ML20024J489

Summary of 940922 Meeting W/Nrc Staff & Util in Rockville, MD Re Request to Discuss Diesel Generator Surveillance Requirements When 1 Out of 8 Diesels at (BFN) Had Been Removed from Svc for Preventive Maint.Attendance List Encl

ML20024J489
Person / Time
Site:	Browns Ferry
Issue date:	10/07/1994
From:	Williams J Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9410180309
Download: ML20024J489 (30)

Text

{{#Wiki_filter:- 1 s pa nscg e .Ti S UNITED STATES (( d![tj NUCLEAR REGULATORY COMMISSION '"g WASHINGTON, D.C. 20565-0001 %...../ October 7, 1994 LICENSEE: Tennessee Valley Authority (TVA) FACILITY: Browns Ferry Nuclear Plant, Units 1, 2, and 3

SUMMARY

OF THE SEPTEMBER 22, 1994 MEETING WITH THE TENNESSEE VALLEY AUTHORITY REGARDING DIESEL GENERATOR SURVEILLANCE REQUIREMENTS AT THE BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 A meeting was held on September 22, 1994 in Rockville, Maryland, between representatives of the NRC staff and the Tennessee Valley Authority (TVA). The meeting was held at TVA's request to discuss diesel generator surveillance requirements when one of the eight diesels at the Browns Ferry Nuclear Plant (BFN) is removed from service for preventive maintenance. Meeting attendees are listed in Enclosure 1. A copy of the handout provided by TVA is given in. BFN Unit 2 has been operating at power while TVA was performing biennial maintenance on BFN diesel generators. Units I and 3 are shut down pending completion of modifications and other corrective actions. The BFN resident inspectors questioned TVA's interpretation of surveillance requirement 4.9.B.3 of the BFN Unit 2 Technical Specifications, which states: When one of the units I and 2 diesel generators is found to be INOPERABLE, all of the remaining diesel generators shall be demonstrated to be OPERABLE within 24 hours, and power availability for the associated boards shall be verified within I hour and at least once per 8 hours thereafter. TVA has interpreted this requirement as not being applicable if a diesel generator is deliberately made inoperable due to preventive maintenance activities. The resident inspectors contacted the NRR technical staff through the Project Manager to discuss TVA's interpretation. The primary concern of the inspectors was the failure to perform power alignment checks when a diesel generator was removed from service. Initial staff feedback was based on a review of TS 4.9.B.3 and the safety evaluation, dated August 19, 1988, which accepted the current specification wording. This review concluded that there was no information suggesting the staff had made any distinction regarding the circumstances of diesel generator operability, whether for preventive or corrective maintenance. Therefore, operability testing of the diesel generators would be expected when preventive maintenance is being performed. The resident inspectors provided this feedback to TVA, which then committed to testing the other diesel generators and performing power availability verification pending an opportunity to discuss this issue in greater detail with the staff. This meeting provided that opportunity. TVA opened by stating the NRC and TVA share a common goal in maximizing diesel generator availability and operability, and that TVA believes that their current surveillance and testing practices have led to high diesel generator reliability. TVA stated that it recognized that the phrasing of TS 4.9.B.3 is n 9410180309 941007 PDR ADOCK 05000259 Ik P PDR

_ -- s not consistent with standard wording, and that it would submit a license amendment request to clarify the diesel generator surveillance requirements. After describing the BFN electrical power distribution system, TVA noted the current diesel generator reliability and availability are high. TVA is concerned that unnecessary testing of diesel generators could reduce their performance, creating a reliability problem because of the extra wear and tear. TVA reviewed the current diesel generator maintenance and testing scheduie. This schedule had been questioned by the staff, since the biennial schedule would permit maintenance to be performed during a refueling outage. TVA admitted that the biennial maintenance could be coordinated with a refeling outage if only one reactor is operating, as is currently the case.

However, when more than one unit is operating, TVA does not expect there will be an outage window which would accomodate this activity without affecting an operating reactor.

TVA provided a review of other technical specifications in an effort to demonstrate consistency in their interpretation of the requirements of TS 4.9.B.3. Several specifications use the phrase "is made IN0PERABLE" or "is made or found to be inoperable," while other specifications are limited to "is found to be INOPERABLE" similar to TS 4.9.B.3. These phrases date to the original BFN technical specifications. It is TVA's view that when a distinction needed to be made between "made" and "found," it was done so, therefore, TS 4.9.B.3 should not be interpreted to require operability testing unless a diesel generator is "found" inoperable. TVA does not believe that testing is required when a diesel generator is "made" inoperable for preventive maintenance. TVA stated that preventive maintenance does not create a common-mode failure; therefore, starting the other diesel generators is not required. TVA agreed that verification of breaker alignment and power supply availability is desirable when a diesel generator is removed from service for maintenance, even though TVA does not believe the current TS 4.9.B.3 requires this action. TVA committed to perform this verification for future diesel generator maintenance outages. As noted above, TVA also committed to submit a license amendment request to clarify the TS 4.9.B.3 requirements. TVA stated it expects to submit this request in October 1994. Original signed by Joseph F. Williams, Project Manager Project Directorate 11-4 Division of Reactor Projects - I/II Docket Nos. 50-259, 50-260 and 50-296

Enclosures:

1. Attendance List 2. TVA Handout cc w/ enclosures: See next page DOCUMENT NAME: G:\\BFN\\DGMTG. SUM T3 receive a copy of this docunont, Indicate in the tanu "C" = Copy without attachment / enclosure "E" e Copy with ettschment/ enclosure "N" a No copy / OFFICE PDII-#14 @ ) l6 PDII-4/PM //f l 6 PDII-4/D C l NAME BClani>F JWilliams?" FHebdon 4)- DATE dl /d/94 9 / 11 /94 m / 7' /94 0FFICIAL RECORD COPY

3 BROWNS FERRY NUCLEAR PLANT cc: General Counsel Mr. Craven Crowell, Chairman Tennessee Valley Authority Tennessee Valley Authority ET 11H ET 12A '400 West Summit Hill Drive 400 West Summit Hill Drive Knoxville, TN 37902 Knoxville, TN 37902 Mr. Roger W. Huston, Manager Mr. W. H. Kennoy, Director Nuclear Licensing and Tennessee Valley Authority Regulatory Affairs ET 12A Tennessee Valley Authority. 400 West Summit Hill Drive 4G Blue Ridge Knoxville, TN 37902 1101 Market Street Chattanooga, TN 37402-2801 Mr. Johnny H. Hayes, Director Tennessee Valley Authority Mr. T. D. Shriver ET 12A Nuclear Assurance and Licensing 400 West Summit Hill Drive Browns Ferry Nuclear Plant Knoxville, TN 37902 Tennessee Valley Authority P.O. Box 2000 Mr. Oliver D. Kingsley, Jr. Decatur, AL 35602 President, TVA Nuclear and Chief Nuclear Officer Mr. Pedro Salas Tennessee Valley Authority Site Licensing Manager 6A Lookout Place Browns Ferry Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, Tennessee 37402-2801 P.O. Box 2000 Decatur, AL 35602 Mr. O. J. Zeringue, Sr. Vice President i Nuclear Operations TVA Representative Tennessee Valley Authority Tennessee Valley Authority 3B Lookout Place 11921 Rockville Pike, Suite 402 1101 Market Street Rockville, MD 20852 Chattanooga, TN 37402-2801 Regional Administrator Dr. Mark 0. Medford, Vice President U.S. Nuclear Regulatory Commission Engineering & Technical Services Region 11 Tennessee Valley Authority 101 Marietta Street, NW., Suite 2900 1 3B Lookout Place Atlanta, GA 30323 1101 Market Street Chattanooga, TN 37402-2801 Mr. Leonard D. Wert Senior Resident Inspector Mr. D. E. Nunn, Vice President Browns Ferry Nuclear Plant New Plant Completion U.S. Nuclear Regulatory Commission Tennessee Valley Authority 10833 Shaw Road 3B Lookout Place Athens, AL 35611 1101 Market Street Chattanooga, TN 37402-2801 Chairman Limestone County Commission Mr. R. D. Machon, Site Vice President 310 West Washington Street Browns Ferry Nuclear Plant Athens, AL 35611 Tennessee Valley Authority P.O. Box 2000 State Health Officer Decatur, AL 35602 Alabama Department of Public Health 434 Monroe Street Montgomery, AL 36130-1701 l . - ~

t. .i . Distribution w/ Enclosure 1 W. Russell /F. Miraglia i--

R. Zimmerman

-A. Thadani .S. Varga G. Lainas F. Hebdon OGC E. Jordan, D/AE00 P. Kang L. Wert l

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r ATTENDEES TVA/NRC MEETING SEPTEMBER 22. 1994 NAME AFFILIATION Joe Williams NRR/PDII-4 Peter J. Kang NRR/EELB Gene Preston TVA BFN Plant Manager Joe McCarthy TVA BFN Regulatory Licensing Manager Stewart A. Wetzel TVA BFN Regulatory Engineer Robert J. Moll TVA BFN Operations Manager Pedro Salas TVA/BFN Licensing Manager Len Wert Region II/ Senior Resident Inspector

0. P. Chopra NRR/EELB ENCLOSURE 1 i

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.xx 1 Diesel Generators Technical Specification Required Surveillances i l TVA/NRC Meeting September 22,1994 l l k i m. r

AGENDA 1. OPENING REMARKS i>EDRO SALAS 11. BACKGROUND PEDRO SALAS 111. TECHNICAL SPECIFICATIONS R. J. MOLL IV. CLOSING REMARKS E.PRESTON 1 I PS 1

I. OPENING REMARKS KEY POINTS OVERALL OBJECTIVE OF BOTH TVA AND NRC IS TO MAXIMlZE LONG TERM DIESEL GENERATOR AVAILABILITY AND RELIABILITY THE BFN AUXILIARY POWER SYSTEM CONFIGURATION IS HIGHLY REDUNDANT TVA'S CURRENT LICENSING BASIS IS CONFORMANCE WITH GENERIC LETTER (GL) 84-15, PROPOSED STAFF ACTIONS TO IMPROVE AND MAINTAIN DIESEL GENERATOR RELIABILITY, AND THE INTENT OF REGULATORY GUIDE (RG) 1.108, PERIODIC TESTING OF DIESEL GENERATOR UNITS USED AS ONSITE ELECTRIC POWER SYSTEMS AT NUCLEAR POWEP. PLANTS CURRENT SURVEILL.ANCE AND TESTING PRACTICES HAVE ENSURED HIGH DIESEL GENERATOR RELIABILITY TVA RECOGNIZES CURRENT TECHNICAL SPECIFICATION 4.9.B.3 IS DIFFERENT FROM STANDARD WORDING TVA WILL SUBMIT A PROPOSED AMENDMENT TO RESOLVE INTERPRETATION ISSUE l l l l l PS 2

, :w II. BACKGROUND BFN STANDBY AUXILIARY POWER SY, STEM BFN HAS EIGHT DIESEL GENERATORS FOUR ARE UNITS 1/2 DIESELS FOUR ARE UNIT 3 DIESELS TWO UNITS 3 DIESELS ARE REQUIRED TO SUPPORT COMMON EQUIPMENT (STANDBY GAS TREATMENT AND CONTROL ROOM EMERGENCY VENTILATION SYSTEMS) FOUR 4-KV SHUTDOWN BOARDS SUPPLY EMERGENCY POWER LOADS FOR UNITS 1 AND 2 FOUR 4-KV SHUTDOWN BOARDS SUPPLY EMERGENCY POWER LOADS FOR UNIT 3 ONE DIESEL SUPPLIES BACKUP POWER TO EACH 4-KV SHUTDOWN BOARD l ~ \\ t l PS 3 l

,7 II. BACKGROUND (CONTINUED) BFN STANDBY AUXILIARY POWER SYSTEM (CONTINUED) THERE ARE FOUR POSSIBLE 4-KV SUPPLIES TO EACH UNITS 1 AND 2 SHUTDOWN BOARD FIRST ALTERNATE IS FROM THE OTHER SHUTDOWN BUS SECOND ALTERNATE IS FROM THE DIESEL GENERATOR t THIRD ALTERNATE IS FROM THE UNIT 3 DIESLL GENERATOR VIA A UNIT 3 SHUTDOWN BOARD THERE ARE THREE POSSIBLE 4-KV SUPPLIES TO EACH UNIT 3 SHUTDOWN BOARD FIRST ALTERNATE IS FROM THE BUS TIE DOARD (CURRENTLY UNAVAILABLE) SECOND ALTERNATE IS FROM THE DIESEL GENERATOR UNITS 1 AND 2 DIESEL GENERATORS CANNOT SUPPLY POWER TO UNIT 3 SHUTDOWN BOARDS. HOWEVER, THEY MAY BE PARALLELED WITH A UNIT 3 DIESEL FOR BACKFEED OPERATION. i CONFIGURATION SHOWN ON FIGURE PS 4

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II. BACKGROUND (CONTINUED) BFN STANDBY AUXILIARY POWER SYSTEM (CONTINUED) A LOSS OF OFFSITE POWER AT BFN IS A LOW PROBABILITY INITIATING EVENT (4.24 X 10-2) CURRENT RELIABILITY OF DIESEL GENERATORS IS HIGH (99.5%) CURRENT AVAILABILITY OF DIESEL GENERATORS IS HIGH (97.6%) CURRENT SCHEDULE FOR DIESEL GENERATOR MAINTENANCE AND TESTING: OPERABluTY SURVEILLANCE - MONTHLY LOAD ACCEPTANCE TEST-ONCE PER CYCLE VENDOR RECOMMENDED MAINTENANCE - ONCE PER TWO YEAFiS 6 PS

... = II. BACKGROUND (CONTINUED) EVOLUTION OF REGULATORY GUIDANCE REGULATORY GUIDE (RG) 1.108, REV.1, PERIODIC TESTING OF DIESEL GENERATOR UNITS USED AS ONSITE ELECTRIC POWER SYSTEMS AT NUCLEAR POWER PLANTS (8/77) INTERVAL FOR PERIODIC TESTlHG DEPENDENT ON DEMONSTRATED PERFORMANCE FAILURE DEFINED AS FAILURE TO START, ACCELERATE, AND ASSUME RATED LOAD WITHIN TIME PRESCRIBED FAILURE NOT DEFINED AS MADE INOPERABLE FOR MAINTENANCE OR TESTING NRC ISSUED GENERIC LETTER (GL) 84-15, PROPOSED STAFF ACTIONS TO IMPROVE AND MAINTAIN DIESEL GENERATOR RELIABILITY, ADDRESSED RELIABILITY GOALS OF RG 1.108 (7/84) IMPLEMENT MODEL TECHNICAL SPECIFICATIONS TO REDUCE COLD FAST START SURVEILLANCE TESTS FURNISH RELIABILITY DATA FOR RESOLUTION OF USI A-44, STATION BLACKOUT IMPLEMENT MODEL TECHNICAL SPECIFICATIONS FOR DIESEL GENERATOR REUABILITY PROGRAMS l l PS 7 1

l' II. BACKGROUND (CONTINUED) EVOLUTION OF REGULATORY GUIDANCE (CONTINUED) TVA SUBMITTED TECHNICAL SPECIFICATION 231 IN RESPONSE TO GL 84-15 (5/87) PREVIOUS TECHNICAL SPECIFICATION 4.9.B.3: "When one of the units 1 and 2 diesel generators is found to be INOPERABLE, all of the CSQRHRl(LPCIjAhd@oht!Elsmenti$yooli@)ysy5fsE5]IiH1 the remaining diesel generators and associated boards shall be demonstrated to be OPERABLE 1AmEdiatielyphdfd511p, thereafter." REVISED TECHNICAL SPECIFICATION 4.9.B.3: "When one of the units 1 and 2 diesel generators is found to be INDPERABLE, all of the remaining diesel generators shall be demonstrated to be OPERABLE withlh} $ hours, and power availability for the associated boards shall be EEElfied'Olt6id71jjb6uryahdjAtEleastijsh6ejpdr[8]Nb0ry thereafter." NEW TECHNICAL SPECIFICATION TABLE 4.9.A, DIESEL GENERATOR RELIABILITY NRC APPROVED PROPOSED TECHNICAL SPECIFICATION CHANGES AS AMENDMENTS 153,149, l AND 124 (8/88) 9 l l PR O

t II. BACKGROUND (CONTINUED) EVOLUTION OF REGULATORY GUIDANCE (CONTINUED) SUPPLEMENTAL SAFETY EVALUATION FOR STATION BLACKOUT (9/92) THREE OUT OF EIGHT DIESEL GENERATORS SUFFICIENT TO ACHIEVE SAFE SHUTDOWN TWO DIESEL GENERATORS NECESSARY FOR ALTERNATE AC ASSISTANCE CLASSIFIED AS EMERGENCY AC GROUP *C" (1/2 DEDICATED OR 1/3 SHARED) REQUIREMENTS OF IMPROVED STANDARD TECHNICAL SPECIFICATIONS (9/92) 10 CFR 50.65, - MAINTENANCE RULE (6/93) "The objective of preventing failures of systems and components through maintenance must be balanced against the objective of minimizing system unavailability due to maintenance activities" GL 94-01, REMOVAL OF ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FOR EMERGENCY DIESEL GENERATORS (5/94) l UCENSEES MAY REQUEST REMOVAL OF TECHNICAL SPECIFICATION PROVISIONS FOR ACCELERATED TESTING l AND SPECIAL REPORTING REQUIREMENTS i UCENSEES MUST COMMIT TO IMPLEMENT MONITORING AND MAINTENANCE REQUIREMENTS OF MAINTENANCE RULE AND GUIDANCE OF RG 1.160 l l I PS 9

III. TECIINICAL SPECIFICATIONS L TECHNICAL SPECIFICATION 4.9.B.3: "When one of the units 1 and 2 diesel generators is found.itofbej;;l INOPERABLE, all of the remaining diesel generators shall be demonstrated to be OPERABLE within 24 hours, and power availability for the associated boards shall be verified within 1 hour and at least once per 8 hours thereafter." TVA INTERPRETATION t TVA INTERPRETS THIS ACTIONS STATEMENT LITERALLY - ACTIONS ONLY TAKEN IF THE DIESEL GENERATOR IS

• FOUND TO BE INOPERABLE *.

WHEN ONE OF THE UNITS 1 AND 2 DIESEL GENERATORS IS DELIBERATELY MADE INOPERABLE DUE TO MAINTENANCE OR TESTING, THE OTHER DIESEL GENERATORS THAT ARE REQUIRED TO BE OPERABLE ARE CONSIDERED OPERABLE IF THEY ARE WITHIN THE REQUIRED SURVEILLANCE TESTING FREQUENCY AND THERE IS NO REASON TO SUSPECT THEY ARE INOPERABLE. BFN TECHNICAL SPECIFICATIONS DIFFERENTIATE BETWEEN: "FOUND TO BE INOPERABLE

• AND "MADE TO BE INOPERABLE
• EXAMPLES OF OTHER BFN TECHNICAL SPECIFICATIONS SHOWN ON NEXT TWO PAGES RJM 10

l III. TECHNICAL SPECIFICATIONS (CONTINUED) I l OTHER BFN TECHNICAL SPECIFICATION REQUIREMENTS i 4.2.B, CORE AND CONTAINMENT COOLING SYSTEMS - INITIATION AND CONTROL "Whenever a system or loop ;1'sjmadei,INOPERABI E because of a required test or i calibration, the other systems or loops that are required to be OPERABLE shall be considered OPERABLE if they are within the required surveillance testing frequency and there is no reason to suspect they are INOPERABLE." 3.7.B.3, STANDBY GAS TREATMENT SYSTEM "Frosa and after the date that one train of the standby gas treatment system ;is k dk$bkh.fd%5d[ M Nj{NON pk N$ for any reason, REACTOR POWER OPERATION and fuel handling is permissible only during the succeeding 7 days unless.such circuit is sooner made OPERABLE, provided that during such 7 days all active components of the other two standby gas treatment trains shall be operable." 3.7.E.3, CONTROL ROOM EMERGENCY VENTit.ATION "From and after the date that one of the control room emergency pressurization systems isjusds[orifodsdfto!ibO}inoperabie for any reason, REACTOR POWER OPERATIONS or refueling operations are permissible only during the succeeding 7 days unless such circuit is sooner made OPERABLE." RJM 11

III. TECHNICAL SPECIFICATIONS (CONTINUED) OTHER BFN TECHNICAL SPECIFICATION REQUIREMENTS (CONTINUED) 4.9.B.4, OPERATION WITH INOPERABLE EQUIPMENT "When one 4-kV shutdown board is{fourfdito3be} INOPERABLE, all diesel generators associated with the remaining 4-kV shutdown boards shall be demonstrated to be OPERABLE within 24 hours, and power availability for the remaining 4-kV shutdown boards shall be verified within 1 hours and at least once per 8 hours thereafter." 4.9.B.5, OPERATION WITH INOPERABLE EQUIPMENT "When a shutdown bus is[fodrsilt@be[ INOPERABLE, all 1 and 2 diesel generators shall be proven OPERABLE within 24 hours." 4.9.B.6, OPERATION WITH INOPERABLE EQUIPMENT "When one units 1 and 2 diesel auxiliary board ilsjfbbhd{foj[li{ INOPERABLE, each unit 1 and 2 diesel generator shall be proven OPERABLE within 24 hours, and power availability for the remaining diesel auxiliary board shall be verified within 1 hour and at least once per 8 hours thereafter." RJM 12 1

III. TECHNICAL SPECIFICATIONS (CONTINUED) TECHNICAL SPECIFICATION 4.9.B.3: "When one of the units 1 and 2 diesel generators is founditolbe? INOPERABLE, all of the remaining diesel generators shall be demonstrated toWOP RABLE witii5in 24 hours, and power availability for the associated boards shall be verified within I hour and at least once per 8 hours thereafter." VERBAL NRC INTERPRETATION IF A DIESEL GENERATOR IS FOUND_TO,BE INOPERABLE OR MADE INOPERABLE, ALL OF THE REMAINING DIESEL GENERATORS SHALL BE DEMONSTRATED TO BE OPERABLE WITHIN 24 HOURS, AND POWER AVAILABILITY FOR THE ASSOCIATED BOARDS SHALL BE VERIFIED WITHIN 1 HOUR AND AT LEAST ONCE PER a HOURS THEREAFTER MAINTENANCE AND TESTING OF DIESEL GENERATORS,4-KV SHUTDOWN BOARDS, SHUTDOWN BUSSES, AND DIESEL AUXILIARY BOARDS RESULTS IN A SIGNIFICANT INCREASE IN DIESEL GENERATOR STARTS; REGARDLESS OF THE RELIABILITY OF THE DIESEL GENERATORS INCREASE IN DIESEL GENERATOR STARTS INCREASES THE WEAR ON THE DIESEL GENERATORS AND DECREASE THEIR LONG TERM RELIABILITY AND AVAILABILITY -L RJM 13

III. TECIINICAL SPECIFICATIONS (CONTINUED) IMPROVED STANDARD TECHNICAL SPECIFICATION 3.8.1 REQUIRES THE FOLLOWING l ACTIONS FOR AN INOPERABLE DIESEL GENERATOR: VERIFY CORRECT BREAKER ALIGNMENT AND INDICATED POWER AVAILABILITY FOR EACH OFFSITE CIRCUIT WITHIN 1 HOUR AND ONCE PER 8 HOURS THEREAFTER. AND DETERMINE THE REMAINING OPERABLE DIESEL GENERATORS ARE NOT INOPERABLE DUE TO COMMON CAUSE FAILURE WITHIN 24 HOURS. OR r VERIFY EACH DIESEL GENERATOR STARTS FROM STANDBY CONDITIONS AND ACHIEVES STEADY STATE VOLTAGE AND FREQUENCY WITHIN THE PRESCRIBED ACCEPTANCE CRITERIA WITHIN 24 HOU.9S. l RJM 14

I III. TECHNICAL SPECIFICATIONS (CONTINUED) RESOLUTION OF INTERPRETATIONS OF TECHNICAL SPECIFICATION 4.9.B.3 TVA WILL PROPOSE A TECHNICAL SPECIFICATION AMENDMENT TO INCORPORATE REQUIREMENTS OF IMPROVED STANDARD TECHNICAL SPECIFICATIONS UNTIL TECHNICAL SPECIFICATION AMENDMENT DISPOSITIONED, TVA WILL VERIFY CORRECT BREAKER ALIGNMENT AND INDICATED POWER AVAILABILITY FOR EACH OFFSITE CIRCUIT WITHIN 1 HOUR AND ONCE PER 8 HOURS THEREAFTER WHEN A DIESEL GENERATOR IS DELIBERATELY MADE INOPERABLE DUE TO MAINTENANCE OR TESTING, A COMMON FAILURE MODE IS NOT INTRODUCED. THEREFORE, STARTING REMAINING DIESEL GENERATORS IS NOT REQUIRED. RJM 15

? III. TECHNICAL SPECIFICATIONS (CONTINUED) PROPOSED UNITS 1 AND 2 TECHNICAL SPECIFICATION AMENDMENT CURRENT LCO CURRENT SURVEILLANCE PROPOSED SURVEILLANCE "When one of the units 1 "When one of the units When one of the units 1 and 2 diesel and 2 diesel generator is 1 and 2 diesel generators is inoperable, power INOPERABLE, continued REACTOR generators is found to availability for the associated boards POWER OPERATION is be INOPERABLE, all of shall be verified within 1 hour and at permissible during the the remaining diesel least once per 8 hours thereafter. succeeding 7 days, provided genere' !s shall be that 2 offsite power sources demonstrated to be And are available as specified in OPERABLE within 3.9.A.1.C and all of the CS, 24 hours, and power Determine OPERABLE units 1 and 2 diesel RHR (LPCI and containment availability for the generators are not inoperable due to cooling) systems, and the associated boards common cause failure within 24 hours. remaining three units 1 and 2 shall be verified diesel generators are within 1 hour and at or OPERABLE. if this least once per a hours requirement cannot be met, an thereafter." The remaining units 1 and 2 diesel orderly shutdown shall be generators shall be demonstrated to be initiated and the reactor OPERABLE within 24 hours. shall be in the COLD SHUTDOWN CONDITION within 24 hours." MARK-UP PAGES AND REVISED PAGES ATTACHED RJM 16

, ~. ' - l c-III. TECHNICAL SPECIFICATIONS (CONTINUED) PROPOSED UNIT 3 TECHNICAL SPECIFICATION AMENDMENT l CURRENT LCO CURRENT SURVEILLANCE PROPOSED SURVEILLANCE "When one unit 3 diesel "When one unit 3 When one of the unit 3 diesel generator (3A, 3B, 3C, or 3D) diesel generators is generators is inoperable, power is inoperable, continued found to be availability for the associated boards reactor operation is inoperable, all of the shall be verified within 1 hour and at permissible during the remaining unit 3 least-once per 8 hours,thereafter. succeeding 7 days, provided diesel generators that 2 offsite power sources shall be demonstrated Anil are available as specified in to be OPERABL5: within 3.9.A.1.C and all of the CS, 24 hours, and power Determine operable unit 3 diesel RHR (LPCI and containment availability for the generators are not inoperable due to cooling) systems, and the associated boards common cause failure within 24 hours. remaining three unit 3 diesel shall be verified generators are OPERABLE. If within 1 hour and at or l this requirement cannot be-least once per 8 hours i met, an orderly shutdown thereafter." The remaining unit 3 diesel generators shall be initiated and the shall be demonstrated to be OPERABLE reactor shall be shut down within 24 hours. I and in the Cold Condition I within 24 hours." MARK-UP PAGES AND REVISED PAGES ATTACHED RJM 17

NOV 18 ISE '. c 3.9/4.9 Afffff.T Any Tf Wr'TRf t'AT. gYgTEM LIMITING CONDITIONS POR OPERATION SURVEILLANCE REQUIREMENTS ^ 3.9.B. Doeration with fnenerable 4.9.B. Oneration With Inonerable Zouinment Eauinment 3. When one of the unita 1 3. When one of the and 2 diesel generator is unita 1 and 2 diesel IN0PERABLE, continued generators is-found REACTOR POWER OPERATION to be INOPERABLE, permissible turing the all of the remaining succeeding 7 days, diesel generators provided,that 2 offsite shall be demonstrated power sources are to be OPERABLE within available as specified 24 hours, and power in 3.9.A.I.e and all of availability for the the CS, RER (LPCI and associated boards containment cooling) shall be verified systems, and the remaining within 1 hour and three units 1 and 2 diesel at least once per generators are OPERABLE. g hours thereafter. If this requirement cannot be met, an orderly shutdown shall be initiated and the reactor Delete and replace shall be in the COLD SNUTDOWN CONDITION within as Shown 24 hours. r 4 When one units 1 and 2 4. When one 4-kV 4-kV shutdown board is shutdown board is I3 OPERABLE, continued fotand to be REACTOR POWER OPERATION INOPER&BLE, all is permissible for a period diesel generators of 5 days provided that associated with the 2 offsite power sources remaining 4-kV shutdown are available as boards shall be demon-specified in 3.9.A.1.c strated to be OPERABLE and the remaining 4-kV within 24 hours, and shutdown boards and power availability for associated diesel-the remaining 4-kV. generators, CS, RNR (LPCI shutdown boards shall and containment cooling) be verified within l systems, and all 480-V 1 hour and at least emergency power boards once per 8 hours are OPERABLE. If this thereafter. requirement cannot be met, an orderly shutdown shall be initiated and ) the reactor shall be in i the' COLD SEUTDOWN CONDITION within 24 hours. r BFN 3.9/4.9-9 AMENDMENT N0.15 8 Unit 1 MARK-UP PAGE

f u e -{, 3.9/4[9 Affrff TAnv wf uf'TRYcAt. SYSTEM LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.9.B. Oneration with inenarable 4.9.B. Onaration With Tnanarable 2auinment Eauinment 3. When one of the units 1 3. When one of the unit 3 and 2 diesel generator is diesel generators is INOPERABLE, continued inoperable, power f REACTOR POWER OPERATION availability for the periaissible liuring the associated boards shall be succeeding 7 days, verified within 1 hour and provided,that 2 offsite at least once per 8 hours power sources are thereafter. available as specified in 3.9.A.1.c and all of the CS, REE (LPCI and d containment cooling) systems, and the remaining Determine OPERABLE unit 3 three units 1 and 2 diesel diesel generators are not generators are OPERABLE, inoperable due to common If this requirement cannot cause failure within be met, an orderly 24 hours. shutdown shall be initiated and the reactor g shall be in the COLD $5UTDOWN CONDITION within The remaining unit 3 diesel 24 hours. generators shall be dem utrated to be O N BM 4. When one units 1 and 2 i 4-kV shutdown board is within 24 hours. INOFERABLE, continued REACTOR POWER OPERATION is' permissible for a period 4. When one 4-kV of 5 days provided that shutdown board is 2 offsite power sources found to be are available as INOPERABLE, all specified in 3.9.A.1.c diesel generators and the remaining 4-kV associated with the shutdown boards and remaining 4-kV shutdown associated diesel boards shall be demon-generators, CS, RER (LPCI strated to be OPERABLE and containment cooling) within 24 hours, and systems, and all 480-V power availability for emergency power boards the remaining 4-kV-are OPERABLE. If this shutdown boards shall I requirement cannot be be verified within set, an orderly shutdown 1 hour and at least shall be initiated and once per 8 hours the reactor shall be in thereafter. the COLD SHUTDOWN CONDITION within 24 hours. BFN 3 '/4 '-' AMENDMENT NO.15 8 Unit 1 REVISED PAGE

',P. o ~ = s, 2.9/A,9 AUXILIARY ELECT 2TCAL SYSTTM OV 181988 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE RE0UIREMENTS' 3.9.B. Oceration With Inceerable 4.9.B. Overation With Inonerable Ecuiement Ecuiement 3. When one of the units 1 3. en one of the and 2 diesel generator is units 1 and 2 diesel INOPERABL2, continued generators is found REACTOR POWER OPERATION is to be INOPERABLE, permissible during the all of the remaining succeeding 7 days, diesel generators provided thac 2 offsite shall be demonstrated power sources are to be OPERABLE within available as specified I 24 hours, and power in 3.9.A.1.c and all of crailability for the the CS, RER (LPCI and associated boards containment cooling) shall be verified systems, and the remaining { within 1 hour and i j three units 1 and 2 diesel at least once per generators are OPERABLE. 8 hours thereafter. If this requirement cannot be met, an orderly -~ shutdown shall be Delete and replace initiated and the reactor RS Shown shall be in the COLD SHUTDOWN CONDITION vithin 24 hours. 4 When one units 1 and 2 4 When one 4-kV 4-kV shutdown board is shutdown board is INOPERABLE, centinued found to be REACTOR POWER OPERATION INOPERABLE, all is permissible for a period diesel generators of 5 days provided that associated with the 2 offsite power sources remaining 4-kV are available as shutdown boards shall specified in 3.9.A.1.c be demonstrated to be and the remaining 4-kV OPERABLE within 24 hours, shutdown boards and and power availability associated diesel for the remaining 4-kV generators, CS, RER (LPCI shutdown boards and containment cooling) shall be verified systems, and all 480-V within 1 hours and emergency power boards at least once per are OPERABLE. If this 8 hours thereafter. requirement cannot be met, an orderly shutdown shall be initiated and the reactor shall be in the COLD SHUTDOWN CONDITION within 24 hours. BFN 3.9/4.9-9 AMENDMENT Nn.15 4 Unit 2 MARK-UP PAGE

p,- t 2.o/4.9 s.UIILTDY ~2TICAL SYS'"ZM LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS-3.9.B. Ooeration With Irenerable~ 4.9.B. Oneration With Inanarable Equirment Eauinment 3. When one of'the units 1 3. When one of the units'1 ~: and 2 diesel generator is and 2 diesel generators INOPERABLE, continuea is inoperable, power REACTOR POWER OPERATION is availability for the permissible.during the associated boards shall succeeding 7 days, be verified within 1 provided that 2 offsite hour and at least once power sources are per 8 hours thereafter. available as specified in 3.9.A.1.c and all of ADA the CS, RER (LPCI and containment' cooling) Determine OPERABLE systens, and the remainin4 units 1 and 2 diesel three units 1.and 2 diesel generators are not generators are OPERABLE. inoperable due to If this requirement cannot. common cause failure be met, an orderly within 24 hours. shutdown shall be initiated and the reactor gI shall be in the COLD SHUTDOWN CONDITION within 24 hours. .The remaining units 1 and 2 diesel generators 4 When one units 1 and 2 shall be demonstrated 4-kV shutdown board is to be OPERABLE within INOPERABLE, continued 24 hours. REACTOR POWER OPERATION is per=1ssible for a period of 5 days provided that 4 When one 4-kV 2 offsite power sources shutdown board is are available as found to be specified in 3.9. A.I.c INOPERABLE, all and tht remaining 4-kV diesel generators shutdetn boarcs and associated with the associa:ed diesel remaining 4-kV generators, CS, RHR (LPCI shutdown boards shall and containment cooling) be demonstrated to be systems. and all 480-V OPERABLE within 24 hours, emergency power boarcs and power availability are OPERABLE. If this for the remaining 4-kV. requirement cannot be shutdown boards met, an orderly shutdown shall be verified shall be initiated and within 1 hours and the reactor shall be in at least once per. the COLD SHUTt0WN CONDITION 8 hours thereafter. i within 24 hours. 3FN 3,9f4,9_o Unit 2 REVISED PAGE

= 1 3.9/4.9 AUTTLTARY YLECTRf f*AT. SYSTTM h{h]hhh LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREME3tTS ) 3.9.B. Oceration with Inocerable 4.9.B. Doeration with Inocerable Ecutoment Zautunent Whenever the reactor is in STARTUP mode or RUN mode and not in a Cold Condition, the availability of electric power shall be as specified in 3.9.A except as specified herein. 1. From and after the date

1. When only one that only one offsite offsite power source power source is available, is OPERABLE, all unit 3 reactor operation is diesel generators must permissible under this be demonstrated to be condition for seven days.

OPenani.x within 24 hours, and power availability for the associated boards shall be i verified within 1 hour and at i least once per 8 hours thereafter. ,z z : 2. When one unit 3 diesel

2. When one unit 3 diesel generator (3A, 3B, 3C, generator is found to be or 3D) is inoperable, inoperable, all of the continued reactor operation remaininn unit 3 diesel is permissible during the generators shall be succeeding 7 days, provided demonstrated to be that two offsite power OPEtanfR within 24 hours, f

sources are available as and power availability for l !' specified in 3.9.A.1.c. the associated boards ahall be verified within j and all of the CS, RHR l (LPCI and containment 1 hour and at least once cooling) systems, and the per 8 hours thereafter. l remaining three unit 3 diesel generators are OPERABLE. If this require-ment cannot be met, an orderly shutdown shall be Delete and repl8Ce initiated and the reactor shall be shut down and in as Shown the Cold Condition within 24 hours. E AMENDMENT NO. I 24 BFN 3.9/4.9-8 Unit 3 MARK-UP PAGE

9, ; a #; 3.9/4.9 AffrTLTARY vtvCTRTr'At SYSTEM 4 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.9.B. Oneration with Tuonerable 4.9.B. Oneration with Inonerable Eauinment Zauinment l Whenever the reactor is in STARTUP mode or EUN mode-and 1 not in a Cold Condition, the availability of electric l power shall be as specified in 3.9.A except as specified herein. 1. From and after the date

1. When only one k

that only one offsite offsite power. source power source is available, is OPFRARLI, all unit 3 reactor operation is diesel generators must permissible under.this. be demonstrated to be I condition for seven days. OPERABLE within 24 hours, and power availability for the associated boards shall be verifisd within 1 hour and at' i least once per 8 hours thereafter. 2. When one unit 3 diesel 2.. when one of the unit'3 generator (3A, 3B, 3C, diesel generators is or 3D).is inoperable, inoperable, power I continued reactor operation availability for the is permissible during the associated boards shall be succeeding 7 days, provided verified within 1 hour and that two offsite power at least once per 8 hours sources are available as. thereafter. specified in 3.9.A.1.c. and all of the CS, REE Anst (LPCI and containment i cooling) systems, and the Determine OPERABLE unit 3 remaining three unit 3 diesel generators are not diesel generators are inoperable due to common OPERABLE. If this require-cause failure within ment cannot be met, an 24 hours. orderly shutdown shall be r initiated and the reactor . gg shall be shut down and in the Cold Condition within The remaining unit 3 diesel 24 hours, generators shall be j demonstrated to be OPERABLE within 24 hours. I l BFN 3.9/4.9-8 Unit 3 REVISED PAGE

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