Text

License Amendment Request to Remove Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery and High Pressure Core Spray Diesel Generator
	ML18157A123
Person / Time
Site:	LaSalle
Issue date:	04/19/2018
From:	Gullott D; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-18-028
	Download: ML18157A123 (56)
	v • d • e

e e ti RS-18-028 10 CFR 50.90 April 19, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

License Amendment Request to Remove Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery and High Pressure Core Spray Diesel Generator In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Exelon Generation Corporation, LLC (EGC) requests amendments to Renewed Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2, as follows:

The proposed amendments Would revise Technical Specifications (TS) 3.8.4, "DC Sources-Operating," and TS 3.8.6, "Battery Parameters," by removing the Mode restrictions for performance of TS Surveillance Requirements (SR) 3.8.4.3 and SR 3.8.6.6 for the Division 3 direct current (DC) electrical power subsystem battery. The Division 3 DC electrical power subsystem feeds emergency DC loads associated with the High Pressure Core Spray (HPCS) system. SR 3.8.4.3 verifies that the battery capacity is adequate for the battery to perform its required functions. SR 3.8.6.6 verifies battery capacity is ~ 80% of the manufacturer's rating when subjected to a performance discharge test (or a modified performance discharge test). The proposed amendments would remove these Mode restrictions for the Division 3 battery, allowing performance of SR 3.8.4.3 and SR 3.8.6.6 for the Division 3 battery during Mode 1 or 2, potentially minimizing impact on HPCS unavailability. Eliminating the requirement to perform SR 3.8.4.3 and SR 3.8.6.6 only during Mode 3, 4, or 5 (hot shutdown, cold shutdown, or refueling conditions) will provide greater flexibility in scheduling Division 3 battery testing activities by allowing the testing to be performed during non-outage times.

The proposed amendments would revise TS 3.8.1, "AC Sources-Operating," by revising certain SRs pertaining to the Division 3 HPCS diesel generator (DG). The Division 3 DG is an independent source of onsite alternating current (AC) power dedicated to the HPCS system. The TSs currently prohibit performing the testing required by SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.16, SR 3.8.1.17, and SR 3.8.1.19 in Modes 1 or 2. The proposed amendments would remove these Mode restrictions and allow all eight of the identified SRs to be performed in any operating Mode for the Division 3 DG.

April 19, 2018 U.S. Nuclear Regulatory Commission Page 2 The request is subdivided as follows:

- Attachment 1 provides a description and evaluation of the proposed changes.

- Attachment 2 provides the markup of the affected TS pages.

- Attachment 3 provides the TS Bases pages marked up to show the proposed changes.

The TS Bases pages are provided for information only and do not require NRC approval.

- Attachment 4 provides a simplified one-line diagram of the LSCS onsite 4.16 kV emergency electrical distribution system.

The proposed change has been reviewed by the LSCS Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program .

EGC requests NRC approval of the proposed amendments by April 19, 2019. Once approved, the amendments shall be implemented within 90 days. This implementation period will provide adequate time for the affected station documents to be revised using the appropriate change control mechanisms.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

EGC is notifying the State of Illinois of this application for license amendments by transmitting a copy of this letter and its attachments to the designated State Official.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of April 2018.

Respectfully, D_f)r11a;J David M. Gullett Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Evaluation of Proposed Change

2) Markup of Technical Specifications Pages

3) Markup of Affected TS Bases Page (For Information Only)

4) One-Line Diagram Station Auxiliary Power - UFSAR Figure 8.1-2 cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency- Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Change

SUBJECT:

License Amendment Request to Remove Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery and High Pressure Core Spray Diesel Generator 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Description of the Proposed Change 2.2 Background

3.0 TECHNICAL EVALUATION

3.1 Division 3 Battery Surveillance Testing 3.2 High Pressure Core Spray Diesel Generator Surveillance Testing 3.2.1 General Basis 3.2.2 Administrative Controls for Online Maintenance 3.2.3 Online Risk Management 3.2.4 Online Testing Versus Outage Testing 3.2.5 Discussion for Individual Surveillance Requirements

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

Page 1 of 20

ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Exelon Generation Corporation, LLC (EGC) requests to amend Renewed Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Unit 1 and Unit 2.

Division 3 Battery Surveillance Testing The proposed amendments would revise Technical Specifications (TS) 3.8.4, "DC Sources-Operating," and TS 3.8.6, "Battery Parameters," by removing the Mode restrictions for performance of TS Surveillance Requirements (SR) 3.8.4.3 and SR 3.8.6.6 for the Division 3 direct current (DC) electrical power subsystem battery. The Division 3 DC electrical power subsystem feeds emergency DC loads associated with the High Pressure Core Spray (HPCS) system. SR 3.8.4.3 verifies that the battery capacity is adequate for the battery to perform its required functions. SR 3.8.6.6 verifies battery capacity is ?: 80% of the manufacturer's rating when subjected to a performance discharge test (or a modified performance discharge test).

The proposed amendments would remove these Mode restrictions for the Division 3 battery, allowing performance of SR 3.8.4.3 and SR 3.8.6.6 for the Division 3 battery during Mode 1 or 2, potentially minimizing impact on HPCS unavailability. Eliminating the requirement to perform SR 3.8.4.3 and SR 3.8.6.6 only during Mode 3, 4, or 5 (hot shutdown, cold shutdown, or refueling conditions) will provide greater flexibility in scheduling Division 3 battery testing activities by allowing the testing to be performed during non-outage times.

High Pressure Core Spray Diesel Generator Surveillance Testing The proposed amendments would revise Technical Specification (TS) 3.8.1, "AC Sources-Operating," by revising certain Surveillance Requirements (SRs) pertaining to the Division 3 diesel generator (DG). The Division 3 DG is an independent source of onsite alternating current (AC) power dedicated to the HPCS system. The TSs currently prohibit performing the testing required by SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.16, SR 3.8.1.17, and SR 3.8.1.19 in Modes 1 or 2. The proposed amendments would remove these Mode restrictions and allow all eight of the identified SRs to be performed in any operating Mode for the Division 3 DG. The Mode restrictions will remain applicable to the other two safety-related (Division 1 and Division 2) DGs.

The proposed change will provide greater flexibility in scheduling Division 3 DG testing activities by allowing the testing to be performed during non-outage times. Having a completely tested Division 3 DG available for the duration of a refueling outage will reduce the number of system re-alignments and operator workload during an outage.

2.0 DETAILED DESCRIPTION 2.1 Description of the Proposed Change Division 3 Battery Surveillance Testing The proposed amendment request includes the following revisions to the LSCS TS:

Page 2 of 20

ATTACHMENT 1 Evaluation of Proposed Change SR 3.8.4.3: TS 3.8.4 specifies requirements for the Division 1, Division 2, and Division 3 DC electrical power subsystems. The three DC electrical power subsystems are required to be operable in plant Modes 1, 2, or 3 (i.e., power operation, startup, or hot shutdown, respectively). SR 3.8.4.3 currently contains Note 2 that states that the SR shall not normally be performed during Modes 1 or 2 for the 125 VDC batteries. The proposed change would revise Note 2 to remove the Mode restrictions for the Division 3 battery.

SR 3.8.6.6: SR 3.8.6.6 specifies parameters for the Division 1, Division 2, Division 3, and opposite unit Division 2 DC batteries. The battery parameters for Division 1, Division 2, Division 3, and opposite unit Division 2 DC batteries are required to be within the limits when the associated DC electrical power subsystems are required to be operable. SR 3.8.6.6 currently contains Note 1 that states that the SR shall not normally be performed during Modes 1 or 2 for the 125 VDC batteries. The proposed change would revise Note 1 to remove the Mode restrictions for the Division 3 battery.

High Pressure Core Spray Diesel Generator Surveillance Testing The proposed amendment request includes the following revisions to TS 3.8.1:

SR 3.8.1.9: Revise Note 1 to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that following rejection of a load greater than or equal to its associated single largest post-accident load for the Division 3 DG (i.e., the 2421 kW HPCS pump), the frequency is within specified limits.

SR 3.8.1.10: Revise Note 1 to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that following a full load rejection (a load 2:: 2600 kW), the Division 3 DG does not trip, and voltage is maintained within specified limits.

SR 3.8.1.11: Revise Note 2 to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated loss of offsite power (LOOP) signal, achieves the required voltage and frequency, and supplies permanently connected loads for 2:: 5 minutes.

SR 3.8.1.12: Revise Note 2 to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated ECCS initiation signal, achieves the required voltage and frequency within the specified time, and operates for 2:: 5 minutes.

SR 3.8.1.13: Revise the Note to remove the restriction that prohibits performance of the SR in Modes 1 or 2 for the Division 3 DG only. This SR requires verification that the Division 3 DG automatic trips are bypassed on an actual or simulated loss of voltage signal on its associated emergency bus concurrent with an actual or simulated ECCS initiation signal, except for critical protective trip functions.

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ATTACHMENT 1 Evaluation of Proposed Change SR 3.8.1.16: Revise the Note to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that the Division 3 DG can be synchronized with the offsite power source while loaded with emergency loads, and upon a simulated restoration of offsite power, all loads are transferred to offsite power and the DG returns to ready-to-load operation.

SR 3.8.1.17: Revise the Note to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that, with the Division 3 DG operating in the test mode and connected to its bus, an actual or simulated DG overcurrent trip signal automatically disconnects the offsite power source, remaining connected to the emergency bus, while the DG continues to supply normal necessary loads.

SR 3.8.1.19: Revise Note 2 to remove the restriction that prohibits performance of the SR in Modes 1 or 2, for the Division 3 DG only. This SR requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated LOOP signal in conjunction with an actual or simulated ECCS initiation signal, achieves the required voltage and frequency within the specified time, and supplies permanently connected loads for~ 5 minutes. provides markups of the existing TS pages to show the proposed changes.

Markups of the current TS Bases pages are provided in Attachment 3 for information only and do not require NRC approval. The TS Bases changes will be processed in accordance with the LSCS TS Bases Control Program.

2.2 Background Division 3 Battery Surveillance Testing The LSCS DC electrical power system, described in Section 8.3.2 of the LSCS Updated Final Safety Analysis Report (UFSAR), provides the alternating current (AC) emergency power system with control power and provides both motive and control power to selected safety-related equipment. The emergency 125 VDC electrical power system consists of three independent Class 1E DC electrical power subsystems, Divisions 1, 2, and 3. Each subsystem consists of a battery, associated battery chargers, and all the associated control equipment and interconnecting cabling. As required by 10 CFR 50, Appendix A, General Design Criteria (GDC) 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The emergency 125 VDC electrical power system is illustrated in UFSAR Figure 8.3-12.

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC loads are automatically powered from the associated battery. Each DC battery subsystem is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between the redundant Class 1E subsystems such as batteries, battery chargers, or distribution panels. The independence of the three divisions of the emergency DC system is maintained throughout the distribution system and the DC loads.

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ATTACHMENT 1 Evaluation of Proposed Change The function of the Division 3 DC electrical power subsystem is to provide a reliable, continuous 125 VDC power source for the emergency DC loads associated with the HPCS system. Those loads include the Division 3 DG field flashing control logic, the control and switching function of the 4.16 kV Division 3 breakers, and control and motive power for the HPCS system logic, HPCS DG control and protection, and all Division 3 related controls. The Division 3 DC electrical power subsystem is classified as Class 1E. As noted above, the Division 3 battery and battery chargers are physically separated from and electrically independent of all other divisional batteries and battery chargers.

UFSAR Table 8.3-14 outlines the Division 3 battery load profile, including both the load magnitudes and durations. The Division 3 battery has adequate storage to carry the required load continuously for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 100-percent capacity Division 3 DC electrical power subsystem battery charger has sufficient capacity to restore the battery bank from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads.

The TS require that periodic service tests (i.e., SR 3.8.4.3) be performed for each of the Division 1, 2, and 3 batteries. The battery service test verifies the battery's capability to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The TS require that periodic performance discharge test (or modified performance discharge test) (i.e., SR 3.8.6.6) be performed for each Division 1, 2 and 3 battery. The TS SR frequencies are not being changed by the proposed license amendment request.

High Pressure Core Spray Diesel Generator Surveillance Testing LSCS TS 3.8.1, "AC Sources-Operating," specifies requirements for the Class 1 E electrical power distribution system AC sources. These AC sources consist of the offsite power sources and the onsite standby power sources (i.e., DGs). As required by 10 CFR 50, Appendix A, General Design Criterion (GDC) 17, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems. The offsite and onsite power systems are described in detail in Chapter 8.0 of the LSCS UFSAR. A simplified one-line diagram of the LSCS onsite 4.16 kV emergency electrical distribution system is shown in Attachment 4.

The LSCS Class 1 E AC distribution system supplies electrical power to three divisional load groups, Divisions 1, 2, and 3, with each division powered by an independent Class 1 E 4.16 kV emergency bus.

Division 1 and 2 emergency buses have access to two offsite power supplies (one normal and one alternate). The alternate offsite power source is normally supplied via the opposite unit system auxiliary transformer and the opposite unit circuit path. The alternate offsite circuit path includes the associated opposite unit's 4.16 kV emergency bus, unit tie breakers, and associated interconnecting bus to the given unit's 4.16 kV emergency bus. Division 3 load group has access to one offsite power supply (respective unit's system auxiliary transformer). Division 2 and 3 emergency buses on each unit have a dedicated onsite DG.

The ESF systems of any two of the three divisions provide for the minimum safety functions necessary to shut down the unit to maintain it in a safety shutdown condition.

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ATTACHMENT 1 Evaluation of Proposed Change Offsite power is supplied to the LSCS switchyard from the transmission network. From the switchyard, two electrically and physically separated circuits provide AC power to the unit onsite Class 1E 4.16 kV emergency buses.

3.0 TECHNICAL EVALUATION

3.1 Division 3 Battery Surveillance Testing The Bases for TS 3.8.4 and TS 3.8.6 currently state that the reason for the Mode restriction Note for both SR 3.8.4.3 and SR 3.8.6.6 is that performing the Surveillance would remove a 125 VDC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. However, the noted concern is not warranted with respect to the Division 3 DC electrical power subsystem. As discussed in UFSAR Sections 6.3.2.2.1, 8.3.1.4, and 8.3.2, the HPCS system is a stand-alone system with a dedicated DG and independent distribution system; therefore, there is minimal opportunity for the performance of this SR to have any impact on other safety-related plant equipment. The Division 3 battery and battery chargers are physically separated from and electrically independent of all other divisional batteries and battery chargers, and interconnection with the battery and battery chargers or the emergency DC load groups of any other division is not permitted under any condition of plant operation. The Division 3 battery is disconnected from the battery chargers during the surveillance tests and has no connection with any other equipment that is required to be operable. Therefore, performance of the required testing during plant operation would not result in a challenge to any other plant safety system.

Currently the HPCS system is removed from service to perform scheduled maintenance while in Mode 1, 2, or 3 as allowed by the TS. The proposed changes will allow the Division 3 battery service test required by SR 3.8.4.3 and periodic performance discharge test required by SR 3.8.6.6 to be performed in Modes 1 or 2, potentially minimizing impact on HPCS unavailability.

The TS allow the HPCS system to be inoperable for up to 14 days if the Reactor Core Isolation Cooling system is operable. This provides ample time for the performance of the battery SR.

The time needed to perform the battery testing (i.e., SR 3.8.4.3) is approximately 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The time needed to perform the periodic performance discharge test (or modified performance discharge test) (i.e., SR 3.8.6.6) is approximately 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Division 3 battery is therefore expected to be unavailable to support the HPCS system for approximately 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This testing period is within the window of time that the HPCS system will already be out of service for a planned system outage. The battery testing will occur during a planned HPCS outage and therefore will not result in an increase in risk above the current work practices of planned HPCS system maintenance outages.

Regarding configuration risk management, the testing of the Division 3 battery will be bounded by the risk associated with a HPCS system outage. Configuration risk management of the system outage is addressed in several ways. First, in addition to the TS limitations that apply to inoperable HPCS system equipment, the Safety Function Determination Program (SFDP) described in LSCS TS 5.5.12, "Safety Function Determination Program (SFDP)," and required by TS LCO 3.0.6 is utilized to protect against a loss of safety function. Second, the LSCS approach to performing maintenance uses a protected division concept. This means that, without special considerations, work is performed on only one division of equipment at a time.

Additionally, access to areas of the plant containing protected equipment is restricted. These Page 6 of 20

ATTACHMENT 1 Evaluation of Proposed Change administrative controls provide additional assurance that work is pertormed on only one division at a time.

LSCS has integrated risk management procedures in place that address the requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." These procedures provide assurance that when risk-significant plant equipment is removed from service, any increase is risk appropriately assessed and managed. Additionally, the HPCS system reliability and availability are monitored and evaluated in relationship to the Maintenance Rule program to ensure that total outage times are maintained with the program constraints and do not degrade operational safety over time to any significant degree.

3.2 High Pressure Core Spray Diesel Generator Surveillance Testing 3.2.1 General Basis Although the TS Bases, as currently written, state that the reasons for the SR Notes imposing Mode restrictions is to preclude the potential for perturbations of the electrical distribution systems during plant operation, challenge to continued plant safety systems, and removal of a required offsite circuit from service, reconsideration of these bases for the Division 3 AC Sources has determined that the noted concerns are not warranted with respect to requiring the affected SRs to be pertormed only during shutdown conditions.

This conclusion is based on: (1) the LSCS AC power supply and associated protection features; (2) industry and plant experience with the pertormance of testing required in accordance with the affected SRs; (3) administrative controls that minimize plant risks during pertormance of the affected testing; and (4) the low probability of a significant voltage perturbation during such testing.

The subject surveillance testing makes the Division 3 DG and its associated loads unavailable for responding to an accident during portions of the testing. The effect on safety of pertorming the subject SRs for the Division 3 DG during plant operation is not significantly different than the effect on safety associated with the pertormance of other DG surveillances required by the TS that are not prohibited from being performed during plant operation. For example, SRs 3.8.1.9, 3.8.1.10, and 3.8.1.17 are performed by paralleling the DG in test with offsite power, similar to the existing monthly run of the DG, which is conducted with the plant online. Further, performance of the required testing online does not challenge the Division 1 and Division 2 safety systems or the Reactor Core Isolation Cooling (RCIC) system, which provides a function similar to the HPCS system - refer to LSCS TS 3.5.3, and does not interfere with normal plant operation.

3.2.2 Administrative Controls for Online Maintenance The LSCS TSs impose requirements and restrictions on the amount of equipment allowed out of service at any given time. Required Action B.2 of TS 3.8.1, "AC Sources-Operating," requires identification of inoperable required features that are redundant to required features supported by the inoperable DG. This Required Action is applicable throughout the entire period of DG inoperability. Inoperable features on the redundant division would then cause entry into other more stringent Required Actions, thus providing further incentive not to perform testing on Division 3 AC Sources with redundant equipment inoperable. As previously described, the SFDP (TS 5.5.10) ensures that a loss of safety function is detected and appropriate actions are taken.

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ATTACHMENT 1 Evaluation of Proposed Change The LSCS approach to performing maintenance requires a protected division concept.

This means that without special considerations, work is only allowed on one division at a time. Additionally, access to areas of the plant containing protected equipment is restricted. These administrative controls provide additional assurance that work is performed on only one division at a time. LSCS procedures contain precautions to minimize risk associated with surveillance testing, maintenance activities, and degraded grid conditions when paralleling a DG with offsite power. For example, during testing, only one DG at a time is operated in parallel with offsite power. This configuration provides for sufficient independence of the onsite power sources from offsite power while still enabling testing to demonstrate DG operability. In this configuration and with the administrative controls for DG testing in place, it is possible for one DG to be affected by an unstable offsite power system. Even if this unlikely scenario were to occur, plant safe shutdown capability would still be assured with the two remaining OGs.

3.2.3 Online Risk Management EGC procedure WC-AA-101 , "On-Line Work Control Process," provides requirements to conduct a configuration risk assessment for all maintenance activities performed while LSCS is online. This procedure implements the requirements of paragraph (a)(4) of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." As required by this procedure, a PRA-based risk evaluation tool is used to quantify the potential risk implications of planned or emergent work activities. Based on this evaluation, if specific risk thresholds are exceeded, the schedule must be adjusted and appropriate risk reducing compensatory actions must be implemented prior to beginning work. These compensatory actions mitigate the increase in risk associated with the configuration and minimize the potential to allow work on redundant DGs or other related systems.

3.2.4 Online Testing Versus Outage Testing Due to the relationship between the Division 3 DG and the HPCS system, the TS allow up to 14 days of inoperability for the HPCS system, and consequently allow up to 14 days of inoperability for the Division 3 DG if the RCIC system is operable. Thus, the existing TS provide ample time for the online performance of the SRs that this request proposes to revise. The actual time needed to perform these SRs is approximately 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . A comparison of the TS requirements for emergency core cooling systems (ECCS) (i.e., TS 3.5.1 and 3.5.2) and AC Sources (i.e., TS 3.8.1 and 3.8.2) indicates that the TS requirements are more restrictive during Modes 1, 2, or 3 than the requirements during Modes 4 or 5. Thus, due to the redundancy and diversity of the ECCS, adequate accident mitigation equipment will be available if an event occurs while performing the subject surveillance testing during Modes 1 , 2, or 3.

The Division 3 HPCS system is a stand-alone system with its dedicated DG and independent electrical distribution system. As discussed in the LSCS UFSAR Section 8.3.1.4, this system is both physically and electrically separated from the other two safety-related divisions. All controls, wiring, and other components are separated to prevent common cause failures and cross-divisional damage due to external events such as fires, pipe ruptures, falling objects, etc. The Division 3 DG supplies only the HPCS pump and associated support equipment and auxiliaries (as listed in LSCS UFSAR Page 8 of 20

ATTACHMENT 1 Evaluation of Proposed Change Table 8.3-1). Therefore, there is minimal opportunity for the performance of these SRs to have any impact on other safety-related plant equipment.

As described in LSCS UFSAR Section 6.3, the HPCS system has a full flow test line to route water from and to the suppression pool without entering the reactor pressure vessel and instrumentation to indicate system performance during normal test operation. These features allow system testing without discharging into the reactor vessel. System configuration is such that HPCS system testing can be performed without impacting other divisional safety systems.

During both normal plant operation and during shutdown conditions, the three 4.16 kV emergency buses are normally aligned to the system auxiliary transformer.

The on-line performance of the subject SRs for the Division 3 DG will have little effect on managing equipment unavailability goals described in 10 CFR 50.65(a)(3). The availability performance criteria are monitored in accordance with the Maintenance Rule program. The addition of approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of unavailability per 24-month period does not challenge achievement of the established performance criteria.

3.2.5 Discussion for Individual Surveillance Requirements SR 3.8.1.9 and SR 3.8.1.10 SR 3.8.1.9 requires verification that following rejection of a load greater than or equal to the associated single largest post-accident load for the Division 3 DG (i.e., the 2421 kW HPCS pump), the frequency remains within specified limits (i.e., :s; 66.7 Hz). SR 3.8.1.10 requires verification that following a load rejection (i.e., a load of;:::: 2600 kW), the Division 3 DG does not trip and voltage is maintained within specified limits. Currently, these SRs contain a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for the Note is that performing the surveillances could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems.

SR 3.8.1.9 and 3.8.1.1 O are performed by paralleling the Division 3 DG with offsite power, similar to the existing monthly run of the DG that is conducted with the plant on line. For performance of the load rejection tests per SR 3.8.1.9 and 3.8.1.10, the typical approach taken is to load the Division 3 DG output breaker. Opening the DG output breaker separates the DG from its associated emergency bus and allows the offsite power source to continue to supply the bus. This evolution has little impact on the plant electrical distribution system. The power system loading during such testing is within the rating of all transformers, switchgear, and breakers, both before and after the load rejection, and as further explained below, performance of the load rejection SRs does not cause any significant perturbations to the electrical distribution systems as the DG is separated from the bus.

During plant operation, the 4.16 kV emergency buses are normally aligned to the system auxiliary transformer, which is fed from a 345 kV offsite system. This is the same configuration maintained during plant shutdown when the load rejection testing is currently conducted. The probability for a grid disturbance to occur during the timeframe of a test performed per SR 3.8.1.9 or SR 3.8.1.1 O is low since the occurrence of a grid disturbance Page 9 of 20

ATTACHMENT 1 Evaluation of Proposed Change is independent of the testing. Protective relaying for the DG would be available to protect the DG while it is connected to the offsite power source. In addition, the protective instrumentation for sustained offsite power low-voltage conditions, required to be operable per TS 3.3.8.1, "Loss of Power (LOP) Instrumentation)," would be available to respond to such a condition.

Historical voltage data from testing performed pursuant to these SRs for the Division 3 DG full load rejection test, with the unit in a shutdown condition, has shown that the generator voltage change which occurs during the transient is approximately 365 volts, which is 9 percent of the 4.16 kV rated voltage, with voltage recovery within approximately three seconds. Thus, the voltage transient experienced by loads on the bus is minor and would not challenge the loss of voltage or degraded voltage relays.

Starting the HPCS pump motor is a more limiting transient than a Division 3 full load rejection due to the presence of the pump motor starting transient. HPCS pump starts are routinely performed online, with offsite power supplying the Division 3 emergency bus, to satisfy quarterly inservice testing requirements. These tests have not disturbed plant operation.

Based on the above discussion, the reasons for the mode restrictions stated in the TS Bases for SR 3.8.1.9 and SR 3.8.1.1 Oare not valid for the Division 3 DG.

SR 3.8.1.11 SR 3.8.1.11 requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated LOOP signal, achieves the required voltage and frequency, and supplies permanently connected loads for;;::: 5 minutes. Currently, this SR contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for Note 2 is that performing the surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

With the Division 3 - 4.16 kV emergency bus aligned to a station system auxiliary transformer, a LOOP is simulated by the use of key-operated switches that cause the Division 3 emergency switchgear to de-energize, thereby isolating the Division 3 electrical subsystem from the other two safety-related electrical subsystems. The Division 3 DG starts, re-energizes its associated emergency bus, and runs for at least 5 minutes. Since this test does not involve an ECCS initiation signal, the HPCS pump does not automatically start; however, following the 5-minute run, the HPCS pump is manually started for the purpose of performing testing in accordance with SR 3.8.1.16.

Because the HPCS system is a stand-alone system with a dedicated DG and independent electrical distribution system, there is minimal opportunity for the performance of this SR to have any impact on other safety-related plant equipment or normal plant operation.

The simulated LOOP signal is generated only at the Division 3 switchgear and does not affect the other two safety-related electrical divisions. Additionally, due to the relative size of the loads associated with the HPCS system (i.e., 2540 kW), there is minimal potential for this testing to create an offsite power supply perturbation when the Division 3 - 4.16 kV emergency bus is de-energized. Although the offsite source of power to the Division 3 emergency bus is disconnected for this test, the period of time that this condition exists is Page 10 of 20

ATTACHMENT 1 Evaluation of Proposed Change small and is acceptable since the HPCS system is already inoperable for performance of the test (see the Note to the Applicability requirements for TS 3.8.1 ). Therefore, the reasons for the mode restrictions stated in the TS Bases for SR 3.8.1.11 are not valid for the Division 3 DG.

SR 3.8.1.12 SR 3.8.1.12 requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated ECCS initiation signal, achieves the required voltage and frequency within the specified time, and operates for 2: 5 minutes. This SR currently contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for Note 2 is that performing the surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems.

This test is performed by inserting an ECCS initiation signal into the Division 3 control logic with the use of a switched jumper. With the ECCS initiation signal present, the Division 3 DG starts and runs unloaded (i.e., DG output breaker open) for 2: 5 minutes while acceptable performance parameters (voltage and frequency) are verified. Similar steps would likewise be taken when performing this test online. Following the test, restoration of all safety-related functions to operable status are independently verified.

Similar methods and procedural controls would be employed when performing the surveillance test online.

The HPCS system is a stand-alone system with a dedicated DG and independent electrical distribution system. The simulated ECCS initiation signal is generated only in the HPCS logic and does not affect the other two safety-related electrical divisions. Thus, performing the SR 3.8.1.12 test for the Division 3 DG, whether shutdown or on line, affects only the HPCS system. In addition, since this test is conducted with the Division 3 DG unloaded and isolated from its emergency bus, there is no impact to the electrical distribution system, and no mechanism for challenging continued steady state operation.

Therefore, the reasons for the mode restrictions stated in the TS Bases for SR 3.8.1.12 are not valid for the Division 3 DG.

SR 3.8.1.13 SR 3.8.1.13 requires verification that the Division 3 DG automatic trips are bypassed on an actual or simulated ECCS initiation signal, except for critical protective trip functions (engine overspeed and generator differential current). Currently, this SR contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for the Note is that performing the surveillance removes a required DG from service.

Performance of testing required per SR 3.8.1.13 in Modes 1 or 2 is justified on the basis that: ( 1) this SR is not performed with the DG paralleled to offsite power; and (2) unavailability of the DG during the conduct of this test is minimal. Unavailability of the DG mainly occurs when the DG is tripped to complete the surveillance. Availability is restored once the DG trip is reset.

Page 11 of 20

ATTACHMENT 1 Evaluation of Proposed Change Verification that the Division 3 DG automatically trips on engine overspeed and generator differential current is performed with the Division 3 DG operating unloaded and isolated from its 4.16 kV emergency bus. Manual action is required to reset the emergency trips so that the DG can then be placed in a normal standby lineup.

The HPCS system is a stand-alone system with its dedicated DG and independent distribution system. Performing the SR 3.8.1.13 tests for the Division 3 DG, whether online or shutdown, affects only the HPCS system, and there is minimal opportunity for the performance of these tests to have any impact on other safety-related plant equipment. As noted previously, the unavailability of the Division 3 DG that occurs during the conduct of these tests and the other SRs that are proposed to be performed online is well within the 14 days of inoperability that is allowed by the TS and does not challenge achievement of the administrative goal that has been established for Division 3 DG maintenance rule unavailability performance. Therefore, the reason for the mode restrictions stated in the TS Bases for SR 3.8.1.13 is not valid for the Division 3 DG.

SR 3.8.1.16 SR 3.8.1.16 requires verification that the Division 3 DG can be synchronized with the offsite power source while loaded with emergency loads, and upon a simulated restoration of offsite power, all loads are transferred to offsite power, and the DG returns to ready-to-load operation. This SR currently contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for the Note is that performing the surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

This test is typically performed following completion of the LOOP test of SR 3.8.1.11 (for aligning the Division 3 - 4.16 kV emergency bus to the system auxiliary transformer) and following completion of the LOOP/LOCA test of SR 3.8.1.19. After the Division 3 DG has started and re-energized its associated emergency bus, the HPCS pump is started and placed in the full flow or minimum flow test mode. Actual discharge of water into the reactor vessel by the HPCS system will be prevented. The Division 3 emergency bus is then paralleled to offsite power and the bus loads are transferred to the offsite power source. The DG output breaker is then tripped opened, and the DG is verified to return to ready-to-load operation.

The HPCS system is a stand-alone system with a dedicated DG and independent electrical distribution system; therefore, there is minimal opportunity for the performance.

of this SR to have any impact on other safety-related plant equipment or normal plant operation. Although the offsite source of power to the Division 3 emergency bus is disconnected at the beginning of this test, the period of time that this condition exists is small and is acceptable since the HPCS system is already inoperable for performance of the test (see the Note to the Applicability requirements for TS 3.8.1 ). Additionally, the relative size of the loads associated with the HPCS system (2540 kW) presents minimal potential for creating an offsite power supply perturbation when shifting the load between the Division 3 DG and the offsite power source. The offsite power source for the Division 3 - 4.16 kV emergency bus during the test is through a system auxiliary transformer, regardless of whether the test is performed online or during shutdown conditions. Completed test results performed during shutdown conditions have shown that the required bus voltage parameters stay within expected limits, and no anomalous Page 12 of 20

ATTACHMENT 1 Evaluation of Proposed Change actions regarding load transfer sequences occur. Conducting this test online is not expected to be more challenging to plant safety systems than performance during shutdown conditions.

Based on the above discussion, the reasons for the mode restrictions stated in the TS Bases for SR 3.8.1.16 are not valid for the Division 3 DG.

SR 3.8.1.17 SR 3.8.1.17 requires verification that, with the Division 3 DG operating in the test mode and connected to its 4.16 kV emergency bus, an actual or simulated ECCS initiation signal overrides the test mode by returning the DG to ready-to-load operation and automatically energizing the emergency loads from offsite power. This SR currently contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for the Note is that performing the surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

This test is performed by paralleling the DG in test with offsite power, similar to the existing monthly run of the DG that is conducted with the plant online. The performance of test mode override test per SR 3.8.1.17 ensures that the availability of the Division 3 DG under accident conditions is unaffected during rejection tests (i.e., SR 3.8.1.9 and SR 3.8.1.10). With the DG manually started in the test mode and paralleled to its emergency bus, an ECCS signal is inserted by arming and depressing the HPCS manual initiation pushbutton on the main control room panel. This causes the DG output breaker to open, and return of the DG to a ready-to-load condition is verified. Opening the DG output breaker separates the DG from its associated emergency bus and allows the offsite power source to continue to energize the bus. Consequently, performance of testing pursuant to SR 3.8.1.17 does not cause any significant perturbations to the electrical distribution system as the DG is separated from the bus. In addition, similar to testing performed for SR 3.8.1.9 and SR 3.8.1.10, the power system loading for this test is within the rating of the affected transformers, switchgear, and breakers. Therefore, the reasons for the mode restrictions stated in the TS Bases for SR 3.8.1.17 are not valid for the Division 3 DG.

The intent of the requirement associated with SR 3.8.1.17.b is to show that the emergency loading is not affected by DG operation in the parallel test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the AC electrical power system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. On this basis, performance of routine testing required pursuant to SR 3.8.1.17 does not required separating the Division 3 emergency bus from offsite power. Consequently, performance of this surveillance for the Division 3 DG does not require removing an offsite circuit from service, as currently indicated in the Bases for SR 3.8.1.17.

Page 13 of 20

ATTACHMENT 1 Evaluation of Proposed Change SR 3.8.1.19 SR 3.8.1.19 requires verification that the Division 3 DG automatically starts from the standby condition on an actual or simulated LOOP signal in conjunction with an actual or simulated ECCS initiation signal, achieves the required voltage and frequency within the specified time, and supplies permanently connected loads for <:: 5 minutes. This SR currently contains a Note that prohibits performance in Modes 1 or 2. The TS Bases state the reason for Note 2 is that performing the surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

A LOOP signal is simulated, causing the Division 3 switchgear to de-energize (e.g., by opening test switches simulating bus undervoltage). Following the DG start signal, an ECCS initiation signal is inserted into the Division 3 control logic (e.g., by arming and depressing the HPCS manual initiation pushbutton on the main control room panel). The Division 3 DG starts, re-energizes its associated emergency bus, and powers the HPCS pump and other permanently connected loads. For this test, the HPCS pump suction is from the suppression pool, and pump discharge is through the test return line back to the suppression pool. The HPCS system discharge pathway to the reactor vessel is isolated.

Actual discharge of water into the reactor vessel by the HPCS system is prevented during the current performance of this test during shutdown conditions in order to preclude unwanted effects on reactor vessel water level. Discharge into the reactor vessel would likewise be prevented when performing this test online to preclude unwanted effects on reactor vessel water level and core reactivity. The current method of preventing HPCS system discharge into the reactor vessel is by shutting HPCS manual isolation valve 1/2E22-F038 when performed in an outage. Following the test, restoration of all safety-related functions, including restoration of the HPCS system to operable status, are independently verified.

As previously discussed, the HPCS system is a stand-alone system with a dedicated DG and independent electrical distribution system; therefore, there is minimal impact resulting from the performance of this SR on other safety-related plant equipment. The simulated LOOP and ECCS initiation signals affect only the HPCS system and do not affect the other two safety-related electrical divisions. Although the otfsite source of power to the Division 3 emergency bus is disconnected for this test, the period of time that this condition exists is small and is acceptable since the HPCS system is already inoperable for performance of the test (see the Note to the Applicability requirements for TS 3.8.1 ).

Additionally, due to the relative size of the loads associated with the HPCS system (i.e.,

2540 kW), there is minimal potential for this testing to create an offsite power supply perturbation when the Division 3 electrical bus is de-energized. HPCS pump starts are routinely performed online to satisfy quarterly inservice testing requirements, without disturbing plant operation.

Based on the above discussion and past experience performing this test, conducting this test online is no more challenging than conducting the test while shutdown; therefore, the reasons tor the mode restrictions stated in the TS Bases for SR 3.8.1 .19 are not valid for the Division 3 DG.

Page 14 of 20

ATTACHMENT 1 Evaluation of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

General Design Criterion 17 10 CFR 50, Appendix A, General Design Criteria (GDC) 17, "Electrical Power Systems,"

requires, in part, that a nuclear power plant onsite and offsite electric power system shall be provided to permit functioning of structures, systems, and components that are important to safety. The onsite electric power system, including the batteries and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of, or coincident with, the loss of power from the onsite electric power supplies, the unit, or the offsite transmission network.

The Division 3 battery and battery chargers are physically separated from and electrically independent from all other divisional batteries and battery chargers, and interconnection with the battery chargers or the emergency DC load groups of any other division is not permitted under any conditions of plant operation.

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

The proposed TS changes affect only the operating conditions during which certain Division 3 battery testing and (HPCS) DG surveillance tests can be performed. The design or function of the emergency DG electrical power system is not affected. The evaluation of the proposed changes demonstrates that performing these surveillance tests while online will not create a transient that could cause perturbations to the LSCS electrical distribution system, disrupt power operation, or challenge plant safety systems. Therefore, the emergency DG electrical power system continues to comply with the requirements of GDC 17.

General Design Criterion 18 10 CFR 50, Appendix A, GDC 18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety be designed to permit appropriate periodic inspection and testing of important areas and features. The emergency DC electrical power system is divided into three separate and independent divisions feeding redundant safety-related electrical load groups, thereby permitting the inspection and testing of any division while the other divisions are feeding their connected loads. The proposed TS changes do not alter this inspection and testing capability.

Page 15 of 20

ATTACHMENT 1 Evaluation of Proposed Change The proposed TS changes affect only the plant operating conditions during which certain Division 3 (HPCS) DG surveillance tests can be performed. The technical evaluation of the proposed changes demonstrates that performing these surveillance tests while online will not create a transient that could cause perturbations to the LSCS electrical distribution system, disrupt power operation, or challenge plant safety systems. For these same reasons, the proposed changes do not alter LSCS's compliance the requirements of GDC 18.

Regulatory Guide 1.32 NRC Regulatory Guide (RG) 1.32, "Criteria for Power Systems for Nuclear Power Plants,"

Revision 3, March 2004, describes a method acceptable to the NRC for complying with the NRC's regulations for the design, operation, and testing of electric power systems in nuclear power plants. Specifically, it provides guidance for meeting the GDC for the safety-related portions of systems and equipment in the alternating current power systems, direct current power systems, and instrumentation and control power systems. As discussed in the LSCS UFSAR, Appendix B, LSCS is in compliance with RG 1.32, Revision 2, "Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants," dated February 1977.

Paragraph C.1.c of RG 1.32, Revision 2, endorses IEEE Standard 450-1975, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations." Exception is taken to the requirements of IEEE Standard 450-1975 for battery testing; IEEE Standard 450-1995 will be utilized to perform battery testing (Reference LSCS UFSAR 8.3.2.1.1 and UFSAR Appendix 8). The proposed changes do not alter LSCS's compliance the requirements of RG 1.32.

Regulatory Guide 1.129 NRC RG 1.129, "Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," Revision 1, February 1978, describes a method acceptable to the NRC for performing maintenance, testing, and replacement of large lead storage batteries at nuclear power plants. RG 1.129 states that the battery service test should be performed during refueling operations or at some other outage. The proposed changes do not alter LSCS's compliance the requirements of RG 1.129.

4.2 Precedent The NRC has approved similar license amendments to remove operating mode restrictions for performing Division 3 battery testing. An example includes the following:

Letter from R. V. Guzman (U.S. Nuclear Regulatory Commission) to S. L. Belcher (Nine Mile Point Nuclear Station, LLC), "Nine Mile Point Nuclear Station, Unit No. 2 -

Issuance of Amendment Regarding Removal of Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery (TAC No. ME2972)," dated January 31, 2011 (ADAMS Accession No. ML110190268)

The NRC has approved similar license amendments to remove operating mode restrictions for performing Division 3 DG surveillance testing. An example includes the following:

Page 16 of 20

ATTACHMENT 1 Evaluation of Proposed Change

Letter from R. V. Guzman (U.S. Nuclear Regulatory Commission) to S. L. Belcher (Nine Mile Point Nuclear Station, LLC), "Nine Mile Point Nuclear Station, Unit No. 2 -

Issuance of Amendment Regarding Removal of Operating Mode Restrictions for Performing High Pressure Core Spray Emergency Diesel Generator Surveillance Testing (TAC No. ME1042)," dated March 18, 2010 (ADAMS Accession No. ML100460016) 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Exelon Generation Company, LLC (EGG) requests amendments to Renewed Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2.

The proposed amendments would revise Technical Specification {TS) 3.8.4, "DC Sources-Operating," and TS 3.8.6, "Battery Parameters," by removing the Mode restrictions for performance of TS Surveillance Requirement (SR) 3.8.4.3 and SR 3.8.6.6 for the Division 3 direct current (DC) electrical power subsystem battery. The Division 3 DC electrical power subsystem feeds emergency DC loads associated with the High Pressure Core Spray (HPCS) system. SR 3.8.4.3 verifies that the battery capacity is adequate for the battery to perform its required functions. SR 3.8.6.6 verifies battery capacity is <:: 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test. The proposed amendments would remove these Mode restrictions for the Division 3 battery, allowing performance of SR 3.8.4.3 and SR 3.8.6.6 for the Division 3 battery during Mode 1 or 2, potentially minimizing impact on HPCS unavailability. Eliminating the requirement to perform SR 3.8.4.3 and SR 3.8.6.6 only during Mode 3, 4, or 5 (hot shutdown, cold shutdown, or refueling conditions) will provide greater flexibility in scheduling Division 3 battery testing activities by allowing the testing to be performed during non-outage times.

In addition, the proposed amendments would revise TS 3.8.1, "AC Sources-Operating," by revising certain SRs pertaining to the Division 3 HPCS diesel generator (DG). The Division 3 DG is an independent source of onsite alternating current (AC) power dedicated to the HPCS system. The TSs currently prohibit performing the testing required by SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.16, SR 3.8.1.17, and SR 3.8.1.19 in Modes 1 or

2. The proposed amendments would remove these Mode restrictions and allow all eight of the identified SRs to be performed in any operating Mode for the Division 3 DG.

EGG has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No.

The Division 3 HPCS DG electrical power subsystem and its associated emergency loads are accident mitigating features, not accident initiators. Therefore, the proposed TS changes to allow the performance of certain Division 3 AC Sources surveillance Page 17 of 20

ATTACHMENT 1 Evaluation of Proposed Change testing in any plant operating Mode will not significantly impact the probability of any previously evaluated accident.

The design and function of plant equipment is not being modified by the proposed changes. Neither the battery test frequency nor the time that the TSs allow the HPCS system to be inoperable are being revised. Battery testing in accordance with the proposed TS changes will continue to verify that the Division 3 DC electrical power subsystem is capable of performing its required function of providing DC power to HPCS system equipment, consistent with the plant safety analyses. The battery testing will occur during a planned HPCS outage and therefore will not result in an increase in risk above the current work practices of planned HPCS system maintenance outages. Any risk associated with the testing of the Division 3 battery will be bounded and addressed with the risk associated with the HPCS system outage. In addition, the HPCS system reliability and availability are monitored and evaluated in relationship to Maintenance Rule goals to ensure that total outage times do not degrade operational safety over time.

Testing is limited to only one electrical division of equipment at a time to ensure that design basis requirements are met. Should a fault occur while testing the Division 3 battery, there would be no significant impact on any accident consequences since the other two divisional DC electrical power subsystems and their associated emergency loads would be available to provide the minimum safety functions necessary to shut down the unit and maintain it in a safety shutdown condition.

The Division 3 HPCS DG and its associated emergency loads are accident mitigating features, not accident initiators. Therefore, the proposed TS changes to allow the performance of Division 3 DG surveillance testing in any plant operating mode will not significantly impact the probability of any previously evaluated accident.

The design of plant equipment is not being modified by the proposed changes. As such, the ability of the Division 3 DG to respond to a design basis accident will not be adversely impacted by the proposed changes. The proposed changes to the TS surveillance testing requirements for the Division 3 DG do not affect the operability requirements for the DG, as verification of such operability will continue to be performed as required. Continued verification of operability supports the capability of the Division 3 DG to perform its required function of providing emergency power to HPCS system equipment, consistent with the plant safety analyses. Limiting testing to only one DG at a time ensures that design basis requirements are met. Should a fault occur while testing the Division 3 DG, there would be no significant impact on any accident consequences since the other two divisional DGs and associated emergency loads would be available to provide the minimum safety functions necessary to shut down the unit and maintain it in a safe shutdown condition.

Therefore, the proposed change does not result in a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

Page 18 of 20

ATTACHMENT 1 Evaluation of Proposed Change No changes are being made to the plant that would introduce any new accident causal mechanisms. Equipment will be operated in the same configuration with the exception of the plant operating mode in which the Division 3 battery and DG surveillance testing are conducted. Performance of these surveillance tests while online will continue to verify operability of the Division 3 battery and DG. The battery testing will potentially minimize the out-of-service time for the HPCS system. The proposed amendments do not impact any plant systems that are accident initiators and do not adversely impact any accident mitigating systems.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed changes do not involve a significant reduction in the margin of safety.

Margin of safety is related to confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system, and primary containment) to perform their design functions during and following postulated accidents. The proposed changes to the TS surveillance testing requirements for the Division 3 AC Sources and DG do not affect the operability requirements, as verification of such operability will continue to be performed as required . Continued verification of operability supports the capability of the Division 3 AC Sources and DG to perform the required functions of providing emergency power to HPCS system equipment, consistent with the plant safety analyses.

Consequently, the performance of the fission product barriers will not be adversely impacted by implementation of the proposed amendments. In addition, the proposed changes do not alter setpoints or limits established or assumed by the accident analysis.

The additional online unavailability of the HPCS system does not constitute a significant reduction in a margin of safety. The battery testing will be performed when the HPCS system is already out of service for a planned system outage and therefore the testing will not result in an increase in risk above the current work practices of planned system maintenance outages, as currently allowed by the TS.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendments do 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.

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

Page 19 of 20

ATTACHMENT 1 Evaluation of Proposed Change

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendments would change a requirement with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

Page 20 of 20

ATTACHMENT 2 Markup of Technical Specifications Pages LASALLE COUNTY STATION UNITS 1AND2 Docket Nos. 50-373 and 50-374 Renewed Facility Operating License Nos. NPF-11 and NPF-18 TS Page 3.8.1-10 TS Page 3.8.1-11 TS Page 3.8.1-12 TS Page 3.8.1-13 TS Page 3.8.1-14 TS Page 3.8.1-15 TS Page 3.8.1-16 TS Page 3.8.1-17 TS Page 3.8.1-18 TS Page 3.8.4-5 TS Page 3.8.6-5

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SUR VE I LLANCE FREQUENCY SR 3.8.1.9 - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - - - (not applicable

1. This Surveillance shall no ormally Division 3 DG) be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

2. A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.

Verify each required DG rejects a load In accordance greater than or equal to its associated with the single largest post-accident load and Surveillance following load rejection, the frequency is Frequency

66.7 Hz. Control Program SR 3.8.1.10 - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - - - -

1. This Surveillance shall no normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

2. A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.

Verify each required DG does not trip and In accordance voltage is maintained ::; 5000 V during and with the following a load rejection of a load Surveillance

~ 2600 kW. Frequency Control Program (continued)

LaSalle 1 and 2 3.8.1-10 Amendment No. 200/187

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.11 - - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - -

1. All DG starts may be preceded by an engine prelube period.

~----1--1 (not applicable

2. This Surveillance shall not ormally Division 3 <)

be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of In accordance offsite power signal: with the Surveillance

a. De-energization of emergency buses; Frequency Control Program

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in $ 13 seconds,

2. energizes auto-connected shutdown loads,

3. maintains steady state voltage

~ 4010 V and$ 4310 V,

4. maintains steady state frequency

~ 58.8 Hz and$ 61.2 Hz, and

5. supplies permanently connected and auto-connected shutdown loads for

~ 5 minutes.

(continued)

LaSalle 1 and 2 3.8.1-11 Amendment No. 200/187

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.12 - - - - - - - - - - - - - - - - - - - NOTES - - - - - - - - - - - - - - - - - - -

1. All DG starts may be preceded by an engine prelube period.

,------i---1 (not applicable to

2. This Surveillance shall no~IJi ormally Division3DG) be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Emergency In accordance Core Cooling System (ECCS) initiation with the signal each required DG auto-starts from Surveillance standby condition and: Frequency Control Program

a. In $ 13 seconds after auto-start, achieves voltage 2 4010 V and frequency 2 58.8 Hz;

b. Achieves steady state voltage 2 4010 V and $ 4310 V and frequency 2 58.8 Hz and $ 61.2 Hz; and

c. Operates for 2 5 minutes.

(continued)

LaSalle 1 and 2 3.8.1-12 Amendment No. 200/187

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.13 - n-_ b-_

(not applicable to

~~~ ~ s~~~~~ l l ~~~~- ~~~~~~~._--~-- ~-~-~-~-l-l-~-- ~---_-_-_-i--1Division 3 DG) performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each required DG's automatic trips In accordance are bypassed on an actual or simulated ECCS with the initiation signal except: Surveillance Frequency

a. Engine overspeed; and Control Program

b. Generator differential current.

(continued)

LaSalle 1 and 2 3.8.1-13 Amendment No. 200/187

INo changes on this page -- Provided for information only AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.14 - - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - -

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2 unless the other two DGs are OPERABLE. If either of the other two DGs becomes inoperable, this Surveillance shall be suspended. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

3. If grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.

4. A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.

Verify each required DG operating within In accordance the power factor limit operates for with the

<': 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: Surveillance Frequency

a. For<':: 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded<':: 2860 kW; and Control Program

b. For the remaining hours of the test loaded <': 2400 kW and ~ 2600 kW.

(continued)

LaSalle 1 and 2 3.8.1-14 Amendment No. 200/187

!No changes on this page -- Provided for information only AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SU RV EI LLANCE FREQUENCY SR 3.8.1.15 - - - - - - - - - - - - - - - - - - -NOTES- - - - - - - - - - - - - - - - - - -

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 2400 kW and ~ 2600 kW.

Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

3. A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.

Verify each required DG starts and In accordance achieves: with the Surveillance

a. In~ 13 seconds, voltage~ 4010 V and Frequency frequency ~ 58.8 Hz; and Control Program

b. Steady state voltage~ 4010 V and

~ 4310 V and frequency ~ 58.8 Hz and~ 61.2 Hz.

(continued)

LaSalle 1 and 2 3.8.1-15 Amendment No. 200/187

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY (not applicable to SR 3.8.1.16 - 11 - _

~~i ~ s~~~~i ~~~~ ~~~ii~i,..._-~--n-- ~-~-~-~-1-1_; b- ~---_-_-_--t--1Division 3 DG) performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each required DG: In accordance with the

a. Synchronizes with offsite power source Surveillance while loaded with emergency loads upon Frequency a simulated restoration of offsite Control Program power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation.

(continued)

LaSalle 1 and 2 3.8.1-16 Amendment No. 200/187

AC Sources-Operating 3.8.l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY (not applicable to SR 3.8.1.17

~h~ ~ -s~~~~~ 11 ~~~~ - 0

~~~i~~i~--~---~--~-~-~-,-,-;--b- ~--------Division 3 DG) performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify, with a required DG operating in In accordance test mode and connected to its bus: with the Surveillance

a. For Division 1 and 2 DGs, an actual or Frequency simulated ECCS initiation signal Control Program overrides the test mode by returning DG to ready-to-load operation; and

b. For Division 3 DG, an actual or simulated DG overcurrent trip signal automatically disconnects the offsite power source while the DG continues to supply normal loads.

SR 3.8.1.18 - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - -

This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load In accordance block, for Division 1 and 2 DGs only, is with the

~ 90% of the design interval for each time Surveillance delay relay. Frequency Contro 1 Program (continued)

LaSalle 1 and 2 3.8.1-17 Amendment No. 200/187

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.19 - - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - -

1. All DG starts may be preceded by an engine prelube period.

r------+-i (not applicable to

2. This Survei l lance shall no ormally Division 3 DG) be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify, on an actual or simulated loss of In accordance offsite power signal in conjunction with an with the actual or simulated ECCS initiation signal: Surveillance Frequency

a. De-energization of emergency buses; Control Program

b. Load shedding from emergency buses for Divisions 1 and 2 only; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in ~ 13 seconds,

2. energizes auto-connected emergency loads including through time delay relays, where applicable,

3. maintains steady state voltage

~ 4010 V and~ 4310 V,

4. maintains steady state frequency

~ 58.8 Hz and~ 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for

~ 5 minutes.

(continued)

LaSalle 1 and 2 3.8.1-18 Amendment No. 200/187

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.3 - - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - -

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

2. This Surveillance shall not normally be performed in MODE 1 or 2 for the 125 VDC batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to I[\

supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery In accordance service test. with the Surveillance Frequency Control Program SR 3.8.4.4 - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - -

When the opposite unit is in MODE 4 or 5, or moving irradiated fuel in the secondary containment, the following opposite unit SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

For the opposite unit Division 2 DC In accordance electrical power subsystem, the SRs of the with applicable opposite unit Specification 3.8.4 are SRs applicable.

LaSalle 1 and 2 3.8.4-5 Amendment No. 200/187

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.6 - - - - - - - - - - - - - - - - - - NOTES- - - - - -,_-_-_- -_-_-_- -_-_-_- -_-_- -t-!lli~o6i~:~~~~le I

1. This Surveillance shall n t normally be performed in MODE 1 or 2 or the 125 VDC batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2. In MODE 1, 2 or 3, and the opposite unit In accordance in MODE 4 or 5, or moving irradiated with the fuel in the secondary containment, this Surveillance Surveillance is not required to be Frequency performed for the opposite unit Division Control Program 2 DC electrical power subsystem.

3. In MODE 4, 5 or during movement of irradiated fuel in the secondary 12 months when containment in Mode 4, 5 or defueled, battery shows this Surveillance is not required to be degradation or performed. has reached 85%

of expected life with Verify battery capacity is 2 80% of the capacity manufacturer's rating when subjected to a < 100% of performance discharge test or a modified manufacturer's performance discharge test. rating 24 months when battery has reached 85% of the expected 1 ife with capacity 2 100% of manufacturer's rating LaSalle 1 and 2 3.8.6-5 Amendment No. 200/187

ATTACHMENT 3 Markup of Affected TS Bases Pages (For Information Only)

LASALLE COUNTY STATION UNITS 1AND2 Docket Nos. 50-373 and 50-374 Renewed Facility Operating License Nos. NPF-11 and NPF-18 Page B 3.8.1-28 Page B 3.8.1-29 Page B 3.8.1-30 Page B 3.8.1-31 Page B 3.8.1-32 Page B 3.8.1-33 Page B 3.8.1-34 Page B 3.8.1-35 Page B 3.8.1-36 Page B 3.8.1-37 Page B 3.8.1-38 Page B 3.8.1-39 Page B 3.8.1-40 Page B 3.8.1-41 Page B 3.8.1-42 Page B 3.8.1-43 Page B 3.8.4-11 Page B 3.8.4-12 Page B 3.8.6-9

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued)

REQUIREMENTS response characteristics and capability to reject the largest single load without exceeding predetermined frequency and while maintaining a specified margin to the overspeed trip. The load referenced for the Division 1 DG is the 1190 kW low pressure core spray pump; for the Division 2 DG, the 638 kW residual heat removal ( RHR) pump; and for the Division 3 DG the 2421 kW HPCS pump. This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test is acceptable if the diesel speed does not exceed 75% of the difference between nominal speed and the overspeed trip setpoint, or 15% above nominal speed, whichever is lower. This corresponds to 66.7 Hz, which is the nominal speed plus 75 % of the difference between nominal speed and the overspeed trip setpoint. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by two Notes. The reason for Note (Note 1 is not 1 is that during operation with the reactor critical, applicable to the erformance of this SR could cause perturbations to the electrical distribution systems that could challenge Division 3 DG) continued st y state operation and, as a result, plant safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a (continued)

LaSalle 1 and 2 B 3.8.1-28 Revision -5+

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued)

REQUIREMENTS successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR. To minimize testing of the common DG, Note 2 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.10 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, this Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits. The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions.

This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load.

These acceptance criteria provide DG damage protection.

While the DG is not expected to experience this transient during an event, and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

LaSalle 1 and 2 B 3.8.1-29 Revision 51

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 (continued)

REQUIREMENTS This SR has been modified by two Notes. The reason for Note

~(-N-o-te~1-i_s_n_o_t~~-. 1 is that during operation with the reactor critical, erformance of this SR could cause perturbations to the applicable to the electrical di tri buti on systems that could challenge

_D_i_v_is_io_n~3_D_G~)~~ continued st y state operation and, as a result, plant safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consiser the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR. To minimize testing of the common DG, Note 2 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.11 Consistent with Regulatory Guide 1.9 (Ref. 3),

paragraph C.2.2.4, this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including (continued)

LaSalle 1 and 2 B 3.8.1-30 Revision 42-

INo changes on this page -- Provided for information only AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS shedding of the nonessential loads (Divisions 1 and 2 only) and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG auto-start and energization of permanently connected loads time of 13 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA (Ref. 5). The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanently connected loads and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.

For instance, ECCS injection valves are not desired to be stroked open, systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. The prelube period shall be consistent with manufacturer recommendations. For the purpose of this testing, the DGs must be started from normal standby conditions, that is, with the engine jacket water and lube oil being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. The reason for Note 2 is (continued)

LaSalle 1 and 2 B 3.8.1-31 Revision 51

AC Sources-Operating B 3.8.1 BASES

- - - - - - - - - - - - - - - - - - - - - - 1 (Note 2 is not applicable to the SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS Division 3 DG) that performing the Surveillance would remove a requir offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.5, this Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (13 seconds) from the design basis actuation signal (LOCA signal). In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved. The voltage and frequency limits are normally achieved within 13 seconds.

The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The DG is required to operate for

~ 5 minutes. The 5 minute period provides sufficient time to demonstrate stability.

(continued)

LaSalle 1 and 2 B 3.8.1-32 Revision~

AC Sources-Operating B 3.8.l BASES SURVEILLANCE SR 3.8.1.12 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. The prelube period shall be consistent with manufacturer recommendations. For the purpose of this testing, the DGs must be started from normal standby conditions, that is, with the engine jacket water and lube oil being continuously circulated and temperature is being maintained consistent (Note 2 is not with manufacturer recommendations. The reason for Note 2 is that during o eration with the reactor critical, erformance applicable to the of this SR could cause perturbations to the electrical Division 3 distribution systems that could challenge continued s ady state operation and, as a result, plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

(continued)

LaSalle 1 and 2 B 3.8.1-33 Revision 5+

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.13 REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 3) paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ECCS initiation test signal and critical protective functions (engine overspeed and generator differential current) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the OBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The Surveillance Frequency is controlled under the ance Frequency Control Program.

is modified by a Note. The reason for the Note is forming the Surveillance removes a required DG from This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

(continued)

LaSalle 1 and 2 B 3.8.1-34 Revision -s+

INo changes on this page -- Provided for information only AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 3),

paragraph C.2.2.9, this Surveillance requires demonstration that the DGs can start and run continuously near full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of which is at a load equivalent to 92% and 100% of the continuous rating of the DG, and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of which is at a load between the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating and the 7 day rating of the DG. The DG starts for this Surveillance can be performed either from normal 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 conditions that bound all credible design basis events, testing must be performed at a power factor as close to the accident load power factor as practicable. The accident kVAR load defines the power factor limit in the isochronous mode. Based on this relationship, if the reactive power (kVAR) level for the DG is maintained above the calculated accident load limiting value while the real power (kW) is maintained within a specified 90 to 100% operating band during the 22-hour surveillance period, the power factor limit will be met. During the 2- hour period that the DG is operated

2860 kW, the power factor limit will be restricted by the DG overload ratings. Continuous operation of the DG above the overload rating will accelerate wear and may negatively impact the machine's reliability and result in more frequent teardown inspections.

The DG 2-hour overload limit within any 24-hour period allows up to 3420 kVA of apparent power. This kVA limit is based on values of 2860 kW (DG 24-hour rated limit) and 1876 kVAR (Operations kVAR loading limit with DG at 2860 kW). Therefore, the kVAR output of the DG during the 2-hour overload period should be maintained at a level that will ensure that the 3420 kVA limit is not exceeded. The established 3420 kVA value is slightly less than the generator manufacturers rating limit to provide margin for operating tolerances. The specific power factor limit for the emergency diesel generators is contained in the design basis loading calculations and varies for each particular DG. The kW and kVAR operating bands provided in the DG operating surveillances for performance of the 24-hour (continued)

LaSalle 1 and 2 B 3.8.1-35 Revision 42

!No changes on this page -- Provided for information only AC Sources-Operating B 3.8.1 BASES SU RV EI LLANCE SR 3.8.1.14 (continued)

REQUIREMENTS endurance tests envelope the accident kVAR load and therefore, the power factor requirements. This power factor is chosen to bound the actual worst case inductive loading that the DG could experience under design basis accident conditions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This Surveillance is modified by four Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Similarly, momentary power factor transients above the limit do not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. However, it is acceptable to perform this SR in MODES 1 and 2 provided the other two DGs are OPERABLE, since a perturbation can only affect one divisional DG. If during performance of this SR one of the other DGs becomes inoperable, this Surveillance is to be suspended. In addition, this restriction from normally performing the Surveillance in MODE 1 or 2 with any of the remaining two DGs inoperable is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant (continued)

LaSalle 1 and 2 B 3.8.1-36 Revision 51

!No changes on this page -- Provided for information only AC Sources-Operating B 3.8.l BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2 with any of the remaining two DGs inoperable . Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR. Note 3 is provided in recognition that under certain conditions, it is necessary to allow the surveillance to be conducted at a power factor other than the specified limit. During the Surveillance, the DG is normally operated paralleled to the grid, which is not the configuration when the DG is performing its safety function following a loss of offsite power (with or without a LOCA). Given the parallel configuration to the grid during the Surveillance, the grid voltage may be such that the DG field excitation level needed to obtain the -specified power factor could result in a transient voltage within the DG windings higher than the recommended values if the DG output breaker were to trip during the Surveillance.

Therefore, the power factor shall be maintained as close as practicable to the specified limit while still ensuring that if the DG output breaker were to trip during the Surveillance that the maximum DG winding voltage would not be exceeded. To minimize testing of the common DG, Note 4 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.15 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 13 seconds. The 13 second time is derived from the requirements of the accident analysis for responding to a design basis large break LOCA (Ref. 5). In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved. The voltage and frequency limits are normally achieved within (continued)

LaSalle 1 and 2 B 3.8.1-37 Revision 42

!No changes on this page -- Provided for information only AC Sources-Operating B 3.8.l BASES SURVEILLANCE SR 3.8.1.15 (continued)

REQUIREMENTS 13 seconds. The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by three Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot.

The requirement that the diesel has operated for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at 92% to 100% of full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing. The prelube period shall be consistent with manufacturer recommendations. To minimize testing of the common DG, Note 3 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.16 Consistent with Regulatory Guide 1.9 (Ref. 3),

paragraph C.2.2.11, this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the auto-start logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in (continued)

LaSalle 1 and 2 B 3.8.1-38 Rev i sion 51

AC Sources-Operating B 3.8.l BASES SURVEILLANCE SR 3.8.1.16 (continued)

REQUIREMENTS ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the individual load time delay relays are reset.

(The Note is not The Survei 11 ance Frequency is cont applicable to the Survei 11 ance Frequency Control Pro Division 3 DG)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a require offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.17 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.13, demonstration of the parallel test mode override ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the Divisions 1 and 2 DGs to automatically reset to ready-to-load operation if an ECCS initiation signal is received during operation in the test (continued)

LaSalle 1 and 2 B 3.8.1-39 Revision M

AC Sources-Operating B 3.8.l BASES SURVEILLANCE SR 3.8.1.17 (continued)

REQUIREMENTS mode. Ready-to - load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

These provisions for automatic switchover are required by IEEE-308 (Ref. 11), paragraph 6.2.6(2).

The Division 3 DG overcurrent trip of the SAT feeder breaker to the respective Division 3 emergency bus demonstrates the ability of the Division 3 DG to remain connected to the emergency bus and supplying the necessary loads.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(The Note is not This SR has been modified by a Note. The reason for the applicable to the Note is that performing the Surveillance would remove a requi d offsite circuit from service, perturb the Division 3 DG) electr al distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, def i cient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety i s maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients asso ciated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

(continued)

LaSalle 1 and 2 B 3.8.1-40 Revision 1-

jNo changes on this page -- Provided for information only AC Sources-Operatin g B 3.8.l BASES SURVEILLANCE SR 3.8.1.18 REQUIREMENTS (continued) Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the individual time delay relays. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents.

The -10% load sequence time interval limit ensures that a sufficient time interval exists for the DG to restore frequency and voltage prior to applying the next load.

There is no upper limit for the load sequence time interval since, for a single load interval (i.e., the time between two load blocks), the capability of the DG to restore frequency and voltage prior to applying the second load is not negatively affected by a longer than designed load interval, and if there are additional load blocks (i.e., the design includes multiple load intervals), then the lower limit requirements (-10%) will ensure that sufficient time exists for the DG to restore frequency and voltage prior to applying the remaining load blocks (i.e., all load intervals must be~ 90% of the design interval). Reference 2 provides a summary of the automatic loading of emergency buses.

Since only the Division 1 and 2 DGs have more than one load block, this SR is only applicable to these DGs.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance during these MODES would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shal l , as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a (continued)

LaSalle 1 and 2 B 3.8.1-41 Revision 51

INo changes on this page -- Provided for information only AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.18 (continued)

REQUIREMENTS perturbation of the offsite or onsite system when they are tied together or operated independentl y for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Survei l lance are performed in MODE 1 or 2.

Risk insights or deterministi c methods may be used for thi s assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. The prelube period shall be consistent with manufacturer recommendations. For the purpose of this testing, the DGs must be started from normal standby conditions, that is, with the engine jacket water and lube oil being continuously circulated and temperatu re is being maintained consistent (continued)

LaSalle 1 and 2 B 3.8.1-42 Revision 51

AC Sources-Operating B 3.8.l BASES

- - - - - - - - - - - - - - - - - - - - - - - 1(Note 2 is not applicable to the --

SURVEILLANCE SR 3.8.1.19 (continued) Division 3 DG)

REQUIREMENTS with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical , 1 distribution system, and challenge plant safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to all ow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns ) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 This Surveillance demonstrates that the unit DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper frequency and voltage within the specified time when the unit DGs are started simultaneously.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

LaSalle 1 and 2 B 3.8.1-43 Revision -5+

jNo changes on this page -- Provided for information only DC Sources-Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.2 (continued)

REQUIREMENTS The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur).

This level of loading may not be normally available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current.

The battery is recharged when the measured charging current is s 2 amps.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.4.3 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test. This substitution is acceptable because a modified performance discharge test represents a more severe test of battery capacity than SR 3.8.4.3. The reason for Note 2 is that performing the Surveillance would remove a required 125 VDC electrical power subsystem from service, (continued)

LaSalle 1 and 2 B 3.8.4-11 Revision 51

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.3 (continued)

REQUIREMENTS perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillanc in MODE 1 or 2 is further amplified to The Division 3 test allow portions f the Surveillance to be performed for the may be performed purpose of ree tablishing OPERABILITY (e.g., post work testing follow ng corrective maintenance, corrective in MODE 1 or 2 in mo 1 1cat1on, deficient or incomplete surveillance testing, conjunction with and other unanticipated OPERABILITY concerns) provided an HPCS system assessment determines plant safety is maintained or outages. enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2.

Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy the Surveillance.

SR 3.8.4.4 With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.4.1 through 3.8.4.3) are applied to the given unit DC sources. This Surveillance is provided to direct that appropriate Surveillances for the required opposite unit DC source are governed by the applicable opposite unit Technical Specifications. Performance of the applicable opposite unit Surveillances will satisfy the opposite unit requirements as well as satisfy the given unit Surveillance Requirement.

The Frequency required by the applicable opposite unit SR also governs performance of that SR f or the given unit.

(continued)

LaSalle 1 and 2 B 3.8.4.-12 Revision 'H

Battery Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.6 (continued)

REQUIREMENTS The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 4) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer' s rating, sin ce IEEE-485 (Ref. 5) recommends using an aging factor of 125%

in the battery sizing calculation. A capacity of 80 % shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this 80% limit. If an aging factor other than 125% is used, the minimum capacity should be adjusted accordingly.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer s rating, the Surveillance Frequency is reduced to 12 months.

However, if the battery shows no degradation but has reached 85% of its expe cted life, the Surveillance Frequen cy is onl y reduced to 24 months for batteries that retain capacity ~

100% of the manufacturers rating. Degradation is indicated, consistent with IEEE-450 (Ref. 4), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is~ 10% below the manufacturers rating. The 12 month and 60 month Frequencies are consistent with the recommendations in IEEE-450

( Ref. 4).

This SR is modified by three Notes. The reason for the first Note is that performing the Surveillance would remove a required 125 voe electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillan e in MODE 1 or 2 is further amplified to The Division 3 test allow portions of the Surveillance to be performed for the may be performed purpo se of ree tablishing OPERABILITY (e.g., post work testing foll o ing corrective maintenance, corrective in MODE 1 or 2 in modification, deficient or incomplete surveillance testing, conjunction with and other unanticipated OPERABILITY concerns) provided an HPCS system assessment determines plant safety is maintained or outages. enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed (continued)

LaSalle 1 and 2 B 3.8.6-9 Revision -5+

ATTACHMENT 4 One-Line Diagram Station Auxiliary Power LASALLE COUNTY STATION UNITS 1AND2 Docket Nos. 50-373 and 50-374 Renewed Facility Operating License Nos. NPF-11 and NPF-18 1 page follows UFSAR Figure 8.1-2

LSCS-UFSAR NOTES:

KICKAPOO MAlON CREEK 1118 {i) es WA 'J45f<</t99.2KY-8.9KV/l98KV WYE-4. f et<<fl.<<1 Wr'E-1112 4.16KV DELTA 3t SVS. AUX. TR., X(8.9KY) JeMVA.

Y(4.16KV) 29 UVA; IMPED. ON 39 tNA BASE:

71T 138 KY Bua H-X 12.79. H-Y 18.75X, X-Y 28X. 2x2l\X SRAIDWQOO 8RAIDWOOO TAPS JN ntE 345KV WINOlNG.

T ""

TR (1)

PIM)

I

@es WA 2l.7KV-6.91CV/3.98KV-4.19KY/2.4KY 341 UNIT NJX.

81 POWER lR. X{&.9KV) 36 WA. Y(4.1GKV) 29 WA; IMPED. OH 39 'flVA BASE: H-X 14.M, H-Y 19.9, X-Y 33.SX. 2x2~ TAPS IN 23.7f(tl WINDING.

12~Sltt Q) 91 WA. HR AMP 8.9KV CIRCUIT BREN<ER.

@2Y& KW, 325fJ VYA DIESEL DRIVEN GENERATOR 0.8 P.r., 4..1 IS KV.

350 MVA, 3018 NAP 4 KV CIRCUIT BREN<ER.

11

~ 350 MVA. 1280 NM' 4 KV CIRCUIT BR£N<ER.

300 MVA AUTO lRANSA:>RMER.

....M . .

111f2£Y'lv YIYlRIZf lASALl.£ COUNTY STATION UPOArED F1NotL WllY NW.YSIS RIPORF' mlM£ a.1-2 4 KY 'til':l"i' OME-LJNE DIN3IWf 241-1 241-Y STmoN AUXJWRV POWER REV. 29, APRIL 2114

RS-18-028, License Amendment Request to Remove Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery and High Pressure Core Spray Diesel Generator

Contents

Text

Subject:

SUBJECT:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

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RS-18-028, License Amendment Request to Remove Operating Mode Restrictions for Performing Surveillance Testing of the Division 3 Battery and High Pressure Core Spray Diesel Generator

Text

Subject:

SUBJECT:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

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