ML17250B218

Proposed Tech Specs Re Offsite & Onsite Power Sources Available for Operation of Plant Auxiliaries

ML17250B218
Person / Time
Site:	Ginna
Issue date:	06/29/1990
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17250B216	List: ML17250B215 ML17250B217 ML17250B218
References
NUDOCS 9007120094
Download: ML17250B218 (26)

Text

ATTACHMENT A Revise the Technical Specification pages as follows:

Remove Insert Table of Contents (i) Table of Contents (i) 3.0-3 3.0-3 3 ~7 1 3~7 1 3 ~7 2 3~7 2 3 ~7 3 3~7 3 3.7-4 3.7-4 3.7-5 3.7-6 3~7 7 4.6-1 4.6-1 4.6-2 4.6-2 4.6-4 4.6-4 4.6-5 4.6-5 4.6-5A 4.6-5A 9007120094 900629 PDR AGOCK 05000244 P PDC

TABLE OF CONTENTS Pacae 1.0 DEFINITIONS 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS 2.1-1 2.1 Safety Limit, Reactor Core 2~1 1 2.2 Safety Limit, Reactor Coolant System Pressure 2.2-1 2.3 Limiting Safety System Settings, Protective Instrumentation 2~3 1 3.0 LIMITING CONDITIONS FOR OPERATION 3.0 Applicability 3.0-1 3.1 Reactor Coolant System 3~1 1 3.1.1 Operational Components 3~1 1 3.1.2 Heatup and Cooldown 3.1-5 3.1.3 Minimum Conditions for Criticality 3.1-18

3. 1. 4 Maximum Coolant Activity 3 ~ 1 21 3.1.5 Leakage 3.1-25 3.1.6 Maximum Reactor Coolant Oxygen, Fluoride, and. Chloride Concentration 3 ~ 1 31 3.2 Chemical and Volume Control System 3~2 1 3.3 Emergency Core Cooling System, Auxiliary Cooling Systems, Air Recirculation Fan Coolers, Containment Spray and Charcoal Filters 3~3 1 3.4 Turbine Cycle 3.4-1 3.5 Instrumentation System 3.5-1 3.6 Containment System 3.6-1 3.7 Auxiliary Electrical Systems 3~7 1 3.8 Refueling 3.8-1 3.9 Plant Effluents 3.9-1 3.10 Control Rod and Power Distribution Limits 3.10-1 3.11 Fuel Handling in the Auxiliary Building 3 ~ 11 1 3.12 Movable In-Core Instrumentation 3 ~ 12 1 3.13 Shock Suppressors (Snubbers) 3 ~ 13 1 3.14 Fire Suppression System 3.14-1 3.15 Overpressure Protection System 3.15-1 3.16 Radiological Environmental Monitoring 3.16-1 4.0 SURVEILLANCE REQUIREMENTS 4.1 Operational Safety Review 4.1-1 4.2 Inservice Inspection 4.2-1 4.3 Reactor Coolant System 4.3-1 4.4 Containment Tests 4.4-1 4.5 Safety Injection, Containment Spray and Iodine Removal Systems Tests 4.5-1 4.6 Preferred and Emergency Power Systems Periodic Tests 4.6-1 4.7 Main Steam'top Valves 4.7-1 Amendment No. gg Proposed

0 inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The time limit of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to hot shutdown and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to cold shutdown do not apply because the time limits for 1 accumulator inoperable are more limiting. It is assumed that the unit is brought to the required mode within the required times by promptly initiating and carrying out the appropriate action statement.

Specification 3.0.2 delineates what additional conditions must be satisfied to permit operation to continue, consistent with the action statements for power sources, when a normal or emergency power source is not operable.

It allows operation to be governed by the time limits of the action statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individual action statements for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source.

)

For example, Specification 3.7,.1.1.a requires in part that I

two emergency diesel generators be operable. The action

'H statement provides for a maximum out-of-service time when one emergency diesel generator is not operable. If the definition of operable were applied without consideration of Specification 3. 0. 2, all systems, subsystems, trains, components and. devices supplied by the inoperable emergency power source would also be inoperable. This would dictate invoking the applicable action statements for each of the applicable Limiting Conditions for Operation. However, Amendment No. g4 3.0-3 Proposed

3.7 AUXILIARYELECTRICAL SYSTEMS A licabilit Applies to the availability of electrical power for the operation of plant auxiliaries.

To define those conditions of electrical power availability necessary to provide for the continuing availability of engineered safeguards.

3.7.1 S ecification 3.7.1.1 The reactor coolant system shall not be taken above the mode indicated unless the following conditions are met:

a. Above 350'F;

~ the independent offsite sources (34.5 kV-4160 volt station service transformers, 12A with dedicated circuit. 751, and 12B with dedicated circuit 767) are operable

~ the 480-volt buses 14 and 18 (Train A) and buses 16 and 17 (Train B) are energized.

~ the two diesel generators are operable with onsite supply of 5,000 gallons of fuel available for each diesel generator.

b. Above cold shutdown;

~ both batteries and both dc systems are operable.

~ at least 150 amps of battery charging capacity for each DC system that is in service.

Amendment No. 3 ' 1 Proposed

1 3.7.1.2

~

Actions To Be Taken If Conditions ~

of 3.7.1.1 Are Not Met:

a. Operation above 350'F may continue with one independent offsite source inoperable, provided all remaining conditions of 3.7.1.1 are met.

b. With both independent offsite sources operable, and one diesel generator inoperable above 350 F, demonstrate the operability of the remaining diesel generator by:

1. Performing the surveillance requirements identified in Specifications 4.6.1.a.4 and 4.6.l.a.6 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at. least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter and restore the inoperable diesel generator to operable status within 7 days; OR

2. Run the diesel generator continuously as long as such operation is not in excess of 7 days (total for both diesels) during the previous 31 day period. OTHERWISE:

3. Be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than or equal to 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With one independent offsite source inoperable, and one diesel generator inoperable, operation above 350'F may continue providing the remaining diesel generator is run continuously and such operation is not in excess of 7 days (-total for both diesels) during the previous 31 day period, OR; be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than or equal to 350 F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Amendment No. 3~7 2 Proposed

d. With both independent offsite sources inoperable, both diesel generators must be operable. In addition, restore one independent offsite source within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least the hot shutdown condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than or equal to 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

e. Operation above cold shutdown may continue if less than 150 amps of battery charging capacity is available to one dc system, provided at least 150 amps of battery charging capacity is available to each dc system within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If not available, the reactor shall be placed in at least the hot shutdown condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in the cold shutdown condition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

3.7.2 S ecification 3.7.2.1 With fuel in the reactor vessel, the following conditions are to be met:

'. 'h At or below 350'F;

~ One independent offsite power source operable, or backfeed through unit auziliary transformer 11; and

~ One train of 480-volt buses (14 and 18, or 16 and.

17) operable; and

~ One diesel generator operable with onsite supply of 5,000 gallons of fuel available and either buses 14 and 18, or 16 and 17, operating and capable of being

=

supplied from that diesel generator.

b. At cold or refueling shutdown

~ One battery and one dc system, and at least 150 amps of battery charger capacity to the battery must be operable.

3 ' 3 Proposed

3.7.2.2 Actions To Be Taken If Conditions of 3.7.2.1 Are Not Met:

With less than the above minimum required power source operable, immediately suspend all operations involving positive reactivity changes, core alterations, movement of irradiated fuel and initiate corrective action to restore the required power sources to operable status.

-Basis for 3.7.1 and 3.7.2:

The electrical systems equipment is arranged so that no single failure can inactivate enough safeguards equipment to jeopardize the plant safety. The 480-volt safeguards equipment is arranged on 4 safeguards buses. The 4160-volt equipment (none of which is safety-related), is supplied from 4 buses.

Two separate offsite sources supply station service power to the plant.

The plant auxiliary equipment is arranged electrically so that redundant safeguards loads receive power from separate sources. In the event that 1 offsite source is not available, the remaining offsite source is capable of supplying both trains of safeguards loads. Safeguards loads such as safety injection pumps, containment fans, residual heat removal pumps, and motor control centers 1C and 1D are divided between the 480-volt buses No. 14 and 16. Redundant loads including service water pumps are supplied by buses No. 18 and

17. Together these buses form the Train A and B redundant Class 1E sources.

AC power for safeguards equipment originates from both offsite and onsite sources. The operability of these power sources and associated distribution systems ensures that sufficient power will be available to supply the safety-related equipment required for (1) the safe shutdown of the plant, and (2) the mitigation and control of accident conditions within the plant.

3.7-4 Proposed

When the RCS

~

temperature is greater than

~ both emergency 350 F, diesel generators are required to be operable. The two diesel generators have sufficient capacity to start and run all the engineered safeguards equipment at design loads. The safeguards equipment operated from one diesel generator can adequately cool the core and maintain the containment pressure within the design value for any loss of coolant incident. The minimum diesel fuel oil inventory is maintained to assure that both diesels can carry the design loads of required engineered safeguards equipment for at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, or for one engineered safety feature train for 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />, or for operation under hot standby non-accident conditions for 111 oil supplies and trucking facilities exist to assure hours.'~'ommercial deliveries within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The offsite power source consists of separate dedicated 34.5 kV-4160 volt station service transformers served by dedicated. 34.5 kV lines (12A transformer with dedicated circuit 751, or 12B transformer with dedicated circuit, 767) in operable status. Either offsite source of power can supply all auxiliary loads and transfer can be accomplished within the time constraints of GDC 17. Thus, GDC 17 is explicitly met.

With fuel in the reactor vessel and. the RCS temperature'below 350'F a minimum of one offsite source and one onsite source of AC power are required. The offsite power source may be provided by one of three configurations:

1. Transformer 12A served by a dedicated 34.5 kV line (circuit 751), or

2. Transformer 12B served by a dedicated 34.5 kV line (circuit 767), or

3. Backfeed through unit auxiliary transformer 11.

3.7-5 Proposed

The offsite t

power source is the preferred t source of AC power.

Operability of an offsite source requires that one station service transformer served by a dedicated 34.5 kV line is operating and providing power to the unit. The emergency diesel generator provides power upon loss of the offsite source. One emergency diesel generator with 5,000 gallons of fuel can provide power to a minimum level of engineered safeguards equipment for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (the required safeguards loads at cold. shutdown/refueling are significantly less than during power operation). One operable diesel fuel oil transfer pump is required to supply fuel from one of the two fuel storage tanks to the day tank of the operable diesel generator. With less than one offsite and one onsite AC source of power available, no operations involving positive reactivity changes, core alterations, and movement of irradiated fuel shall occur.

Battery chargers with at least 150 amps. capacity shall be in service for each battery so that the batteries will always be at full charge.

This ensures that adequate dc power will be available.

During cold or refueling shutdown, one train of batteries and dc system shall be available to specifically support refueling operations, and operation of safeguards loads, if necessary.

The plant can be safely shutdown without the use of offsite power since all vital loads (safety systems, instruments, etc.) can be supplied from the emergency diesel generators and the station batteries.

3.7-6 Proposed

l I

The two

~ ~

diesel generators, each capable of supplying safeguards loads, and the station auxiliary transformers provide four separate sources of power immediately available for operation of these loads.

Thus, the power supply meets the single failure criteria.

References (1) UFSAR Section 9.5.4 3 ' 7 Proposed

4.6 Preferred and Emer enc Power S stems Periodic Tests A licabilit Applies to periodic testing and surveillance requirements of the preferred and emergency power systems.

To verify that the preferred and. emergency power systems will respond promptly and properly when required.

S ecification The following tests and surveillance shall be performed as stated:

4.6.1 Diesel Generators Each diesel generator shall be demonstrated operable:

a. Except during cold or refueling shutdown at least once per 31 days by:

1. Verifying the fuel level in the day tank.

2. Verifying a minimum oil storage of 5,000 gallons for each generator is onsite.

3. Verifying the fuel transfer pump can be started and transfer fuel from the storage system to the day tank.

4. Verifying the diesel starts from normal standby conditions, and. attains rated voltage and.

frequency.

5. Verifying the generator is synchronized, loaded. to at least 1950 kw but less than the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating of 2250 kw and. operates for at least 60 minutes but less than 120 minutes.

6. Verifying the diesel generator is aligned to provide standby power to the associated emergency buses.

b. The tests in Specification 4.6.1a will be performed prior to exceeding 350 F if the time since the last test exceeds 31 days.

c. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified in Table 1 of ASTM D975-78 when checked for viscosity, water and sediment.

4.6-1 Proposed

d. At least once per 18 months during shutdown by:

l. Inspecting the diesel in accordance with the manufacturer's recommendations for this class of standby service.

2. Verifying the generator capability to reject a load of 295 KW without tripping.

3. Simulating a loss of offsite power in conjunction with a safety injection test signal and:

(a) Verifying de-energization of the emergency buses and load shedding from the emergency buses.

(b) Verifying the diesel starts from normal standby condition on the auto-start signal, energizes the automatically connected emergency loads with the following maximum breaker closure times after the initial starting'ignal for Trains A and B not being exceeded A B Diesel plus Safety Injection 20 sec 22 sec Pump plus RHR Pump All Breakers 40 sec 42 sec and operates for > five minutes while its generator is loaded with emergency loads.

(c) Verifying that all diesel generator trips, except engine overspeed, low lube oil pressure, and overcrank,'re automatically bypassed upon a safety injection actuation signal.

4.6-2 Proposed

c. At each time data is recorded, new data shall be compared with old to detect signs of deterioration.

d. Each battery shall be subjected. to a load test within a twelve-month period from the last load test; however, to permit the load test to coincide with a scheduled refueling, the period. may extend for an additional three months. The battery voltage as a function of time shall be monitored to establish that the battery performs as expected. during heavy discharge and that all electrical connections are tight.

e. Each battery shall be subject to a discharge test at least once per 60 months. The purpose of this test is to show that the battery capacity is at least 80% of the manufacturer's recommendations. When performed, this discharge test may substitute for the load test.

f. The discharge test shall be performed annually for any battery that shows signs of degradation. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous discharge tests, or is below 90: of the manufacturer's rating.

4.6.3 Preferred (Offsite) Power Su lies Each offsite power source shall be demonstrated operable:

a. At least once per 7 days by:

1. Verifying nominal voltage indications on the high-voltage side of transformers 12A and 12B; and on the 4160 volt buses 12A and. 12B.

2. Verifying 4160 volt circuit breakers 12AX or 12BX, AND 12AY or 12BY are open.

3. Verifying tie breakers 52/BT16-14 and 52/BT17-18 are open when plant mode is above 200'F.

b. At least once per 18 months by transferring unit power supply to 4160 volt buses 12A and 12B from the normal circuit to the alternate circuit.

Amendment No. X4 4.6-4 Proposed

Basis The tests specified are designed to demonstrate that the diesel generators will provide power for operation of equipment. They also assure that the emergency generator system controls and the control systems for the safeguards equipment will function automatically in the event of a loss of all normal 480V AC station service power.'~'he test frequency specified will be often enough to identify and correct any mechanical or electrical deficiency before it can result in a system failure. The fuel supply and starting circuits and controls are continuously monitored and any faults are indicated by alarms. An abnormal condition in these systems can be identified without having to test the diesel generators.

Periodic tests are also specified to demonstrate that the offsite power sources will provide power for operation of equipment.

Offsite power source operability requires correct breaker alignment and indicated power availability from the two preferred power circuits, 767 and 751, to the 4160 volt buses. These requirements are met by monitoring nominal voltage indications on the high-voltage side of transformers 12A and 12B; and on the 4160 volt buses 12A and 12B.

Offsite power source independence requires separate- 4160 volt circuits supplying power to the 4160 volt buses. Interlocks prevent concurrent closure of 12AX and 12BX, OR 12AY and 12BY; and surveillance is specified. to ensure separation is maintained.

Amendment No. 4.6-5 Proposed.

Furthermore, to assure independence between redundant Class 1E 480 volt buses 14 and 18 (Train A) and buses 16 and 17 (Train B), tie breakers 52/BT16-14 and 52/BT17-18 are required to be open when the plant mode is above 200'F. Once tie breakers are open, interlocks prevent closure when independent and redundant buses are energized.

Station batteries may deteriorate with time, but precipitous failure is extremely unlikely. The surveillance specified is that which has been demonstrated. over the years to provide an indication of a cell becoming unserviceable long before it fails, and to ensure that the battery capacity is acceptable.

The equalizing charge, as recommended. by the manufacturer, is vital to maintaining the ampere-hour capability of the battery. As a check upon the effectiveness of the equalizing charge, the battery should be loaded rather heavily and. the voltage monitored as a function of time. If a cell has deteriorated or if a connection is loose, the voltage under load will drop excessively indicating replacement or maintenance.

The minimum permissible on-site fuel inventory, 10,000 gallons, (5,000 gallons for each generator), is sufficient for operation under loss-of-coolant accident conditions of two engineered safety features trains for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, or for one train for 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />, or for operation under hot standby non-accident conditions for 111 hours0.00128 days <br />0.0308 hours <br />1.835317e-4 weeks <br />4.22355e-5 months <br />.'eferences (1) UFSAR, Section 8.3 (2) UFSAR, Section 9.5.4 Amendment No. 4.6-5A Proposed

ATTACHMENT B The purpose of this Amendment is to incorporate additional Specifications and Action Statements regarding required operability of the Ginna Station Auxiliary Electrical Systems. In particular, additional Specifications and Action Statements have been added to address the modifications being made to the offsite power system.

The reconfiguration will increase the availability margin of the offsite system by dedicating a 34.5kV 4160 volt transformer to each of the two offsite transmission lines. The detailed changes are listed on Table 1.

Additional requirements have been added .including required actions based on reactor coolant system operation above and below 350'F, and specific power source operability requirements. Those new power source operability requirements are considered more conservative than previous specifications while also more explicit. During plant startup, all available power sources are required to provide power for engineered safeguards and auxiliary cooling system. The format has been modified to identify separate specifications and actions.

Minor changes have been made to the periodic test requirements for the emergency power supplies. The changes have been made to clarify the diesel generator testing requirements prior to exceeding 350'F.

This is a conservative change as previously the testing was required for completion prior to exceeding 5% power. Periodic testing requirements to verify operability of the offsite power sources previously unidentified within the Technical Specifications have been added. These testing requirements are consistent with Standard Technical Specifications.

Previously, Ginna Station offsite power supply was configured as shown in Figure 8.1-1 of the UFSAR. Supply from the transmission grid consisted of two independent 34.5kV transmission lines; each capable of serving a single 4160 volt Station Auxiliary transformer (Unit 12A). Transformer 12A served a dual purpose in that it used as a startup source. and was also a dedicated offsite source for was all the Class lE equipment. The design as it existed was less reliable in that the loss of 12A transformer resulted in the reliance on two onsite diesel generators until such time as the Unit Auxiliary Transformer (Unit 11) could be backfed through the 115kV system.

Backfeeding the Unit Auxiliary Transformer is considered a delayed.

access source and. results in the long-term reliance on the diesel generators and the batteries for maintaining safe shutdown loads.

Although the offsite power system met the requirements of all existing license;ng commitments, the operating margin could be improved. The modified system provides additional margin by dedicating two independent offsite power sources with separate transformers.

This Technical, Specification Amendment addresses specific requirements and actions resulting from the modification, and further defines those time requirements previously unspecified within the Technical Specifications.

Specifications 3.7.1 and 3.7.2 have been created to identify the auxiliary electrical system requirement depending upon reactor coolant system temperature conditions. The specifications proposed identify system temperature requirements more restrictive than those currently existing. This has been done to make them consistent with temperature limitations existing for other safety system operations.

The actions specified within Sections 3.7.1.2.a, b and c identify the emergency power operability and plant operations requirements based upon independent offsite power source operability. The plant operation alternatives are progressive with prudent time requirements identified based upon both the potential safety impact of the reduced power availability configuration while allowing some time to make repairs. Allowable times are consistent with Standard Technical Specifications and also consider the safety implications of unwarranted plant cycling. Actions specified in Section 3.7.1.2.b.1 permit operation with one diesel generator inoperable providing the operability of the remaining diesel generator is demonstrated utilizing periodic tests every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or by running the remaining diesel. This configuration is allowed for a period not to exceed seven (7) days in order to permit time to effect repairs. Periodic testing of the remaining diesel generator in this manner versus continuous running provides the assurances of diesel generator operability without the adverse impact of continuously running the diesel generator.

The action specified in Section 3.7.1.2.a allows power operation to continue following the loss of one station service transformer, provided all remaining conditions are met. The preferred (offsite) electrical system reliability with one offsite source available has been proven, as't has existed since original plant licensing. It is also more'onservative than existing technical specifications as power operation was previously allowed to continue with no offsite power sources, available.

The actions specified within Section 3.7.1.2.d identify the emergency power operability requirements with both offsite power sources inoperable. Prudent maximum out-of-service duration for both offsite sources of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was chosen to both minimize this mode of operation, while allowing some time to make repairs.

Section 3.7.2 identifies the Specifications and actions to be taken when the reactor is below 350 F for AC power and below cold shutdown for DC power. Battery and DC System specifications are identified for operations at or below .cold shutdown. The specifications identify the operability requirements for offsite and.emergency power during specific reduced temperature operations with fuel in the reactor vessel. One (1) onsite, one (1) offsite, and one (1) dc system will be available during periods of operation in this mode.

Previous technical specifications identified no specific requirements regarding operation limitations for conditions below power operation including refueling activities. Section 3.7.2.1 and the action specified in Section 3.7.2.2 identify requirements more conservative than the existing requirements. They have been added to provide the operators with clear specifications when less than normal power supplies are available.

B-2

Section 4.6.1.d.3(c) has been changed to clarify diesel generator trip testing. RG&E has determined that the words "loss of voltage on the emergency bus and/or safety injection actuation signal" are misleading since there is no bypass of protective trips on loss of voltage. Bypass. of protective trips is caused. only by SI. The origin of the words "loss of voltage on the emergency bus and/or" are not explicitly known. A description of diesel generator trips and bypasses provided by letter from L.D. White (RG&E) to A. Schwencer (NRC), dated May 16, 1977, makes no mention of an undervoltage bypass. A License Amendment request of November 16, 1977 states that the "Standard Tech Specs published. by the NRC have been used as guidance in preparation of. the proposed, Technical Specification."

The current Standard. Tech Specs (p. 3/4 8-5) includes the words "loss of voltage on the emergency bus concurrent with a safety injection signal" to verify the automatic bypass feature. RG&E meets thi:s requirement with test procedure RSSP-2.2. There is no technical basis to bypass the "overcurrent" and "reverse power" trips on a loss of voltage to the emergency bus, since this would not be consistent with the accident condition assumption that an SI signal actuation is generated. Unnecessary risk to the diesel generator would be created if these two trips were bypassed in this case. RG&E therefore deleted the words "loss of voltage on the emergency bus and/or" from has Section 4.6.1.d.3(c).

Section 4.6.2.c no longer specifies detecting signs of abuse through the comparison of new and old test data. Abuse, as a cause of deterioration, need, not be specified within. the plant Technical Specifications.

Section 4.6.3 has been created to address the surveillance requirements for the preferred (offsite) power supplies.

Section 4.6.3.a identifies verifications every 7 days for emergency power capacity and capability from the offsite power supplies. In addition, correct tie breaker alignment verification is specified to ensure independence between the redundant 480 volt safeguards buses.

These requirements are consistent with Standard Technical Specifications and more conservative than existing Technical Specificatio'ns.

In accordance with 10CFR50.91, these changes to Technical Specifications have been evaluated to determine if the operation of the facility. in accordance with the proposed. amendment would:

1. involve a significant increase in the probability or consequences of an acc'ident prevj.ously evaluated. or

2. create the possibility of a new or different kind of accident previously evaluated; or

3. involve a significant reduction in a margin of safety.

These proposed changes do not increase the probability or consequences of a previously-evaluated accident or create a new or different kind of accident. Furthermore, there is no reduction in the margin of safety for any Technical Specification. The detailed changes are described in Table 1.

B-3

Therefore, .Rochester Gas and Electric submits that the issues associated with this Amendment request are outside the criteria of 10CFR56.91; and a no significant hazards finding is warranted.

TABLE 1 r

Chanche Effect Table of Contents revised See Section 4.6 to include Preferred Power System Periodic Tests.

Section 3.0.2 Bases states No technical change.

example in 3.7.1.d. New reference example is 3.7.1.1.a.

Reformat Specifications All specifications including into Section 3.7.1, actions for operation with Specifications Reactor the reactor above 350'F are Coolant System Operation included in Section 3.7.1.

above 350 F and Section Specifications for. operation 3.7.2, Specification with the reactor below 350'F Reactor Coolant System and fuel in the reactor operation at or below 350 vessel are included in with fuel in the reactor Section 3.7.2.

vessel. Appropriate Specification and Action Statements listed within each section.

Section 3.7.1.1.a includes Increased operating the addition of station availability margin through service transformer 12B the addition of requirements with dedicated circuit 767 for operation requiring operable. Two diesel additional transformer generators are identified, operability. Increased independently with clarity regarding diesel required 5,000 gallon fuel operability is specified.

supply. 4160 volt buses energized has been deleted.

Section 3.7.1.1.b Increased requirements addresses DC System specifying cold shutdown requirement above cold requirement vs. reactor shutdown. criticality for redundant train DC System operability.

Section 3. 7. 1. 2. a similar Power operation may continue to existing 3.7.2.a. with one station service transformer operable vs. the station service transformer, inoperable.

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7. Section 3.7.1.2.b and

~ ~ ~ ~ Compara e to previous 3.7.1.2.c addresses diesel Specification 3.7.2.b with generator emergency power increased specificity

. operability, time, and provided for operability action requirements with determinations and shutdown one independent offsite requirements.

source operable and/or one diesel generator inoperable.

8. Section 3.7.1.2.d New additional Technical addresses emergency power Specification action limiting operability and time and power operation when offsite action requirements with power -is not available.

both independent offsite Based. upon Standard Tech sources inoperable. Specs.

9. Section 3.7.1.2.e is Minor clarifying word changes similar to previous are included.

Section 3.7.2.c.

10. Proposed Section 3.7.2.1.a New additional Technical addresses operation with Specifications. There were the reactor below 350'F previously no electrical with fuel in the reactor power system Technical vessel. DC System Specifications or actions specifications for at or applicable to low temperature below cold shutdown are operations.

described in 3.7.2.1.b and actions to be taken are in

.Section 3.7.2.2 Section 4.6 modified to Broader periodic testing identify periodic tests requirements to address both for preferred (offsite) emergency and preferred power system in lieu of (offsite) power supply emergency power system operability. Based upon periodic tests only. Standard Tech Specs.

12. Section 4.6.1.a.2 oil Minor clarifying oil storage storage requirements requirements per diesel redefined. for each diesel generator.

generator.

13. Section 4.6.1.b modified. Increased requirements to require testing prior requiring earlier diesel to exceeding 350 F in lieu generator operability of 5% power. periodic testing during startup operations.

14. Specification 4.6.1.d.3(c) Clarifies test requirements is comparable to previous for automatic bypass of Specification 4.6.1.d.3(c) diesel generator trips. Loss except that statement of voltage on the emergency "loss of voltage on the bus does not cause an emergency bus and/or" has automatic bypass of been deleted. protective trips.

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15. Section 4.6.3 added. to New itional Technical identify periodic test Specification. There were requirements for offsite previously no periodic test

.i power. requirements for offsite power sources.

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