RBG-47461, Application for Change to Technical Specification 3.8.1, AC Sources - Operating
| ML14212A396 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/09/2014 |
| From: | Olson E Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RBG-47461 | |
| Download: ML14212A396 (36) | |
Text
Entergy Operations, Inc.
River Bend Station f5485 U.S. Highway 61N Enterg St. Francisville, LA 70775 Tel 225-381-4374 Eric Olson Site Vice President RBG-47461 July 9, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Application for Change to Technical Specification 3.8.1, "AC Sources -
Operating" River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47
Dear Sir or Madam:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for River Bend Station (RBS), Unit 1.
The proposed amendment modifies the existing Surveillance Requirements (SRs) related to Technical Specification 3.8.1, "AC Sources - Operating" to revise the SR Acceptance Criteria Tolerance Band (ACTB). The proposed changes will; lower the upper bound of the frequency SR ACTB, lower the upper bound of the voltage SR ACTB for DG 1A and DG 1 B (existing DG 1 C voltage SR ACTB is retained), and raise the lower bound of the test load SR ACTB. The Bases are also revised to reflect the change to the SRs. provides a description of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides the existing TS BASES pages marked up to show the proposed changes. Attachment 4 includes regulatory commitments to be implemented in support of this change.
Although this request is neither exigent nor emergency, your prompt review is requested.
If you have any questions or require additional information, please contact Mr. J. A. Clark at (225) 381-4177
RBG-47461 Page 2 of 3 Once approved, the amendment shall be implemented within 60 days.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 9, 2014 Sincerely, EO/JAC/bmb Attachments:
- 1. Analysis of Proposed Technical Specification Change
- 2. Proposed Technical Specification Changes (mark-up)
- 3. Proposed Technical Specification BASES Changes (mark-up for information only)
- 4. List of Regulatory Commitments cc: Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Attn: Mr. Alan Wang MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852
RBG-47461 Page 3 of 3 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue P. O. Box 13326 Austin, TX 78711-3326 RBFI-14-0055 LAR 2014-02
Attachment I RBG-47461 Analysis of Proposed Technical Specification Change 1
SUMMARY
DESCRIPTION..................................................................................................
1 2
DETAILED DESCRIPTION.............................................................................................
2 3
TECHNICAL EVALUATION...........................................................................................
6 3.1 In tro d u c tio n.....................................................
6 3.2 Frequency Tolerance Changes..............................................................................
6 3.3 Voltage Tolerance Changes...................................................................................
8 3.4 Test Load Tolerance Changes.................................................................................
9 3.5 Combined Changes............................................................................................
10 4
REGULATORY EVALUATION..............................................................................
11 5
NO SIGNIFICANT HAZARDS CONSIDERATION........................................................
13 6
ENVIRONMENTAL CONSIDERATION..........................................................................
15 7
P R E C E D E N T S..................................................................................................................
16
RBG-47461 Page 1 of 16 1
SUMMARY
DESCRIPTION In the discussions that follow, SR ACTB is the acronym for Surveillance Requirement (SR)
Acceptance Criteria Tolerance Band (ACTB).
River Bend Station has three (3) Emergency Diesel Generators (EDG):
DG 1A - Division I DG lB-Division II DG 1C-Division Ill Changes are proposed to Technical Specification 3.8.1, "AC Sources - Operating" to revise the SR ACTBs for all three EDGs in SR 3.8.1.2, SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.14, SR 3.8.1.15, SR 3.8.1.19, and SR 3.8.1.20.
The proposed changes will (a) lower the upper bound of the frequency SR ACTB, (b) lower the upper bound of the voltage SR ACTB for DG 1A and DG 1B (existing DG 1C voltage SR ACTB is retained), and (c) raise the lower bound of the test load SR ACTB.
These changes will align the SR ACTBs with updated EDG electrical loading calculations and ensure margin between the EDG SR test loads and the EDG maximum calculated loads.
Frequency Steady State SR ACTB Changes DG 1A and DG 1B From:> 58.8 Hz and < 61.2 Hz [60.0 +/-1.2 Hz (+/-2.0%)]
To:
> 58.8 Hz and < 60.2 Hz [59.7 +0.5 Hz / -0.9 Hz (+ 0.8% /-1.5%)]
DG 1C From:> 58.8 Hz and < 61.2 Hz [60.0 +/-1.2 Hz (+/-2.0%)]
To:
> 58.8 Hz and < 60.2 Hz [60.0 +0.2 Hz / -1.2 Hz (+ 0.3% /-2.0%)]
The revised frequency SR ATCB applies when the EDG is not synchronized to offsite power,. and the EDG governor is controlling frequency (isochronous mode).
Voltage Steady State SR ACTB Changes DG 1A and DG 1B From:> 3740 V and < 4580 V [4160 +/-420V (+/-10%, rounded to +/- 420 V)]
To:
> 3740 V and <4368 V [4160 + 208V, - 420V (+5%, -10%, rounded to -420 V)]
DG 1C No change from existing SR ACTB:
> 3740 V and < 4580 V [4160 +/-420V (+/-10% rounded to +/- 420 V)]
RBG-47461 Page 2 of 16 Test Load Steady State SR ACTB Changes DG 1A and DG 1B From: > 3000 kW and < 3100 kW To:
> 3050 kW and < 3100 kW DG 1C From: > 2500 kW and < 2600 kW To:
> 2525 kW and < 2600 kW In addition to the above changes to the RBS Technical Specifications the BASES will be revised to be consistent with these changes. These changes are expected to include; a revision to the discussion in SR 3.8.1.3 on the selected load values based upon instrument range as the current testing methods are not limited to the identified meter, and, a revision to SR 3.8.1.14 to revise the load values as noted above and clarify the 110% load equivalent testing is limited to the Division III EDG. The proposed BASES changes are included as Attachment 3 of this submittal for information.
2 DETAILED DESCRIPTION In the discussions that follow, SR ACTB is the acronym for Surveillance Requirement (SR)
Acceptance Criteria Tolerance Band (ACTB).
The proposed changes are described below. Technical Specification (TS) markups are provided in Attachment 2. Technical Specification Bases markups are provided in (for information only). Proposed Technical Specification pages are provided in Attachment 4.
2.1 Description of Proposed Changes Changes are proposed to Technical Specification 3.8.1, "AC Sources - Operating" to revise the SR ACTBs in SR 3.8.1.2, SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.14, SR 3.8.1.15, SR 3.8.1.19, and SR 3.8.1.20. The proposed changes will (a) lower the upper bound of the frequency SR ACTB, (b) lower the upper bound of the voltage SR ACTB for DG 1A and DG 1B (existing DG 1C voltage SR ACTB is retained), and (c) raise the lower bound of the test load SR ACTB.
These changes will align the SR ACTBs with updated EDG electrical loading calculations and ensure margin between the EDG SR test loads and the EDG maximum calculated loads, which will demonstrate TS Operability of the EDGs, and ensure that the EDGs operate as assumed in the accident analyses.
The proposed changes do not involve any physical alteration of the plant (i.e., no new or different type of equipment will be installed), or a change in the methods governing EDG operation.
The revised steady state frequency, voltage, and test power limits are within, and more restrictive than, the existing steady state SR ACTBs. The effect of the proposed changes is, thus, to tighten the steady state SR ACTBs, which will not adversely affect the EDGs or
RBG-47461 Page 3 of 16 components that are powered by the EDGs, such as pumps, motorized valves, fans, and relays. As discussed in the Technical Evaluation, the revised steady state SR ACTBs are within the capabilities of the respective EDG, governor, voltage regulator, and watt meter.
TS 3.8.2, "AC Sources - Shutdown," requires certain SRs from TS 3.8.1 to be performed that are necessary to ensure operability of the AC sources when shutdown. Therefore, the proposed change is also relevant to TS 3.8.2 SRs. However, there are no revisions to TS 3.8.2.
2.2 Proposed Chanqes Note, replaced values are shown with a double strikethrough, and new values are bolded.
The proposed changes for DG 1A and DG 1B are identical. The proposed changes for DG 1C are not identical to the DG 1A and DG 1B changes. Where the proposed changes cause the DG 1C acceptance criteria to differ from the DG 1A and DG 1B acceptance criteria, the existing DG 1C acceptance criteria are restated explicitly (e.g., the DG 1C voltage SR ACTB is not changed, and therefore, is restated).
SR 3.8.1.2 is being revised to verify each DG starts from standby conditions and achieves:
- a. For DG 1A and DG 1B, steady state voltage> 3740 V and <460 4368 V, and frequency > 58.8 Hz and < 64= 60.2 Hz.
b.2 Steady state voltage > 3740 V and < 4580 V and frequency > 58.8 Hz and < 642 60.2 Hz SR 3.8.1.3 is being revised to verify each DG operates for > 60 minutes at a load
> *QQQ 3050 kW and < 3100 kWfor DG 1A and DG 1B, and
> Q 2525 kW and < 2600 kW for DG 1C SR 3.8.1.7 is being revised to verify each DG starts from standby conditions and achieves:
- a. ForDG1AandDG1B
- 2. Steady State voltage > 3740 V and < 458 4368 V, and frequency > 58.8 Hz and
< 64= 60.2 Hz.
- b.
ForDG1C:
- 3. Steady State voltage > 3740 V and < 4580 V and frequency > 58.8 Hz and <
64=
60.2 Hz.
SR 3.8.1.10 is being revised to verify each DG operating at a power factor < 0.9 does not trip and voltage is maintained < 4784 V for DG 1A and DG 1 B and < 5400 V for DG 1 C during and following a load rejection of a load > Q 3050 kW and < 3130 kW for DGs 1Aand 1Band
> -Q 2525 kW and < 2600 for DG 1C.
RBG-47461 Page 4 of 16 SR 3.8.1.11 is being revised to verify on an actual or simulated loss of offsite power signal:
- c. DG auto-starts from standby condition and:
- 3. maintains steady state voltage > 3740 V and <458Q 4368 V for DG 1A and DG IB and > 3740 V and < 4580 V for DG IC,
- 4. maintains steady state frequency > 58.8 and < 64 60.2 Hz SR 3.8.1.12 is being revised to verify on an actual or simulated Emergency Core Cooling System (ECCS) initiation signal each DG auto-starts from standby condition and:
- c. Achieves steady state voltage > 3740 V and <48 4368 V for DG IA and DG I B and > 3740 V and < 4580 V for DG IC and frequency > 58.8 and < 64=1 60.2 Hz SR 3.8.1.14 is being revised to verify each DG operating at a power factor < 0.9, operates for
> 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
- b. for DG 1C:
- 2. For the remaining hours of the test loaded >
Q 2525 kW and < 2600 kW SR 3.8.1.15 Note 1 and SR 2 are being revised to:
Note 1. This surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> loaded > *GO* 3050 kW and < 3100 kWfor DG 1A and DG 1 B, and >_2G 2525 kW and < 2600 kW for DG 1 C, or operating temperatures have stabilized, whichever is longer.
Verify each DG starts and achieves:
3740 V and <_4580 V for DG IC, and frequency > 58.8 Hz and < 64=
60.2 Hz SR 3.8.1.19 is being revised to verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- c.
DG auto-starts from standby condition and:
- 3. achieves steady state voltage > 3740 V and <
8 4368 V for DG IA and DG lB, and > 3740 V and < 4580 V for DG 1C,
- 4. achieves steady state frequency > 58.8 Hz and < 64 60.2 Hz SR 3.8.1.20 is being revised to verify when started simultaneously from standby condition, each DG achieves
RBG-47461 Page 5 of 16
- 2. steady state voltage > 3740 V and <4,,
4368 V for DG IA and DG 1B and >
3740 V and < 4580 V for DG IC and frequency > 58.8 Hz and < 64= 60.2 Hz.
2.3 Background
The River Bend Station has two standby EDGs (DG 1A and DG 1 B) that provide power to the emergency 4.16-kV buses and a high pressure core spray EDG (DG 1C).
When the diesel start signal is received, the EDGs are designed to attain rated voltage and frequency, and be ready to accept load in < 10 seconds (DG 1A and 1B), and < 13 seconds (DG 1C).
The USAR discusses the EDGs in USAR Sections 8.1.6.2, 8.3.1.2.2.1 and 8.3.1.2.2.2.
The applicable requirements associated with conformance to Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1 E Onsite Electric Power Systems at Nuclear Power Plants," Revision 2, are discussed in USAR Table 1.8-1, Section 8.3.1.2.2.1, and Section 8.3.1.2.2.2.
The station's EDGs are tested at 1-month, 6-month, 24-month and 120-month intervals per the Technical Specification SRs. In order to demonstrate margin the SR test load should be > the maximum expected load. In the course of an NRC Component Design Basis Inspection (CDBI), it was found that the EDG electrical load calculations did not account for the EDG frequency variation and, therefore, did not provide for the maximum expected load conditions. This condition is described in the CDBI report, where it is characterized as a finding of low safety significance. It is tracked in the River Bend Corrective Action Program.
The EDG electrical load calculations have been updated, and incorporate the proposed SR ACTBs for both frequency and voltage. The proposed changes will bring the SR ACTBs into alignment with the updated calculations. The proposed SR ACTBs for test loads are greater than the maximum calculated loads (using the proposed SR frequency and voltage ACTBs).
The revised steady state frequency, voltage, and power level SR ACTBs have been determined to have no adverse effects. Under these circumstances, the revised steady state SR ACTBs were administratively incorporated into the SR tests prior to completing the amendment process. Therefore, administrative controls have been established, in accordance with NRC Administrative Letter 98-10, to incorporate the revised SR ACTBs into the SR test procedures under the provisions of 50.59 during the license amendment
- process, These proposed changes, combined with the administrative controls, comprise the corrective action that is necessary to demonstrate the margin between each EDG's capacity and its respective maximum calculated electrical load.
RBG-47461 Attachment I Page 6 of 16 3
TECHNICAL EVALUATION 3.1 Introduction The onsite standby power sources are designed in accordance with 10 CFR 50, Appendix A, General Design Criteria (GDC) 17 and 18. Periodic tests are supplemented by extensive functional tests during refueling outages. The SRs for demonstrating operability of the EDGs are in accordance with the recommendations of Revision 2 of Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used As Class 1 E Onsite Electric Power Systems at Nuclear Power Plants," with exceptions as described in USAR Table 1.8-1, Section 8.3.1.2.2.1 and Section 8.3.1.2.2.2.
The design function of the EDGs is to provide AC power to safety related equipment required for a safe shutdown within 10 seconds (DG 1A and DG 1B) and 13 seconds (DG 1 C) during a Loss of Offsite Power (LOP) event. During a LOP event, each EDG starts and its output breaker closes on the de-energized buss to supply power.
The time for the EDG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The proposed steady state SR ACTBs are more restrictive (tighter) than the existing SR ACTBs, and will ensure margin between the test load and the maximum calculated loads.
The SR ACTBs continue to include allowances for the capabilities of the EDG governors, voltage regulators, and instrumentation accuracy.
3.2 Frequency Tolerance Changes The EDG electrical load analyses conservatively bound the total EDG loads due to operation above 60 Hz. As discussed below, the proposed upper bound of the SR ACTB (60.2 Hz) continues to incorporate sufficient margin to account for associated uncertainties. Although the upper bound (60.2 Hz) is the same for all three EDGs, DG 1C differs from DG 1A and DG 1 B, which results in small differences in the associated uncertainties that are incorporated into the SR ACTB and analytical limit.
3.2.1 DG IA and DG lB Technical Evaluation The DG 1A and DG 1B electrical load analyses conservatively bound the total electrical load due to operation above 60 Hz, and use 60.2 Hz as the indicated value and 60.5 Hz as the analytical limit. The upper SR ACTB frequency limit is obtained by subtracting 0.3 Hz from the analytical limit (60.5 Hz) for frequency meter uncertainty, which yields an indicated (read) value of 60.2 Hz. For DG 1A and DG 1 B, it is necessary to reduce the existing EDG nominal frequency setpoint (60 Hz) to support an SR ACTB of 60.2 Hz. The EDG nominal frequency setpoint is obtained by subtracting 0.3 Hz (for the combined setting tolerance and governor control accuracy) from 60 Hz to yield a value of 59.7 Hz.
The existing minimum allowable steady state frequency, 58.8 Hz, is retained unchanged.
The resulting setpoint and tolerance are 59.7 Hz +0.5 Hz / -0.9 Hz. As discussed below, the tolerance is within the capabilities of the EDG governor and frequency meter.
RBG-47461 Page 7 of 16 The EDGs use a Woodward Speed Control (Governor), Model 2301A, which has a steady state governor accuracy of +/- 0.25 % (+/- 0.15 Hz). Allowances for the inaccuracies associated with the setpoint change (e.g., test equipment, meter readability) have been incorporated into the total uncertainty. The resulting total uncertainty used to determine the nominal frequency setpoint of +/- 0.3 Hz.
Combining the revised setpoint, 59.7 Hz, with the total uncertainty (+/- 0.3 Hz) yields a bounding range of 59.4 Hz to 60.0Hz, which is within the SR ACTB of 58.8 Hz to 60.2 Hz and within the limits in the EDG load calculation which are 58.8 Hz to 60.5 Hz. The SR maximum frequency of 60.2 Hz also falls directly on a minor scale division on the frequency meter, which reduces meter reading error and permits straightforward identification of the limit.
The new frequency nominal setpoint and upper limit have been evaluated, and no adverse effects have been identified with respect to the performance of the EDGs, EDG loads, mission time, or affected equipment. The engineering evaluation demonstrated that a decrease in EDG nominal frequency of 0.3 Hz (from 60 Hz to 59.7 Hz) would not prevent the safety related equipment from performing their design functions. Additionally, safety related motor operated valves would not exceed their maximum allowed stroke times if the EDG nominal frequency was reduced by 0.3 Hz, because the allowed stroke times are based on the minimum SR ACTB, which remains unchanged at 58.8 Hz.
Since the standby diesel generator nominal frequency is being reduced (from 60 Hz to 59.7 Hz), the "ready to load" speed setpoint above which the DG output breaker will close has been verified to be below the new nominal frequency of the generator set. The nominal and upper limits of the speed portion of the "ready to load" setpoint are 468 cycles per second (CPS) and 477.4 CPS, respectively. These correlate to engine speeds of 430 RPM and 438.6 RPM. Thus, the nominal speed of the EDG must be above 438.6 RPM. For conservatism, the lower bound of the Technical Specification allowable frequency for the generator set can be considered, 58.8 Hz, which corresponds to an engine speed of 441 RPM. Therefore, the EDG sets will be able to start and load at the new nominal frequency setpoint of 59.7 Hz.
3.2.2 DG 1C Technical Evaluation The DG 1C electrical load analyses conservatively bound the total electrical load due to operation above 60 Hz, and use 60.2 Hz as the indicated value and 60.49 Hz as the analytical limit. The upper SR ACTB limit is obtained by subtracting 0.29 Hz from the analytical limit (60.49 Hz) for frequency meter uncertainty to yield an indicated (read) value of 60.2 Hz. As discussed below, based on DG 1C, operating experience the existing frequency control setting (nominally 60 Hz) does not require a change to support an SR ACTB of 60.2 Hz. Therefore, an allowance for setting inaccuracies is not required.
The existing minimum allowable steady state EDG frequency, 58.8 Hz, is retained unchanged. The resulting tolerance setpoint and tolerance are 60.0 Hz and +0.2 Hz / -1.2 Hz. As discussed below, this tolerance is within the capabilities of the EDG governor and frequency meter.
RBG-47461 Page 8 of 16 For DG 1C the frequency change entails administratively reducing the steady state frequency limit from 61.2 Hz to 60.2 Hz. It does not require a setpoint change. As discussed below, the SR ATCB is sufficient to accommodate the associated uncertainties (governor accuracy).
The DG 1C uses a Woodward Speed Control (Governor), Model UG-8, which has a steady state governor accuracy of +/- 0.25 % (+/- 0.15 Hz).
The existing frequency setpoint is 60 Hz. Historical Plant Data System (PDS) frequency data for DG 1C surveillance tests from August through December of 2012 indicate that DG 1C starts and settles in at a steady state frequency of approximately 59.9 Hz. It is concluded that DG 1C consistently operates very closely to the nominal setpoint, 60 Hz, and that, therefore, the existing frequency setting need not be changed. (That is, the existing physical status of the frequency controller will not be altered.)
Combining the setpoint, 60.0 Hz, with the governor tolerance band (+/- 0.15 Hz) yields a bounding range of 59.85 Hz to 60.15 Hz, which is within the SR ACTB of 58.8 Hz to 60.2 Hz and within the limits in the EDG load calculation which are 58.8 Hz to 60.49 Hz. The SR maximum frequency of 60.2 Hz also falls directly on a minor scale division on the frequency meter, which reduces meter reading error and permits straightforward identification of the limit.
3.2.3 Frequency Change Conclusion Because the maximum frequency of 60.2 Hz is more restrictive than the current SR limit of 61.2 Hz; the EDG governor system can maintain the frequency within the narrower range.
It has been confirmed that there are no adverse effects; the proposed change to the EDG maximum steady state frequency in the SRs is considered acceptable.
3.3 Voltage Tolerance Changes The EDG electrical load analyses conservatively bound the total electrical load due to operation above 4160 V. As discussed below, DG 1A and DG 1B use 4368 V as the indicated value and 4473 V as the analytical limit to include associated uncertainties for potential over-voltage operation when determining electrical loads, and the existing DG 1C upper bound will be retained unchanged.
3.3.1 DG IA and DG 1B Technical Evaluation The DG 1A and DG 1B electrical load analyses conservatively bound the total electrical load due to operation above 4160 V, and use 4368 V as the indicated value and 4473 V as the analytical limit to include associated uncertainties for potential over-voltage operation when determining electrical loads. The proposed over-voltage limit is obtained by administratively reducing the indicated SR ACTB upper limit from +10% (+416 V rounded to + 420 V) to +5% (208V). A setpoint change is not required. The existing minimum allowable steady state voltage, 3740 V, and nominal voltage, 4160 V, are
RBG-47461 Page 9 of 16 retained unchanged. The resulting tolerance is +208 /-420 V (+5% / -10%). As discussed below, this is within the capabilities of the EDG voltage regulator and meter.
The voltage regulators are capable of maintaining the voltage within +/- 0.5% (+/- 21 V).
The total loop uncertainty, including an allowance for meter reading is +/- 105 V.
Combining the nominal voltage, 4160 V, with the regulator control (+/- 21 V) and total loop uncertainty (+/- 105 V), yields a range of 4034 V to 4286.V, which is within the SR ACTB of 3740 V to 4368 V.
3.3.2 DG 1C Technical Evaluation The DG 1 C voltage SR ACTB is retained unchanged. Therefore, a technical evaluation is not required.
3.3.3 Voltage Change Conclusion Because the maximum DG 1A and DG 1 B voltage, 4368 V is more restrictive than the current SR limit, 4580 V. The EDG voltage regulator can maintain the voltage within the narrower range; and it has been confirmed that there are no adverse effects from the reduced over-voltage, the proposed change to the EDG maximum steady state voltage in the DG 1A and DG 1B SRs is considered acceptable. The DG 1C voltage SR ACTB is retained unchanged. Therefore, there are no effects.
3.4 Test Load Tolerance Changes The EDG load analyses conservatively bound the total EDG load due to operation with the proposed over-frequency and over-voltage limits. The change consists of administratively increasing the minimum test load to be attained while the EDG is connected to the grid.
This does not entail a setpoint change.
3.4.1 DG IA, DG lB Technical Evaluation The calculated loop uncertainty is +/- 97kW. This is added to the maximum calculated load (2933.1 kWfor DG 1A and 2749.5 kWfor DG 1B) to derive a value for the corresponding indicated load (3030.1 kW for DG 1A) and 2846.5 kW for DG 1 B). The minimum indicated test load, 3050 kW is greater than the corresponding indicated loads.
(See Table 3.4-1.) The existing maximum allowable SR ACTB test load, 3100 kW, is retained unchanged.
One result of increasing the minimum SR test load is to narrow the margin to the operating limit, 3130 kW indicated, from 130 kW (currently 3000 kW to 3130 kW) to 80 kW (proposed 3050 kW to 3130 kW). However, the 80 kW allowance is sufficient to ensure that controls currently in place can maintain the SR test load runs below the operating limit of 3130 kW indicated.
RBG-47461 Page 10 of 16 3.4.2 DG 1C Technical Evaluation The calculated loop uncertainty is +/- 93 kW. This is added to the maximum calculated load (2430.9 kW) to derive a value for the corresponding indicated load (2523.9 kW). The minimum indicated test load, 2525 kW, is greater than the corresponding indicated load.
(See Table 3.4-1.) The existing maximum allowable SR ACTB test load, 2600 kW, is retained unchanged.
One result of increasing the minimum SR test load is to narrow the margin to the 2000 hr rating, 2850 kW indicated, from 350 kW (currently 2500 kW to 2600 kW) to 325 kW (proposed 2525 kW to 2850 kW). However, the 325 kW allowance is more than sufficient to ensure that controls currently in place can maintain the SR test load runs below the 2000 hr limit of 2850 kW indicated.
3.4.3 Test Load Change Conclusion The loads calculated based on the proposed technical specifications and resulting margins for each EDG are provided in Table 3.4-1 below.
Table 3.4-1: EDG SR Test Load Marain DG / Division Minimum Loop Minimum SR Maximum Margin to SR Uncertainty Indicated Test Calculated Minimum Indicated (LU) load minus LU Load SR Test Load Indicated Test Load 1A/ Division I 3,050 kW 97 kW 2953 kW 2,933.1 kW 19.9 kW 1B / Division II 3,050 kW 97 kW 2953 kW 2,749.5 kW 203.5 kW 1C/ Division III 2,525 kW 93 kW 2432 kW 2,430.9 kW 1.1 kW The increases in the minimum EDG SR test loads do not affect the EDG capability to accept the loads in the accident analysis because, as indicated in Table 3.4-1, there is sufficient margin to accommodate the maximum calculated test load and loop uncertainty.
Since the proposed test loads are more restrictive, and do not impose additional stress on the EDGs, they are considered acceptable.
3,5 Combined Changes 3,5.1 Accidents The EDGs are not initiators for accidents evaluated in the USAR. The proposed changes do not alter the capability of the EDGs or their supporting systems to start, load and perform their intended functions as described in the USAR. The proposed changes do not impact the initiators of analyzed events, nor do they impact the mitigation of accidents.
RBG-47461 Page 11 of 16 The purposes of the EDG surveillance tests are to confirm the capability of each EDG to start and achieve the minimum conditions required to accept the loads determined in the accident analysis. No changes are being made in operating philosophy, testing frequency, how EDGs operate or how EDGs are physically tested. The proposed changes do not affect the EDG's ability to supply minimum voltage and frequency within 10 seconds (DG 1A and DG 1B) and 13 seconds (DG 1C), or the minimum steady state voltage and frequency. The EDGs will continue to perform their intended safety function in accordance with the safety analysis. Therefore, the proposed changes do not affect safety analysis assumptions.
In addition to the SR requirements, the time for the EDG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
3.5.2 Margin The proposed changes enable SR testing to demonstrate sufficient margin to ensure that the EDGs and equipment being powered by the EDGs will function as required to mitigate an accident as described in the USAR and Table 3.4-1 above.
The proposed changes increase the minimum EDG test loads, but the upper limits of the test loads are not changed. Furthermore, the test program (number and type of SR starts, test loads and run length) is not changed. Therefore, the effect of the proposed changes on EDG wear and/or reliability is negligible, and the proposed changes will not reduce EDG reliability from the current value of 95%.
In addition to the discussion above, RBS has submitted a request dated November 4, 2013, (RBG-47404) to remove various ventilation filter heater loads. The request is based upon the determination that the heaters are not required to ensure the respective filters can perform their required functions post-accident. Once approved the heater loads can be removed from the respective EDGs. This additional margin will be used to address future operational and design issues. This future margin does not impact the basis for this request.
3.5.3 Failure Modes and Effects The proposed changes do not degrade the EDGs, the circuits connected to the EDGs or the equipment powered by the EDGs. Therefore, no new failure modes or effects are introduced that could create the possibility of a new or different kind of accident from any previously evaluated.
4 REGULATORY EVALUATION 10 CFR 50.36 (c) (2) (ii) requires that a technical specification limiting condition for operation must be established for each item meeting one or more of the following criteria.
- 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
RBG-47461 Page 12 of 16
- 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to the integrity of a fission product barrier.
- 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
- 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
10 CFR 50 Appendix A, Criterion 17-Electric power systems requires that 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 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.
10 CFR 50 Appendix A, Criterion 18 - Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.
The proposed changes are more restrictive than the current TS SRs, which ensures continued compliance with 10 CFR 50.36 (c) (2) (ii). The maximum calculated loads are less than the SR test load lower limits, which demonstrates that 10 CFR 50 Appendix A, Criterion 17 continues to be met.
The proposed changes do not remove any TS SR requirements for test criteria or test schedules. Thus 10 CFR 50 Appendix A, Criteria 17 and 18 continue to be met.
TS SRs for demonstrating the operability of the EDGs are based on the recommendations in Regulatory Guide 1.9 with exceptions as described in USAR Table 1.8-1. The current USAR description states that recovery of voltage and frequency to within 10 percent and 2 percent of nominal, respectively, has been verified to be accomplished within 40 percent of the sequencing interval of 5 sec. The proposed voltage change for DG 1A and DG 1 B would be more restrictive, specifically requiring that DG 1A and DG 1 B voltage be restored to within +5% and -10% within 40 percent of the sequencing interval of 5 sec.
The DG 1 C voltage SR ACTB is unchanged. The proposed frequency change would be more restrictive, specifically requiring that the frequency be restored to within + 0.8% / -
1.5%, within 40 percent of the sequencing interval of 5 sec. Thus, the proposed changes do not adversely affect continued compliance with Regulatory Guide 1.9.
RBG-47461 Page 13 of 16 An engineering evaluation has confirmed that there are no adverse effects as a result of reducing the frequency upper SR ACTB (61.2 Hz to 60.2 Hz), reducing the DG 1A and DG 1 B voltage upper SR ACTB (4580 V to 4368 V) and increasing the minimum test loads (DG 1A and DG 1 B, 3000 kW to 3050 kW; and DG 1 C 2500 kW to 2525 kW).
The maximum SR EDG test loads are not changed. With associated uncertainties included, the test loads remain below the existing test load upper limits. This ensures that the EDG operability will not be challenged.
The proposed changes do not alter the expected EDG response and have no effect on the EDG operation or availability. Therefore, the proposed changes do not have an unacceptable impact on safety.
Therefore, operation with the proposed changes will continue to meet regulatory requirements and provide assurance that the EDGs and the equipment powered by the EDGs will be available to actuate to mitigate a design basis accident or transient.
NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The EDGs are not initiators for accidents evaluated in the USAR. The proposed changes do not alter the capability of the EDGs or their supporting systems to start, load and perform their intended functions as described in the USAR. The proposed changes do not impact the initiators of analyzed events, nor do they impact the mitigation of accidents.
The proposed changes enable SR testing to demonstrate sufficient margin to ensure that the EDGs and equipment being powered by the EDGs will function as required to mitigate an accident as described in the USAR. Thus, the EDGs will be capable of performing their accident mitigation function as described in the USAR, and there is no impact on the consequences of accident analyses.
The proposed changes increase the minimum EDG test loads, but the upper limits of the test loads are not changed. Furthermore, the test program (number and type of SR starts, test loads and run length) is not changed. Therefore, the effect of the proposed changes on EDG wear and/or reliability is negligible, and the proposed changes will not reduce EDG reliability from the current value of 95%.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
RBG-47461 Page 14 of 16
- 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 changes do not involve any physical alteration of the plant (e.g., no new or different type of equipment will be installed), or a change in the methods governing EDG operation. The changes ensure margin between the EDG SR test loads and the EDG maximum calculated loads and that the EDGs operate as assumed in the accident analyses.
The purposes of the EDG surveillance tests are to confirm the capability of each EDG to start and achieve the minimum conditions required to accept the loads in the accident analysis. No changes are being made in operating philosophy, testing frequency, how EDGs operate or how EDGs are physically tested. The proposed changes do not affect the EDGs' ability to supply minimum voltage and frequency within 10 seconds (DG 1A and DG 1B), 13 seconds (DG 1C) or the minimum steady state voltage and frequency. The EDGs will continue to perform their intended safety function in accordance with the safety analysis. Therefore, the proposed changes do not affect safety analysis assumptions.
The proposed changes do not degrade the EDGs, the circuits connected to the EDGs or the equipment powered by the EDGs. Therefore, no new failure modes or effects are introduced that could create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes do not affect the initiators of analyzed events, nor do they affect the mitigation of accidents.
Therefore, the proposed changes do 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 changes enable SR testing to demonstrate sufficient margin between demonstrated EDG capability in the surveillance tests and maximum calculated EDG loads to ensure that the EDGs and equipment being powered by the EDGs will function as required to mitigate an accident as described in the USAR. Thus the proposed changes do not involve a significant reduction in the EDG electrical load margin.
The proposed changes increase the minimum EDG test loads, but the upper limits of the test loads are not changed. Furthermore, the test program (number and type of SR starts, test loads and run length) is not changed. Therefore, the effect of the proposed changes on EDG wear and/or reliability is negligible and the proposed changes do not involve a significant reduction in the EDG physical margin.
RBG-47461 Page 15 of 16 The margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The proposed changes do not directly affect these barriers, nor do they involve any adverse impact on the EDGs that serve to support these barriers in the event of an accident concurrent with a loss of offsite power. The proposed changes do not affect the EDG's capabilities to provide emergency power to plant equipment that mitigates the consequences of the accident.
In summary: the proposed changes have no affect the ability of the EDGs to start and load; no change is made to the accident analysis assumptions; no margin of safety is reduced as part of this change; and the margin between the calculated emergency loads and minimum test load is ensured. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Conclusion Based on the above discussion, Entergy concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
Also, based on the considerations discussed above, Entergy concludes that; (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 ENVIRONMENTAL CONSIDERATION 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 paragraph (c)(9) of 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review."
Therefore, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.
RBG-47461 Page 16 of 16 6
PRECEDENTS The NRC has approved requests for similar changes to Surveillance Requirements for EDG steady state frequency and voltage, and for test power.
6.1 Crystal River Unit 3 Nuclear Generating Plant - Issuance Of Amendment Regarding Request To Revise The Technical Specification Surveillance Requirements For Emergency Diesel Generator Voltage And Frequency Limits (TAC No. ME01 07),
December 10, 2009, ML092680285 6.2 Donald C. Cook Nuclear Plant, Units 1 And 2 - Issuance Of Amendment To Renewed Facility Operating License Regarding Technical Specification Change Relating To Diesel Generator Steady-State Parameters (TAC Nos. MD8773 and MD8774), April 30, 2009, ML090630245 6.3 Prairie Island Nuclear Generating Plant, Units 1 And 2 - Issuance Of Amendments Re: Technical Specification Changes To Revise Emergency Diesel Generator Test Loads In Surveillance Requirement (SR) 3.8.1.9 (TAC Nos. ME0086 and ME0087),
June 21, 2010, ML101481082 RBG-47461 Proposed Technical Specification Changes (mark-up)
Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
RBG-47461 Page 1 of 10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power 7 days availability for each required offsite circuit.
-NOTES
- 1.
Performance of SR 3.8.1.7 satisfies this SR.
- 2.
All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
- 3.
A modified DG start involving gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.
Verify each DG starts from standby conditions and 31 days achieves:
- a.
For a
e voltage
>_3 OVand _468V and freque yŽ>58.8 Hz an <
Hz.
- b.
Fo fg!
- 1.
Maximum of 5400 V, and 66.75 Hz, and
- 2.
Steady state voltage -a 3740 V and
(
1 euncýa--
uncy a 58.8 Hz and (continued)
RIVER BEND 3-8-5 Amendment No.
-4, Q(ý-121
RBG-47461 Page 2 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.3
- 1.
DG loadings may include gradual loading as recommended by the manufacturer.
- 2.
Momentary transients outside the load range do not invalidate this test.
- 3.
This Surveillance shall be conducted on only one DG at a time.
- 4.
This SR shall be preceded by, and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7 V
eachDG tes for -> 60 minutes at a load
>OOkWand*
OOkWforDGlAandDGlB,and
Ž 2k~kWand*
OOkWforDG 1C.
31 days SR 3.8.1.4 Verify each day tank contains _> 316.3 gal of fuel oil.
31 days SR 3.8.1.5 Check for and remove accumulated water from each 31 days day tank.
SR 3.8.1.6 Verify the fuel oil transfer system operates to 31 days automatically transfer fuel oil from the storage tank to the day tank.
(continued)
RIVER SEND 3.8-.6 Amendment No. 84, O 121
RBG-47461 Page 3 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.7 NOTE-------
All DG starts may be preceded by an engine prelube period.
Ver;fy each DG starts from standby' conditions and 184 days achieves:
- a.
- 1.
In _< 10 seconds, voltage >_ 3740 V and frequency _> 58.8 Hz; and
- 2.
Sea y t e olag 3740 V and 4
and frequen y > 58.8 Hz and 64388
- b.
Fo 610
- 1.
Maximum of 5400 V, and 66.75 Hz, and
- 2.
In < 13 seconds, voltage _? 3740 V and frequency >_ 58.8 Hz; and
- 3.
1 U,, ývtae_
3740 V and aýWout~
e~ncy -.- 58.8 Hz and SR 3.8.1.8 This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.
Verify manual transfer of unit power supply from the 24 months normal offsite circuit to required alternate offsite circuit.
(continued)
RIVER BEND 3.8-7 Amendment No.
4 12*4.6.5, 168
RBG-47461 Page 4 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.9 N
- 1.
Credit may be taken for unplanned events that satisfy this SR.
- 2.
If performed with DG synchronized with offsite power, it shall be performed at a power factor
_ 0.9 Verify each DG rejects a load greater than or equal to 24 months its associated single largest post accident load and following load rejection, the engine speed is maintained less than nominal plus 75% of the difference between nominal speed and the overspeed trip setpoint or 15% above nominal, whichever is lower.
SR 3.8.1.10 NOTE Credit may be taken for unplanned events that satisfy this SR.
Verify each DG operating at a power factor _< 0.9 does 24 months not trip and voltage is maintained and DG 1B and _< 5400 V for DG du d
3050 following a load rejection of a oa Se6 kW and
- 31300 kW for DGsllcA and lB an
Ž kW and o2600 kW for DG 1 C.n (continued)
RIVER BEND 3.8-8 Amendment No. 81 424 122 41-3X7, 168
RBG-47461 Page 5 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.11 N-----
-OTES------
- 1.
All DG starts may be preceded by an engine prelube period.
- 2.
This Surveillance shall not be perform3d in MODE 1, 2, or 3. (Not applicable to DG 1C)
However, credit may be taken for unplanned events that satisfy this SR.
Verify on an actual or simulated loss of offsite power 24 months signal:
- a.
De-energization of emergency buses;
- b.
Load shedding from emergency buses for Divisions I and II; and
- c.
DG auto-starts from standby condition and:
- 1.
energizes permanently connected loads in
< 10 seconds for DG 1A and DG 1B and
- 13 seconds for DG 1C.
- 2.
energizes auto-connected shutdown loads,
- 4.
a_
s t s t encyŽ 58.8 Hz
- 5.
Ii s nected d
->5 minutes.
(continued)
- a.
_> 3740 V and < 4368 V for DG 1A and DG 1B,
- b.
>3740Vand<4580VforDG 1C, RIVER SEND 3.8-9 Amendment No. R! 12! !23, 168
RBG-47461 Page 6 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.12
-NOTES-----
- 1.
All DG starts may be preceded by an engine prelube period.
- 2.
This Surveillance shall not be performed in MODE 1 or 2. (Not applicable to DG 1C)
However, credit may be taken for unplanned events that satisfy this SR.
Verify on an actual or simulated Emergency Core 24 months Cooling System (ECCS) initiation signal each DG auto-starts from standby condition and:
- a.
For DG 1C during the auto-start maintains voltage _ 5400 V and frequency *66.75 Hz;
- b.
In < 10 seconds for DG 1A and DG 1B and
- ý 13 seconds for DG 1 C after auto-start and during tests, achieves voltage >_ 3740 V and frequency _> 58.8 Hz.
C.
Achieves steady state voltage-8.H a 60.2 t. Hz;and
- d.
Operates for Ž!5 minutes.
(continued)
- a.
>3740Vand<s4368VforDG lAandCDr-lB
- b.
>_374OVand<458OVforDGIC RIVER BEND 3-8-10 Amendment No. 4 424. 133 165, 168
RBG-47461 Page 7 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.13 NQTE This Surveillance shall not be performed in MODE 1, 2, or 3. (Not applicable to DG 1 C)
However, credit may be taken for unplanned events that satisfy this SR.
Verify each DG's automatic trips are bypassed on 24 months an actual or simulated ECCS initiation signal except:
- a.
Engine overspeed; and
- b.
Generator differential current.
SR 3.8.1.14 NOTES
- 1.
Momentary transients outside tMe load and power factor ranges do not invalidate this test.
- 2.
Credit may be taken for unplanned events that satisfy this SR.
Verify each DG operating at a power c r < 0 months operates for Ž24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
- a.
For DG 1A and DG 1B Ioadec_ ý-3 kW and < 3130 kW; and
- b.
For DG 1C:
- 1.
For Ž 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded >_ 2750 kW and
- 2850 kW, and
- 2.
For t urs of the test load kW 2600 kW.
2-530 (continued)
RIVER BEND 3.8-11 Amendment No. 91 94 121 33, 168
RBG-47461 Page 8 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.15 NOTES
- 1.
This Surveillance shall be performed within 5 minutes of shutting down tr aG r
DG has operated _> 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ioade -
kW d
{YTI1[tr DG 1A and Dt=
5OkW VVd < 2600 for DG 1 C, or operating 2530 have stabilized, which ever is longer.
Momentary transients outside of the load range do not invalidate this test.
- 2.
All DG starts may be preceded by an engine prelube period.
Verify each DG starts and achieves:
24 months
- 1.
In _< 10 seconds for DG 1A and DG 1B and
__ 13 seconds for DG 1C voltage Ž3740 V and frequency > 58.8Hz a d
- b. > 3740 V and < 4580 V for DG 1 C med in MODE 1. 2, or 3. (Not applicable to DG 1CmHwever, credit may be taken for unplanned events that satisfy this SR.
Verify each DG:
24 months
- a.
Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;
- b.
Transfers loads to offsite power source; and
- c.
Returns to ready-to-load operation.
(continued)
R*IVER BEND 3.8-12 Amendment No. 4-4Q4l4331+,
16I
RBG-47461 Page 9 of 10 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.19 NOTES-
- 1.
All DG starts may be preceded by an engine prelube period.
- 2.
This Surveillance shall not be performed in MODE 1, 2, or 3. (Not applicable to DG IC)
However, credit may be taken for unplanned events that satisfy this SR.
Verif~y, on an actual or simulated loss of offsite power 24 months signal in conjunction with an actual or simulated ECCS initiation signal:
- a.
De-energization of emergency buses;
- b.
Load shedding from emergency buses for Divisions I and II; and
- c.
DG auto-starts from standby condition and:
- 1.
energizes permanently connected loads in
< 10 seconds for DG 1A and DG 1B and
-9 13 seconds for DG 1C,
- 2.
energizes auto-connected emergency
- loads,
- 4.
acrMe e s state frequency Ž 5.8 Hz
- 5.
supplies permanently connected and auoconcedemergency load for
\\
(continued)
- a.
>3740Vand<4368VforDG 1AandDG1,
- b.
_>3740Vand<5458OVforDGiC RIVER BEND 3.8-14 Amendment No.
1 4 2 433, 168
RBG-47461 Page 10 of 10 SURVEILLANCE SR 3.8.1.20
.NOTE All DG starts may be preceded by an engine prelube period.
Verify, when started simultaneously from standby condition, each DG achieves:
10 years
- 1.
In!
10 seconds for DG 1Aand DG 1B and
!5 13 seconds for DG IC voltage > 3740 V and frequency > 58.8 Hz, and
- 2.
Steady state voltU frequency Ž 58.8 RIVER BEND 3.8-15 Amendment No.84-124, 165 RBG-47461 Proposed Technical Specification BASES Changes (mark-up)
For Information Only Note, markup deletions identified by strikethrough (delete) and additions identified by underline (addition).
RBG-47461 Page 1 of 2 SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued)
REQUIREMENTS SR 3.8.1.7 requires that, at a 184-day Frequency, the DG starts from standby conditions and achieves the required voltage and frequency within 10 seconds for DG 1A and DG 1B and 13 seconds for DG 1C. The start requirements for each DG support the assumptions in the design basis LOCA analysis (Ref. 5). The start requirements may not be applicable to 3.8.1.2 (see Note 3 of SR 3.8.1.2), when a modified start as described above is used. If a modified start is not used, the start requirements of SR 3.8.1.7 apply. Since SR 3.8.1.7 does require a 10 second start for DG 1A and DG 1B and 13 seconds for DG 1C, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2. Similarly, the performance of SR 3.8.1.12 or SR 3.8.1.19 also satisfies the requirements of SR 3.8.1.2 and SR 3.8.1.7.
In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The normal 31 day Frequency for SR 3.8.1.2 is consistent with the industry guidelines for assessment of diesel generator performance (Refs. 14 and 15). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
SR 3.8.1.3 This Surveillance demonstrates that the DGs are capable of synchronizing and accepting the surveillance test. lead ef 3,000 3,100 kW. There Torhnical Specification load v.'aluoc.
ree.
t olat.d in vicw.' of hu-,.m.a oinring GOnzideratians that the amfailoct graduation on tho watt meter:
e61 00 W.
-The minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is an operational limitation to ensure circulating (continued)
RIVER BEND B 3.8-15 Revision No. 139
RBG-47461 Page 2 of 2 BASES SURVEILLANCE SR 3.8.1.14 (continued)
REQUIREMENTS equivalent to the continuous rating of the DG, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to 110% of the continuous duty rating of the DG for Division Ill. An exception to the loading requirements is made for DG 1A and DG lB. DG 1A and DG 1B are operated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a load greater than or equal to the maximum expected post accident load. Load carrying capability testing of the Transamerica Delaval Inc. (TDI) diesel generators (DG 1A and DG 1B) has been limited to a load less than that which corresponds to 201 psig brake mean effective pressure (BMEP).
Therefore, full load testing is performed at a load ;> 23030 3050 kW but <
3130 kW. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor -- 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.
The 24 month Frequency takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This Surveillance is modified by two Notes. Note 1 states that momentary transients do not invalidate this test. The lower limit of the load band ensures the generator is sufficiently loaded during the test and the upper limit of the load band is to avoid an overload of the diesel generator during the routine test. The upper and lower limits provide a reasonable band to operate the DG in for the specified run time while achieving the intent of a full-load. The Note recognizes that there are external grid conditions that can cause a shift in load sharing with the DG and allows the operator time to recognize and adjust load back into the band without invalidating the performance of the surveillance. It also allows for momentary transients where the DG governor system acts to bring the load back into the load band. Momentary DG load "spikes" which are beyond the ability of the operator to monitor and control with normal control room instrumentation, and which the governor acted to maintain proper DG load band do not invalidate the test and the DG can be considered to have met the intent of operating "at full rated load" for the specified duration. Similarly, momentary power factor transients above the limit do not invalidate the test. The reason for Note 2 is that credit may be taken for unplanned events (continued)
RIVER BEND B 3.8-25 Revision No. 151 RBG-461 List of Regulatory Commitments to RBG-47461 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check one)
SCHEDULED ONE-CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE ACTION In addition to the above changes to the RBS X
Upon Technical Specifications the BASES will be Implementation revised to be consistent with these changes.