Text

Proposed Tech Specs Re Extended Allowed Outage Time for EDGs
	ML17228B179
Person / Time
Site:	Saint Lucie
Issue date:	06/21/1995
From:	; FLORIDA POWER & LIGHT CO.
To:	;
Shared Package
ML17228B178	List: L-95-148, Application for Amends to Licenses DPR-67 & NPF-16.Amends Would Extend Allowed Outage Time for Inoperable EDGs; ML17228B179; ML17228B180;
References
	NUDOCS 9506230230
	Download: ML17228B179 (18)
	v • d • e

3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and b.

Two separate and independent diesel generator sets each with:

1.

Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel, 2.

A separate fuel storage system containing a minimum of 16,450 gallons of fuel, and 3.

A separate fuel transfer pump.

MODES 1, 2, 3 and 4.

hQlQH'.

With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f.

below, demonstrate the OPERABILITYof the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

7 days b.

With one diesel generator of 3.8.1.1.b inoperable, demonstrate the OPERABILITYof the A.C. sources by performing Surveillance Requirement 4.8,1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITYof the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2,a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on t e emaining EDG*; restore the diesel generator to OPERABLE status withi ou r be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Additionally, verify within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months that:

If the absence of any common-cause failure cannot be confirmed, this test shall be

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The OPERABILITYof the A.C. and D.C. power sources and associated distribution systems during operation ensures that sufficient power willbe available to supply the safety related equipment required for 1) the safe shutdown of the facilityand 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C.

and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A"to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facilityoperation commensurate with the level of degradation.

The OPERABILITYof the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one of each of the onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C.

source.

When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE. This requirement is intended to provide assurance that a loss of offsite power event willnot result in a complete loss of safety function of critical systems during the period one of the diesel generators is inoperable.

The term verify as used in this context means to administratively check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons.

It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITYof the component.

All EDG inoperabilities must be investigated for common-cause failures regardless of how long the EDG inoperability persists'.

When one diesel generator is inoperable, required ACTIONS 3.8.1.1.b and 3.8.1

~ 1.c provide an allowance to avoid unnecessary testing of EDGs. 'If it can be determined that the cause of the inoperable EDG does not exist on the remaining OPERABLE EDG, then SR 4.8.1.1.2.a.4 does not have to be performed.

Eight (8) hours is reasonable to confirm that the OPERABLE EDG is not affected by the same problem as the inoperable EDG.

If it cannot otherwise be determined that the cause of the initial inoperable EDG does not exist on the remaining EDG, then satisfactory performance of SR 4.8,1.1.2.a.4 suffices to provide assurance of continued OPERABILITYof that EDG. Ifthe cause of the initial inoperability exists on the remaining OPERABLE EDG, that EDG would also be declared inoperable upon discovery, and ACTION 3.8.1.1.e would be entered.

Once the failure is repaired (on either EDG), the common-cause failure no longer exists.

Ambient conditions are the normal standby conditions for the diesel engines.

Any normally running warmup systems should be in service and operating, and manufacturer's recommendations for engine oil and water temperatures and other parameters should be followed.

The OPERABILITYof the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facilitycan be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the facilitystatus.

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St. Lucie Unit 1 and Unit 2 Docket Nos.

50-335 and 50-389 Proposed License Amendments Emer enc Diesel Generator AOT Extension ATTACHMENT 4 ST ~ LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES Page 3/4 8-1 Page B 3/4 8-1 j:;,'.;.!SUBMITTED,~,,'::BY',,IFPL%,,:LETTER";.;

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3.8.1.1 As a roinirnum, the following A.C. electrical power sources shall be OPERABLE:

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and b.

Two separate and independent diesel generators, each with:

1.

Two separate engine-mounted fuel tanks containing a minimum volume of 200 gallons of fuel each, 2.

A separate fuel storage system containing a minimum volume of 40,000 gallons of fuel, and 3.

A separate fuel transfer pump.

MODES1,2,3, and4.

AQIIQ5:

a.

With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f.

below, demonstrate the OPERABILITYof the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

7 day<

b.

With one diesel generator of 3.8.1

~1.b inoperable, demonstrate the OPERABILITYof the A.C. sources by performing Surveillance Requirement 4.8.1.1

~1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITYof the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on the e

aining EDG*; restore the diesel generator to OPERABLE status withi o r or be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Additionally, verify, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months that:

Ifthe absence of any common-cause failure cannot be confirmed, this test shall be completed re ardless of when the ino erable EDG is restored to OPERABILITY.

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I day 4@i& wry be. ex~Jed 4o o- <<>i~<n o$ lo days Qovn i~'h<'at. dsscouev'y of laiturc ko vneek +ha LCO.

ST. LUCIE-UNIT2 3/4 8-1 Amendment No. 95, 69,

The OPERABILITYof the A.C. and D.C. power sources and associated distribution systems during operation ensures that sufficient power willbe available to supply the safety related equipment required for1) the safe shutdown of the facilityand 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C.

and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A"to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facilityoperation commensurate with the level of degradation.

The OPERABILITYof the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C.

source.

The A.C. and D.C. source allowable out-of-service times are based on Regulatory Guide 1 93 "Availabilityof Electrical Power Sources," December 1974 When one diesel generator is inopera e, t ere s an additional ACTION requ rement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE. This requirement is intended to provide assurance that a loss of offsite power event willnot result in a complete loss of safety function of critical systems during the period one of the diesel generators is inoperable.

The term

, verify as used in this context means to administratively check by examining logs or other information to determine ifcertain components are out-of-service for maintenance or other reasons.

It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITYof the component, All EDG inoperabilities must be investigated for common-cause failures regardless of how long the EDG inoperability persists.

When one diesel generator is inoperable, required ACTIONS 3.8.1

~1.b and 3.8.1.1,c provide an allowance to avoid unnecessary testing of EDGs.

If it can be determined that the cause of the inoperable EDG does not exist on the remaining OPERABLE EDG, then SR 4.8.1.1.2,a,4 does not have to be performed, Eight (8) hours is reasonable to confirm that the OPERABLE EDG is not affected by the same problem as the inoperable EDG. If it cannot otherwise be determined that the cause of the initial inoperable EDG does not exist on the remaining EDG, then satisfactory performance of SR 4.8.1.1.2.a.4 suffices to provide-assurance of continued OPERABILITYof that EDG. Ifthe cause of the initial inoperability exists on the remaining OPERABLE EDG, that EDG would also be declared inoperable upon discovery, and ACTION 3.8.1.1.e would be entered.

Once the failure is repaired (on either EDG), the common-cause failure no longer exists.

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St. Lucie Unit 1 and Unit 2 Docket Nos.

50-335 and 50-389 Proposed License Amendments Emer enc Diesel Generator AOT Extension L-95-148 ENCLOSURE Joint Applications Report for EMERGENCY DIESEL GENERATORS AOT EXTENSION (CE NPSD-996, Final Report CEOG Task 836; May, 1995)

C Sources Operatina 3.8.1 ACTIONS CONDITION REQUIRED ACTION COHPLETION TIME A.

(continued)

A.3 Restore

[required]

offsite circuit to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND days from discovery of failure to meet LCO B. ---HOTE---

Regui red Action 8.3. 1 or B.3.2 shall be completed if this Condition is entered.

One [required]

DG inoperable.

B. 1 AND 8.2 AND B.3.1 OR Perform SR 3.8.1.1 for the OPERABLE

[required offsite ci rcuit(s).

Declare required feature(s) supported by the inoperable DG inoperable when its redundant required feature(s) is inoperable.

Determine OPERABLE DG(s) is not inoperable due to common cause failure.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B

concurrent with inoperability of redundant required feature(s)

[24] hours B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).

AND

[24] hours (continued)

CEOG STS 3.8-2 Rev.

0, 09/28/92

t AC Sources Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued) 8.4 Restore

{requi red3 DG to OPERABLE status.

AND days from discovery of:

failure to meet LCO C.

Two {required] offsite circui ts inoperable.

C.1 Declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from'iscoveryof Condition C

concurrent with inoperability of redundant required feature(s)

C.2 Restore one

{required3 offsite circuit to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

CEOG STS 3.8-3 Rev.

0, 09/28/92

INSERT A NOTE On a once-per-refueling cycle frequency, the Completion Time for REQUIRED ACTION B.4 can be extended to "10 days AND 10 days from discovery of failure to meet LCO."

AC Sources Qperating B 3.8.1 BASES ACTIONS A.3

{continued) during any single contiguous occurrence of failing to meet the LCO.

If Condition A is 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

. ~eve~

This could lead to a total of ~heaEs, since initial failure to meet the LCO, to restore the offsite circuit.

At this time, a

DG could again become inoperable, the circuit restored

OPERABLE, and an additional

{for a total days) allowed prior to complete res oration of the LCO.

The da Com letion Time provides a limit on the time allowed in a specific con i ion a er 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 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and day Completion Time means that both omp e ion Times apply simultaneously, and the more restrictive Completion Time must be met.

As in Required Action A.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This will result in establishing the "time zero" at the time that the LCO was

'initia'lly not met, instead of at the time Condition A was entered.

fQ s

JO B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis.

Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met.

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

Upon offsite circuit inoperabi lity, addi tional Conditions and Requi red Actions must then be entered.

B.2 Required Action B.Z is intended to provide assurance that a

loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety

{continued)

CEOG STS B 3.8-7 Rev.

0, 09/28/92

t AC Sources Operating B 3.8.1 BASES ACTIONS (continued)

B.3.1 and B.3.2 The Note in Condition B requires that Required Action B.3.1 or B.3.2 must be completed if Condition B is entered.

The intent is that all DG inoperabilities must be investigated for common cause failures regardless of how long the DG inoperability persists.

Required Action B.3. 1 provides an allowance to avoid unnecessary testing of OPERABLE DGs.

If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed.

If the cause of inoperabi lity exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered.

Once the failure is repaired, the common cause failure no longer exists and Required Action B.3. 1 is satisfied.

If the cause of the initial inoperable DG cannot be confirmed

.not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

According to Generic Letter 84-15 (Ref. 7),

[24] hours is reasonable to confirm that the OPERABLE DG(s) is not

~ffected by the same problem as the inoperable DG.

Q}JSc:El RB B.4 Refe.~c ig According to operation may continue in Condition B for a period that should not exceed

~m7~y5 n Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the 7

onsite Class 1E Distribution System.

The ompletion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second 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 (continued)

CEOG STS B 3.8-9 Rev.

0, 09/28/92

~

INSERT AA Additionally, Reference 14 states that operation may continue in Condition B for a maximum continuous period of 10 days on a once per refueling cycle frequency.

Reference 14 provides a series of deternunistic and probabilistic justifications for the Completion Times corresponding to the periods in which continued power operations are allowed with Condition B.

AC Sources-Operatina 8 3.S.1 BASES ACTIONS B.4 (continued) subsequently returned 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 could lead to a total f

since initial failure to meet the LCO, to r store the DG.

At this time, an offsite circuit could again become inoperable, the OG restored OPERABLE and additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total o

ays a

owed prior to ~

complete restoration of the LCO.

The Com 'letion Time provides a limit on time allowed in a specified condition JQ 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 t e~~~nd a

Com letion Times means that both o pleti on Times apply simu taneous y,

an restri cti ve Comp Ieti on Time must be met.

As in Required Action B.2, the Completion Time allows for an exception to the normal "time zero'or beginning the allowed time "clock."

This will result in establishing the "time zero" at the time that the LCO was initially not met, instead of at the time Condition B was entered.

C.l and C.2

~

Required Action C.I, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions.

The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Requi red Action A.2).

The rationale for the reduction to 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 trains 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 powered from redundant AC safety trains.

This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

(continued)

CEOG S.=

B 3.8-10 Rev.

0, 09/2S/92

AC Sources-.":-eratina B 3.8.1 BASES REFERENCES (continued) 3.

Regulatory 'Guide 1.9, Rev. [3], [date].

4.

FSAR, Chapter [6].

5.

FSAR, Chapter

[15].

6.

Regulatory Guide 1.93, Rev. [ ], [date].

7.

Generic Letter 84-15.

8.

10 CFR 50, Appendix A, GDC 18.

9.

Regulatory Guide 1.108, Rev. [1], [August 1977].

10.

Regulatory Guide 1.137, Rev. [ 3, [date].

11.

ANSI C84.1-1982.

12Property "ANSI code" (as page type) with input value "ANSI C84.1-1982.12" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

ASHE, Boiler and Pressure Vessel

Code,Section XI.

13.

IEEE Standard 308-[1978].

CEOG STS B 3.8-33 Rev.

0, 09/28/92

INSERT AB 14.

CE NPSD-996, "CEOG Joint Applications Report for Emergency Diesel Generator AOT Extension," April 1995

V I

ML17228B179

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