ML082270670

Improved Technical Specification Conversion License Amendment Request, Volume 13, Revision 1, ITS Section 3.8, Electrical Power Systems

ML082270670
Person / Time
Site:	Davis Besse
Issue date:	08/07/2008
From:	FirstEnergy Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
References
L-08-240, TAC MD6398
Download: ML082270670 (325)

Text

{{#Wiki_filter:ý I li 1ý 7 ' ', F , ",_' ý' ' '-= -, , ý ý .DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST I,, VOLUME 13 (Rev. 1)SECTION 3.8 -ELECTRICAL POWER SYSTEMS Attachment 1, Volume 13, Rev. 1, Page i of i Summary of Changes ITS Section 3.8 Change Description Affected Pages The changes described in the Davis-Besse Page 20 response to Question 200710101710 have been made. Corrected typographical error in Discussion of Change (DOC) M05.The changes described in the Davis-Besse Pages 28, 38, 53, and 78 response to Question 200710221417 have been made. Changed Note 1 to be applicable to the automatic portion of SR 3.8.1.9.a and all of SR 3.8.1.9.b. The changes described in the Davis-Besse Pages 36 and 70 response to Question 200710101512 have been made. This changed 3.8.1 Condition H and appropriate Bases to reflect that sequencers are load sequencers. The changes described in the Davis-Besse Pages 20, 45, 51, 52, and 89 response to Question 200712171517 have been made. Added the power factor criteria to part a of ITS SR 3.8.1.13.The changes described in the Davis-Besse Pages 62, 64, 66, and 100 response to Question 200802041718 have been made. Removed TSTF-402T. The changes described in the Davis-Besse Page 178 response to Question 200711161204 have been made. Changed SR 3.8.4.2 to verify the "required design" capacity of the required battery changers.The changes described in the Davis-Besse Pages 162 and 178 response to Question 200711161207 have been made. Changed the total battery terminal voltage to the minimum design voltage.The changes described in the Davis-Besse Pages 162, 167, 169, and 176 response to Question 200711161150 have been made. Adopted a more conservative Completion Time for restoring batteries to OPERABLE status.The changes described in the Davis-Besse Pages 211 and 233 response to Question 200711161149 have been made. Revised the bases for SR 3.8.6.3 to include a specific value for the electrolyte level.The changes described in the Davis-Besse Page 213 response to Question 200711161159 have been made. Deleted wording in DOC M01.The changes described in the Davis-Besse Page 234 response to Question 200711161212 have been made. Changed the Bases for SR 3.8.6.6 to require a service test instead of a performance discharge test. Also deleted the word "modified" from the performance discharge' test for the Bases of SR 3.8.6.6.Corrected the CTS reference number on an ISTS Page 48 Markup page (4.8.1.1 .d.2.a and 4.8.1.1 .d.2.b changed to 4.8.1.1.2.d.2.a and 4.8.1.1.2.d.2.b). Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page i of i Attachment 1, Volume 13, Rev. 1, Page 1 of 323 ATTACHMENT 1 VOLUME 13 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 1 Attachment 1, Volume 13, Rev. 1, Page 1 of 323 Attachment 1, Volume, 13, Rev. 1, Page 2 of 323 W 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 0 Attachment 1, Volume 13, Rev. 1, Page 2 of 323 Attachment 1, Volume 13, Rev. 1, Page 3 of 323 ATTACHMENT 1 ITS 3.8.1, AC SOURCES -OPERATING Attachment 1, Volume 13, Rev. 1, Page 3 of 323 Attachment 1, Volume 13, Rev. 1, Page 4 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 13, Rev. 1, Page 4 of 323 Attachment 1, Volume 13, Rev. 1, Page 5 of 323 ITS 3.8.1 ITS" 3/4.8 ELECTRICAL POWER SYEMS 3/4.8.1 AC. SOURCES QPERAT ING LIMITING CONDITION FOR OPERATION LC03.8.1 .3.8.1.1 As a minimum, the following A.C. electrical power sources shall be. OPERABLE: a. Two qualified circuits between the .offsite transmission network and the onsite Class IE A.C. electrical power distribution system, and /b. Two andinde endent diesel generators each with: SR 3.8.1.4 1. A s day fuel tank containing a minimum volume of 4000 gallons of fuel, S2. A separate fuel storage system containing a minimum volume.r See of 32,000 gallons of fuel, and ITS 3.8.3 13. A/seoarate fuel tran~fer, oumo. I APPLICABILITY:

MODES 1, 2, 3 and 4. dposeACONNoe}A

a. With one offsite circuit of the above required A.C. electrical.

power sources inoperable, demonstrate:the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement ).48.~l~~awithin one hour and at least once Der 8 hours (thereaf ter. nadb efring-Survei-llande Reouirement---l RS'I(4.8.-1.2a. wlhn Restore at'leas-t two.offsite LcrCults 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 L6llowing 30hours. 'ACTION A ACTION F':1\ I b. With one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the. OPERABILITY of the Add proposed Required)ACTION B remaining A.C. sources by performing Surveillance Requirement Action B.3.1 4.8.1.I.1.a within one hour and at least once per 8.hours _.thereafter and by performing Sqrveillance 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 ACTION F within the next 6 hours and in COLD SHUTDOWN within the following 130 hours: Add proposed ACTION D Note ---"A0)3 ACTION D C. With one offsite circuit and one diesel generator 9_ the above Lreouired 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 .l.a within one hour and at least once per 8 hours thereafter by performing Surveillance Renuired Action R.3.2 1 .....DAVIS-BESSE, UNIT I 3/4 8-1 Amendment No. 6, 97.-2o3, 206 Page 1 of 10 Attachment 1, Volume 13, Rev. 1, Page 5 of 323 Attachment 1, Volume 13, Rev. 1, Page 6 of 323 ITS 3.8.1 ITS ELECTRICAL POWER SYSTEMS L O5 ACTION (Continued. '. Ro e d pAtoAddpronposed 1 Required Action B.3.2 Nqui rement 4.8.1.1.2. a.4 within hours Rstore at east one o d po ACTIOND he inoperable sources to OPERABLE status within 12 hours -or be in a east STANDBY within the next 6 hours and in COLD SHUTDOWN ithin the following 30 hours. With the inoperable o.ffsite source Required Action B.4 restored, restore two diesel generators to OPERABLE status within days from the time of the initial loss.For be in at least HOT ACTION F STANDBY within the next 6 hours and in COLD SHUTDOWN within the Nollowing 30 hours. With the inoperable diesel generator Required Action A.3 _ restored, restore two offsite power sources to OPERABLE status R e nithin 72 hours from the time of the initial loss or be in at Host SANDBY within the next 6 hours and in COLD SHUTDOWN ACTION F within the following 30 hours.ACTIONC d. With two of the above reouired offsite A.C. circuits inoperable. demonstrate the PERABILITY of two diesel gen rators by performing _ LOl Surveillance Re irement 4.8.1.l.2.a.4.within/8 hours and at least once per 8 hour thereafter Unless the r already opera restore at least one' of the inoperable offsite ACTION C Esources to OPERABLE status within 24 hours For be in at least HOT ACTION F -ANDBY within the next 6 hours. With only one offsite source Required Action A.3 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 ACTION F ffollowing 30 hours..ACTIONE e. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by Required Action B.1 performing Surveillance Requireement 4.8.1.l.I.a within one hour Land at least once per 8 hours therea fter: r-estore at least one oF ACTION E -theinoperable diesel generators to OPERABLE status within 2 hours o-robein at least HOT STANDBY within the next 6 hours and in COLD ACTION F SHUTDOWN Within the following 30 hours. Restore at least two d Act -------di.esel generators to OPERABLE, status within 7 days from time of RequiredAction-- Ljitial. loss or be in at least HOT STANDBY within the next 6 hours ACTION F [jand 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: SR3.8.1.1

a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments and indicated power availability, and-- proposed Note I to SU.. A10 SIR3.8.1.9

b. '{Dmonstrated OPERABLE at-ps nce each REFELN INEVAL Idurin' L08 Ishutdnwnllby transferring. (manually.

and automatic~ally) unit Fs-up-pyto-each of the offsite circuits./ 4.8.1.1,2 Each diesel generator shall be: demonstrated OPERABLE: L0o SIR 3.8.1.2, SR33.8.1.3, aý At least once per ti days lit Surveillance Requirement 4.8.1.i.2.c SR3.8.1.4, 1has not been per/formed within the previous 31/dayI by: SR 3.8.1,6, SR 3.8.1,7 DAVIS-BESSE, UNIT 1 314 8-2 Amendment No. 114,1.07,20O3,26T,219 Page 2 of 10 Attachment 1, Volume 13, Rev. 1, Page 6 of 323 Attachment 1, Volume 13, Rev. 1, Page 7 of 323 ITS 3.8.1 ITS 0 ELECTRICAL POWER SYSTEMS Addproposed SR 3.8.1.2-Note 2 SURVEILLANCE REqUIREMENTS m~onti nued I SR 38.1.4 1; Verifying the fuel level in the day "fuel tank. See SI TSTS 3.8.)3]jI 2. Verifying the fuel level in the fuel storage tank.SR3.8.1.7

3. Veri fying the fuel transfer pump can be started and trans- Addproposed steadystate Moll fers fuel from the storage system to the day tank. voltage and frequency SR3.8.1.2

4. Verifying the diesel starts and jaccelerates to 900 r " SR3.8.1.3 A08 R .preceded by an engine prelube' and/or appropriate other Notes I and2 SIR 3.8.1.2 Lwarmup procedures..

/ 'S ... SR 3.8.1.3 5. '(Verifying the generator is synchronized, loaded to > Notes 3and4.11(.1 and operates tor >_,60 minutes. Noe n 0 6. Verifying the diesel generator is al gned:to provide 2340kWand<2600kW standby poq/er to the Associated essovtial busses. LA0 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 vjl Ue. " !-Add propose, d SI b. At least once per 92 days by verifying that a sample of diesel See, fuel from the fuel storage tank is within the acceptable limits lITS5.5 J specified in Table I of ASTM D975-68 when checked for viscosity, " (water and sedimentFr__

-' " f " C.. At least once per [~4fays by: I SR3.8.1.4

1. ' Verifying the fuel. level in the day fuel tank. L10 12. Verifying the fuel level in the fuel storage tank. [~See 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. SR3.8.1.8

4. Verifying the diesel starts.from ambient !condition and Add p SI 3]a cc l e r t e s o l ea t g 0 r m] i s 0 s e o nd .A dd proposed voltage and frequency SR3.8.1.3 5.J Verifying the generator is synchronized, loaded to -0 0 and operates tor 2:, ba mnutes. 3- wanoi' < 2600 kW 6. Verifying t (e diesel generator is al'/gne~d to provide L -SR3.8.1.6

7. Veri.fying'that the automatic load sequence timer is OPERABLE.

M0 with each load sequence time within 10%. of its reqi Pe d value.DAVIS-BESSE , UNIT 1 3/4 8-3 Amendment No. , ^ -03 Add proposed SIR 3.8.1.3 Notes I and 2 SAdd proposed SIR 3.8.1.3 Notes 3 and 4](Page 3 of 10 Attachment 1, Volume 13, Rev. 1, Page 7 of 323 Attachment 1, Volume13, Rev. 1, Page 8 of 323 ITS 3.8.1 ITS0 ELECTRICAl. 'POWER SYSTEMS z .:SURVEILL.ANCE REQUIREM ENTS (Continued) M05 d.At le:ast once each REFUE LING INTERVAL Pluring SR 3.8.1.10 1. 4Verifyingthe generator capability to reject a load equal to thelargest 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 Add p Nopoted sytem SF ) test signal 3.8.1.15 Note (a), Ve~riflying de-energization of the ess'ential busses, and load' sheddiiig from the --" 0*essential busses. ""x._(b) Verifying the diesel starts froin ambient condition on the auto-start signal, energizes the essential busses with permanently connected loads, energizes the auto-eonnct.etd essentkal loads~thro'ugh the load sequencer and operates for Add proposed start a 5 minutes while its generator is loaded with the essential loads. time limit and steady state voltage and frequency limits SR 3.8.1.12 (q) Verifying that all diesel: generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage ornthe essential bus nihd/ofran SFAS testsignal. SR 3.8.1.13 3. Verifying the diesel generator operates for> minutes while loaded to 20 w 4. l)eleted. IAdd proposed Note 1 and Note 3 e. 'At least once pr0mnths by subjecting the-diesels to an iscton in accordance with]p roe -edures prep~ared ill/conjun ction with its mnanufacturer's rcc mmendations; tbr this LA0ýclass of standby .sereni.'l,[Add proposed SIR 3.8.1.5, SR 3.8. 1.11, and SR 3.8.1.141 I' The provision of SpecifiCation 4.. r [ntapicable. D)AVIS-BESSE, UNIT 1 3/4 8-4 Amendment No. 97, 105, 141, 219, 273 0 Page 4 of 10 Attachment 1, Volume 13, Rev. 1, Page 8 of 323 Attachment 1, Volume 13, Rev. 1, Page 9 of 323 ITS 3.8.1 ITS ,314 LMTTIHG COMITTONS FOR OPERATION AND SURVEILLANCE' REOUTRENETS 3/4.0 APPLICABILITY LIMITING CONMITION FOR OPERATION 3.0.1 Limiting Conditions for Operation and ACTION requirements shall be applicable during the OPERATIONAL MOCES 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 speclfied~time interval shall constitute compliance.with the specificatlon. 'In the event ýthe Limiting Condition for Operation is restored prior to expiration of the specified time interval.completion.of the ACTION statement is not required.3.0.3 When -a Limiting Condition for Operation is hot 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: I. At, least HOT.STANIDBY within the next 6 hours, 2. At" ,east:HOTSHUTDOWN within the following 6 hours,.and 3.. At least COLOSHUTDOWN within the subsequent 24 hours.Where corrective measures: afe.completed, that permit operation under the ACTION requirements, theACTION 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-not-be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained' in the ACTION statements unless lotherwise excepted. This provision shall not prevent passage through OPERATIONAL, MODES as required to comply with ACTION See ITS 3.0 I istgements, Required A.2, B.2, a Actions 3.0.5 When a system, subsystem, train, component or device is determined to nd C.1 be inoperable solely because its emergency power source is inoperable', or.solely because its normal power source is' inoperable, 'it may'be 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 .traints), comonent(s) and device(s) are OPERABLE,.or likewise satisfy the requirements of this soecification. Unless both co ditions I1 and (2) are' satisfIed wlthin 2 wu acti on shall 'be nitiated to place t e unit In a KOEFIn e applicable Limitinq Condi ion or drto does n~ot .apol y by nl aci n I t a s anol jcahl g I n:l " 1. At.least HOT STANDBY within the net 6 hours.2. Atleast HOý SHUTDOWN within,,the fL14owlng 6 hours, and At ifh~n t rie .nt hlurs.F A j N ýIth'- jh_-'..e (This Soecifi~ation Is'not applicable in MODES 5 or 61 3.0.6 Equipment removed .from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY Of other equipment. This. is an exception to Specification 3.0.2 for the system"returned. to service under administrative control to perform the testing required to demonstrate OPERABILITY. See ITS 3.0 OAVIS-BESSE, UNIT I 3/440-I Amendment No. ;A-]43_,224 Declare required features inoperable. 24 hours for proposed Required Action A.2 4 hours for proposed Required Action B.2 12 hours for Required Action C. 1 L04 Page 5 of 10 Attachment 1, Volume 13, Rev. 1, Page 9 of 323 Attachment 1, Volume 13, Rev. 1, Page 10 of 323 ITS 3.8.1 ITS_INSTRUMENTATION 3/4,3,2 SAFETY INSTRUMENTATION SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITIONFOR 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 offTable 3.3-4.APPLICABILITY: As shown in'Table 3.3-31 I ACTiON: a.With a SFAS functional unit trip setPoint less, conservative than the value shown in the Allowable Values column of Table 3.3-4, declare the functional unit inoperable and apply the applicable ACTION'requiremefit of Table 3.3-3, until the functional unit is restored to OPERABLE status, with the trip setpoint adjusted consistent, with Table 3.3-4.See ITS 3.3.5land ITS 3.3.8_)See.ITS 3.3.5,1 ITS 3.3.6,lITS 3.3.7,1 and ITS 3.3.8)b. With a SEAS functional unit inoperable, take the action shown in.Table 3.3-3.SURVEILLANCE REQUIREMENTS 4.3.2.1 .1 Each SEAS functional unit shall bedemonstrated OPERABLE by the performance of the, CHANNEL 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 funciional units affected.by the, RCS pressure operating bypass operation. This RCS pressure operating bypass functionmshall be demonstrated OPERABLE at least once per REFUELING INTERVAL during CHANNEL CALIBRATION testing of each func'tional unit affected.by the RCS pressure operating bypass operation. See ITS 3.3.5 4,3.2,1.3 The SAFET'Y FEATURES. RESPONSE TIME" of each SEAS function"shall be demonstrated to be within the limit at least once perREFUELING INTERVAL. Each test 'shall include at least one functional unit per function such that all functional units are tested at least once every. N.times the REFUELING INTERVAL where N is the total number of redundant functional units in a specific SFAS function as shown in the "Total No. of Units" Column of Table 33-3., "Seea "---ITS 3.3.5 and ITS 3.3.8)* The response times (except for manual initiation) include diesel generator starting and sequence loading delays, when applicable. The response time limit (excepifor manual initiation) includes movement of See valves and attainment of pump or blower discharge pressure. " ITS 3.3.5 J DAVIS-BESSE. UNIT 1 3/4 3-9 Amendment No. 2H. 2Z5, 241, 243., 2,275 0 Page 6 of 10 Attachment 1, Volume 13, Rev. 1, .Page 10 of 323 0 ITS 3.8.1 ITS CD 0 CD CD CD 0-h w%LCO 3.8.1.c tl'TABLE:3.313 (Cocithitued' SAFRTY FRATIMRF ACrTIIATIO)N qY1TI:M INSTRII IMPNTATION, OT. NO OF ý"Its MINIMUM UN!TS UNITS APPLICABLE TO RIP OPERABLE -MODES ACTI(FUNCTIONAL UNIT 3. MANUAL ACTUATION a. SFAS (except Conlainment Spray and Emergency Sump Recireulation) 2 2 2 1,2,3,4 12 b. Contain'meit Spray 22 2 .1,2,3,4: 12 C)N See ITS 3 .3I.6J A09_ See ITS 3.3.8 J 4. SEQUENCE LOGIC CHANNELS a. Sequencer Ib m6ZP~I 0)CD 0 C: CD CD,, CD 0)wo NJ 0 2/1BUS, 112,3,4, b. Essential Bus Feeder Breaker Trip Degraded Voltage Relay (DVR) 4.'" 2/BUSý 2!BUS: 1,2,3,4 15#c, Diesel Generator Stan, Load Shed.on Essential Bus Loss ofV6otage. Relay (LVR) 4 2/BUS 2/BUS. 1,2,3,4M 1 .5. rNTER ilCK CHANNELS.Sa.: Decay flle~t' ho lat ion"Valvel I 1. 1 ij2,3 1#b. Pressurizer 2 2 " 2 "'3'**'" t See ITS 3.4 .14 See ITS 3.3.5]Page 7 of 10 Attachment 1, Volume 13, Rev. 1, Page 12 of 323 ITS 3.8.1 TAB4LE 3.3-3 (Cortinued) TABLE NOTATION* Trip function may be bypassed inthisMODE with RCS pressure below 1800 psig. Bypass shall be automatically removed when RCS pressure exceeds 1800 psig." Trip function may be bypassed in this MODE with RCS pressure below 660 psig. Bypass shall be automatically removedwhen RCS pressure exceeds 660 psig.*** DELETED TIM* nrCrtMr C See LTs 3.35 J L See l Aftunrctional units mayibe bypassed for p to one minute wheni starting each Reactor'Coolant. ITS 3.3.8 J Pump or Circulating Water Pump.See When either Decay Heat Isolation Valve is open. ITS 3.3.5 J A The provisio s of Spccirication 3.0.4 re not applicable.. A09 ACTION STATEMENTS See ACTION 10 -With the number of OPERABLE functi6nal units one less than the Total Number'of ITS 3.3.5 Units, STARTUP and/or POWER OPERATION may proceed provided, within one 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 ofinoperability. 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.L .1 ACTION 11 -With anycomponent in the Output Logic inoperable, trip the associatedcomponents See within one hour or be in-at least HOT STANDBY within the next.6 hours and in COLD ITS 3.3.7 SHUTDOWN within the following 30 hours.DAVIS-BESSE, UNIT I 3/4 3-12 Arnrendment No. 28,37,52,102,135, 159,186,211,218,221, 259 Corrected by letter dated.6/2198 Page 8 of 10 Attachment 1, Volume 13, Rev. 1, Page 12 of 323 Attachment 1, Volume 13, Rev. 1, Page 13 of 323 ITS 3.8.1 ITS TABLE 3.3-3 (Continued) ACTION STATEMENTS ACTION 12 -With the number ofOPERABLE.Units one less than the Total Number of Units, restore the inoperable functional unit to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6.hours and in COLD SHUTDOWN withinthe following 30 hours.ACTION 13 -a. With less than the Minimum Units OPERABLE and indicated reactor coolant pressure 328 psig, both.Decay Heat.Isolation Valves (DH1! and DH12) shall be verified closed.b. 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, indilcated reactor coolant pressure above 328 psig.See ITS 3.3.6 J See ITS 3.3.14 See ITS 3.1 51 I 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 tolincreasing indicated reactor coolant pressure above 328 psig, or the inoperable, functional unit.,shall be placed in the-tripped state.L ACTION G ACTION 15 -a.With the number of OPERABLE units one less than:theMinimum 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 b physical removal of the sequencer module. lThe inoperable See functional uni t.may be. bypassed for up to 2 hours for ITS3.3,.Isurveillance testing per Specification 4.3.2.1.1-,.' T 8 ACTION H b. With the number ofOPERABLE units two less than the Minimum Units Operable per Bus, declare inoperable the Emergency AddproposedAcionH Diesel Generator associated with the functional units not (firstCondition) meeting the required minimum units OPERABLE and take the ACTION required of Specification 3.8.1,1.DAVIS-BESSE, UNIT I 3/4 3-12a Amendment No. 28 5 ,1 ,1Z,11 8 Page 9 of 10 Attachment 1, Volume 13, Rev. 1, Page 13 of 323 ITS 3.8.1 TABLE 43.2 (Crnw itted)U SAFETY FEATURES ACTUATION SYSTEM INSTRUM-NTATION SURVEILLANCE REQUTREMENTS .......CH } CHANNEL. CHANNEL FUN12JIONAL SURVEILLANCE FUNCTIONAL UNIT CHEC CALIBRATION TEST _..._U_4, SEQUENCE LOGIC CHANNELS L0 a. Sequiencer 4NA M- SR 3.8.1.6 1 2,3 4 b, Essential Bus Feeder Breaker Trip,. S. A(37 M(_,43)ý 1, 2, 3,4.Degraded Voltage Relay (DVR) See c. Diesel Generator Start, Load Shed on S. A(3) M(3) 1,ý2, 3, 4 ITS 3.3.8 J Essential Bus, Lossof Vohage Relay.(LVR)CD 0 E 3 CD CD CD 0.3+1 w'I pz 5. INTERLOCK CHANNELS I f)naeav Heat Isalalion Valve S ,, F T, presstirizer Heater S R 3 ##L[ See ITS 3.3.See ITS 3.4.14 TABLE NOTATION (1) 'Manual actuation switches shall be tested at least once per REFUELING INTERVAL. All other circuitry associated with manual See safeguards actuatiOn shall receive a CHANNEL FUNCTIONAL TEST at least once per 31 days. -ITS 3.3.6 j (2) The CHANNEL FUNCTIONAL TEST-shall include exercising the transmitter by applying either vacuumror pressure to the appropriate See side of the transmitter- [ITS 33.5 (3) The as-left instrument setting shall be returned to A setting within the tolerace: band of the. trip setpoint estabIished to protect t(e safety: See limit. I ITS 3.3.8 J See peciicaion .5 2d~lsee ITS 3.4.14 1#4 'When either'Decay Heat Isolation Valve is Open See'ITS 3.3,5.]0)=r 3 CD 0 C 3 CD_Al CD CD 0)Page 10 of 10 Attachment 1, Volume 13, Rev. 1, Page 15 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES -OPERATING 0 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 if a 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. 1, Page 15 of 323 Attachment 1, Volume 13, Rev. 1, Page 16 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES -OPERATING 0 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 if three 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. 1, Page 16 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 17 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 18 of 323 Attachment 1, Volume 13, Rev. 1, 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 andrespective 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 isto 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. 1, Page 19 of 323 Attachment 1, Volume 13, Rev. 1, 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 "If performed 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 if the testing is conducted by synchronizing with the offsite sources. Other changes to CTS 4.8.1.1.2.d.1 are discussed in DOC M08.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 "If 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 perform their safety function. This change is designated as more restrictive because it adds more stringent testing requirements to the CTS.Davis-Besse Page 6 of 16 Attachment 1, Volume 13, Rev. 1, Page 20 of 323 Attachment 1, Volume 13, Rev. 1, 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 C.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. 1, Page 21 of 323 Attachment 1, Volume 13, Rev. 1, 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 1E 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 I -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 b6 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 1iP) 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 0 Davis-Besse Page 8 of 16 Attachment 1, Volume 13, Rev. 1, Page 22 of 323 Attachment 1, Volume 13, Rev. 1, 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.S 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 theTechnical 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 Required Action) 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. 1, Page 23 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 4 -Relaxation of Required Action) 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. 1, Page 24 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 3 -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. 1, Page 25 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 3 -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. 1, Page 26 of 323 Attachment 1, Volume 13, Rev. 1, 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, 1, Page 27 of 323 Attachment 1, Volume 13, Rev. 1, 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, the automatic transfer portion of SR 3.8.1.9.a and all of SR 3.8.1.9.b) 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 MODE S 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 (Category 4 -Relaxation of Required Action) 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. 1, Page 28 of 323 Attachment 1, Volume 13, Rev. 1, Page 29 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES -OPERATING 0 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. 1, Page 29 of 323 Attachment 1, Volume 13, Rev. 1, Page 30 of 323 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES -OPERATING 0 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 (Category 6 -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.0 Davis-Besse Page 16 of 16 Attachment 1, Volume 13, Rev. 1, Page 30 of 323 Attachment 1, Volume 13, Rev. 1, Page 31 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 31 of 323 CTS Attachment 1, Volume 13, Rev. 1, Page 32 of 323 ACSources -operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS LCO 3.8.1.1.a LCO 3.8.1.1.b 3.3.2.1 Table 3.3-3 38.1 AC Sources -Operating LCO 3.8.1 The following AC electricalpower so:uces shall be OPERABLE: a. Two qualified circuits between the offsite transrmission1 network and the onsiteýdiass'1E AC Electrical Power, Distribution System emergeny b. Two diesel generators ýDGs)each capable of supplying one train of the.onsite:Classl E AC Electrical Power Distribution Svsten' and M c. a oad.sequencers for TrainA and Train [a M two load sequencers for 0 0 0 0 APPLICABILITY: MODES 1, 2, 3, and4.ACTIONS NT.. .... 6- .. ....... NOTEL ------ i -t -DOC A02 LCO 3.0A4:bis notapplicaet Gs.0 Action a, LCO 3.0.5 CONDITION REQUIRED ACTION, COMPLETION TIME A. One [req 'red] offsite A.1 Perform SR 3.8.1.1 for 1 hour crcu it inopera e. OPERABLE [reqied]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 onejtrain its redundant required concurrent with feature(s) is inoperable. inop'erability of redundant required feature(s) AND, 0 BWOG STS 3.8.1-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 32 of 323 Attachment 1, Volume 13, Rev. 1, Page 33 of 323 CTS ACSources -Operating 3.8.1 Action a, LCO 30.5 Action b, LCO 3.0.5 0 ACTIONS (continued) CONDITiON REQUIRED ACTION COMPLETIQN TIME A.3 Restore [requed] offsite 72 hours circuit to OPERABLE status.B. One .G 5.1 Perform SR 3.8.1.1 for 1 hour inoperablej OPER.ABLE [ .offsite circuit(s). AND Once per 8-hours thereafter -AND.: B.2 Declar, e required feature(s) 4 hours from supported by the inoperable discovery.of E DG inoperable when its Condition B redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(S) AND B.3.1 Determine OPERABLE M24M hours-DGMis not inoperabledue, to common cause failure.OR B.3.2 Perform SR 3.8.1.2 for h24oh~urs AND 7 days B.4 Restore [DG to 72 urs OPERABLE status.0}00 0 30 0 0(D 000ýBWOG STS 3.8.1-2 Rev. .11, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 33 of 323 Attachment 1, Volume 13, Rev. 1, Page 34 of 323 CTS AC Sources -Operating 3.&.!Action d, LCO 3.0.5 Action c, LCO 3.0.5 I Action e ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two [requed] offsite: C.1 Declare required feature(s) 12 hous ,from-circuits inoperable inoperablei when its ,discovery of redundarnt required Cohditioh: C.feature(s) is inoperable. concurrent:with inoperability of redundait required feature(s)" AND C.2 Restore:one [req ed] '24 hours* ffsite, circuit to-OPERABLE status.D. One [req ed] offsite ---- ---NOTE ---------- circuit inoperable. Enter applicable Conditions. and Required Actions. of LCO 3.8.9, AND "Distribution Systemse-Operating," when Condition DIis entered with no One I[reqied]DG ACpower source :to any train.inoperable. L .- -D.1 Restore q edoffsite 12 hours circuit to OPERABLE status.OR E D.2 Restore t6req 12 hours'OPERABLE status.E, Two reqeDs E.1 Restore one [reqed]DG 2hours inoperable. E.1 to OPE sABLE E]0 0 00 00 0)00 00 BWOG STS 3:8.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 34 of 323 Attachment 1, Volume 13, Rev. 1, Page 35 of 323 CTS AC"Sources. Operating 3.81 ACTIONS (continued) Table 3.3-3 Action 15a Actions a, l c, d, and e DOC A04 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated 7 days power availability for each L6requ e d] offsite circuit.4.8.1.1.1,a 0 BVVOG STS 3.8.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 35 of 323 Attachment 1, Volume 13, Rev. 1, Page 36 of 323 3.8.1 (D INSERT 1---------- NOTE ---------- Separate Condition entry is allowed for each train.0 INSERT 2 DOC L09, Table 3.3-3 Action 15b H. ---------- NOTE ---------- Separate Condition entry is allowed for each train.Required Action and associated Completion Time of Condition F not met.OR One or more trains with two load sequencers inoperable. H.1 Declare associated EDG inoperable. Immediately Insert Page 3.8.1-4 Attachment 1, Volume 13, Rev. 1, Page 36 of 323 Attachment 1, Volume 13, Rev. 1, Page 37 of 323 CTS AC Sources.- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE: FREQUENCY: 4.8.1.1.2.a.4 SR 3.8.1.2... .NOTES --- ------t1 Al4DG starts may be preceded by an engine prelube period and followed by:a warmup aior~ l Iai nrlll=.E2. A modified'DG start involving idling a.ngradual acceleration to synchronous speed may be Lused for this SR0as.recomrmended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR'3.8.1 must be met. ]'[' Verify each G starts from standby conditions and achieves steady:state voltage > F374M"fVand 441a? 0V, and frequency > Hzand< .H 0 00 0(31 days 0}0 4.8.1.1.2.a.5 SR 3.8.1.3 ------------------------ NOTES ----------------

1. _DG loadings may include gradual loading as E "recommended by the manufacturer.

2. Momentary transients outside the load range do not.invalidate this test.3. This Surveillance shall be;conducted on only one OGata time.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 Verify each G is synchronized and loaded and operates foe> 60 minutes at a load > [45 0] kW.and 2340 --0}0 31 days LCO3.8.1.1.b.1, SR 3.8.1.4 4.8.1.1.2.a.1 Verify each day tankl[and engine Jnedfnted tank]l contains '>!. gal of fuel oil.E:::ýý4000 31 days BWOG STS 3:8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 37 of 323 CTS Attachment 1, Volume 13, Rev. 1, Page 38 of 323 AC.Sources.-

Operating, 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SU RVEILLANCE FREQUENCY SR 3.8.1.5 Check for and remove accumulated Waterfrom each M31[days.day tank l[and engine: nted tank]ýDOC M04 10 4.8.1.1.2.a.3 SR 3.8.1 Move SR 3.8A168 T to here from page 3.8.1-14 4.8.1.1.2.c.4

SR, 3.8.1.%0E Verify the fuel oil transfer system operates to. fuel oil I[auto callytransfer fuel oil fro storage tankp)to the day tankl[andengine nw ted tank]j R924days NOTE -------.-------------

AllG starts may be preceded by an engine prelube.period.Verify eac DG starts from standby condition and achieves-00 184 days.0 a. In-< 1(j seconds, voltage frequency >_T58.8 Handd F b. Steady state voltage :_ ;374DrV and o V, and frequency [. Hz and<} 0'i,.4.8.1.1.1.b .3.8A4 1---------------------

---

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

SR hshallnotnor-mallybeperformed SiNSERT3 in MODE. 1 or'2'. However, This SuTVti lanceI may be performed to reestablish OPERABILITY provided an assessment determines the safety ofthe plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.Verify manual[Mtransfer. of AC power sources:trom e normal offsite.circuit:toi55_6 alternate [reqied] offsite circuit.prio of SR 3.8.1.9.a and all of SR 3.8.1.9.b months 100 20 BVWOG STS, 3.8.1-6 Rev. 3A., 12101105 Attachment 1, Volume 13, Rev. 1, Page 38 of 323 Attachment 1, Volume 13, Rev. 1, 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. 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. 1, Page 39 of 323 Attachment 1, Volume 13, Rev. 1, Page 40 of 323 CTS 0 AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4.8,1.1.2,d.1 SR 3.8.1 Fd------ --NO T E S ------- --- -----[ 1. 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 maintainied or enhanced'. Credit may be taken for unplanned events that satisfy this SR.a UE 2. If performed with thelDG synchronized with wit offsite, power,' it shall be performed a a power.factr'1i However, if grid conditions do not permit, the: power factor limit is not requifed to be.met. Under~this condition the power factor shall be. maintainied as~close to the limit as practica ble. 1'E'-Verify each DG rejects a load greater than or equal to its associated single largest p0st-accident loaid, an Eg]~olowig load rejection, the freqUency is.2 67[Mmonths 0 0@00 0 0@b.c.Within [3] seconds followingqIad rejection, the Voltage is > [3740] V and 4580] V, and Within [3] secondsflf owing load rejection, the frequency is _ [5 Hz and < [61.2] Hz.I0 BWOG STS 3:8.1-7 Rev. 3.1. 12/0.1/05 Attachment 1, Volume 13, Rev. 1, Page 40 of 323 Attachment 1, Volume 13, Rev. 1, Page 41 of 323 AC Sources.- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued).SURVEILLANCE 'FREQUENCY SIR 3.8,.:1-10-R.1--- ----------- NOTES ---------------- .[1. Thi Surveillance shallnot normally be pe ormed in MODE o.or 2. However, this /S rveillance may be performed to: reestablis O ERABILITY provided an assessment tetrmines the safety of the plant is mainta ed renhanced. Credit may be taken for nplanned events that satisfy this SR.2. If performed with the DG synchronized wi h 6ffsite power,. it shall be performed at a p wer factor < [0.9]. However, if grid condition, do not permit, the power factor limit is not requi ed~to be met. Underthislcondition the power actor shall be maintained as close to the limi as practicable. ]Verify each DG does not trip, and voltage s Smaintained._< [5000] V during and followin a load.rejection of [4500]'kW and.! [5000] kW 0[18] ýmonths I I BWMOG STS 38.1-.8.Rev. 31, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 41 of 323 Attachment 1, Volume 13, Rev. 1, Page 42 of 323 CTS AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (6ontinued) SURVEILLANCE FREQUENCY DOC M04 SR 3.8.1..11

---

---

NOTES ---------------

A 1. AlDGstarts may be preceded by an engine prelube period.2. This Surveillance shall not normally be performed inMODE 1,2, 3, or4. However, portions of the;Surveillance-may be performed to.reestablish OPERABILITY provided aIn 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: a. De-energization -of buse b. Load shedding from merncybuses land c. DG auto.-starts from standby-condition-and:

1. Energizes.

permanently connected loads Jin..- P 1 second'2.. Energizes auto-connected shutdown load4 through I[automat cpC-0 equencerI individual time delay relays}3: Maintains steady-state voltage ."M 374 1Z]V 44000 4. Maintains steady-state frequency> Hzand " H and 5.. Supplies permanently connected and auto-connected shutdown loads.for>:5 minutes, 0[1 1 months 24 S 6 0 0 BWOG STS 3.8.1-9 Rev.. 3.1, 12/01-/05 Attachment 1, Volume 13, Rev. 1, Page42 of 323 Attachment 1, Volume 13, Rev. 1, Page 43 of 323 AC Sources -Operating 3.8.81 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANC E FREQUENCY SR 3.8.1.12-.... ....L. ...---NOTES--------------

1. All DG tarts may be preceded by an engine prelub. period.2. This S rveillance shall not normally be r perr ed in. MODE .1 or 2. fHowever, portions ofthe urveillance may be performed to reesta lish OPERABILITY providedaan asses ment determines the safety of the plant is mai tained or enhanced.

Credit may be taken: or unplanned events that satisfy this SR Verify oh n actual or simulated [Engineered Safet Feature ( SF)] actuation signal each DG auto-sta s from stan by condition and: a. In <[ 2] seconds after auto-start and during tests achievesvoltage > [3740] Vand frequ ncy _ [58.8] Hz, b. Achi ves stepady state voltage _> [3740] .v and [4580]:V and frequency > [58.8] Hz and<[61.2] Hz, c. Ope ates for 5 minutes, d. Pe r anently connected loads remain.energil ed fro the offsite power system, and e. Emi rgency.loads are energized [or auto-con ected through the automatic load seq encer] from the offsiteý power system.-1[18] months ]BWOG STS.3.8.1-10 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 43 of 323 CTS Attachment 1, Volume 13, Rev. 1, Page 44 of 323 AC:Sources -Operating 3.8.1 SURVEILLANICE RE0Q.UREMENTS (continued),SURVEILLANCE FREQUENCY 4.8.1.1.2.d.2.c SR 3.......-...NOTE--------------- [ThisSurveillance shall not normally be performed in MODE 1:or0 2. this Survdillance may be performed to reestablish OPERABILITY provided an assessment determines the: safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this:SR:.M VerifY each Gs.noncritical automatic trips are bypassedon or sirmulated loss of Voltage~sjgna! on thl. ny bus rconcurernt with an actual or simulated []Eactuation signal S 0.(0 mo:ths Safety Features Actuation System (SFAS)BWOG STSý37:8.1 -11 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 44 of 323 Attachment 1, Volume 13, Rev. 1, Page 45 of 323 CTS ACSources -Operating 3.8.;1 SURVEiLLAN'E REQUIREMENTS (coritinued) S,,u°RVEILLAN,'E- -FREQUENCY, 4.8.1.1.2.d.3 SRý 3.1 ,. j"...NO.TES.---------------

1. Momentary transients outside the load and power factor ranges donot invalidate this test.2. This Surve illanceshall not normally'be.

performed in MODE 1 or 2. HowevVe-r, ,this Surveillance maybe performed to reestablish OPERABILITY'provided an assessment determines theý.safety of theplant is maintained or enhanced. Credit may be'taken for unplanned events that satisfythis SR.3. If performed with-l] synchronized with offsite power, itshall be performed apower factot r 'li .However, if gridconditions do not permit, the .power factor limit is not. required to be:met. Under this condition the power factor shall bemaintained as clbse .to the limit as practi'cable. 0I---- M- ----- ------ 6 -------- m ------- m-w ----E Verify, eachGoprtsfr a.FofIýMhoursloadedýý5 OkWa6nd.6,0kVand-D

b. For theremaining hours of the test loaded[14 k- and! ý230 --L600O[1 Jmnthsl 00 Bw06 sbTS 318.1-12 Rev. -31, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 45 of 323 Attachment 1, Volume 13, Rev. 1, Page 46 of 323 CTS AC.Sources

-Operating 3.8a1 SURVEILLANCE REQU IREMENTS (continued)

SURVEILLANCE.

FREQUENCY DOC M04 SR 3.-... .. ...NOTES --------............

1. This Surveillance shall.be ýperformed within 5 minutes ofshutting down thel.DG after the4DG has operated 4hour. loaded >4 kW* and,: W-.4j E2:~3 J~~2600l Momentary transients outsideof load range do not invalidate:

this: test.E 2; Al DG starts may be precededby~an engine prelube period.0 0 E E Verify each [DG starts and achieves: a. In _<lC10 seconds, voltage_> 7AVand frequency MI5o81g Hz and b. Steady state volt~age! >! 74 V and ý F[4W0 'c', and freqgeny ýjj5~ .8t- and H.59.5 F60 5 IT ronths S R 8.8. 1.16 SR.....1.----------------- NOTE ......-------- This Survei lance shall not normally be performed i MODE 1,.2 3, or 4. However, this Surveillance ma be perfor dtio reestablish OPERABILITY provide an assess ent determines the safety ofthe plant-i maintaine. or enhanced. Credit may be taken for unplanne events that satisfy this SR.--- i--- ---- ---- ----------------....Verify ea DG: a. Sync ronizes with offsite power source while load d with emergency loads upon azsimulat d rest ration of offsite power, b. Tra sfers. loads to offsite power source, and c. Ret ms to ready-to-load operation. 0Q_17[1 8],months I BWOG STS 3.8.1-13 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 46 of 323 CTS Attachment 1, Volume 13, Rev. 1, Page 47 of 323 AC Sources -Operating 3.8.1 SURVEILLANCE R EQUIREMENTS (continued) SURVEILLANCE FREQUENCYýSR 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.Verify, wi h a DG operating in test mode.and connecte 'to its bus, an actual or simulated ESF actuatino signal overrides the test modelby: a. Rt rning DG to readyto-Iload operationand [b. Aut matically energizing the emergency Ioa fro. offsite power.]1_8[1.8] months ].1.1.2.a.7 Move to after SR 3.8.1.5 on -Page 3.8.1-6 SR---- L -..NOTE-------- ---.--.-- -.-. -[This Surveilla ce shall.not normall be performed in MODE 1, 2,3, or 4. However, this Surveillande may be. perfor ed to reestablish 0 ERABILITY providedan sessment'determin sthez safety of the plant is 'aintained or enhanc d. Credit may be taken-for un lanned events that , tisfy this SR.]0 0 0 0 Verify: interval between each sequenced load block is of design intervaQl for each emergency j[and shown load sequencer F[l -8 ]-T-Yn-t -hs]and each emergency time delay relay 0 BWOG STS 3.8.1-14 Rev. 3.1,, 12101105.Attachment 1, Volume 13, Rev. 1, Page 47 of 323 Attachment 1, Volume 13, Rev. 1, Page 48 of 323 CTS AC Sources- Operating 3.8:1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4.8.1.1.2.d.2.a, SR 3.8.1 .4.8. 1.1.2.d.2,b t .-------- ----. NOTES ---------------

1. 'AIDG starts may be preceded by an engine prelube period.2. This Surveillance shall not normallybe 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 orenhanced.

Credit maylbe taken for unplanned events that satisfy this SR.so Verify on an actual orlsimulated loss of offsite power, signal in conjunction with an actual or simulated f I- ]Factuation signal: a. De-energization of ,emer nc b.usest e b. Load shedding from mer nc byuses--.c[7. DG auto-starts from standby condition and: 1. Energizes permanently connected loads in < Ml1seconds

2. Energizes auto-connedted emergency loads througlh load sequence0_.

3. Achieves steady-state .and 0 Vm 4 4.. Achieves steady-state frequencyIHz and1 _ 2ý]aHz cd 5. Supplies permanentlyconnected and auto-connected emergency loads for>_ N minutes..T months and individual time delay relays 0 030 0 0)0d 0)0o 0 BWOG STS 318.1-15 ,Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 48 of 323 Attachment 1, Volume 13, Rev. 1, 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 byan engine prelu.b period. t Verify, w edn 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..19 0 BWOG STS 3:8.1-16 Rev. :3:1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 49 of 323 Attachment 1, Volume 13, Rev. 1, 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 towhat 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. 1, Page 50 of 323 Attachment 1, Volume 13, Rev. 1, 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." 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. 1, Page 51 of 323 Attachment 1, Volume 13, Rev. 1, 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 2.15. 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 _ 24 hours. ITS SR 3.8.1.13 requires each EDG to operate for _> 8 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 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. Davis Besse Page 3 of 4 Attachment 1, Volume 13, Rev. 1, Page 52 of 323 Attachment 1, Volume 13, Rev. 1, Page 53 of 323 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES -OPERATING 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 manually placed in service when in MODE 1, the Note restriction has only been applied to the automatic transfer portion of SR 3.8.1.9.a and all portions of the transfer from the normal offsite circuit to the alternate offsite circuit.Davis Besse Page 4 of 4 Attachment 1, Volume 13, Rev. 1, Page 53 of 323 Attachment 1, Volume 13, Rev. 1, Page 54 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 54 of 323 Attachment 1, Volume 13, Rev. 1, Page 55 of 323 I All changes are unless otherwise noted 9 AC:Sources -Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B ý3.8.1, AC Sources.-Oertn BASES BAC.KGROUNDU The unit Class I E AC Electical Power Distribution System.AC sources consistof the offsite power sources (preferred power sources, normal and alternate-) and the onsite standby power-sources rain and Tr in BI diesel-generators PDGs)). As required by IO0CFR 50, Appendix A,[GDC 17 (Ref. 1), the design ofthe AC electrical powersystem provides'independence and redundancy to ensure an available.-source of power to the Engineered.Safety Featur (E'F) .ystems.The onsite Class 1E AC Distribution System is divided into redundant.load groups (trains)ý so that the loss.of: any one group does not prevent the minimum'safety functions from being performed. Each train has connections to .two preferred offsite power sources and a single;DG. 0 0 Offsite0.power is supplied to thlý uni!t switchYardfflfrom thetransmission

network by [two] tra/smission lines'. From the swi chyard) ;tw0. ýSR e .lectrically and ph /sically se pa rated :circuits provi le AC .power, ISteP down statio' auxiliary tran sforrnersi Ito thes I. A6k ES Fb u s e s.a detailed description' f the offsite power network and the circuits to the Colass 1V EF buses is found in thel-SAR, Cha r [8] (Ref. 2).Se, cti on 8.3.1.1 Q An offsite circuit-consists of all breakers, transformers, switches, interrupting devices,, cabling, and controls required to transmit power from the offsite trahsmissio nnetwork to the onsite Class I E ý us(es)..e re dare returned toservice sne predeterm ne s uWhen a Safet-eaes I .I i " " Actuation System Asequence i order preventoverloadmg the transf L 3m8r supplying E ffsite piower to theronsit Class 1oE DistributionSystem ithin [1 minuL terter the initiatincsigal ist received, All automaticand permanently connected loads needed to recover the unit or maintain it in a safe condition are eretsusrpd Ioservie Ilvoia thf e r-E] The onsite.,st~andby ower sourc fo.reaeh 4.16'kVE¥1 Fbus-,, dedictdDG. ,DGs' [ and[] are dedicated ,to [ suses[] (a'n respecti~v~eq-y_. starts automatically on la React4-oolantj

" SSEAS Incident 9 ::K S Oe pesr sgnlor~on-an E R.us degraded voltage or -LCeve 2 acuto SiignaM (refer to LCO 3.3'.5, 1EgrrdSafety .s Mls Actua~tiion System (MSFAS) Instrumentation"Mand LCO3:3.8, "Eergency Diesel Generator (EDO) Loss of Power.StartN LPS') After, the 3G LJ" has started, it will automartically tie tO its. respective, bus after offsite power is tripped as a consequence ofM ]bus or degraded BWAOG STS B 3.8.1-1 Rev. 3.1, 12/01/05.Attachment 1, Volume 13, Rev. 1, Page 55 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 56 of 323 Attachment 1, Volume 13, Rev. 1, Page 57 of 323 r All changes are .AC Sources -Operating K unless otherwise noted B 3;8.1 BASES BACKGROUND (continued) an SFAS Incident Level 2 actuation voltage, independent of orcoincident withia saftinect n(SI)signal.--Fs Incdn LZJ will also start and'operate 'inthe standby mode without tying t Level 2 actuation T-tialhde' bus on an SI s al l5one. Following the trip~of offsite power,-ise ce4ý an undervoltage signalJstrips nonpermanent loads from th.4I bus. When the d-:his tied'to. the EF us, loads are then t sequentially connected toý its respective E Fus by the automatic load or indidual time dea , sequende .The sequencing Iogi controlmthe permissive and starting relays, as applica le ., .-: ' I ". -.g.signals to motor breakers to0 prevent overloading theuDG. y automatic load application. and individual time delay relays essential In the event of a loss of preferred power, the FE-ý-Felectrical loads areautomatically connected to the'DGs in sufficient time to provide forsafe reactor. shutdown and to mitigate theconsequences of a Design: Basis Accident (DBA) such as a .loss of coolant accident (LOCA).Certain required unit Ioads;are returned to;service. in a predetermined F cSequence in order to prevent overloading theýDG in the. process. VVithin-]- after the initiating signal is received, all loads heeded to recover the unit or maintain it in a safe, condition are returned to service.EG11-2 are consistent with Ratings for andr3aand 0 the requirements of 260_ Regulatory Guide 1 .9 (Ref. 3). The continuous service rating of each#DG i[700 k with permissible for upto 2 hours .in a ny -(1 24 hour period. The ESF loads that are: powered.from the 4.16 kV essen.ial busesazre listed in Reference

2. IST r UýAPPLICABLE The 'initial conditions of.DBA and transient analysesin (7'SAFETY Cha er 6M (Ref. 4) and ha ýer [5(Ref. 5), aSsume ESF gystems are ANALYSES OPERABLE.

The AC electrical power sources are designed toprovide:. Sci sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary powerto ESF OyStems so that the fuel, RCS,:and 0 containmentdesign limits are not exceeded. These limits are discussed in more detail in.tthe Bases for Section 3.2, Power Distribution Limits;Sectio.,n 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: BWOG STS B 3.8.1-2 Rev. 3.1, 1.2/01/05 Attachment 1, Volume 13, Rev. 1, Page 57 of 323 Attachment 1, Volume 13, Rev. 1, Page 58 of 323 B 3.8.1 0 (0 INSERT IA 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. 1, Page 58 of 323 Attachment 1, Volume 13, Rev. 1, Page 59 of 323 AC Sources -Operating B.3.8.1 BASES APPLICABLE SAFETY ANALYSES (continued)'

a. An assumed loss of all 6ffsite power or all onsite AC power and b. Aworst-case single failure. 0 r- Operating -i The AC.ources atisf Crite rion .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 independentDGs for each train ensure availability of the. required power, to shut dowrn thereactor and maintain it ina safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA: Qualified offsite circuLtsa are, those that aref described ithe FSAR and-are part of ,the licesn tbsis for the unit.B3.8.1-4, after two Move to Pagemutb(lZ first paragraphB 38,--,[ln addition, one. requir ýutomatic load. sequencer, per train must be firstpararaphOPERAL.~ 'Each offs.ite circuit must be capable of maintaining rated frequency and voltage, and.accepting required loads during an accident, while-connected to°the [IOffsite circuit #1.. con 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 of the StartupN Transformer, which s normally fed from the Switchy rd Bus A, and'is'fed through breaker P 0201 powering the ESFtransfo mer, which, in turi, ,powers the #2 ES bus through .its normal feeder, b, eaker.]-EachlG must be capable ofstarting, accelerating to rated speed ande voltage, and connecting to its respective g .us on detection of bus undervoltage. This will be accomplished withinjpflseconds. Each'DG (must also be capable of accepting required loa swithin the assumed timsl .oa ing se en interval, and continue to operate until offsite power essentiai can be restored to tl&D] buses. These capabilities are required to be.met from a variety of initial conditions, such as 4 DG.in Standby with the Eengine hot and G in standby with the engine at ambient conditions. [Dý Additional G capabilities must be demonstrated to meet required FE Surveillances, e~g., capability, of to rever.to sta status on an ECCS signal while ýperating in paralleltest, mode.0 BWOG STS B 3.8.1-3 Rev. 3.1, 12101/05 Attachment 1, Volume 13, Rev. 1, Page 59 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Insert Page B 3.8.1-3 Attachment 1, Volume 13, Rev. 1, Page 60 of 323 Attachment 1, Volume 13, Rev. 1, Page 61 of 323 All changes are unless otherwise noted J AC. Sources -Operating B 3.8;1 BASES LCO (continued) Insert paragraph from Page B 3.8.1-3 (which include all required individual time delay relays)Proper sequencing of load jlJncluding tripping of non7-essential !oads]is{ .Ja required function forDG OPERABILITY. 0 The AC sources in one train must be separate and independent to the extent possible) of the AC sources, in the other train. For the4DGs;-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, with fast-tr ansfer capability to the other circuit OPERABLE, and not violate separationcriteria. circuit that is not connected .to an E Frus is required to have OPERABLE fast-transfer interlock mechanisms to FsupportOPERABI LITYof that circUitl t 3 0 0 APPLICABILITY/ The reserv) the non-selector ofswitches are used to ensure thisl capability is available. / Therefore, if both reserve Ssource selector switches arelselected to the same offsite//circuit (i.e., the same startup Stransformer), the non-selected.The AC sourcesbnatsequcernJr]are required to beOPERABLE in MODES 1, 2, 3, and 4 to ensure that: a. Acceptable fuel design limits and reactor coolaht pressure boundary limits are not exceeded'.as:a result of AQOs or abnormal transientsL, andt b. Adequate core cooling is provided and containment OPERABILITY and other j functions are maintained in the event of a postulated DBA.0 0 0 The AC poWer requirements for MODES 5 and 6tare covered in LCO3.8.2, "Ac Sources -Shutdown." [ and other conditions in which AC sources are required 0 ACTIONS A Note prohibits the application of LCO 3.0.4.bto an inoperableVDG; There is aný increased risk associated with ehtering a MODE or other E specified condition in the Applicabilitywith an inoperable6 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. BVWOG STS B 3.8.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 61 of 323 Attachment 1, Volume 13, Rev. 1, Page 62 of 323 All changes are unless otherwise noted 9 ACSources -Operating B 3;8.1 BASES ACTIONS (continued) A.I To ensurea 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, fortwo offsite circuits inoperable, is;.entered..-REIEWR' NT ----- --- ----------

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... ....--- ----R E .V IE .W E R 'S N O T E& -- ....i--' .'The turbine driVenauxi iary feedwater pump is only requir d to be considered a redunda t required feature, and, therefore, rq luired 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 relianceon he motor driven auxiliary feedwater p mp powered by the emergency bu associated with the inoperable diese generator),of providing 100% of th auxiliary feedwaterflow'ass ed in the safety~analysis.

0 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 M.coincident withia singlefailure of the wil ,not result in a complete loss of safety-funiction of critical redundant. required features.These features are powered from the redundant AC electrical power train.This includes motqr driven emergency feedvater pumps. Single train.systems; .such asAturbine driven ere6rgency/feedwater pumps ,may not be included..The Completion Time for Required Action A.2 is: intended to0allow 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. The train has no offsite power supplying itlOard and b. required feature on theother train is..inoperable. redundantt 0 00 0 BWOG STS B 3.8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 62 of 323 Attachment 1, Volume 13, Rev. 1, Page 63 of 323 D All changes are EIY AC.,Sources -Operating unless otherwise noted 9 B 38A'BASES ACTIONS (continued) If at anytime-during the existence of Condition A (one offsite circuit inoperable);a redundant required feature subsequently becomes inoperable, this .Completion Time beginsto be trackedcl (4)Discovering rno offsite power to , one train. ofthe onsiteb. Class 1E Electrical Power Distribution System coincident with one or more. inoperable reudant (2)-required support or supported features, or both, that are associated with the othertrain that has offsite power,'results in starting the Completion TimeJfor the Required Action. Twenty4our hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transientsassociated with shutdowno The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power t ra A and rBf the onsite Class 1 E Distribution System. Th e 24 hour Comp etion Time takes into account the coniponent 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. DBAoccurring during this period.A.31 Consiteh Accor to Regulatory Guide 1.93 '(Ref. 6), operation may continue in0 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 lossoof 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+lGsare adequate 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 f a DBA.occurring during this period.B.1 To ensure a highly reliable power source remains with an inoperableZG, it is necessary to verify the-availability of the offsite circuits on a more frequent.basis. Since .the Required Action only specifies "perform," a n failure of SR 3.8.1.1 acceptance criteria does not result in a Required;Action being not met. However, if jcircuit fails to pass SR.3.8.1, it is 0 inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions. must thenbe entered.BWOG STS B 3.8.1-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 63 of 323 Attachment 1, Volume 13, Rev. 1, Page 64 of 323 BASES All changes are a,,2.9 ]unless otherwise noted AC Sources -Operating B 3.8.1 ACTIONS (continued)

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

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--*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 bythis Required Action, if th design is such that.the remaining OPE ABLE.motor or turbine driven au iliary feedwater pump(s) isý not by it elf capable (without any. reliance on the motor driven auxiliaryfeedwater pump powered by the emergenc.

bus associated with the inoperable die el generator) of providing 100% f the auxiliary feedwater flow a umed in the safety.analysis. B.2 Required Action B.2 is intended to provide assurance that a loss ofoffsite power, during the period that a+DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are:!designed with redunda'nlt.tafdty related trains..This inclu es motor driven.emergency~teedwator pumps. :Single train systems, sucl as-turbine i driven emergency foedwater pumps, are not included. I Redundant required feature.failures consist of inoperable features associated with a train, redundant to.the train that has 0 0 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, discoverythatboth:

a. An inoperable.

G exist and b. A equired.feature on the other train is inoperable. fat any time during the existence-of this ierondition (one G inoperable) a required feature subsequently become.s inoperable, thisCompletion Time begins to be tracked.0 0 Discovering oner G inoperable coincident with one or more U rddn inoperable~required support or supported features, or both, that.are associated with the OPERABLEiDG, results in starting the Completion Time for the Required Action. Four hours fromthe discovery of these events existing concurrently is acceptable because it minimizesrisk 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. 1, Page 64 of 323 Attachment 1, Volume 13, Rev. 1, Page 65 of 323 All changes are O r unless otherwise noted AC.Sources -Operating K. 9B 3.38.1 BASES ACTI.ONS (cobntinued) In this! Condition, the remaining OPERABLE0DG'and offsite circuits~are ,adequateto .supply electrical power to the onsite Class 1 E Distribution

System. Thus, owna .component basis, single-failure protection for the required feature's ifunction may have been lost; however, function has not been lost. The 4 h our Completion Time takes into account the OPERABILITYlof the redundant.counterpart to the, inoperable required feature., Additionally, the ,4 hour Completion Timetakes into account theq: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 B13.1 provides an allowance to avoid unnecessary testin of OPERABLEIDG(s).

If it can.be determined that the cause of the inoperable'DG does not exist on the OPERABLE G, SR 3.8.1.2 does not have~to be performed. If the cause of indperability.exists on other )G(s); the other+DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8'.1 would be entered. Oncethe failure is repaired, the common cause failure no longer exists and E Required Action B.311 is satisfied. If the cause of the initial inoperable D6, cannot be confirmed not to exist on the remainingýoG(s), performance of SR 3.8.11.2 suffices to provide assurance of continued OPERABILITY of that6G.In the event the inoperable&DG is restored to OPERABLEstatus prior'to completing either B.3.1 or B.3.2, theMplant corrective action 0 continue to evaluate the common cause possibility. This .continued evaluation, however, is no longer under the24 hour constraint imposed twhile in Condition B.According to Generic Letter 84-15 (Ref. 7), 2 hours is reasonable to 0 confirm that.the OPERABLEODG(s).. is not affected by the same problem..as the inoperable DG.BWOG STS B 3.8.1-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 65 of 323 Attachment 1, Volume 13, Rev. 1, Page 66 of 323 All changes are r unless otherwise noted I ACSources,- Operating s o B ,3.8.1 BASES ACTIONS (continued) B.4 According to Re ulatory Guide 1.93 (Ref. 6), operatio may continue in Condition B for ýperiod that should not exceed 72 h£urs.In Condition B, the remaining OPERABLE'DG and.offsite circuits are 7day ade uate to supply electrical power to the onsitetClass 1 E. Distribution System. Th 2 oU Completion Time takes into:account the capacity 0'and capability of the remainingAC sources, a reasonable time for repairs,ýand the low probability of a DBA occurring during this period. f The 7 day Completion Time is also acceptable as described in Reference

8. I C.1 and C.2 Required Actio~n CG 1, which applies When two offsite circuits are finoperable, is intended to provide assurance that an event with-a coincidet single failure will not result nma complete loss of redundant required[safety he Completion Time for this failure of ,redundant required features!

is reduced'to 12 hours from that allowed for one train withoutoffsite power (Required Action A.2). The rationale for the reduction to 12 hours' is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of. 24 hours for two required offsitecircuits inoperable, based upon the assUmptio nthat two completeýsafety trains are OPERABLE. When a concurrent redundant required feature failure.:exists, tl .isl assumption is not the case, and a 'shorter:ComnplIeti IonTime of 12' hoerSis appropriate* IThese.features aire powered from redundant'ACl Isaifety t'rains.lT Tiis includes~motor driven auxiliary fe~eywater PUmps;Single train feat res, such as turbine driven auxiliary 1umps, are not0 included in the ýst.The Completion Time for Required Action C.1 is intended to.:allow the.operator time to evaluate and repair any discovered inopera.bilities. This Completion Time also allows foran exception to the normal "time zero" for beginning the allowed outage time "clock," In this Required Action, the Completion Time only begins o.ndiscovery that both::a.. All required offsite, circuits are inoperable and Fredudn b; A required feature is inoperable. "ýnIf at any time during the existence of Condition C (two offsite circuits inoperable) and a4required feature becomes inoperable,. this Completion Time begins to be tracked.0 BWOG STS B 3.8.1-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 66 of 323 Attachment 1, Volume 13, Rev. 1, Page 67 of 323" All changes are (EIY AC.SoSurces -Operating K unless otherwise noted 9 B 3A8:1 BASES ACTIONS, (continued) Aqccoqrding to: Regulatory.Guide 1.93 5 (Refl;6)i operation may'continue in Condition CGfor 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 ýnotý been degraded.. This level of degradation general ly 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 twoIAC sources inoperable that involve one or more DGs 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 and b. The time required to detect and restore an unayailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.VVith boith of the :requireddoffsite circuits inoperable,.sufficient onsite AC sources are available to maintainthe unit in a safe':shutdown condition in the event ofa DBA or transient.

In fact, a simultaneous loss of offsite AC sources, a LOCA, and a wbrst-case single failure were postulated as: part of theO design basis in thesafety analysis. Thus, the 24 hour Completion. Time provides a period of time-.to.effect restoration of one of the offsite circuits com.mensurate with the importance, of maintaining an AC electrical powersystem capable of meeting its design criteria.Regulatory Guide 1.93 (Ref. Refenc 4with 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.0 BWOG STS B 3.8.1-10 Rev. 3.1, 12/01/05'Attachment 1, Volume 13, Rev. 1, Page 67 of 323 Attachment 1, Volume 13, Rev. 1, Page 68 of 323 All changes are 0."]unless otherwise noted ACSourceS -Operating) B 3.38.1 BASES ACTIONS (continued) D21 and D.2 s -Operating Pursuant to LCO 3.0.6",the Distribution Syste ýACTIONS would not be entered.eYen if all AC sources to it were inoperable resulting in de--energization. Therefore, the2 Required Actions of Condition D are modified by a Note t0 indicate that when Condition D is entered with no AC source to0any train, the, Conditions and Required Actions for LCO 3.8.9, "Distribution Systems -Operatingi,i' mustbe immediately entered. This allows Condition D to provide.requirements for-the loss~of one offsite circuit and oheDG without regard to.whether a train is-de-.energized. 70, 3 .8'9 pro~vides::the appropriate restrictio~ns for a.de enrizd LCO 3.8.9rvdsh prpit reticin forade energ.izedtrain. According to Regulatory Guide 1.93 ý(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 diversesources of power, however, the, reliability of the power systems in this Condition may appear higher than that in ConditiontC (loss of both required offsite circuits). This difference in-relilabilityjis offset by the susceptibility of this power system.con ,figurationto, a single bus oriswit~hing~failure. The 12 houLr.Completi~n Time takes into ýaccount the capacity and capability of the remaining AC.sourc.os, reasonable time for repairs, and the. low probability of a DBA occurring during this peribd..E.1 With .Train A rain Gs 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 levelo6f degradation. S BWOG STS B, 3.8.1 -11 Rev. 3.1, 12/01/05.Attachment 1, Volume 13, Rev. 1, Page 68 of 323 Attachment 1, Volume 13, Rev. 1, Page 69 of 323 All changes are (I"]unless otherwise noted AC Sources -Operating B 3.8.1'BASES ACTIO NS (continued) i----Regulatory Guide 1.93, (R.f.According to Kefe nce 4; withboth4?Gsinoperable,operation may, continue for'a period~that should not-exceed 2 hours:.0 0 INET31 The sequencer(s) i ýan essential support system to both the offsite circuit and the DG associ ted twith a given ESF bus]., [Fu hermore, the sequencer is on th primary success path for mos. major AC electrically powered safety: sy tems., powered from the associ te d ESIF 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 problemcommensuratelwiithe importance0of maintaining seqq encer OPERABILITY. This tin e period also ensures that the pr6bab 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 all s the Condition to be deleted if the nit design is such that anyse encerfailure mode will only affect the abi ty of the:associated DGto po er its respective safety loads under any c nditions..

Implicit in this Note i the concept that the Condition mr st be :retained if any sequenc failure. mode results in the inability to s art all or part of the.safety oab' when required, regardlessof power availl bility, or results inoverloadin. the offsite power:circuit to a: safety bus uring an event thereby'causi g'itsfailure. Also implicit in the.Note is th ft the Coihditioh;is not applicabl to any train that does not have a sequen er. ]A 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 unitmrnust be brought to atleast MODE 3 within 6 hours and to MODE 5 within 36hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from.full, power conditions in an orderly mannerandwithout challenging plant systems.0 0 BVVOG STS B 3.8.1-12 Rev. 3.1, 1.2/01/05 Attachment 1, Volume 13, Rev. 1, Page 69 of 323 Attachment 1, Volume 13, Rev. 1, 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 load sequencer modules.With one or more trains with one load 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 load sequencers in each train.H.1 With one or more trains with two load 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 load sequencers in each train.0 Insert Page B 3.8.1-12 Attachment 1, Volume 13, Rev.. 1, Page 70 of 323 Attachment 1, Volume 13, Rev. 1, Page 71 of 323 All changes are K unless otherwise noted AC Sources -Operating B 3.8.1 BASES ACTIONS (continued) Condition lcereSponds to a level of degradation in Which all redundancy inthe AC-electrical power supplies has been lost. At thisvseverely degraded level,.a.ny 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 3.03 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 9 function, in accordance CFR O,

18. (Ref.Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accidentconditions).

The SRs for demonstrating the OPERABILITY of the+DGs aregin accodance with the. recommendations of Regulatory Guide 1.9 (Ref. 3)R IGuidel. 1.0Ref.9 :9,[ and Regulatory Guide 1.137 laddressedi-tlfie FSAR[0 Where the SRsdiscussed herein specify Voltage and frequency tolerances, the following is applicable. The minimum steady state:output VIS 3 vtage of V[7A]I .90% of the nominal 4160 V output voltage is;value,-which s sp fied. iANS C84 .(Ref. 11), allo for voltage'drop and is consistent o the termin oI with Safety Guide9 as the ota.g00 Vdmotorswhose mnmumop atingvoltages'i (Ref. 11). specifiedaS 900°Of 3600 V. It also allows for Voltag dropsto motors.and other equi ment:down through the 120 V leve01 here minimumri operating voi ge is. also usually specified as 90% f name plate rating..The specified maximum steady state.outputvoltage of Viss equal.to the maximum operating voltage specified for 4000'V motors. It. ensures that for .a. lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no, more than the maximum rated operating voltages.,E steady state --The specified~rninimum and maximum frequencies of theDPG are (E ai nd ý Hz, respectively: These values are equal ýto.*+/- 2% oft he 6 0Z[ nominal frequepe and, are de'rived from the recgYnmendations given in I Regulator~y,9 de 1.9 (Ref. 3) .... based on plant-sp~ecif~ic analysis values.BWOG STS: B 3.8.1-13 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 1, Page 71 of 323 Attachment 1 , Volume 13, Rev. 1, Page 72 of 323 r All changes are 0.] AC Sources -Operating K unless otherwise noted B 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 o f offsite AC electrical power. The breakerfaligriment'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 approprlateý independence of offsite circuits is maintained. The 7 day FrequenCy is, adequate since breaker position isý.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. (3)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.' to indicate that all DG starts for these { J( K::-Surveillances may be precededtan engine pirelube, period and followed by 7 Eb w r u p ro prior to loading I rbyan engine b e d 7)Forthe purposes ofSR 3.8.1.2 and :SR 3.8.1,. bsting,the DGs are cI}started from standby.conditions. Standby conditions for VG Means that [].the diesel engine coolant and oil are being continuouslylcircu aaean7.temperature is being maintained consistent with manufacturer recommendations. In order to reduce stress and wear on diesel engines, some , manufacturers recommend a modified start, inwhich the starting speed of f1DGs is limited, warmup is limited to this lower speed, and the+DGs are. e4 gradually accelerated to Synchronous speed prior to loading. This is the intent of Note 2, which is only applicable. when such modified start procedures are recommended by. the manufacturer. 0 SR 3.8.1.4 requires that, at a 184 day Frequency, theýDG 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 FSAR, IChape [15]] (Ref; 5).The minimum voltage limit is based on the voltage required[or EDG breaker closure and the minimum frequency limit is based~on the recommendations of Safety Guide 9 (Ref. 11).0 BVOG STS B 3.8.1-14 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 72 of 323 Attachment 1, Volume 13, Rev. 1, Page 73 of 323 K All changes are Ei) .AC:Sources -Operating K unless otherwise noted 9 B 3.81;i BASES SURVEILLANCE REQUIREMENTS (continued) The l0second 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 startis not used, the: 10 second start requirementof SR3.8.1.T applies8 ....1-*Y (Since SR 3,8.1. requires a 10second start, it is more restrictive than SR 3.8.1.2, and it may be, performed in lieu ýof SR 3.8.1.2.In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified+DG start. method is employed, is monitored land the trgepfvaluatedj to identify degradation of governor and voltage regulator performance. The 31 day Frequency for SR 3.8.1.2 is consistent with Regulato ry Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1. s a reduct ion 0[ (incold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance. o0DOG OPERABILITY' while minimizing degradation resulting from testing.:SR 3.8.1.3-Týi- Ihis Surveillance verifiesthatitheý Gs are capable ofsynchronizing with )the offsite electrical systemnand accepting loads rgieat, r-than- or-,equal[ U T--.the equivalent of the r~aximum expected accident 1oa SL A m----run ensures the engine time of 60 mirwtes is re uired to stabii e emeratures, while temperatures are stabilized minimizing the time that thePG is connected to the offsite source.lagging Although.no power factor requirements are established by this SR, the---DG is normally operated at aipower factor between V.8 a gandl. The [0.8Mvalue is the design rating of the machine, while:t1ie b 'fis a _per nallimitation [o ensure circulatingscur-rt-are minimize amsrv- e load band is provided to avoid routine overloading of the+I7G..Routine overloading may result in more frequent teardown 6accordance with ver or recommendations, in, 0rd r to. maintain DG l~~OpE RABILI'I ." ...The 31 day Frequency forthis Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3)..0 BWOG STS B 3.8.1-15 Rev. 3.1, 1.2/01105 Attachment 1, Volume 13, Rev. 1, Page 73 of 323 Attachment 1, Volume 13, Rev. 1, Page 74 of 323 B 3.8.1 0 INSERT 4 Consistent with Regulatory Guide 1.9 (Ref. 3), INSERT 5 90% to 100% of the continuous rating of the EDG INSERT 6 being required in order to maintain EDG reliability 0 Insert Page B 3.8.1-15 Attachment 1, Volume 13, Rev. 1, Page 74 of 323 Attachment 1, Volume 13, Rev. 1, Page 75 of 323 All changes are unless otherwise noted I AC Sources -Operating B 3.8.1 BASES SURVEILLANCE 'REQUIREENTS (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. simi arly, momentary power fact prfansients above the limit will not invalidte the test Note 3 indicates that this Surveillance, shou d be conducted ononlyoneDG atVa 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 ofthis SR. A successfUMl Gstart must precede this test to credit. satisfactory performance. E SR 3.881.4 This SR provides verification that the level of fuel oil in the day tank ad i thin the " engine m oned tank] is at or above the eich fuel oil is required limit automatl ade. The level iS expressed as an equivalent volume in[ gallons,:.and Ris t o ensureoadequate fuel oil forl a minimrm mofl_-]hourof peration at full ladl plus/00/ 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 areprovided and unit operators required level in the associated would be aware of any large uses of fuel oil during this period.Istorage tank) to support 7 dayslof EDG operation at full load../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 ofwater from fuel oilday[and engi ountedtanlk once everyfM]31iM]daYs eliminates (j the necessary environment for bacterialsurvival. This isthe most effective means of controlling microbiological fouling. In addition, it__eliminates the potential for water entrainment in the fuel oil'duringiDG_ 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 ofaccumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil~system. The Surveillance .Frequenc -()is consistent are estase Regulatory Guide.1.137 (Ref. 10). This SR isfor with preventive maintenance. The presence of water does not necessarily represent failure'ofthis.SR, provided the accumulated Water is removed during the-performance offthis Surveillance. BvvOG STS B 3.8.1-16 Rev. 3.1, 12/0V056 Attachment 1, Volume 13, Rev. 1, Page 75 of 323 Attachment 1, Volume 13, Rev. 1, Page 76 of 323 0 I All changes are 1 unless otherwise noted J AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) Move SR 3.8.1.6 ------------- "-to here from SR 3.8.1 (one per fuel oil transfer system)Page B 3.8.1-31 This Surveillance demonstrates that each fuel oil transfer pumpv 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.MJThe Frequency for this SR is variable, de endin9 on indiviclal.systeml.design,vth up to 9ý921da ta The I92M day Frequency corresponds'to the testing requirements for pumps as contained in the 12j), hoviyever, the design of fue.Ittraflsfer systems.Is. om such~that p mp wil operate automatic .ally Or mu st b 'started manually inýorder:to. maintain ar/ adequate. volume. of fuel in .tle: day [and ,engine mounted.] tanks dueing or following DG :testing. Ins sch a case:, a. 311 day Frequency is appr priate. Since proper operation f fuel transfer systems is an inherent partof DG OPERABILITY, the Freq ency of this SIR should/be modified to ref ect indivi, dual design SR3..See.SV/3.8.1.2:. INSERT 6A [SR 3.8.1. eseta Transfer ofeach kV EVE F busJ power supply from the normal offsite (via the fast tran~sferbetwe~en the two startup transfrormeeersn circuit to t e alternate osi teci-rcuti demonstrates the OPERABILITY of the alternate circuit distribution networkto power the shutdown loads." The monthMJFrequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be-consistent~with..expected fuel cycle 2 lengths. Operating experience has shown that these components usually pass the SR when performed at theM month FrequencY. Therefore,.the Frequency was concluded to be acceptable from a reliability standpoint. 0 00d 0 0 0 0 0 0 BVVOGST B 3.8.1-17 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 76 of 323 Attachment 1, Volume 13, Rev. 1, Page 77 of 323 0 B 3.8.1INSERT6A 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 if the unit auxiliary source is supplying the electrical power distribution subsystem. 0 Insert Page B 3.8.1-17 Attachment 1, Volume 13, Rev. 1, Page 77 of 323 Attachment 1, Volume 13, Rev. 1, Page 78 of 323 All changes are unless otherwise noted I AC-Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modified bywa Noteý The reason for the Note. is that durin the automatic transfer portion of-g1....SIR 3.8.1.9.a and all of j operation withthe reactor critical, performance o SR could cause perturbations to the electricaldistribution systems that could challenge continued steady'state. operation and, as a result, unit safety systems.This restrictionfrom normally performing theSu-lanc in MODE 1 or2 automatic is further amplified to allow the Surveillance to be performed for the transfer* ... .... " * " .p o r t io n o f purpose~of reestablishing QPERABILITY(e.g., post work testing following SR 3.8.1.9.a ,corrective maintenance, corrective modification, deficient or incomplete and all of 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'ajfailed Surveillance, a successfulSirveillance, :and a perturbation of the offsite:orornsite system when they aretied' together or operated independently for the Surveillance; as Well asthe 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 beltaken for unplanned events:that satisfy this SR " SR (EachbDG is provided.with an engine overspeed trip to preventdamage 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 tripof the engine. This Surveillance demonstrates theý)G load response characteristics and capability to reject the largest single load withoutexceeding predetermined voltage and and while 00 im i tain _g a e cife margin to the o verspeedoe~ l trqipL., orft -G _jem ergen cy:,DGs, thj: larg est single load is 616 k)iV (H PI um )performance o ...1, the diesel load is reduced approximately 1200 kWand allo ed to run at~this load for 3 to:5.minut

s. The load is then reduced'to kW and the DGs output bre~aker opened* r IVerifid~ation'that DG ;did not trip is madel This Surveillance may. be accomplished by either: a. Tripping tfhel G output breaker with tJebDG carrying greater-than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bu ýor I r BWOG STS B 3.8.1-18 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 78 of 323 Attachment 1, Volume 13, Rev. 1, Page 79 of 323 B 3.8.1 O INSERT 7 (the high pressure injection pumps -approximately 540 kW)0'Insert Page B 3.8.1-18 Attachment 1, Volume 13, Rev. 1, Page 79 of 323 Attachment 1, Volume 13, Rev. 1, Page 80 of 323 I All changes are unless otherwise noted 9'AC Sourcesý-

Operating B 3.8 1 BASES SURVEI LLANCE REQUIREMENTS (continued) lrg s or its equivalent a t -h b. Tripping its associated single largest postratcident !oadAith, heOG solely supplying the bus:.As requed by (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. 4-- TSA The time, voltage, and frquency tolerances specified in this SR.ar derived from RegulatorGuide 1.9 (Ref. 3) recommendations for response during load equence intervals. The [3] seconds spe ified is, equal to 60% of a tyical 5 se'cond load sequence initerval as ciated with.sequencing of the. rgest load. The voltage;and frequency pecified are consistent withl .design range of the equipmernt powere bythe DG, SR 3.8.1 .9,a c"responds to theh maximum frequency ex ursioh,.while SR 3.8.1 .9.b nd SR' 3.8,1.9,care steady state voltag and frequency values to w.h'cthpe ystem must recover to followin oad rejection. The 0 0 (1-*iment Frequency is consistent with the r/ecommendation orfI., Regulatory Guile 1.108 .(Ref 9f.f takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths p.I This SR is modified by two. Notes. The.reason for Note 1 is that during ,operation with -the performance of this SR could cause perturbations to the electricalldistribution systems that could challenge continued steady state operation and, as aresult, unit safety systems'.This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplifiedto allow the Surveillance to be performed foirthe 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 aretied 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 unpl.anneld events that satisfy. this SR. Note 2: 0 BWOG STS B 3.8.1-19 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 80 of 323 Attachment 1, Volume 13, Rev. 1, Page 81 of 323 0 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.0 Insert Page B 3.8.1-19 Attachment 1, Volume 13, Rev. 1, Page 81 of 323 Attachment 1, Volume 13, Rev. 1, Page 82 of 323 BASES All changes are unless otherwise noted P AC Sources,- Operating B 38:1 BASES SURVEILLANCE REQUIRE.MENTS .(continued) wthin the'ensures that theDG is tested under load conditions that are:as. close to design basis conditions as possible. When synchronized with 'oste power, testing should be Performed a a power ,----This --EEO rfactor limit power factoris representative of the actual inductive loading aQDG would and -0.86 for EDG2 see under design basis accident conditions. Under certain conditions, however, Note 2-1allows the Surveillance to be conducted at a power outside the power factor limit factor othe-nt.5 [0.9]% These conditions occur when, grid voltageis, high,, and the additional field excitation needed to get the power factorto within theliit results in voltages.on the e ncy¶ us es that are too high. (a )Under these conditions, the power factor'should be rraintained as. close.aspracticable to whestill maintaining acceptablevoltage limnitson 0 eUS~es In other circumstances, the grid voltage may be wl hth excitation levels needed to obtain a power facto f may not cause unacceptable voltages on the Mes, butythe EDb excitation levels are in excess of~those recommended forthe in such.cases, the power factor shall be maintained as close as practicable, to }(the power factor limit H without exceeding the4DG 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 minany of the restricte MODES can satisfy the following cr .eria, as aipplicable:

a. Performance of he..SR will not render any safety sys emor component ino rable, b. Performance, o the SR will not cause perturbations o, any of the (I electrical distri ution systems that could result in a hallenge to.steady state o eration or to plant safety systems, .nd c. Performance ofthe SR, or failure of-the SR, will.n t cause, or'result in, an AOO ith attendant challenge toplant safe systems.B\AOG STS ,B 3.8.1-20 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 1, Page 82 of 323 Attachment 1, Volume 13, Rev. 1, Page 83 of 323 K All changes are 1 unless otherwise noted J ACGSources

-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) SIR 3.8.1.10 This Surveillance demonstra s the DG capability to reject a f 11 load without overspeed tripping o. exceeding the predetermine~d ,v Itage. limits.;The DG full load rejection my yoccur because ofea system fa It or inadvertent breaker tripping This Surveillance ensures pro, r-engine.generator load response urder the simulated .test condition .This test simulates the loss of the to al connected.load that the DG ,e peiences following a full load rejecti n and verifies that the DG ,will n t-trip upon lossof the load. These a ceptance criteria provide DG ,da age protection. While the, DG is not:expected to experience th s transient during an event and con nues to be available, this respo se ensures that.the DG is, not degraded or future application, including r cohnnection to:the bus if the -trip initiato can be corrected or isolated.The [18 month]. Freq ency ýis consistent with the r commendation of Regulatory Guide 1.1 8 (Ref. 9) and is intended to ee consistent With expected fuel cycle leigths.This SR is modified yltwo Notesý.. The reason for No e 1 is that during operation with the r ctor critical, performance of thi , SR could cause perturbation to the': lectricaldistribution systems.tha could challenge continued steady s te operation and, as a result, u it:safety systems, This restriction fro normally performing the Survei 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 testig, a nd other unanticipated OP ABILITY concerns)Provided an ass ssment determines plant safety is maintained or.enhanced. Thinassessment shall, as a minimu , consider the, potential.

outcomes and ýansients associated with a.faile Surveillancea successful Su eillance, and a perturbation of t e offsite or onsite system whenrthey are tied together or operated indep J/dently forthe Surveillance; swell 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 n and startup to determine that lant safety is maintained or enhanced en the Suryeillance is.performe, in MODE 1 or 2. Risk insights or ceterministic methods may be us d for this:asse.ssment.

Credit may/be taken for unplanned events t at satisfy this SR.0 0 BVWOG STS.B 3.8.1-21 Rev. 3.1,, 12/01/05'Attachment 1, Volume 13, Rev. 1, Page 83 of 323 Attachment 1, Volume 13, Rev. 1, Page 84 of 323 I All changes are unless otherwise noted J 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. Whenbsynch onized with offsite power, testing ould be performed at a power fa orzof.: [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 faor other han _4 [0.9]. These conditions occ r when grid voltage is- high, and the a ditional field excitation needed to g tthe power factor to_5 [0.9] results/ n voltages on.the emergency buss sthat are too high.Under these co ditions, the power factor should be. intained as close as practicable o [0.9] while still maintaining accept blevoltage limits;,on the emergen, busses. In other circumstances, tle grid voltage may be such that th DC excitation levels needed to obta n a power factor of [0.9]may not ca seunacceptable voltages~on the e, rgency busses, but the:excitation I Velsare in ie5cess of those recbmmrnded forthe DC. In such:cases, th power factor shall be maintained as close as practicable to[0.9] witlut exceeding the DGQ excitation limit------------ --.-- .REVIEWER'S; NOTE------ .-- ---- --The above.MODE r strictions may be deleted if it can be emonstratedto the staff, on a plan specific basis, that performing the SIR 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 stemor componen inoperable, b. Performa ce of the.SR will not cause perturbatio s,to, any of the electrical distribution systems. that could result ir a challenge to.steady ate operation orto plant safety syster, and c. Perforr nce of theSR, or failure of the SR, wInot cause, or result in, an/ 00 with attendant challenge to plant afety systems.0 0 SIR 3.8..11M 1.9F 2 c2 24ýntwithI Regulatory Gidea1 (Ref., ragraph 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 essential F the non-essential loads and energization ofthem erj1ncyuses and respective loads from theýDG. It further: demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.0 BWOG STS B 3.8.1-22 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 84 of 323 Attachment 1, Volume 13, Rev. 1, Page 85 of 323 All changes are G K unless otherwise noted AC..Sources -Operating B 3.8A1 BASES SURVEILLANCE REQUIREMENTS (continued)The bG auto-start time-of V I]seconds is derived from requirements of (3)the accident~analysis to respond to a.design basis,, large break LOCA.The Surveillance should be continued for a minimum of 5 minutes in,,order to demonstrate that'all starting transients have decayed and stability, has been achieved.The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily.show the (i.e., the individual time delay relationship of.these loads to theDG loading logi In certainlrelays for the component cooling .l1 water, service water, and makeup Circumstances, of these loads.can not actually* be connected or JJ L. pumps) J oaded witoutundue hardship or potential for undesired operation.Fo instance, Emerg ncyC.ore Cooling Systems (ECC injection valves are not desired.to b stroked open, high pressure injec ion.systems-are not capable of bein operated at full flow, or decay.he t removal (DHR).systems. perfor ,ing a DHR function are not desire to be realigned to the: ECCS mode of operation. In lieu of actual demonstration of connection [ and Iading of loads,testing that adequately shows the capability of the LJ DG .system to perform these functions. is acceptable. This testing may include any series of~sequential, overlapping, or total ,steps.so that the entire connection and loading'sequence is verified.0 The Frequencyof month is consistent wite recommendations 0o.JlReg~ulatory: Guide 1..1/p8. ..(Ref. 9)., parag~raph. ()ltakes* into.consideration unit conditions required to pe orm e Surveilllance, and is intended to~be consistent with expected fuel cycle lengths.This SR 'is modifiedby two Notes. The.reason for Note 1 is to minimize wear and tear on the DGs..during testing. For the purpose of this testing, 1hIiGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturerrecommendations. Theireason 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 o (T Surveillance in MODE 1, 2Iis further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY.(e.g., postwork testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITYconcerns) provided an assessment determines plant safety is maintainedor enhanced. This assessment shallas a minimum, consider the potential outcomes andtransients associated with a failed partial Surveillance, a successful partial 0 BWOG STS B 3.8.1-23 Rev. 3.1, ,12iO1/65 Attachment 1, Volume 13, Rev. 1, Page 85 of 323 Attachment 1, Volume 13, Rev. 1, Page 86 of 323 I All changes are unless otherwise noted 9 ACSources -Operating B 3.81 I-BASES SURVEI LLANCE REQUIRE EllE.NTS (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 Risk (3 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 nstratesthat 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 CA 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.e 6nsure that permanently conne ed loads and emergency loads ar 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. t 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 potntial for undesired operation. For i tance, ECCS injection valves are no0t desired to bestroked open, high pressure injection syste s are not capable of being operate at full flow, or DHR 0 systems perfo ming a DH R function are not desirel to be realigned to the ECCS mode f operation. In lieu of actual demon tration of connection and loading l loads, testing that adequately shov the capability of the DG system t perform these functions is accepta leý 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 isr inteIe 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 y. Therefore,.the. Frequency was c 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. 1, Page 86 of 323 Attachment 1, Volume 13, Rev. 1, Page 87 of 323 All changes are 0 L unless otherwise noted A ACBSources -Operating B 3.8.1 BASES SURVEILLANCE RE QUIREMENTS (continued) This SR is modified bYto Notes. The-reason for Note 1 i to mrinimize wear and.tbar onthe Ds 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 manuf cturer recommendations.. There,-on for Note 2 is'.that during -operation ith the. reactor.critical, performan of this Surveillance could c use perturbations to the electrical istribution systems that could hallenge continued steady state o eration and,,as a, result, unit safety's stems. This restriction from norm ly performing the Surveillance in M E 1E or 2 isjfurther 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, orr -ective modifi ation, deficient orincomplete surve llance testing, and other unanticip ed OPERABILITY concerns) provi d an assessment determines. pla t safety is maintained or enhanced. ThiSassessment shall, as a min) um, consider the potential outco s and transients associated wi a failed partial Surveillance,,a suc essful partial Surveillance., nd a perturbation of the offsite or *site system when :they are tied toge her or operated independently fort partial Surveillance; as well as the perator procedures available to cop with these outcomes.These shal be measured againstthe avoided ri k of a plant shutdown and startu to determine that plant safety is majntained'or enhanced when, portions fofthe Surveillance are performe in MODE 1 or 2. Risk insights o deterministic methods maybe use for the assessment. Credit m y be taken. for unplanned events th satisfy this SR.]--1 SR 3.8.1.A This Surveillance demonstrates that G noncritical protective functions S(e.g., high jacket water temperature) are bypassed on a loss of"voltage or s igna, concur ,e:withlan E F actuation test signal. Noncritical automatic S trips are a a automatic trips except: a. Engine overspeed; -b. Generator differential current%[c. Low lube oil pres re;d. High crankcae pressure; and:e. Start fail erelay.]0 0 0@The noncritical trips are bypassed during DBAs and provide M alarm.Rn:-abnormal engine. conditiý ,. alar rrprovideýthe operator with B\AK)G STS B 3.8.1-25 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 1, Page 87 of 323 Attachment 1, Volume 13, Rev. 1, Page 88 of 323 I All changes are unless otherwise noted AC Sources -Operating B 3.81 BASES SURVEILLANCE REQUIREMENTS ,(continued) a sufficientltime to react appropriately.. The availability to. mitigate the DBA is more critical than protecting the.engine against minor problems that are not immediately detrimental to. emergency operation of theaOG.-TheRf 8nmontIh]Frequency is based on engineering judgment,.taking into consideration unit conditions requited to perforrn the Surveillance[ I intended to be q'0nsistent with eXpected~fuel _cycle lengthsI. Operating. ex eXperience has shown that these.components usually pass -the SR whenperfprmed at Frequency. Therefore, the Frequency was concluded to be.acceptable from a reliability standpoint. 09 0 The SR is modified by a Note. The reason for the Note. is that performing ,the Surveillance would remove-a requiredilDG from service. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allowthe Surveillance to be perforimed for the purpose of reestablishing OPERABILITY (e.g., .post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and otherunanticipated OPERABILITY concerns)provided anmassessment determines p!ant.safety is maintained or enhanced. Thisa.assessmentshall, as a~minimum, consider the potential:outcomes and.transients associatedwith a failed Surveillance, a successful Surveillance, and a perturbation of the offsite ior 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 zagainst theavoided 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 ----------

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The above MODE re trictions.

may be deleted if it can be demonstrated to the staff, on af plant s ecific basis, that performing'the S with the reactor in any of the restrict d MODES can satisfy the riteria, as applicable:.a. Performance o theSR will not render. any safety s stem or component ino erable, b. Performance f the. SR will not cause perturbation to any of the electrical dist bution systemsthatcould result in challenge to steady state peration or to plant safety systems, an.d*c. Performanc ofthe SR, or failure of the.SR, will ot cause, orresult in, an AOO ith attendant challenge to plant saf ty systems..0 BWOG STS B 3.8.1-26 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 88 of 323 Attachment 1, Volume 13, Rev. 1, Page 89 of 323 S All changes are G, unless otherwise noted ACSoijrces:- Operating B 3.8.1 BASES.SURVEILLANCE REQUIREMENTS (continued) SR 3 0 Consistent with IEEE 387-1995 (Ref. 13),1_ Regulatory G~i i -1 .108 (Ref. 9)ý, paragraph 2/a:.'3),.rae u~ir~es.]- this~ ~ ~ý buvilnedmntae , per 18 months-thatlt~hGs c and. 10'(90% to 100% of the EDG] J co~ntinuously, at full load capabilit4for an interval,.of not less tharn4 hVours,. 105%o rating) -[ ours of which is".at:a load equivaleritfftof1 0%. of the:continuous-dt conti-uous rating and the, remaiderof the time ata load equi!va.ie..lnt tothe c ,continuo us;g frating ofthe4DG. The6DG starts, for this.Surveilance 6can be 90% to 100% of performed either from standby-por hot',conditions... Th"e provisions for 10 prelubridating-,and warmup, discussed, inhSR 3.8.12-, bahdfor gradual loading, discussed in SR3.:8.1.3, are applicable to this,'SR.fE The load banid is provided.to,.avoid routinieovedoading of theiDG.Routine, overloading may result in more frequent teardown inspections, in accordance with vendor recommendations, in orderto maintain'lOG `OPERABILITY. 24based on engineering judgment, taking The mont Frequency is consistent-With.the r commen ations O Q SRegulatory Guide 1/.108 (Ref. T)paragraph 2.a. f):takes into consideration unit conditions. required to perform the. Surveillance and is intended to.be consistent with expected'fuetcycle-lengths. t This Sureillance is modified by three Notes. Note 1 states that'consistent with Regulatory Guide 1.9 (Ref. momentary transient s due:to changingbys loads do not invalidatethis

3) for the 2-hour portion of the test ands possible test. Similarly, mnomentary power factor transients above the power factor for the 6-hour portion of the test., limrit-will not invalidate the test. The reas6n for Note 2 is that during I N operation with the' reactor critical, performance ofthis Surve illance :could Inser ao e ,,, "" .., ..i ' , ," , , ... :" ; ' .: ,"' t : ; t '~ t ' :" ...from page caus perturbationis to the',electrical distribution llsystims ,that could B 3. 1 -28 challenge continued'steady state operation and,.as a result, :ýunit:safety syste ms Note:3 ensures:that the,.G is testedIunderloadconditions that 1 (D7 10 When an EDG is tested at a load d. i Nh'en synch"ronized equivalent to105% to°110% of the l "a .61;6" to ...... .-f .... .' ' § .... si b rme. oe rf syn r -ni continuous rating (part a), the with offsite:power., testing should be pefo rmed a a owen facto rU an pow istested aim t i a lod 09 W Thisi power factor is represenitativeof the actual inductive 10a'ding equivalent to 90% to 100% of the I Gwould :see: under designý basis accident conditionsl.f Under certain outside^te

[ cotiuos atng(prtb) te ....-.--- cdrdidtons.,, howe~er, to bedo* power factor pimit is e 0.85 forf EDG 1 and S 0.86 for EDG 2. 1power, factor. han _ 0.9. These conditions occur when grid voltage ishi h, and the-additional field excitat ion needed to ge't the power fadctor'-~t ijresults imnvoltages on teee cbus~s thatare tdoohigh.telUnder these-conditions, the powerfactor should be maintained as close e aas, practicable tq0while still maintaining acceptabl.e voltage limits on L NiiID fij rnc busles. In other circumstances, the grid voltage ma be w[ -suchýthathe4DG excitation levels needed to obtain a power'factor of ý9 may not cause unacceptable voltagesvon the s e oer.ncthuses, buut e excitation levels are in excess of-those recommended for-theG In-such _BWOG STS, B 3.8.1-27 Rev. 3:1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 89 of 323 Attachment 1, Volume 13, Rev. 1, Page 90 of 323 B 3.8.1 O 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. 1, Page 90 of 323 Attachment 1, Volume 13, Rev. 1, Page 91 of 323 All changes are a unless otherwise noted 9 AC:Sources.- Operating B 3.8.A 0 BASES SURVEILLANCE REQUIREMENTS (continued)

cases, the power factor shall be maintained as close as practicable'to

[0 withoutexceeding the4DG excitation limits. his restriction from.the power facto limit normally performing the Surveillance in MODE 1i 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 modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY conc.erns) provided'an assessmert determines plant safety, is maintained or enhaniced. This assessment Moveto Page shall, as a minimum consider the potential outcomes and transients B3 3.8 .1-27 as ... .. .. ...... .minimum co sd rtep te .o to e Sinsert Note 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 0--0 0 measured against the avoided risk of a plant shutdown and startup to determine that plant'safety is-maintained orenhanced when theSurveillanceis performed in MODE 1 ,or 2. Risk insights or deterministic metho"ds may-be used for this, assessment. Credit may be taken for unplanned events that satisfy this SR. F SR 3.8;.1.0 The minimum voltage limit is based on the vtage required for EDG breaker closure and the minimum frequency limit is based on the recommendations of Safetv Guide 9 (Ref. 11).,/This Surveillanceo demonstrates thatfthe diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within s10 secondsIJ The M10 seconcftime is deirived from the requirements of" the accident analysis to respond toa design basis large break LOCA.Eý T O 'hermontlq]Frequency is consistent with he. ecommendations of INSERT 10 Regulatory Guide 1/108 (Ref. 9):, paragraph 2:a50).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:theýhG.. Routine overloads may resUlt in more frequent teardown inspections, in accordance with vendor recommendations, in order to maintain4DG OPERABILITY. The 0 reqUirement that'the diesel has operated for at leastoKtur a ull load conditions prior to performance of this Surveillance is based on approximately) Imanufacturer re endations or achieving hot Cnditions. Momentary sa transients due to changing bus loads do not invalidate this test. Note 2 lliows starts to be' preceded by an engine prelu.be period to minimize wear and tear on the diesel during testing.0 BVVOGST B 3.8.1-28 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 91 of 323 Attachment 1, Volume 13, Rev. 1, Page 92 of 323 B 3.8.1 0 O 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. 0 Insert Page B 3.8.1-28 Attachment 1, Volume 13, Rev. 1, Page 92 of 323 Attachment 1, Volume 13, Rev. 1, Page 93 of 323 I All changes are a unless otherwise noted ACGSouices -Operating B .38.81 BASES SURVEILLANCE REQ,U.IREMENTS (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 DGt.the offsite .source, can be :ade a DG.cah.be returned to ready o load :status when offsite power islns estored:. It also.ensures tht 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 signal on bus undervoltage, and he:.load sequence timers are reset.The Frequency of [18 months] is consistent with the r commendations'of. Reguly GuIde 1.108 (Ref. 9), paragraph 2.,a.(6), a dtakes into.Regulatory Guid , 1. ak1s1 int:c6nsideraItion uni conditions required to perform the urVeillance. This SR is modi ied by a Note. The reason for theN teNeis that performing the SUrveillanc would remove4a required offsite cir uit from service, perturb the ele trical distribution system, and challe ge safety systems.This restriction from normally performing the Surve* lanQe .in MODE' 1 or:2 is furtherampý fied to allow'the Surveillance to be. erformed for the purpose .of re stablishing OPERABILITYi(e.g., Po t work testing following ,corrective mn intenance, corrective modification, d ficient or incomplete surveillance e.sti.ng, and other unanticipated OP-ABILITY concerns)provided an ssessment determines, plant safety s maintained or enhanced. his assessmentshall, as a minimur, consider:the potenrtial outcomes ndtransients associated. with a faile Surveillance, a successful Surveillance, and a perturbation of t 6e offsite or onsite system.when they are tied together or operated indepe dently for the Surveilla. .e; -aswell as the operator prlcedaur available to cope with.these 6umes. These shall be measured ag inst the avoided risk of a plant sh down and startup to determine that lantsafety is.s maintained or enhanc d when the Surveillance isperforme 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.0 0[SR 3.8j.1.17 Demonstration. oft test mode override ensures that e DG availability under, accident c ditions will not be compromised ai the, result of testing and the DG will utomatically reset.to ready toload peration if aý LOCA.actuation sig. I is receive.d 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' outputbreaker open.. These provii ions forautomatic switchov rare required by'IEEE-308 (Ref. 1 , paragraph 6.2,6(2).0 BWOG STS B 3.8.1-29 Rev. 3.1, 1,2/01/05 Attachment 1, Volume 13, Rev. 1, Page 93 of 323 Attachment 1, Volume 13, Rev. 1, Page 94 of 323 I All changes are unless otherwise noted J AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) The requirement to autor atically energize the emergency. , ds with offsite, power is essentiall,, identical to that of SR 3.8.1.12. he intent in the requirement associaed

with.SR 3.8.1 .17.b is to showth t:the.emergency -loading was not affected.

by the DG operation i test mode. In lieuof actual demonstr tion connectibn and loading of I ads,testing that adequately shows he capability of the:emergency'loa s to perform.these functions is acC ptable. This testing.rmay include ay .series of ,sequential, overlappir, or total steps so that the entire..c innection and loading sequence is erified.The [18 month] Fre ency is consistent with..the: recomi endations of Regulatory Guide 1 08 (Ref. 9), paragraph 2.a.(8), tak s into conisideration unit c nditions required to perform the Su veillance, and is intended to be con istent with expected fuel cycle lengr s.This SR ýis modifi by a Note. The: reason'for the No Ais that performing the Surveillancevould remove a required offsite circu t from service., perturb'the electr cal distribution system, and challenh e safety systems.This restriction frim normally performing the Surveill nce in MODE 1 or'2 is furtheramplifild to allow portions0of the Surveillan e to be performed for the purpose of reestablishing OPERABILITY (e. ., post work testing following corre tive maintenance, corrective modific tion, deficient or.incomplete su eillance testing; anrid other unanticip -tedOPERABILITY 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 ysafey is maintained or enh nced when portionsof.-the srve ance areperformed in MODE 1 or 2 Risk insights or determini tic methods may be usedfor the ass ssment. Credit may. be taken for unplanned events that satisfy this S ..0 BWOG STS B 3.8.1-30 Rev. 3.1,12/01105 Attachment 1, Volume 13, Rev. 1, Page 94 of 323 Attachment 1, Volume 13, Rev. 1, Page 95 of 323 All changes are unless otherwise noted J AC Sources -Operating B 38.1 BASES SURVEILLANC E REQUIREMENTS (continued) and emergency_ time delay relays (ile., the makeup 1 ,S ...coincident with pu p el Under accident [a. d lodss~of offsite poweQjconditions loads are -/ }sequentially connected tothe bus.by the [auto.ati load sequence The sequencing logic controls the permissive and-starting signals to ýmotor (D breakersto preventoverloading of the4DGsdue to high motor starting currents-The Mier%/ load sequence time interval tolerance ensures that Ssufficient time exists:for theDG'to0 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 automaticloading ofl buses.T10 Move to after SR 38.1.5 on Page B 3.8.1-17u e .nt The Frequencyofi[t8 uths] is consisren to withrthe recommendations, ofi judgme nt enineing egulatory Guide 1r .t I(Rf 9, paragraph '2:a.(2), takes i-nto[ ugettkn conside-ration unit conditions. required to perform ý-3)I intended to be cq/nsistent with expected/fuel cycle: lengthsj.- This SR .is modified by a Note. The reason for the Not! is that performing the Surveillance woul remove a required offsite circui.from service, perturb the electrical istribution system, and challengsafety systems.This restriction from ormally performing the Surveill ce in'MODE 1 or2l is further amplified to allow the Surveillance to be the purpose ofreestabli 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 plantsafety is maintained or " enhanced. This:a essment shall, as a minimum, consider the potential ,outcomes andtra *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 operate.d indepen .ently for the.Surveillance; as elI as the operator procedures available to'cope with.these outcomes. These shall be.measured aga- st theavoided risk of a plant shutdown nd startup to determine that pI nt safety is raintained ,or enhancedwhen the Surveillance is~performed i MODE I or 2. Risk insights or dete ministic methods may be used for this assessment. Credit* may be.t ken for unplanned events.tha satisfythis SR.a BWOG STS B 3.8.1-31 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 95 of 323 0 Attachment 1, Volume 13, Rev. 1, Page 96 of 323 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. B 3.8.1 0 Insert Page B 3.8.1-31 Attachment 1, Volume 13, Rev. 1, Page 96 of 323 Attachment 1, Volume 13, Rev. 1, Page 97 of 323 0 All changes are 1 unless otherwise noted AC.Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

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REIEWERS NOTE -- 7....-------

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The above MODE re'Srictions may be deleted if it can be..ý 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 safetysy tem or component ino erable, b. Performance o the SR will.not cause perturbation to any ofthe.electrical distri Lution systems that could result in.a challenge to steady'state o eration or to plant safety systems, nd c.i Performance o'f.the SR, or failure of theý SR, will n t cause, or result in, an AOO ith attendant challenge to plant safe systems.0 0.SR 3.8.1A In the event of a DBA coincident with a loss of offsite power, theDGs are requiredto.

supply the necessary powerto ESF systems so that the fuel, RCS, and containment design limits are not exceeded.For this test, the EDG loading logic includes both the load sequen and the individual time delay relays for the ,makeup pumps.This Surveillance demonstrates the OG operation, as discussed in the'Bases for SR 3.8.1.11, during a loss of offsite poweriactuation test signal in conjunction withl ai actuation signal. tIn lieu of actual demonstration of connection and loading of loads, testing thatadequately shows-the capabilityof theDG systeemto performthese functions'is er 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 monthsj]takes into consideration. unit conditions required to perform the Surveillance and is intended to be consistent \Vith an expected fuel cycle.length of M This SR .is modified bytwo Notes: The reason for Note 1 is to minimize earand tear on the*DGs during testing. For the purpose of this testing,ýthe Gs must be started fromstandby conditions, that is, with the engine coolant and oil contindously circulated and temperature maintained. 0 0)0 BVVOGST B, 3.8.1-32 Rev. 3.1, 1.2101/05 Attachment 1, Volume 13, Rev. 1, Page 97 of 323 Attachment 1, Volume 13, Rev. 1, Page 98 of 323 r All changes are Q'] ACSources-Operating unless otherwise noted A B 3.8:i BASES SURVEILLANCE REQUIREMENTS (continued) consistent with manufacturer recommendations fot 4 DGs. Thereason 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 2+isfurther amplified to :a.low portions of the.Surveillance:to:be performedfor the purpose.of reestablishing L '}OPERABILITY (e.g., post work testing following corrective maintenance, coirrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment.determines plant safety is maintained or enhanced. Thisassessment shall,'as a minimum, consider the potential outcomes.and transients. associated with a failed partial. Surveillance; a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as.well as the operator procedures available to cope with these outcomes!. These shall be.measured

against the avoided risk of a plant-shutdown ,and startup to determine that plant safety is maintained or enhanced when .portions of the S urveillahce are performed in MODE [lV- 2Zhniskiq

(ý'insights'or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR..:SR 3.8.1.20 This Surveillance de onstrates that the DG:starting ind endence has not been compromis

d. Also, this:Surveillance demon rates that each engine can achieve roperspeed within the specified time when the DGs are started simulta .eously.The 10 year Fre uency is consistent with the reCorendations of 0 Regulatory Gui e 1.108 (Rbf. 9), This SR is rfdified 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 s rted from standby conditions, that i. , with the engine coolant and oil co, tinuously circulated, and temperatu e maintained consistent with ma. facturer recommendations.

BVVOG STS B 3.8.1-33 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 98 of 323 Attachment 1, Volume 13, Rev. 1, Page 99 of 323 AC Sources -Operating B 3.8.1 BASES REFERENCES

1. 50,,AppendixjA, GDC 17.2. FSAR, ¶-_.. .. (Section 8.3.1 .1 3. Regulatory Guide 1.9, Rev. 3.4. t FSAR, ater 5. tFSAR, 9Chaer 15J U Section 6'. Regulatory Guide 1.93, Rev. [d e.7 GniDecember 1973Generic* Letter :84-15.00 0 NRC Safety Evaluation for Amendment 206, dated February 26, 1996, J 8. 110 CFR 50. Ampendix A..GDC 18.1*UFSAR, Section 8.)9. lRegulatory Gode: 1.1,08; Rev. [1], [t gust 1977].1 10., Regulatory Guide: 1.137,. 11. NSI 084.11982.I

'--Ocor17 12.1 ASME Code for Operation and Maintenance of Nuclear Power: Plants.0 0 0 0 13.:

3/-[17]I

.11. Safety Guide 9, March 10, 1971.-- 13. IEEE 387-1995.0 BWOG STS B 3.8.1-34 Rev. 3.1, 1,2/01/05 Attachment 1, Volume 13, Rev. 1, Page 99 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 11. The qualified offsite circuit is described in this LCO section. Therefore, a reference to a description in the FSAR is not needed.0 Davis-Besse Page 1 of 1 Attachment 1,. Volume 13, Rev. 1, Page 100 of 323 Attachment 1, Volume 13, Rev. 1, Page 101 of 323 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 13, Rev. 1, Page 101 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 102 of 323 Attachment 1, Volume 13, Rev. 1, Page 103 of 323 WATTACHMENT 2 ITS 3.8.2, AC SOURCES -SHUTDOWN 0 Attachment 1, Volume 13, Rev. 1, Page 103 of 323 Attachment 1, Volume 13, Rev. .1, Page 104 of 323*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 104 of 323 Attachment 1, Volume 13, Rev. 1, Page 105 of 323 SITS ITS 3.8.2 ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION LCO 3.8.2 138.1.2 As-a minimnim, the following A.C. electrical power sources shall be OPERABLE: a. One qualifiedcircuit between..the offsite transmission network and the:onsiteClass JE A.-C. electrical power distribution systm and b. One diesel:generator Witth:: SR 3.8.2.1 1. Day fuel tank contaiiing'a minimum. volume of 4000 gallons>of fuel,.12.. A fuel storage system containinga minimum volumeof 32,000. galons of fuel, and See3.8.3TS

13. A fuel tPnsfer urn APPLICABILiTY:

MODES'5ýand

6. Durng movement of irradiated fuel assemblies. -it.proposed A-CTIONS Note}O 4 __.__--- Add proposed ACTION A Note proposed Required Action A.1I ACTIONS A With lessthan the above minimum required A.C. electrical power sources.OPERABILE, suspend L01 and B all operations involving CORO ALTERATONS orlpositive reactivity changesluntil .the03iequired AC. electrical powerr sourcesire restored tb.OPl2RA3L

' status..SURVI LAdd proposed Required Actions A.2.3 and B.3 SURVEIILLANcE,.REQUIREMENTS. SR 3.8.21 4;.8.1,2 The above required A.C; electrical power sources shall be demonstrated OPERABLE'by the peffomiance of each of the Surveillai ce Requiremenits of .and 4 .except for requirements .8.1.1, b 4.8.1.2a.55 4.8.1.1.2.a,7,.4.8.1l1.2,c.5; 4,8..1 .2:c.7 and4:8,1.t ,2.d.2ý L.. .. add, proposed SR3821exceptions) L04 DAVIS-BESSE, UNIT 1 3/48-5 Amendment No. 75, 203, 273 0 Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 105 of 323 Attachment 1, Volume 13, Rev. 1, 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 1 E distribution system to be OPERABLE. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite 1 E 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. 1, Page 106 of 323 Attachment 1, Volume 13, Rev. 1, Page 107 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES,- SHUTDOWN 0 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 1 E 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. 1, Page 107 of 323 Attachment 1, Volume 13, Rev. 1, 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 LA0I (Category I -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 0 OPERABLE. This change is acceptable because the Required Actions are used Davis-Besse Page 3 of 7 Attachment 1, Volume 13, Rev. 1, Page 108 of 323 n Attachment 1, Volume 13, Rev. 1, Page 1.09 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 inbperable. 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 reactorvessel 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 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 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. 1, Page 109 of 323 Attachment 1, Volume 13, Rev. 1, Page 110 of 323 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES -SHUTDOWN 0 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. 1, Page 110 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 5--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. 1, Page 111 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 112 of 323 Attachment 1, Volume 13, Rev. 1, Page 113 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 113 of 323 Attachment 1, Volume 13, Rev. 1, Page 114 of 323 CTS AC Sources -:Shutdown 0 3.8 ELECTRICAL POWER SYST EMS 3.8.2 ACC Sources -. Shutdown LCO 3.8.1.2 LCO 3.8.2: The following AAC ,'ele-ctricaI power s'ources:,shall be OPERABLE: pa.: One qualified. circuit.between the ,offsite transmission .n~twork and the .ohsite Class 1 E ACelectidcalpolwer distribution subsystem(s) required by LCO 3.8.10, '"Distribution Systems -Shutdown " and emrgnc on~isleeao"I------t G -One diesel generator ýDG) capable of supplying one train of the onsite Class 1 E AC electrical power distribution subsystem(s) required by LCO 3.8.10.0 0 APPLICABILITY: ACTIONS MODE&5,.a~n~d 6,ýDuring movement.of[r ectly] irradiated fuel assemblies. 0 DOC M03 LCO 3.0.3 is :not applicable. Action CONDITION REQUIRED ACTION COMPLETION TIME*A. One required offsite --------,---NOTE---------- circuit inoperable. Enter applicable Condifions and Required Actions of LCO 3.8.10, with onerequired train de-energized as,,a result of Condition.A.

---

" = --- -- --A.1 Declare affected required Immediately feature(s) with nooffsite power available inoperable.

OR 0 BWOG STS ,3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 114 of 323 Attachment 1, Volume 13, Rev. 1, Page 115 of 323 CTS 0 AC Sources -.Shutdown 38.2 ACTIONS (continued) CONDaITIOmN REQUIRED ACTiON :COPVLETIOQN TIME Action A.2.1l Suspend CORE ALTEE/ATIONS. AND /)STF-47 TST Suspend m6vemrrenrt of J[rec tly] irradiated.f.uel assemblies. AND Immediately 0 VA.2.J Suspend operations involving positive reactivity additions that could result:ii.n loss of required SDM or bdoron cdncentration. Immediately Immediately TST 0 AND.Initiate actionto restore: J required offsite o circuit to OPERABLE status.ýSýTF Action B. One required4OG inoperable.. B.1 AND SUspe $d CORE ALTEf ATIONS'.0 TST-47 TST-47 SB.AND Suspend movement of recty y irradiated fuel assemblies. Immediately, Immediately Suspend operations involving positive reactivity additions that could result in loss of required .SDM or boron concentration. AND BWOG STS 3.8.2-2 Rev. 3.0,, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 115 of 323 Attachment 1, Volume 13, Rev. 1, Page 116 of 323 CTS AC Sources -: Shutdown 3.8.2 0 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Action Initiate action'to restore required to OPERABLE statUs. L-LJ Immediaitely TSTF 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY" 4.8.1.2 SR 3.8.2.1 -.------ .-- --- NOTE ---- ---------- The following SRs are not required to be performed:, S1 R 3.8.1 3, S R 3.8'.1 R 3.8. 1.11, 1,[SRr3 1181. 1 SR 3ý8.1.For AC sources required to be OPERABLE, the,'SRs.of Specification 3.81, "AC Sources.-Operating;!" SR8..6 exceptSR3 3.8.1;iR:3:i .1 :. .1 Fa R 3_d.20 are applicable. In acdordance with .appIlicabis 1@0 BWOG ST&3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 116 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 117 of 323 Attachment 1, Volume 13, Rev. 1, Page 118 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs): Attachment 1, Volume 13, Rev. 1, Page 118 of 323 Attachment 1, Volume 13, Rev. 1, 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 BAC.KGROUNDý A description of the AC sources is provided n~the Bases for LCO 3.81,'AC Souurces -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 b. Sufficient instrumentation and control capability, is available for monitoring and maintaining the. uit statul]and c. Adequate AC electrical power is provided to mitigate~events postulated during shutdown, such as a fuel handling accident,[involving handlingfecently irradiated fuel. Due to radioactive decay,.AC~electrical powet is only required to mitigatefu/l handling accidents involvino handling recently irradiated f el (i.e., fuel that has occupied part of -wcritica 'reaCtorcorewithin the crevious [x]fdays)]. 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 orall 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, 2,3j and 4 have no specific analyses in MODES 5 and 6. Worst-case bounding events are deemed not credible in MODES 5 and 6 becausethe energy contained within the reactor pressure boundary,. reactor coolant temperature and pressure, and the correspondingstresses 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.O BWxG STS B 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 119 of 323 Attachment 1, Volume 13, Rev. 1, Page 120 of 323 AC Sources -Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYS ES (continued) During MODES 1, 2, 3, ,and 4 various deviations from the analysis assumptions and design. requirements areallowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an-,acceptable level of risklisnot exceeded. During MODES'5 and :.6, perftrmance 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.consideratio , b. Requiringappropriate 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 bothI (1 0-c. Prudent utility consideration of the riskassociated with multiple activities thatcouldaffect multiple systemsland [d. Maintaining, to the extent practical, the ability toý perform required functions (even if not meeting MODE 1 ,..2, 3, and 4 OPERABILITY requirements)with systems assumed tofunction during an event.In the event of an accident during shutdoWn,this LCO ensures the capability.to, support systems necessary to avoid immediate difficulty, " assuming either a lossof all.offsite power or a loss of all onsite4Tdiesel generator ýDG) power.:~ satis criten 3 of 10 CFR 50.36(c)(2)(ii). LCO One offSite circuit capable-of supplying the onsite-Class 1 E power distribution subsystem(s) of LCO 3.8.10,"'Distribution Systems -Shutdown;, ensures that all required loads are powered from offsite Spower. An OPERABLE;DG, 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 E of the offsite circuit. Together, OPERABILITY of the required offsite ensures the availability of sufficient AC sources to,.oPerate (the unit in a safe manner and to mitigate the consequences of postulated eventsO during shutdown (eSgT, fuel handling Rccidentsl[invo.vi3.,0ndling3/ FreCently ir .rrated fuel]V.'OBWOG STS B 3'.8.272 Rev. 3.Q, 03/31104 Attachment 1, Volume 13, Rev. 1, Page 120 of 323 Attachment 1, Volume 13, Rev. 1, Page 121 of 323 AC Sources -.Shutdown B33.8.2 BASES LC=O (continued) The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loadsduring an accident, while connected to the.JEngineered Sa eature (ESF us(es).Qualified offsite circuits arethose that ar ribed in the FSAR and-are part of the licensing basis for tbý-[Offsitecircuit

1. 1 co, sists of Safeguards Transformer

-, which is supplied from Switchyard Bu, B, and is fed through breaker 5 -3 powering the ESF transformer X, B01, which, in turn, powersthe 1 ESF bps through its normal feeder b eaker. The second offsite, circuit consists of the ISR 1;Startup Transform r, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the SF transforme r, which, in turn, po ers.the #2 ESF bus through its n rmal.feeder breaker. ]The G must be capable of starting, accelerating to rated:speed and essential (loss of voltage or voltage, and connecting to its respective EFus on detection of bus degraded voltage) undervoltagegr. This sequence must be. accomplished P CMseconds.(shutdown loads d -n ThebDG must becapable of accepting required oads Within thp-asumed are started Iloading s.eguenf intervall, and must continue tozoperate until offsite through individual power can be-restored to th EF buses. These capabilities are required time delay relays) e l to be met.from a :variety of initial conditions such as DG in standby with ULEJ Dthe engine hot and.,lG in standby at ambient Conditions. Proper sequencing-of loads, including tr ipping of non-essential loads, is a (,___required function fortDG OPERABILITY. [In addition,'proper .'equencer operation is an integral part of offsite circuit OPERABILITY'sin e its inoperability impacts on the bility to start and 0 Smaintain ene rgized loads required OPERABLE by CO 3.8.10.]It is acceptable for trains to be cross tied during shutdown conditions,. allowinga 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 recty irradiated fuel assemblies provide assurance that: a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblie 0 0 BWOG STS B 3.8.2-3 Rev. 3.0, ,.03i31104 Attachment 1, Volume 13, Rev. 1, Page 121 of 323 Attachment 1, Volume 13, Rev. 1, Page 122 of 323 B 3.8.2 INSERT I 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.0 Insert Page B 3.8.2-3 Attachment 1, Volume 13, Rev. 1, Page 122 of 323 Attachment 1, Volume 13, Rev. 1, Page 123 of 323 AC Sources -.:Shutdown B 3;8.:2 BASES APPLI-CABILITY (continued)

b. Systems- needed to mitigate a fuel handling accident [involving handling recently i radiated fuel (i.e., fuel th :t has; occupied part of a 0 critical reactor corý within the previous [X] c ays)] are. a elal c. Systems necessary to mitigate the effects of events that can: lead to core damage during shutdown are available and d. Instrumentation and controlcapability:is availablefor 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 38.1.ACTIONS LCO 3.0.3 isý not.applicable while in MODE 5 or 6. However, since irradiated fuelassembly movement can occur in MODE 1, 2,.3, or 4, the ACTIONS have been modified by a Note statingthat 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. An offsite circuit would be considered inoperable if it were not available to one required FE train. A IoI two trains are required by LCO 3.8.10, 4( 3 the one train with offsite power available may be capable of supporting TSTF sufficient'required features to allow continuation of FCORE AL ATIONSI 471 and [ ently irradiated fuel movement'. By the allowance of the option: to (0 declare features inoperable with no offsite *power available, appropriate restrictions will be implemented inaccordance with the affected required features LCO's ACTIONS.BWOG STS B 3.&2-4_ Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 123 of 323 Attachment 1, Volume 13, Rev. 1, Page 124 of 323 AC Sources -Shutdown~B 3.8.2 BAsEs ACTIONS (continued) 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 conservative actions 7is made. With the inoperable, the minimum required diversity of AC power sources is not available. It is, INSERT 2 6 therefore, required to suspend CORE AL3ERATIONS; movement of '247[ irradiated fuel assoembliesmand operations involving positive f-7 0 Ireactivity additions that could result in loss of required SDM (MODE ,5) or boron concentration (MODE 6A Suspending positive reactivity additions, that could result in failure to meet the minimum SDM or boron.concehtration' limit is required toassure continued safe operation. Reictor Introduction of coolant inventory must be from sources that have a. boron on cean concentration greater than that what would, be required ,in the RCSfor 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 moderator temperatu ie changes including temperature increases when. operating with a positive--MTC must also be evaluated to-ensure they do not result in a loss of K.)SrequiredSDM. Suspension of these activities does not'preclude.completion of actions to establish'a safe conservative condition. These actions minimize the probability, orthe 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 necessaryAC 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 modified by a Note to indicate that when ConditionA is entered with no AC power to any requiredTF 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. 1, Page 124 of 323 Attachment 1, Volume 13, Rev. 1, Page 125 of 323 B 3.8.2INSERT 2 specified in LCO 3.1.1, "Shutdown Margin (SDM)," INSERT 3 specified in LCO 3.9.1, "Boron Concentration." 0 Insert Page B 3.8.2-5 Attachment 1, Volume 13, Rev. 1, Page 125 of 323 Attachment 1, Volume 13, Rev. 1, Page 126 of 323 AC Sources -.Shutdown B 3.8'2 BASES SURVEILLANCE REQUIREMENTS. SR 3.8.2.1 SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. ISR 3.8A11,. is not requiredto be met since only one offsite.SafetyFeatures circuit is required.to be OPERABLE. SR 3.8.1 1a -nd SR 3.8.1.a (SFAS) not required to be met because thjE actuation signal is not required to be OPERABLE, JSR 3.8.1.6 is not required to be met be ause the, required OP RABLE DG(s)Ais not' required to undergo prnods of being synchronize to the offsite circuit. SR3,.8.1.9 is ex6ept d because starting ind pendence is not required with the DG(s) tht is not required to be OPE ABLE.0 0-, This SR is modifiedby a Note. The reason for the Note is to preclude requiring the OPERABLE*DG(s) from being paralleled with the-offsite (power network or otherwise rendered"inoperable during performance of SRs, and to: precude deenergizing a required 4160 Eýusor disconnecting a required offsite.,circuit during performance of SRs. With limited AC sources-availabie, :a single event couldcompromise both the required circuit and the4 G. It is the intent that these SRs'must still be (capable of being met, but:actual performance is not required'during [ periods when the0 Gand offsite circuit is required tobe6-OPERABLE. (Refer to the corresponding, Bases for LCO 3.8.1 for a discussion of:each SR.REFERENCES None., D 0 4D BVWO0G STS B 3.8.2-6 Rev. 3.0,, 03131/04 Attachment 1, Volume 13, Rev. 1, Page 126 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Davis-Besse Page 1 of I Attachment 1, Volume 13, Rev. 1, Page 127 of 323 Attachment 1, Volume 13, Rev. 1, Page 128 of 323Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 128 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 129 of 323 Attachment 1, Volume 13, Rev. 1, Page 130 of 323* ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 0 0 Attachment 1, Volume 13, Rev. 1, Page 130 of 323 Attachment 1, Volume 13, Rev. 1, Page 131 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)S 0 Attachment 1, Volume 13, Rev. 1, Page 131 of 323 Attachment 1, Volume 13, Rev. 1, Page 132 of 323 ITS 3.8.3 ITS 3 ELECTRICAL POWER SYSTEMS U/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION Add proposed LCO 3.83 1 ..A002 II LCO3.8.3 3 As minimum, he following A.C. electrical power sources shall be OPERABLEV a. Two qualified circuits between the offsite transmission network and the onsite Class IE A.C. electrical power distribution system, and b. Two separate and independent diesel generators each with: I. A separate day fuel tank contalning~a minimum volume of 4000 gallons of fuel, See ITS es 3.8.1J SR 3.8.3.1 2. A isepiatelfuel storage system containing a minimum volume of 32,000 gallons of fuel, and F3. A searate fuel transfer. urn See ITS APPLICABILITY: IMODES/1, 2 3/and 4. EDG is required to be OPERABLEA02 ACTIO Add proposed ACTIONS A, F, and proposed ACTIONS Notei L8 0 a. With one offsite circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.l.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 atleast two offsite circuits to OPERABLE status within 72 hoursor be In at'least HOT 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 remaining A.C. sources by performing Surveillance Requirement 4.8.1.I.I.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 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 Der 8 hours thereafter and by nerformtna Surveillance I See ITS 1 3.8.1 1 I DAVIS-BESSE, UNIT 1 3/4 8-1 Amendment No. 6, 97, ao3, 206---CAdd proposed ACTIONSB CnD Add proposed ACTIONS C and D Add proposed ýACTION ýE ý0 Page 1 of 4 Attachment 1, Volume 13, Rev. 1, Page 132 of 323 Attachment 1, Volume 13, Rev. 1, Page 133 of 323 ITS 3.8.3 ITS ELECTRICAL POWER SYSTEMS ACTION (Continued) Requirement 4.8.1.I.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 Requi:rement. 4.8.1,E.2.a.4 within'8 hours and at least once per 8 hours thereafter, unless the diesel generators are already operating; restore at least one of the inoperable offslite 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 orbe 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 4.8.1.1.1.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 bein at least HOT STANDBY within the next 6hours 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.See ITS]3.8.1]0 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: a:. Determined OPERABLE at least once per'7 days by verifying correct breaker alignments and indicated power availability, and b. Demonstrated OPERABLE at least once each REFUELING INTERVAL during shutdown by transferring (manually and automatically) unit power supply to each of the offsi.te circuits.See ITS 3.8.1 ]4.8.8.1.2 Each diesel generator shall be demonstrated OPERABLE*SR 3.8.3.1 a. A~t least once er 3.1 dayS, if Surveillance Re uirement 4,8..1,1.2.c A03 has not been performed/within the previous 31 days,j by: DAVIS-BESSE, UNIT 1 3/4 8-2 Amendment No. 97,107,203,206-,219 Page 2 of 4 Attachment 1, Volume 13, Rev. 1, Page 133 of 323 Attachment 1, Volume 13, Rev. 1, Page 134 of 323 ITS 3.8.3 ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. Verifyinq the fuel level in the day fuel tank. See ITS V y f eo3.8.1r 2.- Verifying the fuel level in the fuel storage tank.SR 3.8.3.1 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, loaded to > 1000 kw, and operates for > 60 minutes.6. Verifying the'diesel generator is aligned to provide.standby power to the associated essential busses.7. sVerifying that the automatic load sequence timer is OPERABLE with each load sequence time within +/- 10% of its.required value.See ITS]3.8.1]SR 3.8&3.1 SR 3.8.3.1 1b. At least once per 92 days by verifying that a sample of dieseli fuel from the fuel storage tank is within the acceptable limits SeeITS specified in Table I of ASTM D975-68 when checked for viscosity water and sediment."drpse R38.c. At least once per 114 days by: 11. Verifying the fuel level in the day fuel ta-nk. See ITS" th3.8.1 J 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.kw, and operates for ? 60 minutes.6. Verifying the diesel generator is aligned to provide standby power to the associated essential busses.7. Verifying'that the automatic load sequence timer is OPERABLE with each load sequence time within +/-. 10%of its required value.See ITS 3.8.1 J DAVIS-BESSE, UNIT 3/4 8-3 Amendment No. 5S, 105,203 SAdd proposed SIR 3.8.3.2[Add proposed SIR 3.8.3.4]----..

0 Page 3 of 4 Attachment 1, Volume 13, Rev. 1, Page 134 of 323 Attachment 1, Volume 13, Rev. 1, Page 135 of 323 ITS 3.8.3 ITS ELECTRICAL POWER SYSTEMS c.C."SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE,'

a. One qualified eircui. between the offsite transmission network and the onsite Class IE A:C. electrical power distribution system, and b... One diesel,generator with: I. Day fuel tank containing a minimum volume of 4000 gallons of fuel, See ITS "]3.8.2 J SR 3.8.3.1 2. Ajfuel storage system.coinaining a minimum volum cof 32,000 gallons of fuel, and I A.e transfer p pSee ITS 3. Afueltranfer ump.3.8.2J 0 APPLICABILITY:,MODES 5 and 6.ACTION: With less than the above minimum required AC. electrical power sources OPERABLE, suspend all operations invoivinig CORE ALTi3RATIONS or positive reactivity changesuntil the minimum required A.C. electrical power sources are restored to OPERABLE status.SURVEILLANCE REQUIREMENTS 4,8.L2 The above required A:C. electrical power sources shall~be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8. 1.1.I and 4.8.1.1.2 except for requiremnents 4:8.1.1 .t .b, 4.8.1.1 .2.a.5, 4.&81. 1:2.a.7, 4:8.1 l .2.c.5, .4.8.1.1 .2.c.7, and 4.8.1.1 .2.d.2.r See ITS 3.8.2 )DAVIS-BESSE, UNIT I 3/4 8-5 Amendment No. 75, 203, 273 Page 4 of 4 Attachment 1, Volume 13, Rev. 1, Page 135 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 136 of 323 .Attachment 1, Volume 13, Rev. 1, 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 if the 6 day limit is not met, then the associated EDG is required to be declared inoperable immediately. Furthermore, as stated in the ITS 3.8.3 ACTIONS note, ITS 3.8.3 ACTION B is allowed to be separately entered for each EDG.Therefore, this change is acceptable. This change is considered more restrictive because it adds a new requirement to maintain a 7 day lube oil inventory for each EDG.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. 1, Page 137 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 138 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 139 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 1, Page 140 of 323 Attachment 1, Volume 13, Rev. 1, Page 141 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 13, Rev. 1, Page 141 of 323 Attachment 1, Volume 13, Rev. 1, Page 142 of 323 CTS Diesel Fuel Oil, Lube Oil, andStairting 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, APPLICABILITY: The stored diesel fuel oil, lube oil, and starting air lsubsystem shall be Within limits for~each require diesel generator. G), When associte G is required to be OPERABLE.0 0 ACTIONS Separate w -------------------------------- NOTE-Separate, Condition entryis: allowed for each-DG..DOC L01 DOC L01 0 DOC M01 CONDITION REQUIRED ACTION 'COMPLETION TIME A. One or moreDGs with A.I. Restore fuel oil level'to 48 hours fuel level < [33, 00] gal. within limits: and .> , gal i-32,000 storage-tank. 28 B. One or moreFDGs With lube oil inventory]gal and gal.B.1 RestoreIube oil inventory to within limits..48 hours.0 (D 0 0)0 0)0 0 DOC M02 DOC M02 DOC M03 C. One or more4DGs-ith C.1 Restore fuel oil'total 7 days stored fuel oil total particulates to within limits.particulates, not within limit.D. One or moreDG with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limits.not within limits.E. One moreF ith~starting air receiver miedpressure < psig and I psig._,,[1391 E.1 Restore starting air receiver pressure to [2 5] psig.210 48 hours.0 0 0 BVVOG STS 3.8.3-1 Rev.. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 142 of 323 Attachment 1, Volume 13, Rev. 1, Page 143 of 323 Diesel Fuel Oil, Lube Oil, and.Starting.Air ACTIONS (continued) DOC L01 3.8.1 .b.2 4.8.1.1.2.a.2, 4.8.1.1,2.c.2, 3.8.1.2 DOC M01 DOC A04 DOC M03 CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F..1 Declare associated DG Immediately associated Completion inoperable,. .Time not met.of Conditon A, OR B.,CD, orE One or more'G~swith diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days[_ Ogal of fuel.Sfor each EDGJ SR 3.8,3,2 Verify lube oil inventoris:>1[5 al. 31 days.SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance aretested 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 Verify eac G air start receiver pressure is 31 days 0 0 0 0b 00 DOC M04 SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.M31Rdays 0 BWOG STS 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 143 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 144 of 323 Attachment 1, Volume 13, Rev. 1, Page 145 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs).0 Attachment 1, Volume 13, Rev. 1, Page 145 of 323 Attachment 1, Volume 13, Rev. 1, Page 146 of 323 Diesel Fuel Oil, Lube'Oil, and Starting Air, B 3.8.3 B3,.8 ELECTRICAL POWER SYSTEMS, B 3,.8.3 Diesel, Fuel .Oil, Lube Oil, and Starting ,Air BASES emergency E BgýCKGROUND generator IDG) is provided with Astorage tanl~having a fuel Qil capacity sufficient~to. operate that diesel for a period of 7 days while the j[5-'.DG is supplying maximum post loss of coolant accident load demand discussed in.thetFSAR, Section 2f(Ref. 1). The maximum load-ýdenmand:is calculated Using the assumption thatat least two+DGs are available.. This onsite fuel oilcapacity is sufficient to operatethe+DGs for longer than the time to, replenish .the onsite supply from outside sources."-the a submersed (ii~d~Th Fuel oil is transferred fromstoragge tank to daytank, by eithe .t two L--I- I S transferpum associ wit each storage tank. IRo dundancy of Each storage tank pumps andpiping pre udes the failure of one pump,jor the rupture of any is installed above pipe, valve or tank to r suit in theloss of moreithan One DG. AIloutside grade elevation. ý tanks, pumps, and plpncI are located undercaround.[ iD D D r3 While Davis-Besse is ] For proper operation of the standbyýDGs, iS necessaryto ensure'the not committed to this o Regulatory Guide, proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level.The G lubrication system is designed to provide sufficient lubrication to permit proper operation of its associatedbDG 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 byfriction during D- operation. Each engine oil sump~contains-an inventory capable of supporting a minimum ofJcdays of operation. [,I he onsite storage in/addition to the engine oil sump is sufficient to ensure 7 days, of continuous joperation.] 1ihis supply issufficientto

aiiow theoperator to repienish lube oil from outside sources. two air start receivers per subsystem,: and each air start receiver has Each DG has an air start system withradequate.capacity for five successive startattempts.6n the DG without recharging the~air start receiverj.

17q (0 0 BWOG STS B 3.8.3-1 Rev. 3.0, 03/31104 Attachment 1, Volume 13, Rev. 1,'Page 146 of 323 Attachment 1, Volume 13, Rev. 1, Page 147 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES FSe.tio.nl FSe-ction APPLICABLE The initial conditions of Design Basis Accident (DBAj) and transient. SAFETY' arialyses' in the FSAR, I Ia er (Ref..4)and or ER(Ref. 5), ANALYSES Elassume Engineered Safety Feature(ESF):systems are:OPERABLE. The ,-,ýDGs .are designed to provide sufficient capacity, capability, redundancy, L~J a nzd reliability to ensure the availability of necessary power to ESF systeyms. so% that fuel,. Reactor Coolant System, and containment:design limits are notexceeded. These limits::are discussed in more detail in the.Bases forSection 3.2, Power Distribution Limits; Section 3.4, Reactor:CoolantSystemr (1R C); Sand.Section 3.6, Containment Systems.Since diesel fuel. oil, lube ýoil,, and the air start subsystem support the::operation f~the Standby AC power'sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii}. 00 0 LCO Stored diesel fuel oil is required to have sufficient supply for 7 days-of full load operation. It is al.so required to ýmeet specific standards for quality.Additionally, .sufficient lubeaoiltsupply must be available to ehsure the:capability to operate at full load for7 days. This requirement, in conjunction with an abilityto obtain replacement supplies: within 7 days, supports the availability-of+DGs required to shut down the react6r and to 0 maintain it in a safe condition for an anticipated operational occurrence E (AOO) or a postulated DBA with loss of offsite power. ,DG day tank fuel K)requirements, as wellas transfer capability from the storage tank to the day. tank, are addressed in LCO 3.8.1, "Ac Sources -Operating," and LCO 3.8.2, "AC Sources -Shutdown." E sub Thus, only one of the two air start receivers for each EDG is required to be OPERABLE.-The starting ai 'ystem is required to have a minimumcapacity for five 1 su7 v7 startattempts without recharging the air'start receivers. K) (2 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 n'a. safe shutdoWn condition after an. AOO or a postulated DBA. Since stored diesel fuel.il, lube oil, and the starting air subsystem support LCO 3.8.t1 and LCO;3.8.2, stored diesel fuel oil, lube oil, andstarting air are required to be within'limits when the associatedtDG is required to be OPERABLE. IK.)ACTIONS The ACTIONS Table is modified by a Note indicating that separate [ (7F Condition entry is allowed for eachi4DG. This is acceptable since the L-i Required Actions for each Condition provide appropriate compensatory E actions for each inoperableCDG subsystem. Complying with the Required Actions for one inoperable )G subsystem may allow for continued operation,.and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.BWVOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 147 of 323 Attachment 1, Volume 13, Rev. 1, Page 148 of 323 Diesel Fuel Oil, Lube.Oil, and Starting Air B 3.8.3 BASES*ACTIONS (continued) A.1 D t Int this Condition, the 7 day fuel oil supply for aIDGis not available. 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 hecessitated by increasing particulate.levels:or, any number of otheroil quality degradations.. This restriction allows sufficient time for obtaining the requisite replacement volume and performing.the analyses required prior toiaddition of fuel oil to:the tank. A period of 48 hours is considered sficient to complete restoration:of the required level prior to declaring 0 M- 4DG inoperable. This period is acceptable based on the remaining capacit-y] 6idays), the fact that procedures will be: initiated to obtain rep enis ment, and the1 ow:probability of an event during this brief period.B.1 E With lubeoil'inventory-5 0gal, sufficient lube oil to support 7 days of 3 continuous DG operation at full load conditions may. not be:available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply.. This:restrictioh allows sufficient time to obtain the requisite replacement volume, A periodzof 48 hours is FF considered sufficient to complete restoration of the required volume prior:to. eclaring t DG inoperable, This period is accePtable based on the remaining icapacity,9 6 days), the low rate of usage, thefact that D- procedures:will e initiated to obtain replenishment, and the low probability of an event during this brief period.This Condition is entered as a result of a failure to meet the acceptance criterion 'of SR 3.8.3.. Normally, trending of particulate levels allows 0 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 p/roduce failuresthat do: not follow a trend. Since the presence of BWOG STS B 3.8.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 148 of 323 Attachment 1, Volume 13,-Rev. 1, Page 149 of 323 Diesel Fuel Oil, Lube:.Oil, and Starting Air B 3.8.3 BASES ACTIONS :(continued) particulates does not mean fallure of the fuel oil to burn properly in~the diesel engine, particdulate concentration is unlikely to: change significantly between Surveillan6e Frequency intervals, and proper engine performance has been recently demonstrated (within 31. days),jt'is prudent to allow a brief period prior to declaring the associated DG E 0 inoperable. The 7 day Completion Time allows for-further evaluation, resampling, and re-aalsi fue oIl lthat are not required tobeobtained prior to addition of the new fuel oil to the storage tanks are D. 1 nwfe n-Atest results for the 3 Wh the new fuel oil properties definedin'the Bases for SR 3. not 00 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 oi~lproperties. This restoration may involve feed and ble'ed procedures, (T filtering,, orcombinatidns of these procedures. Even if a DG startand KJ 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 in the required air start receiver With startihg air receiver pressure. psig 4 ,,sufficient capacity forfive.CE successive OG start aftempts does not exist. However, as long~as the recesive r pressure i psig,.there is adequate capacityfor at least 19 one start and can be considered OPERABLE while the ,air receiver pressure is restored to the required limit. A perio.d of48 hours.is considered sufficient to complete restoration to the required pressure E prior to declaring the+DG inoperable. This:period is acceptable based on the remaining air start capacity, the fact that most G starts are accomplished on the first attempt, and the low probability of an event during this brief period.F.1 With a Required Action and associated Completion Time not met, or one or more. Gs with fuel oil, lube oil, or starting air subsystem notwithin limits for reasons other than addressed by Conditions A through E, the associated G may be incapableof performing its intended function and must be immediately declared inoperable. O BWOG STS B 3.8.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 149 of 323 Attachment 1, Volume 13, Rev. 1, Page 150 of 323 Diesel Fuel Oil', Lube Oil, and Starting Air O ~B 3.8.31 BASES SURVEILLANCE SR 3.8.3:.1 REQUIREMENTS redit forthe This SR provides verification that.there is an adequate inventory of fuel oil minimum required a:in the storage tanks to support eachlDG's operation for 7 days'at fullo lad.level in the -The 7 day period is sufficient time to place the unit in a safe shutdown, associated day tank (4000 condition and to0.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, sincel ow level alarms are provided and unit operators EDG operation. would'be aware of any large uses of fuel oil durihg this period.SR 3.8.3.2 This Surveillance'ensuroes that sUfficient lube oil inventory is available to suppoftat least 7 days of full load operation for eacltDO. The [5 )0al requirement is based on thetDG manufacturer consurmption Values for the run time of the+DG, Implicit in this SR is the requirement to verify the aabilitYto transfer the lube :oil from its storage location to the G, 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 isadequate to ensure that a sufficient lubeoil supply is onsite, since DG starts and run time are closely monitoredby the unit C)staff. L SR 3.8.3.3 The tests listed be!ow 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.imnpact 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 tothe storage:tank(s), but in no case isthe 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 D4057-2 C)(Ref. 6)TS ' 3'.O BV\OG STS 'B 3.8.3-5 ,Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 150 of.323 Attachment 1, Volume 13, Rev. 1, Page 151 of 323 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8'3, BASES SURVEILLANCE REQUIREMENTS (continued) " b. Verify in accordance. with the tests specified in ASTM 0 0.825 R 6) that the., sample has an a.bsolute specific gravity !at60/60° F of n0.876 anq1gg or an API.gravity at.60*F of,ý -and <5 M`when 30-tested in accordance with ASTM D1295-j (Ref., 6), a kinemratic 40 LIi-j viscosity at 40*C -of&Z 1 .9 centistokes 'and,-- 4.1 centistokes",land a flash point.of> 125*F and.c, Verify that the new fuel oil has a clear and bright appearance with 86--E proper color when tested in accordance with ASTM D4176 [ Ior a water and sediment content Within limits-when tested in accordance with-STM D0 9[ ]] (Ref. 6). 75)Failure to-meet anyof the above imits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage, tanks.Within 31 days followingthe initial. new fuel oil sample, the fuel oil is 0 analyzed to establish that the other properties specified in Table- 1 of ASTM D97 [ ] (Ref. 7) are met for new fuel oil-when tested in accordance with [A D97 (Ref. 6), except that the analysis for ,sulfur may beý performed in accordance-with ýASTM jJt5527[ ], j[bý[ SM 0 T-[ 1, 0orI AS.TM D4294.7-] (R.ef, 6). The. 31 day period isýacceptable because. the fuel oil properties of interest, even ifthey were not within stated limits, would not have an immediate effect onibG [operation. This Surveillance ensures"the availability of high quality fuel oil for th DGs.E Fuel oil degradation during long term storageshows up as an increase inýparticulate, due- mostly to oxidation., The presence of particulate does not mean the-fuel oil will not burn properly in a dieselengine. The particulate can cause fouling of filters and -fuel oil injection equipment, however,.which can:cause, engine failure.0 0 0 0 0D Particulate concentrations should be determined in accordance with ASTM ](Ref.:6). This method iv a gravimetric The eterm tion o total particulate concentration in the fuel oil 0 has a li mit of 10Q mg~l. I i -to obt.a~in a. field s*.nple for subseque-nt]I Llaboratory testing ing2U of field testing .[or those dl signs in which teI total stored ruel oil v is contained in~tw0 or mo e: in!terconnete tanks, each tank rrst be considered and tested se/ aratjely.] 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. 00 70 BWJG STS B 3.8.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 151 of 323 Attachment 1, Volume 13, Rev. 1, Page 152 of 323 Diesel Fuel Oil, Lube Oil, and Startirig Air B 3.8.3 BASES SSU RVEILLANCE REQUIREMENTS (continued) SR 3.8.3.4 This Surveillance ensures that, without the.aid df the refill compressor, sufficientlair startcapacity for each+DG is available. The system design Ifor each air start receiver} requirements. rovide for a minimum of [Dfivef enginedstart cycles without recharging. start ycle: is defined by the DGyverdor, but usually is0.measured in illrms pt time, (seconds 0f cranking):ýr engineicranking speed.]I The pressure specified in this SR is intended to reflect the lowest value at which the jivd[ starts can be accomplished. I using only one of the two air start receivers for each EDG ----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 every31M]days eliminates the necessary environment for bacterial survival. This is-the mosteffective means of controlling microbiological fouling. In addition, iteliminates the potential for water entrainment in the fuel oil duringDG. ope~ration. 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 remeoValIof aIcumulated 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. O BVOG STS B 3.8.3-7 Rev. 3.0 03/31/104 Attachment 1, Volume 13, Rev. 1, Page 152 of 323 Attachment 1, Volume 13, Rev. 1, Page 153 of 323 Diesel Fuel Oil, Lube. Oil, and StartingAir B 3.8.3 BASES REFERENCES 1 FSAR, Section [9 2 ( 0 0 2. Regulatory Guide 1.13.7.3. ANSI N195-1976, Appendix B, 4. FSAR, Cha er 61.U Section 5. FSAR, Cha er [51Jq1 U1 06~f 85 --86ý6. ASTMStandards: D4057-0Jjl; D975 ;D1298 D4176-];J[D27 -[ 111131 f-[ TD-26,2--[ ]ID4294-i; 545-08 90 2276-88 7. ASTM Standards, D975 1t I,7.bo,1 00 00@0 BV\OG STS B 3.8.3-8 Rev. 30, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 153 of 323 Attachment 1, Volume 13, Rev. 1, 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 5.1.3.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 154 of 323 Attachment 1, Volume 13, Rev. 1, Page 155 of 323 Specific No Significant Hazards Considerations (NSHCs)S 0 Attachment.

1, Volume 13, Rev. 1, Page 155 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of I Attachment 1, Volume 13, Rev.l, Page 156 of 323 Attachment 1, Volume 13, Rev. 1, Page 157 of 323 p ATTACHMENT 4 ITS 3.8.4, DC SOURCES -OPERATING 0 0 Attachment 1, Volume 13, Rev. 1, Page 157 of 323 Attachment 1, Volume 13, Rev. 1, Page 158 of 323* Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 13, Rev. 1, Page 158 of 323 Attachment 1, Volume 13, Rev. 1, Page 159 of 323 ITS 3.8.4 ITS ELECTRICAL POWER SYSTEMS'D.C. DISTRIBUTION.- OPERATING[ electrica pwer sources }LA01 LIMITING CONDITION FOR OPERATION See ITS a i i~ ;,~iLa...Ini' ~ ~ .Ltl I,. ...l fnrD~y~'3.8.9J LCO 3.8.4 L~+/-+/-+/-~AJ~fla La!1 9M+/- e~ anC 5 LC GI UFEWLVEl Iwith disconnect -switches 'between bus trains opeil: See ITS~3.8.9 j(TAN "A".Fconsisting. of 250/125-volt.D.C. MCCI, ,25-vol D.C.Istation batteries ir/and IN and2fl aaiyCrer] See ITS 1-, 3.8.9 TRAIN"B". consisting of 250/125-volt D.C, MCC 2, 125-vol D.C .lstation batte-ries 2P/and 2N. and 2 full capacity c-rr-APPLICABILITY,: MODES 1, 2,;:3 and 4.,ACTION: ACTION A, ACTION B ACTION C a1. 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 See ITS hours or be. in at, lea'st HOT STANDBY. within the next 6 hours and 3,8.9 9 in, COLD SHUTDOWN within 'the following 30 hours.b. FWi'th 125-volt D.C. battery or ýnly one char er of one fCC OPERABLE, restore the ionoerable battery or charger to OPERABLE status' within 2ore in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 0 hours.SURVEILLANCE REOUIREMENTS 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 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.See ITS5 3.8.9 4.8.2.3.2 Each 125-volt 'battery and charger shall be 'demonstrated OPERABLE: a. At least once per 7 days by: 1. Verifying that the parameters in Table 4.8-.I meet the 3. .6 1 Category A limits, and 3.8 DAVIS-BESSE, UNIT I 3/4 8-8 Amendment No. 100 Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 159 of 323 Attachment 1, Volume 13, Rev. 1, Page 160 of 323 ITS 3.8.4 ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) SR 3.84.1 2. Verifying total battery terminal voltage is greater than .or equal to[ joltS on float charge. k An..., ..esa s a oa age b. At least once per 92 days and within 7.days (battery terminal voltage below 110 volts), (battery terminal voltage above 150 Volts),.after a battery discharge or battery overcharge by-: I 1. Verifying that the parameters in Table 4.8-1 meetrthe Category B limits, 2. Verifying that there is no visible corrosion at either terminals or connettors, or the connection resistance of these items is less than ,150 X 10-60 hms, and.3. Verifying that the average. electrolytet:emperature of every sixth connected cell is above 60'F1.See ITS 1 3,8.6 ]SR3.8.4.2

c. At least once pert 18 months by verifying'supply at least 475 amperes at a: minimum hours; land.. at least once each REFUELING.

INTERVAL by verifying that: 1. The cells, cell plates and battery racks show no visual indication of physical. damage or abnormal deterioration, 2. The cell-to-cell and terminal connections are clean, tight and coated with anti-corrosion material, and 3. The resistance of each cell-to-cell and'terminal connection is less than or eoual to 150x 1106 ohms.See ITS 3.8.6 I SR 3.8.4.3 d.At least once each REFUELING INTERVAL, durin shutdown by verifying that the battery capacity is adequate to supp y and maintain in OPERABLE statusall of the actual or simulated emergency loads for the design Smedattryissubiected to a battery service test.lodpr6 htsramodifi~ed performance discharge test may be performed .n 'lieu of the battery serv~ice test..006 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, during shutdown, when the battery shows no signs of degradation, and has not reached 85% of service life.2. At least once per 12 months, during shutdown, when the battery shows 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.See ITS 3.8,6 ]DAVIS-BESSE, UNIT 1 3/4 8-9 Amendment No. 4-OO-2 1 9-, 2 2 9 0Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 160 of 323 Attachment 1, Volume 13, Rev. 1, 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 IN 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 I -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. 1, Page 161 of 323 Attachment 1, Volume 13, Rev. 1, 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. Furthermore, the voltage limit is being changed from 129 V to 130.2 V to ensure the float voltage is maintained greater than or equal to the minimum established design limits provided by the manufacturer. 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 72 hours. 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 72 hour 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.I. The second* tiered action proposes 12 hours to establish that the battery has sufficient Davis-Besse Page 2 of 5 Attachment 1, Volume 13, Rev. 1, Page 162 of 323 Attachment 1, Volume 13, Rev. 1, Page 163 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES -OPERATING capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12 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 (Category 6,- 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 Davis-Besse Page 3 of 5 Attachment 1, Volume 13, Rev. 1,,Page 163 of 323 Attachment 1, Volume 13, Rev. 1, Page 164 of 323 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES -OPERATING functions. This changes the CTS by deleting the actual voltage limit and replaces it with the minimum established float voltage limit. This change is 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.T 'his 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 ba *ttery 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 Surei.ellance 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. 1, Page 164 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 1, Page 165 of 323 Attachment 1, Volume 13, Rev. 1, Page 166.of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 166 of 323 Attachment 1, Volume 13, Rev. 1, Page 167 of 323 CTS DC Sources- Operating 3.8A4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources -Operating LCO 3.8.2.3 LCO 3.8.4 APPLICABILITY: ACTIONS The Train I-and Train DC electrical power m suby, 8eshall be OPERABLE.MODES 1,2, 3, and 4.00 CONDITION REQUIRED ACTION ,COMPLETION TIME Action b-required A. .Oneortw attery chargerb on oneý traira inoperable. AK Restore .battery terminal voltage to.greater than or equal to..the minimum established'float voltage.:2. hours IOnce. perM1 2M hours 00 0D AND A.2 Verify battery float current_< "aramps.AND A.3 required C- M(S)Restor battery charge&r to OPERABLE status.7,sours[ B. One [or two] batter[y ies B.1 Restore batter[y][ies] to [2] hours on one train] inoper ble. OPERABLE status.0 Action b Action b V_. One DC electrical power a su s minoperable source forreasons .other than Condition [B Restore. DC electrical power e 0 OPERABLE. status. sourc Dg hours 00 0 0 4 ReqUired Action and Associated Completion Time not met.AND e in MODE 3.6-hours 36 hours 0 0 V2_Be in MODE 5.BWOG STS 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 167 of 323 Attachment 1, Volume 13, Rev. 1, Page 168 of 323 CTS DC Sources -Operating 3.8.4 SURVEILLANCE REOUIREMENTS SURVEILLANCE FREQUENCY i 4.8.2.3.2a.2 -SR 358.4.4.8.2.3.2.c .SR 3.8A..4.8.2.3.2.d SR 3.8.4..1 Verify battery terminal voltage is greater than .or equal to. the minimum established float, voltage.7 days 2 Verify each ,battery charger supplies _> ms at greater than~or equal to the minimum established float voltage, for_ [ hours.OR Verify eacl battery charger can recharge the battery to the fully charged state within[ ours whi'e.supplying the -largest combined demands of the various continuous steadystate loads, after a battery discharge to the bounding design basis event discharge state, I 1!8M months 00 0:--------- 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 be performed in MODE 1-2, 3, or 4. owever, portionsof th Surveillance may be performed to reestablis OPERABILITY pr vided an assessment determines the saf ty of the plant is maintaine or enhanced. Credit may be taken for unplanned events that satisfy this SR.Verify battery capacity is adequate to supply,, and maintain: in OPERABLE status.,, the required emergency loads for the design duty cycle when: subjected to.a battery: service test. Factual or simulated 00 0 0[ 1 ] mhonths0 BWOG STS 3.8.4-2 Rev. 3.0,.03/31/04 Attachment 1, Volume 13, Rev. 1, Page 168 of 323 Attachment 1, Volume 13, Rev. 1, 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.9. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 7.2 hours. This change is consistent with an NRC request documented in NRC question 200711161150 (in the Davis-Besse RAI database). This change is consistent with proposed TSTF-500.Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 169 of 323 Attachment 1, Volume 13, Rev. 1, Page 170 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 13, Rev. 1, Page 170 of 323 Attachment 1, Volume 13, Rev. 1, Page 171 of 323 DC Sources- Operating B 3.8.4 B3.8 ELECTRICAL POWER SYSTEMS B3.8.4 DC Sources- Operating BASES BACKGROU ND The station-DC electrical power, system provides the AC emergency power system with control power. Italso provides both motive and control powertoselected safety related equipment and.preferred AC:vital bus power,(Viajinverters). As required by 10 CFR 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!EEIE-308 (Ref :.3).sources 8 and redundant isafety related Class 1 E DC :electrical powersu s ems rain and Each su s e.mconsists~ofltw 125VDC source a eres[(each batterj' ocapacty e faterycharge for each battery, and all the associated control equipment an one 8 in~terconnecting cabling.[FThe 250 VDC~source is obtained by use of the two 125 VDCbatteries one connejted in series._ Additionally there is oneI spare battery charger per the two,which provides backup service in the event that t e referred battery charge is out of service. If the spare battery charger is e two&] substituted forone Of[ýýreferred battery chargers, then'the requirements of independence and redundancy between sare maaintaine.d. J]souces8 )During normal operation, the e M1 25/25CMVDC load is powered fromm the 0 batterychargers with the batteries floating on the system.. In case of loss ,of normal power to the battery charger, the DCload is automatically powered from the station batteries. s ,-re, The T[radnd Train.IDC electrical power s provide the control power for its associated Class 1 E.AC. power load group'[D4.16WkV switchgear, and[J480MV.:oad centers: The DC electrical power sources subsems also0 provide DC electrical powerto the inverters, which in ]turn power theACvital buses.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." 0 0 BWOG STS B 3.8.4-1 Rev. 3.0, .03/31/04 Attachment 1, Volume 13, Rev. 1, Page 171 of 323 Attachment 1, Volume 13, Rev. 1, Page 172 of 323 DC Sources -Operating B 3.8.4.BASES BACKGROU N.D (continued) Each 25/250 VDC batte. is separately:housed in a ventilated r0 "M apartfrom its charger and distribution centers,. Each subs -emis located in an area separated physically and electrically ftomr the Other source Iemto ensure.that a singlefailure in one substem]does not, 8 cause -a failure-in:-a redundant.subs"tem-There is :no.sharing between EE redundant ClasslE subs ems, such-as batteries, battery chargers, or distribution panels.. L " " s, u Each battery has adequate storage capacity to-meet the duty cycle(s)discussed in the FSAR6 Ch te ,(Ref 4). Theý battery is designed with 00 additional capacity above-that required by the design duty cycle to allow for temperature variations and other factors". .(k The batteries for TrainNand Tri DC electrical .power.[sustems pre sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%Adesign demand. Th.e.minimum design voltage limit is I0M 2V.The battery cells are of flooded lead acid construction with a nominal specific gravity of This specific gravity corrsponds to.an open, circuit, battery .vo a e o approximately 120 V-for a [18] cell battery (i.e., ,cell voltage of [2.0 r 5] volts per cell (Vpc)). The op n circuit voltage is the voltage maintaine when there is no charging or di dcharging. Once fully charged with its o en circuit voltage [2.065] Vpc, the battery cell will maintain its capa ity for [30] days without further-c arqinq per Lmanufacturer's i structions. Optimal-lng term perforiance how er; is-obtained by maintaining a float voltage MP'to.2.25MVpc. This provides (.'adequate over-potential,which-lirmits the formation of lead sulfate and self*discharge. IThe nominal' float voltage of [2.22]-Vp_; qorýresponds, to a total float-volt~age otput of/ [128.81 V for-a [58],cell battffiry at disc~ussed ini.th, .SFSAR, Chapter [8] ( 6ef. 4). " Each and Tranj D.C electrical " charg 0 has ample power outputpcapacity for the steady state operation of: connected loads required-during normal operation, while, at the 'same time maintaining its battery bank fully charged. Each batterycharger also-has sUfficient excess capacity to restorethe battery from the designminimum Shg to its fully charged state withii hours while supplying normal steady state loads discussed inthe SAR, er J'(Ref. 4).BVVOG STS, B 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 172 of 323 Attachment 1, Volume 13, Rev. 1, Page 173 of 323 DC 'Sources -Operating B 3.8.41 BASES.BACKGROUND (continued) The ba~ttery, charger is. normally in thefloat-charge mode., Float-charge is the condition in which the.chargerjis supplying the, connected loads and.the batterycells are receiving .adequate currient ito optimhally charge the: batte.ry. This assures thejinternal losses of a .battery areovprcome and the' battery is,maintained in aeful ly-charged state,.When-desire.d, 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 rechargel:characteristic accepts current at the current limK of the, battery:,charger z(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',redhargecycle. Lead-:calcium batteries have echarge efficiencies of greater than"95%, so once~~ai at least 1.05% of the ýampere--hours discharged have been returned, the.battery-dapacity would be restored to the samer 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.DesignBasis Accident (DBA and.trafnsient SAFETY analyses in the FSAR Ca er [ '(Ref. .5) and a er (Ref. 6), (J ANALYSES assume that Engineered Safety Feature(ESF) systems are OPERABLE.The DC electrical power'system provides normal and emergency DC LJ (J electrical power for the+DGs, emergency auxiliaries, and control and L *IJ switching during all MODES ofope6ration. The OPERABILITY'of the DC: sources isconsistent 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 powe and b. A worst-ca.se'single failure.0 The DC ýources satisf ron:3of 10"CFR'5036(c)(2)(ii).(BWOG STS B 3.8.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 173 of 323 Attachment 1, Volume 13, Rev. 1, Page 174 of 323 DC.Sources -Operating B 3.814 BASES I ores TrEin:ndran2 LcO The DC electrical power .boeachqnsistingof MtwoM 8 batteriesý,battery charger #or.each batterb and the.correspohding control 0 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, condition after an anticipated operational occurrence (AOO)or a lpostulated DBA. Loss of any train DC ele6ctrical power subsldadoes not prevent the minimum safety function from being performed (Ref. 4)'.e oursýAn OPERABLE gDC electrical, power subsstem requires r i redbatteries andresptiv chargerjto beoperatingand connected.to the associated DC bus(es). L4-......)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 asia: result of AQOs or abnormal transients and Lo 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 powe0rerementsk for MODES :5and 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 .or twdattery chargers inoperable e.g., evog limit of SR3.4.1 is Yo maintaine. The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a, reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum establishedfloatvoltage 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 11 hours, the battery will be restored to its fullycharged condition (Require .Action A.2):from any -discharge thatmight have occurred due to the .charger ihoperability. 0 0 00 0)0 BVWOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 174 of 323 Attachment 1, Volume 13, Rev. 1, Page 175 of 323 DC 'Sources -Operating B 3.8.4 BASES ACTIONS (coniinued) -"___w;--- --REVIEWER'S NOTE,--ý---- A plant that cannot et the 12 hour Completion Time ue to an inherent batteryýchaiging cha acteristic:6ah: proposean alternat time equal'to.21 hours plus the tir. experienced to accomplish.the e, ponentialcharging current portion 0of th battery charge ýprofile following th service test.(SR 3.8..3).(S .38A 3 ....... ..... ...... ... ........................--

---

Adischarged battery having terminal voltage of at least the minimum established float voltage indicatesthat the battery is on the exponential charging -current portion (thesecond 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.anmount of the previousdischarge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 2 hours, avoiding a premature. shutdown with its own attendant risk.If established batteryterrminal 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 chargerthat 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 necessaryduring-the recoveryperiod 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 isan indicationthat the battery is partially discharged and itscapacity margins will be reduced. The time to return the, battery to its fullycharged condition in this case is a function0of 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 cha'rge time.can be extensive, and there is not adequate assurance that it can be recharged within M1U2.M hours .(Required Action A2.2).Required Action A.2 requires that the battery float current be verified as less than or.equal to0M42amps. This indicates that, if the battery had been (9 discharged as the result of the inoperable, battery charger, ithas now been fully recharged.. If at the expiration of the initial M1 2ffJ hour period the battery floatcurrent is not lessthan or'equal to 2 amps this indicates I .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. 1, Page 175 of 323 Attachment 1, Volume 13, Rev. 1, Page 176 of 323 DC Sources-- Operating B 3.8.4 BASES ACTIONS (continued) 7 Required Action A.3 limits the restoration time for the inoperabI battery chargertdo7

s. This'action:

isapplicable if an alternate means of0 restoring battery terminal voltage to greater than or equal to the minimum, use of an inoperable, but functional Class l1 established float voltage has, been used (e.g., balance of plant non-Class battery charger 1 E battery charge). The[ 6ompletion Time reflects a reasonable hour time to effect res oration:of the qualified battery charger to OPERABLE status.0 B.1----------------

• .I EVIEWER'S NOTE --------------

The 2 hour Completion Tin es of Required Actions B.1 and C.1 are in brackets. Any licenseewi hingto requesta longer Compl tion Time will need to demonstrate that he longer Completion Tiime is a propriate for the plant in accordance w h the guidance in RegulatoryG ide (RG),1.177, ',An Approach for lant-Specific,. Risk-,Informed De isionmaking: Technical Specifications.

---

'" -'t -----" -- --- ------ -;:--- ":-'- ; ---- '; .-i --- --." ------- -n----.- --.---- -.- 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 P.ERABLE battery charger[s]. A y event that results in a loss of the *C bus supportingthe battery ch rger[s] will also result in 1lss of DC to at train. Recovery of the AC bu , especially if it is due to a loss of 6ffsite spower, will be hampered by the f ct that many ofýthe components: nece sary forthe recovery (e.g., diesel generator control and field flash, AC.Io 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 esss than [2.07] V, etc.) are identifi d in;Specifications 3.8.4, 3.8.5, and 3 .6 together withadditio na specifi Completion Times.0 0 BWOG STS B 3.8.4-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 176 of 323 Attachment 1, Volume 13, Rev. 1, Page 177 of 323 DC Sources' -Operating B 3.8.4 BASES, ACTIONS (cointinued) Condition ] sents. one train with a,1lss of abilityto completely respond to an event, and a potential lossý,f .a remain'energized during normal operation. It is therefore, imperative that the. operator's

attention focus on stabilizing the unit, minimizingthe potential for complete loss of DC power to the affectedtrain.

The 2 hour limit-is consistent with the allowed time for a'n inoperable DC distribution system train.0 0 Dsoures If one of the required DC electrical power sub s em is inoperable for one or both reasons other than Condition AF (e.g., linoperable ba ar er, an batteries in a associated in le battery ,the remaining DC.electrical power train inoperable subsystem has the capacity tolsupport a safe shutdown and to mitigate an accident condition. Since a subsequent

worst case single failure could, however, result in the loss of minimum necessary DC electrical srS subsy_'ems to mitigate a worst case. accident, cont.inued 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 Lsubsem f sor and, if the DC electrical power subs yster is not restored to OPERABLE /)status, to prepare to effect an orderly andWsafe unit shutdown.Mu.1 and c.2 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 MODEIn which the LCO does not apply. To achievethis status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5vwithin 36hours. The allowed Completion Times are reasonable, based on operating experience; to reach therequired 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).0 0 BWOG STS B 3.84-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 177 of 323 Attachment 1, Volume 13, Rev. 1, Page 178 of 323 DC:Sources.- Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifyingbattery terminal voltage while on float charge helps to ensure the effectiveness of the battery'chargers, which support the ability of the batteries to perform theirintended 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 full charged state while supplying the continuous:steady state loads of the associated DC subs tem. On float charge, battery cells will receive adequate current:t6loptimally 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 2.201 Vpr[1276 at the batteryterminals). This 1 0 voltage maintains the.: battery platesý in a condition thatsupports, maintaining thegrid life (expected:to be approximately 20 years). The 7 day Frequency is consistent with ma.nufacturer recomr...ndations and IEEE-450 (Ref. .8).SR 3.8.4.2 This SR verifies thesign capacity of the aitery chargers. According to 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 thezcharging 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 eachbattery [ charger be capable of supplyin[ amps at the minimum established float voltage for Pq hours. The ampere requirements are bas on he (D Q output rating of the chargers. The voltage requirements are base.d on the alsowell wthin charger voltage level after a response to a loss of AC power. The time Ipero sufficient for the charger temperature to have stabilizedand to ,.have been maintained for at eastMhours.(The other option requires that eachbatte Farger be capable of r'echarging the battery after a .service test coincident with supplying the-largesLtcoin J.iet demands of the various continuous.steady state loads 451T (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 O BWOG STS B 3.8.4-8 Rev. 3.0, 03/31/04 Attachment 1 , Volume 13, Rev. 1, Page 178 of 323 Attachment 1, Volume 13, Rev. 1, Page 179 of 323 DC Sources -Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (ciontinued)-loads. The duration for this test may be longer than the charger sizing.c.riteria, since the battery recharge is affected by float vboltage, temperature, and the exponentialdecay in charging current. The battery is recharged when the measured charging current is. .-42Mamps. 0 The Surveillance Frequency is acceptable, given the unit conditions.required to perform the test and the other administrative controls existing to ensure adequate: charger performance during these [18. month] 0 intervals. In addition, this Frequency is. intended to Je consistent withl Fe-xpected fuel cyci6 len~gths:I SR 3.8.4.3 A battery service testis 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 .correspondto the design duty cycle requirements as.specified in Reference 4.The Surveillance Frequency of monthsRJ is consistent with the 0 recommendations of Regulatory, Guide 1.32 (Ref. 9) and Regulatory Guide 1.129:(Ref. 10), which state that the battery service 'test should be I ure'ntis Lprormed during refueling operations,/or ýatsomýe ott'eroutage.,,with at ],intervals b en tests not to exceedl M h.. (This SR is modified by two: Notes. Note 1 allows the performance.of a modified performance discharge testin lieu of a service test.The reasonfor Note 2 is that performing the Surveillance would. perturb the electrical distribution.system and challenge safety systems. FThis restriction from! norm~Illy performing. the Surveillancq tin MODE 1 or 2 is further amplified to allow portions of the Surveillanc to be: performed for..the purpose Of ree-stblshing ,OPERABILITZ (. .,Iotw rkesigL following corrective nai ntenance, moii tion, deficie~nt~or in :com plete surveilla cetesting, and oth 'er unanticilp ted'OPERABILITY

• concerns) provided n assessment determines p a safety is maintained or enhanced.

This -ssessmentshall, as a minimu , consider the.potential outcomes and transients ass.ociate.d with failed partial Surveillance, a.su essful partial Surveillance, an a perturbation of the offsite or onsite sy tem when they are tied togeth r or operated BWVOG STS B 3.8.4-9 Rev. 3.0, .03i31/04 Attachment 1, Volume 13, Rev. 1, Page 179 of 323 Attachment 1, Volume 13, Rev. 1, 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. T ese shall be measured against t e avoided risk of a plant shutdo and startup to.determine that plaqrt safety is maintained or enhance when, portions of.the Surveillancea eeperformed in MODE I or 2. Ris insights or-deterministic mett ods may be used for the assessm nt. ICredit may be taken for unplanned eventthat satisfy this SR.0 0 REFERENCES

1. 10-CFR 50, Appendix ,&--DC 1.7.2. Regulatory.Guide 1.6, March 10, 1971, 3. I EE E-30841 97fj7-i 4 FSAR h 5. SAR, 6. 4SAR, hae I.7., Regulatory Guide 1.93ý December 1974...8. lEE E-450-i19951 August 1972 9. Regulatory Guide 1.32, IFebrupf 197 10., Regulatory Guide 1.129- December 1974..0 0 0 0 BWOG STS B 3.8.4-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 180 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 181 of 323 Attachment 1, Volume 13, Rev. 1, Page 182 of 323 Specific No Significant Hazards Considerations (NSHCs)0\0 Attachment 1, Volume 13, Rev. 1, Page 182 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 183 of 323 Attachment 1, Volume 13, Rev. 1, Page 184 of 323, W ATTACHMENT 5 ITS 3.8.5, DC SOURCES -SHUTDOWN 0 Attachment 1, Volume 13, Rev. 1, Page 184 of 323 Attachment 1, Volume 13, Rev. 1, Page 185 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 13, Rev. 1, Page 185 of 323 Attachment 1, Volume 13, Rev. 1, Page 186 of 323 ITS 3.8.5 ITS ELECTRICAL POWER SYSTEMS LA01 D.C. DISTRIBUTION'- SHUTDOWN LIMITING CONDITION FOR OPERATION power source shall be 3.8.2.4 lAs a mi imum, the f llowingi D.C. electrical jequieat an bus -shall bA eneri an OPERAB I"F to support one train of the DC Electrical Power Distribution System/ required byILCO 3.8.10, "Distribution Systems2-Sh ud ownDC a LCO 3.8.5 TS j 12 -125-volt battery/banks and chargers supplyinýAPPLICABILITY: MODES 5 and 6. During movementofi ACTION Cl: rAdd proposed ACTION Note " lWith less than the a ove complement of-D.C., equipment and bus OPERABLE,I lrrn1 N TNTIErRITT within 8 houlrs 1 1---[Add proposed ACTION AL SURVE ILLANCE -SURVEILLANCE REOUIREMENTS 4.8.2.41I The above required 25O/125-volt D.C. MCC shall be determined OPERABLE and energized at least once per 7 days by verifying correct disconnect switch/breaker alignmenti indicated power availability from the charger and battery', and voltage on the bus of greater than or equal, to 125 volts D.C.See ITS 3.8.10 I SR 38.5.1 4.8.2.4.2 ý 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 L02 DAVIS-BESSE, UNIT I 31.4 8-11 Amendment No. 100 I Page 1 of I Attachment 1, Volume 13, Rev. 1, Page 186 of 323 Attachment 1, Volume 13, Rev. 1, 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 0 Davis-Besse Page 1 of 3 Attachment 1, Volume 13, Rev. 1, Page 187 of 323 Attachment 1, Volume 13, Rev. 1, Page 188 of 323 ITS 3.8.5, DC SOURCES -SHUTDOWN* REMOVED DETAIL CHANGES LA01 (Category I -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 -250/1 25-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 i 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 (Category 4 -Relaxation of Required Action) 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. 1, Page 188 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 189 of 323 Attachment 1, Volume 13, Rev. 1, Page 190 of 323 p Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 190 of 323 Attachment 1, Volume 13, Rev. 1, Page 191 of 323 CTS DC Sources -: Shutdown 3.8'5 3.8 ELECTRICAL POWER SYSTEMS 3:8:5 LCo 3..5: DC Sources -Shutdown[DC electrical power'subsystem shall be OPERAPLE to support the DC.electrical power disribution subsystem(s)requirqd by LCOG.8,.10,"Distribution SysteAi -Shutdown."] /l 3.8.2.4=..um r-------fNSERT I~netDCelectrical power rsubsy!stemn shall be OPERABLEg[Train 1 or Train 2)0 0 0.----------.-----....-- ......-REVIEWER'S NOTE ---- ...........------------------ The second.option a ove applies for plants having a pre-ITS licensing basis (CTS) for elec ical power reqduirements duri g shutdown conditions that required only o e DC electrical power~subsys m to be -OPERABLE. Action A and jhe br'cketedoptional wording in Co dition B are. also eliminated forthis c se. Th6:firsto0ption aboveis dopted for, plants that have a CTS requiri g the same level of DC electri alpower subsystem support as is requir d for power operating conditi ,ns.APPLICABILITY: MODES 5 and 6,ýDuring movement of [rec tly] irradiated fuel assemblies. 0 ACTIONS----------------------------------- NOTE-DOc M01 LCO 3.0.31is 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 AND The redundant train battery and charger[ A.2 Verify battery float curre t Once per [12] hours OPERABLE. < [2] amps.AND 0 0 BWVOG STS 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 191 of 323 Attachment 1, Volume 13, Rev. 1, Page 192 of 323 3.8.5 CTS O INSERT I 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. 1, Page 192 of 323 Attachment 1, Volume 13, Rev. 1, Page 193 of 323 CTS DC Sources -Shutdown 3.8'5.ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore, battery charger[] 7 days I to OPERABLE status.Action [. One [or rrelrequired DC electrical power subsyj e.m[sfinoperable ~J-'[for reaqons otheq than Conditi n A.OR Requi ed Actio and asso, ated Co pletion Time/of Confditibn A notB.2.1 Suspe d ýCORE Immediately ALTE[ATIoNS. AND Al .Suspend movement of[ t irradiated fuel assemblies. 0--AND B 3 Suspend operations involving positive reactivity A2 additions.that could result in loss of required SDM or boron concentration. 4-AND B. Initiate action to restore required DC electrical LA 3 power Fsubs yems to'OPERABLE Status oc Immediately Immediately Immediately 40 0 0 00D BV\AOG STS 3.8.5-2 Rev. 3,A 03/31104 Attachment 1, Volume 13, Rev. 1, Page 193 of 323 Attachment 1, Volume 13, Rev. 1, Page 194 of 323 CTS DC Sources -:Shutdown 3.8.5 4.8.2,4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5:1 ----------------- NOTE--------,ThefollowingS, ae not required to be performed: R 3. .and SR 3.8.4.3;.Fo+DC: sourceJ required to be. OPERABLE the In accordance following SRs are applicable:, with applicable SRs SR'3.;8.4A1 SR 3.8.4.2 SRý3.6.4.3 0 0 0 BVWOG STS 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 194 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 195 of 323 Attachment 1, Volume 13, Rev. 1, Page 196 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 196 of 323 Attachment 1, Volume 13, Rev. 1, Page 197 of 323 DC Sources -.Shutdown'B 3J8&5 B3.8 ELECTRICAL PQVOER SYSTEMS B 31.8.5 DC Sources- Shutdown BASES BAC KGROUNDD A descriptinonf the DC sources is provided inthe IBases forLCO 3.,8'4,A"DC .Sources -Operating." APPLICABLE SAFETY ANALYSES The initial conditions of DesignB.asis Accident (DBA)arid transient* analyses in the SAR, Chater [ (Ref. 1) and Chater f 5M(Ref, 2),'assume that Engineered Safety Featureý,(ESF) systems are OPERABLE.The DC electrical power system"iprbvides normal-and emergency DC[E)electrical:

power for'the+D.Gs, emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC su s is.consistent with the initial assumptions of the:accident analyses and the requirements for the supported.systems" OPERABILITY, 00 The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [rec tly] irradiateld fuel assemblies ensures that: 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 r~dioactive decay;DC electrical power is only required to mitigate fuel aandling accidents involvino handling recently irradiated fuel (i.e. , fuel that has occupied part of alcritical reactor core within the pr vious. [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 orall onsite power is not required.The rationale for this is basedon the factthat manyDBAs that are analyzed in MODESP1, 2, 3, and 4jjhave no specific analyses in 0 0 0 0 0 0 BVVOG STS B 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 197 of 323 Attachment 1, Volume 13, Rev. 1, Page 198 of 323 DC Sources -Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYS ES (continued). MODES r and 6Mbecause the energy contained within the reactor Q pressure boundary, reactor coolant temperature and pressure, and .the corresponding stresses reSUlt i nthe probabilities of occurrence being significantly reduced or eliminated, and in minima Iconsequences. These ,deviations from DBA analysis assurnptions. 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 lowerenergies involved. The Technical Specifications therefore. require a lesser complement of electrical-equipmentto be available during shutdown than is required.during operating MODES. More recent work completed on the potential risksassociated with shutdown, however, have found significant risk associated with certain shutdownevolutions. As a result, in addition to the requirements establishedin the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess ZShutdown 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 bythe shutdown Technical Specifications. ~The DC,ýIource~satisq-Criterion 3 of IO.CFJR 50;38(*)(2)(ii). sources LCO. t 7 nof-.fhe DC electrical powrI .s [each re uiredl [the r quired]Isubs temconsisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling within the train, r[ -]]is[ required to be OPERABLE t0osupport reqe of the distribution systems 'equired OPERABLE'by LCO 3.8.10, "Distribution Systems -Shutdown.'U] This ensures the, 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 [involving ha g recently jirradiated fuelD.O BWOG STS B 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 198 of 323 Attachment 1, Volume 13, Rev. 1, Page 199 of 323 DC .Sources -.Shutdown O B 3.8.5 BASES APPLICABILITY The DC electrical power .sourceg required to be OPERABLE in MODES 5: 0D5 and 6 and during movement of [rec tly] irradiated fuel assemblies, (D provide assurance that: a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel .assemblies .in the cor .0 b. Required features needed to mitigate a fuel handling accident[involving handlihg recently irradiated fuel (iLe., fu I that has occupied]a critical/reactor core Within the previous ] days)] are available*c. Required features. necessary to mitigate the effects of eventsthat 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 coId shutdoWn condition or refueling. condition. TheDC electrical power'requirements for MODES1, 2, 3, and 4:.are covered in LCO 3.8.4.ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or6. 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 Ais include only when p!ant-specific impleme tation of LCO 3.8.5 includes t, epotential to require both-trains o the DC System to be OPERABLE. If plant-specific implementation res Its in LCO 3.8.5 requiring onlyone tr in of the DCSystem to be OPER BILE, then ACTION A is omitte and ACTION Bis renumbered as ACTION A.O BVOG STS B 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 199 of 323 Attachment 1, Volume 13, Rev. 1, Page 200 of 323 DC 'Sources -,Shutdown B BASES ACTIONS (continued) Condition A represen s one train with one [or two] batte chargers inoperable (e.g., the oltage limit ofSR,3.8.4.1 is notrm intained). The ACTIONS provide a.t ered response that focuseson rot rning the battery to' the fully charged s ate :and restoring. a fullyqualified harger to:OPERABLE status i a reasonabletime period. Requir-d Action. A requires that the batt ry terminal voltage be restoredto greater than or equal to the minimu establishedfloat'voltage within 2 hours. This time provides for returnin the inoperable charger to OPER , BLE status or providing an.alternat 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 geprovides good assurance thapt 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 time equal to 21 hours plus the ti experienced to accomplish the exk 3onential'charging current portion of th battery. charge profile following th service test (SR 3.8.4.3).-------------. -. ----....... -- ---------- ------ ---------0 0 0 A discharged battery aving terminal *voltage of at lea~st the minimum'established float volt 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 underthis c ndition is simply a function of the amou t of the previous discharge and t e recharge characteristic of the attery, Thus there is:good assur nce offully recharging the batte within [12] hours, avoiding a pre ature,shutdown with.its own attenda. t.risk, 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. Afaul charger that is incapablef of.main aining established batteiy terminal flia 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 t that'the DC system is designed or, 0 BWVOG STS B 3.8.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 200 of 323 Attachment 1, Volume 13, Rev. 1, 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,aftei indication that the. ba ery is partially discharged and its will be reduced. The ime to return the battery'to its full, condition in this case is a function of the battery chargei amount of loads on t e associated DC system, the! amo previous discharge, .a d the recharge characteristic oft charge time can be e tensive, and there is not adequat can be recharged Wit in [12] hours (Required Action A..2 hours that isian capapity margins Y-charged capacity, the lunt of the e battery; The.assurance that it 2).nt be verified as) battery, had been er, it has now 2] hour period the this indicates yMust be Required Action A.2 less than or equal to discharged asthe reýbeen fully recharged battery float current.!: there may be additioi declared inoperable. equires that the battery float currE[2]amps. This indicates that, if th wult of the inoperable battery~char(Ifat the expiration of the initial [1 not less.than or equal to [2].amp ial .battery problems and theabatte 0 Required Action A.3 1imits ,the restoration time forathe i operable battery charger to 7 days. -ihisaction is applicable if an alternate means of restorng battery terr inal voltage to greater than or :eq to the: minimum established float voll ge~has been .used (e.g.,, balance of plant non-Class 1 E battery ch~arger). The 7 dayCompletion Timerefle -ts a reasonable time to effect restor ion of the qualified battery chargý r to OPERABLE status.IA1A.and A.3 IB1, B.2:1! B.2.2.,B.2.3j. nd B.2.41[If two trains are req ired by LCO 3.8.10,the remaining rain with DC power available mýabecapabie of supporting sufficien Systems to allow continuation of /E ALTand [recently] irjadiated fuel movement];. By all ng theoption to declare require features inoperable with the associated DC power source(s) inperable,. appropriate restric ons will be implemented in accor -,nce with'the affected required f atures LCO ACTIONS. In many -hstances this option may involve undelired administrative efforts. Therei0re, the allowanice for sufficiently corsrvtve actions. is made '(i.e. to/5uspend.ALTE ION3, movement of jeedljirradiated fuel'assembliesmand operations. involving positive reactivity additions that could result in 0 2 TST.47©W~1 BWOG STS B 3.8.5-5 Rev. 3.0, D0331/04 Attachment 1, Volume 13, Rev. 1, Page 201 of 323 Attachment 1, Volume 13, Rev. 1, Page 202 of 323 B 3.8.5 O INSERT 1 With the required train of DC electrical power sources inoperable, the minimum required DC electrical power source is not available. Therefore, suspension of 0 Insert Page B 3.8.5-1 Attachment 1, Volume 13, Rev. 1, Page 202 of 323 Attachment 1, Volume 13, Rev. 1, Page 203 of 323 DC Sources -Shutdown B3:.&5 BASES, BASES is re.qured loss of required S.DM (MODE 5)or boron concentration (MODE 6 Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to continued s Introductionof coolant inventory must belfrom[Reactor Coolant Syste o Z) sur ces t b nIado that have a boron c tion greater would be required in the4RCS 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. Moderator Temperature Introduction of temperature changes including temperature, increases Coefficient( "when operating.with.a, positive MTCtmust also be evaluated to ensure 2J they do not:result in a loss of required SDM..00 Suspension of these activities shall not preclude completion of acions,.to establisha. 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-r and to continue this action until restoration is :accomplished in order to providethe necessary DC electrical power to the unit safety systems..The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. Therestoration of the required DC.electrical pov s. should be completed as quickly as possible in.order to minimize-the time during which the unit safety systems may be: without sufficient power.SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by.SR 3.8.4.1 through SR 3.8.4.3. Therefore,see the correspondingBases for LCO 3.8.4for 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 inoperableduring the performance of SRs. It is the intent that these SRs must still becapable of being met, but actual performance is not required.0 0©00 REFERENCES ` 1. EE2. +FSAR., 0 BWOG STS B 3.8.5-6 Rev. 3.0',. 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 203 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 204 of 323 Attachment 1, Volume 13, Rev. 1, Page 205 of 323 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 205 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 206 of 323 Attachment 1, Volume 13, Rev. 1, Page 207 of 323* ATTACHMENT 6 ITS 3.8.6, BATTERY PARAMETERS 0 0 Attachment 1, Volume 13, Rev. 1, Page 207 of 323 Attachment 1, Volume 13, Rev. 1, Page 208 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 208 of 323 Attachment 1, Volume 13, Rev. 1, Page 209 of 323 ITS 3.8.6 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION -OPERATING LIMITING CONDITION FOR OPERATION[Add proposed LCO 3.8.6 A02 trains shall be energized and :OPERABLE, bus trains, open: 3.8.2.3 The following D.C. bus with disconnect switches.between TRAIN "A" consisting of 250/125-Volt D.C. MCCJ, 125-volt D.C.station batteries lP and IN 'and 2 full capacity chargers:. TRAIN "B" consisting of 250/125-volt D.C. MCC 2, 125-volt D.C.station batteries 2P and 2N and 2 full capacity chargers.I I'A02 APPLICABILITY.IHODES l-. 2. 3'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 See hours or be in at least HOT STANDBY withina the next 6 hours and ITS3.8"gI'in COLD SHUTDOWN within the following 30 hours..SRELbAC. EUIEEr With only one 125-volt D.C. battery or only one charger of one MCC OPERABLE, restore the inoperable battery or charger to See OPERABLE status'within 2 hours or be in at least HOT STABY UHITS 3.8.4D within the next 6 hours and in COLD SHUTDOWN within the followin 30 hours-.SURVEILLANCE REQUIREME.NTS 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 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.See ITS 3.8&9 14.8.2.3.2 Each 125-volt battery and charger shall be demonstrated OPERABLE: -ITS3.8.4"~~~- See "L " .L01 SR 3.8.6.2 a. At least once per days by: 31 daysforvoltage t Ii.Verifying that 'the parameters in Table 4.8-1 meet the Category A limits, and I 0 [ Add proposed SR 3.8.6.1 I DAVIS-PESSE, UNIT I 3/4 8-8.Amendment. No, 100 Page 1 of 4 Attachment 1, Volume 13, Rev. 1, Page 209 of 323 Attachment 1, Volume 13, Rev. 1,. Page 210 of 323 ITS 3.8.6.ITS ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) r See Verifying total battery terminal voltage is greater than or equal to ITS 3.8 .4] M02 SR3.8.6.3, b At least once per 2daysnd within / pays a"er a .a e .sc arg 31 days for electrolyte temperature SR3.8.6.4, 1(battery termin vo tage below 110 vo ts) or battery ovrcharge. SR 3.8.6.5 1(battery termin I voltaqe above .150 vts , by: SR 3.8.6.3, 1. Verifying that the parameters in Table 4.8-1 meet the ýCategory B SIR 3.8.6.5 limits, SR 3.8.6.4 2. Verify' hig that there is 'no yifible corrosion at ey~her terminals. or )(0" co~nnefx~tors,.or the connectAfon resistance of items is less thanl 115 x 10-6 Ohms, and :/ .*on e ' ....Vefyn that the aeagelectrolyte-temperaturei,,i1 offevery J ce lsabo .greater than or equal to minimum establishd design limits } LA01 s .upply: at least 475 amperes at a~minimum f3.Vlsfra es IS384 hours-, and at Ieast once e.ach REFUELING INTERVAL by _Jrfyn I~~t.The cells/ cel.l plates and bat ery racks showno vis al indication of physical damage or abnormal d erioration, 2. The. cel -to-cell and termina connections are cleh, tight and coated with a ti-corrosion materia ,and 3. The esistance of each ce -to-cell and termina connection is less tha or eaual to 150 x 1 6 ohms.L0 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 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 thebattery service test.See ITS 3.8.4J I SR 3.8.6.6 e. Verify battery capacity is 2 80% of the manufacturer':s rating when subjected to a performance discharge test or modified performance discharge test: 1. At least once per 60 monthsidurina shutdownl when the battery shows no signs of degradation, and has not reached 85% of service life: 2. At least once per 12 months, ldurinq shutdown] when the battery shows 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,ldurinq shutdown[ when the battery has reached 85% of service life with 2 100% of the manufacturer's rated capacity.LI10 Li DAVIS-BESSE, UNIT 1 3/4 8-9 Amendment No. I002149,229 0 Page 2 of 4 Attachment 1, Volume 13, Rev. 1, Page 210.of 323 Attachment 1; Volume 13, Rev. 1, Page 211 of 323 ITS 3.8.6 ITS TABLE 4.8-1 RATTFRY SURPVFTI] ANC 1F OUIREMENTS SR 3.8.6.3 SR 3.8.6.2, SR 3.8.6.5 S(a) Correcvted or e ectrolyte emperature and eveY. .f the level is b j ween the high marks and the .iteerature 'correctedL0 sp ific gravity is-wi}I~n -the man'ufacturerls'nominal iSpecific a vit v rp nae- 'it is neces'sary t o co /rlcts for level ..5"b e~rcted for aw&rjqe- electro1v ~~emperatureý L0 ()or ba~tt.Sy charging currenyv following a servife performance i"disclpzfge, or modified poffo~rmance di.scharggeyfest, is "less, than L06 I on a charge.y (d),It .is ..K ceptable for the etrolye level to/temp or aril y incr ae above the Ispec' led maximum duiring 1 i 9n charges" ti) For any 2egory A parameaer{ ouisloe lhe Inm]ts snown, tne batterY aybe considered OPE BLE provided that w&thin 24 hours all the /ategory Breasureme ts are taken and foun to be within their a 'lowabley values, and rovided all parfamete (s)1are restor d to within limits w thin the next 6 days.(2) For an Category Bparamet ,(s) outside'the limi (s) shown, the batte y may be considered PERABLE provided tha *they are within thel allowable values an providedthe paramet r(s) are, rest red.to within limits within.7 days...(3) Any Category B parameter not Within its allow le value indicates an inoerable battery.Add proposed ACTIONS, L0 A, B, C, D, ,E, andF DAVIS-BESSE, UNIT 1 3/4 8-10 Amendment No. RIGOl-&ý8a29 Page 3 of 4 Attachment 1, Volume 13, Rev. 1, Page 211 of 323 Attachment 1, Volume 13, Rev. 1, Page 212 of 323 ITS 3.8.6 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION -SKUTDOWN.[Add propoeLC 3.88.F6 LIMITING COND'ITION FOROPERATION /3,8.2.4 As a minimum, the following DC. electrical equipment andd bbus Ishall be energized and OPERABLE: "!sI Se-250/125-volt D.C. M1CC, and ITS 3.8.10 2 -125-volt, battery banks and chargers supplying the above D.C; M1CC. See I --I I .ITS 3 .APPLICABILITY: [NODES 5 and 6.ACTION: See.With less than the above complement of D..C. equipment and bus OPERABLE, ITS 3.8.5 establish CONTAINENT INTEGRITY within 8 hours.. ITS3.8.10 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 250/125-volt D.C. MCC shall be determined I 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.See 1 ITS 3.8.10J 4.8.2.4.2 The above required 125-volt battery banks and. chargers be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2. shall See CTS Markup Pages fl- 1 of 4, 2 of 4, and 3 of 4 (i.e., previous 3 pages)DAVIS-BESSE, UNIT 1 3/4 $-I1 Amendment No. 100 I Page 4 of 4 Attachment 1, Volume 13, Rev. 1, Page 212 of 323 Attachment 1, Volume 13, Rev. 1, 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 determine the state of charge of the battery. 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.0 Davis-Besse Page 1 of 8 Attachment 1, Volume 13, Rev. 1, Page 213 of 323 Attachment 1, Volume 13, Rev. 1, 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 600F. ITS SR 3.8.6.4 specifies the limit to be greater than or equal to the minimum established design limits. This changes the 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. 1, Page 214 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 215 of 323 Attachment 1,Volume 13, Rev. 1, 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 I and Train 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 toperform 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 (Category 6 -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. 1, Page 216 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 5 -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 (Category 5- 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. 1, Page 217 of 323 Attachment 1, Volume 13, Rev. 1, 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 (Category 6 -Relaxation Of Sunve i/lance 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 :2.13 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 SIR 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. 1, Page 218 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 219 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 220 of 323 Attachment 1, Volume 13, Rev. 1, Page 221 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 221 of 323 Attachment 1, Volume 13, Rev. 1, Page 222 of 323 Battery, Parameters 3.8.6 CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters -- VIEWER'S NOTE --- ------------ w---------- Licensee's must implement a p raham, as specified. in Specification 5.5. 17 o monitor battery parameters that is based o.he recommendations of IEEE Standard -1995', 'IEEE Repcommended Pract For Maintenance, Testing And Replac Vented Lead-Acid Batteries For St nhary Applications." 0 DOC A02 LCO 3.8.6 Battery parameters for,the Train -and Train.Tlbatteries shall be within limits.When associated DC electrical. power sub7stems ,.are required to be, OPERABLE.0 0)APPLICABILITY: DOC A02 ACTIONS---------' I..... .... .1--. --- ----- ----I, -- -- -;. ....IKlt T&E--------- Table 4.8-1 footnotes (1), (2), and 02)Table 4.8-1 footnotes (1), (2), and (3)Table 4.8-1 footnotes (1), (2), and (3)Sepa.rate Condition entry is allowed for~each battery.---- ---- --- I. .-- --- -I. .--- -- --- -- --- -- --- -- ... ----.. __ _ _ _, _ ., ..-...-------- ._ ._ L -. .. ---- ---- ---- ---- ---- --- ----.-.--... _.. ..CONDITION REQUIRED ACTION COMPLETION TIME A. Oneg~or o battefrlr~es o r with one or more battery cells float.voltage X 07$V, A.1 Perform SR 3.8.4.1.2 hours, AND A.2 Perform SR 3.8:6.1.AND A.3 Restore.affected cell voltae .OMZ.0 ]V.0)0 2 hours 24 hours 0 B. One or batte?1ies Ion o ith float current >1 amps.B.1 Perform SR 3.8.4.1.2 hours AND B.2 0)0)0)Restore battery float current to <ý 2]amps.r12Ehours. 0 BWOG STS Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 222 of 323 Attachment 1, Volume 13, Rev. 1, Page 223 of 323 Battery Parameters CTS 3.8.6.ACTIONS (continued) Table 4.8-1 footnotes (1), (2), and (3)0 Table 4.8-1 footnotes (1), (2), and-(3)CONDITION REQUI.RED ACTION COMPLETION TIME------- ----NOTE ---------------- ---NOTE---------- Required Action C;2 shall be Required Actions C.1 and C.2 are completed ifelectrolyte level, onl Yapplicable if electrolyte level was belowithe top of plates. was below the top ofplates.C. OneMor afbatter~Mfes C.1 Restore:electrolyte levelto 8'hours on o, rainwith one or above.top of plates:.more cells, electrolyte level less than minimum AND.established design limits. C..2 Verify. no evidenceof 12 hours leakage.AND C.3 Restore electrolyte level to 31 days greater than or eqUal to minimum established design limits.D. One batte[nies. D.i Restore batterypilotlcell 12 hours n rain with pilot temperature to greater than cell electrolyte or equal to minimum temperature less than established design limits.minimum established design limits.0 0 Table 4.8-1 footnotes (1), (2), and (3)E.ne more Iatteries in redundant trains with.battery parameters not within limits.E.1 Restore battery parameters for batteriesi n one train to within limits.2 hours.0D 0 BVVOG STS 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 223 of 323 Attachment 1, Volume 13, Rev. 1, Page 224 of 323 Battery Parameters 3.8.6 O CTS Table 4.8-1 footnotes (1), (2), and (3)0DOC M01 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Declare associated battery Immediately associated Completion inQperable; Time of Condition A, B, C, D, or E notmet.OR more Onelor o] batteriWles on o etrainwith one-or more: battery cells float voltage o2O07 and foa current > 2T armps......... R : 3.8.6.6 notmet.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 38,6.1 ---- --------------- 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 [< M. Jamps. 7 days 0 0 0 0 0 4.8.2.3.2.a.1, SR 3.8.6.2 Table 4.8-1 Verify each battery pilot cell Voltage iti.07MV.31 days 4.8.2.3.2.b.1, Table 4.8-1 SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than. or equal to minimum established design limits.4.8.2.3.2.b.3 SR 3.8.6.4 Verify each battery pilot cell temperature is greater, than or equal to, mihimum established design limits.31 days BWOG STS 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 224 of 323 Attachment 1, Volume 13, Rev. 1, Page 225 of 323 Battery, Parameters 3.8.6.CTS 4.8.2.3.2.b.1 Table 4.8-1 4.8.2.3.2.e 0 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY" SR 3.8.6.5 Verify each battery connectedocell voltage is 92 daysýSR 3.8.6.6. ------...---------------------- NOTE--. -------------- This Surveillance shall notbe performed in MODE 1, 2. 3, or 4./However,. portions.0f tl- e Surveillance maybe p rformed to reestablish 0 ERABILITY provided an assessment deterministhe safe of the la is maintained or enhanc d. Credit may be taken for unplanned events that. satisfy this:SR.Verify. battery~capacity; is. > [80.%/1t the manufacturer's rating when subjected.to a 60 months performance discharge test. or a modified performance discharge test. AND 12 months~when battery shows degradation, or has reached Rg5r/o of the expected life with capacity < 100%of manufacturer's rating AND 24 months when battery has reached p85Y/Oof the expected life with capacity_> 100% of manufacturer's rating 0 0 BWAOG STS 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 225 of 323 Attachment 1, Volume 13, Rev. 1, 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 I Attachment 1, Volume 13, Rev. 1, Page 226 of 323 Attachment 1, Volume 13, Rev. .1, Page 227 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 227 of 323 Attachment 1, Volume 13, Rev. 1, 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 ctrica cel. electrolyte temperature, level, and float voltage for the DC soure sub Se batteries. A discussion of these batteries and their OPERABILITY requirements is provided inthe Bases for LCO 3..8.4 "DC Sources -Operating:," and LCOG3.8.5, ,DC Sources -Shutdown-." In addition to the. limitations of this Specificati0n, the j[licensge&6-ontrolle ro amlso implements a program specified in Specification 5.5. for J 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); Battery Monitoring and.. ..... ...... ...(Maintenance Program The battery, cells are of flooded lead acid construction with a nominal specific gravity of jThis specific gravity corresp nds to an open circuit battery volage of approximately 120 Vfor [58] c II battery (i.e., cell voltage of [2.06 volts per cell (Vpc)). The open circu t voltage is the voltage maintaied whlren there is. no chargingor disc arging. Once fully K-charged with its/open circuit voltage ?.[2.065] Vpc, th battery cell will O maintain its Caipacity for [30] days without further'cha ging per Imaniufacture[ iinstructions .OptirmaI is obtained by maintaining a float~voltag{m to:2.225Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self:discharge. IThe no i la[float~voltage of [2.22] Vpc corresp/B0d to a totalI/foat voltage .0ut of [1M288] V for a [58] cell battery discussed inthe I L.FSAR, C r [8] (Ref. 2).j .... " ..APPLICABLE The initial conditions of Design Basis Acciden -DBA) an -a n t SAFETY analyses in thefeter ehtea ir .(Ref. 02, ANALYSES assume Engineered Safety Featuresystems are OPERABLE. The DC UFSAR, Section 6 electrical poWer system provides normal and emergency DC elec-trical K E power for thetDGsemergency auxiliaries, and control and switching 0 during all MODES ofoperation. The OPERABILITY of DC subsystems isiconsistent wi *e initial assumptions oft accident analyses and isbased meeting the design bas' the.unit. This includes maintain at least one train of DC s c.es OPERABLE during accident itions, inthe event of: The specific Applicable Safety Analyses for he DC Electrical Power System are provided in the Bases for LCO 3.8.4 and LCO 3.8.5.O BVVOG STS B 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 228 of 323 Attachment 1, Volume 13, Rev. 1, Page 229 of 323 Battery Parameters B 3.8.6 BASES APPLICABLE SAFETY ANALYSES: (continued) a.. An assumed los I offsite.AC power or all.onsite wer and b. A -case single failure..Battery parameters satisfy Criterion:3 of 10 CFR 5Q`36(c)(2)(ii). 0 LCO Battery parame.ters must remain within acceptable limits to ensure availability ofthe required DC power to Shut down the reactor and maintain it in a safecondition after an anticipated operationa loccurrence. 6r a postulated DBA. Battery parametertlimits are conserVatively established, allowing continued DC ,lectricaloystem function even with limits not met. Additional preventative maintenance, testing, and Battery.monitdring: performed in accordance with the .i7enS ontrolled and.ro am] is conducted as'specifed. nSpecifcat ion 5.5.,---ý] Program 0 0 0b APPLICABILITY The battery parameters are: required solely for theýýsupport of the associated DC e'lectrical powe subsytem. Therefore, battery. electrical E parameter limits are ony requi red when the DC4power source. is required to. be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and, LCO 318.5.0 6 (D ACT IONS A.I, A.2, and A.3'With one or more cells in one or more batteries lin opfrain the D' battery cell is degraded. .Within 2 hoursverification ofthe. required battery-eired ) chargerOPERABILITY is g by monitoring the battery terminal Voltage v(SR 3.8.4.1) and'of the overall battery state of charge~by monitoring the battery floatcharge current (SR 3.8.6.1). This assures that there il 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 [-2.07R V, and continued operation is permitted for a. limited period u pto24flours.. (-}0,}Since the Required Actions only~specify "perform," a failure of.SR 3.8.4:1 or SIR 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. BWOG STS B 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 229 of 323 Attachment 1, Volume 13, Rev. 1, Page 230 of 323 Battery Parameters. 1B 3.8.6'BASES ACTIONS (continued) B.1 ,and BU2 One or .m0or batteries;in o Wrain with float current indicates (1 ,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 more battery cells. in a low voltage condition reflecting some loss of Dcapacity. Within 2;hours~verification .of the required battery charger requd OPERABILITYi by monitoHrig the battery terminal voltage. If the terminal voltagejis.found to be .ess'than the .minimum established float Voltage there are two possibilities, the battery charger is inoperable or is operating inthe current limit mode. lCondition A rsses charger(n b If the, charger is operating in the current limit mode after*2 hour that is an indication that the battery has been substantially 0 --tdischarged and. likely cannot perform its required design functions. The time to return the battery to its fully -charged condition in this: case isa function of the batterywcharger capacity, the amount of loads on the associated DC.systemr, the amount ofthe 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.2[hours (Required.Action B.2). The battery must therefore be declared'inoperable. Ifthe float V01tage. is:foundl to.- be Satisfact6itybu:teia rg-ene or, more.battery:cells wth f'o than [2.U1.] V, the. ociated O.statement in Co ition F is applicable and the i ymust be declared in~p era~ble.j ledi~ately, If float"vb1tage i~s and,there are no.Icells le han 2.07] Vthere isgood assurance that, within T12 hours, the (P r battery Willbe restored to its fully charged condition (Required Action B;2)from any discharge that might have occurred due to a temporary loss of the batterytcharger. ........ -EVIEWER'S NOTE -m _ ------------ A plant that cannot et the 12 hour Completion Time due, an inherent battery charging aracteristic:can proposeaan alternat me equal to 2 ous lu tmeepeiece t acopish th"xponential charging 0 current po on .of the battery charge profile follo. g the service test (SR 3. .s.3)3 OBVVOG STS B 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 230 of 323 Attachment 1, Volume 13, Rev. 1, Page 231 of 323 Battery Parameters B 3.8.16 BASES ACTIONS (continued) A discharged battery with float voltage (the charger setpoint).across its terminals indicates that the battery is o the Mexponential charging:.current portion (the second part) of its recharge cycle. The time to return- a battery topits fully charged state under.ii is is simply a jfunction of the amount of the previous discharge and:the rechtargecharacteristid of the battery. Thus there is good assurance of fully recharging the battery within ýi12E] hours, avoiding a premature shutdown withý its own:attendant, risk.If the condition is due to. one or more cells inma.low voltage condition but.still greater than f2.07M V and float voltage is found:to be satisfactory,'this} ýis noindication of a substantially discharged ba'ttery and M1,2M]hours.is a.reasonable time prior to, deblari ng the: battery, 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, iSjentered." C. C.2, and C.3 With one or more batteries.i withone or more bells electrolyte level above the top of the plates , but below the.minimum established. design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not reqUired~to be considered inoperable solely as a result of electirolyte 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 platesthere is a potential for H dryout and plate degradation. Required Actionis .;1 and C.2 address this potential (aswell as provisions in pecification

5. 41,Battery Monitoring (1[L and Maintenance Prograrr,).

They are modified. by a Note that indicates they areonly applicable if electrolyte leve! is below thetop of the plates.L Withiin8husToVuilevel is required to be, restoredto, above the top of the requirement plates. The Required ActionC'2 requirement to verify that there is no Eqleakage by visual inspection and the Specification.5..b o initiate ( (action to equalize and test in accordance with manufacturer's recommendation are.taken from Annex Dof IEEE Standard 450-1995.They are performed following the restoration ofthe electrolyte level to above the top of the plates.. Based on the .results~of the manufacturer!s. recommended testing the battedmesl] may have to be declared inoperable and the affected cell"st] replaced.O BWOG STS B 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 231 of 323 Attachment 1, Volume 13, Rev. 1, Page 232 of 323 Battery Paramreters, B 3.8.6 BASES.ACTIONS (continued) DA With one. or more batteries. With-pilot.cell temperature less (than the minimum established design limits, 12 hoursis allowed to restore the temperature to within limits. AIow electrolyte Atemperature limits the current and power available, Since the: battery is sized with margin, while battery capacityis 'degraded, sufficientcapacity 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 notmet.E.1 With o batteries in.redundant trains with battery. parameters not Within limits thdre 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 onwnon-redundant batteries notwithin limits are therefore not appropriate, and the parameters must be restored to within limitseon at train within 2 hours.F.1 rfailure oSR] 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, sufficientcapacity to supply the maximrrum 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 thanJ2.07MV and float current greater7amps indicates that the battery capacity.may not be sufficient to 0 perform the intended functions. The battery must therefore be. declared inoperable, immediately.. BVVOG STS B 3.8.6-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 232 of 323 Attachment 1, Volume 13, Rev. 1, Page 233 of 323 Battery Parameters B BASES SURVEILLANCE REQUIREMENTS SR 3.8.:61 Verifying battery float currentwhile on float charge is used to determine the state of charge of the battery. FIoat charge is the conditionin 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 conservativethanthe The floatcurrent requirements, are based on the float current indicative of recommendations of a charged battery. Use of float current to determine the state of charge of the batteryjis:consistent with. IEEE-450 (Ref. 1). The 7 day Frequency is I consnsttwith IEEE-450'(Ref: 1).Thisý SR .is modifi ed by a Note that states the float.current requirement is, not required to be met when battery terminalvoltage 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 0fj2j amps is established based onthe nominal'float::voltage value and is. not directly applicablewhen this voltage is not maintained. SR 3.8.6.2.and SR 3.8.6.5 0 0 Optimal long term battery performance is obtained by maintaining a float voltage greater than .or equal to the minimum established design.limits 2 provided by the battery manufacturer, which corresponds to at.the batteryterminals, oyr[5Vpc. This provides adequate over-potential, which limits the formation of lead sulfate. and self discharge, which could.eventually render the battery inoperable. FloatVvoltages in this range or less;, but greater than.M2.07I],Vpc, are addressed in 6 S SRs 3'8.6.2 and 3.8.6.5 require verification that the 0 cell float.voltages are e ulto o greater than the-short term absolute.minimum Voltage ofM2.07I1 V. The: Frequen foi cell voltage verification 00 every 31 days for pilot cell and 92:days for each connected ff consistent with IEEE-450 (Ref. 1),. -SR .(greater than the minimum SR 3.8.6~3 level indication mark)(minimum establisheddsgný

---

I Theilimit specified for electrolyte leve ehsures that the plates suffer no. ( physical damage and maintains adequate electron transfer capability.

The Frequency:is consistent -with IEEE-450.(Ref. 1).0 BVVOG STS B 3.8.6-6 Rev. 3.0, 03/31J04 Attachment 1, Volume 13, Rev. 1, Page 233 of 323 Attachment 1, Volume 13, Rev. 1, Page 234 of 323 Battery Parameters B 3.8,6 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater thaneor-equal to the minimum established design limit (i.e.. [ IPilot cell 0 electrolyte temperature isnMaintained above this temperatureto assure the battery can provide:-the required current and voltage to meet the design requirements. Temperatures lower than assumedin battery sizing calculationSact 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 lest of.constantcurrent 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 ýage 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 performrance'.discharge test may be. used to satisfy the battery service test requirements of SR 3.8.4.3.A mod fied 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 thecritical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to: those specified for a service test..---. [as 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 'ofthe service test. Since the ampere-hours removed by a one Fdischarge'"I minute discharge represents a very small portion of the battery capacity, the test ratecan be changed to that for estwithout compromising the results of the performance discharge test. The battery terminal voltage, for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.BV\OG STS B 3.8.6-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 234 of 323 Attachment 1, Volume 13, Rev. 1, Page 235 of 323 Battery Parameters 83.8.6 BASES SURVEILLANCE REQUIREMENTS (continued) The acceptance:criteria for this Surveillance: are consistent with IEEE-450.(Ref. 1):and IlEEEE-485 (Ref.. These references recommend that the Yj)battery be replaced if its capacity is below.80% of the manufacturer's rating. A capacity, of 80% shows that .the, battery rate ofdeterioration 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 p8. 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 retain capacity, 100% of the manufacturer's ratings..

Degradationis indicated, according to IEEE-450 (Ref. 1), when the battery, capacity drops by more than 10% relativeato its capacity on the previous performance test or when it is belovthe manufacturer's rating.These Frequencies are consistent with the recommendations in IBEEE-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 normally p rformingthe Surveillance in 2 is.further amplified to. allowý 0ho~rtipnS: Of the Surveillance to be perf rmed for the purpose of reestabli hing OPERABIL ITY: (e.g.,. ost work testing following

• .orrectie, maintenanice., corrective mobdificatio/h, deficient or.inC~mplete surveillaice testinig,.and otherunanticipated PERABILITY concerns) provide an assessment 0 determines-plant sa/ety is: rraintained, or enhanced.-Ihs sesm n shall, as a minimui, .consider the potential outcome and transients associated.

with a ailed partial Surveillance, a succ ssful partial Surveillance, an a perturbation of the offsite or on ite system when.they are tied togethe or operated independently forth partial Surveillance; as well as the ope ator procedures available to cope with these outcomes.These shall b measured againStthe avoided ri of a plant.shutdown and startup, to determine thatplant safety is mai tamned or enhanced when portior of the Surveillance are performe in MODEl or2. Risk insights or terministic methods may be use for the assessment. Credit may be~taken for unplanned events that satisfy this SR.O BV\OG STS B 3.8.6-8 Rev. 3.0, 03/31/04: Attachment 1, Volume 13, Rev. 1, Page 235 of 323 Attachment 1, Volume 13, Rev. 1, Page 236 of 323 Battery Parameters B 3.8.6 BASES REFERENCES

1. IEEE-450-P19951 u *2. FS [81.1 ED , r Section 6lM-- FSAR, -Chaptqfr

[6].b ---La IFSAR, J. June 1983.0 0 00 00 0 BVWOG STS B 3.8.6-9 Rev. 3.0, 03/3-1/04 Attachment 1, Volume 13, Rev. 1, Page 236 of 323 Attachment 1, Volume 13, Rev. 1, 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/spe[ling 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.

0 Davis-Besse -Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 237 of 323 Attachment 1, Volume 13, Rev. 1, Page 238 of 323 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 238 of 323 .Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 239 of 323 Attachment 1, Volume 13, Rev. 1, Page 240 of 323 ATTACHMENT 7 ITS 3.8.7, INVERTERS -OPERATING 0 Attachment 1,.Volume 13, Rev. 1, Page 240 of 323 Attachment 1, Volume 13, Rev. 1, Page 241 of 323 WCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)S 0 Attachment 1, Volume 13, Rev. 1, Page 241 of 323 Attachment 1, Volume 13, Rev. 1, Page 242 of 323 ITS 3.8.7 ITS i Add proposed ITS 3.8.7 1 0 Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 242 of 323 Attachment 1, Volume 13, Rev. 1, 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 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 243 of 323 Attachment 1, Volume 13, Rev. 1, Page 244 of 323 p Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 244 of 323 Attachment 1, Volume 13, Rev. 1, Page 245 of 323 Inverters -Operating 3.8.7 O CTS 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters:.- Operating The Trainand Train inverters shall be.OPERABLE. DOC M01 LCO 3.8.7-------- ----7------7 -- -NOTE--- ----------------------- -[,[One/two] inverter[s] may bedisconnected from [its/the r] associated DC bus for < hours to perform an equalizing# charge on [* stsheir]asstoiate [common].battery provided: a. Th. associated AC vital bus.(es) [is/are] energiz d from [its/their] [Cl ss 1 E constant voltage source transformers [inverter using'in rnalAC source] and b. I other AC vitalbuses are energized from th ir associated PERABLE inverters.. 0 0 I-DOC Mo0 APPLICABILITY: MODES 1, 2, 3, and 4.ACTIONS'CONDITION REQUIREDACTION COMPLETION TIME DOC M01 A. One [req ired] inverter inoperable. A.1 ---- ------NOTE -------- r ------Enter applicable Conditions, and Required Actions of LCO 3.8.9, "Distribution Systems- Operating". with any vital busde-energized. 120 VA-0 Restore inverter to OPERABLE status.24 hour.4--1 3+ -4 N~t({llII DOC M01 Required Action and F1 -Be in MODE 3. 6 hours.associated Completion. Time not met. AND 2[ Be in MODE 5. 36 hours 0 0 0 0 BWOG STS 3.8.7-1 Rev. 3.0. 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 245 of 323 Attachment 1, Volume 13, Rev. 1, Page 246 of 323 3.8.7 O INSERT I DOC M01 B. Two inverters in one B.1 Restore one inverter to 8 hours train inoperable. OPERABLE status.I 0 Insert Page 3.8.7-1 Attachment 1, Volume 13, Rev. 1, Page 246 of 323 Attachment 1, Volume 13, Rev. 1, Page 247 of 323 Invertes -Operating 3.8.7 SURVEILLANCE REQUIREMENTS DOC MOI BWOG STS 318.7-2 Rev. 3.0,,03/31/04 Attachment 1, Volume 13, Rev. 1, Page 247 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 248 of 323 Attachment 1, Volume 13, Rev. 1, Page 249 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 249 of 323 Attachment 1, Volume 13, Rev. 1, Page 250 of 323 Inverters -Operating B 3:8.7 B:38 EILECTRICAL POWAER SYSTEMS B:3.8.7 Inverters -.Opercating BASEs BACKGROUND The inverters are the preferred source of power.for the4AC-vital buses 10 because of the stability and reliability they achieve. The function'of K inverter is to.provide AC electrical power to thekital bus. The inverterslassociated nverter Lcan be powered from an internal AC source/rectifier or from the station2 VAC battery' statio atte provides an uninterruptible power source for the instrumentation and controls for the Reactor Protection System (RPS)and the ESafety Featur Actuation System 4ESFAS). Specific Setin details on inverters and their operating characteristics are:found in*FSAR,..Cha er 8 (Ref. 1). j (R APPLICABI SAFETY ANALYSES The initial conditions of Design.Basis Accident (DBA) and transient section 15 anal sesin th FSAR,:. ,apter 6](Ref. 2)M 1 and IChatr [14] Ref. 3), ,-(assume Engineered Safety Feature 4 systems are OPERABLE. The I QJ S inverters are designed to.. provide the required capacity, capability, Section 6 redundancy, and reliability to ensure theavailability of.necessary power to the RPS and [SFAS instrumentation and icontrols so that the fuel, 0 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 1 (D OPERABLE during accident conditions in the event of: a. An assumed 'loss of all offsite AC electrical power or all onsite AC electrical powereand b. A worst-case single failure.electdical power]Inverterslare a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 0 0 LCO The inverters ensure the availability o C electrical power for the.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.0 BWVOG STS B 3.8.7-1'Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 250 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 251 of 323 Attachment 1, Volume 13, Rev. 1, 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.designh of the RPS and Q irnstrurnentatio-and controlsis maintained. The four invertersM(two per 2',train)]ensure an uninterruptiblebsupply:of ACeliectrical power to the 120 V, (Th vital buses even if the 4:16 kV saey buses are .de-energized. OPERABLE inverters require the associatedv'ib o be powered by'the inverter'with output;vo1tage and frequency within tolerances, and power input to the inverter batterY. Alternatively, K) Q power supply may be froman [t .AC source~via rectifier as, long as.the station battery is available as the uninterruptible power supply:' or battery chargeri (D)This LCO i modified by a Note that allows.[one/two] 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 'othrr inverters are operable. This allows an equalizing chargeto. be plac d on one battery.If the ihV rteswere not'disconnected, the:, resulting v tage condition might da ge the inverter[s]. These provisions mini ize the loss :of equipm t that would occur in the event of a loss of o site power. The.24 hour ime period-for the allowance minimizes the tme during which a loss.of, ffsite power.could result in the loss of equip ent energized from the affe ted AC vital bus while taking into considerat on the time required to perf rm an equalizing, charge on the battery, bank The in ent--of this Note isto limit the number.of inve ters that. may be disco nected. Only those inverters associated wit -the single. battery undo oing an equalizing charge may be disconne ed. AILother inver ers must be aligned to their associated batte ies, regardless of the num erof inverters or unit desiqn..0 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 ofAOOsor abnormal transients tand b. Adequate:core cooling is provided,and containment OPERABILITY 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:." and other conditions in which[inverters are required J 0 0 0O BAOG STS B 3.8.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 252 of 323 Attachment 1, Volume 13, Rev. 1, Page 253 of 323 Inverters -Operating B 3.817 BASES ACTIONS 6.11 Train 1 or Train 2 unless With a reir ter inoperable, its associatedACvital bus becomes: inoperabli u til tis [man liyTre- enlergized from itsM lass I E constant }. 2 v oltage0 s transformrnorinverter usin -iernal Asource j this reason, a Note has; been includedinh Condition A'requiring entry into the Conditions and Required Actions of LCO 3.8..i that proper action ISy'tems Ope tin ." This ensuresf vital bus is l-i6"eraizedw for ade-energized..,. .. * ..T '. .1r20 VAC deenrge i Required Action A. 1 allows 24 hours to fix the inoperable tae inverter and return it to service. The 24 hour limit is based upon, 6 engineering judgment, taking into1 consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the. inverter inopeprability. This has. to be .balanced against the, risk .of an immediate shutdown, 'along with the potential challenges to safety " 201____.__ systems such a shutdown might entail. Wen the\C\vital bus is powered fromiJts constant voltý s itis relying upon interruptible AC 0 ereectrical power sources.(offsite and onsite). The. uninterruptible inverter source to the C vital bUses is the preferred source for powering instrumentation trip setpoint devices.t!T3 2) ýan d K-2 nrl 0 0~Train 1 or Train 2 inverters] 'If the inoperable de vices or com 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 achievethis 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 anorderly manner and without challenging plant systems.SURVEILLANCE REQUIRFMFNTS SR 3.8.7.1 This Surveillance verifies that the inverters are functioning, properly with all required circuit breakers .closed andACA vital, buses energized from the 4D .Qinverter.

• The verification of proper voltage and frequency output ensures tat e required.

power, is readily available for the instrumentation of the.RPS and S FAS connected to the4AC vital buses. The 7 day Frequency 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 theluninterruptible power supply. I 0 0 0 0 BVWOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 253 of 323 Attachment 1, Volume 13, Rev. 1, Page 254 of 323 B 3.8.7INSERT 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.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.0 0!nsert.Page B 3.8.7-3 Attachment 1, Volume 1:, Rev. 1, Page 254 of 323 Attachment 1, Volume 13, Rev. 1, Page 255 of 323 Ihvertersm -operating B 3.8.7 BASE.S REFERENCES

1. FSAR,har [8.-f eco8 2 FSAR,.--h

[6 3. FSAR,:e 00 BWOG STS B 3.8.7-4 Rev.3.01, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 255 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 256 of 323 Attachment 1, Volume 13, Rev. 1, Page 257 of 323* Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 13, Rev. 1, Page 257 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 258 of 323 Attachment 1, Volume 13, Rev. 1, Page 259 of 323 ATTACHMENT8 ITS 3.8.8, INVERTERS -SHUTDOWN S 0 Attachment 1, Volume 13, Rev. 1, Page 259 of 323 Attachment 1, Volume 13, Rev. 1, Page 260 of 323 pCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 13, Rev. 1, Page 260 of 323 Attachment 1, Volume 13, Rev. 1, Page 261 of 323 ITS 3.8.8 ITS A-dg p e I3of.8 Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 261 of 323 Attachment 1, Volume 13, Rev. 1, 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 0 None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 262 of 323 Attachment 1, Volume 13, Rev. 1, Page 263 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 13, Rev. 1, Page 263 of 323 Attachment 1, Volume 13, Rev. 1, Page 264 of 323 Inverters -,:Shutdown 3.8.8 O CTS 3.M ELECTRICAL POWER SYSTEMS, 3.8.8 :Inverters -Shutdown 0 DOC M01 LCO 3.8.8[inverters hail beýOPERABLE'to support the onsite lass IEACvital bus elei rical power distribtion subsystem(s).req

• red by LCO 3.8.10,*Distr' ution Systems -Shutdown."]

0 0 , -to support the 120 VAC vital electrical distribution MOneM inverter [ shall be OPERABLE Isubsystem required by LCO 38.10, Distribution [Systems-Shutdown." I-- ----------- -.......... REVIEWER'SNOTE

---

----------

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 lis case. The first.option a 6ve is adopted for plants thathavea CTS r qui'ring the Same level of DC electrical power subsystem/inverter suplort as is required. for;power perrating conditions. 0D APPLICABILITY: MODES 5 and 6, During movement of cenirradiated fuel assemblies. 0 ACTIONS------------------ NO LCO 3.0.3 is not applicable, CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A, One [or ýore] equirecd]inverterN inoperable. A.A /eclare affected required /Imme.diately Afeature(s) inoperable. /2,A../uspend CORE /Immediately [ LTERATIONS /0@DT BW\OG STS 38.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 264 of 323 Attachment 1, Volume 13, Rev. 1, Page 265 of 323 Inverters -.Shutdown CTS ACTIONS ,(continued) CONDITION R REQEDA-1ACTION COMPLETION TIME DOC M01 A.M- Suspend movement of[recnty irradiated:fuel assernblies. A2 Su-spend operations involving positive reactiyity additions that could result in loss of required SDM or-boron concentration. AIX ate,,actinto restore required invetterg to OPERABLE status.Immnediately 0©TSF(Immediately Immediately TST-47 0 0 0 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE: FREQUENCY DOC M01 SR 3.8.8;1 V orrect inverter Voltage, Tfrequency nd/aignmenri to 'C vital bus;" " 7 days for the required theassociated inverter, 2 BV\OG STS 3.8.8-2 Rev. 3.01, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 265 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 266 of 323 Attachment 1, Volume 13, Rev. 1, Page 267 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 13, Rev. 1, Page 267 of 323 Attachment 1, Volume 13, Rev. 1, 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.descriptionmof the inverters is provided in the Bases for:LC`O 3.8.7, lnverters -Operating." APPLICABLE The initial conditions of Design Basis Accident (DBA) and tranEsientSection 15}SAFETY analyses in'th FSARaater [6(Ref. 1) andlChaptr [141 (Ref. 2)_, ( 2 ANALYSES assume Engineered Safety- Featurelsystems are OPERABLE. The DC to UFSAR, AC inverters are designed to provide the required capacity, capability, LJ Section 6redundancy, and reliability to ensure the availability of necessary power .to.the Reactor Protection System and Snaiere' Safety Features Actuation System.(NSFAS)iristrumentation and controls so.that the fuel, Reactor 0*(RS) Coolant Syste , 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. required120 V The OPERABILITY of~the rreimuc inver e.!,AC vital bus during 0 (0 MODES 5'and 64ensures that: and during movement of irradiated fuel assemblies 0.a. The unit can be maintained in the shutdown or refueling condition.for. extended periods b. Sufcin 0 171(:b. Sufficient instrumentation and control capability is' available forýmonitoring and maintaining the'unit status and c. Adequate power is available to mitigate events postulated..during shutdown, such as a fuel handling accident [involvi an iing recently irradilate/ fei. Due to radioatie ecay, 6~ inverters are only required to mitigate fuel handling-.accidents in/olving handling (recently: irradlia/ed fudel (i.e., fuel that has bccupie ýpart of a.critical reactor core: vthin the. previous [X] 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 alloffsite or all onsite power is not required.The rationale for this is based on the factthai many DBAs that are ahalyzed in MODES [1_.2,.3, and 4Mljhave. no specific analyses in (I BWOG STS B 3.8.8-1 Rev. 3.0, 3/31/04: Attachment 1, Volume 13, Rev. 1, Page 268 of 323 Attachment 1, Volume 13, Rev. 1, Page 269 of 323 Inverters -,Shutdown B 3.8.8 BASES$APPLICABLE SAFETY ANALYSES (continued). MODES)5 and,6lbecause the:energy contained within the reactor pressure boundary, reactor coolant temperature, and pressure, andthe.corresponding stresses result ir ithe probabilities of occurrence being significantly reduced or eliminated, andlin minimal consequences. These deviations from DBA analysis assumptions and de'sign 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 atan'acceptable low level.. This may require the availability. of additional equipment beyond that required by the shutdown Technical Specifications. r-7--{ eectrcalpower] The inverters were previously identified as part. of the.distribution. system 0 and,. as such, satisfy Criterion 3 of 1.0 CFR 50.36(c)(2)(ii). LCO The invertelHsJ ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe.condition after an anticipated-operational occurrerce or a postulated DBA.. The"bafttery, owered inverte4I} provideH y:- uniner upibe supply of AC electrical power to theAC vital buses Jif the 4.16.kV safe-ty are de-energize .OPERABILITYo e 120V inverter[] requireta e viba us w5ered by the inverter .This (ensures the avai ability of sufficient inverter power sourcesto:operate the unit in.a safe manner and to mitigate the consequencesof postulated events during shutdown (e.g,, fuel handling accidents involvirg andlingj Irecently fuel]"the 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 stationl 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 '-0 O BWOG STS B 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 269 of 323 Attachment 1, Volume 13, Rev. 1, Page 270 of 323 Inverters -Shutdown B 3.8.8 BASES APPLICABILITY The inverter[M required to be.OPERABLE in MODES;5 and 6 and during movement of rn irradiated fuel assemblies.provide assurance that:.a. Systems: to provide adequate coolant inventory makeup ,are~availabie for the irradiated fuel in the (I b. Systems, needed to mitigate a fuel handlin accident [involving handling recenoy irradiated fuel ,(i~e., fuel that-has/occupied part of aI critical reator/core within the. previous [XI days)]Iare, avaikable%.

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

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

Inverter requirements for MODESi, 2,3, and 4 are covered in LCO 3.8.7.42 0 0 0 0 ACTIONS LCO'3.0.3 is not applicable~while in MODE 5 or 6. However, since irradiatedfuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note statingthat LCO 3.0.3 is not applicable. If movingirradiated 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 LCQ 3.0.3, while in MODE 1, 2, 3,or4 :Would require, the unit to be shutdown unnecessarily. JA.A.2.1 .A.2.2, A.2.3 ndA.2,4 A.1,A.2,andA.3 T2T 0[If two trains are rluired 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 -(-JALTE0RATIONS /uel movement [involving handlin recently irradiated fuel], and opera ons with a potentialfor positive r activity.additions that could result in I ss 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 limitis 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 0 BVWDG STS B 3.8.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 270 of 323 Attachment 1, Volume 13, Rev. 1, Page 271 of 323 B 3.8.8 OINSERT I 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. 1, Page 271 of 323 Attachment 1, Volume 13, Rev. 1, Page 272 of 323 Inverters-Shutdown B 3z8.8 BASES ACTIONS (continued) concentration, but provides acceptable margin to maintaining subcritical m operation,

Introduction:

of temperature changes including temperature etemperature increases When operating with a positive MTCi3riust also be evaluated to 0 coefficient ( ensure theye"do not~result in..a loss:of required SOM.I By~the- a!!ovvnce'of/-the opption~to.d ec are required features inoprabe With the a~ssociaed inverte~r(s ) inoPe able,.appropriate restrictions, wi!!e implemented in accordance witl the affected required features L QOs': Required Actions Q imdite intiont 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 inverter1] Should be.completed as quickly: a s possible in order to classlE the time the unit safety systems may be without power or powered-from a constant voltage so rc ' or non-essential power'source] URVEILLAN .E R 3.8.8e'REQUIREM ENTS S .81e r fu nct 0 T h is S u r v e illa n c e v e r if ie s t a t h n v e r te r I ao in p r o p e r ly w it h finverter may be connected all-required circUit breakers closed and,$"C vital energized 'from the lits associated rectifier as long as inverter. fThe verification of-proper voltage and frequencyoutput ensures (that the required power is. readily available for the instrumentation s l eh batter is avilbl as ethe e te unt lconhected to theCvital bus. The 7 day Frequency takes into account prp the re undant ca a f the inverters and other indications available in 0 the control room thatalert the operator to invtert malfunctions. REFERENCES 1.eFSA R, toal ster[] Iec tion6 0 t 2. FSAR, C .[]-cton15 B WnO G s T s B 3 .8 .8 -4 R e v .3 .0 , 0 3 /31 /0 4 Attachment 1, Volume 13, Rev. 1, Page 272 of 323 Attachment 1, Volume 13, Rev. 1, 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 5.1.3.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 273 of 323 Attachment 1, Volume 13, Rev. 1, Page 274 of 323 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 13, Rev. 1, Page 274 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 275 of 323 Attachment 1, Volume 13, Rev. 1, Page 276 of 323 ATTACHMENT 9 ITS 3.8.9, DISTRIBUTION SYSTEMS -OPERATING 0 0 Attachment 1, Volume 13, Rev. 1, Page 276 of 323 Attachment 1, Volume 13, Rev. 1, Page 277 of 323 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 13, Rev. 1, Page 277 of 323 Attachment 1, Volume 13, Rev. 1, Page 278 of 323 ITS 3.8.9 0 ITS F LECTRICAL POWER SYSTEMtS.3/ý4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A rn!iýZT0TQ"T~n -fltqATr.Nr LIK1-,tL-a=OI40IT[O14 FOR OPERATION (Train I and Train 2 AC and AC vital LA02 power distribution subsystems 3:9. 2 .1 11 he Q C, electrical ss s shall be OPENABLE and jeneegized wýth tie b tween r undant busses: LCO 3.8.9 ACTIONS A and B ACTION D SR 3.8.9.1 I 4160 ýalt Ess ntlal Bu # C!4160 volt~ Ess ntial Bu 4, 0 48 0 volt Ess ntial Bu 0 Elý480 vol't Es ential t S # Fl 1 2 vo It A. .Vital us Y 1 12 volt A. Vi tal us 4 Y12 12 Volt A. V VitalI Bus I y3 12 volt A C. VitalI Bus I Y14 I I I , APPLCA8(LrTY: MODES 1, 2, 3 and 4.ACT -O-j ACTION A Note With less than the above complement of A.C. busses OPERABLE, restore the inoperable bus to OPERABLE status within.8 hours/ar tie in at least HOT ISTANOBY within the next 6 hours and in COLD SHUTDOWN within the folicwiini-L3_ hours.Add proposed ACTION E -SURVEILLANCE REgUIREMENTS E 4...2.1 [he specified A.C. busses shall be de.tena n.er OE L a el LiA lreae r5 gen between redun t sssa ýeast once per P--ays PT-y ve =, : in corc reak.er aligmn ayi~~U nal iridia1~~ed power avasyabilitA. voltage. M02 DAVIS-BESSE, UN~IT1 3/4 8-6 Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 278 of 323 Attachment 1, Volume 13, Rev. 1, Page 279 of 323 ITS 3.8.9 ITS ELECTRICAL POWER SY ISTEMS L0 D.C. DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION electrical power distribution subsystems LA01 raino an Tr n 2 __." X LCO 3.8.9 ACTION C ACTION D 3.8.2.3 The following D.C. [bu i shall be ene ize ,an OPERABLE Lwith discOn-ng?_,switches between busz4rains open: IN "A" cpsistins of 250/125-voft D.C. MCC ,II25-volt D.C.L station batteries IP and IN and 2 full capacitychargers. ITRAIN "B" cads~isting.-of 250/125-vgft D.C. MC:C 05-v -12 i0tD.C. L0 Istation batteries 2P and 2N and 2 full capacityichargers..APPLICABILITY: MODES 1, 2, 3 and 4.. IS384 ACTION.: 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 urs or be in at least HOT STANDBY within the next 6 hours andODSHTDOWN within the following* 30 hours.[ AdpopsdCTO E0 b. With only one 125-volt D.C. battery or only one charger. of one MCC OPERABLE, restbre the inoperable battery or charger, 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.See ITS 3.8.4J SR 3.8.9.1 SURVEILLANCE REQUIREMENXTS 4p.8r2.3.1 Each D.C. bus train shalr be determined OPERABLE tand/enerbized 1with disconng-f switches open between redundant at least once.. per {7 days by verifying correct disconnect switch/breaker a Iligament, lic Pe iPower avaijli~lity from the chargef and batter-A, and voltage. on the bus n LAO3)lot Rreaterttban or eoual to 125 volts D.0.4.,8.2.3.2 Each 125-volt battery and 'charger shall be demonstrated See a AtlaS 3 .8.od as. At least once per 7 days by-. {.I. Verifying that the para Category A limits, and meters in Table 4,.8-w meet the See ITS 3.8.6 J DAVIS-BESSE-, UNIT 1 3/4 8-8 Amendment. No. 100 Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 279 of 323 Attachment 1, Volume 13, Rev. 1, 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-1 430, 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. 1, Page 280 of 323 Attachment 1, Volume 13, Rev. 1, 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 LA0i (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. 1, Page 281 of 323 Attachment 1, Volume 13, Rev. 1, 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 1 -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.0 Davis-Besse Page 3 of 4 Attachment 1, Volume 13, Rev. 1, Page 282 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 283 of 323 Attachment 1, Volume 13, Rev. 1, Page 284 of 323 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)S 0 Attachment 1, Volume 13, Rev. 1, Page 284 of 323 Attachment 1, Volume 13, Rev. 1, Page 285 of 323 Distribution. Systems -Operating 3.8 ELEC:,TRItCAL POWER,,SY'STEMS 3.8.9.Distribution Systems -Operating 3.8.2.1, 3.8.2,3 LCO 3.8.9 Train TrainAC, DC, and AC:vital bus electrical powerdistribution subsystems shall be OPERABLE.0 APPLICABILITY: MODES! 1, 2, 3, and 4.ACTIONS 3.8.2.1 Action 0 CONDITION REQUIRED ACTION .,COMPLETION TIME A. One:or more AC ------------------ NOTE-electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO,3.84, "DC inoperable. Sources -Operating," for DC tr ns made inoperable by inoperable s power, distribution subsystems. A.1 Restore AC electrical power 8 hours distribution subsystem(s) -to OPERABLE status.0 3.8.2.1 Action B. One or more AC vital buses inoperable.(es)B.1 Restore AC vital bus, sus ems to OPERABLE status.hour's 00 3.8.2.3 Action a C. One o DC C.1 Restore DC electrical 2 hours electrical power power distribution distribution subsystems s ubsystermM to inoperable. OPERABLE status.0 BWOG STS 3.8.9-1 Rev. 3.1,12/01/05 Attachment 1, Volume 13, Rev. 1, Page 285 of 323 3.8.2.1 Action, 3.8.2.3Action a DOC M01 4.8.2.3.1 Attachment 1, Volume 13, Rev. 1, Page 286 of 323 Distribution Systems -Operating ACTIONS (Contihued) CONDITION REQUIRED ACTION COMPLETION TIME.D. RequiredtAction and D.1 Be in MODE 3. 6 hours.associated Completion Time not met ANDion A, 8. or C]D.2 Be: in MODE 5. 36 hours E. Two or more electrical E.1 Enter LCO 3.0'.3. Immediately power distribution subsystems inoperable that result in a loss of fyun.ction,. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.:01 Verify correct breaker alignments and voltage to 7 days Nrequired]AC,. DC, and:AC vital bus electrical power, distribution subsyste ms.0)0 BWOG STS 3.8.9-2 Rev. 3.1, ,1201/05 Attachment 1, Volume 13, Rev. 1, Page 286 of 323 Attachment 1, Volume 13, Rev. 1, 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 forPlant-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.a Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 287 of 323 Attachment 1, Volume 13, Rev. 1, Page 288 of 323 WImproved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 288 of 323 Attachment 1, Volume 13, Rev. 1, Page 289 of 323 L All changes are Distribution.

Systems- Operating unless otherwise noted B 3.8.9 B3..8 EýLECTRItAL POWER SYSTEMS B: 3.8.9 EDistribution ýSystems -Operating BASES.BACKGROUND The onsite Class , E.AC, DC, and AC via buus electrical power distribution system areý divided by train into[gtwo6]redundant and: independent AC, DC,, andA C vital bus electrical power distribution subsystems. The AC electrical power subsystem for. each'train consists of a primary jEngineered S Feature .(ESF-) 4.16 kVMbus and secondaryfM480 and_ (( t T 1 2iV buses, distribution panels, motor control centers and ioad centers, Each E4,16 k f busM1J haslatleast separate and independent.offsite source of powefas Well as a dedicated onsite iesel generator q__.G) source. EachM4.1-6 k-TW bus is normally connected to.a remergency preferred offsitesource. Aftera loss the power source to a bus, adtransfer to the~alternate offsite source is accomplished by utilizing a tir e delayed bus unde olta e rela[. If all (?effsite sources are unavailable, the:.onsite ý DG'supiplies power to the 4.16kV' bus. Control power for'the 4.16 k ea 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, "DCSoqurces -Operating,'. The Cecoda AC electrical, power distribution subsystem for each train includes the safety related buses oa centers, r control centers, land distr!ion panelsishown in Tableý B 38.9-1.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 LCO3.8.7, ",Inverters -Operating..' Each constant voltage source transformer is powered from a Class 1 E AC, bus. _mot2orontrolce The DC electrical distribution subsysterm, consists.06 25M bus~stýg (MCC), and each Idistributffo panelsfe(sa i 2501125 VDC MCC h train consists ./The list of all required DC andvital AC]distribution buses a is presented in Table B 3.8.9-1..O BVOG STS B 3.8.9-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 289 of 323 Attachment 1, Volume 13, Rev. 1, Page 290 of 323 Distribution Systems' -Operating B 3.,89 BASES~on6 APPLICABLE .-LThe initial conditions iflDesign Basis Accident (DBA) and transien Section 15 SAFETY '---analyses in the FSAR,C(ef

1) andlhap r 2.),---- .1 ANALYSES assume+ES systems are OPERABLE.

The. AC DDC and AC vita.l bus En aetatures electrical power distribution systemrsare designed to provide suffici ent E n i e e e S ae t F e t r s ,] ..... ......- , .. ... ......... ..capacity, capability,, redundancy,, and reliability to ensure the availability of necessary power to ESF systems so thatthe fuel,. Reactor *Coolant',System, and containment design limits' are not exceeded. These.lifiitS are discussed in more detail in the Bases for Section 3.2, "Power Distribution Limits," Section 3.4, "Reactor Coolant (RCS)," and Section :316, "Containment Systems." The OPERABILITYofthe AC, DC, andAC 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 ofa; An assumed loss of all offsite power or all onsite AC electrical power and b. A worst-case single failure.The distribution systems satisfy Criterion 3'of 10 CFR. 50.36(c)(2)(ii). 0 LCO Th'e required power distribution subsystems listed in Table B'3.8.9-1 ensure the availability of AC, DC, and AC vital bus electrical powerfor the systems.required to shut down-the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or, a portion of the buses listed in postulated DBA. The AC, DC, and AC vital. bus electrical power Table B 3.8.9-1 power distribution subsystems are: required to be,OPE RABLE, essential loads and are not Maintaining the.Train i [ Train [ , DC, and AC vital bus electrical power distribution subsystems OPERABLE ensures that the redundancy systemsincorporated into the design of ESFis not defeated. Therefore:,a single failure within any system or within the electrical power~distribution subsystems will not prevent safe shutdown of the reactor..0 OPERABLE ACelectrical: power distribution subsystems require the associated busesl, load centers, ,otor control centers. W distribution] (3 aeto be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses LI-d]I distr ution p Ane s to be energized to their proper voltage. from either the c (associated battery' or charger. OPERABLEhvital bus electrical power distribution subsysterns.require the:associated buses to be energized to their proper voltage from the associated ]inverterkvia invertedtDC voltageg " linverter Oing internal source, or Class 1 E constant voltage 125 transformerl] BVVOG STS B 3.8.9-2 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 1, Page 290 of 323 Attachment 1, Volume 13, Rev. 1, Page 291 of 323 Distribution, Systerms -Operating B 3:8'.9 BASES LCO (continued) T1 --f and disconnect switches N Inaddition, tie breakers between redundant safety related AQ,. DC, and e AC vital bus1power di'stibutiori subsyste must be open.This prevents any.eiectrical malfuhntion in any power distribUti6n " subsystem from. propagating to the; redundant subsystem, thatcould cause the failure of a redundant subsystem and a loss of essentialVsafety For disconnect] that are not being powered function(s). If any tie breaker4are.closed, the afec e redudan C (i.e., they are being powered electrical power distribution'subsystems ere considered inoperable. Thisl from their redundant .applies to the onsite, safety related redundant electrical power.distribution electrical power distributionem) subsystems. It doesnot, however, preclude redundant Class 1E 4.16 kV buses from being powered from the: same offsite circuit. (Dj 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 bo.undary limits are not exceeded as~a. result of.AOOs or abnormal transients and b. Adequate core. cooling is provided, and containment OPERABILITY andlother vital functionsi are maintainied in the event of a postulated DBA. and other conditions in which electrical [power distribution subsystems are required Electrical power distribution subsystem requirements for MODES :5 and 6*are covered in the Basesý for LCO .3.8.1 0, 'Distribution Systems -Shutdown.," ACTIONS AA.ramin 2 distribto "r With one or more Train[&and required AC buses, )ad centers moor S distribution I L " :. .. ...,. '.. ..subsystems 1control cerers, or istriuon pane s 'except AC vital buses), o rain inoperable and a loss of function has not-occurred, the remaining AC electrical, power distributionsubsystems are.capable of supporting the.minimum safety functions necessaryto shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The.overall reliability is reduced,. hwever, because a. single failure in the er remainin power distribution'subsystems could result in the minimum.electrica power required ESF functions:not being supported. Therefore, the -required AC distribution buses, load centerg motor control centers, an istriution pane must subsystem(s) be restored to OPERABLE status within 8 hours..0 0 0 0 0 0 BWOG STS B 3.8.9-3 Rev. 3.1, 12/01105 Attachment 1, Volume 13, Rev. 1, Page 291 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 292 of 323 Attachment 1, Volume 13, Rev. 1, Page 293 of 323 Distribution Systems- Operating B 318.9 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). Inmthis Condition,'the Unit is more Vulnerable to a complete loss of AC power. It is, LJ'therefore, imperative that the unit operator's attention be focused on.minimizing .the potentialfor loss of power to the :remaining train by stabilizing the unit, and on restoring power to.the affected train. The& hour time limit before requiring a unit shutdown in this Condition is acceptable because of: a: The potential for decreased safety if the unit operators attention is diverted from the evaluations and actions necessary to restore power to the affected train to the actions associated withtaking the unit to shutdown within this. tim e limit nd J b. The, potential for an event in conjunction With a single failure Of a redundant component in the, train with AC power.Required Actioh.A;l ismodified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.A, "DC Sources -Operating," Eii1to be enteredrfor DC!rj made inoperable by inoperable power "(distribution subsystems. This is an exception to LCO 3.0.6 and ensures the. proper actions are: taken for these components. Inoperabilityof 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 powerto 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 krequiredcTAC Vital bus mustbei restored to OPERABLE status within 0 8 -hours by powering the bus fromtheassociated Jinverter ia inverted.[2 Dq, inverter Vsing internal ource.or Class 1E constant voltage transformer, t otg ,i B\AOG STS B 3.8.9-4 Rev. 3.1, 12/01/05;Attachment 1, Volume 13, Rev. 1, Page 293 of 323 Attachment 1, Volume 13, Rev. 1, Page 294 of 323 Distribution Systems -Operating B 3.8.9 BASES ACTIONS (continued).Condition B represents one or more AC vitalbuses without power;potentially both the DC source and the associated ACsource are nonfunctioning. In this situation the unit is significantly more vulnerable to Pa 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.8 This. hour limit-is more conservative than Completion Times allowed for 0 the vast Majority of components that are without adequateavital 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 than hours if declared inoperable, is~acceptable because of: (3 a. The potential for decreased.safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable, operations to continuef b. The potential for decreased safety by requiring entry into numerous applicable Conditions and RequiredActions 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. train and, c. The potential for.an event in conjunction with a single failureof a redundant component. The hour Completion Time takes into account the importance to safety 0 of restoring the ACvital bus to OPERABLE status, the redundant. capabilityafforded by the other OPERABLE Vital buses, and the low probability of a DBAoccurring during this period.electrical C. 1 power C____1 distribution subsystem VWith one or or DC uses is ibutiorypnelslinoperable, and a loss: ( (of function has not yet occurred, the remaining DIC electrical power distribution subsystem"rf capable of supporting.the minimum safety functions necessary'to shut down the reactorand 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 electrical functions not being supported. Therefore, the DC bu es d power distriution nelsmust be restored to OPERABLE status .within 2 hours distribuOnem by powering the bus from the associated battery or charger.BWAOG STS B 3.8.9-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 294 of 323 Attachment .1, Volume 13, Rev. 1, Page 295 of 323 L All changes are Distribution Systems -Operating unless otherwise noted B 3.8.9 BASES ACTIONS (continued) electrical power distribution subsystem Condition C represents oner DC buses. Ord strbu*without.adequate. DC power; potentially both With the, battery significantly degraded-and the associated Charger nonfunctiohing, In this situation, the unit is significantly more;vulnerable toýa 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 powerlto the affected train.This.2? hour limit ismore conservative than Completion Times allowed for thevast majority of componentsithat are without power. Taking exception to LCO 3.0.2 for components without adequate DC power,. whichwould have Required Action Completion Times shorter than2.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 c3(operations to continu.b. Theý potential for decreased safety by requiring entry into, numerous applicable Conditions and. RequiredActions 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 traineand c. The potential foran 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, orC is notýmet If the inope.r .ale distribution subsystem can fot be restored to OPERABLE: status within the required. CoApletion 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 MODE3 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 3.8.9-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 295 of 323 Attachment 1, Volume 13, Rev. 1, Page 296 of 323 I All changes are 0'i unless otherwise noted J DistributionSystems, -Operating B 3.8.9 BASES.ACTIONS j(co.ntin u.ed)E.1 Condition E. corresponds to a level of degradation in the. electrical distribution sysfem that -causes: a r.equired 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 additionaltime is justified for continued operation. LCO 3.0'3. must be entered immediately to commence a controlled shutdown-SURVEILLANCE .SR 3.8.9.1 including tie breakers open REQUIREMENTS R between redundant buses, This Surveillance.verifies that thelrequiredTAC, DC, and AC vital, bus (which includes all types of electricalpower are functioning properly withthe 0 circuit breaking devices) correct circuit breaker alignment. The: correct breaker alignmen nsures the. appropriate separation and independence, of the :electrical divisions is maintained, and the appropriate, voitage isavailable. 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 systemloads connected to these buses. The7 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 qual to 125 V 1C. subsystem malfunctions; REFERENCES 1., FSARhaier[6. c 2. "2. FSAR, chapker [14,.3. Regulatory Guide 1.93, December 1974.0 0 BWAOG STS B 3.8&9-7 Rev. 3.1, 12/01/05 , Attachment 1, Volume 13, Rev. 1, Page 296 of 323 Attachment 1, Volume 13, Rev. 1, Page 297 of 323 All changes are a unless otherwise noted DistributionSystems -Operating B 3.8.9 TableWB 3.8.9-1 (page 1 of 1)AC and DC Electrical Power Distribution Systems TRAIN TYPE, VOLTAGE essentiauses ACs1y ue$4160 VC$480 V]Load ente rs[NGO1,\NG03]l Moto control Ce ters[NG01 , NG01 I, NG01 B, NG03C, NG031, :G03D]Distribu n Panels[N P01, NP03]TRAIN VD f---Essential Load enters Bus El[NG02\NG04] Eh----ina Motoý Control C eters,NG021, NG02B, NG04C, NG04i, G04D]Distribupon Panelsj[NP02\,NP04] DC buses~F25--Bus[ KO3]Distribu on Panels[NK41, N 3, NK511]Bus K02]Bgus K04]M Distribu\iOn Panels[NK42, N44, NK52]1 BusN Bus [N 04]Y4 AC vital buses, M120'V Bus ý[N 01]Each train of the AC and DC electrical power distribution systems is a subsystem. BVVOG STS B 3.&9-8 Rev. 3.1, 12101/05 Attachment 1, Volume 13, Rev. 1, Page 297 of 323 Attachment 1, Volume 13, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 298 of 323 Attachment 1, Volume 13, Rev. 1, Page 299 of 323 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 13, Rev. 1, Page 299 of 323 Attachment 1, Volume 13, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 300 of 323 Attachment 1, Volume 13, Rev. 1, Page 301 of 323 W ATTACHMENT 10 ITS 3.8.10, DISTRIBUTION SYSTEMS -SHUTDOWN 0 0 Attachment 1, Volume 13, Rev. 1, Page 301 of 323 Attachment 1, Volume 13, Rev. 1, Page 302 of 323*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 13, Rev. 1, Page 302 of 323 Attachment 1, Volume 13, Rev. 1, Page 303 of 323 IITS 3.8.10 0 ~IT.SS ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION -SHUTDOWN rn~hIT~NFOR OPER TIO Te necessar portions of te LIMITINGCODTO OOeRTn7 ICO 3.8.10 3.82.2 AS a minimu following]A.C. electrial busses shaII be OPERABLE:/ / .I and AC vital bus electrical power 4 -46o volt Es ential Bus/ distribution subsystems APPL CABILI TY: MODES s and During movement of irradiated fuel assemblies ACTION: Add proposed ACTIONS Note M02 ACTIONA W t an the above complement of A.C. busses OPERABLE and energized, ,-!ttiabý2i CONTAI.NMEt~- INTEGRITY~u;-itnin 8 -t_,Add proposed Required Action A.2".1' A.2.2, A.2.3, and A'=22'4 }o"'Add proposed Required Action A. 1 M01t SURVEILLANCE REQUIREMENTS SR3.8.10.1 4,8.2.2 The specified AC. busses shal.1 be determined OPERABLE at least once per 7 days by verifying correct breaker alignment and indica powerl voltage M03 DAVIS-BESSE, UNIT 1 3/4 8-7 0 Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 303 of 323 Attachment 1, Volume 13, Rev. 1, Page 304 of 323 ITS 3.8.10 ITS ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION -SHUTDOWN LCO 3.8.10 ACTION A power__ __ __ aiuuins~ssesILAO 1 J- L 0/125-volt D.. ?CC, and See 12.- 125-voit battery banks and chargers supplyingt;he above. D.C. MCC. ITS3.8.5 APPLICABILITY: flODES .5 and 6., During movement of irradiated fuel assemblies ACTION: [Add proposed ACTIONS NoteM0 With less thae the above complement of. DC. ieqipment and bus OPERABLE, LO0 esta bh CONTAINbW INTEGRITY ifhin, 8 hour Add proposed Required Action* AAdd proposed Required Action A.1 SA.2.1 A,2.2, A.2.3, and A.2.4 " SURVEILANCE. RE UIREHENTS ___0 SR 3,8.10.1* 4.8.2.4.1 The above required 250/125-volt D.C. KCC shall be determined LA02 OPERABLEriniVenerlzedl at, least once per 7days by verifying correct disconnect switch/breaker alignment.'inicated:powr ,,!ila-i--i [the charger :and katterl, and-voltage on the bus of aer ttan e ua LA0I Ito 1/25 4.8.2.4.2 ,'The above required 125-volt battery 'banks and chIargers 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 I 0Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 304 of 323 Attachment 1, Volume 13, Rev. 1, 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-1 430, 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 if this 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 O with the conservative additional requirements placed on the electrical power Davis-Besse Page 1 of 5 Attachment 1, Volume 13, Rev. 1, Page 305 of 323 Attachment 1, Volume 13, Rev. 1, Page 306 of 323 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS -SHUTDOWN distribution subsystems, Required Action A.1, which requires the associated S 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 DOG 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 ve rifying 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 t his 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. 1, Page 306 of 323 Attachment 1, Volume 13, Rev. 1, 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 I -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 Procedural Details 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. 1, Page 307 of 323 Attachment 1, Volume 13, Rev. 1, 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 Required Action) 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. 1, Page 308 of 323 Attachment 1', Volume 13, Rev. 1, 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.0 0 Davis-Besse Page 5 of 5 Attachment 1, Volume 13, Rev. 1, Page 309 of 323 Attachment 1, Volume 13, Rev. 1, Page 310 of 323 0 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 13, Rev. 1, Page 310 of 323 Attachment 1, Volume 13, Rev. 1, Page 311 of 323 Distribution ,Systems -iShutdown 3.8.10 CTS 3.8* ELECTRICAL POWER:SYSTEMS 3;8.1,0 Distribution Systems -. Shutdown 3.8.2.2, 3.8.2.4 LCo 3.8.1,0 APPLICABILITY: The necessary portion of.AC, DC,.and AC'vital'bus electrical power distribution subsystems shall be OPERABLE to support:equipment required to be OPERABLE.MODES 5 and 6',1 During movement of [recntyjirradiated fuel: assemblies. 0 D ACTIONS LC. 3.0.3. i- ..ap-p-l.. ------LCO 3.;0.;3,Js not. applicabie. CONDITION REQU.IR:E bACTiOiN COMPLETION TIME 3.8.2.2 Action, A.0 3 8.2.4 Action One or more required AC, DC, or AC-vital bus electrical power distribution subsystems inoperable., A. I Declare associated Immediately required feature(s) -inoperable. OR A.2.1 Suspend C Immediately ALTERATIONS.'-. @D AD A.24.r Suspend movement of ([Fecifiyjjirradiated fuel assemlies. AND A.2. Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. AND Immediately (t)0 Immediately TST 0 BWOG STS 318.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 311 of 323 Attachment 1, Volume 13, Rev. 1, Page 312 of 323 Distributior Systemis -:Shutdown 3.8.10 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 3.8.2.2 Action, 3.8.2.4 Action A.2 -A Initiate acti6ns to restore.required AAC, OC, and AC',ital bus electrical power distribution sdbsystems to OPERABLE status.AND A Declare associated required ,decay heat removal subsystem(s) inoperable and not in operation. Immediately Immediately, TST-47 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 7 days SR 3.8.1.0.1 4.8.2.2, 4.8.2.4.1 Verify correctýbreaker alighnments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems. BWOG STS 318.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 312 of 323 Attachment 1, Volume 13, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 313 of 323 Attachment 1, Volume 13, Rev. 1, Page 314 of 323 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 13, Rev. 1, Page 314 of 323 1 Attachment 1, Volume 13, Rev. 1, Page 315 of 323 Distribution Systems -Shutdown B 3.8.10, 0 B 3.8 ELECTRICAL POW.ER SYSTEMS B 3,.8.1.0.Dbi~s~tributioin System -,Shutdown BASES BACKGROU ND A description of the AC, DC :a.ndAC vital bus electrical power distribution

+ .I

• y, p A -,.vI .zJJ1.1 0, 1 0W V nL~ 1-n.'.. ;tJI L LUIU .+ yL; C:O perating." Section 6 APPLCABL Theini~tial c~ondiutions of, Design.Basis Aiccident,(gBA) and titansient'-

SAET analyses in the FSAR, hae[6lRef

1) andjChap'rDt~r1](Ref.

2), (D 0 ANALYSES assurme Engineered Safety Featureý(ESF) systems are OPERABLE. The*AC, D.C,rand AC vital bus~electrical power distribution.systems are designed to provide sufficient capacity, capability, redundancy, and reliability'to ensure the, availability of necessary powerto ESF systems ýso that the fuel, Reactor Coolant System, and containment;de~sign limits are not exceeded.0 The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution Systems is consistent with the initial assumptionsof the accident analyses and the requirements for the supported systems'OPERABILITY. The OPERABILITY.of the minimumAC, DC, and AC vital bus electrical power distribution subsystems: during MODES 5 and 6, and during movement of Y] rradiated fuel assemblies ensures that:.,a: The unit can be maintained in the shutdown or. refueling condition for extended period,"-.

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit statusindFg--j

c. Adequatepower is provided to mitigate events postulated during shutdown; such as a fuel handling-accident

[invol g handling recentl irradiated fuel. Due o radioactive decay, A', DC, and AC vital bus lectrical power is 6 y required to mitigate f I handling accidents nvolving handling re. ently irradiated fuel:(i.e. fuel that has.occupied rt of a. critical reacto core within the previous X] days)]-The AC and DC electrical power distributionsystems satisfy Criterion 3-of 10 CFR 50.36(c)(2)(ii). 0 0 0 0 BVWOG STS B 3.8.1.0-1. Rev. 3.0, .03/31/04 Attachment 1, Volume 13, Rev. 1, Page 315 of 323 Attachment 1, Volume 13, Rev. 1, Page 316 of 323 Distribution Systems -Shutdown B 3.8.1.0 BASES.LCO Various combinations of subsystems,. equipment, and components are required OPERABLE by other LCOs, depending on the.specificplant condition. Implicit in those requirements is'the required OPERABILITY of necessary support reqUired features. This LCO explicitly requires LýI.ehenergization of the portions of the electricaltdistribution system necessary stoUpport OPERABILITY of required systems, equipment, and ,cormponents -all specifically addressed in each LCO~andr implicitly required via the definition of OPERABILITY.. Maintaining these portions of the distribution system energized ensures the availability of sufficient powerto operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handlin- ently irradiated fuel]).APPLICABILITY The AC-and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement.:of [rec tly]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 [iný olving handling I~cently irradiated fuAi.e., fuel that has.occup kd part.of a 0 Icritical r eakor core within the. p vious [X] days)] are, availablef], c. Systems necessary to mitigate the :effects of events that can lead to coredamage during shutdown are availablea_ .do.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 38.9-.ACTIONS LCO :3.0.3 is not~applicabl ewhile in MODE 5 or6.. However, since irradiated fuel assembly. movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating thatLCO 3.0.3is not applicable. Ifmoving .irradiated fuel assemblies while;.in. MODE 5 or 6, LCO3.0.3 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 l, 2,13, or 4. would require the unit tobe shutdown unnecessarily. BVVOG STS B 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 316 of 323 Attachment 1, Volume 13, Rev. 1, Page 317 of 323 B 3.8.10INSERT I 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.0 Insert Page B 3.8.10-2 Attachment 1, Volume 13, Rev. 1, Page 317 of 323 Attachment 1, Volume 13, Rev. 1, Page 318 of 323 Distribution .Systems -.Shutdown B 3.8.10 BASES.ACTIONS (co0ntinued) Although redundant required features may require redundant trains of electrical .powercdistribution subsystems t0o be OPERABLE, one.:OPERABLE distribution subsystem train may be capable of su -ortin.sufficient required features to allow.continuation of CORE ALTFRATIONS 4 an cent irradiated fuel movement. By allowing the option to declare required features.associated with an inoperable distribution subsysterh inoperable, appropriate restrictionsare implemented in accordance with the affected distribution subsystems:.LCO's Required Actions. In many instances, this option may involve undesired administrative efforts.Therefore, the allowanc.e for sufficiently conservative actions is made (i~e., to suspend[CmREoAL"-RAI IONS, movement of irradiated fuel assembliesw and operations: involving positive reactivity additions that specified in LCO 3.1.1, could result in loss of required SDM (MODE 5)+or boron concentration"SHUTDOWN MARGN(SD)"SHUTDON MARGN (SDM,_ MODE 6)vith coolant/a oron concentrat~io/ns less than required tol 7_specified in LCO 3.9.1 sr eRC bo cnetaini a["Boron Concentration",). Suspension of these activities does notpreclude completion of actions to ,establisf

a. safe conservative condition.

These actions minimize the.probability of the:occurrence:of postulatedevents, It is further required to immediately initiate action to restore the required AC: and DC.eiectrical 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 inoperable. In this case, Required Actions A.2.1 through A.2Ao not -adequately address the concerns relating to coolant Circulationand heat removal. Pursuant to LCO 3.0.6, the DHR ACTIONS would not be entered. Therefore, Required Actioni.A.2 is provided to direct declaring .>DHR, inoperable, which results in taking the~appropriate DHR actions.The CompletionTime 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.BVVOG STS B 3.8.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 318 of 323 Attachment 1, Volume 13, Rev. 1, Page 319 of 323 B 3.8.10 0 INSERT 2 Suspending positivereactivity 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 maintainingsubcritical 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. 1, Page 319 of 323 Attachment 1, Volume 13, Rev. 1, Page 320 of 323 Distribution Systems -;Shutdown B 3.8.10 BASES SURVEILLANCE REQUIREMENTS The voltage of the requiredýDC bus must be greater than or equal to 125 VOC.SR3.8e.10.1 4the correct breaker (which re.uire includes all types of circuit'breaking devices) alignment 40 This Surveillance verifies that:the AC, DC, and ACvital buselectrical power distribution subsYstems are ,functioning properly, witha uses ee .The verification ,of proper voltage availability on the buses ensures thatthe required power is readily ayailable for motive as well as, equied.control functions for critical system loads connnected to these buses. The- 7 day Frequency takes into account the capability of the electrical power.distribution subsystems, and otherindications available in the control room that alert to Subsystemmalfunctions. (D REFERENCES

1. ,FSAR,Ci e-rý2. FSAR,FC-hap'Vr I1:4t1 ecio 00 00 BWOG STS B 3.8.10-4 Rev. 3.0, 03131/04 Attachment 1, Volume 13, Rev. 1, Page 320 of 323 Attachment 1, Volume 13, Rev. 1, 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 descriptionm

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 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 321 of 323 Attachment 1, Volume 13, Rev. 1, Page 322 of 323 Specific No Significant.

Hazards Considerations (NSHCs)Attachment 1, Volume 13, Rev. 1, Page 322 of 323 Attachment 1, Volume 13, Rev. 1, 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. 1, Page 323 of 323}}