. By the allowance of the option to (D declare features inoperable with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS. BWOG STS B 3.8.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 123 of 323

Attachment 1, Volume 13, Rev. 0, Page 124 of 323 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) A.2.1, A.2.2, A.2.3,ýB.1, B.2,_F--*lR With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently ((D> conservative actions is made. With the require&DG inoperable, *the t-- minimum required diversity of AC power sources is not available. It is, --- STF) therefore, required to suspend CORE AL TIONS, movement of I, 2 -471 [ t irradiated fuel assemblies[Dand operations involving positive 0 reactivit additions that could result in loss of required SDM (MODE 5) or ET3 boron concentration (MODE 6 Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron 0 concentration limit is required to assure continued safe operation. Reactor Introduction of coolant inventory must be from sources that have a boron Csoolat concentration greater than that what would be required in theC forCSystem minimum SDM or refueling boron concentration. This may result in an *J overall reduction in RCS boron concentration, but provides acceptable moderator teperr cmargin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM. 0) Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit 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 sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power. Pursuant to LCO 3.0.6, the Distribution System's ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are essential modified by a Note to indicate that when Condition A is entered with no AC power to any required7 bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 provides the appropriate restrictions for the situation involving a de-energized train. BVVOG STS B 3.8.2-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 124 of 323

Attachment 1, Volume 13, Rev. 0, Page 125 of 323 B 3.8.2 O INSERT 2 specified in LCO 3.1.1, "Shutdown Margin (SDM)," 0 INSERT 3 specified in LCO 3.9.1, "Boron Concentration." Insert Page B 3.8.2-5 Attachment 1, Volume 13, Rev. 0, Page 125 of 323

Attachment 1, Volume 13, Rev. 0, Page 126 of 323 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for 9 ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 00 3, and 4. SR 3.8.1'7 is not required to be met since only one offsite 6 SafelyFeatures circuit is required to be OPERABLE. SR 3.8.1. nd SR 3.8.1 .M_[_ (SFAS) not required to be met because th- E actuation signal is not required to be OPERABLE. SR 3.8.1.6 is not required to be met be use the required OP1RABLE DG(s) is not required to undergo p riods of being synchronize to the offsite circuit. SR 3.8.1.9 is except/d because 0 starting ind pendence is not.required with the DG(s) th t is not required to be OPE ABLE. FThis SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLEDG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of e SRs, and to preclude deenergizing a required 4160 V[ Fus or disconnecting a required offsite circuit during performance of SRs. With F: limited AC sources available, a single event could compromise both the required circuit and the OG. It is the intent that these SRs must still be [] capable of being met, but actual performance is not required during periods when the OG and offsite circuit is required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR. REFERENCES None. BWAOG STS B 3.8.2-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 126 of 323

Attachment 1, Volume 13, Rev. 0, Page 127 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

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

2. These punctuation corrections have been made consistent with the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

3. Changes are made to the Bases to reflect changes made to the 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. Changes are made to reflect the actual Specification.

6. Editorial change made for clarity and consistency.

7. The qualified offsite circuit is described in this LCO section. Therefore, a reference to a description in the UFSAR is not needed.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 127 of 323

Attachment 1, Volume 13, Rev. 0, Page 128 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 128 of 323

Attachment 1, Volume 13, Rev. 0, Page 129 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 129 of 323

Attachment 1, Volume 13, Rev. 0, Page 130 of 323 ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Attachment 1, Volume 13, Rev. 0, Page 130 of 323

, Volume 13, Rev. 0, Page 131 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 131 of 323

Attachment 1, Volume 13, Rev. 0, Page 132 of 323 ITS 3.8.3 ITS

3/4.8 ELECTRICAL POWER SYSTEMS 314.8.1 A.C. SOURCES QPERATING

                                                               ,//          Add proposed LCO 3.8.3                     A 02 I MITTNGI CONDITION FOR OPERATION LCO 3.8.3   3.8.1.1 /         minimum    he following A.C. electrical power sources shall Ibe OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class IEA.C. electrical power distribution system, and See ITS]

3.8.1

b. Two separate and independent diesel generators each with:

1. A separate day fuel tank containing a minimum volume of 4000 gallons of fuel, SR 3.8.3.1 2. A sepate fuel storage system containing a minimum volume of 32,000 gallons of fuel, and

13. A separate fuel transfer pump. i SeeTS.

APPLICABILITY: IMODES/ 1 22 3 and 4. When associated EDG is required to be OPERABLE A0 ACTION:i Add proposed ACTIONS A, F, and proposed ACTIONS Note L.l

a. Withlone offsite circuit of the above required A.C. electrical I 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 hours thereafter and by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours. Restore at least two offsite circuits to OPERABLE status within 72 hours or be in at least HOT I STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

b. With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the See ITS remaining A.C. sources by performing Surveillance Requirement 3.8.1 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter and by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours. Restore at least two diesel generators to OPERABLE status within 7 days or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

c. With one offsite circuit and one diesel generator of the above I 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 hours thereafter and by performing Surveillance DAVIS-BESSE, UNIT 1 3/4 8-1 Amendment No. 6, 97, 293, 206 Add proposed ACTION BC Add proposed ACTIONS C and D

                                                                  -- Add proposed ACTION E*

Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 132 of 323

Attachment 1, Volume 13, Rev. 0, Page 133 of 323 ITS 3.8.3 ITS ELECTRICAL POWER SYSTEMS ACTION (Continued) Requirement 4.8.1.1.2.a.4 within 8 hours. Restore at least one of the inoperable sources to OPERABLE status within 12 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. 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 hours and in COLD SHUTDOWN within the following 30 hours. With the inoperable diesel generator restored, restore two offsite power sources to OPERABLE status within 72 hours from the time of the initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

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 hours and at least See ITS 3.8.1 once per B hours thereafter, unless the diesel generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours. With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

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.l.1.a within one hour and at least once per 8 hours thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. 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 hours and in COLD SHUTDOWN within the following 30 hours.

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: See ITS

a. Determined OPERABLE at least once per 7 days by verifying correct 3.8.1 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: SR 3.8.3.1

a. At least once per 31 da s, if Surveillance Reduirement 4.8.l.I.2.c A03 Ihas not been performediwithin the previous 31 days, by:

DAVIS-BESSE, UNIT I 3/4 8-2 Amendment No. 97,107,293,295,219 Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 133 of 323

Attachment 1, Volume 13, Rev. 0, Page 134 of 323 ITS 0 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVETILLANCE REOUIREMENTS (Continued) 3.. I1- Ve rf inl the fuel level in the dayfe ak See ITS] SR 3.8.3.1 2_ Verifying the fuel level in the fuel storage tank.

3. Verifying the fuel transfer pump can be started and trans-fers 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, kw, and operates for > 60 minutes.

loaded to _ 1000 See ITS 3.8.1]

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 -r fuel from the fuel storage tank is within the acceptable limits SITS specified Lwater and in Table I of ASTM D975-68 when checked for viscosity,5"""

sealimerit"/_.-/*1Adp1~edS ' SR 3.8.3.1 c. At least once per 1 4 days by:

11. Verifying the fuel level in the day fuel tank. SeeTS 3.8.

SR 3.8.3.1 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 _ 1000 See ITS kw, and operates for > 60 minutes. 3.8.1

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, 19S,203 Add proposed SIR3.8.3. [Add proposed SIR 3.8.3.5-Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 134 of 323

Attachment 1, Volume 13, Rev. 0, Page 135 of 323 ITS 3.8.3 ITS ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIýITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE: a 0 -A ; ' 1 ,na~nzL 'k.LO M; I. dI A U U tiaa iaL : A.C. electrical power distribution system, and See ITSJ 3.8.2

b. One diesel generator with:

I. Day fuel tank containing a minimum volume of 4000 gallons of fuel, SR 3.8.3.1 2. A fuel storage system containing a minimum volume of 32,000 gallons of fuel, and APPILI CABILITY: MODES 5 and 6. ACTIC )N: With icess than the above minimum required A.C. electrical power sources OPERABLE, suspend all operrations involving CORE ALTERATIONS or positive reactivity changes until the minim um required A.C. electrical power sources are restored to OPERABLE status. LSee ITS 3.8.2 J 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 of4.8.1.I.I and 4.8.1.1.2 except for requirements 4.8.1.1.1 .b, 4.8.1.1.2.a.5, 4.8.1.1.2.a.7, 4.8.1.1.2.c.5, 4.8.1 .1 .2.c.7, and 4.8.1.1 .2.d.2. DAVIS-BESSE, UNIT I 3/4 8-5 Amendment No. 75, 203, 273 Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 135 of 323

Attachment 1, Volume 13, Rev. 0, Page 136 of 323 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS). These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.8.1.1 and 3.8.1.2 states the requirements for the AC Sources during operating and shutdown, respectively. These requirements are used to form the LCO and Applicability for the ITS diesel fuel oil Specification. ITS LCO 3.8.3, in part, states that the stored diesel fuel oil shall be within limits for each required EDG. The Applicability for this requirement is when the associated EDG is required to be OPERABLE. This changes the CTS by combining the requirement for diesel fuel oil into one Specification. This change is acceptable because the current requirements are translated into ITS form with no technical changes. Diesel fuel oil is a support system for each EDG. The CTS and ITS maintain this relationship between the EDGs and the Diesel Fuel Oil System 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. A03 CTS 4.8.1.1.2.a and 4.8.1.1.2.a.2 require verifying the fuel level in the fuel storage tank every 31 days, while CTS 4.8.1.1.2.c and 4.8.1.1.2.c.2 require the same verification every 184 days. In addition, CTS 4.8.1.1.2.a includes a statement that CTS 4.8.1.1.2.a.2 is only required if CTS 4.8.1.1.2.c.2 has not been performed within the previous 31 days. ITS SR 3.8.3.1 performs the same verification on a 31 day Frequency. This changes the CTS by combining these two Surveillances into a single Surveillance with a Frequency of 31 days. This change is acceptable because CTS 4.8.1.1.2.c.2 is duplicative of CTS 4.8.1.1.2.a.2. Based on the 31 day requirement of CTS 4.8.1.1.2.a.2, the test would be performed at a 31 day interval, not the 184 day interval of CTS 4.8.1.1.2.c.2. This change is designated as administrative because it does not result in a technical change to the CTS. A04 CTS 4.8.1.1.2.b specifies the requirements for the properties of stored fuel oil. The technical content of CTS 4.8.1.1.2.b is being moved to ITS 5.5.12, "Diesel Fuel Oil Testing Program." A Surveillance Requirement is added (ITS SR 3.8.3.3) to clarify that the tests of the Diesel Fuel Oil Testing Program must also be completed and passed for determining OPERABILITY of the stored diesel fuel oil. The purpose of CTS 4.8.1.1.2.b is to ensure the stored diesel fuel oil properties are consistent with the specified standard. This change simply moves the actual properties to ITS 5.5.12. Any technical changes will be addressed in the Discussion of Changes for ITS 5.5. This change is acceptable since this is a Davis-Besse Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 136 of 323

Attachment 1, Volume 13, Rev. 0, Page 137 of 323 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR presentation preference that maintains current requirements except for those discussed in the Discussion of Changes for ITS 5.5. This change is designated as administrative because it does not result in a technical change to the CTS. MORE RESTRICTIVE CHANGES M01 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 is when the associated EDG is required to be OPERABLE. ITS SR 3.8.3.2 requires a verification that the lube oil inventory is > 260 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 ACTION 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, 260 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 hours, provided sufficient lube oil inventory is available for 6 days. If the lube oil inventory is not restored within 48 hours, or ifthe 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. M02 CTS 3/4.8.1.1 does not provide any requirements for stored diesel fuel oil total particulate level or new diesel fuel oil properties. ITS SR 3.8.3.3 requires a verification that new and stored fuel oil properties are tested and maintained within limits, as specified in the Diesel Fuel Oil Testing Program. This includes stored fuel oil total particulate level and new fuel oil properties. The addition of this SR is discussed in DOC A04. Due to this addition, two new ACTIONS have been added. ITS 3.8.3 ACTION C specifies the compensatory actions for one or more EDG with stored fuel oil total particulates not within limits. ITS 3.8.3 Required Action C.1 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 one or more EDGs with new fuel oil properties not within limits. ITS 3.8.3 Required Action D.1 requires the restoration of the stored fuel oil properties to within limits within 30 days. This changes the CTS by providing explicit ACTIONS for fuel oil total particulates and new fuel oil properties limits not met. The purpose of ITS SR 3.8.3.3 is to provide the appropriate property limits for stored and new fuel oil. This change provides explicit Required Actions and Completion Times for restoring both total particulates and stored fuel oil properties (affected by the addition of new fuel oil whose properties are not within limits) to within limits. ITS 3.8.3 ACTION C is entered as a result of a failure to meet the acceptance criterion of total particulate concentration specified in ITS 5.5.12. Normally, trending of particulate levels allows sufficient time to Davis-Besse Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 137 of 323

Attachment 1, Volume 13, Rev. 0, Page 138 of 323 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 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 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 3.8.3 ACTION D is entered as a result of failure to meet the requirements specified in ITS 5.5.12.b. With the new fuel oil properties defined in the Bases for ITS 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 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 an 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 are included in the Technical Specifications for stored fuel oil total particulates and new diesel fuel oil properties not within limits. M03 The CTS does not provide any starting air receiver pressure requirements. ITS LCO 3.8.3, in part, requires the required starting air receiver pressure to be within limits for each required EDG. The Applicability for this requirement is when the associated EDG is required to be OPERABLE. ITS SR 3.8.3.4 requires verification that the required starting air receiver pressure is > 210 psig for each EDG. ITS 3.8.3 ACTION E provides an ACTION if the limit of ITS SR 3.8.3.4 is not met. This changes the CTS by adding a starting air receiver pressure requirement, and an appropriate ACTION and Surveillance Requirement. The purpose of the starting air receiver pressure requirement in ITS LCO 3.8.3 and SR 3.8.3.4 is to ensure starting air for five diesel air starts for each EDG. The proposed ITS SR 3.8.3.4 value, 210 psig, will ensure the five diesel air start requirement is met. In addition, ITS 3.8.3 ACTION E will allow the five diesel air start requirement to not be met for each EDG for up to 48 hours, provided the required starting air receiver pressure is sufficient for one EDG start. If the required starting air receiver pressure is not restored within 48 hours, or if the required starting air receiver pressure is not sufficient for one start, 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 E 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 starting air receiver pressure for each EDG. M04 While CTS 4.8.1.1.2.b specifies the requirements for the properties of stored fuel oil, the CTS does not provide any specific testing requirements to check for or remove accumulated water from the fuel oil storage tank. ITS SR 3.8.3.5 requires this verification every 31 days. This changes the CTS by requiring a Davis-Besse Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 138 of 323

Attachment 1, Volume 13, Rev. 0, Page 139 of 323 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 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 more restrictive because it adds a new Surveillance Requirement to CTS. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Category I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.1.1.b requires a "separate" fuel storage system for each required EDG. ITS LCO 3.8.3 does not state that the fuel oil storage tanks are separate between diesels. This changes the CTS by moving the details of the separate fuel storage system 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. The ITS still retains the requirements that the required fuel storage tank contains the specified volume of diesel fuel oil. 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 Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes. LESS RESTRICTIVE CHANGES L01 (Category 4- Relaxation of Required Action) The CTS 3.8.1.1 and CTS 3.8.1.2 Actions do 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, the associated EDG must be declared inoperable and CTS 3.8.1.1 Action b or the CTS 3.8.1.2 Action must be entered, as applicable. ITS 3.8.3 ACTION A allows the unit to not declare the associated EDG inoperable as long as the volume of stored fuel oil is greater than a six day limit (i.e., > 26,800 gallons). In this situation, ITS 3.8.3 Required Action A.1 allows 48 hours to restore the fuel oil volume to within limits. If this Required Action and associated Completion Time are not met or if the EDG fuel oil storage tank volume is < 26,800 gallons, the associated EDG must be declared inoperable immediately (ITS 3.8.3 ACTION F). In addition, a Note has been added to the ITS 3.8.3 ACTIONS that allows separate Condition entry for each EDG. This changes the CTS by allowing each EDG not to be declared inoperable with the Davis-Besse Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 139 of 323

Attachment 1, Volume 13, Rev. 0, Page 140 of 323 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR fuel oil storage tank volume not within the specified Surveillance limit as long as each EDG has enough fuel oil for 6 days (> 26,800 gallons) of operation at full load. The purpose of ITS 3.8.3 ACTION A is to 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, 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 associated EDG not to be declared inoperable with the stored diesel fuel oil volume not within the specified Surveillance limit as long as each EDG has enough fuel oil for 6 days of operation at full load. In this Condition, the 7 day fuel oil supply for a EDG 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 necessary 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 fuel oil to the tank. A period of 48 hours is considered sufficient to complete restoration of the required volume prior to declaring the affected EDG 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 since less stringent Required Actions are being applied in the ITS than were applied in the CTS. Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 0, Page 140 of 323

Attachment 1, Volume 13, Rev. 0, Page 141 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 141 of 323

Attachment 1, Volume 13, Rev. 0, Page 142 of 323 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL :POWER SYSTEMS 3.8.3 Diesel .Fuel Oil, 'Lube Oil, and Starting Air LCO 3.8.1.1.a LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator .(G). eh sencyi* 0 APPLICABILITY: When asso~ZciaeýG is required to be OPERABLE. 0 ACTIONS E NOTE-NT DOC L~lSeparate Condition entry is allowed for each DG. 0 CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One or moreltsith fuel level < [33, 00] gal A.1 Restore fuel oil level to 48 hours 0 I and > P6ga storage tank. \ iT2_.8 0 within limits. 0

                                                           @      D DOC M01           B. One or more4's with                    B.1        Restore lube oil inventory to      48 hours 00 260       ube oil inventory                              within limits.
                               ] gal and

[] gal. DOC M02 C. One or more+DGs-ith stored fuel oil total C.1 Restore fuel oil total particulates to within limits. 7 days 0 particulates not within limit. DOC M02 D. One or more DGs with new fuel oil properties D.1 Restore stored fuel oil properties to within limits. 30 days 0 not within limits. DOC M03

         ,,  4 E. One or moreDGs with starting air receiver E.1        Restore starting air receiver pressure to F[2-5] psig.

48 hours 01 pressure < [254]psig a Ž1 psig. 210 00 BWOG STS 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 142 of 323

Attachment 1, Volume 13, Rev. 0, Page 143 of 323 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and associated Completion F.1 Declare associated DG inoperable. Immediately 0 Time not met.E Time,,ot* m Ff Condition A,

                                    ý B,C, D, or E 0

OR One or more'G~swith diesel fuel oil, lube oil, or 0 starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.8.1.1.b.2, SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days 4.8.1.1 .2.a.2, 4.8.1.1.2.c.2. >[ gal of fuel. . 3.8.1.2 [for each EDG DOC M01 SR 3.8.3.2 Verify lube oil inventory~is > F 31 days 00 DOC A04 SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program SR 3.8.3.4 air start receiver pressure is 31 days DOC M03 DOC M04 SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank. 311 days 0 BWOG STS 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 143 of 323

Attachment 1, Volume 13, Rev. 0, Page 144 of 323 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.

2. The brackets have been removed and the proper plant specific information has been provided.

3. These corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

4. The Davis-Besse design includes two redundant starting air receivers per emergency diesel generator (EDG). Each starting air receiver provides sufficient air for five start attempts. Therefore, ITS 3.8.3 Condition C has been modified to only specify the "required" starting air receiver. This change is consistent with the use of the word required in the ISTS, as stated in the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.3.b.

5. The lube oil inventory value provided in ISTS SR 3.8.3.2 is for each EDG, as stated in ISTS 3.8.3 Condition B. Therefore, the clarifying phrase "for each EDG" has been added.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 144 of 323

Attachment 1, Volume 13, Rev. 0, Page 145 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 145 of 323

Attachment 1, Volume 13, Rev. 0, Page 146 of 323 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 BASES eme~ ° BIACKGROUND Each'diesel generator ýG)is provided with -f]storage tanl~having a fuel oil capacity sufficient to operate that diesel for a period of 7 days while the D tl-0 DG is supplying maximum post loss of coolant accident load demand8

                           -- discussed in the FSAR, Sectioný                    ý(Ref. 1). The maximum load demand is calculated using the assumption that at least twotDGs are                          -

available. This onsite fuel oil capacity is sufficient to operate theDGs for longer than the time to replenish the onsite supply from outside sources. Fuel oil is transferred frorrstorage tank tolday tank byleither.-6f twor se-Ltransfer pumlaoidwt each storage tank. R dundancy of Each storage tank pumps and piping pre udes the failure of one pump, or the rupture of any is installed above grade elevation. H pipe, valve or tank to r suit in the loss of more than ne DG. All outside tns pms pm s and a ipOpýInc i are located underciround.I notlcomittBed IWhile to hisis* Davis-Besse not comm itted toth&s For proper operation of the standbyvDGs,.i. it is necessary to ensure the 0 Regulatory Guide. I proper quality of the fuel oil. ýRegulatory 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, the kinematic viscosity, specific gravity (or API gravity), and impurity level. E *)The G lubrication system is designed to provide sufficient lubrication to permit proper operation of its associatedýDG 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 n y operation. Each engine oil sump;contains an inventory capable of supporting a minimum ofR7Mdays of operation.I Ihe onsite storage in

                                 ýacldition to the engine oil sump is sufficient to ensure 7 days of continuous0
                                  ýoperation.]l Ihs spply is 'suthciento allowteFoperator to replenish lube oil from outside sources.                     two air start receivers per subsystem.

_-1 and each air start receiver has Each G has an air start system with adequate capacity for five successive start attempts on the DG without recharging the air start receiverm -. 1ý } BWOG STS B 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 146 of 323

Attachment 1, Volume 13, Rev. 0, Page 147 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 Section BASES Secto APPLICABLE The initial conditions of Design Basis Accident (DBA)and transient SAFETY ANALYSES analyses in the FSAR, ater (Ref. 4) and I [Kassurne Engineered Safety Featurf(ESF) systems are OPERABLE. The 1 E] (Ref. 5), 00 W DGs are designed to provide sufficient capacity, capability, redundancy,

                    .and reliability to ensure the availability of necessary power to ESF 0

systems so that fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems. Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full load operation. It is also required to meet specific standards for quality. Additionally, sufficient lube oil supply must be available to ensure the capability to operate at full load for 7 days. This requirement, in F conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of 4DGs required to shut down the reactor and to 0 maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. ,DG day tank fuel requirements, as well as transfer capability from the storage tank to the E (D day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown." u Thus, only one of the two air start receivers for each EDG is required to be OPERABLE. [ The starting air 'ystem is required to have a minimum capacity for five sucssiveDG start attempts without recharging the air start receivers. 01 (D) 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. Since stored diesel fuel oil, lube oil, and the 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 associatedýDG is required to be D ' OPERABLE. __ __ _ ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each4 DG. This is acceptable, since the 0

                                                                                                                                 }0 Required Actions for each Condition provide appropriate compensatory

_-- -- actions for each imoperableN G subsystem. Complying with the Required Actions for one inoperableDG subsystem may allow for continued operation, and subsequent inoperable4oG subsystem(s) are governed by separate Condition entry and application of associated Required Actions. BVVOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 147 of 323

Attachment 1, Volume 13, Rev. 0, Page 148 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) A.1 yo In this Condition, the 7 day fuel oil supply for aG is not available. 0 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 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 fuel oil to the tank. A period of 48 hours is considered sficient to complete restoration of the required level prior to declaring rDG inoperable. This period is acceptable based on the remaining capacity 6 days), the fact that procedures will be initiated to obtain D-Lreplenis ment, and the low probability of an event during this brief period. B.1 E* With lube oil inventory <F50 gal, sufficient lube oil to support 7 days of continuous G operation at full load conditions may not be available. 0 However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. This restriction allows sufficient time to obtain the requisite replacement volume. A period of 48 hours is F 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 [D procedure's, weibeinitiated 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 ofSR 3.8.3.*. 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 BVWOG STS B 3.8.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 148 of 323

Attachment 1, Volume 13, Rev. 0, Page 149 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) particulates does not mean failure of the fuel oil to burn properly in the diesel engine, particulate concentration is 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&DG 0 inoperable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysisofrthe DG"fuel oil. that are not required to be obtained 0 prior to addition of the new fuel oil to the storage tanks are D[---the test results for the 3 new fuel oil properties defined in the Bases for SR 3.8.3 not 05 4 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 combinations of these procedures. Even if a:;DG start and 0 load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function. E.1 inthe required air start receiver With starting air receiver pressure <2 psig,`sufficient capacity for five [ s ucessiveG start attempts does not exist. However, as long as the receiver pressure ii, psig, there is adequate capacity for at least one start attempt, and the4lJG can be considered OPERABLE while the [J air receiver pressure is restored to the required limit. A period of 48 hours is considered sufficient to complete restoration to the required pressure E prior to declaring the4DG inoperable. This period is acceptable based on, the remaining air start capacity, the fact that most4DG starts are accomplished on the first attempt, and the low probability of an event during this brief period. F.1 E, With a Required Action and associated Completion Time not met, or one or more Gs with fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable. BWOG STS B 3.8.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 149 of 323

Attachment 1, Volume 13, Rev. 0, Page 150 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE ZSR 3.8.3.1 REQUIREMENTS Crdtfor the E5 This SR provides verification that there is an adequate inventory of fuel oil minimum required in the storage tanks to support eachlDG's operation for 7 days at full load. level in the The 7 day period is sufficient time to place the ,unit in a safe shutdown associated day tank (4000 condition and to bring in replenishment fuel from an offsite location. gallons per SR 3.8.1.4) is being taken to support The 31 day Frequency is adequate to ensure that a sufficient supply of the 7 days of fuel oil is available, since low level alarms are provided and unit operators

 ,EDG  operation,        would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 This Surveillance ensures thatload sufficient lubefor operation inventory isThavailable to26 oil eah4G ] a -5_9 0._ support at least 7 days of full E0 requirement is based on thetDG manufacturer consumption values for the run time of the*)G. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to theiDG, when the G lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer 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 unit staff. L E SR 3.8.3.3 The tests listed below 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 contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

a. Sample the new fuel oil in accordance with ASTM D4057-E7_E 02 (Ref. 6)%- 0 BWAOG STS B 3.8.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 150 of 323

Attachment 1, Volume 13, Rev. 0, Page 151 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) 06 0.825.

b. Verify in accordance with the tests specified in ASTM D975-&Z (Ref. 6) that the sample has an absolute specific gravity at 60/60 'F of 3 0

0.87 0M-3 angý or an API gravity at 60°F of > *and _< ' when tested in accordance with ASTM D1298_.- (Ref. 6).,a kinematic 40 0 Vliscosity at 40'C of 1-.9 centistokes and _ 4.1 centistokes, and a flash point of-- 125°Fjn7 dd

c. Verify that the new fuel oil has a clear and bright appearance with_

08 proper color when tested in accordance with ASTM D4176-[ or a water witl and sediment content SmM DP2709q-[ ))I(Ref. 6). within limits when tested in accordance th tst specified in . 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 00 fuel oil is not added to the storage tanks. 0 Within 31 days following the initial new fuel oil sample, the fuel oil is

                         *analyzredýto establish that the other properties specified in Table 1 of ASTM D97            ] (Ref. 7) are met for new fuel oil when tested in                       (

accordance wit (Ref. 6), except that the analysis for sulfur may be performed in accordance with ASI M D1,552-

                                                 , orlASTM D4 2 9 4 -U (Ref. 6). The 31 day period is j_-
                                                                                                       ]J           jASTM acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on+HG operation. This Surveillance ensures the availability of high quality fuel oil i      0 for the+DGs.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean 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. Particulate concentrations should be determined in accordance with SASTM [*45,fý[ ] (Ref. 6). IThis method ivea Iion gravimetricl total particulate concentration in the fuel oil M has a 00 limit of 10 mg/l. It is ac, gptable to obtain a field s~rnple for subsequentI I lbortor tetin -in, -J~of field testing. ý[I-or tlhose e ~signs in which the total stored tuel oil vo*lume is contained in two or m'e interconnected7 00 Itanks, each tank rrost be considered and tested s arately.] 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. B\AWOG STS B 3.8.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 151 of 323

Attachment 1, Volume 13, Rev. 0, Page 152 of 323 Diesel Fuel Oil, Lube Oil., and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.3.4 E This Surveillance sufficient ensures that, air start capacity without the aid of the The refillsystem compressor, f for each+DG is available. design 0 for eachairsarreceiver requirements4 provide for a minimum of Ifive] engine start cycles without recharging. J[A start fycle is defined by the DG ver/dor, but usually isI 0 Smeasured in terms *)f time (seconds of cranking) Jr engine cranking - speed.] IThe pressure specified in this SR is intended to reflect the lowest val e a which the [iveM starts can be accomplished, Susing only one of the two air start receivers for each EDG * - 00 The 31 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 every[P31lJdays eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil duringoDG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from 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. 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. BWOG STS B 3.8.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 152 of 323

Attachment 1, Volume 13, Rev. 0, Page 153 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES REFERENCES 21 FSARe Section 9 1.2 00

2. Regulatory Guide 1.137.

3. ANSI N195-1976, Appendix B.

t L~LJ5- _.lSAR, Cha er section 10 SAR' Cha er [1* 0@

6. ASTM Standards: D4057-7j-; D975-r D1298-1; D4176-r; j[D27 09-[ J;ID15 2-[ 26*2- D4294-Q; 4 -

                                                         - I       -2276-8

7. ASTM Standards, D975- ,-Table 1.

BWVOG STS B 3.8.3-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 153 of 323

Attachment 1, Volume 13, Rev. 0, Page 154 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

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

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

4. Typographical error corrected.

5. Editorial change made for clarity.

6. Changes made to be consistent with the Specification.

7. ASTM D2276-88 already provides these methods and allowances. Therefore, it is not necessary to include the statements.

8. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 154 of 323

Attachment 1, Volume 13, Rev. 0, Page 155 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 155 of 323

Attachment 1, Volume 13, Rev. 0, Page 156 of 323 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. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 156 of 323

, Volume 13, Rev. 0, Page 157 of 323 ATTACHMENT 4 ITS 3.8.4, DC SOURCES - OPERATING , Volume 13, Rev. 0, Page 157 of 323
, Volume 13, Rev. 0, Page 158 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 158 of 323

Attachment 1, Volume 13, Rev. 0, Page 159 of 323 ITS 3.8.4 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - OPERATING LAO 1 LIMITING CONDITION FOR OPERATION See ITS 3.8.9 LCO 3.8.4 ,~~~~ .~ ~~ I F l.......1 4.~ A Al (,OrDAUTV 1with disconnect switche-s etween bus trains openl: / I See ITS 3.8.9 TRIN "A' consistling of 250/125-volt D.C. MCC L1 125-vol D.C. - LO Istation Batteries IF/and ]IN and -2 full capacigy chargers. _elT7

                                                                                 /                                   3.8.9 1 TRAIN "B" Iconsisting of 250/125-volt D.C. MCC 2,:]125-volý D.C.                                              LA01 Istation barter2.es ZF/and 2-Nand 2 full capaci y chage.

APPLICABILITY: MODES 1, 2, 3 and 4. ACTION:

a. With only one 125-volt D.C. bus of a 250/125 volt D.C. MCC OPERABLE, restore the inoperable bus to OPERABLE status within 2 SeelTS hours or be in at least HOT STANDBY within the next 6 hours and 3.8.9 9 in COLD SHUTDOWN within the following 30 hours.

b. FWi oh 125-volt D.C. battery or jnly one char er of one ACTION A, ACTION B tICC OPERABLE, restore the innperable battery or charger to OPERABLE status within _h_ or e in at least HOT STANDBY ACTION C within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

SURVEILLANCE REQUIREMENTS 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with disconnect switches open between redundant busses at least once per 3.8.9 ] 3SeeITS 7 days by verifying correct disconnect switch/breaker alignment, indicated power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts D.C. 4.8.2.3.2 Each 125-volt battery and charger shall be demonstrated OPERABLE:

a. At least once per 7 days by: I See ITS

                           . Verifying that the parameters in Table 4.8-1 meet                                    3.8.6 Category A limits,         and DAVIS-BESSE,        UNIT 1                        .3/4 8-8                   ..Amendment No. 100 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 159 of 323

Attachment 1, Volume 13, Rev. 0, Page 160 of 323 ITS 3.8.4 ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) SR 3.8.4.1 2. Verifying total battery terminal voltage is greater than or equal to [* lolts on fl oat charge. [minimum established float voltage L0

b. AL least once per 2 Udays anu wltnii / days aTrer a battery discharge (battery terminal voltage below 110 volts), or battery overcharge (battery terminal voltage above 150 volts), by:

1. Verifying that the parameters in Table 4.8-1 meet the Category B limits, ý See ITS 1 3.8.6

2. Verifying that there is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 106 ohms, and

3. Verifying that the average electrolyte temperature of every sixth L03 connected cell is above 60*F.L0 SR 3.8.4.2 c. At least once per 18 months by verifying that the battery charger will establishedfloatvoltage supply at least 475 amperes at a minimum of 130frvolts for at least 8 .- -

hours;-and at least once each REFUELING INTERVAL by verifying that: Addproposed 2nd option for

1. The cells, cell plates and battery racks show no visual indication of SR3.8.4.2 physical damage or abnormal deterioration,

2. The cell-to-cell and terminal connections are clean, tight and coated . TSee 3.8.6ITSa witn anti-corrosion material, and

3. The resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10.6 ohms.

J 0L05 SR 3.8.4.3 d. At least once each REFUELING INTERVAL, Iduring shutdownrby verifying that the battery 6apacity is adequate to supply and maintain in OPERABLE status'all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test. Onc4 per 60 vonths.a -modified performance discharge test may be performed in lieu of the battery service test.

e. Verify battery capacity is Ž 80% of the manufacturer's rating when subjected to a performance discharge test or modified performance discharge test:

1. At least once per 60 months, during shutdown, when the battery shows no signs of degradation, and has not reached 85% of service life.

See ITS

2. At least once per 12 months, during shutdown, when the battery shows 3.8.6 J signs of degradation, or has reached 85% of service life with < 100%

of the manufacturer's rated capacity.

3. At least once per 24 months, during shutdown, when the battery has reached 85% of service life with

100% of the manufacturer's rated capacity.

DAVIS-BESSE, UNIT 1 3/4 8-9 Amendment No. 100,219,229 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 160 of 323

Attachment 1, Volume 13, Rev. 0, Page 161 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (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 None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Category I - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.3 states that the DC bus trains shall be energized and OPERABLE with tie breakers between bus trains open. The details of what constitutes Train A and Train B are also listed. Train A consists of 250/125-volt DC MCC1, 125-volt DC station batteries 1P and 1N and 2 full capacity chargers. Train B consists of 250/125-volt DC MCC2, 125-volt DC station batteries 2P and 2N and 2 full capacity chargers. ITS LCO 3.8.4 requires the Train 1 and Train 2 DC electrical power sources to be OPERABLE. This changes the CTS by moving the details of the components of the DC Sources (battery and charger) from the CTS to the Bases. The 250/125-volt DC MCC buses are part of the Distribution System Specification (ITS 3.8.9) and all aspect of the buses are addressed in ITS 3.8.9. 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. The ITS still retains the OPERABILITY statement for the Train 1 and Train 2 DC electrical power sources. 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 is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications. LA02 (Category 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.a.2 requires the total battery terminal voltage to be greater than or equal to 129 volts on float charge. ITS SR 3.8.4.1 Davis-Besse Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 161 of 323

Attachment 1, Volume 13, Rev. 0, Page 162 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING requires the verification that the battery terminal voltage is greater than or equal to the minimum established float voltage. This changes the CTS by moving the specific value of the minimum established float voltage (129 V) from the CTS to the Bases. The removal of this value, 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. The ITS still retains the requirement that the battery terminal voltage be greater than or equal to the minimum established float voltage. 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 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 L01 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 Action b states, in part, that with only one charger of one MCC OPERABLE, restore the inoperable charger to OPERABLE status within 2 hours. ITS 3.8.4 ACTION A has been added and covers the condition of one or two Train 1 or Train 2 battery chargers inoperable. ITS 3.8.4 Required Action A.1 requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours. ITS 3.8.4 Required Action A.2 requires the verification that the battery float current is < 2 amps once per 12 hours and ITS 3.8.4 Required Action A.3 requires the restoration of the battery charger to OPERABLE status within 7 days. This changes the CTS by extending the time one or two battery chargers in one train may be inoperable. The purpose of CTS 3.8.2.3 is to ensure that the Train 1 and Train 2 DC Sources are capable of supplying the associated loads during a design bases accident. 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. 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 proposed ITS 3.8.4 ACTION A provides a 7 day restoration time for one train (i.e., Train 1 or Train 2) with one or two inoperable battery chargers. However, this time is contingent on a focused and tiered approach to assuring adequate battery capacity is maintained. The first priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours (ITS Required Actions 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 a reasonable basis for extending the restoration time for one or two inoperable chargers beyond the 2 hour limit of ITS 3.8.4 Required Action A.1. The second tiered action proposes 12 hours 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 Davis-Besse Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 162 of 323

Attachment 1, Volume 13, Rev. 0, Page 163 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING shutdown in this condition (as currently required) versus a 12 hour 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 is 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 hours, while in other cases it may be the degraded inservice charger that can continue to float the battery. Furthermore, the remaining DC source is fully OPERABLE during this extended time period and can still perform the assumed safety function. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L02 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 Action b states that one of the required 125 VDC batteries or chargers for an MCC may be inoperable and provides 2 hours for the inoperable battery or charger to be restored to OPERABLE status. ITS 3.8.4 ACTION B provides the actions for one DC electrical power source inoperable for reasons other than those covered by ITS 3.8.4 ACTION A. Thus ITS 3.8.4 ACTION B covers one or two batteries inoperable in one train and covers both batteries and chargers in one train concurrently inoperable. The required DC electrical power source must be restored to OPERABLE status within 2 hours. This changes the CTS by allowing more than one battery or charger in the same train to be inoperable concurrently. 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 more than one battery or charger on the same train to be inoperable at the same time. This is allowed since the remaining DC electrical power source (i.e., train) remains OPERABLE and is fully redundant to the inoperable train. The remaining DC source can still perform the assumed safety function. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L03 (Category6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS 4.8.2.3.2.c requires that the battery charger supply 475 amperes at a minimum of 130 volts for at least 8 hours. ITS SR 3.8.4.2 requires the verification that each battery charger will supply > 475 amps at greater than or equal to the minimum established float voltage for > 8 hours. This changes the CTS by deleting the actual value for the minimum voltage for the test. The purpose of CTS.4.8.2.3.2.c is to help ensure the effectiveness of the battery chargers to perform their intended function. This change is acceptable because the relaxed Surveillance Requirement acceptance criterion is not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by deleting the actual voltage limit and replaces it with the minimum established float voltage limit. This change is Davis-Besse Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 163 of 323

Attachment 1, Volume 13, Rev. 0, Page 164 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING acceptable since the proposed value will continue to ensure that the battery chargers remain OPERABLE to perform their specified safety function. For the battery chargers to supply 475 amps as required by ITS SR 3.8.4.2, they must be at a higher voltage than the 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. L04 (Category 6 - Relaxation of Surveillance Requirements Acceptance Criteria) CTS 4.8.2.3.2.c provides a test for the 125 V battery chargers. ITS SR 3.8.4.2 includes a similar test. In addition, the SR provides an alternative test method. This method requires a verification that each required battery charger can recharge the battery to the fully charged state within 12 hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. This changes the CTS by allowing an alternate test that is not currently allowed. The purpose of CTS 4.8.2.3.2.c is to verify the required 125 V battery chargers can recharge their respective batteries following a loss of offsite power event. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify the equipment used to meet the LCO can perform its required functions. The alternate test provides an acceptable method for determining charger capability by actually recharging a discharged battery within 12 hours while supplying the required loads. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. L05 (Category 10 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.2.3.2.d contains a requirement to perform the battery capacity test "during shutdown." ITS SR 3.8.4.3 requires a similar Surveillance, and includes a Note that states the Surveillance shall not be performed in MODE 1, 2, 3, or 4. The Note also states that credit may be taken for unplanned events that satisfy the SR. This changes the CTS by allowing the Surveillance to be performed in the operating MODES, provided that it is an unplanned event that satisfies the requirements of the SR. The purpose of CTS 4.8.2.3.2.d is to confirm the OPERABILITY of the batteries. This change is acceptable because the proposed Surveillance Frequency provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions at all times. It allows the unit to credit an unplanned event for satisfying the Surveillance, provided the necessary data is obtained. Furthermore, the proposed Surveillance Note still restricts planned performance of the Surveillance to MODES other than MODES 1, 2, 3, and 4. 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 at plant conditions other than shutdown. Davis-Besse Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 164 of 323

Attachment 1, Volume 13, Rev. 0, Page 165 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING L06 (Category 6 - Relaxation of Surveillance Requirements Acceptance Criteria) CTS 4.8.2.3.2 d requires verification of the station battery capacity when the battery is subjected to a service test. The CTS allows substitution of a modified performance discharge test for this service test once per 60 months. ITS SR 3.8.4.3 requires a similar battery capacity test. The SR is modified by Note 1, which allows the modified performance discharge test in SR 3.8.6.6 to be performed in lieu of the service test in SR 3.8.4.3. This changes the CTS by allowing a modified performance discharge test to be substituted for a service test all the time, instead of the current once per 60 months. 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 modified performance 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). As stated in the Bases for ITS SR 3.8.6.6, 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. This modified test has been shown to be as effective in determining battery capacity as the standard service test. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 0, Page 165 of 323

Attachment 1, Volume 13, Rev. 0, Page 166 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 166 of 323

Attachment 1, Volume 13, Rev. 0, Page 167 of 323 CTS DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating The Train fand TraineDC electrical powerlsby tesshall be LCO 3.8.2.3 LCO 3.8.4 OPERABLE. oehb 00 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

                                           -- 1                                        I-Action b      A. OneIlrtw         attery charger1s on one trairn A.1   Restore battery terminal voltage to greater than or 2 hours                    G0 inoperable.                          equal to the minimum established float voltage.

AND A.2 Verify battery float current

amps.

Once per M12M hours 0 AND A.3 Restore battery charge[__ to OPERABLE status. 7 days 00 Action b f [B. One [or two] batter[y [ies on one train] inoper ble. _. One DC electrical power I B.1 Restore batter[y][ies] to OPERABLE status. Restore DC electrical I [2] hours] H hours sseinoperable for reasons other than T8 power ý ýto OPERABLE status\-c 0 Condition A -or.

                                                                                      +/-                              0© Action b 40J    Required Action and Associated Completion Time not met.

S1_ AND Be in MODE 3. 6 hours 0 [ Be in MODE 5. 36 hours BWOG STS 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 167 of 323

Attachment 1, Volume 13, Rev. 0, Page 168 of 323 CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.3.2.a.2 SR 3;8.4.1 Verify battery terminal voltage isgreater than or 7 days equal to the minimum established float voltage. required i7 4.8.2.3.2.c SR 3.8.4.2 Verify each battery charger supplies >ŽM4 greater than or equal to the minimum established amps at r 8M months 00 float voltage for >!hours. 0 OR Verify each battery charger can recharge the battery to the fully charged state within [ ours while 12 supplying the largest combined demands of the 00 various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. 4.8.2.3.2.d SR 3.8.4.3 --------------------- NOTES ---------------

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 nor y be performed in MODE 1s2, 3, or 4. owever, 0 portions of thp Surveillance may be performedd to reestablisl~ OPERABILITY pr vided an 0}

assessment/!determines the saffty of the Iln is maintaine/d or enhanced. Credit may be taken for unplanned events that satisfy this SR. Verify battery capacity is adequate to supply, and mots 0 maintain in OPERABLE status, the required *-- emergency loads for the design duty cycle when 0 subjected to a battery service test. (actual or simulated) BWVOG STS 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 168 of 323

Attachment 1, Volume 13, Rev. 0, Page 169 of 323 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 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 renumbered.

3. Editorial change for clarity.

4. Typographical error corrected.

5. No portions of the battery service test can be performed in MODE 1, 2, 3, or 4 without making the battery inoperable. Furthermore, the battery service test is not performed in steps, where only part of the test can be performed. Therefore, this part of the Note has been deleted.

6. Changes are made to reflect the plant specific nomenclature.

7. The title of ISTS 3.8.4 is "DC Sources - Operating". Therefore, ISTS LCO 3.8.4 has been changed to be consistent with the title. The ITS LCO 3.8.4 now requires DC electrical power "sources" to be OPERABLE in lieu of "subsystems." This terminology is also consistent with ISTS 3.8.1, which provides the requirements for AC "sources," not "subsystems".

8. For Davis-Besse, each DC electrical power source includes three 125 VDC battery chargers, two normally in service (preferred) and one spare. If the spare charger is substituted for one of the two preferred battery chargers, then the requirements of independence and redundancy between sources is maintained. Therefore, ISTS 3.8.4 Condition A and Required Action A.3, and SR 3.8.4.2 have been modified to only specify the "required" battery chargers. This change is consistent with the use of the word required in the ISTS, as stated in the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.3.b.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 169 of 323

Attachment 1, Volume 13, Rev. 0, Page 170 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 170 of 323

Attachment 1, Volume 13, Rev. 0, Page 171 of 323 DC Sources - Operating B 3.8:4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating BASES BACKGROUND The station 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 and preferred AC vital bus power (via inverters). As required by 10CFR 50, Appendix A, GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3). source 8 The 11 25/250j VDC electrical power system consists of two independent 2 and redundant safety related Class 1 E DC electrical power su s ems (Jerain and Traibattery-15011o-bJ6attfe-r'ie-s[(each subs em [h

                                                         ). Each capacity)]   consists s,ýit of l]tw  125VDC atrchargerl]      se for each battery, and all the associated control equipment an                one           8 interconnecting cabling.

MThe 250 VDC source is obtained by use of the two 125 VDC batteries one of he two connected in series. Additionally, there is EoneM spare battery charger per

                                          ~ which provides backup service in the event that t ereferred -

s battery charger is out of service. If the spare battery charger is t tw {. substituted for one of ýg ýreferred battery chargers, then the requirements of independence and redundancy between subs emq are maintained.om sources During normal operation, the 125/25CMjVDC load is 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 load is automatically powered from the station batteries. Themlrain~and Train' DC electrical powers provide the control power for its associated Class 1 E AC power load group,4J4.16M]kV switchgear, andP]J48CfV load centers. The DC electrical power 4*0 sorces su sy emsI also provide DC electrical power to the inverters, which in turn power the AC vital buses. Felec-tricali- L ý 120V The DC power distribution system is described in more detail in Bases for LCO 3.8.9, "Distributions System - Operating," and for LCO 3.8.10, "Distribution Systems - Shutdown." BWAOG STS B 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 171 of 323

Attachment 1, Volume 13, Rev. 0, Page 172 of 323 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued) Each 25/250VDC batte is separately housed in a ventilated room apart from its charger and distribution centers. Each substemris located in an area separated physically and electrically from the other j3 e to ensure that a single failure in one subs em does not _u cause a failure in a redundant Fsubsy-temr There is no sharing between L l redundant Class 1 E substems, such as batteries, battery chargers, or distribution panels. * ) Fu Each battery has adequate storage capacity to meet the duty cycle(s) S discussed in the ýSAR C t (Ref 4). The battery is designed with additional capacity above that required by the design duty cycle to allow 0 0 for temperature variations and other factors. 0 The batteries for TrainRand Train[ DC electrical powersuse mare sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage limit is 1052V. The battery cells are of flooded lead acid construction with a nominal specific gravity of M1.21 'ES IThis specific gravity correLsponds to an open circuit battery vo la e of approximately 120 V for a [58] cell battery (i.e., cell voltage of [2.0l5] volts per cell (Vpc)). The op circuit voltage is the voltage maintaineo when there is no charging or di charging. Once fully charged with its open circuit voltage > [2.065] Vpc, the battery cell will maintain its capa ity for [30] days without further c arging per ymanufacturer's irlstructions. Optimal long term performance how er, is obtained by maintaining a float voltage *j~to 2.25MVpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge. lThe nomir Ifloat voltage of [2.22] VpI corresponds to a totall float voltage output of/[128.81 V for a r58] cell battobry as discussed in the FSAR, Chapter [8] (lef. 4). Each Train'and TrainMDC electrical 0h 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 battery charger also has sufficient excess capacity to restore the battery from the design minimum 12 charg.-e to its fully charged state withit[Jhours while supplying normal steady state loads discussed in t'SAR, ter" (Ref. 4). 0 0 BWOG STS B 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 172 of 323

Attachment 1, Volume 13, Rev. 0, Page 173 of 323 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.

                 \Men 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 havetrecharge efficiencies of greater than 95%, so once 2 aat 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. APPLICABLE The initial conditions of Desig Basis Accident (DBA and transient SAFETY analyses in theFSAR, C a er [ (Ref. 5) and P5er [5M(Ref. 6), ( ANALYSES assume that Engineered Safety Featuret(ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC ( D electrical power for the#DGs, emergency auxiliaries, and control and E) LL} switching during all MODES of operation. The OPERABILITY of the DC 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 DC sources OPERABLE during accident conditions in the event of:

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

b. A worst-case single failure.

The DC ýources satisfofZon 3 of 10 CFR 50.36(c)(2)(ii). Operating BWAOG STS B 3.8.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 173 of 323

Attachment 1, Volume 13, Rev. 0, Page 174 of 323 DC Sources - Operating B 3.8.4 BASES [sources (Train 1 and Train2) tri LCO The DC electrical power u, each subsyý"em consistingofmtwom* ( D1,i LCbjaries,4battery charger #or each batterym and the corresponding control ( equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AO r a postulated DBA. Loss of any train DC electrical powerssemdoes sue not prevent the minimum safety function from being performed (Ref. 4). An OPERABLE DC electrical power requiresr T E batteries andre chargerlo be operating and connected to the associated DC bus(es). L pbt APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 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 transients and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical powve~r~7 ments for MODES 5 and 6 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 train with one Mor two rerdchargers inoperable [(e.g., the voltagq limit of SR 3.8.4.1 is ot mainaine . The 2 battery ACTIONS provide a tiered response that focuses on returning the 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 hours. 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 51 hours, (D the battery will be restored to its fully charged condition (RequiredAction A.2) from any discharge that might have occurred due to the charger inoperability. BWOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 174 of 323

Attachment 1, Volume 13, Rev. 0, Page 175 of 323 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

                         ---------------------REVIEWER'S NOTE -----               ---------------
                 .A plant that cannot eet the 12 hour Completion Time ue to an inherent battery charging cha acteristic can propose an alternat time equal to
                 .2 hours plus the ti     experienced to accomplish the e ponential charging        0 current portion of th battery charge profile following thl service test (SR 3.8.4.3).

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 1121 hours, avoiding a premature shutdown with its own attendant risk. 0 If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours, 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 hours 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 withinT12M hours (Required Action A.2). 0 Required Action A.2 requires that the battery float current be verified as less than or equal to 2Mamps. This indicates that, if the battery had been (D discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial T1 2M hour period the battery float current is not less than or equal to j2M]amps this indicates there may be additional battery problems and the battery must be declared inoperable. BWOG STS B 3.8.4-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 175 of 323

Attachment 1, Volume 13, Rev. 0, Page 176 of 323 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 0 [ use of an inoperable restoring edfo etbl battery terminal o voltage to greater than or equal to the minimum but functional Class 1E battery charger buto Clas fucioa 1sE established float voltage has been used (e.g., balance of plant non-Class 1 E battery chargeg). The 7 day Completion Time reflects a reasonable 0 time to effect res oration of the qualified battery charger to OPERABLE status. B._1 " EVIEWER'S NOTE The 2 hour Completion Ti es of Required Actions B.1 and .1 are in brackets. Any licensee wi hing to request a longer Compl tion Time will need to demonstrate that e longer Completion Time is a propriate for the plant in accordance h the guidance in Regulatory G ide (RG) 1.177, "An Approach for lant-Specific, Risk-Informed De isionmaking: Technical Specifications.' Condition B represents ne train with one [or two] batter[ ][ies] inoperable. With one [o two] batter[y][ies] inoperable, th DC bus is being supplied by the PERABLE battery charger[s]. A y event that results in a loss of the C bus supporting the battery ch rger[s] will also result in loss of DC to t at train. Recovery of the AC bu , especially if it is 0 due to a loss of offsite ower, will be hampered by the f ct that many of the components nece sary for the recovery (e.g., diesel generator control and field flash, AC lo d shed and diesel generator outp t circuit breakers, etc.) likely rely upon t e batter[y][ies]. In addition the e ergization transients of any DC oads that are beyond the capabili of the battery charger[s] and norm Ily require the assistance of the b tter[y][ies] will not be able to be broug t online. The [2] hour limit allows ufficient time to effect restoration of n inoperable battery given that th majority of the conditions that lead to battery inoperability (e.g., loss f battery charger, battery cell voltage ess than [2.07] V, etc.) are identifi d in Specifications 3.8.4, 3.8.5, and 3. .6 together with additional specifi Completion Times. BVVOG STS B 3.8.4-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 176 of 323

Attachment 1, Volume 13, Rev. 0, Page 177 of 323 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) 0 Condition f r'presents one train with a loss of ability to completely 0 respond to an event, and a potential loss of ability to remain energized 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 train. The 2 hour limit is consistent with the allowed time for an inoperable DC distribution system train. If one of the required DC electrical power u i is inoperable for one or both reasons other than Condition A o-r (e.g., ino erable ba ar er an batteries in a associated in train inoperablesubsystem le batte to ,support has the capacity the remaining a safe DC electrical shutdown andpower to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical soues subsvtemsI to mitigate a worst case accident, continued power operation should not exceed 2 hours. The 2 hour Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power substem s ý and, if the DC electrical power subsyftem is not restored to OPERABLE ) status, to prepare to effect an orderly and safe unit shutdown. 00 If the inoperable DC electrical power em cannot be 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 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7). BWOG STS B 3.8.4-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 177 of 323

Attachment 1, Volume 13, Rev. 0, Page 178 of 323 DC Sources - Operating B 38.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying batteryterminal 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 source ful charged state while supplying the continuous steady state loads of the associated em. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer d[2.201 V [2 V at the battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 8). SR 3.8.4.2 FEED This SR verifies the [ capacity of thea-attery chargers. According to (1 Regulatory Guide 1.32 (Ref. 9), the battery charger supply is recommended to be based on the largest combined demands of the 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 ensure that these requirements can be satisfied. This SR provides two options. One option requires that each battery charger be capable of supplyi'ng[4 ]_amps at the minimum established ['* float voltage for H hours. The ampere requirements are baskon the output rating of the chargers. The voltage requirements are based on the also well within charger voltage level after a response to a loss of AC power. The time SPerid sufficient for thefcharger temperature to have stabilized and to mantanedfor at ýeast~hours. havebee The other option requires that each itry cargr be capable of recharging the battery after a service test coincident with supplying the

           =-T--__largest coin    en demands of the various continuous steady state loads d    (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 BWOG STS                              B 3.8.4-8                                Rev. 3.0, 03/31104 Attachment 1, Volume 13, Rev. 0, Page 178 of 323

Attachment 1, Volume 13, Rev. 0, Page 179 of 323 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) 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 _[M2M]amps. 0 The Surveillance Frequency is acceptable, given the unit conditions required to ensuretoadequate perform the test and charger the other during performance administrative controls these M18 monthEexisting ( intervals. In addit n, this Frequency is intended to /be consistent with Iexpected fuel cycle lengthsj.- SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4. The Surveillance Frequency of [M months] is consistent with the C recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 curn'lýperformed (Ref. refueling during 10), whichoperations,/or some otwoutagwt state that theatbattery service test should be at intervals biei en tests not to exceedlM m h. This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test. The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. iThis restriction from norm lly performing the Surveillanceý in MODE 1 or 2 is for D further amplified to a Iow portions of the Surveillanc4 to be performed the purpose of reestZ "*neaccretive blishing OPERABILITY moiiaion, (e.g., Iost work testingor deficient following corrective incomplete surveilla *ce testing, and other unanticir ted OPERABILITY pla t safety is maintained concerns) provided n assessment determines or enhanced. This ssessment shall, as a minimu , consider the potential outcomes and transients associated with failed partial Surveillance, a su essful partial Surveillance, anq a perturbation of the offsite or onsite sy tem when they are tied togethqr or operated BWOG STS B 3.8.4-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 179 of 323

Attachment 1, Volume 13, Rev. 0, Page 180 of 323 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) independently for th partial Surveillance; as well as th operator procedures availabl, to cope with these outcomes. Tlese shall be measured against t e avoided risk of a plant shutdo and startup to 0 determine that pla safety is maintained or enhance when portions of the Surveillance a performed in MODE 1 or 2. Ris insights or deterministic met ods may be used for the assess taken for unplanned eventtthat satisfy this SR. nt. Credit may be 0 REFERENCES 1. 10 CFR 50, Appendix AGDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-1197fjAI 0

5. tFSAR,' e

6. SAR, 00(D

7. Regulatory Guide 1.93, December 1974.

8. IEEE-450-*1995E August 1972 0

9. Regulatory Guide 1.32, IFebruVf 1977. 0

10. Regulatory Guide 1.129, December 1974.

BWOG STS B 3.8.4-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 180 of 323

Attachment 1, Volume 13, Rev. 0, Page 181 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

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

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

3. Changes are made to the Bases to reflect changes to the Specification.

4. The battery design values have been deleted, since they are more specific than necessary and are not required to provide sufficient background for this Specification. Furthermore, the batteries are not maintained on open circuit. Thus, these statements are deleted.

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

6. Grammatical/editorial/spelling error corrected.

7. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

8. 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.

9. Another example has been provided.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 181 of 323

Attachment 1, Volume 13, Rev. 0, Page 182 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 182 of 323

Attachment 1, Volume 13, Rev. 0, Page 183 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 183 of 323

, Volume 13, Rev. 0, Page 184 of 323 ATTACHMENT 5 ITS 3.8.5, DC SOURCES - SHUTDOWN , Volume 13, Rev. 0, Page 184 of 323
, Volume 13, Rev. 0, Page 185 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 185 of 323

Attachment 1, Volume 13, Rev. 0, Page 186 of 323 ITS 3.8.5 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION LCO 3.8.5 SURlVE ILLANCE REOU IRFEMENTS SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 250/125-volt D.C. MCC shall be determined OPERABLE and energized at least once per 7 days by verifying correct See ITS disconnect switch/breaker alignment, indicated power availability from 3.8.10J the charger and battery, and voltage on the bus of greater than or equal to 125 volts D.C. to 125 volts DC_ SR 3.8.5.1 4.8.2.4.2 +The above required 125-volt battery banks and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2. [Add proposed Note to SR 3.8.5.1 L0 2 DAVIS-BESSE, UNIT 1 3/4 8-11 Amendment No. 100 I Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 186 of 323

Attachment 1, Volume 13, Rev. 0, Page 187 of 323 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (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 M01 CTS 4.8.2.4 is applicable in MODES 5 and 6. ITS 3.8.5 is applicable in MODE 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable. This change is acceptable because the proposed requirements are necessary to ensure the DC electrical power source is OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies. Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate distribution system requirements are specified during fuel handling and ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supply is not available (See DOC L01 for the changes to the Required Actions). This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.5 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only when in MODES 5 and 6. RELOCATED SPECIFICATIONS None Davis-Besse Page 1 of 3 Attachment 1, Volume 13, Rev. 0, Page 187 of 323

Attachment 1, Volume 13, Rev. 0, Page 188 of 323 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN REMOVED DETAIL CHANGES LA01 (Category 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.4 states that as a minimum, the following DC electrical equipment and bus shall be energized and OPERABLE. It lists one - 250/125-volt DC MCC, and one 125-volt battery banks and chargers supplying the above DC MCC. ITS LCO 3.8.5 requires One Train 1 or Train 2 DC electrical power source to be OPERABLE. This changes the CTS by moving the details of the components of the DC Sources (battery and charger) from the CTS to the Bases. The 250/125-volt DC MCC buses are part of the Distribution System Specification (ITS 3.8.10) and all aspect of the buses are addressed in ITS 3.8.10. 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. The ITS still retains the OPERABILITY statement for the Train 1 or Train 2 DC electrical power source. 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 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 L01 (Category4 - Relaxation of RequiredAction) With less than the minimum complement of DC sources OPERABLE, CTS 3.8.2.4 Action requires the establishment of containment integrity within 8 hours. ITS 3.8.5 ACTION A requires suspending movement of irradiated fuel assemblies, suspending operations involving a positive reactivity addition that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore the required DC electrical power source to OPERABLE status. This changes the CTS by replacing the existing Required Action to restore containment integrity. The purpose of the CTS 3.8.2.4 Action is to isolate the containment to minimize any release from the plant if an event were to occur during shutdown conditions with no DC Sources 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 proposed Required Actions require the suspension of movement of irradiated fuel assemblies, suspension of operations involving a positive reactivity additions that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore required DC electrical power source to OPERABLE status. Suspending the movement of irradiated fuel assemblies will prevent a fuel handling accident from occurring and suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit will ensure the reactor remains subcritical. The actions to restore the required DC electrical power source to OPERABLE status will ensure the plant is placed in Davis-Besse Page 2 of 3 Attachment 1, Volume 13, Rev. 0, Page 188 of 323

Attachment 1, Volume 13, Rev. 0, Page 189 of 323 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN compliance with the LCO in an expeditious manner. The proposed actions will immediately minimize the potential for any accident releases outside of the containment and are considered acceptable in lieu of the current action to restore containment integrity within 8 hours. The actions may be considered somewhat more restrictive since immediate action is required, however, is classified as less restrictive since the current actions to restore containment integrity have been deleted. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L02 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.2.4.2 requires the demonstration of the OPERABILITY of the 125 VDC battery banks and chargers in accordance with the Surveillance Requirements of CTS 4.8.2.3.2. ITS SR 3.8.5.1 requires SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 to be applicable. However, a Note has been added that states ITS SR 3.8.4.3 does not have to be performed. This changes the CTS by allowing a certain SR not to be performed. Changes to the Surveillances of CTS 4.8.2.3.2 are discussed in the Discussion of Changes for ITS 3.8.4, "DC Sources - Operating." The purpose of the ITS SR 3.8.5.1 Note is to ensure that required equipment is not made inoperable by testing when the equipment is the only OPERABLE equipment available to support unit operations. 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. ITS SR 3.8.4.3 is the battery capacity test. The performance of SR 3.8.4.3 involves tests that would cause the only required OPERABLE Train 1 or Train 2 DC electrical power source to be rendered inoperable. This condition presents a significant risk if an event were to occur during the test- The NRC has previously provided Surveillance exceptions in the Davis-Besse CTS to avoid a similar condition for the AC Sources, but the exceptions have not been applied to DC Sources. In an effort to consistently address this concern, ITS SR 3.8.5.1 has a Note that excludes performance requirements of any Surveillance that would require the required OPERABLE DC electrical power source to be rendered inoperable. This allowance does not take exception to the requirement for the DC electrical power source to be capable of performing the particular function, but just to the requirement to demonstrate that capability while that source of power is being relied on to support meeting the LCO. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. Davis-Besse Page 3 of 3 Attachment 1, Volume 13, Rev. 0, Page 189 of 323

Attachment 1, Volume 13, Rev. 0, Page 190 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 190 of 323

Attachment 1, Volume 13, Rev. 0, Page 191 of 323 CTS DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 [DC electrical power/subsystem shall be OPERAPLE to support the DC electrical power disyribution subsystem(s) requirq/d by LCO 3.8.10, 0 "Distribution Systehns - Shutdown."] 3.8.2.4 nIorTrain2 neDC electrical power s tshall be OPERABLLI

                                                                    -REVIEWER'S NOTE The second option a ove applies for plants having a pre-ITS licensing basis (CTS) for ele ical power requirements duri g shutdown conditions that required only o e DC electrical power subsys m to be OPERABLE.

Action A and the br cketed optional wording in Co dition B are also 0 eliminated for this c se. The first option above is dopted for plants that have a CTS requiri g the same level of DC electri al power subsystem support as is requir d for power operating conditijns. APPLICABILITY: MODES 5 and 6, , During movement of [rectY] irradiated fuel assemblies. 0 ACTIONS

       -      ----------------------------------        NOTE           -------------------------------

DOC M01 LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME [A. One [or two] battery A.1 Restore battery terminal 2 hours charger[s on one train voltage to greater than o inoperable. equal to the minimum established float voltage. AND The redundant train AND 0 battery and charger[ A.2 Verify battery float curre t Once per [12] hours OPERABLE. < [2] amps. AND BVVOG STS 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 191 of 323

Attachment 1, Volume 13, Rev. 0, Page 192 of 323 3.8.5 CTS O INSERT 1 LCO 3.8.2.4 to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution System - Shutdown." Insert Page 3.8.5-1 Attachment 1, Volume 13, Rev. 0, Page 192 of 323

Attachment 1, Volume 13, Rev. 0, Page 193 of 323 CTS DC Sources - Shutdown 3.8.5 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore battery charger[I] 7 days] to OPERABLE status. Action [. One [or re] required DC electrical power sore subsy em sl inoperable [for reaons ot e than B.2.1 Suspend CORE Immediately ALTE ATIONS. asso of Time lated Cor Condit n A not pletion' AND I [. Suspend movement of Immediately met]J. FA 1 rc yirradiated fuel assemblies. 0 4-AND

Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or TSTF boron concentration. -471

                                        -AND SInitiate action to restore       Immediately required DC electrical power Isubsy emsL to OPERABLE status.                                         0 BWOG STS                                      3.8.5-2                          Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 193 of 323

Attachment 1, Volume 13, Rev. 0, Page 194 of 323 CTS DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ---------------------- NOTE--------------- 4.8.2.4.2 The following S 5ýe not required to be performed: 0 SR 3. . andSR 3.8.4.3. For C sourceg required to be OPERABLE, the In accordance 0 following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 BWOG STS 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 194 of 323

Attachment 1, Volume 13, Rev. 0, Page 195 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.5 and "Reviewers Note" have been deleted since the current licensing basis only requires one DC electrical power subsystem to be OPERABLE. ISTS 3.8.5 ACTION A has been deleted since only one required DC electrical power subsystem is specified in the LCO. This allowance is only acceptable if the first option of the LCO is used. The subsequent Condition and Required Actions have been renumbered and modified, 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 Train 1 or Train 2 125 VDC electrical power source to be powering a DC distribution train required OPERABLE by LCO 3.8.10. Also, ISTS SR 3.8.5.1 has been modified to be consistent with the LCO (only one DC Source is required to be OPERABLE).

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 continued fuel movement. Thus this Required Action assumes two DC power sources are required by the LCO. This option has been deleted since only one Train 1 or Train 2 125 VDC electrical power source is required to be OPERABLE by the LCO. Subsequent Required Actions have been renumbered and modified, as applicable.

5. The allowance to not perform SR 3.8.4.2 has been deleted. The Davis-Besse design includes three battery chargers per train. Therefore, the battery charger SR can be performed without making the train inoperable for the entire duration of the test.

6. The proper plant specific nomenclature has been provided.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 195 of 323

Attachment 1, Volume 13, Rev. 0, Page 196 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 196 of 323

Attachment 1, Volume 13, Rev. 0, Page 197 of 323 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 The initial conditions of Designý3asis Accident (DBA),and transient e CDanalyses in the SAR, Chater [ (Ref. 1) and Chater [15$}(Ref. 2), 0Q SAFETY ANALYSES assume that Engineered Safety Featurei(ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for theCDGs, emergency auxiliaries, and control and switching during all MODES of operation. _ The OPERABILITY of the DC s is consistent with the initial f assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [rec tly] irradiated fuel assemblies ensures that: 0

a. The unit can be maintained in the shutdown or refueling condition for, I extended periods:

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statu and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling/recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel Iandling accidents involvino handling recently irradiated fuel (i.e., fuel that has 0 0 occupied part of alcritical reactor core within the prqvious [X] days)]F 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 DBAs that are analyzed in MODESP, 2, 3, and 4M]have no specific analyses in BVWOG STS B 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 197 of 323

Attachment 1, Volume 13, Rev. 0, Page 198 of 323 DC Sources - Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYSES (continued) MODESM5 and 6M]because the energy contained 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. The DC ý,vurces. atisf Criterion 3 of 10 CFR 50.36(c)(2)(ii).0 [sources LCO One train ofJ ,Yhe DC electrical power su s ems, [each reluired] [the roquired]a Isubs temconsisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling within the train, ar isf]required to be OPERABLE to supportrqe [jne*]trainffl of the distribution systems [Required OPERABLE by LCO 3.8.10, "Distribution Systems - Shutdown.'lM This ensures the Q availability of 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 l[involving ha g recentlyl jirradiated fuel]). BWOG STS B 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 198 of 323

Attachment 1, Volume 13, Rev. 0, Page 199 of 323 DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY The DC electrical power sourcel required to be OPERABLE in MODES 5 5 and 6 and during movement of [rectly] irradiated fuel assemblies, provide assurance that: 00

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core-

b. Required features needed to mitigate a fuel handling accident

[involving handliipg recently irradiated fuel (i.e., fu I that has occupied ( part of a critical/reactor core within the previous days)]arie availabl Eg 0

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available and

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, 3, and 4 are covered in LCO 3.8.4. ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, 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 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily. A.1, A.2, and A.3

                 -------------------------- REVIEWER'S NOTE                  ------------------

ACTION A is include only when plant-specific impleme tation of LCO 3.8.5 includes t e potential to require both trains o the DC System to be OPERABLE. If plant-specific implementation res Its in LCO 3.8.5 requiring only one tr in of the DC System to be OPER BLE, then ACTION A is omitte and ACTION B is renumbered as ACTION A. BWOG STS B 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 199 of 323

Attachment 1, Volume 13, Rev. 0, Page 200 of 323 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) Condition A represen s one train with one [or two] batte chargers inoperable (e.g., the oltage limit of SR 3.8.4.1 is not m intained). The ACTIONS provide a .tered response that focuses on ret rning the :battery to the fully charged s ate and restoring a fully qualified harger to OPERABLE status .i a reasonable time period. Requir d Action A.1 requires that the batt ry terminal voltage be restored to greater than or equal to the minimu established float voltage within 2 hours. This time 0 provides for returnin the inoperable charger to OPER BLE status or providing an alterna't means of restoring battery termi al voltage to greater than or equa to the minimum established float oltage. Restoring the battery terminal oltage to greater than or equal to he minimum established float vol ge provides good assurance that within [12] hours, the battery will be re tored to its fully charged conditio (Required Action A.2) from any disch rge that might have occurred due o the charger inoperability. REVIEWER'S NOTE A plant that cannot et the 12 hour Completion Time' ue to an inherent battery charging cha acteristic can propose an alternate time equal to 2 hours plus the ti experienced to accomplish the e4 onential charging current portion of th battery charge profile following th, service test 0 (SR 3.8.4.3). A discharged battery aving terminal voltage of at least the minimum established float vol ge indicates that the battery is on the exponential charging current porti n (the second part) of its recharc e cycle. The time to return a battery to ts fully charged state under this c ndition is simply a function of the amou t of the previous discharge and tte recharge characteristic of the attery. Thus there is good assur nce of fully recharging the batte within [12] hours, avoiding a pre ature shutdown with its own attenda t risk. 0 If established batte terminal float voltage cannot be r stored to greater than or equal to the inimum established float voltage within 2 hours, and the charger is not o rating in the current-limiting mod s, a faulty charger is indicated. A faulI charger that is incapable of main aining established battery terminal floa voltage does not provide assura ce that it can revert to and operate prop rly in the current limit modes that is necessary during the recovery period ollowing a battery discharge eve that the DC system is designed or. BWOG STS B 3.8.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 200 of 323

Attachment 1, Volume 13, Rev. 0, Page 201 of 323 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) If the charger is oper ting in the current limit mode after 2 hours that is an indication that the ba ery is partially discharged and its apacity margins will be reduced. The ime to return the battery to its full charged

                       -condition in this case is a function of the battery charge capacity, the amount of loads on t. e associated DC system, the am unt of the previous discharge, and the recharge characteristic oft e battery. The charge time can be e tensive, and there is not adequat assurance that it can be recharged wit in [12] hours (Required Action A..

Required Action A.2 equires that the battery float curr nt be verified as less than or equal to discharged as the re 2] amps. This indicates that, if th battery had been ult of the inoperable battery char er, it has now 0 been fully recharged. If at the expiration of the initial [1 ] hour period the battery float current i not less than or equal to [2] amp this indicates there may be additio al battery problems and the batt ry must be declared inoperable. Required Action A.3 limits the restoration time for the it operable battery charger to 7 days. his action is applicable if an alter te means of restoring battery ter inal voltage to greater than or eq jal to the minimum established float vol ge has been used (e.g., balance of plant non-Class 1 E battery charger). The 7 day Completion Time refle .ts a reasonable time to effect restor tion of the qualified battery charg4 r to OPERABLE status. I A.1, A.2, and A.3 4 B.1 B.2.1 B.2.2, B.2.3, nd B.2.4 TSTF-471 ( ýD [If two trains are req ired by LCO 3.8.10, the remaining rain with DC power available ma be capable of supporting sufficien systems to allow continuation of CAT, ONS and [recently] ir adiated fuel movement]. By all ing the option to declare require features inoperable with the associated DC power source(s) in perable, appropriate restrict ons will be implemented in accor nce with the affected required f atures LCO ACTIONS. In many stances this option 0 may involve unde fired administrative efforts. There ~ore, the allowance for sufficiently cor servative actions is made (i.e., to/upn TSTF

                                                                                                                  -471 ALTE RION , movement of rec             y irradiated fuel assembliesrand operations involving positive reactivity additions that could result in BWVOG STS                                    B 3.8.5-5                                   Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 201 of 323

Attachment 1, Volume 13, Rev. 0, Page 202 of 323 B 3.8.5 (O INSERT I With the required train of DC electrical power sources inoperable, the minimum required DC electrical power source is not available. Therefore, suspension of Insert Page B 3.8.5-1 Attachment 1, Volume 13, Rev. 0, Page 202 of 323

Attachment 1, Volume 13, Rev. 0, Page 203 of 323 DC Sources - Shutdown B 3.8.5 BASES Ar'TInrkI /rý^ntinuirll loss of required SDM (MODE 5) or boron concentration (MODE6[- 0©D Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from [Reactor Coolant System () sources that have a boron concentration greater than ýwhat would be ( D60 required in theIRCS for minimum SDM or refueling boron concentration. L This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Coefficienture Introduction of temperature changes including temperature increases when operating with a positive+MTC1imnust also be evaluated to ensure II they do not result in a loss of required SDM. Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power oe s m and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit 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 L-J electrical poweu should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be 0 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. REFERENCES uL.-I-*.FSAR, Faer 0) 0 SAction 0)0 BWOG STS B 3.8.5-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 203 of 323

Attachment 1, Volume 13, Rev. 0, Page 204 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

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

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. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

5. Changes are made to reflect the Specifications.

6. Typographical/grammatical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 204 of 323

Attachment 1, Volume 13, Rev. 0, Page 205 of 323 Specific No Significant Hazards Considerations .(NSHCs) Attachment 1, Volume 13, Rev. 0, Page 205 of 323

Attachment 1, Volume 13, Rev. 0, Page 206 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 206 of 323

, Volume 13, Rev. 0, Page 207 of 323 ATTACHMENT 6 ITS 3.8.6, BATTERY PARAMETERS , Volume 13, Rev. 0, Page 207 of 323
, Volume 13, Rev. 0, Page 208 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 208 of 323

Attachment 1, Volume 13, Rev. 0, Page 209 of 323 ITS 3.8.6 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - OPERATING Add proposed LCO 3.8.6 LIMITING CONDITION FOR OPERATION A02 3.8.2.3 The following D.C. bus trains shall be energized and OPERABLE'" with disconnect switches between bus trains open: I TRAIN "A" consisting of 2.50/125-volt D.C. MCC 1, 125-volt D.C. station batteries IP and IN and 2 full capacity chargers. See ITS 3.8.4 and] TRAIN "B" consisting of 250/125-volt D.C. MCC 2, 125-volt D.C. ITS3.8.9 station batteries 2? and 2N and 2 full capacity chargers. A02 APPLICABILITY: MODES 1. 2 3 and 4. ACTION:

a. With only one 125-volt D.C. bus of a 250/125 volt D.C. MCC OPERABLE, restore the inoperable bus to OPERABLE status within 2 ITSSee 3.8.91 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the followine 30 hours.

b.

b. With only one 125-volt D.C. battery or only one charger of one MCC OPERABLE, restore the inoperable battery or charger to ITSee OPERABLE status within 2 hours or be in at least HOT STANDBY ITS 3.8.4 within the next 6 hours and in COLD SHUTDOWN within the followin SURVEILLANCE REQUIREMENTS 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with disconnect switches open between redundant busses at least once per See 7 days by verifying correct disconnect switch/breaker alignment, indicated ITS 3.8.9 power availability from the charger and battery, and voltage on the bus

                ---------------------- 1 1.8.2.3.2    Each 125-volt battery and charger shall be demonstrated OPERABLE:

SR 3.8.6.2 a. At least once per Zdays by: _L L01__ Verifying that the parameters in Table 4.8-1 meet the

1. Category A limits, and Add proposed SR 3.8.6.1 DAVIS-BESSE, UNIT 1 3/4 8-8 ..Amendment No. 100 Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 209 of 323

Attachment 1, Volume 13, Rev. 0, Page 210 of 323 ITS 3.8.6 ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) See I.Verifying total battery terminal voltage is greater than or e~qualýtO -I-"---TS 3.84] M0 129 volts on float charge.

                                                  "                                ,

31 days for electrolyte level SR 3.8.6.3, b. At least once per 2 days na wi thin ays after a baT er scXarg L31 days for electrolyte temperature SR 3.8.6.4, (battery termin vo age below 110 vo ts) or batter ov rchar e.

SR3.8.6.5 (batter, termin 1 voltaqe above 150 v ts , by: SR 3.8.6.3, 1. Verifying that the parameters in Table 4.8-1 meet the Category B _H3 SR 3.8.6.5 limits,

2. Verify~lig that there is no V*ible corrosion at eij4her terminals or I(0" Contor s, r o teonetonrstace of thes items is less thanl of every iP SR 3.8.6.4 3. Verifying fthat the avera e electrolyte temperature l~n~c/ed cell is IaJbovh (R°) ..

                                                             ,. greater than or equal to minimum established design limnits L 0

c. At least once per 18 months by verifying that the battery charger will See supply at least 475 amperes at a minimum of 130 volts for at least 8 hours; and at least once each REFUELING INTERVAL by verifying thItI

1. The cells cell plates and bat ery racks show no vis al indication of physical damage or abnormal d erioration,

2. The cel -to-cell and termina connections are cle , tight and coated L03 with a ti-corrosion materia , and

3. The sistance of each cel -to-cell and termina connection is less tha or equal to 150 x 1 6 ohms.

d. At least once each REFUELING INTERVAL, during shutdown, by verifying that the battery 6apacity is adequate to supply and maintain in OPERABLE status'all of the actual or simulated emergency loads for the design See ITS 3.8.4J duty cycle when the battery is subjected to a battery service test.

Once per 60 months, a modified performance discharge test may be performed in lieu of the battery service test. SR 3.8.6.6 e. Verify battery capacity is > 80% of the manufacturer's rating when subjected to a performance discharge test or modified performance discharge test:

1. At least once per 60 months, ldurinq shutdownL when the battery shows S

no signs of degradation, and has not reached 85% of service life. L10

2. At least once per 12 months, lduring shutdowni when the battery shows signs of degradation, or has reached 85% of service life with < 100%

of the manufacturer's rated capacity. G

3. At least once per 24 months, ldurinq shutdownL when the battery has reached 85% of service life with Ž 100% of the manufacturer's rated capacity.

DAVIS-BESSE, UNIT 1 3/4 8-9 Amendment No. 100,219,229 Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 210 of 323

Attachment 1, Volume 13, Rev. 0, Page 211 of 323 ITS 3.8.6 ITS Q TABLE 4.8-1 BATTERY SURVEILLANCE REQUIREMENTS CATEGORY A... CATEGORY B' Parameter L08 Limits for each Limits for each Allowable(3) designated pilot connected cell value for each cell [ connected cell Electrolyte >Minimul level >Minimu level Above op of greater than or equal SR 3.8.6.3 Level indicat on mark, indicat on mark, plates and not to minimum estalishned design and < 1/4 above and < Js above overf owing limits maximum level maximu level indica ion mark(d) indica ion mark~8 ) SR 3.8.6.2, Float L0 jZ._J1Vol tsSR 3.8.6.2 >2.13/vol ts('ý >2.07 volts SR 3.8.6.5 SR 3.8.6.5 L007 Voltage

                                                   /                         /
                                                                                    /Not more than                  I0 Specific         >1.200(c)               >1.195                    .020 below the Gravity(a)                                                         average of cell
                                                                                 /connected        all s Average of all            Average of all connected cell            connected cells (a)  Correc ed for electrolyte emperature and leve . If the level is b{ween the high and          w marks and the te erature corrected                                         L06 sp ific gravity is wi in the manufacturer's nominal specific n vvitv rgno,      it is ot necessary to corr ct for level.

Ih I Ptpd for avJr lctolyl:C*temperature.I L07 (c) Or bcattFiy charging currenit/7tolowing a servip~e, performance I I

disc *ge, or modified pj~formance dischargeest, is less than L0 tomswhen on a fl~t charge. 7 (d) It is teptable for t e *ec rolyte 'level to°/temporarillY l incrse pr -eor above the spec ie ie nnt ied cmaximum during efonwing qualizing p charges (1)For any ategory A parameter( outside the limi shown, the battery ay be considered OPE BLE provided that w thin 24 hours all the/ategory B measureme ts are taken and founp to be within their a lowable values, and rovided all paramete (s) are AZd d restord to within limits w thin the next 6 days./ proposed (2) For a Category B paramet (s) outside the limi (s) shown, the ACTIONS L0 batte y may be considered PERABLE provided tha they are within A, B, C, D, thei allowable values an provided the paramet r(s) are ,E, and .F rest red. to within limi.ts within.7 days.

(3) Any/ Category B parameter not within its allow le value indicates an ino erable battery. I DAVIS-BESSE, UNIT I 3/4 8-10 Amendment No. 40O....8,229 Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 211 of 323

Attachment 1, Volume 13, Rev. 0, Page 212 of 323 ITS 3.8.6 ITS 0 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN Add proposed LCO 3.8.66 LIMITING CONDITION FOR OPERATION A02 3.8.2.4 As a minimum, the following D.C. electrical equipment and bus shall be 1 2T and. OPER 250/125-volt D.C. MCC, E and 125-volt battery backs and chargers supplying the above D.C. MCC See ITS 3.8.10 See I APPLICABILITY: IMODES 5=ad ITS 3.8.5 J ACTION : Se -} See With less than the above complement of D.C. equipment and bus OPERABLE, ITS 3.8.5 establish CONTAIN11ENT INTEGRITY within 8 hours. and38.0 SURVEILLANCE REQUIREMENTS ITSee 1 4.8.2.4.1 The above required 250/125-volt D.C. MCC shall be determined ITS 3.8. 101 OPERABLE and energized at least once per 7 days by verifying correct disconnect switch/breaker alignment, indicated power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts D.C. I 4.8.2.4.2 The above required 125-volt battery banks and chargers shall See CTS Markup Pages be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2. 1 of 4, 2 of 4, and 3 of 4 (i.e., previous 3 pages) DAVIS-BESSE, UNIT I 3/4 8-11 Amendment No.100 Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 212 of 323

Attachment 1, Volume 13, Rev. 0, Page 213 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS). These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.8.2.3, in part, requires the Train A and B batteries to be OPERABLE during MODES 1, 2, 3, and 4. CTS 3.8.2.4, in part, requires the Train A or B batteries to be OPERABLE during MODES 5 and 6. ITS LCO 3.8.6 requires the battery parameters for Train 1 and 2 batteries to be within limits. ITS 3.8.6, which only covers the requirements for battery parameters, is applicable when the associated DC electrical power sources are required to be OPERABLE. This changes the CTS by combining the requirements for the Train 1 and Train 2 battery parameters into one Specification and replacing the actual MODES with the phrase "When associated DC electrical power sources are required to be OPERABLE." The purpose of ITS 3.8.6 is to cover the battery parameter requirements for the Trains 1 and 2 batteries in one Specification. This change combines the CTS 3.8.2.3 and 3.8.2.4 requirements for the Train A and Train B battery parameters into one Specification. There are no technical changes as a result of this change since it simply converts the Specifications into the format of the ITS. The proposed Applicability ensures the battery parameter requirements are met when the associated battery is required to be OPERABLE. Any technical changes to the battery parameters are discussed below. Any changes to the LCO and Applicability of the Train A and Train B batteries are discussed in the Discussion of Changes for ITS 3.8.4 and 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 4.8.2.3.2 specifies the Surveillances for the Train A and Train B batteries while the unit is operating and CTS 4.8.2.4.2 specifies the Surveillances for the Train A and Train B batteries during shutdown. ITS 3.8.6 includes a new Surveillance. ITS SR 3.8.6.1 requires the verification every 7 days that each battery float current is < 2 amps. This changes the CTS by adding an explicit Surveillance for battery float current. The purpose of SR 3.8.6.1 is to assist in the determination of the state of charge of the battery to assure the battery 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. This Surveillance is consistent with IEEE 450-1995. This change is acceptable since the Surveillance is necessary to help ensure the batteries remain OPERABLE. This change is designated as more restrictive because an explicit Surveillance Requirement has been added. Davis-Besse Page 1 of 8 Attachment 1, Volume 13, Rev. 0, Page 213 of 323

Attachment 1, Volume 13, Rev. 0, Page 214 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS M02 CTS 4.8.2.3.2.b.1 and the Category B limits in Table 4.8-1, in part, require verification that electrolyte level of each battery connected cell be within limit every 92 days. CTS 4.8.2.3.2.b.3 requires the electrolyte temperature of every sixth connected cell be verified within limit every 92 days. ITS SR 3.8.6.3 requires verification of each battery connected cell electrolyte level is greater than or equal to the established limit every 31 days. ITS SR 3.8.6.4 requires verifications of each pilot cell temperature is within limits every 31 days. This changes the CTS by increasing the frequency of performance of the Surveillances from 92 days to 31 days. The purpose of CTS 4.8.2.3.2.b.1 and the Category B limits in Table 4.8-1 is to ensure the electrolyte level is within the specified limit to ensure the battery plates suffer no physical damage and maintains adequate electron transfer capability. The purpose of CTS 4.8.2.3.2.b.3 is to ensure the battery can provide the required current and voltage to meet design limits. The applicable IEEE 450-1995 standard recommends a Surveillance Frequency of 31 days. The change is acceptable since it will help ensure the battery plates will not suffer physical damage and maintain adequate electron transfer capability and to ensure the battery can provide the required current and voltage to meet design limits. This change is designated as more restrictive because the Surveillance Requirement Frequency has been increased. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2 requires the average electrolyte temperature to be above 60 0 F. ITS SR 3.8.6.4 specifies the limit to be greater than or equal to the minimum established design limits. This changesthe CTS by relocating the actual value of electrolyte temperature 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. The ITS still retains the requirement that the battery cell temperature be greater than or equal to the minimum established design limits. 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 Specifications Bases Control Program in Chapter 5. 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. Davis-Besse Page 2 of 8 Attachment 1, Volume 13, Rev. 0, Page 214 of 323

Attachment 1, Volume 13, Rev. 0, Page 215 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS LESS RESTRICTIVE CHANGES L01 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.2.3.2.a.1 requires the verification that the pilot cell voltage is greater than or equal to the specified limit every 7 days. ITS SR 3.8.6.2 requires the verification of each pilot battery cell voltage every 31 days. This changes the CTS by extending the Surveillance interval for verification of pilot cell voltage from 7 days to 31 days. The purpose of CTS 4.8.2.3.2.a.1 is to ensure the cell float voltages are equal to or greater than the short term absolute minimum voltage. This change extends the Surveillance Frequency from 7 days to 31 days for verification of pilot cell voltage. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability, and is consistent with the Frequency recommended in IEEE-450, 1995. This change is also acceptable since ITS 5.5.16, "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. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. L02 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.2.3.2.b, in part, requires the performance of several Surveillances within 7 days after a battery discharge (battery terminal voltage below 110 volts), or battery overcharge (battery terminal voltage above 150 volts). ITS 3.8.6 does not require these Surveillances to be performed after a battery discharge or overcharge. This changes the CTS by not including a specific Surveillance Requirement to perform these tests after a discharge or overcharge. The purpose of the CTS 4.8.2.3.2.b Frequency is to ensure the battery remains OPERABLE after a severe battery discharge or overcharge. This change is acceptable because the proposed Surveillance Requirement Frequencies continue to ensure that it provides an acceptable level of equipment reliability. CTS 4.8.2.3.2.b, in part, requires the performance of several Surveillances within 7 days after severe battery discharge or battery overcharge. CTS 4.8.2.3.2.b.1 requires a verification that electrolyte level, float voltage, and specific gravity are within the specified limits. CTS 4.8.2.3.2.b.2 requires verification that there is no visible corrosion at either terminals or connectors, or the connections resistance are within limits. CTS 4.8.2.3.2.b.3 requires verification of average electrolyte temperature. CTS 4.8.2.3.2.b.2 is not required to be performed because corrosion rates and connection resistance are not believed to be immediately and significantly affected by a severe discharge or overcharge condition. ITS SR 3.8.6.1 requires verification that each battery float current is < 2 amps every 7 days. The float current requirements are based on the float current indicative of a charged battery. Therefore, this Surveillance will detect a discharge condition of the battery. In addition, ITS 5.5.16, "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on the recommendations of IEEE 450-1995. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-1995, Davis-Besse Page 3 of 8 Attachment 1, Volume 13, Rev. 0, Page 215 of 323

Attachment 1, Volume 13, Rev. 0, Page 216 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS and as such, will be maintained in the Davis-Besse procedures implementing ITS 5.5.16. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. L03 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.3.2.b.2 requires verification that there is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 10-6 ohms. CTS 4.8.2.3.2.c, in part, requires verification that the cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, the cell-to-cell and terminal connections are clean, tight and coated with anti-corrosion material, and the resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10-6 ohms. ITS 3.8.6 does not include these requirements for battery inspections, the removal of visible corrosion, and the verification that the cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material. This changes the CTS by deleting the explicit battery requirements from the Technical Specifications. The purpose of CTS 4.8.2.3.2.b.2 and CTS 4.8.2.3.2.c, for the Train 1 and Tra.in 2 batteries, is to ensure that the proper preventative maintenance type of battery activities are performed. In accordance with ITS SR 3.0.1, when any SR is not met, the LCO is not met. This is based on the premise that SRs represent the minimum acceptable requirements for OPERABILITY of the required equipment. However, the failure to meet these specific Surveillances do not necessarily mean that the equipment is not capable of performing its safety function. When the Train 1 and Train 2 batteries are capable of meeting ITS SR 3.8.4.1, the battery terminal voltage verification and ITS SR 3.8.4.3, the battery capacity test, they are considered to be able to meet their safety function. The Surveillances that are proposed to be deleted are considered preventative maintenance type activities and are not considered the minimum acceptable requirements for OPERABILITY of the batteries. This change is acceptable because the SR requirements proposed in ITS 3.8.4 continue to ensure that the batteries are maintained consistent with the safety analyses and licensing basis. In addition, ITS 5.5.16, "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on the recommendations of IEEE 450-1995. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-1995, and as such, will be maintained in the Davis-Besse procedures implementing ITS 5.5.16. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS. L04 (Category6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.8.2.3.2.b.3 requires the average electrolyte temperature of every sixth connected cell to be verified within limit. ITS SR 3.8.6.4 requires verification that each pilot cell temperature is within limits. This changes the CTS by monitoring the pilot cells instead of the every sixth connected cell. The purpose of CTS 4.8.2.3.2.b.3 is to ensure the battery can provide the required current and voltage to meet design limits. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. The change is acceptable because it will help ensure the battery can provide the required current and Davis-Besse Page 4 of 8 Attachment 1, Volume 13, Rev. 0, Page 216 of 323

Attachment 1, Volume 13, Rev. 0, Page 217 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS voltage to meet design limits. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. L05 (Category5 - Deletion of Surveillance Requirement) CTS 4.8.2.3.2.a.1 requires verification that the electrolyte level of each pilot cell is greater than the minimum level indication mark and < 1/4 inch above the maximum level indication mark every 7 days. ITS 3.8.6 does not include this requirement. This changes the CTS by deleting the requirement to monitor pilot cell electrolyte level every 7 days. The purpose of CTS 4.8.2.3.2.a.1 is to ensure the battery pilot cells contain sufficient electrolyte level for electron transfer capability. 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. 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 pilot cell Surveillance has been deleted, another Surveillance is included which help to ensure the batteries will function as designed. 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. The Frequency for verification of electrolyte level in CTS 4.8.2.3.2.b.1, for each connected cell, has been increased from every 92 days to every 31 days as discussed in DOC M02. This Surveillance give a better indication of the overall battery condition, since all connected cells are being checked. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS. L06 (Category5 - Deletion of Surveillance Requirement) CTS 4.8.2.3.2.a.1 requires the verification that the pilot cell specific gravity is within limit (the Category A limits of Table 4.8-1 as modified by footnote (c)) and CTS 4.8.2.3.2.b.1 requires the verification that the connected cell specific gravity is within limit (the Category B limits of Table 4.8-1). As indicated in Table 4.8-1 (footnote (a)) the specific gravity limit must be corrected for electrolyte temperature and level. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting these Surveillances. The purpose of CTS 4.8.2.3.2.a.1 and 4.8.2.3.2.b.1, the specific gravity verifications, is 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, another Surveillance is included that helps to ensure the batteries will function as designed. ITS SR 3.8.6.1 (discussed in DOC M01) requires the verification that each battery float current is < 2 amps every 7 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. This Surveillance (SR 3.8.6.1) gives a better indication of the overall battery condition. This change is designated as Davis-Besse Page 5 of 8 Attachment 1, Volume 13, Rev. 0, Page 217 of 323

Attachment 1, Volume 13, Rev. 0, Page 218 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS less restrictive because Surveillances which are required in the CTS will not be required in the ITS. L07 (Category6 - Relaxation Of Surveillance Requirement Acceptance Criteria) The Category A limits in Table 4.8-1 for the pilot cell voltage is > 2.13 V. The Category B limits in Table 4.8-1 for each connected cell voltage is 2!2.13 V corrected for average electrolyte temperature and the Allowable Value for each connected cell voltage is > 2.07V. ITS SR 3.8.6.2 requires the verification of each pilot cell voltage is > 2.07 V and ITS SR 3.8.6.5 requires the verification that each battery connected cell voltage is > 2.07 V. This changes the CTS by reducing the acceptance criteria for pilot cell and battery connected cell voltage limits from > 2.13 V to > 2.07 V. 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 the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. At this proposed lower voltage the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.16, "Battery Monitoring and Maintenance Program," has been added and 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 limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L08 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) The Categories A and B electrolyte level limit in Table 4.8-1 for each pilot cell and each connected cell is > minimum level indication mark, and < 1/4 inch above maximum level indication mark. Footnote (d) to the Table states it is acceptable for the electrolyte level to temporarily increase above the specified maximum during equalizing charges provided it is not overflowing. In addition, the Category B electrolyte level Allowable Value for each connected cell (which includes the pilot cells) is above the top of plates, and not overflowing. ITS SR 3.8.6.3 requires the verification that the electrolyte level for each connected cell is greater than or equal to minimum established design limits. This changes the CTS by deleting the specific value for the lower electrolyte level limit and deletes the upper electrolyte level limit requirement. The purpose of the proposed Surveillance limit in ITS SR 3.8.6.3 is to ensure the battery plates do not suffer physical damage and maintain adequate electron transfer capability. This change is acceptable because 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 specific value for the lower electrolyte level limit and replacing it with the minimum established design limit and deleting the upper electrolyte level limit requirement. This change is acceptable since the proposed level will continue to ensure that the battery and the cells remain OPERABLE to Davis-Besse Page 6 of 8 Attachment 1, Volume 13, Rev. 0, Page 218 of 323

Attachment 1, Volume 13, Rev. 0, Page 219 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS perform its specified safety function. This change is acceptable since ITS 5.5.16, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore electrolyte level when it falls below a specified value. This program will help ensure the electrolyte level will not approach the specified design limit. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. L09 (Category 4 - Relaxation of Required Action) CTS Table 4.8-1 Footnote (1) specifies compensatory actions for when Category A parameters are not within limit. The compensatory action allows the battery to be considered OPERABLE as long as all Category B measurements are taken and found to be within their allowable values, and provided all parameter(s) are restored to within limits within the next 6 days. CTS Table 4.8-1 Footnote (2) specifies compensatory actions for when Category B parameters are not within limit. The compensatory action allows the battery to be considered OPERABLE provided that they are within their allowable values and provided the parameter(s) are restored to within limits within 7 days. CTS Table 4.8-1 Footnote (3) states that any Category B parameter not within its allowable value indicates an inoperable battery. In lieu of immediately declaring the associated battery inoperable, the ITS 3.8.6 ACTIONS provide compensatory actions for when battery parameters are not within limits that may be taken prior to declaring the associated battery inoperable. This changes the CTS by adding compensatory actions specifically designed for battery parameters. 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. The ACTIONS are to be taken on a per battery basis as noted in the ACTIONS Note. 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. ITS 3.8.6 ACTION A requires the performance of SR 3.8.4.1 in 2 hours, the performance of SR 3.8.6.1 within 2 hours, and restoration of the affected cell voltage to within limits within 24 hours. ITS 3.8.6 ACTION B covers the condition of one or more batteries with float current not within the specified limit. ITS 3.8.6 ACTION B requires the performance of SR 3.8.4.1 in 2 hours and restoration of the battery float current to within limits within 12 hours. 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. ITS 3.8.6 ACTION C requires the restoration of electrolyte level to above top of plates within 8 hours, verification that there is no evidence of leakage within 12 hours, 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 Davis-Besse Page 7 of 8 Attachment 1, Volume 13, Rev. 0, Page 219 of 323

Attachment 1, Volume 13, Rev. 0, Page 220 of 323 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS batteries with pilot cell electrolyte temperature less than the minimum established design limits. ITS 3.8.6 ACTION D requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours. ITS 3.8.6 ACTION E covers the condition of batteries in redundant trains with battery parameters not within limits. ITS 3.8.6 ACTION E requires restoration of the battery parameters for battery in one train to within limits within 2 hours. ITS 3.8.6 ACTION F covers the condition when a Required Action and associated Completion Time of any of the above ACTIONS could not be met, or 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. ITS 3.8.6 ACTION F requires the immediate declaration that the associated battery is inoperable. 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 hours is allowed to restore at least one redundant train 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. L10 (Category 10 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.2.3.2.e.1, 4.8.2.3.2.e.2, and 4.8.2.3.2.e.3 contain a requirement to perform the battery performance discharge or modified performance discharge test "during shutdown." ITS SR 3.8.6.6 requires a similar test, and includes a Note that states the Surveillance shall not be performed in MODE 1, 2, 3, or 4. The Note also 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 that it is an unplanned event that satisfies the requirements of the SR. The purpose of CTS 4.8.2.3.2.e.1, 4.8.2.3.2.e.2, and 4.8.2.3.2.e.3 is to confirm the OPERABILITY of the batteries. This change is acceptable because the proposed Surveillance Frequency provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions at all times. It allows the unit to credit an unplanned event for satisfying the Surveillance, provided the necessary data is obtained. Furthermore, the proposed Surveillance Note still restricts planned performance of the Surveillance to MODES other than MODES 1, 2, 3, and 4. 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. Davis-Besse Page 8 of 8 Attachment 1, Volume 13, Rev. 0, Page 220 of 323

Attachment 1, Volume 13, Rev. 0, Page 221 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 221 of 323

Attachment 1, Volume 13, Rev. 0, Page 222 of 323 Battery Parameters 3.8.6 CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8,6 Battery Parameters

                           ,--      -VI                                 EWER'S NOTE -----               --------------------

Licensee's must implement a p ram, as specified in Specification 5.5.17 o monitor battery parameters that is based o Recommended Pract e recommendations of IEEE Standard or Maintenance, Testing, And Replac 0-1995, "IEEE ent Of Vented Lead-Acid 0 Batteries For S ary Applications." DOC A02 LCO 3.8.6 Battery parameters for the Train[Iand Train -batteries shall be within limits. 0 DOC APPLICABILITY: When associated DC electrical power subystems are required to be 0 A02 OPERABLE. L__ E ACTIONS Table 4.8-1

               -------------------------------------------------------------NOTE.

footnotes Separate Condition entry is allowed for each battery. (1), (2), and (2) CONDITION REQUIRED ACTION COMPLETION TIME A. One @or batterWjes A.1 Perform SR 3.8.4.1 2 hours Table 4.8-1 footnotes (1), 0 n o train with one or more battery cells float 0) 0 (2), and (3) AND voltage PO071V. A.2 Perform SR 3.8.6.1. 2 hours AND A.3 Restore affected cell 24 hours voItagqP2.07[V. 0 Table 4.8-1 B. One oribattef-y]1ies on op, rain ith f1lo B.1 Perform SR 3.8.4.1. 2 hours 0) footnotes (1), (2), and (3) current > 21 amps. AND 0 B.2 Restore battery float current to < 12Eamps. I1 21hours 0 BWOG STS 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 222 of 323

Attachment 1, Volume 13, Rev. 0, Page 223 of 323 Battery Parameters CTS 3.8.6 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. C. One*or * -eR*es C.1 Restore electrolyte level to 8 hours Table 4.8-1 footnotes (1), (2), and on o trainwith one or above top of plates. 0 (3) more cells electrolyte level less than minimum AND established design limits. C.2 Verify no evidence of 12 hours leakage. AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits. Table 4.8-1 footnotes D. One *orjbatte [ries [or rain with pilot D.1 Restore battery pilot cell temperature to greater than 12 hours 0 (1), (2), and (3) cell electrolyte or equal to minimum temperature less than established design limits. minimum established design limits. Table 4.8-1 footnotes E. ne moreltatteries in redundant trains with E.1 Restore battery parameters for batteries in one train to 2 hours 0 (1), (2), and (3) battery parameters not within limits. within limits. BVWOG STS 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 223 of 323

Attachment 1, Volume 13, Rev. 0, Page 224 of 323 Battery Parameters 3.8.;6 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Table 4.8-1 F. Required Action and F.1 Declare associated battery Immediately footnotes associated Completion inoperable. (1), (2), and (3) Time of Condition A, B, C, D, or E not met. OR more Onelor obattertmes Ion o train with one or 0 more battery cells float voltage][2.071 V and ifoa current >12*Jamps. 0 SR 3.8.6.6 not met. 0 SURVEILLANCE REQUIREMENTS " SURVEILLANCE FREQUENCY DOC MO1 SR 3.8.6.1 ---------------------- NOTE--------------- Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. Verify each battery float current is _< M2ý]amps. 7 days 0 4.8.2.3.2.a.1 Table 4.8-1 SR 3.8.6.2 Verify each battery pilot cell voltage [2.07*V. 31 days 0 4.8.2.3.2.b.1, SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days Table 4.8-1 greater than or equal to minimum established design limits. 4.8.2.3.2.b.3 SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits. BVWOG STS 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 224 of 323

Attachment 1, Volume 13, Rev. 0, Page 225 of 323 Battery Parameters 3.8.6 CTS SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4.8.2.3.2.b.1, SR 3.8.6.5 Verify each battery connected cell voltage is 92 days 0 Table 4.8-1 ru2 071 V. 4.8.2.3.2.e SR 3.8.6.6 --

                                         --- - ----------NOT E - -- -- - -- -- - -- --

This Surveillance shall not be performed in MODE 1, 2, 3, or 4./However, portions of tt e Surveillance/ may be p rformed to reestablish O0 ERABILITY/ provided an assessment determinL h safety of/ tthepla smintained or enhanc d.I Credit may be taken for unplanned events that satisfy this SR. Verify battery capacity is >[!,80%1 of the manufacturer's rating when subjected to a 60 months 0 performance discharge test or a modified performance discharge test. AND 12 months when battery shows degradation, or has reached [85r/o of the expected life with 0 capacity< 100% of manufacturer's rating AND 24 months when battery has reached R85r/o of the expected life 0 with capacity

                                                                                       > 100% of manufacturers rating BWVOG STS                                  3.8.6-4                         Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 225 of 323

Attachment 1, Volume 13, Rev. 0, Page 226 of 323 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 3.8.6 Conditions A, B, C, D, E, and F have been modified to allow batteries in two trains to have 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 is also consistent with the current licensing basis.

5. Changes are made to reflect plant specific nomenclature.

6. This allowance has been deleted consistent with TSTF-360, Rev. 1. This TSTF was previously approved and was incorporated into NUREG-1430, Rev. 2. However, this portion of the TSTF was inadvertently not incorporated.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 226 of 323

Attachment 1, Volume 13, Rev. 0, Page 227 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 227 of 323

Attachment 1, Volume 13, Rev. 0, Page 228 of 323 Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGROUND This LCO delineates the limits on battery float current as well as cell electrolyte temperature, level, and float voltage for the DC4Iower i(D sc subssem 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, the j[licensep ntro e ro amalso implements a program specified in Specification 5.5. for monitoring various battery parameters that is based on the 16 recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications" (Ref. 1). FBattery Monitoring and (,Maintenance Program The battery cells are of flooded lead acid construction with a nominal specific gravity ofM1.2151ý This specific gravity corresponds to an open 0 circuit battery volage of approximately 120 V for [58] c ll battery (i.e., cell voltage of [2.06 volts per cell (Vpc)). The open circu t voltage is the voltage maintaired when there is no charging or disc rging. Once fully charged with its/open circuit voltage _>[2.065] Vpc, th battery cell will 0 maintain its calacity for [30] days without further cha ging per manufacturer'q instructions. Optimal long term performance Ihovdver, is _ obtained by maintaining a float voltag[to 2.25JVpc. This provides (D adequate over-potential which limits the formation of lead sulfate and self discharge. The no al float voltage of [2.22] Vpc correspontls to a total

                        /foat-voltage o(I pu of [128.8] V for a [58] cell batterypa-"*iscussed in h SFSAR, Cýýl err [8] (Ref. 2).F APPLICABLE              The initial conditions of Design Basis Acciden2DBA)an rNient f-3 SAFETY                  analyses in thelFSAR               er    (Ref. wand Ia                     (Ref. ,-                 @    2N ANALYSES                assume Engineered Safety Featuretsystems are OPERABLE. The DC SUFSAR. Section 6      electrical power system provides normal and emergency DC electrical Epower for theDGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of DC subsystems is consistent wi e initial assumptions of t accident analyses and is based design bas' the unit. This includes maintai DC s ces OPERABLE during accident meeting the at least one train of itions, in the event of: 0 The specific Applicable Safety Analyses for the DC Electrical Power System are provided in the Bases for LCO 3.8.4 and LCD 3.85. BVVOG STS B 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 228 of 323

Attachment 1, Volume 13, Rev. 0, Page 229 of 323 Battery Parameters B 3.8.:6 BASES APPLICABLE 'SAFETY ANALYSES (continued)

a. An assumed loss I offsite AC power or all onsite A wer and 0

b. A -case single failure.

Battery parameters 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 ,lectrical~ystem function even with 0 limits not met. Additional preventative maintenance, testing, and 'Battery monitoring performed in accordance with the lflicensee-ontrolledJ&] Mainte*andc 0 ro is conducted as specified in Specification 5.5.[Z-V¶E Program 0 0D APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical powe subs tems. Therefore, battery

                        @parameter limits are only required when the DCipower source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACT IONS A.1, A.2, and A.3 With one or more cells in one or more batteries in o erain P.07lV, the battery cell is degraded. Within 2 hours~verification of the required battery 0 0 required charger OPERABILITY is 5 by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of chargeby monitoring the au 08 S erification I 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 E22.07 V, and continued operation is permitted for a limited period Up tO 24 hours.- 0 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. BVVOG STS B 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 229 of 323

Attachment 1, Volume 13, Rev. 0, Page 230 of 323 Battery Parameters B 3.8.6 BASES ACTIONS (continued) B.1 and B.2 One or more batteries n rain with float current> M2M amps indicates 06 0 that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of a battery charger or possibly due to one or D more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours~verification of the required battery charger reurd OPERABILITY isI'ý by monitoring the battery terminal voltage. If the terminal voltage 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. FCondition A sses charger If the charger is operating in the current limit mode after 2 hoursthat is an indication that the battery has been substantially 0 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 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

                 *142 hours (Required Action B.2). The battery must therefore be declared inoperable.

Q If the float voltage is found to be satisfactorylbut there ar*q'ne or more battery cells wit 0lo otage less than [2.07] V, the oitd"R statement in Co ition F is applicable and the b tr'y must be declared inoperablej'ediately. If float voltage is satfactory and there are no cells le* han [2.07] V there is good assurance that, within 1121j hours, the battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery charger.

                        -------------------- EVIEWER'S NOTE------                         ------------

A plant that cannot et the 12 hour Completion Time due an inherent battery charging aracteristic can propose an alternat me equal to 2 hours plus time experienced to accomplish th xponential charging current po on of the battery charge profile follo g the service test (S.R 3. .4.3). BVWOG STS B 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 230 of 323

Attachment 1, Volume 13, Rev. 0, Page 231 of 323 Battery Parameters B 3.8.6 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 *]12E]hours, avoiding a premature shutdown with its own attendant risk. If the condition is due to one or more cells in a low voltage condition but still greater than T2.071 V and float voltage is found to be satisfactory, this is noindication of a substantially discharged battery and V12Ehours is a (D 2 L!Lý 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. C.1, C.2, and C.3 With one or more batteries r with one or more cells electrolyte level above the top of the plates, but below the minimum established 0 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 Fl dryout and plate degradation. Required Actions C.1 and C.2 address this potential (as well as provisions in Specification 55./7,,Battery Monitoring 0 D and Maintenance Prograrnr). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates. ZfrWith~in hoursýlevel is required to be restored to above the top of the requirement plates. The Required Action C.2 requirement to verify that there is no /" leakage by visual inspection and the Specification 5.5 bff/1o.b oinitiate ) action to equalize and test in accordance with manufacturer's 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 battegies*]may have to be declared inoperable and the affected celllreplaced. BWVOG STS B 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 231 of 323

Attachment 1, Volume 13, Rev. 0, Page 232 of 323 Battery Parameters B 3.8.6 BASES ACTIONS (continued) D. 1 With one or more batteries nwith pilot cell temperature less than the minimum established design limits, 12 hours 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 n batteries in redundant trains with battery parameters not within limits there is not sufficient assurance that battery capacity has 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 train within 2 hours. F.1 For failure of SR With one or more batteries with any battery parameter outside the 3.8.6.6, / allowances of the Required Actions for Condition A, B, C, D, or E, i*sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable. Additionally, discovering one or more batteries in one train with one or more battery cells float voltage less thanp2.07M]V and float current greater" than42Mamps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared 0 inoperable immediately. BVWOG STS B 3.8.6-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 232 of 323

Attachment 1, Volume 13, Rev. 0, Page 233 of 323 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 ofthe 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 than the The float current requirements are based on the float current indicative of recommendations of Ja 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 consnt with 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 taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit ofR21 amps 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 Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits, provided by the battery manufacturer, which corresponds to1 ((T) V at the battery terminals, or'"[2f5]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 this range or less, but greater than M2.01 Vpc, are addressed in , SRs 3.8.6.2 and 3.8.6.5 require verification that the cell float voltages are e greater than the short term absolute minimum voltage ofp2.071V. The Frequenc or cell voltage verification 008 every 31 days for pi ot cell and 92 days for each connected cell[i-1%) I i consistent with IEEE-450 (Ref. 1). 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). BWVOG STS B 3.8.6-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 233 of 323

Attachment 1, Volume 13, Rev. 0, Page 234 of 323 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.6.4 60 This Surveillance verifies that the pilot cell temperature is greater than or-equal to the minimum established design limit (i.e., [0]"). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provide 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 pe-rf o-rmanc~ rated capacity. Initial conditions for the modified performance discharge dischatest should be identical to those specified for e test.---.- Fas specified in IEEE-450 (Ref. 1) 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 one f discharge minute discharge represents a very small portion of the battery capacity, c ncangýed test rate can be changed to thata for thfor the performanc(testf mthe compromising e resu s oe fr an ts witout0 pe ormance 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. BWOG STS B 3.8.6-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 234 of 323

Attachment 1, Volume 13, Rev. 0, Page 235 of 323 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued) The acceptance criteria for this Surveillance are consistent with IEEE-450 [ (Ref. 1) and IEEE-485 (Ref. W. These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements. Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this P0P%limit. 0 The Surveillance 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 90% of retain capacity > 100% of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is

belovthe manufacturers rating. (D These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. /This restriction from normallyap rforming the Surveillance in MOa ae E p2r is furtheri amplified

                                                              ,     toc allow ortions of the Surveillance to be perftaond for the purpose of reestabli hing OPERABILITYoe      e g ost opeork tesdindependent fortpati e maintenance, corrective modip ator pr      cient or incomplete surveilltlhce testing, and other unantimpated          agPEAIT theais)       provi eo an assessment determines pthatpantsaetis maintained or enhanced.           is assessment shall, as a minimu n, consider the potential outcome* and transients associated with a/failed partial Surveillance., a succ ssful partial Surveillance, an* a perturbation of the offsite or on ite system when they are tied togethe for operated independently for th }partial Surveillance; as well as the ope 'ator procedures available to cope/with these outcomes.

These shall bemaured against the avoided ris/ of a plant shutdown and startup to/determine that plant safety is mai tained or enhanced when portion of the Surveillance are performe in MODE 1 or 2. Risk insights or terministic methods may be use for the assessment. Credit may be taken for unplanned events that satisfy this SR. BWAOG STS B 3.8.6-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 235 of 323

Attachment 1, Volume 13, Rev. 0, Page 236 of 323 Battery Parameters B 318.6 BASES REFEREENCES 1. IEEE-45O01995E 0 u 2. FSARCapter[81.1 0 LIIF-7\EIFSAR,[ a erM 00 S*FSAR, a* r Section 15 00 IEI . IEEE-485-11983 June 1983. 00 BWAOG STS B 3.8.6-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 236 of 323

Attachment 1, Volume 13, Rev. 0, Page 237 of 323 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. Furthermore, the batteries are not maintained on open circuit. Thus, these statements are deleted.

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, 3, and 4 (ISTS 3.8.4) and in MODES 5 and 6 and during movement of irradiated fuel assemblies (ISTS 3.8.5). The Applicable Safety Analyses Bases only discusses accident analyses related to MODES 1, 2, 3, and 4; it does not discuss events in MODES 5 and 6 and during movement of irradiated fuel assemblies. Therefore, for completeness, the Applicable Safety Analyses for MODES 5 and 6 and during movement of irradiated fuel assemblies needs to be discussed. However, in lieu of adding this large description from the ISTS 3.8.5 Bases, the MODES 1, 2, 3, and 4 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.

9. This allowance has been deleted consistent with TSTF-360, Rev. 1. This TSTF was previously approved and was incorporated into NUREG-1430, Rev. 2. However, this portion of the TSTF was inadvertently not incorporated.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 237 of 323

Attachment 1, Volume 13, Rev. 0, Page 238 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 238 of 323

Attachment 1, Volume 13, Rev. 0, Page 239 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 239 of 323

, Volume 13, Rev. 0, Page 240 of 323 ATTACHMENT 7 ITS 3.8.7, INVERTERS - OPERATING , Volume 13, Rev. 0, Page 240 of 323
, Volume 13, Rev. 0, Page 241 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 241 of 323

Attachment 1, Volume 13, Rev. 0, Page 242 of 323 ITS 3.8.7 ITS Add prposedITS 3.8 .7 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 242 of 323

Attachment 1, Volume 13, Rev. 0, Page 243 of 323 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirement for inverters to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.8.7 requires the Train 1 and Train 2 inverters to be OPERABLE in MODES 1, 2, 3, and 4. This changes the CTS by incorporating the requirements of ITS 3.8.7. The safety related function of the Train 1 and Train 2 inverters is to provide an uninterruptible power supply for the 120 VAC vital buses. This change is acceptable because the safety analyses assume that the loads supported by the 120 VAC vital buses have an uninterruptible supply of AC electrical power even if the 4.16 kV essential buses are de-energized. 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 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 243 of 323 o,

Attachment 1, Volume 13, Rev. 0, Page 244 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 244 of 323

Attachment 1, Volume 13, Rev. 0, Page 245 of 323 Inverters - Operating 3.8.7 . CTS 3:8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating DOC M01 LCO 3.8.7 The r Train Aand Train 5 inverters shall be OPERABLE. 0 ((One/two] inverter[s] may be disconnected from [its/the r] associated DC bus for _ hours to perform provided: an equalizing charge on [' s/their] associate [common] battery

a. Th associated AC vital bus(es) [is/are] energiz d from [its/their]

0 [CI ss 1E constant voltage source transformers [inverter using 2/ inmrnal AC source] and

b. I other AC vital buses are energized from th ir associated PERABLE inverters. ]

DOC M01 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One [reqired] inverter inoperable. A.1 ---------- NOTE------- Enter applicable Conditions 0 and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any vital bus de-energized. 120 --- - - -- - - Restore inverter to 24 hour--{GJt 0 OPERABLE status. 47ýET 1 0 DOC M01 [Required Action and V. -Be in MODE 3. 6 hours 0 associated Completion Time not met. AND V2 Be in MODE 5. 36 hours 0 BWOG STS 3.8.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 245 of 323

Attachment 1, Volume 13, Rev. 0, Page 246 of 323 3.8.7 O* INSERT 1 DOC M01 B. Two inverters in one B.1 Restore one inverter to 8 hours train inoperable. OPERABLE status. Insert Page 3.8.7-1 Attachment 1, Volume 13, Rev. 0, Page 246 of 323

Attachment 1, Volume 13, Rev. 0, Page 247 of 323 Inverters - Operating O CTS 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M01 SR 3.8.7.1 FV--icorrect inverter voltaae. Illfreauencv.M-and 7 days BVWOG STS 3.8.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 247 of 323

Attachment 1, Volume 13, Rev. 0, Page 248 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train 1 and Train 2 inverters are required.

2. This allowance of the ISTS LCO 3.8.7 Note has been deleted because Davis-Besse does not need to disconnect the 120 VAC vital bus during an equalizing charge.

3. Changes made to be consistent with changes made in another Specification.

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

5. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated 120 VAC vital bus.

6. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 8 hours. The Davis-Besse design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3 when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support engineered safety features operation. Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 8 hours has been selected to be consistent with the allowed outage time in ITS 3.8.9 for two inoperable 120 VAC buses in the same train. In addition, the subsequent ACTION has been renumbered.

7. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 248 of 323

Attachment 1, Volume 13, Rev. 0, Page 249 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 249 of 323

Attachment 1, Volume 13, Rev. 0, Page 250 of 323 Inverters - Operating B 3.8.7 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters are the preferred source of power for theýAC vital buses 120-because of the stability and reliability they achieve. The function of_&r _l inverter is to provide AC electrical power to the~vital bus. The inverterssoid eecan be powered from an internal AC source/rectifier or from the station 1 VAC INST 1battery. statio atte provides an uninterruptible power source for the instrumentation and controls for the Reactor Protection System (RPS) and the ESafety Featur Actuation System (SFAS). Specific SIon" details on inverters and their operating characteristics are found in4FSAR,

               .3      Cha er [8 (Ref. 1).                         ifondjS                     j APPLICABLE              The initial conditions of Design Basis Accident (DBA) and transient          Section   15 SAFETY                  analyses in th FSAR,        apter 6 (Ref. 2)g)and ICha pt-r [14] Ref. 3),

ANALYSES assume Engineered Safety Feature~systems are OPERABLE. The LC) 0 UFSAR, inverters are designed to provide the required capacity, capability, Section 6 redundancy, and reliability to ensure the availability of necessary power to the RPS and E[]SFAS instrumentation and controls so that the fuel, (D Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems. The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required/AC vital buses 120 V ) OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC electrical power or all onsite AC electrical power~and r-._ N

                                                                              ~jJ                                   KL)

b. A worst-case single failure.

Inverters are a part of 4 electrical power distribution system and, as such, satisfy 0 Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO The inverters ensure the availability ofrAC electrical power for the 0 systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. BWOG STS B 3.8.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 250 of 323

Attachment 1, Volume 13, Rev. 0, Page 251 of 323 B 3.8.7 O INSERT 1 Four rectifiers are provided to supply normal DC power to the four essential inverters. Each rectifier output is connected in parallel with the DC panel reserve supply to the inverter. The output voltage of the rectifier is maintained higher than the station battery voltage, which reverse-biases a coupling diode to prevent current flow from the reserve supply, and to prevent back-feeding of the DC system. The failure of the rectifier AC source and/or of the rectifier itself will forward bias the coupling diode, and cause the battery and/or battery charger to become the DC source to the essential inverter with no power interruption. Insert Page B 3.8.7-1 Attachment 1, Volume 13, Rev. 0, Page 251 of 323

Attachment 1, Volume 13, Rev. 0, Page 252 of 323 Inverters - Operating B 3.8.7 BASES LCO (continued) Maintaining the required inverters OPERABLE ensures that the redundancy incorporated into the design of the RPS and [ESFAS Q instrumentation and controls is maintained. The four invertersF(two per 2 train)Mensure an uninterruptible supply of AC electrical power to the 0 vital buses even ifthe 4.16 kVsa-Teybuses are de-energized. (ýT_ 0 OPERABLE inverters require the associatedital us to be powered by 0 the inverter with output voltage and frequency within tolerances, power input to the inverter from a 125 VDCM]station battery. Alternatively, power supply may be from an in na-AC sourcetvia rectifier as long as and

                                                                                                            ) c*

the station battery is available as the uninterruptible power supply. or battery charger K This LCO i modified by a Note that allows [one/two] inv rters to be disconne d from a [common] battery for > 24 hours, if the vital bus(es) is powere from a [Class 1 E constant voltage transfor er or inverter using inte nal AC source] during the period and all oth r inverters are operable. This allows an equalizing charge to be pla d on one battery. If the inv rters were not disconnected, the resulting vo tage condition might da age the inverter[s]. These provisions mini ize the loss of equipmee t that would occur in the event of a loss of ofsite power. The 24 hour ime period for the allowance minimizes the t me during which a 0 loss of ffsite power could result in the loss of equip ent energized from the affe ted AC vital bus while taking into considera on the time required to perf rm an equalizing charge on the battery bank The in ent of this Note is to limit the number of inve ters that may be disco nected. Only those inverters associated wit the single battery unde oing an equalizing charge may be disconne ed. All other inver ers must be aligned to their associated batte ies, regardless of the num er of inverters or unit design. APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 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 b.

                      ,and Adequate core cooling is provided, and containment OPERABILITY 0

and other vital functions are maintained in the event of a postulated DBA. Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown." 0 and other conditions in which] inverters are required BVWOG STS B 3.8.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 252 of 323

Attachment 1, Volume 13, Rev. 0, Page 253 of 323 Inverters - Operating B 3.8.7 BASES ACTIONS A.1 Train 1 or Train 2 Wth a u inverter inoperable, its associated i bus becomes Q "ioperableutlit is menergized from its Class 1E constant 2 voltage so-rTe transformerlor inverter usihnernal A source I 2 _2 ffor this reason, a Note has been included in Condition A re uirin entry into the Conditions and Required Actions of LCO 3.8.Dist*;ution 1 that propereaction [Syslerms - 0e rtin ." This ensurest-d vital bus isr-for Adee rgied t Required Action A.1 allows 24 hours to fix the inoperable taken inverter and return it to service. The 24 hour limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety 120 V systems such a shutdown might entail. When the4C vital bus is powered Ifrom itsconstant v olsoe it is relying upon interruptible AC 0 tranr electrical power sources (offsite and onsite). The uninterruptible inverter 20V source to the C vital buses is the preferred source for powering J instrumentation trip setpoint devices. l n 0 0 Train 1 or Train 2 inverters If the inoperable lde6ices or cam nent cannot be 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 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with 1120-VI all required circuit breakers closed andAC vital buses energized from the 0 0 associated inverter. tThe verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and [SFAS connected to the4AC vital buses. The 7 day Frequency 0 takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions. Each inverter may be connected to its associated rectifier as long as the battery is available as the uninterruptible power supply. 0 BWOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 253 of 323

Attachment 1, Volume 13, Rev. 0, Page 254 of 323 B 3.8.7 O INSERT 2 LCO 3.8.9, "Distribution Systems-Operating," addresses this action however, pursuant to LCO 3.0.6, this action would not have to be entered even if the 120 VAC vital bus were de-energized. 0 INSERT 3 B.1 With two inverters in the same train inoperable, the remaining inverters are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in one of the two remaining inverters could result in the minimum ESF functions not being supported. Therefore, one of the inverters must be restored to OPERABLE status within 8 hours. The 8 hour Completion Time is consistent with that allowed for an inoperable train of 120 VAC vital buses. Insert Page B 3.8.7-3 Attachment 1, Volume 13, Rev. 0, Page 254 of 323

Attachment 1, Volume 13, Rev. 0, Page 255 of 323 Inverters - Operating B 3.8.7 BASES

1. FSARS REFERENCES 2 FSAR, [g r 41 6-

3. FSAR, 15 00 BVWOG STS B 3.8.7-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 255 of 323

Attachment 1, Volume 13, Rev. 0, Page 256 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, INVERTERS - 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 have been removed and the proper plant specific information/value has been provided.

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made to reflect those changes made to the ISTS.

5. Changes are made to be consistent with the Specifications.

6. Editorial correction made.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 256 of 323

Attachment 1, Volume 13, Rev. 0, Page 257 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 257 of 323

Attachment 1, Volume 13, Rev. 0, Page 258 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, INVERTERS - OPERATING There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 258 of 323

, Volume 13, Rev. 0, Page 259 of 323 ATTACHMENT 8 ITS 3.8.8, INVERTERS - SHUTDOWN , Volume 13, Rev. 0, Page 259 of 323
, Volume 13, Rev. 0, Page 260 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 260 of 323

Attachment 1, Volume 13, Rev. 0, Page 261 of 323 ITS 3.8.8 ITS A-dd proposedIS3.8.8 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 261 of 323

Attachment 1, Volume 13, Rev. 0, Page 262 of 323 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirement for inverters to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies. ITS 3.8.8 requires one inverter to be OPERABLE to support the 120 VAC vital electrical distribution subsystem required by LCO 3.8.10, "Distribution Systems-Shutdown." This changes the CTS by incorporating the requirements of ITS 3.8.8 The safety related function of the Train 1 and Train 2 inverters is to provide an uninterruptible power supply for the 120 VAC vital buses. This change is acceptable because this ensures one 120 VAC vital bus has an uninterruptible supply of AC electrical power even if the associated 4.16 kV essential bus is de-energized. 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 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 262 of 323

Attachment 1, Volume 13, Rev. 0, Page 263 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 263 of 323

Attachment 1, Volume 13, Rev. 0, Page 264 of 323 Inverters - Shutdown 3.8.8 . CTS 3.1 ELECTRICAL POWER SYSTEMS 0 3.8.8 Inverters - Shutdown DOC M01 LCO 3.8.8 [Inverters hall be OPERABLE to support the onsite lass 1 E AC vital bus ele rical power distribution subsystem(s) req *red by LCO 3.8.10, "Distri ution Systems - Shutdown." 1 0 L'to support the 120 VAC vital electrical distribution 0) inverterr-_lOne* shall be OPERABLE sLi lsubsystem S---------REVIEWER'S NOTE required by LCO 3.8.10, "Distribution lSystems-Shutdown." I This secon option above applies for plants having a pr -ITS licensing basis (CT ) for electrical power requirements during s tdown conditions that requi ed only [one] inverter to be OPERABLE. Th "[or more]" optional ording in Condition A is also eliminated for is case. The first 0 option a ove is adopted for plants that have a CTS r quiring the same level of DC electrical power subsystemrinverter sup ort as is required for power perating conditions. APPLICABILITY: MODES 5 and 6, During movement of r irradiated fuel assemblies. 0 ACTIONS

                                           ------------------        NO     r------------------------------------------------------------

LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME A. One [or ore] ~equiredc A.1 //eclare

                                                            /feature(s) affected        required        /Immediately DOC M01 inverter[E inoperable.                                         inoperable.           /                                            0 A.2.1/       uspend CORE I    ALTERATIONS.
                                                                                                                                                  -471 BWVOG STS                                                  3.8.8-1                                       Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 264 of 323

Attachment 1, Volume 13, Rev. 0, Page 265 of 323 Inverters - Shutdown 3.8.8 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A.*-J Suspend movement of Immediately l[rec ntly]l irradiated fuel -4712)0 TSTF assemblies. 0 A.M*S-uspend operations involving positive reactivity Immediately 0

                                                                                               -4(TSTF47 additions that could result in loss of required SDM or boron concentration.                                    (2
                                 --IRV-0 A2fnitate action to restore required inverterM to Immediately              TSTF
                                                                                               -471 0

OPERABLE status. DOC M01 BWVOG STS 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 265 of 323

Attachment 1, Volume 13, Rev. 0, Page 266 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, INVERTERS - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.8 and "Reviewer's Note" have been deleted because the current licensing basis does not include any requirements for inverters to be OPERABLE. ISTS 3.8.8 Required Action A.1 provides an option to declare affected required feature(s) inoperable with one or more required inverters inoperable. The ISTS Bases states that this is acceptable since the remaining inverters may be capable of supporting sufficient features to allow continuation of fuel movement. Therefore, this Required Action assumes more than one inverter is required by the LCO. This option has been deleted since only one inverter is required to be OPERABLE by ITS LCO 3.8.8. The subsequent Required Actions have been renumbered and modified, as applicable.

2. The second option of ISTS LCO 3.8.8 is not specific as to what the 120 VAC inverters must be powering. The LCO has been modified to require one inverter to be powering one of the 120 VAC vital buses required by LCO 3.8.10. In addition, SR 3.8.8.1 has been modified to reflect that all inverters at the unit are not required to be OPERABLE and that the required inverter must be aligned to the associated 120 VAC vital bus.

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

4. Changes made to be consistent with changes made in another Specification.

5. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 266 of 323

Attachment 1, Volume 13, Rev. 0, Page 267 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 267 of 323

Attachment 1, Volume 13, Rev. 0, Page 268 of 323 Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating." APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient Section 15 SAFETY analyses in th FSAR apter 6 (Ref. 1) and lChapter [14 ](Ref. 2),), ANALYSES assume Engineered Safety Featureýsystems are OPERABLE. The DC to UFSAR. AC inverters are designed to provide the required capacity, capability, Section 6 redundancy, and reliability to ensure the availability of necessary power to the Reactor Protection System and ngere Safety Features Actuation System (ESFAS) instrumentation and controls so that the fuel, Reactor Coolant Systeni, and containment design limits are not exceeded. The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. ,I {*-'* *rqred d120V The OPERABILITY ofthe rAimuinverte]to AC vital bus during ( 0 MODES 5 and %ensures that: and during movement of irradiated fuel assemblies

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

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statusfand

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident/[involvir handling recentlyirdae/ ul Due to radioactive decay, te inverters areI only requiredI to mitigate fuel handling accidents ir olving handling recently irradia ed fuel (i.e., fuel that has occupied part of a critical reactor core wthin the previous [Xj days)].

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 all onsite power is not required. The rationale for this is based on the fact that many DBAs that are analyzed in MODESTf1, 2, 3, and 4fl]have no specific analyses in BVVOG STS B 3.8.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 268 of 323

Attachment 1, Volume 13, Rev. 0, Page 269 of 323 Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) MODES M5 and ,6r because the energy contained 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. The inverters were previously identified as part of thetdistribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). power 0 LCO The invertelsiensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and required maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Th atteroweredinverteq]} provides nes uninterutil esupply of AC electrical power to theAC vital buse yen 0 0 lif the 4.16 kV safe -t-.es are de-energizedl. OPERABILITY o e 120V inverterfJ require that the vital bus b- wered by the inverter. This ensures the availability of sufficient inverter power sources to operate the 0( 0 unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [nvolvifg handling I Irecently hadiated fuel] . 0 Sthe associated 120 VAC vital bus to be powered by the inverter with output voltage and frequency within tolerances, and power input to the inverter from a 125 VDC station battery. Alternately, power supply may be from an AC Source or battery charger via rectifier as long as the station battery is available as the uninterruptible power supply BWOG STS B 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 269 of 323

Attachment 1, Volume 13, Rev. 0, Page 270 of 323 Inverters - Shutdown B 3.8.8 BASES APPLICABILITY The inverte required to be OPERABLE in MODES 5 and 6, and during 004 movement of ec-tl irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the coref

b. Systems neededto mitigate a fuel handlin accident [involving 0

Shandling recen y irradiated fuel (i.e., fuel that h~as/ocupied part of a/

                       /critical reactor core within the previous [X] days)] are availablelF         0 0

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are availablec and 0

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

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7. ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, 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 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily. IA.1 A.2.1. A.2.2. A.2.3 ,grdA .2. TA1,.2,and A.3] 0 [If two trains are r uired by LCO 3.8.10, "Distributio Systems - Shutdown," the re aining OPERABLE inverters ma be capable of supporting suffici nt required features to allow con inuation of i- cp -- 7 AEL/T jN0f uel movement [involving handlin recently irradiated fuel], and opera ons with a potential for positive reactivity additions that could result in I1ss of required SDM (MODE 5) or oron concentration (MODE 6).] S/spending positive reactivity additi ns that could result in failure to meet/the minimum SDM or boron conc ntration limit Fis -required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron BWOG STS B 3.8.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 270 of 323

Attachment 1, Volume 13, Rev. 0, Page 271 of 323 B 3.8.8 O INSERT 1 With the required inverter inoperable, suspension of movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) specified in LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," or boron concentration (MODE 6) specified in LCO 3.9.1, "Boron Concentration," Insert Page B 3.8.8-3 Attachment 1, Volume 13, Rev. 0, Page 271 of 323

Attachment 1, Volume 13, Rev. 0, Page 272 of 323 Inverters - Shutdown B 3.8.8 BASES ACTIONS (continued) concentration, but provides acceptable margin to maintaining:subcritical operation. Introduction of temperature changes including temperature modperaturrating Ftemp0errau re icessw with a positivMTCihrust also be evaluat coefficient( ensure they do not result in a loss of required SDM. By the allowance of the option to dec are required features inopVerabliie With the associated inverter(s) inopej'able, apropriate restrictions will *e implemented in accordance wit the affected required features L Os' Required Actions In many instaes thi option may involve undes red administrative (3) (-D efforts. Therefl-re, the allowance for sufficiently .onservative -actions is TSTF made (i.e., to uspendICORE ALT-ERATIONS ovement of [recently] -471 irradiated fuel/assemblies, and operations invol ing positive reactivity additions). 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 inverterm and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverter[] should be completed as quickly as possible in order to minimize *-4 f1E the time the unit safety systems may be without power or powered from a/-,) ..,,1 [or non-essential power source} constant voltage s transformer* SURVEILLANCE SR 3.8.8.1 tuired REQUIREMENTS This Surveillance verifies that the nverte a ioning properly with 0-(7> (D The inverter may be connected to' all required circuit breakers closed and AkC vital buso energized from the (D (D its associated rectifier as long as inverter. The verification of proper voltage and frequency output ensures the battery is available as the isaalbefrthDntu etto uninterruptible power supply. that the required power is readily available for the instrumentation

k,(

connected to thedC vital buso. The 7 day Frequency takes into account thelredundant capab f the inverters andlother indications available in the control room that alert the operator to inverter malfunctions. 0 REFERENCES 1 FSAa }t ( 2 FSAR, [14 eChapter 15( ecton BVVOG STS B 3.8.8-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 272 of 323

Attachment 1, Volume 13, Rev. 0, Page 273 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, INVERTERS - 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 have been removed and the proper plant specific information/value has been provided.

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 3.2.2.

4. Changes are made to reflect changes made to the Specification.

5. Changes are made to reflect the Specifications.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 273 of 323

Attachment 1, Volume 13, Rev. 0, Page 274 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 274 of 323

Attachment 1, Volume 13, Rev. 0, Page 275 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, INVERTERS - SHUTDOWN There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 275 of 323

Attachment 1, Volume 13, Rev. 0, Page 276 of 323 ATTACHMENT 9 ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Attachment 1, Volume 13, Rev. 0, Page 276 of 323

, Volume 13, Rev. 0, Page 277 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 277 of 323

Attachment 1, Volume 13, Rev. 0, Page 278 of 323 ITS 3.8.9 ITS ELECTRICAL POWER SYSTEMS 2/'...2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPEWATING J*, and AC vi tal busl [Train 1- and ,Train 2 AC L~H-TT.:ýZGCOND IT! ON -OR OPERATION LCO 3,8.9 4160 *ltEss ntial Bu - Cl 4160 volt Ess ntial 3u Ji01 460 volIt Ess ntjal Bu I ElI 380volt Es ential 3,s i F) ~A02 12 volt A. V.Vital us.! Yi 12 volt A.-. Vital us 1 ?2 12 volt A.C. Vital Bus # Y3 1? volt A C. Vital Bus I Y4

                           ?r3     r.ufl' ~~~~~ss AiCT !Ott :                            *         ~Add ACTIONproposed A NoteA0 ACTIONS A and B  [Wi-th lass than the above comolement of A.C. busses OPERABLE, restore ;ne I inoperable bus to OPEMABLE stIatus within 8 hours/or be in at least HOT ACTION D       _LSTANOBY within the next 6 hours and in LOLD SHUTDOWN within the foliawing 130hours.

Add proposed ACTION E SURVEILLANCE REQUI[REMENTS 4.3.2.1 Che specified A.C. busses shall be deter-mined OPEPABL- ii-n* SR 3.8.9.1 DAVIS-BESSE, UNIT 1 3/4 8-6 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 278 of 323

Attachment 1, Volume 13, Rev. 0, Page 279 of 323 ITS 3.8.9 ITS ELECTRICAL POWER SYSTEMS 1LA2,3-an402. C TOPERATING LIMITING CONDITION FOR OPERATION elecrica power dsrbto ussesL0 ['Train 1 and Train 2 *

LCO 3.8.9 3_.8.2.3 The following D.C. [b-ui r~n[shall be lene ~zed and OPERABLE *.(A2

          /with      discon-neC&t switches between bus,-frains open:1
                                                                                     * /-                            I           _.___[" See      "

IT-AIN "A" coo's~isting of 250/125-vlr D. .M C 1l, 125-volt I.' . ITS 3.8.4j [station batteries IP and IN arid 2 full_ý cac tych11rgers. ITRAIN "B" co,6sistinR of 250/125-v*Idt D.C. MCC 2L 1125-volt D.C. L0 Istation batteries 2P and 2N and 2 full capacity chargers. APPLICABILITY: MODES 1, 2, 3 and 4. I'TS 3.e81 ACTION: ACTION C a. With only one 125-volt D.C. bus of a 250/125 volt D.C. MCC IOPERABLE, restore the inoperable bus to OPERABLE status within 2 urs or-be in at least HOT STANDBY within the next 6 hours and ACTION D in COLD SHUTDOWN within the following 30 hours.- Add proposed ACTION E

b. With only one 125-volt D:C. battery or only one charger of one MCC OPERABLE, restore the inoperable battery or charger to See ITS 3.8.4J OPERABLE status within 2 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

SURVEILLANCE REQUIREMENTS LAO1 SR 3.8.9.1 4.8.2.3.1 Each D.C. bus train shall be deter-mined OPERABLE

wito disconng[et switches open between i~dundant bussed at least once per 7 days by verifying correct disconnect switch/breaker alignment. i I

Ipower avai -ility from the char r and batter , and voltage on the bus lot gra-;-nno qa oI- ot 4.8.2.3.2 Each 125-volt battery and charger shall be demonstrated OPERABLE: See ]

a. At least once per 7 days by:

See

1. Verifying that the paralmeters in Table 4.8-1 meet the ITS 3.8.6]

CateRory A limits, and DAVIS-BESSE, UNIT I 3/4 8-8 .,Amendment No. 100 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 279 of 323

Attachment 1, Volume 13, Rev. 0, Page 280 of 323 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS). These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. A02 CTS 3.8.2.1 Action states that with less than the above complement of AC buses OPERABLE, to restore the inoperable bus to OPERABLE status within 8 hours. ITS 3.8.9 Required Action A.1 allows 8 hours to restore the Train 1 and Train 2 AC electrical power distribution subsystem(s) to OPERABLE status. In addition, a Note has been added (ITS 3.8.9, Note to ACTION A) that requires entry into applicable Conditions and Required Action of LCO 3.8.4, "DC Sources - Operating," for DC Sources made inoperable by inoperable power distribution subsystems. This changes the CTS by requiring the compensatory actions for DC Sources to be taken if a DC Source is made inoperable by inoperable power distribution subsystems. This change is acceptable because no changes are made to CTS requirements. The change in format from the CTS to the ITS maintains all technical requirements. The addition of the Note only acts as a reminder to enter the appropriate actions if the emergency bus which supplies the Train 1 or Train 2 battery charger becomes de-energized. In the event an emergency bus is inoperable such that a Train 1 or Train 2 battery charger were inoperable, ITS LCO 3.0.6 would allow taking only the Distribution System - Operating ACTIONS; taking exception to complying with the DC Sources - Operating ACTIONS. Since the Distribution System - Operating ACTIONS may not be sufficiently conservative in this event (i.e., a battery charger may be without power), specific direction to take appropriate ACTIONS for the DC Sources - Operating is added (ITS 3.8.9, Note to ACTION A) when there is no power to support the associated required battery charger. This change is designated as administrative because it does not result in a technical change to the CTS. MORE RESTRICTIVE CHANGES M01 CTS 3.8.2.1 Action states that with less than the above complement of AC buses OPERABLE, to restore the inoperable bus to OPERABLE status within 8 hours. CTS 3.8.2.3 Action a states that with one 125 VDC bus inoperable, to restore the inoperable bus to OPERABLE status within 2 hours. However, there are no limitations to preclude a loss of function due to numerous concurrently inoperable AC and DC buses. ITS 3.8.9 ACTION E has been added, requiring entry into ITS 3.0.3 if the loss of two or more electrical power distribution subsystems results in a loss of safety function. The purpose of the CTS Actions is to limit the time the unit can operate under these conditions. CTS 3.8.2.3 Action a specifies the compensatory actions for Davis-Besse Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 280 of 323

Attachment 1, Volume 13, Rev. 0, Page 281 of 323 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING one inoperable DC bus. With two inoperable DC buses, CTS 3.8.2.3 does not provide any actions and entry into LCO 3.0.3 would be required. CTS 3.8.2.1 Action is applicable to all inoperable AC buses even if there is a loss of safety function. Certain combinations of inoperable AC and DC electrical power distribution subsystems will result in a loss of safety function (e.g., an inoperable Train 1 AC electrical power distribution subsystem in combination with an inoperable Train 2 DC electrical power distribution subsystem). ITS 3.8.9 includes ACTION E, which requires immediate entry into LCO 3.0.3 if the loss of one or more electrical power distribution subsystems results in a loss of safety function. ITS 3.8.9 Required Action E.1 preserves the intent of ITS LCO 3.0.3 and reflects an additional restriction on plant operation. This change is designated as more restrictive because an explicit action has been added which requires entry into LCO 3.0.3 with any combination of AC and/or DC buses inoperable that result in a loss of safety function. M02 CTS 4.8.2.1 states the specified AC buses shall be determined OPERABLE by verifying correct breaker alignment and "indicated power availability." ITS SR 3.8.9.1 requires the verification of correct breaker alignments and "voltage" to required AC and AC vital bus electrical power distribution subsystems. This changes the CTS by requiring the verification of the correct voltages to the required AC and vital bus electrical power distribution subsystems, whereas the CTS only requires verification of indicated power. The purpose of this change is to ensure proper voltage is supplied to the required AC and 120 VAC vital bus electrical power distribution subsystems. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required AC and vital bus electrical power distribution subsystems. Proper voltage from the required subsystems ensures proper voltage is supplied to the required safety features. This change is designated as more restrictive because the ITS requires verification of the correct voltage, whereas the CTS only requires a verification of indicated power availability. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.1 requires the AC electrical buses to be OPERABLE "and energized with tie breakers open between redundant busses." CTS 4.8.2.1 also requires the AC buses to be determined OPERABLE "with tie breakers open between redundant busses" by verifying correct breaker alignment and indicated power availability. CTS LCO 3.8.2.3 requires the DC bus trains to be "energized" and OPERABLE "with disconnect switches between bus trains open." CTS 4.8.2.3.1 requires the DC bus trains to be determined OPERABLE

     and energized with disconnect switches open between redundant busses" by verifying correct disconnect switch/breaker alignment, indicated power availability from the charger and battery, and voltage on the bus. ITS LCO 3.8.9 requires Davis-Besse                             Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 281 of 323

Attachment 1, Volume 13, Rev. 0, Page 282 of 323 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING the applicable electrical power distribution subsystems to be OPERABLE and ITS SR 3.8.9.1 requires the verification of correct breaker alignments and voltage to required AC, DC, and vital bus electrical power distribution subsystems. This changes the CTS by moving the procedural detail that the buses must be energized with tie breakers or disconnect switches open between redundant buses 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 electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC, DC, and vital bus 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 procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications. LA02 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.1 requires the AC electrical buses to be OPERABLE and lists the specific AC and 120 VAC vital buses, including the applicable nominal bus voltage. CTS LCO 3.8.2.3 requires the Trains A and B DC buses to be OPERABLE and lists the specific MCC. ITS LCO 3.8.9 requires the Train 1 and Train 2 AC, DC, and AC vital bus electrical power distribution subsystems to be OPERABLE. This changes the CTS by moving the specific names of the buses and the associated nominal bus voltages (i.e., 4160 V, 480, 120V, 250/125 VDC) from the CTS to the ITS Bases. The moving 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. The ITS still retains the requirement for the OPERABLE busses, and the appropriate Condition to enter if a required bus becomes inoperable, and the appropriate Surveillance Requirements. 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. LA03 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.1 requires DC bus voltage of greater than or equal to 125 volts DC. This changes the CTS by moving the required bus voltage from the CTS to the ITS Bases. Davis-Besse Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 282 of 323

Attachment 1, Volume 13, Rev. 0, Page 283 of 323 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING The moving 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. The ITS still retains the requirement for correct voltage, with the specific voltage for bus OPERABILITY in the ITS bases for SR 3.8.9.1. The appropriate Condition to enter if a required bus becomes inoperable, and the appropriate Surveillance Requirements. 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 None Davis-Besse Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 283 of 323

Attachment 1, Volume 13, Rev. 0, Page 284 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 284 of 323

Attachment 1, Volume 13, Rev. 0, Page 285 of 323 Distribution Systems - Operating 3;8.9 . CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating 3.8.2.1, 3.8.2.3 LCO 3.8.9 Train and Train*C, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. 0 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.8.2.1 Action A. One or more AC ------------------ NOTE ---------- electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC tr ns made inoperable by inoperableo power distribution subsystems. 0 A.1 Restore AC electrical power 8 hours distribution subsystem(s) to OPERABLE status. 3.8.2.1 Action B. One or more AC vital buses inoperable. B.1 Restore AC vital bus,* sus emsto M-ourLs 00 OPERABLE status. 3.8.2.3 Action a C. One or ore-DC C.1 Restore DC electrical 2 hours electrical power distribution subsystems power distribution subsystemr_ to 0 inoperable. OPERABLE status. BWOG STS 3.8.9-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 285 of 323

Attachment 1, Volume 13, Rev. 0, Page 286 of 323 Distribution Systems - Operating 3.8.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 3.8.2.1 Action, D. Required Action and D.1 Be in MODE 3. 6 hours 3.8.2.3Action a associated Completion Time*-dnotofion met A. B. or C1 AND D.2 Be in MODE 5. 36 hours 0 DOC M01 E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 481 4.8.2.1, 4.8.2.3.1 SR 3.8.9.1 Verify correct breaker alignments and voltage to MrequiredFAC, DC, and AC vital bus electrical power 7 days 0 distribution subsystems. BWOG STS 3.8.9-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 286 of 323

Attachment 1, Volume 13, Rev. 0, Page 287 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

1. Changes made to reflect the plant specific nomenclature.

2. Change made to be consistent with the Specification.

3. The current licensing basis time allowed to restore an inoperable vital bus electrical power distribution subsystem is 8 hours. This 8 hour time is provided for all AC buses - 4.16 kV, 480 V, and the 120 VAC vital buses. The consequences of a loss of a train of the 120 VAC vital buses would be similar to the loss of a train of the higher voltage (4.16kV and 480 V) AC electrical power subsystem. Therefore, this time has been maintained.

4. The allowance in ISTS 3.8.9 ACTION C to have one or more DC electrical power distribution subsystems inoperable for 2 hours has been changed to address only the inoperability of one Train 1 or Train 2 DC distribution subsystem, since if both the Train 1 and Train 2 buses were inoperable, then a loss of safety function would exist and entry into ACTION E would be necessary.

5. This change is made consistent with the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 287 of 323

Attachment 1, Volume 13, Rev. 0, Page 288 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 288 of 323

Attachment 1, Volume 13, Rev. 0, Page 289 of 323 r Allchanges unless otherwiseare C noted-- Distribution Systems - Operating B 3;8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES BACKGROUND The onsite Class IE AC, DC, and AC vital bus electrical power distribution systems are divided by train into fwoý redundant and 0 independent AC, DC, and C vital bus electrical power distribution subsystems. The AC electrical power subsystem for each train consists of a primary jEngineered Safety Feature (ESF) 4.16 k\Vbus and secondary [480 and (. 12CIV buses, distribution panels, motor control centers and load centers. Each [0.16 kW* bus* has at least one separate and independent offsite source of powe% as well as a edicated onsite diesel generator i-Ek__G) source. Each M4.16 k7M buslis normally connected toa emergency L-) preferred offsite source. After a loss of the preferred offsite power source D to a 4.16 k'j bus, ahtransfer to the alternate offsite source is accomplished by utilizing a tir e delayed bus unde oltage relay1. If all eeta offsite sources are unavailable, the onsite me50gencDG supplies power to the 4.16 kV bus. Control power for the 4.16 kT5iR~rs-m----E supplied from the Class 1 E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources - Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating." The eco da AC electrical power distribution subsystem for each train includes the safety related busesý load centers, *r control centers, land distribon anes shown in Table B 3.8.9-1. The 120 VAC vital buses are arranged in two load groups per train and are normally powered from the inverters. The alternate power supply for the vital buses are Class 1 E constant voltage source transformers powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage source transformer is powered from a Class 1 E AC bus. 2* f a 250/125 VDC o* cetrDC *moto two D tor control center The DC electrical distribution subsystem consists4o 5 (MCC), and each Idistributb.Q panel(s). 250/125 VDC MCC consists - The list of all required DC and$vitalACdistribution buses an - ne is presented in Table B 3.8.9-1. BWOGSTS B 3.8.9-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 289 of 323

Attachment 1, Volume 13, Rev. 0, Page 290 of 323 Distribution Systems - Operating B 3.8.9 BASES FSection 6 APPLICABLE fThe initial conditions of Design Basis Accident (DBA) and transienLsectin 15, SAFETY analyses in the-FSAR, Chater [6 ](Ref. 1) and lChaptr [14]*(Ref. 2), ANALYSES assume ESR systems are OPERABLE. The AC, DC, and AC vital bus 0 Engineered Safety Features electrical 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 design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, "Power Distribution Limits," Section 3.4, "Reactor Coolant System (RCS)," and Section 3.6, "Containment Systems."

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical power and 0

b. A worst-case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO The required power distribution subsystems listed in Table B 3.8.9-1 ensure the availability of AC, DC, and AC vital bus electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a The AC, DC, and AC vital bus electrical power portion of the buses listed Table B3.8.9-1 power non-in distribution DBA. postulated subsystems are required to be OPERABLE. essential loads and are not *[ systems Maintaining the Train Train , DC, and AC vital bus electrical 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. OPERABLE AC electrical power distribution subsystems require the associated busesl, load centers, otor control centers, and distribution to be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses F 1* 1distrbution p Ane s to be energized to their proper voltage from either the associated battery or charger. OPERABLE vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage from the associated Minverter;via inverted DC voltage( linverter 46ing internal source or Class 1 E constant voltage 125 transformerl] BVVOG STS B 3.8.9-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 290 of 323

Attachment 1, Volume 13, Rev. 0, Page 291 of 323 Distribution Systems - Operating B 3.8.9 BASES LCO (continued) INSERTand disconnect switches In addition, tie breakers between redundant safety related AC, DC, and 0 electrical AC vital bus power distribution subsystems, if th exist, must be open. 0 This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safet or disconnectj that are not being powered function(s). If any tie breaker4 are closed, thelaffece redudan switches (i.e., they are being powered electrical power distribution subsystemslare considered inoperable. This from their redundantio applies to the onsite, safety related redundant electrical power distribution ersubsystem) subsystems. It does not, however., preclude redundantClass 1E 4.16 kV buses from being powered from the same offsite circuit. 4HtE (D APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 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

b. Adequate core cooling is provided, and containment OPERABILITY 0

and other vital functions are maintained in the event of a postulated DBA. and other conditions inwhich electrical Ipower distribution subsystems are required Electrical power distribution subsystem requirements for MODES 5 and 6÷ are covered in the Bases for LCO 3.8.10, "Distribution Systems - 0 Shutdown." ACTIONS A.1 0 relectrical power WJ-1With one or more Train% and required AC buses, jbad center%, distri)uff-n panels [except AC vital buses), in o motorl rain 0 substybuteon j -- tcontroi inoperable and aorloss ceryers, 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 eroverall reliability is reduced, however, because a single failure in the Lmaci-cgipower distribution subsystems could result in the minimum 0 electrical power distribution subsystem(s) required ESF functions not being supported. Therefore, the required AC buses. load centej:a- motor control centers. an*istrbiu ion ane must be restored to OPERABLE status within 8 hours. 0 BVVOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 291 of 323

Attachment 1, Volume 13, Rev. 0, Page 292 of 323 B 3.8.9 0 INSERT 1 Based on the number of safety significant electrical loads associated with each bus listed in Table B 3.8.9-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LCO 3.8.9 is required. Some buses, such as distribution panels and motor control centers, which help comprise the AC and DC distribution systems, are not listed in Table B 3.8.9-1. 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 3.8.9-1 (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 3.8.9-1 (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 292 of 323

Attachment 1, Volume 13, Rev. 0, Page 293 of 323 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associatedtDG inoperable). In this Condition, the unit is more vulnerable to a complete loss of.AC power. It is, W) therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train to the actions associated with taking the unit to shutdown within this time limit~nd (

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Required Action A.1 is modified by a Note that requires the applicable _____-_ Conditions to be enteredandforRequired DC' Actions made of LCO 3.8.4, inoperable by "DC Sources inoperable - Operating," 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.1 With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the [required]AC vital bus must be restored to OPERABLE status within M*- 1--* hours by powering the bus from the associated inverted- Qinverte 15V DC1, inverter sin internal ourceor Class 1-E constant voltage transformeri _i.E BWOG STS B 3.8.9-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 293 of 323

Attachment 1, Volume 13, Rev. 0, Page 294 of 323 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) Condition B represents one or more AC vital buses without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is., therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected vital bus. D Th-i-s'M hour limit is more conservative than Completion Times allowed for (0 the vast majority of components that are without adequate vital AC power. Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter F8 thanJ, hours if declared inoperable, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue f

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected trainyand - --E,)

c. The potential for an event in conjunction with a single failure of a redundant component.

The hour Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period. electrical power C.1 distribution C. 1 subsystem With one or ore DC 1uses striu oane s inoperable, and a loss (D (Th of function has not yet occurred, the remaining DC electrical power distribution subsysterfi*re capable of supporting the minimum safety Q 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 power distribution subsystem could result in the minimum required ESF electric power

                 - functions not being supported. Therefore, the distri ution DC bu es ard nels must be restored to OPERABLE status within 2 hours 0   (I dsubsUysin   by powering the bus from the associated battery or charger.

BWOG STS B 3.8.9-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 294 of 323

Attachment 1, Volume 13, Rev. 0, Page 295 of 323 I All changes are Distribution Systems - Operating unless otherwise noted J B 3.8.9 BASES ACTIONS (continued) )electrical power distribution subsystem} I Condition C represents one

DC buses ox dlsti' without adequate DC power; potentially both with the battery significantly p

0 degraded and the associated charger nonfunctioning. In this situation, the unit 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 unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train. This 2 hour limit is more conservative than Completion Times allowed for the vast majority of components that are 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 hours, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) whiletallowing stable operations to continuef 0 0

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions to restore power to the affected train and 0

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3). if any Required Action and associated Completion Time D.1 and D.2 of Condition A, B,or C is not met If the noperle distribution subsystem canyfot be restored to OPERABLf- status within the required Co.,pletion Time/, the unit must be 0 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 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. BWAOG STS B 3.8.9-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 295 of 323

Attachment 1, Volume 13, Rev. 0, Page 296 of 323 I All changes are Distribution Systems - Operating unless otherwise noted B 3.8.9 BASES ACTIONS (continued) E.1 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a 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. SURVEILLANCE S R 3.8.9.1 [including tie breakers open REQUILREM ENTS R between redundant buses, J This Surveillance verifies that themrequired]AC, DC, and AC vital bus (which includes all types of electrical power distribution systems are functioning properly, with the_ circuit breaking devices) correct circuit breakertalignment. The correct breaker alignment nsures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus. The 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 takes into account the redundant capability of the AC, DC, and The voltage of the DC bus AC vital bus electrical power distribution subsystems, and other must be greater than or indications available in the control room that alert the operator to equal to 125 VDC. subsystem malfunctions. I 0 REFERENCES 1. FSAR, r 0<2. FSAR,JChaptr [14. 0

3. Regulatory Guide 1.93, December 1974.

BVWOG STS B 3.8.9-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 296 of 323

Attachment 1, Volume 13, Rev. 0, Page 297 of 323 (Q,) I All changes are unless otherwise noted 9 Distribution Systems - Operating B 3.8.9 Table B 3.8.9-1 (page 1 of 1) AC and DC Electrical Power Distribution Systems TYPE VOLTAGE TRAIN TRAIN [C1 I. -Im i~ I. ssentiabuses Essential 14160V\1 Bu[N1 Load Centers Load\ -enters Bus E Eý480 VC [NG01, \NG03] [NG02,\NG04] Es-sentiaýl Moto Control Moto Control Ce ters Ce ters [NG01, NG01 I, [NG02 ), NG021, NG01 B, NG03C, NG02B, NG04C, NG031, G03D] NG041, G04D] Distribu 'o n Panels Distribu 'on Panelsl [NP1 ,N P03] [N P02,\N P04] I r2502/ DC buses Bus K01] DC5 \1c jBus MK02] ' oBusnKael iBus K04] DC MCC2 Distribu*on Panels Distribu tkon Panels [NK41, NK 3, NK51] [NK42, NK 4, NK52]

                                                                    +~I.

FY-1 AC vital buses T120 V] Bu Bus [-2 Bus ý[N 03] Bus [N 04] Y4

Each train of the AC and DC electrical power distribution systems is a subsystem.

BWOG STS B 3.8.9-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 0, Page 297 of 323

Attachment 1, Volume 13, Rev. 0, Page 298 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING

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

2. The brackets have been removed and proper plant specific information has been provided.

3. Changes are made to reflect changes made to the Specification.

4. Editorial/grammatical error corrected.

5. Changes made to reflect the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 298 of 323

Attachment 1, Volume 13, Rev. 0, Page 299 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 299 of 323

Attachment 1, Volume 13, Rev. 0, Page 300 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 300 of 323

Attachment 1, Volume 13, Rev. 0, Page 301 of 323 ATTACHMENT 10 ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN Attachment 1, Volume 13, Rev. 0, Page 301 of 323

, Volume 13, Rev. 0, Page 302 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 302 of 323

Attachment 1, Volume 13, Rev. 0, Page 303 of 323 ITS 0 ITS 3.8.10 ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN Tene FOR OPERATIONS LIMITING CONDITION LCO 3.8.10 3.8.2.2 a minimuboe tAS folloeint A.C. belectrical busses shand be OPERABLE: Tsn

                   *I-APPLICAILITY:

4/60 volt MODES Esiential and6Bus/ Durin meo of iraited fulasmle vemsepoont distribution subsystems enial B0 volt vt0

                         -/120 volt      .C. Essent/ial      Busses A.PPL ICABI LITY :     IMODES 5 and 6.      4                During movement of irradiated fuel a~ssem~blies}

Add proposed CIN oe / ACT ION: 4_,. With less than the above complement of A.C. busses OPERABLE and energized, ACTION A 10,tA bih CONTAINM, by 'R INTEGRITY wEhin 8 hoursI. ~~~~~~~~n veiynvoretbekra i tnmentsand ectrical p pwer

                                             *""Add              proposed Required Action A-1                                  M0 SURVEILLANCE        REQU IREMENTS 4.3.2.2 The specified A.C. busses shall be determined OPERABLE at least SR 3.8.10.1  once 0er 7 days by verifying correct breaker alignment and indicaJ-                                    powerI lava 1*i di ity.j DAVIS-BESSE,       UNIT 1                   3/4 8-7 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 303 of 323

Attachment 1, Volume 13, Rev. 0, Page 304 of 323 ITS 3.8.10 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN LCO 3.8.10 See 12 - 125-volt battery banks and chargers supplying the above D.C. MCC.- ITS3.8.5J APPLI CAB IL ITY: .'IODES 5 and 6.4 During movement of irradiated fuel assemblies ACTION- Add proposed ACTIONS Not~e 1 @0 ACTION A lestab*l'i With lessh CONTIAIN.,.W than the above INTE"lGRITY..-witfhin complement of 8D.C. hourequipment and Required Add proposed bbuss OPERRABLE,L0 Action

FAdd proposed Required Action A.1 A.2.1, A.2.2, A.2.3. and A.2.4 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 250/125-volt D.C. MCC shall be determined LA02 OPERABLE Iand/energizedl at least once per 7 days by verifying correct SR 3.8.10.1 disconnect switch/breaker alignment,- nicatcopower avl t

[the charter and )Satter , and voltage on the buslof xr ater than e uaA Ito 1/25 volts5 I.G 4.8.2.4.2 The above required 125-volt battery banks and chargers shall : See ITS be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2. 3.8.6 DAVIS-BESSE, UNIT 1 3/4 8-11 Amendment No. 100 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 304 of 323

Attachment 1, Volume 13, Rev. 0, Page 305 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (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 M01 CTS LCO 3.8.2.2 requires a minimum of one 4160 V essential bus, one 480 V essential bus, and three 120 VAC vital buses to be OPERABLE. CTS LCO 3.8.2.4 requires one 250/125 VDC MCC to be OPERABLE. The existing requirement of CTS LCO 3.8.2.2 and LCO 3.8.2.4 for distribution buses to be OPERABLE during shutdown conditions is not specific as to what the system must be powering. ITS 3.8.10 specifies that the necessary portions of Train 1 and Train 2 AC, Train 1 and Train 2 250 VDC, and Train 1 and Train 2 AC vital bus electrical power distribution subsystems must be OPERABLE to support equipment required to be OPERABLE. In addition, an optional Required Action (ITS 3.8.10 Required Action A.1) has been added which allows the associated supported required feature(s) to be declared inoperable. This change adds a requirement that the applicable portions of Train 1 and Train 2 AC, Train 1 and Train 2 125 VDC, and Train 1 and Train 2 AC vital bus electrical power distribution subsystems must be OPERABLE when required to support equipment required to be OPERABLE by the Technical Specifications. This could require more buses to be OPERABLE than is currently required. In addition, an action has been added to allow an option to the existing actions. The purpose of CTS 3.8.2.2 and CTS 3.8.2.4 is to ensure that at least one train of AC, DC and VAC vital bus electrical power distribution systems are OPERABLE. This change adds a requirement that the applicable portions of Train 1 and Train 2 AC, Train 1 and Train 2 125 VDC, and Train 1 and Train 2 AC vital bus electrical power distribution subsystems must be OPERABLE when required to support equipment required to be OPERABLE by the Technical Specifications. This added restriction conservatively assures the needed electrical power distribution buses are OPERABLE, even ifthis results in both the trains of one or more of the electrical power distribution systems being required. Since the ITS 3.8.10 electrical power distribution subsystem OPERABILITY requirements require the necessary portions of the distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, if a portion of the electrical power distribution subsystem cannot supply any required equipment, that electrical power distribution subsystem is inoperable. In this event it may not be necessary to suspend all irradiated fuel handling and positive reactivity additions. Conservative actions can be assured if all required equipment without the necessary power is declared inoperable, and the associated ACTIONS of the individual equipment is taken (ITS 3.8.10 Required Action A.1). Therefore, along with the conservative additional requirements placed on the electrical power Davis-Besse Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 305 of 323

Attachment 1, Volume 13, Rev. 0, Page 306 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN distribution subsystems, Required Action A.1, which requires the associated supported equipment to be declared inoperable, is also added. These changes are acceptable since the additions represent restrictions consistent with implicit assumptions for operation in shutdown conditions (required equipment receiving the necessary required power), and these restrictions are not currently imposed by the Technical Specifications. This change is designated as more restrictive because it adds a new requirement to the CTS. M02 CTS 4.8.2.2 and CTS 4.8.2.4 are applicable in MODES 5 and 6. ITS 3.8.10 is applicable in MODE 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable. This change is acceptable because the proposed requirements are necessary to ensure the electrical power subsystems are OPERABLE to support equipment required to OPERABLE during movement of irradiated fuel assemblies. Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate distribution system requirements are specified during fuel handling and ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supply is not available (See DOC L01 for the changes to the Required Actions). This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.10 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only when in MODES 5 and 6. M03 CTS 4.8.2.2 states the specified buses shall be determined OPERABLE by verifying correct breaker alignment and "indicated power availability." ITS SR 3.8.10.1 requires the verification of correct breaker alignments and "voltage" to required AC and AC vital buses electrical power distribution subsystems. This changes the CTS by requiring the verification of the correct voltages to the required AC and AC vital bus electrical power distribution subsystems, whereas the CTS only requires verification of indicated power availability. The purpose of this change is to ensure proper voltage is supplied to the required AC and AC vital buses electrical power distribution subsystems. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required AC and 120 AC vital bus electrical power distribution subsystems. Proper voltage from the required subsystems ensures proper voltage is supplied Davis-Besse Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 306 of 323

Attachment 1, Volume 13, Rev. 0, Page 307 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN to the required safety features. This change is designated as more restrictive because the ITS requires verification of the correct voltage, whereas the CTS only requires a verification of indicated power availability. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.2 requires AC electrical buses to be OPERABLE and specifies nominal bus voltages. CTS LCO 3.8.2.4 requires a 250/125 VDC MCC to be OPERABLE and CTS 4.8.2.4.1 requires the MCC bus voltage to be 125 VDC. ITS LCO 3.8.10 requires necessary portions of the AC, DC, and VAC vital bus electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE. ITS SR 3.8.10.1 requires the verification of correct breaker alignment and voltage to each required AC, DC, and VAC vital bus electrical power distribution subsystems. This changes the CTS by moving description of the buses (including the nominal bus voltages and the specified limit for the 125 VDC MCC) from the Specification to the 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. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems. 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. LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 3.8.2.4 requires the DC electrical equipment including the 250/125 V DC MCC to be demonstrated OPERABLE and "energized." CTS 4.8.2.4 requires the DC 250/125 VDC MCC to be demonstrated OPERABLE and "energized" by verifying correct switch/breaker alignment and indicated power availability, indicated power availability from the "charger and battery". ITS LCO 3.8.10 requires the applicable electrical power distribution subsystems to be OPERABLE and ITS SR 3.8.10.1 requires the verification of correct breaker alignments and voltage to each required AC, DC, and AC vital bus electrical power distribution subsystems. This changes the CTS by moving the procedural detail that the buses must be "energized" and "indicated power availability from the charger and battery" from the CTS to the ITS Bases. Davis-Besse Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 307 of 323

Attachment 1, Volume 13, Rev. 0, Page 308 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN 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 electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC, DC, and 120 VAC vital bus 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 procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications. LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of RequiredAction) With less than the minimum complement of AC busses OPERABLE and energized, CTS 3.8.2.2 requires the establishment of containment integrity within 8 hours. With less than the minimum complement of DC buses OPERABLE and energized, CTS 3.8.2.4 also requires the establishment of containment integrity within 8 hours. ITS 3.8.10 ACTION A requires suspending movement of irradiated fuel assemblies, suspension of operations involving a positive reactivity additions that could result in the loss of required SDM or boron concentration, the initiation of actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status, and the declaration of the associated required decay heat removal subsystems(s) inoperable and not in operation. This changes the CTS by replacing the existing Required Action to restore containment integrity. The purpose of the CTS 3.8.2.2 Action and CTS 3.8.2.4 Action is to isolate the containment to minimize any release from the plant if an event were to occur during shutdown conditions. 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 proposed Required Actions require the suspension of movement of irradiated fuel assemblies, the suspension of operations involving a positive reactivity additions that could result in the loss of required SDM or boron concentration, the initiation of actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status, and the declaration of the associated required decay heat removal subsystems(s) inoperable and not in operation. Suspending the movement of irradiated fuel assemblies will prevent a fuel handling accident from occurring. Suspending positive reactivity additions that could result in failure to meet the Davis-Besse Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 308 of 323

Attachment 1, Volume 13, Rev. 0, Page 309 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN minimum SDM or boron concentration limit is required to assure continued safe operation. The actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status will place the plant in compliance with the LCO. Declaration of the associated required decay heat removal subsystems(s) inoperable and not in operation will require the plant to enter the applicable LCOs to apply additional Required Actions. The proposed actions will immediately minimize the potential for any accident releases outside of the containment and are considered acceptable in lieu of the current action to restore containment integrity within 8 hours. The actions may be considered somewhat more restrictive since immediate action is required, however, is classified as less restrictive since the current actions to restore containment integrity have been deleted. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 0, Page 309 of 323

Attachment 1, Volume 13, Rev. 0, Page 310 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 310 of 323

Attachment 1, Volume 13, Rev. 0, Page 311 of 323 Distribution Systems - Shutdown CTS 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown 3.8.2.2. 3.8.2.4 LCO 3.8.1:0 The necessary portionlof AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment 0 required to be OPERABLE. APPLICABILITY: MODES 5 and 6, During movement of [rec ntly] irradiated fuel assemblies. 0 ACTIONS

                 -- ---------------------------------------NO                       r------------------------------------------------------------

LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME One or more required A.1 Declare associated Immediately 3.8.2.4 Action S3.8.2.2 Action, A. AC., DC, or AC vital bus supported required electrical power feature(s) inoperable. distribution subsystems inoperable. OR A.2.1 Suspend C Immediately ALTERATIONS. (tSF IANDI A.2.MJ Suspend movement of Immediately [rec tly] irradiated fuel assem ies. AND D2

Suspend operations involving positive reactivity additions that could result in Immediately (21 loss of required SDM or boron concentration.

AND BWVOG STS 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 311 of 323

Attachment 1, Volume 13, Rev. 0, Page 312 of 323 Distribution Systems - Shutdown 3.8.10 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 3.8.2.2 Action, A Initiate actions to restore required AC, DC, and AC Immediately (TTF 3.8.2.4 Action vital bus electrical power distribution subsystems to OPERABLE status. AND

Declare associated Immediately required decay heat removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i 4.8.2.2, SR 3.8.10.1 Verify correct breaker alignments and voltage to 7 days 4.8.2.4.1 required AC, DC, and AC vital bus electrical power distribution subsystems. BWVOG STS 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 312 of 323

Attachment 1, Volume 13, Rev. 0, Page 313 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Typographical error corrected.

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 313 of 323

Attachment 1, Volume 13, Rev. 0, Page 314 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 13, Rev. 0, Page 314 of 323

Attachment 1, Volume 13, Rev. 0, Page 315 of 323 Distribution Systems - Shutdown B 3.8.10 B 3:8 ELECTRICAL POWER SYSTEMS B.3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems - Operating." Section 15 APPLICABLE [* an-aly-s-es in theFSAR, ~atr6lRef. 1) and ~a'~r1]'Ref. 2), SAFETY ANALYSES assume Engineered Safety Feature*(ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical 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 design limits are not exceeded. The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. The OPERABILITY of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6, and during movement of [rec[,ntlYlyirradiated fuel assemblies ensures that: 0

a. The unit can be maintained in the shutdown or refueling condition for extended periods * --. .

b. Sufficient instrumentation and control capability is available for 0

0 monitoring and maintaining the unit statusRp 1 J

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [invol g handling 0

recentlyirradiated fuel. Due o radioactive decay, A , DC, and AC vital bus lectrical power is o y required to mitigate f I handling accidents nvolving handling re ently irradiated fuel (i.e., fuel that has occupied pqrt of a critical reacto core within the previous X] days)] The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(iD). BWOG STS B 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 315 of 323

Attachment 1, Volume 13, Rev. 0, Page 316 of 323

Distribution Systems - Shutdown B 3.8.10 BASES LCO Variouscombinations 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 electricaltdistribution system necessary (I to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents J[involving handlin-g-recently irradiated fuel]. APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [r-ec& ntl (3) irradiated fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident jin olving handling cently irradiated Wud (i.e., tuel that has occupi d part ofa critical rea~tor core within the pr~vious [X] days)] are availablelM_

0

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

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

The AC, DC, and AC vital bus electrical power distribution subsystem requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9. ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, 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 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily. BWOG STS B 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 316 of 323

Attachment 1, Volume 13, Rev. 0, Page 317 of 323 B 3.8.10 O INSERT 1 OPERABLE AC vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage either from a) the associated inverter, via inverted 125 VDC voltage or the Class 1 E constant voltage transformer, or b) the associated non-essential power source (regulated instrumentation distribution panel YAR or YBR). Furthermore, tie breakers between redundant safety related AC, DC, and AC vital buses are allowed to be closed. Insert Page B 3.8.10-2 Attachment 1, Volume 13, Rev. 0, Page 317 of 323

Attachment 1, Volume 13, Rev. 0, Page 318 of 323 Distribution Systems - Shutdown o* B 3.8.10 BASES ACTIONS (continued) A.1, A.2.1, A.2.2, A.2.3. 4A.20 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable -of supporting sufficient required features to allow continuation of FCORE AL T'RATIONS < and centl irradiated fuel movement. 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 subsystems 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 suspendICURE AL"t-RAIONb, movement of irradiated T (D fuel assembliesguand operations involving positive reactivity additions that "SUD-A6, W-MM)," specified in LCO 3.1.1.

                                   ,(MODE       6 tth could result      coolan/a in loss        boronSDM of required      (MODE 5)jorless concentratiohs        thanconcentration boron    required to          C specified in LCO 3..1asffsur           the RS borod concentration is maidtainedA

["Boron Concentration".) C( "sr Suspension of these activities does 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 unit safety systems. Notwithstanding performance of the above conservative Required Actions, a required decay heat removal (DHR) subsystem may be b -E inoperable. In this case, Required Actions A.2.1 through A.2 o not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the DHR ACTIONS would not be entered. Therefore, Required Action A.2gis provided to direct declaring DHR inoperable, which results in taking the appropriate DHR 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 unit safety systems may be without power. BWOG STS B 3.8.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 318 of 323

Attachment 1, Volume 13, Rev. 0, Page 319 of 323 B 3.8.10 0 INSERT 2 Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient (MTC) must also be evaluated to ensure they do not result in a loss of required SDM. Insert Page B 3.8.10-3 Attachment 1, Volume 13, Rev. 0, Page 319 of 323

Attachment 1, Volume 13, Rev. 0, Page 320 of 323

                                                                          .Distribution Systems - Shutdown B 3.8.10 BASES the correct breaker ( hich SURVEILLANCE                 SR 3.8.10.1                               required                includes all types of circuit REQUIREMENTS                                                                                   breaking devices) alignment This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution subsystems are functioning properly, with                    uses0 ee          . The verification of proper voltage availability on thetbuses ensures that the required power is readily available for motive as well.as control functions for critical system loads connected to thesevbuses. The                         (D 7 day Frequency takes into account the capability of the electrical power The voltage of the required distribution subsystems, and other indications available in the control DC bus must be greater than or equal to 125 VDC.d  room that alert the operator to subsystem malfunctions.                                         0 REFERENCES                   1. FSAR, 00

2. FSAR,ChapVr Section15 00 BVVOG STS B 3.8.10-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 0, Page 320 of 323

Attachment 1, Volume 13, Rev. 0, Page 321 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10 BASES, DISTRUBUTION SYSTEMS - SHUTDOWN

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

2. The brackets have been removed and proper plant specific information has been provided.

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made to reflect the Specification.

5. Changes are made to be consistent with the Bases of LCO 3.8.2.

6. Changes made to be consistent with changes made to the Specification.

7. Editorial changes for clarity and consistency.

8. Changes made to be consistent with the Bases of LCO 3.8.9 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 321 of 323

Attachment 1, Volume 13, Rev. 0, Page 322 of 323 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 13, Rev. 0, Page 322 of 323

Attachment 1, Volume 13, Rev. 0, Page 323 of 323 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific NSHC discussions for this Specification. Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 323 of 323}}

ML072200479

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