Text

License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating
	ML112770098
Person / Time
Site:	Perry
Issue date:	10/03/2011
From:	Bezilla M; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-11-322
	Download: ML112770098 (43)
	v • d • e

FENOC FirstEnergy Nuclear Operating Company Mark B. Bezilla Vice President October 3, 2011 L-11-322 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant 10 Center Road Perry, Ohio -14081..

10 CFR 50.90 440-280-5382 Fax: 440-280-8029 License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1! !lAC Sources - Operating" In accordance with 10 CFR 50_90, FirstEnergy Nuclear Operating Company (FENOC) requests a license amendment to the Perry Nuclear Power Plant (PNPP) Operating License. The proposed change would revise Technical Specification (TS) 3.8.1, "AC Sources - Operating," to clarify that a delayed access circuit is qualified as one of two required offsite circuits between the offsite transmission network and the onsite Class 1 E alternating current (AC) electric power distribution system. The proposed change would also add the COMPLETION TIME allowed for circuit restoration if the only OPERABLE offsite circuit is a delayed access circuit An evaluation of the proposed amendment is enclosed.

As provided by 10 CFR 50.91 (a)(5), the Nuclear Regulatory Commission (NRC) can issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment if the NRC finds that an emergency situation exists, in that failure to act in a timely way would prevent resumption of operation and result in an extended plant shutdown. Such an emergency situation currently exists at PNPP.

On September 29, 2011, at 5:29 a.m., the Unit 1 startup transformer unexpectedly failed.

Based on questions raised by NRC staff related to the applicability of TS 3.8.1, FENOC completed a controlled manual shutdown of PNPP on October 2,2011, at 4:14 p.m.

Although FENOC believes that reliance on the delayed access circuit is currently allowed by TS 3.8-1, the license amendment request is submitted to address questions recently raised by NRC staff.

The proposed change would clarify that a delayed access circuit is qualified as an alternate for the inoperable offsite circuit, thereby supporting restart.and resumption of operation of PNPP. Accordingly, FENOC requests the NRC to,dispense with notice

Perry Nuclear Power Plant L-11-322 Page 2 of 2 and comment on the determination of no significant hazards consideration and issue the requested license amendment by October 7,2011,'to resume normal power operations.

There are no regulatory commitments included in this submittal. If there are any questions or, if additional information is required, please contact Mr. Phil H. Lashley, Supervisor - Fleet Licensing, at (330) 315-6808.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 3..,2011.

Sincerely,

/Il;!iyj Mark B. Bezilla!

Enclosure:

Evaluation of Proposed Amendment cc:

NRC Region III Administrator NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Evaluation of the Proposed Amendment Page 1 of 18

Subject:

License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, "AC Sources -

Operating" Section 1.0 2.0 3.0 4.0 4.1 4.2 4.3 4.4 5.0 6.0 Attachments Table of Contents Title Page

SUMMARY

DESCRiPTION........................................................................ 2 DETAILED DESCRIPTION........................................................................ 2 TECHNICAL EVALUATION....................................................................... 2 REGULATORY EVALUATION................................................................. 15 Significant Hazards Consideration........................................................... 15 Applicable Regulatory Guidance/Criteria.................................................. 17 Precedent................................................................................................. 17 Conclusions.............................................................................................. 17 ENVIRONMENTAL CONSiDERATION.................................................... 17 REFERENCES......................................................................................... 18 1

PNPP USAR Figure 8.3-1, Main One Line Diagram 13.8 kV and 4.16 kV 2

Proposed Technical Specification Change (Mark-Up) 3 Proposed Technical Specification Bases Changes (For Information)

Page 2 of 18 1.0

SUMMARY

DESCRIPTION

'. ')'"

This evaluation supports a request to amend Operating License NPF-58 for the Perry.-;

Nuclear Power Plant (PNPP). Technical Specification 3.8.1 "AC Sources-Operating,'; is being revised to:

1. more clearly document the acceptability of plant operation with one of the two required offsite electrical circuits being a delayed access circuit

2. require a more restrictive 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time in place of the currently permitted 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months period in ACTION A, should the plant be in a configuration where the only OPERABLE circuit is a delayed access circuit.

2.0 DETAILED DESCRIPTION The proposed Technical Specification changes are provided as Attachment 2; the associated TS Bases changes are provided as Attachment 3. The TS Bases changes are provided for information purposes, since the PNPP Technical Specification Bases Control Program controls the review, approval and implementation of TS Bases changes.

Proposed Technical Specification Changes The Limiting Condition for Operation (LCO) portion of Specification 3.8.1, "AC Sources -

Operating," is being revised to include a parenthetical to note that one of the two qualified circuits between the offsite transmission network and the onsite Class 1 E alternating current (AC) electrical power distribution system may be a delayed access circuit.

In addition, ACTION A is being revised. When one of the two required offsite circuits is inoperable, Condition Ais met and Required Action A.2 currently provides a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for restoration of the required offsite circuit to OPERABLE status. The proposed change is to add an additional Completion Time into this ACTION that will apply when the only OPERABLE offsite circuit is a delayed access circuit. In such a situation, the standard 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months time is reduced significantly, down to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , thereby further limiting plant operation in this configuration.

3.0 TECHNICAL EVALUATION

The LCO for Specification 3.8.1, "AC Sources-Operating," requires that two qualified circuits normally be maintained between the offsite transmission network and the onsite Class 1 E AC electrical power distribution system [the 4.16 kV Engineered Safety Feature (ESF) buses). The ACTIONs provide limitations on plant operation when this requirement is not met. This amendment addresses the acceptable offsite circuit configurations for meeting the LCO requirements, and provides a more limiting Completion Time for situations when only a delayed access circuit is considered to be OPERABLE. This more limiting time is based on a. qualitative assessment of the

Page 3 of 18 guidc3l"1ce in Regulatory Guides 1.32, "Criteria for S~fety Related Eh:~ctrfc".epwe.r;::"..

Syst~~s for Nuclear Power Plants" and 1.93., "Avai~~pi.lity of Electri?" Pow~~:~.~urces."

3.1. Two Qualified Circuits 3.1.1 Evaluation Background The circuits between the switchyard and the 13.8 kV buses [labeled L 10 and L20 - see figures provided as Attachment 1], can be lined up in several different configurations to provide power to those two buses, depending on what components are available in a given situation.

The documents discussed in this evaluation include electrical lineup diagrams; the PNPP USAR; 10 CFR 50 Appendix A, General Design Criterion (GDC) 17, "Electric Power Systems;" PNPP Technical Specification Bases; and the NRC Safety Evaluation Report for PNPP (NUREG-0887).

3.1.2 Executive Summary Based on the following evaluation, it has been determined that the requirements in PNPP Technical Specification (TS) 3.8.1, "AC Sources - Operating," for having two qualified offsite sources can be met utilizing any two of the following three circuits:

1) Unit 1 Startup Transformer (U1 SUT)

2) Unit 2 Startup Transformer (U2 SUT)

3) Backfeeding through the Main and Auxiliary Transformers Since the three PNPP circuits meet all licensing and design requirements, as shown in the following evaluation, it can be concluded that a "best two-out-of-three" arrangement will meet the requirements of Technical Specification 3.8.1.

3.1.3 Licensing Basis Considerations - Technical Specifications The Technical Specifications contain the following requirement: Technical Specification 3.8.1.a requires "two qualified circuits between the offsite transmission network and the onsite Class 1 E AC Electric Power Distribution System". The three sources described in the Technical Specification Bases are the path through the U1 SUT, the path through the U2 SUT, and backfeeding through the main and auxiliary transformer as depicted on Attachment 1.

If one of the startup transformer sources of offsite power is out of service, backfeeding of the Unit 1 main and auxiliary transformers would be credited as a delayed access source of offsite power. It is available in sufficient time to prevent damage to fuel cladding and the reactor coolant boundary as a result of anticipated operational occurrences, and as validated by a time study

[Reference 1].

..'.. ".::."._. ~

Page 4 of 18 The three possible offsite sources,we.re;:d,~sc(ibed above';' :tbe):~~Ghr1icaL**~ -,. c~~,.c...,....,,,-,,;,..

Specification Bases state that "Qualified qffsite circuits are thos~: that are described in the USAR and are part oftne licemsing basis for ttie~*uiiit.'" The:

backfeed circuit is described in the USAR,'as detailedbelowi"n Section 3.1.4. In 1994, during the development and revie~process forthe PNPP,l'mproved "

Standard Technical Specifications (iSTS), the term "physically independent" circuits that was used in the former TSs was replaced with "qualified" circuits in the iSTS specification. It was determined that these two terms were considered to have the same meaning, and although the wording changed, there was no change to the requirements. In 1996, along with the implementation of the PNPP iSTS, a TS Bases change added information regarding the backfeed circuit, using text taken directly from the NRC Safety Evaluation Report (SER) for PNPP (NUREG 0887). This change added clarity by including information from the original SER, and did not change the Technical Specifications.

Therefore, any two of the three offsite sources described above can be used to comply with the current Technical Specifications limiting condition for operation described in section 3.8.1. This amendment request clarifies this point within the TS themselves by adding a parenthetical statement into the LCO 3.8.1 requirement for maintaining two OPERABLE circuits by stating "one of which may be a delayed access circuit."

3.1.4 Licensing Basis Considerations - USAR USAR sections 8.2.1 and 8.2.2 state that the offsite power system is the preferred source of power for the plant. This system includes the grid, transmission lines, transformers, switchyard components, and associated control system provided to supply electric power to safety related components and equipment. The electric grid is the source of energy for the offsite power system. The safety function of the offsite power system is to provide sufficient capacity and capability to ensure that the specified acceptable fuel design limits and design condition of the reactor coolant pressure boundary will not be exceeded, and to ensure that core cooling, containment integrity and other vital functions will be maintained in the event of postulated accidents as specified in General Design Criterion (GDC) 17.

The three offsite supplies are currently described in USAR Section 8.2.1.

This section of the USAR also states "a motor operated main generator disconnect switch is provided to facilitate the availability of this [the backfeed) path." This allows the backfeed configuration to be put in place much more quickly than a bolted link connection.

The NRC SER for PNPP also recognized that three sources of offsite power are available. The SER explicitly described the path through the Unit 1 SUT, the Unit 2 SUT, and a method for powering the ESF buses by using the main and auxiliary transformers to feed either L 11 or L 12 and in turn feed L 10.

.~ ~~'..-

Page S of 18 3.1.S Licensing Basis considerations,~, 1 OCFRSO, ApJ?e~,~ix A" C~it~rion:'17':'~:'i:i;:~",

, ~ OCFRSO, Appendix A, CriterioI1JZs~~tes the following:'*

Criterion 17-Electric power systems. An onsite electric power system and an- "

offsite eleCtric power system shaii be provided to permit ivnctionirig of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all on site alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

The following demonstrates PNPP conformance to General Design Criterion 17.

Criterion 17-Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety.

The Class 1 E buses, and their associated equipment important to plant safety, can be powered from either offsite power through circuits connected to the switchyard or through the emergency diesel generators (EDGs) associated with each Engineered Safety Feature (ESF) bus.

The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure

Page 6 of 18

.. *;;:that (1)specified acceptable: fuel design litnits and design.cond!tlo"s.ofthe

"'reactor coolant pressure boundary are not exceeded as a resulfof.~:.

'anticipated operational occurrences' and (2) the core'is cooled anci~';';::;:...'.. -

,containment integrity and other vita;.functions',are maintained iitjh~event

. of postulated accidents.

A calculation entitled "PNPP Class 1 E Power Distribution System Voltage Study" shows that either startup transformer, the backfeed through the main and auxiliary transformers or the Class 1 E emergency diesel generators can provide sufficient capacity to mitigate a LOCA.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Divisional separation between each of the Class 1 E ESF buses, EDGs, and batteries ensure independence. Having multiple divisions, and requiring only Division 1 or Division 2 to achieve and maintain safe shutdown provides redundancy. All required surveillance testing can be performed which satisfies the testability criterion.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simUltaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable.

PNPP has three lines that traverse from the common switchyard to the onsite electrical distribution. These three are the Unit 1 startup transformer feed, the Unit 2 startup transformer feed, and the connection from the switchyard to the main and auxiliary transformers. Each of these is electrically separated from the other two.

Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded.

With a loss of all onsite AC power supplies (EDGs), and having only a single offsite supply (either the U1 SUT, the U2 SUT, or the backfeed through the main and auxiliary transformer), any single available offsite source would be able to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded.

In the case where two startup transformers are available, either source would be available within a few seconds in order to meet the requirement specified in

',.~

4. ';r.-:.. :....

Page 7 of 18

_______ ODC 17. This would ensure all safetY systems are avaiiable-to;irpalrJtain the -- ;:,: _0;).,=_<

specified acceptable fuel design limitsarid design conditions oOhe reactor coolant;:,~.-~.

. -pressure boundar{are not exceeded. -

.-,.~'::':: :.-

If a startup transformer and the backfeed through the main and-auxiliary transformers are the two available offsite sources, and the startup transformer fails, a loss of AC power to the ESF buses and subsequent reactor scram and turbinetrip would occur. Operators would take manual action to align the ESF

_ buses through the main and auxiliary transformer. This requires breaker manipulations, and opening a disconnect switch that isolates the main generator from the isolated phase bus. A time study indicates that bus power can be restored in approximately two hours [Reference 1].

In the backfeed case, DC power would be available for Reactor Core Isolation Cooling system and manual Safety Relief Valve operation, which will preclude fuel cladding and reactor coolant pressure boundary damage for four hours. Since this re-alignment to the backfeed source can be performed within the four hour capability of the DC system, the backfeed case meets GDC 17. Since each of the three offsite supplies have been shown to adequately assure acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded, the GDC 17 criterion have been satisfied.

One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

If two startup transformers are the available offsite supplies and a LOCA occurs, each of the transformers would be available to immediately supply power to any or all of the ESF buses. Therefore, each startup transformer would be available within a few seconds.

If a single startup transformer and the backfeed through the main and auxiliary transformers are the available offsite supplies, and a LOCA occurs, the startup transformer would be the immediate source for the ESF buses. The backfeed circuit is a delayed access source, but has been shown to meet the previous guidance regarding prevention of fuel damage.

Since at least one of the required sources is always available within a few seconds, all three offsite supplies meet GDC 17 and are considered to be qualified circuits. Therefore, this criterion is met.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Emergency Diesel Generator and switchyard component maintenance plans, grid operating procedures and normal electric lineups minimize the probability of losing

Page B of 1B electric power from any remain'ing supplies as a resLiltof~pr coincident with a unit.

trip, a loss of offsite power (LOOP), or a failure of the EDGs.

Based on the above discussio'1 on, each portion.of GQC J 7, the analysis shows. ;

that no exceptions to any GDC17 criteria were taken> Therefore, PNPP fully complies with General Design Criterion 17.

3.1.6 Licensing Basis Considerations - Review of Conformance to GDC 17 as outlined in NUREG-OBOO, Revision 3 The following is a comparison of the three offsite supplies to the reviewer guidance in NUREG-OBOO, Standard Review Plan (SRP). NUREG-OBOO lists the review considerations and acceptance criteria for meeting GDC 17. The review will focus on those areas within NUREG-OBOO Section B.2, Item 11.2 that relate specifically to GDC 17. The five acceptance criteria are listed as follows:

i)

Capacity and capability to permit functioning of structures, systems, and components important to safety.

ii)

Provisions to minimize the probability of losing power from any remaining supply as a result of loss of power from the onsite power system or loss of the unit generator.

iii)

Physical independence.

iv)

Capability to meet Regulatory Guide 1.32.

v)

Acceptability of generator circuit breakers and generator load break switch.

SRP section B.2, Item 111.1, defines the review process as it relates to GDC 17.

Eight specific areas are examined to ensure that the above listed acceptance criteria are satisfied. This summary evaluates the acceptance of the three offsite source configurations and their acceptability.

a) The electrical drawings should be reviewed to assure that at least two separate circuits from the transmission network to the onsite power distribution system buses are provided.

From the switchyard there are three separate supply lines to the onsite electrical distribution system. One is the feeder for the Unit 1 startup transformer, a second is the feeder for the Unit 2 startup transformer, and the third connects to the main transformer. Therefore, the GDC 17 criterion has been satisfied.

b) The routing of transmission lines should be examined on layout drawings to assure that at least two independent circuits from the offsite grid are available.

Under all conditions, anyone of the three circuits that connect the offsite grid to the onsite electrical distribution system can be out of service, and two physically independent circuits will be available. Therefore, this criterion has been satisfied.

-p-"-

Page 9 of 18

'c) As the switchyard may be common to both offsite circuitsj:th,e/ectrical:,: :-'<;,..... '.. <

schematics of the switchyard breaker control system, itspower'supply, and the breaker arrangement itself should be examined for the'possibilityof '.--.

simultaneous failure of both circuits from s,ingle events suqh as.:B 'breaker.

not operating during fault conditions, spurious relay trip, loss of a control circuit power supply or a fault in a switchyard bus or transformer.

If either startup transformer and the backfeed through the main and auxiliary transformers are the two available offsite sources and the startup transformer fails, operators could take manual action to align the ESF buses through the main and auxiliary transformer (in order to remove reliance on onsite power supplies).

. This requires breaker manipulations, and opening a disconnect switch that isolates the main generator from the isolated phase bus.

A time study has been completed and has shown that bus power can be restored within approximately two hours. This time study simulated a loss of both startup transformers and a loss of offsite power (LOOP).

In the above case if onsite AC power supplies are not utilized, DC power would be available for Reactor Core Isolation Cooling (RCIC) system and manual Safety Relief Valve operation which will preclude fuel cladding or reactor coolant pressure boundary damage for four hours. The design basis calculation does support that DC power will be available for at least four hours following a loss of AC ESF bus power. Since each of the three offsite supply re-alignments can be performed within the four hour capability of the DC system, each of the three offsite supplies satisfy this requirement. Additionally, a calculation concluded that RCIC can provide core cooling for the four hour timeframe. Therefore, no cladding or reactor coolant pressure boundary damage will occur in this timeframe.

All other aspects of the control and relaying protection of these circuits are not susceptible to a single failure that would isolate both offsite supplies. Therefore, the GDC 17 criterion has been satisfied.

d) The design is examined to determine that at least one of the two required circuits can, within a few seconds, provide power to safety-related equipment following a loss of coolant accident. These circuits are not required to be single failure proof. However, it is required that each circuit have the capability to be available in sufficient time to prevent fuel design limits and design considerations of the reactor to be exceeded. For those units that utilize a backfeed path through the main generator step-up transformer, the reviewer must determine if this path is required to satisfy the GDC requirement for an immediate or delayed access circuit. If the circuit is required for delayed access, then the same determination as previously stated must be made, i.e. there is sufficient time to make the circuit available.

Page 10 of 18

_ In the case where two startup transformers are available,.either source would be :: <,:<"-

_ available within a few seconds in order-to meet the requirement specified in

'-' - GOC 17.

In the case where a startup transforme'r and the backfeed through 'the main and auxiliary transformers are the two available offsite sources, the startup transformer would be available within a few seconds to mitigate a LOCA condition as required by GOC 17. In the event that a startup transformer fails, operators would take manual action to align the ESF buses through the main and auxiliary transformer. This requires breaker manipulations, and opening a disconnect switch that isolates the main generator from the isolated phase bus. A time study has been completed and has shown that divisional bus power from offsite sources can be physically restored within approximately two hours. Thus the backfeed circuit has the capability to be available in sufficient time to prevent fuel design.

limits and design considerations of the reactor to be exceeded (based on the above analysis that establishes a four hour capability of the onsite DC power supply to support operation to preclude fuel cladding or reactor coolant pressure boundary damage).

PNPP utilizes a backfeed option through the main generator step-up transformer as discussed above. Each of the startup transformers has clearly been sh.own to adequately mitigate a Loss of Coolant Accident (LOCA) event by supplying required loads. Furthermore, the GOC only requires one of the two offsite power supplies to be able to align within a few seconds to power safety related loads for event mitigation. Therefore, since at least one of the sources is always available within a few seconds, all three offsite supplies meet GOC 17 and are considered to be qualified circuits. Therefore, the GOC 17 criterion has been satisfied.

e) Each of the circuits from the offsite system to the onsite distribution buses should have the capacity and capability to supply the loads assigned to the bus or buses it is connected to during normal and abnormal operating conditions, accident conditions, or plant shutdown conditions.

Therefore, the loads supplied during these conditions should be determined from information obtained in coordination with other branches.

A review of design information and analysis for the three offsite power circuits has been performed via a review of the applicable PNPP electrical calculations.

These calculations review the loads that are required in all bounding plant configurations, including the backfeed case. Overall, the review concluded that power capacity is available with sufficient margin from all three sources with respect to these calculations. Therefore, this criterion has been satisfied.

f) The results of the grid stability analysis must show that the loss of the largest single supply to the grid does not result in the complete loss of preferred power. The analysis should consider the loss, through a single event, of the largest capacity being supplied to the grid, removal of the largest load from the grid, or loss of the most critical transmission line.

I *. _~.;,

Page 11 of 18 The results of the grid stability analysis are presented' in USAR sectiol) 8.2.,*:: '/5' '-.

These results were performed for the original plant design in-accordance with the ',.

above listed guidelines. A full load rejection is still the analyzed worst case condition for stability. The grid is demonstrated to show its capacity to withstand.~.

full load rejection.. Therefore, the GDC 17 criterion has been satisfied.

g) During the review of the electrical schematics, it should be determined that loss of standby power will not result in the loss of preferred power, loss of one preferred power circuit will not result in the loss of the other circuit, and loss of the main generator will not result in the loss of the other preferred circuit.

The three offsite supply configurations will not affect the standby power system (diesel generators), loss of one preferred power circuit will not result in the loss of the other circuit, and the loss of the main generator will not result in the loss of the offsite AC power circuit through either preferred power circuit. These electrical systems maintain their physical and electrical independence as originally designed and remain in compliance with GDC 17. Therefore, the GDC 17 criterion has been satisfied.

h) The preferred power system must be independent of the onsite power system. The basis for acceptance is that no single event, including a single protective relay, interlock, or switchgear failure, in the event of loss of all standby power sources, will prevent the separation of the preferred power system from the onsite power distribution system or prevent the preferred power system from accomplishing its intended function.

There is no active connection between the offsite and onsite sources, except during EDG testing. Therefore, no single failure could prevent separation or prevent safe shutdown capability. Therefore, the GDC 17 criterion has been satisfied.

As demonstrated through evaluation of the NUREG 0800 acceptance criteria, all three offsitesupply configurations comply with the guidelines in GDC 17.

3.1.7 Licensing Basis Considerations - Regulatory Guides 1.32 and 1.93 Regulatory Guides 1.32, "Criteria for Safety Related Electric Power Systems for Nuclear Power Plants," February 1977, Revision 2, as well as Regulatory Guide 1.93, "Availability of Electric Power Sources," December 1974, Revision 0 were reviewed during development of this amendment request to determine if any concerns are raised due to any of the offsite supply configurations.

The introduction to Regulatory Guide 1.93 states that: "Nuclear power plants wherein only one of the two required offsite circuits can be made available within a few seconds following a LOCA are outside the scope of this guide." If only one startup transformer is available, and the backfeed configuration (delayed access source) is used as a qualified offsite supply, this Regulatory Guide does not apply..

Section B of the Regulatory Guide states:

Page 12 of 18 GDC 17 specifies design requirements, not operating requirements; ittherefore does not stipulate operational restrictions on the loss of powersources::"::**~:.

Nevertheless, operational restrictions based on the intent of GDC 17 oil lhe loss.

of power sources have been included in the Teqhnical Specifications o.f rftcently licensed nuclear powerplants. Such restrictions are based on the fol/owing assumptions:

The LCD of nuclear power plants is met when al/ the electric power sources required by GDC 17 are available.

Regulatory Guide 1.32, Position C.1.a states that:

A preferred design would include two immediate access circuits from the transmission network. Detailed guidance for operating procedures and restrictions acceptable to the staff, applicable where two immediate access circuits are available is contained in Regulatory Guide 1.93, '~vailability of Electric Power Sources. " An acceptable design would substitute a delayed access circuit for one of the immediate access circuits provided the availability of the delayed access circuit conforms to Criterion 17.

Thus, this Regulatory Guide is applicable when credit for the backfeed configuration is taken, and it presents the position that the delayed access circuit is an acceptable design as long as it meets GDC 17.

As shown in the previous section, the three offsite supply configurations satisfy the Standard Review Plan (NUREG 0800) criteria for GDC 17 and the General Design Criteria 17 itself. Since the three offsite access circuits comply with the recommendations of Regulatory Guide 1.32, as applicable, and each of the three offsite circuits are qualified, it can be concluded that a "best two-out-of-three" configuration will satisfy the requirements of the limiting condition for operation for Technical Specification 3.8.1.

3.1.8 Impact on USAR Accident Analyses There are four USAR events potentially affected by the three offsite supply configurations. The events are Loss of Auxiliary Transformer (USAR 15.2.6);

Loss of Grid Connections, also referred to as a Loss of Offsite Power (LOOP)

(USAR 15.2.6); the Design Basis Loss of Coolant Accident (LOCA) (USAR Sections 6.2 and 15.6); and Station Blackout (SBO) (USAR Appendix 15H).

The Loss of Auxiliary Transformer event is a moderate frequency transient. As a moderate frequency event, defined as an "anticipated operational occurrence," a failure beyond that which initiated the event is not required to be assumed per USAR 15.0.3.2.1.1. Therefore, with the exception of the system/component that initiated the event, reliance can be placed upon the other systems and components to properly function as designed.

The cause of the Loss of Auxiliary Transformer event ranges from the operation of the transformer protection circuitry to operator error. Offsite power is used to provide power to the systems and components necessary to mitigate the

Page 13 of 18

.. ' consequences of the event. Since the event.assumes the, norrnaLfunctioning of.:'.'

. plant systems and components, only one independent circuit of offsite power is '

... required. As stated above, additional failures are not required to"bej>Ostulated, so availability of additional power sources arenbt required. The eventdoes not impact the integrity of any of the fuel cladding or reactor coolant pressure boundary.

As discussed in USAR 15.2.6, the LOOP event is a moderate frequency event.

Loss of all grid connections can result from major shifts in electrical loads, loss of loads, lightning, storms, wind, etc., which contribute to electrical grid instabilities.

These instabilities will cause equipment damage if unchecked. Protective relay schemes automatically disconnect electrical sources and loads to mitigate damage and regain electrical grid stability. For the USAR event, the onsite power supplies are used to provide power to the systems and components necessary to mitigate the consequences of the event. The event does not impact the integrity of any fuel cladding or the reactor coolant pressure boundary. No fuel failures occur. [Note: the event itself eliminates the offsite sources. Hence, no credit is taken for the use of offsite power for any mitigation activities.]

The Design Basis LOCA event is postulated concurrent with a LOOP. The initiator of the LOOP, in this circumstance, is not defined. For this USAR event, the onsite power supplies are used to provide power to the systems and components necessary to mitigate the consequences of the event. [Note: the event itself eliminates the offsite sources. Hence, no credit is taken for the use of offsite power for any accident mitigation activities.] The consequences of a LOCA, therefore, are not affected by the availability, or lack thereof, of the offsite power sources.

The SBO event assumes a loss of the grid coupled with the failure of the Division 1 and 2 diesel generators. The cause of the loss of the grid would be similar to that described under the LOOP event. The SBO event itself eliminates the offsite sources. Hence, no credit is taken for their use in accident mitigation activities. The consequences of the SBO, therefore, are not affected by the availability, or lack thereof, of the offsite sources.

Therefore, there are no adverse effects upon the existing USAR accident analyses.

3.1.9 Design Basis Preferred power from the offsite power sources to the Class 1 E buses is from the startup transformers as depicted on Attachment 1. The startup transformer takes power from the transmission yard at 345 kV and steps it down to 13.8 kV. At the 13.8 kV level, voltage is further stepped down to 4.16 kV at interbus transformer LH-1-A where it is utilized for the Class 1 E buses. One secondary winding of the Unit 1 interbus transformer LH-1-A feeds the Unit 1,4.16 kV Class 1 E buses. The other secondary winding of the interbus transformer feeds the Unit 2 4.16 kV Class 1 E bus as the alternate source.

Page 14 of 18

. Similarly, the Unit 2 interbus transformer (LH-2-A) hasthe:capability of providing.:.

power to Unit 1 or the Unit 2 Class 1 E 4.16 kV buses.

An alternate path of receiving power from the 345 kV switchyard to the plant is*

also provided. This is by backfeeding through the Unit 1'auxiliary and main"'~.... :

transformers. The Unit 1 main transformer's primary function is to supply power from the turbine generator to the grid. The main generator generates power at 22 kV. The main transformer steps up this voltage to levels of the transmission system (345 kV). Power can also be provided in the opposite direction through the main transformer, thus stepping the voltage down from 345 kV to 22 kV for use in the plant via the auxiliary transformer.

The auxiliary transformer is typically used to provide power to the auxiliary loads in the plant (house loads). The auxiliary transformer steps down voltage from 22 kV at the main generator to 13.8 kV for use on buses L 11 and L 12 during normal operation.

Each startup transformer and the auxiliary transformer is capable of supporting the worst case loading scenario as evaluated in the plant electrical loading calculations.

In the backfeed configuration with the L 11 or L 12 bus feeding L 10 and the ESF buses, the loss of either startup transformer, and consequently the safety related Class 1 E buses, will cause an automatic shutdown of the plant. This configuration was confirmed by review of elementary diagrams. A summary of the events that transpired to cause this shutdown are listed below:

-Division 1 Steam Tunnel High Temperature

-Division 2 Steam Tunnel High Temperature

-Main Steam Isolation Valve (MSIV) closure

-Turbine trip

-Reactor Scram 3.1.10 Power Systems Analysis Calculations Calculations have been performed to demonstrate the adequacy of the three offsite supply configurations to deliver power to the Class 1 E safety related buses.

These calculations have evaluated the load flow, electrical protection, ampacity, short circuit availability, and voltage drops to downstream equipment.

A calculation analyzed the backfeed of bus L 10 from bus L 11 or L 12. The calculation demonstrates the capability of the backfeed configuration to supply adequate voltage to safety related equipment while maintaining operation from the offsite supply circuit under design basis accident conditions. The calculation utilized the pre and post-LOCA electrical loads. These loads represent the worst-case loads when utilizing the backfeed configuration in response to a design basis accident or plant operation at reactor power. A calculation evaluated bus fault duties when in the backfeed configuration. The results indicate that the existing

Page 15 of 18

-protective relay coordination for circuit breaker L 1006 andL 1 009 prQt~qtive relay __.. -':--:c setpoints, is acceptable.

-- ::_~":_,,:~'::_

Therefore, electrical calculations have adequately-demonstrated the abilitY-"of the safety related equipment to perform their functions in all three offsitesupply configurations.

3.1.11 Results and Conclusions Based on the above evaluation, it has been shown that the requirements in PNPP's Technical Specification (TS) 3.8.1, "AC Sources - Operating," for having two offsite sources can be met with any two of the following three circuits:

1) Unit 1 Startup Transformer (U1 SUT)

2) Unit 2 Startup Transformer (U2 SUT)

3) Backfeeding through the Main and Auxiliary Transformers Since PNPP's three circuits meet all licensing and design requirements, as shown in the discussions, it can be concluded that a "best two-out-of-three" configuration will satisfy the requirements of the limiting condition for operation for Technical Specification 3.8.1.

3.2. Shortened Completion Time With One Delayed Access Circuit Operable As described above in the discussions of Regulatory Guide 1.93, plants that operate with two immediate access offsite circuits would find RG 1.93 directly applicable to the Completion Times provided in their Technical Specifications.

However, as noted in Regulatory Guide 1.32 and in RG 1.93, the Completion Times in RG 1.93 regarding offsite circuits are not necessarily applicable if operating with only one delayed access offsite source. A shorter Completion Time could be applied. A change to the PNPP Technical Specification 3.8.1 is being requested to shorten the time allowance for operation in such a configuration from the standard 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to only 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This could be considered to be a more conservative ACTION, although it provides less time to restore an inoperable offsite source [24 hours versus 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s], and therefore may result in a forced plant shutdown transient during a time period when limited offsite power is available to support the shutdown evolution.

4.0 REGULATORY EVALUATION

4.1 Significant Hazards Consideration An evaluation has been performed with respect to whether a significant hazards consideration is involved with the proposed amendment, by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Page 16 of 18 Response: No.

'.. ~~J :.: ;:'-', ~ '.:.-'. "..

The proposed amendment involves the qualification of abackfeed, electrical alignment to meet the requirements of TS 3.8;-1 for maintaining the availabilitY of offsite power. 'The amendment maintains the reliability',

and redundancy of offsite AC electrical sources required by GDC 17, involves no changes to plant equipment design, and creates no accident initiator. Therefore, there is no significant impact on the probability of a previously evaluated accident.

As required by GDC 17, the backfeed circuit is designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. The other circuit necessary to meet the LCO is designed to be available within a few seconds following a loss-of-coolant accident (LOCA) to assure that core cooling, containment integrity, and other vital safety functions are maintained. The amendment maintains the guidelines of GDC 17. Therefore, the proposed Technical Specification change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

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

Response: No.

The proposed amendment involves the qualification of a backfeed electrical alignment to meet the requirements of TS 3.8.1 for maintaining the availability of offsite power. The amendment maintains the reliability and redundancy of offsite AC electrical sources required by GDC 17, involves no changes to plant equipment design, and creates no accident initiator. Therefore, the proposed Technical Specification change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

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

Response: No.

The proposed amendment involves the qualification of a backfeed electrical alignment to meet the requirements of TS 3.8.1 to maintain the availability of offsite power. The amendment maintains the reliability and redundancy of offsite AC electrical sources required by GDC 17 and involves no changes to plant equipment design. Therefore, the proposed

Page 17 of 18 Based on the above, it is concluded that the proposed amendment presents no

" significant hazards consideratio"n u'nder the standardssedc)rth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Applicable Regulatory Guidance/Criteria Discussions of the applicable Regulatory Guidance/Criteria are provided above in Sections 3.1 and 3.2. They are not repeated here.

4.3 Precedent A number of plants have been licensed with credit for a delayed access circuit, as permitted by the guidance in GDC 17, Regulatory Guide 1.32, and Standard Review Plan Section 8.2. Due to PNPP having been originally designed with an extra startup transformer due to the planned (but never completed) Unit 2, PNPP has an extra immediate access circuit normally available. However, if one of the two immediate access circuits requires preventive or corrective maintenance, taking the extra immediate access circuit components out of service simply brings PNPP down to the required number and type of circuits at these other plants. With the more explicit licensing approval obtained through the processing of this amendment, such maintenance will again be possible at PNPP without the time constraints/pressure of a limited length Completion Time, with requirements no longer leading to a plant shutdown.

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

5.0 ENVIRONMENTAL CONSIDERATION

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

Page 18 of 18 to.CFR 51.22(c)(9). Therefore, pursuant to1 OGFFf5t.2~(b), noenvironrn~n.t~!impact.

statement or environmental assessment need be prepared in connection with*.~he*..

pr~posed amendment.

6.0 REFERENCES

1. PSTG-0041, "An Analysis of the Design and Licensing Basis for Technical Specification 3.8.1, AC Sources - Operating," Revision 1

2. Perry Nuclear Power Plant Updated Safety Analysis Report

3. NUREG-0887, "Safety Evaluation Report related to the operation of Perry Nuclear Power Plant, Unit 1 and 2," dated May 1982

4. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," Revision 3

5. Regulatory Guide 1.32, "Criteria for Safety Related Electric Power Systems for Nuclear Power Plants," Revision 2

6. Regulatory Guide 1.93, "Availability of Electric Power Sources," Revision 0

7. 10 CFR 50 Appendix A, General Design Criterion (GDC) 17, "Electric Power Systems"

8. PSTG-0001, "PNPP Class 1 E Power Distribution System Voltage Study,"

Revision 5 PNPP USAR Figure 8.3-1, Main One Line Diagram 13.8"kV and 4.16 kV (3 Sheets Follow)

I ~TERBUS XFMR.

LH*Z*C 3S*IB/IBMVA 13.B/ ** 361 ** 36KV RES. I.Z n ZIIiIIIIA. IISEC.

H22111 311i1111A IZIIA LOAD CE~TER FEEDER (TYPICAL)

H2212 3111111A 2111111A.

IIIIIIIIMVA L2216 12IIIA RES. I.Z n ZIiIIIIIA. IISEC.

IIHERBUS XFMR.

LH*2*B 36*IB/IBMVA 13.B/ ** 36/ ** 36KV RES. I.Z n ZIIIIIA. lISEC.

H22 ** 16KV BUS 311i1111A. 258MVA 12IIIA MOTOR FEEDER RELATED STARTUP XFMR 2111111*PY*B

'!II*65/65 MVA. 65' C

~5/13.B/13.B KV RES *** 111 n 21111i1111A. IIJSEC

5*622 S*6211 S*2'1 S*621 t

L211113 3Il1111A MAIN BUS "2 5*662 5*5 5*6611 5*6 5*661 S*652 S*B S*6511 MAIN BUS "\\

RES *** 111 n RES *** 1 n 21i11111A. IISEC.

21i11111A. IISEC.

LZIIilI 3Il1111A Lzae.

3111aeA TL*12 TL*ZI LIIIIII 31i1111111A S*612 S*6111 S*SII t

L211 13.BKV BUS 3Il1ll1llA. IIIIIIIMVA L21186 1211111A LZI1II3 12IIIIIA L21i11117 ZIIiIIIIA IZIIIIA LOAD CE~TER FEEDER (TYPI CAL)

RES. I.Z n ZIIIIIA. IISEC.

LZIII ZaelilA I~TERBUS XFMR.

LH*Z*A 36*IB/IBMVA 13.B/ ** 36/ ** 36KV RES. I.Z n ZIIilIA. IISEC.

RES. I.Z n ZIIIIiIIIIA. IISEC.

STARTUP XFMR IIiIIII*PY*B

'!II*65/65 MVA. 65' C

~~/13.B/13.B KV RES *** 111 n 2111111A. IISEC.

RES. I.Z n ZIilIIA. IIilSEC.

UNIT Z UNIT I HZIIilI 3Il1lllA HZI ** 16KV BUS 121111A MOTOR FEEDER (TYPICAL)

HZ I 1112

~O 3Il1111A 31111111A. Z51lMVA EHZIII ZIIiIIIIA TH*ZI

--TN-UC:i*EAR-SAFETY (TYPICAL) r-_________________

T~H~*~Z __________________________________________________________________________

~T~H~*2~

- 16KV BUS XHZI IZIiIIIIA LOAD CENTER FEEDER (TYPICAL)

TH*IZ l

DIVISIO~ I J

I---------------------------------------------l UNIT Z LIlli 13.8KV BUS 311i1111A. IIIIIMVA EHlll1 21i11111A TH*IZ LIllI lZIiIIIIA INTERBUS XFMR.

LH*I*A 36*IB/IBMVA 13.814. 36/ ** 36KV RES. I.Z n ZIilIIA. IISEC.

Ll1iIIII3 311i1111A RES ** 111 n ZIiIIIIIIIA

1 lSE C

L I 11114 31i1111111A LIIIZ ZIiIIIIIA Lll 13.8KV BUS ZIIIIIIA. ll1li1111MVA

<J t

<J-UNIT AUX XFMR IIIII*PY*B 6.*.IlI.IIMVA Z2.111/13.8/13.8KV RES ** 111 n ZIIIIIA

1 lSE C

8 MAIN GE~ XFMR I*PY*T 3*3.5KVIZ2KV 415MVA e

DISC SWITCH GEN. NEUTRAL XFMR Z5KVA. Ill'

\\4.4/111. Z4KV L1ZI112 21111111A LIZ 13.8KV BUS 21i111111A. IIIIIIIMVA J * *

--=-

GENERATOR I*PY*G 1 ** 6.7 MVA III. 'IF ZZKV RES. 11.411164 n 122.5KW CONT.

121i1111A LII13 12IIIIIA L1Z1116 12IIIIIA 12IIIA LOAD CE~TER FEEDER (TYPICAL)

RES. I.Z n ZIIIIiIIIIA. IISEC.

HII ** ISKV 12IIIA MOTOR FEEDER (TYPICAL )

Hllll 3aelllA I NTERBUS XFMR.

LH*I*B 36*IB/IBMVA

13. 8/ ** 36/ ** 36KV RES. I.Z n 2111111A. IIilSEC.

HI 11112 3Il1l111A 25I1MVA HIIII 12IIIA TRANSM ISS I Olli STATlOili FEEDER CE I OWO.

~. W~I68 RES. I.Z n ZIIIIIA. lISEC.

LOAD CENTER FEEDER (TYPICAL)

HI2II1 311i1111A INTERBUS XFMR.

LH*I*C 36*18/1BMVA 13.814. 36/ ** 36KV RES. 1.2 n ZIIiIIIIA. IISEC.

HI 2112 311i1111A HIZ 4.ISKV BUS 31111i1111A. 258MVA IZIIIIA MOTOR FEEDER (TYP ICAL)

XFMR XHF*I*A (REF.D*ZI6*121)

TH* I TH* I

~OTESI I. MOTOR FEEDS SHOWN ARE TYPICAL ONLY.

Z. TRANSFORMER RATINGS. UIliLESS OTHER*

WISE NOTED. ARE SHOWN FOR 55C TEMPERATURE RISE A~D FORCED CODLIIliO.

3. TRANSFORMER I MPENOAIliCE BASE IS PRIMARY MVA *

- REF. OWO. D*286*111211 FOR LOAD CENTER.

--T-~~~~ ~ ~-~ SAFETY

~--------~--------------------------------~---------------------------+--------------~

4.ISKV BUS XHII TH*ZI 351lMVA IZIiIIIIA LOAD CEIliTER FEEDER (TYPICAL )

RES

- 11 n L

r STANDBY DIESEL GEN lA 8751 KVA

.BPF 4.I6KV OEN NEUTRAL XFMR 1111 KVA I"

.1611/Z.IV EH13 MCC EF*I*EI EHI313 IZIIIIiIA 1211111A. 351lMVA RES 5.11 n HPCS DIESEL OEIli EIC 3251 KVA

.BPF 4.16KV OEN NEUTRAL XFMR 1111 KVA I"

.16III*Z.III/IZI11V TH*ZI XHI21114 I ZIllA 3511MVA IZIIIIA LOAD CE~TER FEEDER (TYPICALl RES

- 11 n STAIliDBY DIESEL OEIli IB 875111 KVA

.BPF ** 16KV DElli NEUTRAL XFMR II KVA I"

.161l1Z411V

_________________ ~~V~SI~ -------------------1-------------------~~V~~I~~ ~------------------1-------------------- DI_V~~IO~~ _________________ 1 Uili IT 1 NUCLEAR SAFETY RELATED UNIT 1 START --UP XFMR PATH

4.16KV BUS XH21 EH21 EH2116 1200A NO EH2115 1200A 1200A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH2114 1200A TH-12 4.16KV BUS XH11 EH11 EH1116 1200A NO EH1115 1200A 1200A NO EH1102 2000A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH1114 1200A RES 4.0 STANDBY DIESEL GEN 1A 8750 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160/240V EH13 NO EH1302 1200A NO EH1301 1200A 4.16KV BUS, 1200A, 350MVA EH1303 1200A RES 5.0 HPCS DIESEL GEN E1C 3250 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160-240/120V MCC EF-1-E1 EH12 EH1214 1200A NO EH1213 1200A 1200A NO EH1201 2000A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH1212 1200A RES 4.0 STANDBY DIESEL GEN 1B 8750 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160/240V 4.16KV XH1204 1200A BUS XH12 TH-21 TH-21 TH-2 TH-2 TH-1 TH-1 XFMR XHF-1-A (REF.D-206-020)

MAIN BUS #2 S-622 S-662 S-652 S-612 S-620 S-660 S-650 S-610 S-621 S-661 S-611 S-5 S-8 S-29 S-6 MAIN BUS #1 RES. 4.0 2000A, 10SEC.

RES. 4.0 2000A, 10SEC. 290 STARTUP XFMR 200-PY-B 90-65/65 MVA, 65^C 345/13.8/13.8 KV RES. 4.0 2000A, 10SEC.

RES. 4.0 2000A, 10SEC. 180 STARTUP XFMR 100-PY-B 90-65/65 MVA, 65^C 345/13.8/13.8 KV L2001 3000A TL-21 L20 13.8KV BUS 3000A, 1000MVA L2003 3000A NO L2004 3000A L2006 1200A L2007 2000A L2010 2000A TL-12 L1001 3000A L10 13.8KV BUS 3000A, 1000MVA L1003 3000A NO L1004 3000A L1010 1200A L1009 2000A L1006 2000A NO NO LOAD CENTER FEEDER (TYPICAL)

L22 13.8KV BUS 2000A, 1000MVA LOAD CENTER FEEDER (TYPICAL)

L21 13.8KV BUS 2000A, 1200A L2206 1200A L2103 1200A 1200A RES. 1.2 2000A, 10SEC.

RES. 1.2 2000A, 10SEC.

INTERBUS XFMR.

LH-2-C 36-18/18MVA 13.8/4.36/4.36KV INTERBUS XFMR.

LH-2-B 36-18/18MVA 13.8/4.36/4.36KV INTERBUS XFMR.

LH-2-A 36-18/18MVA 13.8/4.36/4.36KV NO H2201 3000A H2202 3000A H22 4.16KV BUS 3000A, 250MVA 1200A MOTOR FEEDER (TYPICAL)

NO H2101 3000A H2102 3000A H21 4.16KV BUS 3000A, 250MVA 1200A MOTOR FEEDER (TYPICAL)

RES. 1.2 2000A, 10SEC.

EH2101 2000A TH-21 EH1101 2000A TH-12 INTERBUS XFMR.

LH-1-A 36-18/18MVA 13.8/4.36/4.36KV LOAD CENTER FEEDER (TYPICAL)

L1202 2000A LOAD CENTER FEEDER (TYPICAL)

L1102 2000A 1200A L1206 1200A L1103 1200A 1200A H1202 3000A 1200A MOTOR FEEDER (TYPICAL)

INTERBUS XFMR.

LH-1-B 36-18/18MVA 13.8/4.36/4.36KV RES. 1.2 2000A, 10SEC.

RES. 1.2 2000A, 10SEC.

L11 13.8KV BUS 2000A, 1000MVA L12 13.8KV BUS 2000A, 1000MVA RES. 1.2 2000A, 10SEC.

INTERBUS XFMR.

LH-1-C 36-18/18MVA 13.8/4.36/4.36KV MOTOR FEEDER (TYPICAL) 1200A H11 4.16KV BUS 3000A H1101 3000A H1102 3000A NO 250MVA TRANSMISSION STATION FEEDER H1110 1200A NO H1201 3000A H12 4.16KV BUS 3000A, 250MVA MAIN GEN XFMR 1-PY-T 3-345KV/22KV A

B C

112 M

111 DISC SWITCH UNIT AUX XFMR 110-PY-B 64-40/40MVA 22.0/13.8/13.8KV GENERATOR 1-PY-G 1446.7 MVA 0.9F 22KV RES 4.0 2000A, 10SEC.

RES 4.0 2000A, 10SEC.

GEN. NEUTRAL XFMR 14.4/0.24KV RES. 0.4064 122.5KW CONT.

NOTES:

1. MOTOR FEEDS SHOWN ARE TYPICAL ONLY.

2. TRANSFORMER RATINGS, UNLESS OTHER-WISE NOTED, ARE SHOWN FOR 55C TEMPERATURE RISE AND FORCED COOLING.

3. TRANSFORMER IMPENDANCE BASE IS PRIMARY MVA.

4. REF. DWG. D-206-020 FOR LOAD CENTER.

DIVISION 1 DIVISION 1 DIVISION 3 DIVISION 2 UNIT 1 UNIT 2 UNIT 1 UNIT 2 NUCLEAR SAFETY RELATED NUCLEAR SAFETY RELATED 1000MVA CEI DWG. 5-W25068 NUCLEAR SAFETY RELATED 10 KVA 1 10 KVA 1 10 KVA 1 25KVA, 1 415MVA UNIT 2 START-UP XFMR PATH

4.16KV BUS XH21 EH21 EH2116 1200A NO EH2115 1200A 1200A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH2114 1200A TH-12 4.16KV BUS XH11 EH11 EH1116 1200A NO EH1115 1200A 1200A NO EH1102 2000A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH1114 1200A RES 4.0 STANDBY DIESEL GEN 1A 8750 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160/240V EH13 NO EH1302 1200A NO EH1301 1200A 4.16KV BUS, 1200A, 350MVA EH1303 1200A RES 5.0 HPCS DIESEL GEN E1C 3250 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160-240/120V MCC EF-1-E1 EH12 EH1214 1200A NO EH1213 1200A 1200A NO EH1201 2000A LOAD CENTER FEEDER (TYPICAL) 4.16KV BUS, 2000A, 350MVA EH1212 1200A RES 4.0 STANDBY DIESEL GEN 1B 8750 KVA

.8PF 4.16KV GEN NEUTRAL XFMR 4160/240V 4.16KV XH1204 1200A BUS XH12 TH-21 TH-21 TH-2 TH-2 TH-1 TH-1 XFMR XHF-1-A (REF.D-206-020)

MAIN BUS #2 S-622 S-662 S-652 S-612 S-620 S-660 S-650 S-610 S-621 S-661 S-611 S-5 S-8 S-29 S-6 MAIN BUS #1 RES. 4.0 2000A, 10SEC.

RES. 4.0 2000A, 10SEC. 290 STARTUP XFMR 200-PY-B 90-65/65 MVA, 65^C 345/13.8/13.8 KV RES. 4.0 2000A, 10SEC.

RES. 4.0 2000A, 10SEC. 180 STARTUP XFMR 100-PY-B 90-65/65 MVA, 65^C 345/13.8/13.8 KV L2001 3000A TL-21 L20 13.8KV BUS 3000A, 1000MVA L2003 3000A NO L2004 3000A L2006 1200A L2007 2000A L2010 2000A TL-12 L1001 3000A L10 13.8KV BUS 3000A, 1000MVA L1003 3000A NO L1004 3000A L1010 1200A L1009 2000A L1006 2000A NO NO LOAD CENTER FEEDER (TYPICAL)

L22 13.8KV BUS 2000A, 1000MVA LOAD CENTER FEEDER (TYPICAL)

L21 13.8KV BUS 2000A, 1200A L2206 1200A L2103 1200A 1200A RES. 1.2 2000A, 10SEC.

RES. 1.2 2000A, 10SEC.

INTERBUS XFMR.

LH-2-C 36-18/18MVA 13.8/4.36/4.36KV INTERBUS XFMR.

LH-2-B 36-18/18MVA 13.8/4.36/4.36KV INTERBUS XFMR.

LH-2-A 36-18/18MVA 13.8/4.36/4.36KV NO H2201 3000A H2202 3000A H22 4.16KV BUS 3000A, 250MVA 1200A MOTOR FEEDER (TYPICAL)

NO H2101 3000A H2102 3000A H21 4.16KV BUS 3000A, 250MVA 1200A MOTOR FEEDER (TYPICAL)

RES. 1.2 2000A, 10SEC.

EH2101 2000A TH-21 EH1101 2000A TH-12 INTERBUS XFMR.

LH-1-A 36-18/18MVA 13.8/4.36/4.36KV LOAD CENTER FEEDER (TYPICAL)

L1202 2000A LOAD CENTER FEEDER (TYPICAL)

L1102 2000A 1200A L1206 1200A L1103 1200A 1200A H1202 3000A 1200A MOTOR FEEDER (TYPICAL)

INTERBUS XFMR.

LH-1-B 36-18/18MVA 13.8/4.36/4.36KV RES. 1.2 2000A, 10SEC.

RES. 1.2 2000A, 10SEC.

L11 13.8KV BUS 2000A, 1000MVA L12 13.8KV BUS 2000A, 1000MVA RES. 1.2 2000A, 10SEC.

INTERBUS XFMR.

LH-1-C 36-18/18MVA 13.8/4.36/4.36KV MOTOR FEEDER (TYPICAL) 1200A H11 4.16KV BUS 3000A H1101 3000A H1102 3000A NO 250MVA TRANSMISSION STATION FEEDER H1110 1200A NO H1201 3000A H12 4.16KV BUS 3000A, 250MVA MAIN GEN XFMR 1-PY-T 3-345KV/22KV A

B C

112 M

111 DISC SWITCH UNIT AUX XFMR 110-PY-B 64-40/40MVA 22.0/13.8/13.8KV GENERATOR 1-PY-G 1446.7 MVA 0.9F 22KV RES 4.0 2000A, 10SEC.

RES 4.0 2000A, 10SEC.

GEN. NEUTRAL XFMR 14.4/0.24KV RES. 0.4064 122.5KW CONT.

NOTES:

1. MOTOR FEEDS SHOWN ARE TYPICAL ONLY.

2. TRANSFORMER RATINGS, UNLESS OTHER-WISE NOTED, ARE SHOWN FOR 55C TEMPERATURE RISE AND FORCED COOLING.

3. TRANSFORMER IMPENDANCE BASE IS PRIMARY MVA.

4. REF. DWG. D-206-020 FOR LOAD CENTER.

DIVISION 1 DIVISION 1 DIVISION 3 DIVISION 2 UNIT 1 UNIT 2 UNIT 1 UNIT 2 NUCLEAR SAFETY RELATED NUCLEAR SAFETY RELATED 1000MVA CEI DWG. 5-W25068 NUCLEAR SAFETY RELATED 10 KVA 1 10 KVA 1 10 KVA 1 25KVA, 1 415MVA BACK FEED XFMR PATH PROPOSED TECHNICAL SPECIFiCATION CHANGE.S

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(2 Pages Follow)

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a.

Two qualified circuits between the offsite transmission network and the onsite Class IE AC Electric Power Distribution System_.fone of which mq~ be a delayed access circuitl: and

b.

Three diesel generators (DGs).

APPLICABILITY:

MODES 1. 2. and 3.

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

Division 3 AC electrical power sources are not required to be OPERABLE when High Pressure Core Spray System is inoperable.

ACTIONS

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION A.

One required offsite circuit inoperable.

PERRY - UN IT 1 A.l AND REQUIRED ACTION COMPLETION TIME Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for OPERABLE required offsite circuit.

AND 3.8-1 Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter (continued)

Amendment No.

131

ACTIONS CONDITION A.

(continued)

A.2 B.

One required DG inoperable.

B.1 AND B.2 AND PERRY - UN IT 1 AC Sources-Operating 3.8.1 REQUIRED ACTION

,COMPLETION TIME Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months offsite circuit to OPERABLE status.

AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from aiscover~ tnat OPERABLE circuit is a ae I a~ea ~Lc:cess circuit AND 17 days from discovery of fa il ure to meet LCO Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for OPERABLE required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s), sug~orted discovery of by the inopera e DG, Condition B inoperable when the concurrent with redundant required i noperabi 1 ity feature(s) are of redundant inoperable.

required feature(s)

(continued) 3.8-2 Amendment No. 99 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES!C:. :'

(FOR INFORMATION)

(15 Pages Follow)

FORMATION AC Sources - Operati ng.

B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operat i ng BASES BACKGROUND The circuits betvveen the

- switchyard and the 13.8 kV buses (L 10 and L20) may utilize appropriate paths involving two startup transformers (immediate access circuits) and the Unit 1 auxiliary transformer (backfeed mode - delayed access circuit). When maintaining the two required offsite circuits, at least one will utilize a startup transformer. This arrangement satIsfies the guidance of GOC 17 (Ref. 1 ) that at least one of these two required circuits can be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

PEHRY - UNIT 1 The plant Class IE AC Electrical Power Distribution System AC sources consist of the offsite power sources and the onsite standby power sources (Division 1. 2. and 3 diesel generators (OGs>>.. As required by 10 CFR 50. Appendix A.

GDC 17 (Ref. 1). the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The Class IE AC distribution system supplies. electrical power to three divisional load groups. with each division powered by an independent Class IE 4.16 leV ESF bus.(refer to LCO 3.8.7. "Distribution Systems-Operating"). Each ESF bus

.receives power from the 345 leV grid through two separate independent circuits. Each ESF bus has a dedicated onsite DG.

The ESF systems of *any two of the three divisions provide for the minimum safety functions necessary to shut down the uni t and ma i nta in it ina sa fe shutdown cond; t ion..

Off site power is supplied to the switchyard from the -

transmission network.

From the switchyard two electrically' and physically separated circuits provide AC power to each 4.16 kV ESF bus. The offsite AC electrical power circuits are designed -and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A detailed description of the off site power network and circuits to the onsite Closs IE ESF buses 1s found in USAR. Chapter 8 (Ref. 2).

An offsi te ci rcui t cons i sts of all brea kers. transformers.

switches. interrupting devices. cabling. and controls required to transmit power from the offsite transmission network to the onsite Class IE ESF bus(es).

The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. A DG starts automatically on loss of coolant accident (LOCA) signal (i.e.. low reactor water level signal or high drywell pressure signal) or on an ESF bus degraded voltage or undervoltage signal (refer to LCO 3.3.8.1. "Loss of Power (LOP) Instrumentation").

(continued)

B 3.8-1 Revision No. 0.

BASES.

BACKGROUND (continued)

INFORMATION ONLY AC Sources-Operating B 3.8.1 No changes to this page; incl4ded for c9nt~xt.

In the event of a loss of preferred power. the ESF electrical loads are automatically connected to theDGs in."'_,.

sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a LOCA.

Certain required plant loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class IE Distribution System or to prevent overloading the DG.

Ratings for DGs satisfy the requirements of Regulatory Guide 1.9 (Ref. 3).

The continuous service rating is 7000 Kw for Divisions 1 and 2 and is 2600 Kw for Division 3.

with 10% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

APPLICABLE The initial conditions of DBA and transient analyses in the SAFETY ANALYSES USAR. Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5). assume ESF systems are OPERABLE.

The AC electrical power sources are designed to provide sufficient capacity. capability.

redundancy. and reliability to ensure the availability of necessary power to ESF systems so that the fuel. Reactor Coolant System (RCS). and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2. Power Distribution Limits; PERRY - UN IT 1 Section 3.4. Reactor Coolant System (RCS); and Section 3.6.

Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit as discussed in Reference 2. This includes maintaining the onsite or offsite AC sources OPERABLE during accident conditions in the event of:

a.

An assumed loss of all offsite power or all onsite AC power: and

b.

A worst case single failure.

AC sources satisfy the requirements of Criterion 3 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132).

(continued)

B 3_8-2 Revision No. 7

NFORMATION ONLY AC Sources - Operati ng "

"." ::"S" 3.8~1 BASES (continued) tCO Two" qua 1ff; ed ":e; rcu; ts between" 'thttoffs i te transm*1*ssf'on'>":

network and the onsite Class IE Distribution System. and "

three separate and independent DGs (Divisions 1.. 2. and 3).

ensure availability of the"required power to shut down the reactor and maintain it in a safe sh~tdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified offsite circuits are those that are described in the USAR and are part of the licensing basis for the u~it.

"Each offsite circuit must be capable 'of maintaining rate~

frequency and voltage. and accepting required loads during" an accident. while connected to the ESF buses. One off site" circuit. consists of the Unit 1 startup transformer through"

. the Unit 1 interbus transformer. to the Class IE 4.16 kV ESF buses through ~ource feeder breakers for each division. The second offsite circuit consists of the Unit 2 startup transformer through the Unit 2 interbus transformer. to the r------:-~ Cl ass IE 4.16 kV ESF buses through source feeder breakers

to respond to for each dfvision. Several additional paths from the anticipated transmission system to' the Class IE srfstem are available as operational alternate off site power sources if lo~s of a startup occurrences.

transfonner occurs. For example. for Unit 1. this includes One of the feeding 13.8 kV bus lIO from bus Lll or 1I2. via the unit" circuits is auxil i ary trans former. A motor-operated di sconnect swi tch is provided to facilitate the availability of this path "designed to be within the time required for operator action. In all cases.

available there are at least two separate paths. with sufficient within a few capacity provided from the transmission network to the seconds standby power distribution system. available in sufficient following a time. in accordance with GOC-17.

loss-of-coolant Each DG must be capable of starting. accelerating to rated.

L.;;;a~cc_id_e_n_t._---, speed and voltage. and connecting to its respective ESF bus on detection of bus undervoltage. This sequence must be accomplished within 10 seconds for the DiviSion 1 and Z 0Gs:

and 13 seconds for the Division 3 DG.

Each DG must also be capable of accepting required loads within the assumed loading sequence intervals. and must continue to operate until offsite power can be restored "to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot and DG in standby with engine at ambient conditions. Additional OG capabilities must be demonstrated" to meet required Surveillances.* e.g.* capability of the OG to revert to standby status on an ECCS signal while operating in parallel test mode.

(continued)

PERRY' - UNIT 1 B 3.8-3 Revision No. 1

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(continued)

APPLICABILITY ACTIONS PERRY - UNIT 1 FORMATION 0 AC Sources-Operating B 3.8.1 No changes to this page; inCluded for.context*.: -.: -- --. -

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Proper sequencing of loa(K;':'including tripping"o'('.'

nonessential loads. is*a* -required.function.*for*;both offs-ite*

circuit and DG OPERABILITY for Divisions 1 and 2.

The AC sources in one division must be separate and independent (to the extent possible) of the AC sources in the other division(s). For the DGs. the separation and independence are complete.

For the offsite AC sources. the separation and independence are to the extent practical.

The AC sources are required to be OPERABLE in MODES 1. 2.

and 3 to ensure that:

a.

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

b.

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

A Note has been added taking exception to the Applicability requirements for Division 3 AC sources. provided the HPCS System is declared inoperable. This exception is intended to allow declaring of the HPCS System inoperable either in lieu of declaring the Division 3 AC source inoperable. or at any time subsequent to entering ACTIONS for an inoperable Division 3 AC source. This exception is acceptable since.

with the HPCS System inoperable and the associated ACTIONS entered. the Division 3 AC sources provide no additional assurance of meeting the above criteria.

AC power reguirements for MODES 4 and 5 are covered in LCO 3.8.2. 'AC Sources-Shutdown."

A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG. 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.

(continued)

B 3.8-4 Revision No. 5

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BASES --

ACTIONS (continued)

PERRY - UNIT 1 IINFOR-MATION ONLY I AC Sources-Operating B 3.8.1 No change~: to this page; included for-context. -

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To ensure a highly reliable power source remains. it -is necessary to verify the availability of the remaining -

required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform." a failure of SR 3.8.1.1 acceptance criteria does not result in the Required Action not met.

However. if a second required circuit fails SR 3.8.1.1. the second offsite circuit is inoperable. and Condition C. for two offsite circuits inoperable. is entered.

(continued)

B 3.8-4a Revision No. 5

BASES

" ACTIONS (continued)

When only one required offsite circuit remains OPERABLE, and that circuit is the delayed access circuit through L 11 or L 12 to L10, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time limits plant operation to a period shorter than that otherwise provided per the Regulatory Guide.

PERRY - UN IT l' ATION ON AC Sources - Operat 1 ng _

_-:::;B 3..8.,1 According to Regulatory Guide 1.93 (Ref. 6). operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Completion Time assumes sufficient offsite power remains to p~ the minimum loads needed to respond to analyzed events.~n the event one or more divisions are without offsite ower. this assumption is not me):.)

re or0 e Completion Time is,specitt'ed.

ould two (or more) divisions be affected. the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is conservative with respect to the Regulatory Guide assumptions supporting a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 'Completion Time for both off site circuits ino erable. With one offsite ClrCUl lnopera e.

e re la 1 1 Y 0 e offsite system is degraded. and the potential for a loss of offsite power is increased. with attendant potential for a challenge to the plant safety systems.

In this Condition. however. the remaining OPERABLE offsite circuit and OGs are adequate to supply electrical power to the onsite Class lE distribution system.

The Completion Ti~a~nto account the ~apacityand capability of the 1emainlng AC sources. reasonable time for repairs. and the low probability of a DBA occurring during thifijS'Od.,

to~/th The Completion Time for Required Action A.2 esta 1S es a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCD. If Condition A1s entered while. for instance. a DG is inoperable and that DG is subsequently returned OPERABLE. the lCO may already have been not met for up to 14 days. This -.situation*could lead to a total of 17 dllYs.

since initial failure to meet the lCO. to restore the' off site circuit. At this ~ime. a DG could again become inoperable. the circuit restored OPERABLE. and an additional 14 days (for a total of 31 days) allowed prior to complete restoration of the lCO., The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of fa1lure to meet the lCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 17 day Completion Times for Required Action A.2 means that both Completion Times apply simultaneously.

and the more restrictive must be met.

(continul:!dl B 3.8-5 Revision No.2

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ACTIONS PERRY - UNIT 1

[~FORMATION ONL AC Sources-Operating B 3.8.1

.. ~ ;.: No changes to this Pt3gEi; in~hJded for context ;..,:;;."::~;

A.2 (continued)

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

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

B.1 To ensure a highly reliable power source remains. it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform." a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met.

However. if a circuit fails to pass SR 3.8.1.1. it is inoperable.

Upon offsite circuit inoperability. additional Conditions must then be entered.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power. during the period that a DG is inoperable. does not result in a loss of safety function of critical features (systems. subsystems. components. or devices). These features are designed with redundant safety related divisions (i.e.. single division features are excluded. although. for this Required Action. Division 3 must be included. and must be considered redundant to Division 1 and 2 Emergency Core Cooling System (ECCS)).

Redundant required features failures consist of inoperable features associated with a division redundant to the division that has an inoperable DG.

When performing the ECCS portion of this cross-division check. if any ECCS system(s)/subsystem(s) in either of the other two redundant divisions are discovered to be inoperable. the Completion Time begins; when it expires. all ECCS supported by the inoperable DG are declared inoperable.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

In this Required Action. the Completion Time only begins on discovery that both:

a.

An inoperable DG exists; and

b.

A required feature on another division is inoperable.

(continued)

B 3.8-6 Revision NO.6

'J BASES ACTIONS PERRY - UNIT 1 INFORMATION ONL AC Sources - Operati ng B 3.8.1 B.2 (continued)

No changes to thi_s pag~;

included for context -

,... *.. ;7~*.*.-:-...

If. at any time duri-ng the exi stence of -thi s Condi ti on (one DG inoperable). a required feature subsequently becomes inoperable. this Completion Time begins to be tracked.

Discovering one required DG inoperable coincident with one or more required support or supported features. or both.

that are associated with the OPERABLE O6(s). results in starting the Completion Time for the Required Action.

Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

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

B.3.1 and B.3.2 Required Action B.3.1 provides an _allowance to avoid unnecessary testing of OPERABLE O6s.

If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE OGs. SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s). the other DG(s) are declared inoperable upon discovery. and Condition E and potentially Condition G of LCO 3.8.1 is entered.

Once the failure is repaired. and the common cause failure no longer exists. Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining O6(s).

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those O6(s).

(continued)

B 3.8-7 Revision No. 0

ACTIONS PERRY - UN IT 1 MATION 0 AC Sources-Operating B 3.8.1 No changes to this page; included for context B.3.1 and B.3.'2 (continued)

In the event the inoperable DG is restored to OPERABLE status prior to completing either Required Actions B.3.1 or B.3.2. the corrective actions program will continue to evaluate the common cause failure possibility. This continued evaluation. however. is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7). 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable time to confirm that the OPERABLE DG(s) are not affected by the same problem as the inoperable DG.

B.4 In Condition B. the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class lE distribution system.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for Division 3 and the 14 day Completion Time for Divisions 1 and 2 take 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.

The Division 1 and 2 Emergency Diesel Generators (EDGs) have a 14 day Completion Time. The period of the Completion Time that is ~ 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is considered to be the "risk-informed" portion of the Completion Time. The provisions of the Configuration Risk Management Program (CRMP)in Specification 5.5.13.1 must be applied to use the risk-informed portion of the Completion Time. The risk-informed portion of the Completion Time is meant to be entered in a controlled fashion whenever possible with a work scope that limits the risk to the plant. The CRMP is controlled by plant administrative procedures.

One preventive maintenance outage using the risk-informed portion of the 14 day Completion Time may be planned for one EDG. Division 1 or 2. within a period of 365 days (one year). The basis of the "once per year" frequency is to minimize the number of times that major intrusive maintenance is performed on the diesels. In accordance with the CRMP and the acceptance criteria of RG 1.177. a qualitative assessment may be used to assess time periods between planned extended preventive maintenance outages of less than one year.

(continued)

B 3.8-8 Revision NO.5

' : :::.i:::",::::, ~

ACTIONS PERRY - UNIT 1 INFORMATION ONL AC Sources-Operating B 3.S.1 No changes to this page; :,

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, B.4 (continued)

The risk-informed provisions in the CRMP also apply if entry into the risk-informed portion of the Completion Time is necessary for corrective maintenance. In addition. the 10CFR50.65 (Maintenance Rule) program includes performance criteria for 'cumulative out-of-service time of the diesels.

Entries into the risk-informed porti'on of the Completion Time for corrective maintenance do not affect the "once per year" frequency of planned extended outages described above.

although such entries may shorten the allowable length of a planned preventive maintenance outage due to the Maintenance Rule performance criteria.

The third Completion Time for Required Action B.4,

establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO.

If Condition B is entered while. for instance. an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE. the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation could lead to a total of 17 days. since initial failure to meet the LCO. to restore the DG.

At this time. an offsite circuit could again become inoperable. the DG restored OPERABLE. and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to complete restoration of the LCO.

The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the Completion Times means that the three Completion Times apply simultaneously. and the more restrictive Completion Time must be met.

(continued)

B 3.S-Sa Revision No. 5

ACTIONS PERRY - UN IT 1 FORMATION ONLY AC Sources-Operating B 3.8.1 No changes!o this page; included for cOfltext B.4 (continued)

As in Required Action B.2. the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This exception results in establishing the "time zero" at the time the LCO was initially not met. instead of the time Condition B was entered.

C.1 and C.2 Required Action C~l addresses actions to be taken in the event of concurrent failure of redundant required features (systems. subsystems. components. or devices). Required Action C.1 reduces the vulnerability to a loss of function.

The rationale for the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable. based upon the assumption that two complete safety divisions are OPERABLE.

When a concurrent redundant required feature failure exists.

this assumption is not the case. and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are designed with redundant safety related divisions (i.e..

single division systems are excluded. although. for this Required Action. Division 3 must be included. and must be considered redundant to Division 1 and 2 ECCS).

Redundant required features failures consist of any of these features that are inoperable. because any inoperability is on a division redundant to a division with inoperable offsite circuits.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

In this Required Action. the Completion Time only begins on discovery that both:

a.

All required offsite circuits are inoperable; and

b.

A required feature is inoperable.

If. at any time during the existence of this Condition (two off site circuits inoperable). a required feature subsequently becomes inoperable. this Completion Time begins to be tracked.

(continued)

B 3.8-9 Revision NO.6

BASES ACTIONS PERRY - UNIT 1 INFORMATION ONLY AC Sources - Operati ng B 3.8.1 C.1 and C.2 (continued)

No changes to this page; included for context According to Regulatory Guide 1.93 (Ref. 6). operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident: however. the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

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

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

With both of the required offsite Circuits inoperable.

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

According to Regulatory Guide 1.93 (Ref. 6). with the available offsite AC sources two less than required by the LCO. operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If two offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . unrestricted operation (continued)

B 3.8-10 Revision No. 0

BASES...

(frJFORMATION ONLY I AC Sources - Ope rat i ng B 3.B.1 No changes to this page; included.,for context*

'~~:'~;::::'.::~::'~:~

-" -.,-.'.-----------~~---------------.. --.. --.::.---.---.;.~'

. ACTIONS PERRY - UNIT 1 C.1 and C.2 (contTnued) may continue.:' f(only one offsite s()u'rce is restored'within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . power operation continues in accordance with Condition A.

0.1 and 0.2 Pursuant to lCO 3.0.6. the Actions for lCO 3.B.7 "Distribution Systems-Operating." would not be entered even if all AC sources to it were inoperable. resulting in de-energization. Therefore. the Required Actions of Condition 0 are modified by a Note to indicate that when Condition 0 is entered with no AC source to any division.

Actions for lCO 3.B.7 must be immediately entered. This allows Condition 0 to provide requirements for the loss of the off site circuit and one DG without regard to whether a division is de-energized.

lCO 3.B.7 provides the appropriate restrictions for a de-energized division.

According to Regulatory Guide 1.93 (Ref. 6). operation may continue in Condition D for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In Condition D. individual redundancy is lost in both the off site electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power. however. the reliability of the power systems in this Condition may appear higher than that in Condition C (loss of both required off site circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes, into account the capacity and capability of the remaining AC sources. reasonable time for repairs. and low probability of a DBA occurring during this period.

L1 With two DGs inoperable. there is one remaining standby AC source. 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 the majority of ESF equipment at this level of degradation.

(CQrit; nuedJ B 3.8-11 Revision No. 0

- .ACTIONS PERRY - UNIT 1

[INFORMATION ONLY I AC Sources - Operati ng B 3.B.1 No. changes to this page;

., Lncll.ld~d for context;, ~.

E.1 (centinued)'"

the risk associated with conti'nued eperation for a'*Very shert time could be less than that asseciated with an immediate contrelled shutdown (the immediate shutdown ceuld cause grid instability. which ceuld result in a tetal loss ef AC pewer). Since any inadvertent generater trip could also result in a tetal less of offsite AC pewer. hewever.

the time allewed fer continued operation is severely restricted. The intent here is to. avaid the risk associated with an immediate cantralled shutdawn and to minimize the risk asseciated with this level af degradatien.

Accarding to. Regu1atery Guide 1.93 (Ref. 6). with both DGs inoperable. operatienmay centinue fer a peried that sheuld net exceed 2 heurs. This Cempletien Time assumes complete loss of ansite (DG) AC capability to power the minimum leads needed to. respond to. analyzed events.

In the event Divisien 3 DG in canjunctien with Division 1 er 2 OG is inaperable. with Divisien 1 er 2 remaining. a significant spectrum ef breaks weuld be capable of being respended to.

with ensite power.

Even the werst case event weuld be mi t i gated to some extent - an extent greater than a typi ca 1 two. divisien design in which this conditien represents cemplete less ef ensite pewer functien. Given the remaining functien. a 24 heur Cempletien Time is apprepriate. At the end ef this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months peried. the HPCS System ceuld be declared ineperable (see Applicability Nete) and this Cendition ceuld be exited with only one required OG remaining inoperable. Hewever. with a Division 1 ar 2 DG remaining inoperable and the HPCS System declared inoperable. a redundant required feature failure exists.

according to Required Action B.2.

F.1 and F.2 If the inoperable AC electrical power sources cannot be restared to. OPERABLE status within the associated Completion Time. the unit must be brought to a MODE in which the LCO does not apply.

To. achieve this status. the unit must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable.

based on operating experience. to reach the required plant conditions frem full power conditions in an orderly manner and witheut challenging plant systems.

(continued)

B 3.B-12 Revision No.. 0

'k'

'.:.,8~E$:,:

.. "ACTIONS

,'" :,,:.c cont i nued)

SURVEILLANCE REQUIREMENTS PERRY - UNIT 1 AC Sources - Operat i ng B 3.8.1 No changes to this page; included for context ".,.::'-

. ~. **::~~~***-;~!:.2 '.~':-~.......

... -'.. '. "~::-.. -. ::

--.~

~

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

The AC sources are designed to permit inspection and testing of all important areas and features. especially those that have a standby function. in accordance with 10 CFR 50. GDC 18 (Ref. 8). PeriodiC component tests are supplemented by extensive functional tests during refueling outages under simulated accident conditions. The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3).

Regulatory Guide 1.108 (Ref. 9). and Regulatory Guide 1.137 (Ref. 10).

Where the SRs discussed herein specify voltage and frequency tolerances. the minimum and maximum steady state output voltages are 3900 V and 4400 V. respectively. The minimum allowable DG voltage provides an acceptable margin above the maximum allowable degraded voltage relay reset value.

The maximum allowable DG voltage is based on the maximum safety bus voltage which will result in a worst case over-excitation level of 111% at the terminals of any device connected to the bus.

The specified minimum and maximum frequencies of the DG of 58.8 Hz and 61.2 Hz. respectively.

are equal to +/- 2% of the 60 Hz nominal frequency.

The specified steady state voltage and frequency ranges are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct (continued)

B 3.8-13 Revision No. 0

v t e Letter Sequence Request
TAC:ME7232, (Withdrawn, Closed)
Initiation Request, Request Acceptance... Administration Questions Answers Results Withdrawal Other:
MONTHYEAR2011-10-03 [Table View]

L-11-322, License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating

Text

SUBJECT:

Enclosure:

Subject:

SUMMARY

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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L-11-322, License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating

Text

SUBJECT:

Enclosure:

Subject:

SUMMARY

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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