Text

Proposed Tech Specs Reflecting Modified Surveillance Requirement Frequencies for Unit 3
	ML20085G543
Person / Time
Site:	Millstone
Issue date:	06/14/1995
From:	; NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	;
Shared Package
ML20085G540	List: B15245, Application for Amend to License NPF-49.Amend Would Modify Frequency of Surveillance Requirements of Unit 3 TSs; ML20085G543;
References
	NUDOCS 9506200260
	Download: ML20085G543 (59)
	v • d • e

.USNRC DRPE TEL:301-415-2102 May 12'95 15:02 No.006 P.08 ELECTRICAL POWER SYSTBt3 LIMITING CofCITI0ll FOR OPERATION

. ACTION (continued)

f. With two of the above required diesel generators inoperable demon-strate the OPDtABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least .

ence per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafters restore one of the inoperable diesel generators to OPFRaAlF status within I hours or be in at least INT STAlW8Y within the next 5 hears and in COLD 3Htirpglel within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Following restoration of one diesel generator unit, follow Action statement b with the time requirement of that Action Statement based on the time of initial loss of the remaining i able diesel generator. A successful test of diesel ILITY per Surveillance Itaquirement 4.8.1.1.2.a.5 under this Action statement for a restered to OPERABLE lesel generator satisfies the diesel generator test requirement of Action statement b.

SLRVEILLAIICE REQUIRBIDITS 4.4.1.1.1 Each of the above required independent circuits between the offsite transmission network and the ensite Class IE Distribution system sha11 be:

)

a. Determined OPIRABLE at least once per 7 by verifying correct ,

breaker alignments, indicated power avail itity,and s e n c h a s p u E.L MmicR V A L i"

6 b. Demonstrated SPERABLE at leest oncedner la e durina **]hy transferring (manually and automatically) unit power supply from the nomal circuit to the alternate circuit.

l 4.8.1.1.2 Each diesel generator shall be demonstrated OretABLE:* Ih j a. In accordance with the frequency specified in Table 4.8-1 on a j STAGSDtED TEST RA315 by:

V i

' 13 Verifying the fuel level in the day tank. l 2p Verifying the fuel level in the fuel tank, j i 3J Verifying the fuel transfer pump starts transfers fuel from the storage system to the tank, ,

2 4 Verifying the lubricating of inventory in storage. -

l 5 Verifying the diesel starts free standby conditions and achieves generator voltage and frequency at 4160 i 420 volts and 60 i 0.8112. The diesel generator shall be started for j) this test by using one of the following signals:

l a) Manual, or oJ' l *All planned starts for the purpose of these surveillances may be r +::f:f by en engine prelube period. V

NILLSTOIE - INIIT 3 3/4 s-3 Amendment No. N , M 112 east

3M 4

9506200260 950614 PDR ADOCK 05000423 8

P PDR L_ . _ _ . _ . . _ . _ _ . - _ . _ . _ _ _ _ _ _ _ . . _ _ . _ .

f USNRC-DRPE TEL:301-415-2102 May 12'95 15:05 No.006 P.10 stucmpAL 90Mut Snmms

$URWD11ANCE REqu!RDerT5 (Continued) !

j '(:

b) A kinematic viscosity at 40*C of greater than or equal to l l 1.g centistokes, but less than er equal to 4.1 centistokes l (alternatively, $aybolt viscosity, SUS at 100'F of greater l i

than or equal to 32.6. but not less than er equal to '

i 40.1),ifgravitywasnotdeterminedbycomparisonwith j the supplier's certification 4

l; c) . A flash point equal to or greater than 125'F; and i d) A clear and bright appearance with proper color uhes testad in accordance with ASTN-04176-St.

' 2) Ry verifying within 30 days of obtaining the sample ht the l

. ot'aer properties specified ta Table 3 of ASTM-Og75-83 are met-when tested in accordance with ASTN Og75-81 except that the analysis for sulfur may be perfomed in accordance with ASTM-i 01552-73, ASIN-D2622-82 or ASTM-D42g4-83.

I

f. At least once e 31 days by obtaint a sample of fuel oil,in

accordance with -02276-78, and veri ing that total particulate

! contamination is less than 10 mg/litar checked in accordance j with ASTM-D2276-78, Method a gcutugc,

g. At least once )Fer la months, during shutdoun] by:

l.

! 1) . Subjecting the diesel to an inspection'in accordance with

. procedures prepared in conjunction with its manufacturer's i reccamandations for this class of standby service;-

2) ' Verifying the generator capability to reject a load of greater ;

, than or equal to 5g5 kW while maintaining voltage at 4160 1 420 j volts and frequency at 60 t 3 Hz; i 1

3'

3) Verifying the generator capability to reject a load of 4g85 kN !

l without trippine. The generator voltage shall act emceed 5000 l

volts during and 4784 volts following the load rejection; 1

4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergitation of the emergency busses and lead shedding from the emergency busses, aad b) VerifyingthedieselstartsfromstandbyconditionsontheI auto-start signal, energizes the emergency busses with

permanently connected loads within 11 seconds, energizes '

) the auto-connected shutdown loads through the load sequencer and operates for greater than er equal to 5 1 minutes while its generator is loaded with the shutdown

. loads. After energization the steady-state voltage and

i. frequency of the emergency, busses shall be maintained at j 4160 1 420 volts and 60 i 0.8 Hz during this test.

NILLSTOIE - WIT 3 3/4S-5 Amendment No. J. 5 . M. N , # p.

4 0 327 IMN2 1 _ _ . . _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ ~ _ . _ . . , _ _ _ _ ,

- . = _ _; --

. a. = - -

f. USNRC DRPE TEL:301-415-2102 May 12'95. 15:08 No.006 P.11 j ELECTRICAL POWER $YSTEMS gocW 9 l

i SURVEILLANCE Rtqu!RDIENTS (Continued) 94 R W "

(

4 5) Verifying that en an ESF Actuation test signal, without less- of-

{ effsite power, h diesel generator starts from standby )

l l conditions on W auto-start signal and operates on standby for l '

i greater than or equal to 5 minutes. The generator voltage and i . frequency shall be 4160 i 420 volts and 6010.8 He within 11 l seconds after the auto-start signal; W steady-state generator

toltage and frequency shall be maintained within these limits j during this test;

! Simulating a loss-of-offsite power in conjunction with an t$F 6)

Actuation test signal, and:

a) Verifying deemergization of the emergency busses and lead j shedding from W emergency busses; t

i b) Verifyingthedieselstartsfromstandbyconditionsonthel

! auto-start signal, energizes the emergency busses with

!. permanently connected loads within 11 seconds, enerytzes

the auto-connected emergency (a<;cident) loads through the j ' load sequencer and operates for greater than or equal to 5

minutes while its generator is loaded with the emergency i

loads. After energitation,tne steady-state voltage and frequency of the emergency basses shall be maintained at 4160 1 420 volts and 60 i 0.8 Hz during this test; and.

i

' c) Verifying that all automatic diem 1 ponerator trips, except i engine nn;xd, labe oil pres'sure ow (t of 3 logic) and j , aenerator differential, are automatically bypassed upon j

Toss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal.

7) Verifying the diesel generator operates for at least 24 tours.

During h first I hours of this test, & diesel mtor shall

! be loaded to greater than or equal to 5485 kW and ng the

remaining 22 tours of this test, the diesel generator shall be loaded to greater than or equal to 4986 kW. The generator i voltage and f shall be 4160 i 420 volts and 60 i 0.8 Hz i within 11 sec after the start signal; h steady-state 4

generator voltage and frequency shall be maintained within these limits during this test.* Within 5 minutes after completing this 24-hour test, perform specification

4.8.1.1.2.a.5);**

1 l

Diesel. generator loadings may include gradual loading as reconnended by W manufacturer. {

- If serveillance Requirement 4.8.1.1.2.a.5) is not, satisfactorily cosy 1sted, it is l not necessary to repeat the preceding 24-hour test. Instead, the diesel generator may be rated at eg86 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or entti operating temperature has stabili .

{

NILLSTtulE - WIT 3 3/4 8-6 Amundsmut Es. Jp, pp.112 i ..ns-

(_: a = =. =.=_ . u= 4: = -- . -=:==. -- - - - -

USNRC DRPE TEL:301-415-2102 May 12'95 15:10 No.006 P.12 l

ga cWAw W

! ELEqt1 CAL 90lst SYSTEIIS oNW i

g (L \ g g l SIRVEILLABICE REQUIlmerTS (Continued)

(

8) Verifying that the auto-connected loads to each diesel generator do not exceed the 2000-hour rating of 5335 kN;

! g) Verifying the diesel generator's capability to:

a) Synchreaize with the offsite power source uhile thej

- generater is loaded with its emergency inads meam-a j simulated restorattan of offsite pomer, '

b) Transfer its loads to the offsite pouer source, and c) Se restored to its standby status.

10) Verifying that with the diesel generator operating in a test j sede, connected to its bus, a simulated Safety laJoction si overrides the test mode by (1)roterni the diesel genera or to standby operation, and 2) automatica ly energizing the emergency loads with offsite power;

11) Verifying that the fuel transfer pump transfers fuel free each j fuel storage tank to the tank of each diesel via the 1 installed cross.ceanection ines;.

12) Verifying that the automatic load sequence timer-is OPERABLE

~ with the interval between each load block within i 105 of its design intervals and Verifyi that the following diesel generator lockout features

13) prevent 1esel generator starting a) Engire overspeed, I b) Lube oil pressure low (t of 3 logic), l c) Generator differential, and d) Emergency step.

h. At least once per 10 years or after any modifications which could d

affect diesel generator interdependence by starting both diesel )

generators simultaneously, during shutdown, and verifying that both diesel generators achieve generator voltage and frequency.at i 4160 t 420 volts and 6010.8 Hz in less than or equal to 11 seconds; )

and

1. At least esce per 10 years by:

1) Draining each fuel oil storage tank, removing the accomulated sediment and cleaning the tank using a sodium hypochlorite solution, and l

11 LLSTOIE - 1811.T 3 3/4 8 7 Amendment Ito, pp, 77, M ,112 1

, .w -

[ .

i 3 3 r -9 y 3

. 3/09/92 ttECTRicAL POWER SYSTEMS N P 1/4.s.2 D.c. souncES F0ll leo oNW y,

SPIBEIE LIMITING CONDITf0N FOR OPERATION

(

l l

3.8.2.1 As a minimum, the following D.C. electrical sources shall be l 0PERABLE:

. a. 125 volt Battery Bank 301A 1, and an associated full capacity charger,

b. 125 volt Battery Bank 301A-2, and an associated full capacity charger.

c. 125 volt Battery Bank 3018-1 and an associated full capacity :

charger, and

d. 125-volt Battery Bank 3018 2 and an associated fuli capacity charger. .

APPLICABILITY: MODES 1, 2, 3 and 4.

EHmi:

a. With either Battery Bank 301A 1 or 30181, and/or one of the required full capacity chargers inowrable, restore the inoperable battery bank and/or full capacity ctarger to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTD0WN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With either Battery Bank 301A 2 or 3018 2 inoperable, and/or one of the required full capacity chargers inoperable, restore the inoper-able battery bank and/or full capacity charger to OPERABLE status '

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least H0T STANDBY within the next 6 I hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEfLLANCE RE001REMENTS l

4.B.2.1 Each*125 volt battery bank and charger shall be demonstrated OPERABLE: ,

1

a. At least once per 7 days by verffying that;

~

3) The parameters in Table 4.9 ta meet the Category A limits, and

3) The total battery terminst voltage is greater than er equal to 123 volts on float chargu.

MILLSTONE - UNIT 3 3/4 8 11 Amendment No. 64 eens

3 ') s -ci % --

a n n m H ens January 3,1995.

l SURVEILLWE REQUIRDIENTS (Continued)

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery-overcharge with battery terminal voltage above 150 volts, by verify-ing that:

, 1) The parameters in Table 4.8-ta meet the Category B limits,

2) There is no visible corrosion at either terminals or connec-tors, or the connection resistance of these items is less than 150 x 10* ohm, and a

j .3) The average electrolyte t' emperature of six connected cells is above 60*F. f<gqspecum zerwwA

c. At least once[per (15 months}by verifying that: l

1) The cells, cell plates, and battery racks show no visual 4

indication of physical damage or abnormal deterioration,

2) The cell-to-cell andl terminal connections are clean, tight, and coated with anticorrosion material,

3) The resistance of each cell-to-cell 'and terminal connection is -

less than or equal to 150 x 10*. ohm, and

4) Each battery charger will supply' at least the emperage indi-

! cated in Table 4.8-2b at 125 volts for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

j % <- eccM2cNeu A reA

d. At least once eer 15 months, durina nhutdowih, by verifying that the l battery capacity is adequate to supp'y and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test;

e. At least once per 60 months,Cduring shutdown verifying that the l

battery capacity is at least 505 of the manufacturer's rating when

. subjected to a perfomance discharge test. Once per 60-month interval this performance discharge test may be perforsed in lieu of the battery service test required by Specification 4.8.2.1d.; and f co a Ernun w - am w m i f. At least once(iier 18 months. during shutdoMwniving performance I

discharge tests of battery capacity to any Dattery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity .

drops more'than 105 of rated capacity from its average on previous performance tests, or is below 905 of the manufacturer's rating. -

NILLSTONE - 5 TIT 3 3/4 8-12 Amendment No. M.- U .100 Femo

l .

3-3r-9y 3/09/92

~

ELECTRICALPOWERSYSTEMS l

3/4.3.4 ELECTRftAt t00fpMENT PROTECTIVE DEVftEt t

CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVffti j LIMITING CONDITION FOR OPERATION i .

! 3.8.4.1 All containment penetration conductor evercurrent protective devices i shall be OPERABLE. '

I APP 1ICABILITY: MODES 1, 2, 3, and 4. J l

EllM:

With one or'more of the containment penetration conductor overcurrent protec-l tive device (s) inoperable:

i j a. Restoretheprotectivedevice(s)toOPERABLEstatusordeenergize j the circuit (s) by tripping the associated backup circuit breaker or l racking out or removing the inoperable circuit breaker within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , declare the affected system or component inoperable, and -

verify the backup circuit breaker to be tripped or.the inoperable i

circuit breaker racked out or removed at least once per 7 days i thereafter; or l b. Be in at least HOT STANDBY within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and in COLD i SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

i SURVEILLANCE RE00fREMENTS 4.8.4.1 All containment penethation conductor overturrent protective devices

! shall be demonstrated OPERABLE: / p g rusuuc ,tersesA' l

a. At least once per la monthal:

i i 1) By verifying that the medium voltage (4-15 kV) circuit breakers

. are OPERA 8LE by selecting, on a rotat4ng basis, at least 10% of l the circuit breakers of each voltage level, and performing the i following:

1 1- a) .A CHANNEL CALIBRAT10N of the associated protective relays, i

! b) An integrated system functional test which includes i

simulated automatic actuation of the system and verifying that each relay and associated circuit breakers and-control circuits function as designed, and i

i 3/4 B 19 Amendment No. 25,57 64 p ,gf g5 TONE-UNIT 3

( u == .==:=-==- ; .- .= x= - -

L l

3 3 hM N

y f.~' , . No C4/WCE'

' ElECTRf tAL POWER SYSTDt1 1 SURVEILLANCE REQUIREMENTS fCentinued) ,

u

! c) For each circuit breaker found inoperable during these an additional representative sample of functional at least I Mtests,ll of a the circuit breakers of the inoperable i !

type shall also be functionally tested until no more i failures are found or all circuit breakers of that type l' have been functionally tested.

t

2) By selecting and functionally testing a representative sample l of at least in of each type of lower voltage circuit breakers. '

Circuit breakers selected for functional testing shall be selected on a rotating basis.

i Testing of air circuit breakers shall consist of injecting a current with a value equal to 300% of the pickup of the i long-time delay trip element and 15M of the pickup of the

! short-time delay trip element, and verifying that the circuit l

breaker operates within the time delay band width for that

current'specified by the manufacturer. The instantaneous i element shall be tested by injecting a current equal to i 20%

i of the pickup value of the element and verifying that the circuit breaker trips instantaneously with no intentional time l

delay.

Molded case circuit breakers and unitized starters (a frame size of 250 amps or less) shall be tested for long time delay s ,

at 300% as described above, and in addition tested for the i instantaneous trip by injecting a current value which falls

! within +40% (of the upper limit) and -25% (of the lower limit) j of the manufacturers instantaneous trip current range and verifying the breaker trips instantaneously with no intentional time delay. For those molded case circuit breakers / unitized starters used in 480V circuits, if single pole instantaneous l, test results fall outside these tolerances, additional-

}

instantaneous testing shall be conducted usinil two poles in series, including A.s. B-C and C-A phase comb' nations. All combination test results shall fall within the specified tolerances.

i - Circuit breakers found inoperable durinfl functional testing.

! shall be restored to OPERABLE status pr' or to resuming i owration. For each circuit breaker found inoperable during i

tgese functional tests, an additional, representative sample of -

st least 10% of all the circuit breakers of the inoperable type l

shall also be functionally tested until no more failures are j found or all circuit breakers of that type bave been func-i tionally tested.

j b. At least once per 60 months by subjecting each circuit breaker i to an inspection and preventive maintenance in accordance with

} procedures prepared in conjunction with its manufacturer's reconnendations.

i 3/4 4-20 Amendment No. U,64 j MILL.

ees STONE - WIT 3

i a

3 -3 s'-9 y

. .. 3/09/92 1

ELECTRICAL POWER SYSTEMS ,

MOTOR.0PERATED VALVES THERMAL OVERLOAD PROTECTION LIMITING CONDITION FOR OPERATION 3.8.4.2.1 Each thermal overload protection bypassed only under accident conditions for safety related motor operated valves shall be bypassed by an d

OPERABLE bypass device integral with the motor starter.

J APPLICABILITY: Whenever the motor-operated valve is required to be OPERABLE.

ACTION:

With the thermal overload protection for one or more of the above required valves not bypassed under conditions for which it is designed to be bypassed, restore the inoperable device or provide a means to bypass the thermal over-load within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or declare the affected valve (s) ino appropriate ACTION Statement (s) of the affected system (s)perable and apply the SURVEILLANCE RE001REMENTS l 4.8.4.2.1 The thermal overload protection for the above required valves shall be verified to be bypassed by the appropriate accident signal sance of a TRIP ACTUATION DEVICE OPERATIONAL TEST sofcircuitry the bnas(s) by perfor-B sont u3 during COLD SHUTDOWN or REFUELING at least once @d gc, @.E FU G L I N b gov 7 E tt v A L O

3/4 8-21 AmendmentNo.25,64 E 'l #ILLSTONE-UNIT sees 3

,.=

, 3-3f-99

- - 3/09/92

e.

, (LECTRICALPOWERSYETEMS er n0 TOR.0PERATED VALVES THERMAL OVERLOAD PROTECTION NOT SYpittfB -

ifMITING CONDITION FOR OPERAT10N ,

3.8.4.2.2- Each thermal overload protection not bypassed under accident conditions for safety-related actor operated valves shall be operable.

APPLICABILITY: Whenever the actor-operated valve is required to be OPERA 8LE.

I

EllQll:

With the thermal overload protection for one or more of the'above required i valves inoperable, bypass the inoperable thermal overload within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ; J restore the inoperable thermal overload to CPERABLE status within 30 days or J

declare the affected valve (s) inoperable and apply the appropriate ACTION Statement (s) for the affected systes(s).

SURVEILLANCE REQUIREMENTS cach 12 E FU FLt NG IN TERvA L.

4.8.4.2.2 The thermal' overload protection for)h[above required valves shall be demonstrated OPERABLE at least oncetsfr Is montu and following maintenance (

1 on the actor starter by the performance of a CHANNEL CALISRATION of a repre-

! sentative sample of at least 25% of all thermal everloads for the above required valves. ,

I l

4 i

h 1

MILLSTONE - UNIT 3 3/4822 Amendment No. 33,64 9712 .

a

. Docket No. 50-423 B15245 Attachment 2

~

Millstone-Nuclear Power Station, Unit No. 3 Proposed Revision to. Technical Specifications 1

24-Month Fuel Cycle Electrical Power Systems Retyped Pages i

1 1

June 1995

. 4

l

l ELECTRICAL POWER SYSTEMS LIMITING C0lWITION FOR OPERATION

)

l ACTION fcontinued) l I f. With two of the above required diesel generators inoperable, demon-strate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least

, once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; restore one of the inoperable diesel

, generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least' HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Following restoration of one diesel generator 4 unit, follow Action Statement b with the time requirement of that' Action Statement based on the time of initial loss of the remaining inoperable diesel generator. A successful test of diesel generator OPERABILITY per Surveillance Requirement 4.8.1.1.2.a.5 performed under this Action Statement for a restored to OPERABLE diesel generator satisfies the diesel generator test requirement of Action Statement b.

] SURVEILLANCE REQUIREMENTS 1 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the Onsite Class IE Distribution System shall be:

4

a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability, and

b. Demonstrated OPERABLE at least once each REFUELING INTERVAL by transferring (manually and automatically) unit power supply from the normal circuit to the alternate circuit.

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE * ,

1

a. In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:

1) Verifying the fuel level in the day tank,

2) Verifying the fuel level in the fuel storage tank, l

3) Verifying the fuel transfer pump starts and transfers fuel from j the storage system to the day tank, 1 Verifying the lubricating oil inventory in storage, 4)

5) Verifying the diesel starts from standby conditions and achieves generator voltage and frequency at 41601420 volts and 60 1 0.8 Hz. The diesel generator shall be started for this test by using one of the following signals:

a) Manual, or a

All planned starts for the purpose of these surveillances may be preceded by an engine prelube period.

MILLSTONE - UNIT 3 3/4 8-3 Amendment No. Jp, pp, J#

oom

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b) A kinematic viscosity at 40'C of greater.than or equal. to 1.9 centistokes, but less than or equal to 4.1 centistokes (alternatively, Saybolt viscosity, . SUS at 100*F of greater than or equal to 32.6, but not less than or equal to 40.1), if gravity was not determined by comparison with the supplier's certification; c) A flash point equal to or greater than 125'F; and' d) A clear and bright appearance with proper cole when tested in accordance with ASTM-D4176-82.. 1

2) By verifying within 30 days.of obtaining the sample that the other properties specified in Table 1 of- ASTM-D975-81 are met when tested in accordance with ASTM-D975-81 except that the analysis for sulfur may be performed in accordance with ASTM-D1552-79, ASTM-D2622-82 or ASTM-D4294-83.

f. At least once every 31 days by obtaining a sample of fuel oil in accordance with ASTM-D2276-78, and. verifying that tota 1' particulate contamination is less than 10 mg/ liter when checked in accordance with ASTM-D2276-78, Method A;

g. At least'once each REFUELING INTERVAL, by: l

1) Subjecting the diesel to an inspection.in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service;

2) Verifying the generator capability to reject a load of greater than or equal to 595 kW while maintaining voltage at 4160 i 420 volts and frequency at 60 1 3 Hz;-

3) Verifying the generator capability to reject a load of'4986 kW without tripping. The generator voltage shall not exceed 5000 volts during and 4784 volts following the load rejection;-

4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and b) Verifying the diesel starts from standby conditions on the ;

auto-start signal, energizes the e:nergency busses with permanently connected loads within 11 seconds, energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage.and frequency of the emergency busses shall be maintained at 4160 1 420 volts and 60 1 0.8 Hz during this test.

MILLSTONE - UNIT 3 3/4 8-5 Amendment No. J,'17, pf, 71. Jpp,

- lip,111,

i I ELECTRICAL POWER SYSTEMS

$URVEILLANCEREQUIRENENTS(Continued) l l b. At least once per 92 days and.within 7 days after a battery j discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verify-

[ ing that:

1) The parameters in Table 4.8-2a_ meet the Category B limits, L

I 2) .There is no visible corrosion at either terminals or connec -

4 tors, or the connection resistance of these-items is less than i 150 x 10* ohm, and-i j 3) The average electrolyte temperature-of six connected' cells is

above 60*F.

c. At least once each REFUELING. INTERVAL by verifying that:- .l

?

f' -1) The cells,. cell plates, and battery racks show no visual l indication of physical damage or abnormal deterioration,

2) The cell-to-cell and terminal connections are clean, tight, and .

coated with.anticorrosion material, I 3) The resistance of each cell-to-cell and terminal connection is l 1ess than or equal to 150 x 10? ohm, and i

i- 4) Each battery charger will supply at least'the amperage indi-cated in Table 4.8-2b at 125 volts for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . .

l d.

At least once each REFUELING INTERVAL by verifying that the batteryca 1

l the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test; i e. At least once per 60 months by verifying that.the battery capacity -is l

i. at least 80% of the manufacturer's rating when subjected to a

i. performance discharge test. Once per 60-month interval this j performance discharge' test may be performed in lieu of the battery

[ service test required by Specification 4.8.2.1d.; and 4

i f. AtleastonceeachREFUELINGINTERVALbygivingperformancedischargel tests of battery capacity to any battery that shows signs of j degradation or has reached 85% of the service life expected for the 4 application. Degradation is indicated when the battery capacity ,

j drops more thn 10% of rated capacity from its average on previous i perfornance tests, or is below 90% of the manufacturer's rating.

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L NILLSTONE - UNIT 3 3/4 8-12 Amendment No. JJ, 77, Jpp, 0380 i

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ELECTRICAL POWER SYSTENS 3/4.8.4 ELECTRICAL E0VIPNENT PROTECTIVE DEVICES CONTAINNENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION 3.8.4.1 All containment penetration conductor overcurrent protective devices shall be OPERABLE.

APPLICABILITY: N0 DES I, 2, 3, and 4.

ACTION:

With one or more of the containment penetration conductor overcurrent protec-tive device (s) inoperable:

a. Restore the protective device (s) to OPERABLE status or deenergize the circuit (s) by tripping the associated backup circuit breaker or racking out or removing the inoperable circuit breaker within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , declare the affected system or component inoperable, and verify the backup circuit breaker to be tripped or the inoperable circuit breaker racked out or removed at least once per 7 days thereafi.sr; or

b. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIRENENTS 4.8.4.1 All containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:

a. At least once each REFUELING INTERVAL: l

1) By verifying that the medium voltsge (4-15 kV) circuit breakers are OPERABLE by selecting, on a rotating basis, at least 10% of the circuit breakers of each voltage level, and performing the following:

a) A CHANNEL CALIBRATION of the associated protective relays, b) An integrated system functional test which includes simulated automatic actuation of the system ard verifying that each relay and associated circuit breakers and control circuits function as designed, and l

l NILLSTONE - UNIT 3 3/4 8-19 Amendment No. 77, 77, JJ 0391

ELECTRICAL POWER SYSTEMS l

N0 TOR-0PERATED VALVES THERNAL OVERLOAD PROTECTION LINITING C0ISITION FOR OPERATION- ,

i 3.8.4.2.1 Each thermal overload r,rotection bypassed only under accident conditions for safety-related motor-operated valves shall be bypassed by an OPERABLE bypass device integral with the motor starter.

APPLICABILITY: Whenever the motor-operated valve is required to be OPERABLE.

ACTION:

With the thermal overload protection for one or more of the above required-valves not bypassed under conditions for which it is designed to be bypassed,

, restore the inoperable device or provide a means to bypass the thermal over-load within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or declare the affected' valve (s) inoperable and apply the

appropriate ACTION Statement (s) of the affected system (s).

SURVEILLANCE REQUIREMENTS 4.8.4.2.1 The thermal overload protection for the above required valves shall be verificd to be bypassed by the appropriate accident signal (s) by perfor-mance of a TRIP ACTUATION DEVICE OPERATIONAL TEST of the bypass circuitry-during COLD SHUTDOWN or REFUELING at least once each REFUELING INTERVAL. l l

l 1

4 NILLSTONE - UNIT 3 3/48-21 Amendment No. 77. JJ.

Met

ELECTRICAL POWER SYSTEMS l

MOTOR-0PERATED VALVES THERMAL OVERLOAD PROTE LIMITING CONDITION FOR OPERATION 3.8.4.2.2 conditions for safety-related motor-operated valves sha .

APPLICABILIT_Y:

ACTION:

Whenever the motor-operated valve is required to be OPERABL .

With the thermal overload protection for one or more of the above required valves inoperable, bypass the inoperable thermal overload within restore the declare theaffected inoperable valve thermal overload (s) inoperable toapply and OPERABLE the appropriat status with Statement (s) for the affected system (s). e ACTION SURVEILLANCE REQUIREMENTS 4.8.4.2.2 be demonstrated OPERABLE at leastoonce owing a each REFU maintenance of on a representative sam the motor starter by the performance N lof a CHANN above required valves. ple of at_least 25% of all thermal overloads for the MILLSTONE 0392 - UNIT 3 3/4 8-22 Amendment No. 77, JJ.

. Docket No. 50-423

, 315245 4

4 i

{ Attachment 3 l 4

Millstone Nuclear Power Station, Unit No.-3 4 Description of the Proposed Technical Specification Changes i 4 . Electrical Power Systems l l

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1 June 1995 i

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l l 3U.S. Nuclear Regulatory Commission l B15245/ Attachment 3/Page 1 L June 14, 1995-i, .

!. Millstone Nuclear Power. Station, Unit No. 3 l- Description of the Proposed Technical j Spooifioation Changes i

1 l Introduction I On June 7, 1995, Millstone Unit No. 3 began- operating 'on a

! nominal 24-month fuel cycle instead of the previous 18-month; fuel

cycles. To take advantage of this longer fuel cycle, Northeast

Nuclear Energy Company (NNECO) is proposing to. modify the i frequency of a' number of the surveillance requirements existing

! in the Millstone Unit No.-3 Technical Specifications. The

proposed changes are' described below:

i

! 1. Surveillance Section 4.8.1.1.1.b. Offsite Power Sources i

l The proposed change to ' Section _4.8.1.1.1.b will extend the -

l 1 frequency for the.offsite. circuit testing ~from at least once per.18 months to at least once each refueling interval. In addition, the: words "during shutdown" have been'ideleted.

1 Because the terms " Hot and Cold ~ Shutdown" are defined in the I technical specifications as operating modes or4 conditions,

) the added restriction to perform certain surveillances during l shutdown may be misinterpreted. -In Generic: Letter (GL) j 91-04, the NRC has concluded that' the technical specifications need not restrict surveillances as'only being-

' performed during shutdown. However, the NRC indicated that

!- if the performance of ' a refueling interval- surveillance

during plant operation would adversely affect ' safety, the

. licensee should postpone the surveillance until the unit is

[ shut down for refueling or is in a condition or. mode that is

consistent with safe conduct of that surveillance.

l 2. Section 4.8.1.1.2.a. Diesel Generator 1

[ The proposed change to Section 4.8.1.1.2.g will increase the- I L interval for testing the diesel generators from 18 months to I a maximum of 30 months (i.e., 24 months +25%) . In addition, the words "during. shutdown" have been deleted. Refer to the I

j. previous paragraph for' additional ~infornation concerning'this

, deletion.

~

3. Section 4.8.2.1. DC sources. Surveillance Reauirements 1 Surveillance Requirement'4.8.2.1 verifies the operability of

['; each 125-volt battery bank and charger-by~ performing various tests at various intervals. Surveillance Requirement- i i 4.8.2.1.d verifies that each battery -bank meets - the design l r duty cycle at least once per 18 months. .The battery

{ performance discharge test (i.e., surveillance Requirement

! 4.8.2.1.f) is performed at least once per 18 months. This i

U.S. Nuclear Regulatory Commission l B15245/ Attachment 3/Page 2 June 14, 1995 test is to determine if the rating of the battery in the -

as-found condition is holding up. This: test is also used to determine if the battery is in -a- degraded _ condition.

Surveillance Requirement 4.8.2.1.c verifies the operability _

of _ the battery banks and the battery charges at least once '

per 18 months. NNECO proposes to : extend the frequency of Surveillance Requirements 4.8.2.1.c, 4.8.2.1.d, and 4.8.2.1.f from at least once . per _ 18. months to . - at- -least once each refueling (i.e., 24 months). In addition, the phrase "during shutdown" in Surveillance Requirements ~4.8.2.1.d, 4.8.2.1.e, and 4.8.2.1.f is being.- deleted. - Because the terms " Hot shutdown" and " Cold Shutdown" are defined' in the Millstone Unit No. 3 Technical Specifications as operating modes - or conditions, the - added restrictions' to ' perform certain surveillances during shutdown may _ be misinterpreted. This change is consistent with tho' recommendations of GL 91-04.

No changes are proposed to the Bases Section.

4. Section 4.8.4.1. Containment Penetration Conductor Overcurrent Protective Devices. Surveillance Reauirement I Surveillance Requirement 4.8.4.1.a' verifies the operability-of the containment penetration conductor overcurrent protective devices at least onceL per 18 months. -NNECO proposes to extend the frequency of _ the' surveillance Requirement 4.8.4.1.a from at least once per.18 months to at least once each refueling interval (i.e., 24 months). .No changes are proposed to the Bases section.

5. Section 4.8.4.2.1. Motor-onerated Valves Thermal Overload Protection. Surveillance Reauirenc %

Surveillance Requirement 4.8.4.2.1 requires that the' thermal overload protection for the required motor- operated valves (MOVs) shall be. verified to be bypassed by the appropriate accident signal (s) by performance of a trip actuating. device operational test of the bypass circuitry at least once per 18 months. NNECO proposes to extend the frequency of Surveillance Requirement 4.8.4.2.1 from at least once per 18 months to at least once each refueling (i.e., 24 months).

No changes are proposed to the Bases section.

6. Section 4.8.4.2.2. MOVs Thermal Overload Protection Mot' Bvnassed. Surveillance Recuirement surveillance Requirement 4 8.4.2.2 requires that the' thermal overload protection for the required valves shall be demonstrated operable at least once per 18 months by the performance of a channel calibration of a representative

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U.S.. Nuclear Regulatory Commission B15245/ Attachment 3/Page 3 June 14, 1995 I

sample of at least 25% of all thermal overload for the '

required valvet;., NNECO proposes to extend the frequency of-Surveillance ' Requirement 4.8.4.2.2 from - at least once per 18 months to at least once each refueling-(i.e., 24 months).

No changes are proposed to the Bases Section.

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L Docket No. 50-423 B15245

. Attachment 4 1

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I Millstone Nuclear Power Station, Unit No. 3-Proposed Revision to Technical. Specifications 24-Month Refuel Cycle El&ctrical Power System a

Safety Assessment and Significant Hazards consideration for:- l 4

I. Safety Assessment and.' Significant Hazards Consideration for~ Changes to:-

AC Sources Operating.(Offsite Power' Supply and Diesel -

Generators)

DC Sources Operating _

i Containment Penetration Conductor .Overcurrent Protective Devices Motor-Operated Valves Thermal Overload Protection June 1995 4 _ _

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i U.S. Nuclear Regulatory Commission j B15245/ Attachment 4/Page 1 1 June 14, 1995 i

i Nillstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical specifications a 24-Nonth Refuel Cycle 1 Electrical Power System j safety Assessment and significant Nasards Consideration 1

3

} I. BAFETY ASSESSMENT AND SIGNIFICANT NASARDS CONSIDERATION FOR ;

CNANGES TO AC SOURCES OPERATING - (OFF8ITE -POWER SUPPLY AND l j, DIESEL GENERATORS) l

! l i

1 l Backaround l j On June 7, 1995, Millstone . Unit No.f3 began operating on a 1 nominal' 24-month fuel cycle instead of the previous 18-month j l cycles. To be consistent-with this longer fuel cycle, Northeast '

! Nuclear Energy Company (NNECO)- is proposing to modify the l

frequency of a number of surveillance requirements . existing ' in

the Millstone Unit No. 3 Technical Specifications.. The, safety 4 assessment and significant hazards connideration for the proposed ;

j~ changes to Sections 4.8.1.1.1.b (offsita power supply) and i

4.8.1.1.2.g.1 through 13 (onsite power supply) are described j below. In the near future, NNECO will' be proposing additional l l changes to the Millstone Unit No. 3 Technical Specifications to j 3

! prepare for the conversion to nominal 24-month fuel cycles. Each i

) of these submittals will contain evaluations that are independent )

3 and which stand alone.

j A. OFF8ITE POWER SUPPLY, SURVEILLANCE REQUIRENENT 4.8.1.1.1.b Safety Assessment

. Surveillance Requirement 4.8.1.1.1.b verifies the operability

{ of the offsite power circuits by transferring '(manually and j automatically) unit power supply from the normal circuit to

the alternate. circuit once per 18 months. NNECO proposes to 1 extend the frequency of Surveillance Requirement 4.8.1.1.1.b j from at least once per 18 months to at least once each j refueling interval (i.e., nominal 24 months) . In addition, j the words "during shutdown" have been deleted. Because the i terms " Hot shutdown" and " Cold Shutdown" are defined in the i Millstone Unit No. 3 Technical Specifications as operating modes or conditions,-the added restriction to perform certain surveillances during shutdown may be misinterpreted. In

' Generic Letter (GL) 91-04, the NRC has concluded that , the 4

technical specifications need not restrict surveillances as j only . being performed during shutdown. However, the NRC

indicated that if the performance of a ' refueling' interval l surveillance during: plant operation would adversely affect safety, the licensee should postpone the surveillance until

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h U.S. Nuclear Regulatory Commission i B15245/ Attachment 4/Page 2 June 14, 1995

]

< the-plant-is shut down for refueling, or is in a condition or 2 mode that -is - consistent with safe conduct of .that i surveillance. NNECO agrees with the NRC in its conclusion.

i NNECO believes that the- deletion of- the_ words "during i shutdown" has no safety impact as long as the surveillances j are conducted at any. mode or condition.without-impacting the j plant safety.

I i The proposed change to Surveillance Requirement 4.8.1.1.1.b

does not alter the intent or method by which the surveillance j is conducted, does not involve any physical changes to the -

plant, doos not alter the - way any structure, system, or l compor.ent functions, and does not modify the manner in which-i the plant is operated. As such, the proposed change to the

} frequency of Surveillance Requirement 4.8.1.1.1.b will not i degrade the ability .of the plant's normal offsite - power

! supply circuit or alternate circuit to perform its intended 4

-function.

[

i Equipment performance over the last four operating cycles was evaluated to determine the. impact of extending-the frequency

) of Surveillance Requirement 4.8.1.1.1.b. This evaluation 4 included a- review of surveillance results,' preventive i maintenance, and' corrective maintenance.. The 4160 volt j switchgear is Class 1E with components of high reliability

[ and a long mean time to failure. The manual and automatic j transfer of the offsite power supply is not time critical in that there is no drift or calibration of the components j involved. No failures were observed during the last four t operating cycle surveillance tests. A review of maintenance

! history and failure reports have not revealed any adverse l conditions that would disable the bus transfer as designed.

l' In addition, surveillance Requirement 4.8.1.1.1.a verifies the operability of the offsite . circuits (normal and

, alternate) by verifying correct breaker alignments and j indicated power availability at least once per 7 days.

i Based on the above evaluation, there is a reasonable

assurance that the frequency _ of Surveillance Requirement 4.8.1.1.1.b can be extended from at least once per 18 months to at least once each refueling interval (i.e.,

nominal 24 months).

! A probabilistic risk assessment (PRA) evaluation. of the proposed surveillance frequency change . concluded that there

is no measurable impact on plant risk.

Significant Easards Consideration 1

j NNECO has reviewed the proposed change in accordance with

10CFR50.92 and has concluded that the change does not involve

l U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 3 June 14, 1995 a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed change does not involve an 1 SHC because the change would not:

1. Involve a significant increase in the . probability or consequences of an accident previously evaluated.

The proposed change to Surveillance Requirement 4.8.1.1.1.b extends the frequency. for demonstrating operability of the offsite circuits by transferring the (manually and automatically) plant power supply from the normal circuit to the alternate circuit. The proposal would - extend the frequency' from at least once .per IP months to at least once each refueling (i.e., nominal 7,4 months) and delete the words "during shutdown."

The proposed change. to Surveillance Requirement

'4.8.1.1.1.b does not alter the intent or the method by which the surveillance is conducted. In addition, the acceptance ' criterion for the. surveillance is unchanged.

As such, the proposed change to the frequency- of Surveillance Requirement 4.8.1.1.1.b will not degrade the ability of the normal circuit or the alternate circuit of the- offsite power supply to perform its intended function.

An evaluation of past surveillances and preventive i maintenance has concluded that decreasing the surveillance frequency will have little impact on safety.

Since the proposed change only affects the surveillance frequency, the proposed . change cannot affect the probability of any previously analyzed accident. While the proposed change can . lengthen the interval between surveillances, the increase --in the interval- has been evaluated and it is concluded that there is no significant impact on the availability of the . offsite power supply normal or alternate circuit-to function, and consequently,.there is no impact on the consequences of any analyzed accident.

2. Create the possibility of a new or different - kind of accident from any accident previously evaluated.

The proposed- change to Surveillance Requirement 4.8.1.1.1.b does not modify the design or operation of any plant system. The proposed change does not alter the intent or method by which the surveillance is conducted.

other than increasing the interval from 18 months to 24 months (nominal). The proposed- change _does' not introduce - a new failure mode. Therefore, the proposed

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U.S. Nuclear' Regulatory Commission 4 B15245/ Attachment 4/Page 4 ,

j- June 14, 1995 l'

< change does not create 'the possibility of a new or

! -different kind of accident from any previously analyzed.-

, 3. Involve'a significant reduct' ion in n margin of safety.

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{ Changing the. frequency of Survoillance. Requirement' j 4.R.1.1.1.b from.at least once per 18 months to at least F once per refueling interval does not change the basis for

frequency. . The proposed change does not alter the intent-j or method by which the surveillance is . conducted, does j not involve any. physical changes to the plant,.does..not i alter the way any structure,- system, or component i functions, and does . not modify the ' manner -in which the i plant is operated. Further, the. previous history of-

[

reliability of the offsite normal and alternate circuits provides assurance that the change will not affect the j reliability of the offsita circuits. Therefore, the-

proposed change - has no. impact. on the margin of - the

safety.

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[ B. BURVEILLANCE REQUIREMENTS 4.3.1.1.2.g.1 through j 4.8.1.1.2.g.13 1

l_ safety Assessment f

l- The emergency AC power source consists of two 4.16 ~ kV, 3-

phase, 60 Hz, diesel engine driven synchronous generators.

l The'. capacity of each diesel generator (DG) is rated 4986 kW -

1- continuous and 5335 kW (2,000 hr). Each DG .is capable of

{ automatienlly starting and socelerating to the rated speed, '

j and subsequent loading of all engineered safety features

j. (ESP) and essential shutdown loads, in the required sequence, j within minimum time intervals established by the accident '

, analysis. The capacity of one DG is sufficient to meet the

! ESF demand. The DGs are started on a loss of-power (LOP) to '

!- the respective 4.16 kV bus to which each DG is connected, by j a safety injection rignal (SIS), or by a containment

j. depressurization act*ation (CDA) signal, or- manually. ,

! Sequential loading is. achieved by a DG load sequencer. The l loading sequence prevents system instability during motor starting. A fast responding exciter and a voltage regulator ensure quick voltage recovery after any load step.

i i The safety function of the DG is to provide electrical power j for the operation of the ESF and safe shutdown equipment during and follewing the shutdown of the plant when the j

offsite power sup)y'is not available.

} The DG aust have the capability to (1) start and accelerate a i number of large loads (motors) in rapid succession,

. and (2) to supply power continuously to the equipment needed i

t U.S. Nuclear-Regulatory Commission B15245/ Attachment 4/Page 5 June 14, 1995 to maintain the plant in a safe condition, if an extended loss of offsite power occurs.

The proposed . change- to Surveillance Requirements-4.8.1.1.2.g.1 through '4.8.1.1.2.g.13 will increase the interval between- surveillance- from at least. once -per 18 months to at' least once a refueling -interval (i.e., ,

nominal 24 months). In addition, the words "during shutdown" i have been deleted. Because the terms " Hot Shutdown and " Cold Shutdown" are defined in the Millstone Unit No. ' S Technical- i Specifications as operating modes or conditions, the added ;

restriction to perform certain.surveillances'during shutdown

may be misinterpreted. In GL 91-04, the NRC has-concluded ,

that the technical specifications need 'not. restrict ;

surveillances as only being performed. during shutdown. '

However, the NRC indicated that . if the performance of a refueling interval, surveillance during plant operation would adversely affect safety, the -licensee should postpone the

surveillance until the plant is shutdown for refueling ~or is l in, condition or mode that is consistent with safe conduct of I that taurveillance. 'NNECO agrees -with the NRC that the l 4

deletion of the words "during shutdown" has no safety impact as long as the surveillance is conducted at any mode or condition without-impacting the plant safety.

The proposed change to Surveillance . Requirements j 4.8.1.1.2.g.1 through 4.8.1.1.2.g.13 does not. alter the intent or method by which the~ surveillance is' conducted, does not involve any physical changes to the plant, does not alter ;

the way any structure / system or component. functions, and does !

not modify the manner in which the plant .is operated. . Ac {

such, the proposed change to the frequency of Surveillance l Requirements .4. 8.1.1. 2.g.1 through- 4. 8.1.1. 2.g.13 will ' not ;

degrade the ability of wch DG to perform its intended I function.-

Equipment (i.e., DG and its supporting components)

, performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of

! Surveillance Requirements 4.8.1.1.2.g.1 through 4.8.1.1.2.g.13. This evaluation included a review- of surveillance results, preventive maintenance and frequency, and ' type of corrective. maintenance. The , summary of the evaluation for each of- Surveillance. Requirements 4.8.1.1.2.g.1 through 4.8.1.1.2.g.13 is provided below:

A PRA evaluation of the proposed surveillance frequency change concluded that there is no measurable impact on plant risk.

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l U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 6 June 14, 1995 surveillance Reauirement 4.s.1.1.225.1. DG Inanection ]

surveillance Requirement 4.8.1.1.2.g.1. requires that the DG be inspected in accordance with the manufacturer's recommendations. Maintenance Procedura SP 3712K. " Emergency Diesel Generator Surveillance Inspection" contains specific-inspection tasks that are performed on the' diesel engine'in order to satisfy Surveillance Requirement 4.8.1.1.2.g.1.

NNECO prnposes to extend- the frequency of Surveillance

Regairement 4.8.1.1.2.g.1 from at least once per 18' months to l at least cnce each refuding interval- (i'.e., nominal 24 months). The impact of the proposed extension in the surveillance. inspection interval on the DG performance during an LOP has been reviewed. .Each inspection task was reviewed, past experience was discussed with the maintenance and system engineers, and possible consequences of extending the ,

particular task were evaluated. Alternative indirect methods

. available through plant trending data were also identified ,

and theirl suitability as a substitute for .the actual !

inspection in predicting engine part deterioration or pending failure were also evaluated. Existing engine ' monitoring programs, i.e., start time trending, ' cylinder temperature trending, and monthly lube oil analyses provides indirect :

indication of possible engine ' problems. The data- is collected during monthly surveillance runs. Start times are trended and are used for an early; detection of engine problems, especially the starting air system. Early detection of a detericroting Engine condition is also available through evaluation of the lube oil analyses results. Lube oil samples are taken at two locations:-~ the rocker arm area and from the engine sump. Lube oil'is tested for water content which indicates an internal engine leak.

l Metal. particle contamination of the lube oil is an indication of excessive parts wear, or bearing problems if tin and/or lead are detected. The tests are performed monthly. Also, cylinder temperatures during monthly engine runs are collected and reviewed by the maintenance engineer. Any deviation from specified temperature is evaluated and action taken to correct the problem (the' lower than required cylinder temperature indicates malfunction of the injection nozzle or injection pump) . Additionally, NNECO has decided

, to implement a supplemental inspection in order to better evaluate engine performance. Maintenance personnel on a six-month basis will measure cylinder firing pressure and evaluate the results. This will allow evaluation of the l engine timing.

a The past performance of the engine has always been satisfactory. With limited numbers of additional hours of diesel operation, no deterioration of the EDG equipment is expected. The total number of hours the engine operates l ,

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j U.S. Nuclear Regulatory Commission i B15245/ Attachment 4/Page 7 l . June 14, 1995 ,

l j between refueling outages .is approximately 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months (for.an j 18-month fuel cycle with 25% allowance per Specification j 4.0.2, maximum 22 months' tests, approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months each).

t An increase of the fuel cycle by . a maximum of 8 months

[ (nominal 24-month cycle with 25% allowance per Specification 4.0.2) will result in only 8 additional monthly tests, each j of approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months duration resulting in a total engine a run time of approximately 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months . This -is' considered

! insignificant and no changes in the engine condition should

{ occur.

i i Based on the above evaluation, 't i is concluded that _the ongoing engine monitoring programs and monthly engine tests provide adequate information about the engine condition. The j proposed change has no adverse - affect on the diesel engine i operation and reliability, and therefore, the . proposed j extension has a minimal impact on safety.

t j A review of the corrective and preventive maintenance

_ activities indicates that the. proposed extension will not i

, cause deterioration in the system condition or performance. l t

NNECO 'has also contacted: the engine manufacturer [ Colt /

Fairbanks- Morse; (FM)] for their. recommendation on the proposed surveillance inspection extension. FM ~ provided a j recommendation which, in addition to a normal surveillance j inspection ever'; 24 months, proposes the following additional j activities:

i i 1. At 12 months time, FM would review engine operational data, lube oil analyses, and other reports of maintenance activities (repairs or modifications) and generate an

" engine health report."

l 2. A mini-inspection of the engine (1-2 day inspection) 1 between the 12th and 18th month to determine the

! condition of components which-cannot~be evaluated;by the l above data review.

l Both aspects of the proposal were reviewed by NNECO, and

NhECO has ' concluded that item one of the proposal is-l fulfilled through our internal review of lube oil. analyses,.

j starting times, cylinder temperatures, and rack setting data.

! It is our opinion.that the NNECO maintenance organization has i considerable experience with the FM diesel-generators to be 1

able to interpret and analyze this data. Should a situation arise that this expertise may not be sufficient, we will 3 consult with FM in this specific area. .It has always been

our position that if additional vendor expertise is needed to resolve- a specific problem, this expertise is rapidly l

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[ U.S. Nuclear Regulatory Commission j B15245/ Attachment 4/Page 8 j June 14, 1995 ,

obtained. The vendor 'has, in NNECO's opinion, always I j- provided excellent support when required.

I Additionally, we have decided to implement a supplemental inspection in order to better evaluate engine' performance.

. Currently only rack settings and temperatures are monitored-l during diesel surveillen e runs. Maintenance on a'six-month basis will measure cylinder firing pressure and evaluate the results. This.will allow an evaluation of.the engine timing

(retard or advanced) and fuel mixture (too rich or too lean). ,

Regarding item "2" of the FM proposal, based on our review of test and trending data NNECO concluded that a mid-cycle inspection is not warranted at this-point in time. Should-our trending data or inspection results indicate a need for' such an inspection in the future, we would perform them until' our confidence ~is restored. Our position is that a mid-cycle inspection would place one of the generators in an inoperable.

status for one to two days. Work performed under LCO . time '

limits (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months per technical specification) increases the risk of equipment damage and, in our opinion, the inspection

benefits do not offset the risk.

PRA Analysis j There are two possible plant conditions for performing'a mid-

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cycle ' diesel inspection. One is operating under a 72 hour-Limiting condition for Operation (LCO). The second option is ,

to shut down the plant for the purpose of performing the l inspection.

A PRA evaluation of the risk associated with the mid-cycle inspection of the DG showed that the first proposed scenario (i.e., performing inspection under 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO condition with one DG out of service), will result in increasing the 4 instantaneous core melt frequency (CMF) by a factor of '

approximately three. The instantaneous increase in CMF can be tolerated only when there is a pressing operational need ,

with other benefits that justify this risk. The second !

proposed scenario assumes plant shutdown for the purpose of performing the inspection. The PRA evaluation concluded that the gain in DG reliability does not justify the risk associated with exposing plant equipment to the changes in state.

Based on the above evaluation, the proposed change has a minimal impact on safety.

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j U.S. Nuclear-Regulatory Commission j B15245/ Attachment 4/Page 9

. June 14, 1995 I ' surveillance Beauirements 4. s.1.1.2.a.2 and 4.a.1.1.2.a. 3, DG

. Load Reiection Test 4

1 Surveillance Requirements' 4.8.1.1.2.g.2 and 4.8.1.1.2.g.3 j

verifies that the DG maintains voltage and frequency within I the limits when subjected to part load and. full load ~ l l rejection and that it does not trip when the output breaker !

is. opened while carrying full load at least once per

18 months. NNECO proposes to extend the frequency of ;

Surveillance Requirements 4.8.1.1.2.g.2 and '4.8.1.1.2.g.3 i from at least once per 18 months to at least - once each refueling interval- (i.e. , nominal 24 months) . The equipment

! covered under the surveillance requirements. are the engine j governor and-the voltage regulator.

Surveillances for part load rejection capability in the scope l of Surveillance Requirement 4.8.1.1.2.g.2 are ~ covered by

Surveillance Procedures SP 3646B.20.1 -and SP 3646B.20.2.

Surveillances for full load rejection capability in the scope i of Surveillance Requirement 4.8.1.1.2.g.3 are ' covered by l Surveillance Procedures SP 3646B.10-1 and SP 2646B.11-1.

!- Based on the review of the past surveillance test results of f the DG load rejection tests over the last four operating

cycles, it can be concluded'that the overall performance of lj. the DG was very good with only one failure noted due to a deficiency in the test procedure. .The subject p;ocedure was j corrected. and the . retest was successful. The review of j corrective maintenance and preventive maintenance records for

the voltage regulator and engine governor _ (performance of i these two pieces of equipment is critical to diesel generator j atility to accept load rejection while maintaining voltage i within the acceptance criteria) over the last four operating cycles indicated that there is no indication that the j j proposed extension could cause deterioration in the system j condition or performance. Based on the above. evaluation, the l

proposed change has a minimal impact on safety.

j surveillance neauirement 4.s.1.1.2.a.4. DG Loss of Power

!- surveillance i Surveillance Requirement 4.8.1.1.2.g.4 verifies

deenergization of emergency buses ' and that the DG starts on

an' auto signal, energizes emergency buses with permanently j connected' loads within 11 seconds, and maintains steady state ,

voltage'and frequency in response'to a simulated LOP signal I i at least once per 18 months. NNECO proposes to extend the frequency of Surveillance Requirement 4.8.1.1.2.g.4 from at i least once per 18 months to at least once each refueling interval (i.e., nominal 24 months). The equipment covered-j_ under this surveillance requirement is

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U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 10 June 14, 1995 3EGS*EG-A - Diesel Generator 'A'

.3EGS*EG-B - Diesel Generator 'B' Surveillance for LOP in the' scope of Surveillance Requirement 4.8.1.1.2.g.4 are covered by Surveillance Procedure SP 3646A.15-1 for . Train 'A' DG and SP 3646B.16-l' for Train

'B' DG. There were six LOP surveillances on each of the DGs.

The only failure of the DG ' occurred. on Train 'B' in March 1987 when the engine failed to reach its full speed within i 10 seconds. The starting time - limit was exceeded' by only O.1 second. From the safety perspective, this failure'is not ~

significant as the engine could have performed its intended: j function. '(It - is noted that ' the test acceptance criterion >

was later revised from a maximum of 10 seconds to a maximum !

of 11 seconds, and the current criterion is 11 seconds in the i technical specification and in the safety analysis.) All l other surveillances met the acceptance criteria and no l problems were noted.

Corrective maintenance records for the DG were reviewed. .The review concluded that even though there were a large number of maintenance activities performed on the DG, none of_them indicated' any deterioration in the engine's ability to perform its functions.. One of. the major preventive maintenance requirements for the DG which is performed at an 18-months frequency includes an engine overhaul. This activity 'is described- in Surveillance Requirement ,

4.8.1.1.2.g.1 above.

Based on the above evaluation, the proposed change has a l

, minimal impact on safety.

Surveillance meauirement 4.s.1.1.2.c.5. DG Autostart on an ESF Signal Surveillance Requirement 4.8.1.1.2.g.5 verifies that the DG starts automatically on an ESF test signal without loss of power and attains the rated voltage 'and frequency within 11 seconds of the start signal at least once per 18 months.

NNECO proposes to extend the frequency of Surveillance Requirement 4.8.1.1.2.g.5 from at least once per 18 months to at least once ' each refueling interval (i.e., nominal 24 months). This surveillance requirement is covered by surveillance Procedure SP 3646A.21.1 and SP 3646A.21.2. The equipment covered under this surveillance is DG 'A' and DG

'B.' Based on the review of the past four operating cycle surveillance test results, it can be concluded that .the overall performance of the DG has been very good. In addition, monthly surveillance testing. (Surveillance Requirement 4,.8.1.1.2.a.5) of the DG exercise the same. logic relays and control circuits that start the DG for all modes y y,_.,y, .,rm. +,.-,,.,.mi

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. B15245/ Attachment 4/Page 11 j -June 14, 1995

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of operation. Also, there have been no corrective or preventive maintenance required -for the components covered j under this surveillance.

t i Based on tha above evaluation, the proposed change . has a j minimal impact on safety.

4

! surveillance meauirements 4.s.1.1.2.a.s. 4.s.1.1.2.n.7.

j_ 4. s .1.1. 2 . a. a . and 4.a.1.1.2.a.9. DG LOP and EsF &ctuat:.on ,

i 24-Hour Load Run. Auty Connected Load and Restoration i

! Surveillance Requirements 4.8.1.1.2.g.'6 through 4.8.1.1.2.g.9 j verifies (1) the DG's ability to start 1 and load ESF loads

under simulated accident conditions (e.g., LOP in conjunction

with an ESF test signal), (2) the DG's hot restart capability

, after 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run test, (3) verification of the i nondestructive trips-signal'are bypassed to allow the DG.to

continua running on a-LOP concurrent with a SIS signal,'and-l (4), the DG's capability to synchronize with the offsite power j source, . transfer the bus load, and . restore the DG to the'

standby condition. NNECO proposes to extend the frequency of

! Surveillance Requirements 4.8.1.1.2.g.6 through 4.8.1.1.2.g.9-from at least once per 18 months to at least once each

{ refueling interval (i.e., nominal 24 months). The j- surveillance requirements are covered by the procedures

SP 3646A.15-1, SP 3646A.16-1,. SP 3646A.17-1, and

! SP 3646A.18-1. Based on the review of the past four operating cycle surveillance test results, it can be

! concluded that the overall performance of the .~ DG was very 1

good. -

l- In' addition, the monthly DG surveillance (i.e., Surveillance i Requirement 4.8.1.1.2.a.5) verifies .the. operability of the DG to start and maintain the correct. voltage and frequency.

! The l

! ESF actuation system under voltage circuits are verified monthly (Surveillance Requirement 4.3.2.1,. Table 4.3-2, Functional Unit 8, LOP) which performs a functional check of

{ the relays that monitor the emergency bus voltage. 1 1

! Based on this evaluation, the proposed change has a minimal j' impact on safety.

{ surveillance Beauirement 4.a.1.1.2.a.10. sis Transfer ot_De from Test to standby i

i The safety injection signal causes a DG running in,the test j mode and connected to its AC bus to return to the standby j mode and maintain the emergency bus energized fror, the

_ offsite power supply.

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! U.S.' Nuclear Regulatory Commission

, B15245/ Attachment 4/Page 12

[ June 14, 1995

[- Surveillance -Requirement 4.8.1.1.2.g.1'O verifies that- a L simulated SIS returns a running DG in the~ test mode to stand-by j operation arid the emergency loads remain energized with j; . the offsite power source. NNECO proposes to extend the j frequency of Suru illance Requirement 4.8.1.1.2.g.10 from at-

least once per - 18 sonths . to at. least once each refueling l . interval (i.e.,'24 months). . Based on the review of the past i four - operating cycle ' surveillance t e s t. r e s u l t s , J i_t can be

! concluded that the overall performance of the DG was very l good. The components used in the DG control circuits are i highly reliable having a long mean time.to failure. Monthly j testing of the DG operate the same.. logic relays and control j circuit that switch.the DG.to the; standby mode. There have

been no corrective or preventive maintenance required on the 1 SIS to the DG's control circuits.

1 l l Based on this evaluation, the. proposed > change'has a minimal

? impact on safety.

Surveillance Reauirement 4.s.1.1.2.a.11. DG Fuel Oil System Transfer capabilities The fuel oil transfer system provides fuel oil to the DG for operation under all plant operating conditions'and during all' .

design basis accidents. There is a separate fuel-oil storage and transfer flow path for each DG. Each flow path' consists of a fuel oil' storage tank, two 100% capacity ~ fuel' oil transfer pumps and strainers, a day tank, and piping to each .

respective.DG. Only one primary pump is required to transfer i fuel oil from a storage' tank to the day. tank. A backup pump is available if the primary pump should fail. An interconnection with two normally. locked-closed valves between _ the two DG ' fuel oil supply headers is provided to facilitate the use of either tank to supply either DG. One pump on each tank is arranged to allow transfer from the 'A' electrical bus to the 'B' electrical bus, or vice versa, by means of a manually operated transfer switch. ,

surveillance Requirement 4.8.1.1.2.g.11 verifies that the fuel transfer pump can transfer fuel from each fuel storage ,

tank to the day tank of each DG via the installed cross- .i section lines. This ensures that either tank is able' to j supply either DG. NNECO proposes to extend the frequency of <

Surveillance Requirement 4.8.1.1.2.g.11 from at least once per 18 months to at least once each refueling (i.e., nominal 24 months). The components covered by Surveillance Requirement 4.8.1.1.2.g.11 are listed in Table 1.

Surveillances for the DG fuel transfer system covered by Surveillance Requirement 4.8.1.1.2.g.11 are performed per Surveillance Procedures SP 3646.6-1 for Train 'A' and

U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 13 June 14, 1995 1

SP 3646B.6-2 for Train- "B." There have 'been five I surveillances performed'on Train 'A' and five on Train 'B.'

All surveillances met the acceptance criteria and no problems ;

were noted.

A review of the corrective maintenance records indicates that

!- there were some design deficiencies in circuit breakers manufactured by Telemecanique, and some- problems with '

accelerated aging of Model J10 relays also manufactured by Telenecanique. The deficient equipment was replaced. It is '

noted that these maintenance tasks could be performed with the plant on line.

Review of preventive maintent.nce indicated only two tasks ~

scheduled. on an 18-month basis. These . include a periodic i calibration of the discharge. flow instrument for the fuel oil transfer pump. This is covered under Surveillance 4

Requirement 4.8.1.1.2.g.1. Tha other one, the fuel oil

, strainer pressure differential a bra calibration, could be performed with the plant on line.

Based on this evaluation, the- proposed change'has minimal <

impact on safety.

surveillance meauirement 4 . s .1.1. 2 . tr .12 . Diesel Generator sequencer hotuation Timer Test The diesel sequence timers are used to add loads to the DG bus in discrete steps and proper order.to avoid overloading the engine. The LOP and load sequence method is' described in the Millstone Unit No. 3 FSAR, Section 8.3. The diesel sequencer actuation timer tests are performed to ensure that the timer intervals have not. changed from the desired value and have an accuracy within 10 percent of the design setting.

Surveillance Requirement 4.8.1.1.2.g.12 verifies that the automatic load sequence timer is operable with the interval between each load block within i 10 percent of its design interval. NNECO proposes to extend the frequency of

Surveillance Requirement 4.8.1.1.2.g.'12 from at least once per 18 months to at least once each refueling interval (i.e., '

nominal 24 months). The equipment covered under 'this 3

surveillance is the DG sequencer panel. 'A' and the DG sequencer panel 'B.'

Review of the past surveillance results indicate that the timing intervals to be consistent and within the minimum resolution of 0.1 second. Review of maintenance history has indicated that there is no indication that the proposed extension could cause deterioration in the load sequencer condition or performance.

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i U.S. Nuclear Regulatory Commission-

, B15245/ Attachment 4/Page 14 j June 14, 1995 1

! Based on the above evaluation', thers is a reasonable l assurance that. the frequency of Surveillance Requirement

{ 4.8.1.1.2.g.12 .can.;be . extended from ~at least once .per l 18 months to at least once each refueling inierval (i.e.,

3 nominal 24 months) .

l surveillance Beauirement 4.s.1.1.2.a.13. Diesel Generator i Lockout Test i

i The lockout protection prevents the diesel engine .from

l. starting.or trips a running diesel' engine for the following.

! conditions:

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4 1. Engine Overspeed I

2.. Lube Oil Pressure Low (2-of 3 pressure switches) l i 3. Generator Differential Protection 1 j 4. Emergency Stop (2 switches) l l

l Surveillance Requirement 4.8.1.1.2.g.33 verifies the 3 operability of the DG by verifying 'that the DG lockout l

features will prevent the DG from starting. NNECO proposes i to extend the. frequency 'of Surveillance Requirement j 4.8.1.1.2.g.13 from at least once-per 18 months'to at least

once each refueling interval (i.e., 24 . months). The t

. components covered by this Surveillance' Requirement are the DGs. +

l f A review of the past surveillance'results. indicate that the

, DG performance has - been very good. Since 1986, only one i corrective maintenance action was performed while performing l this surveillance. Fuses were blown in.the control circuit

!- during testing. . The surveillance procedure was revised to l have the fuses removed during testing.to prevent the overload

that may cause the fuses to blow.

Based on the above evaluation, the proposed change has a minimal impact on safety.

! Sianificant Ensards Consideration L

NNECO has reviewed the proposed changes, in accordance with

10CFR50.92 and concluded that the changes do not involve an SHC.

1 The basis for this conclusion is that the . three criteria of i 10CFR50.92(c) are satisfied. The proposed changes do not involve '

i an SHC because changes would not:

1. Involve a significant increase in the probability or j consequences of an accident previously evaluated.

{ The proposed changes will increase the interval between the

surveillances that are performed during plant shutdown from l.

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U.S. Nuclear Regulatory Commission

. B15245/ Attachment 4/Page 15 June 14, 1995 once per 18 months to a maximum of once per 24 months (24 months i 25 percent as allowed.by Specification 4.0.2.). The proposed changes to surveillance Requirements 4.8.1.1.2.g.1 through 4.8.1.1.2.g.13 do not alter the intent or the method by which the surveillances are conducted. In addition, the acceptance _ criterion for the surveillances is' unchanged. As such, the proposed changes will not degrade the . ability of I the DG to perform its intended function.

A review of the past surveillances, inspections, and maintenance of the DG indicates that the appropriate

, acceptance criterion was met in each case. Therefore, the

! proposed change to the testing frequency will not change the 4 response of a DG to a LOP as described in the Millstone Unit l No. 3 Final Safety Analysis Report (FSAR). . Since the plant 'l j response to an accident will not change, there is no change !

in the potential for an increase in the consequences of an l' accident previously analyzed. Additional assurance of,the DG by. Surveillance -Requirements operability is provided 4

4.8.1.1.2.a.5 and 4.8.1.1.2.a.6, and- 4.8.1.1.2.b (i.e.,

monthly and six month testing of the diesel generators)'. In addition, since a failure of DG cannot cause any of the i .

accidents evaluated in the Millstone Unit ' No. 3 FSAR, the

! proposed changes do not adversely affect ' the probability of an accident previously analyzed.

2. Create the possibility -of a new or a different -kind of accident from any accident previously evaluated.

The proposed changes regarding the testing. frequency of the DG (i.e., from once' per 18 months to : a maximum of once per 24 months (24 months + 25 percent as allowed by Specification 4.0.2)) -does not affect .the . operation or response of any plant. equipment, including the .DG, or introduce any new failure mechanism. The proposed changes do not affect the test acceptance criteria of the DGs. The DG will be. verified to be operable and their response to a. loss

of voltage'as well as loading or rejection part'or' full load will be unchanged. The plant equipment will respond per design and analyses, and there will not be a malfunction of a i new or any type introduced by the testing frequency revision ;

to the DG surveillance requirements. As such, the changes do not create . the possibility of a new. or different kind of accident from any previously ar.alyzed.

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

The base of. the Technical Specification' 3/4.8, Electrical

. Power Systems, state that the operability of the ~ AC - and DC 4

power systems and associated distribution systems ensure that sufficient power 'will be available to supply the safety -

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I U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 16 4 June'14,:1995 related equipment required for safe shutdown and mitigation 4 and control of accident conditions. The-bases also states-that. the surveillance requirements l for determining the.

. operability of- 'the DGs are in accordance with the i recommendations of Regulatory Guide 1.108, Revision l'. The'-

4 revision-of surveillance requirements establishes tests that j will continue to verify that the'DGs-are operable. Operable

{ DGs ensure that~the assumptions'in the bases of the technical.

i specifications are'not affected and ensures that the margin of safety is not reduced. Therefore, the assumptions in the i Bases of Technical Specifications.are'not affected and these j changes do not result in a significant reduction in . the j margin of safety.

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U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 17 June 14, 1995 II. Safety Assessment and Significant Basards consideration for Changes to DC Sources operating, containment Penetration Conductor Overourrent Protective Devices and Motor-Operated Valves Thermal overload Protection

Background

On June 7, 1995, Millstone Unit No. 3 began operating on . a 3

nominal 24-month cycle instead of the previous month cycle.

To take advantage of this longer fuel cycle, 'NNECO will be proposing to modify the frequency of a number of the Surveillance Requirements existing in the Millstone Unit No. 3 . Technical 4

Specifications.

This request modifies surveillance Requirement 4'.8.2.1.e by the removal of the phrase "during shutdown" and also modifies the frequency of Surveillance Requirements 4.8.2.1.c, d, f, and 4.8.4.1.a.1, 4.8.4.1.a.2, 4.8.4.2.1, and- 4.8.4.2.2 of- the 4

Millstone Unit No. 3 Technical Specifications. These surveillance requirements deal with verification of the operability of the Class 1E DC power system, the verification of the containment penetration conductor overcurrent protection-devices, the verification of the thermal. overload protection for safety-related motor-operated valves that are, and are not, bypassed under accidsnt conditions.

In the near future, NNECO will be proposing additional changes to the Millstone Unit No. 3 Technical Specifications to prepare for- '

the conversion to a nominal 24-month fuelLcycle.; Each of these submittals will contain evaluations that are independent and which stand-alone.

'1. Dc Power System. Surveillance Reauirements 4 . 8 . 2 .1,L, 4.s.2.1.d. 4.8.2.1.e. and 4.s.2.1.f safety Assessment l The Class 1E DC power system consists of four redundant and l

independent DC systems, each consisting of a battery.with its own l charger and distribution system. One standby charger- backs up l each pair of operating chargers. The Class 1E'DC redundant load groups have no automatic connection to any other load group and no provisions for automatically transferring loads between these l redundant load groups. The class 1E DC power system has sufficient independence, redundancy, and testability to perform its intended safety function assuming a single failure.

The' class 1E DC power system is operated'at a normal float charge voltage level to maintain the batteries in a - fully charged condition. The battery chargers, associated with eaun battery,

'are rated to supply the largest combined demands of the various

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- U.S. Nuclear' Regulatory Commission ,

B15245/ Attachment 4/Page 18

-June 14, 1995

. . l steady ~ state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state irrespective.of the status of the plant when these demands occur. Each battery is sized to carry safety loads for at least two hours.following loss of all AC power. Each battery voltage level is continuously monitored. and displayed in the control room. Low voltage is alarmed in the control room.

Surveillance Requirements 4. 8. 2.1. a through f of the Millstone Unit No. 3 Technical: Specifications contain provisiores to demonstrate the operability of the Class 1E DC power - syaten.

They are:

Surveillance Requirement '.8.2.1.a 4 requires the verification, at least once per seven days, that each battery ha.s parameters within those specified by Table 4.8-2a of the Millstone Unit No. 3 Technical Specifications and that .the total battery terminal voltage is -greater than or equal to ,

129 volts on float charge.

Surveillance Requirement 4.8.2.1.b requires the verification, at 'least once per 92 days and within seven days after a battery discharge with'a battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, that 1) the parameters in Table 4.8-2a of the Millstone Unit No. 3 Technical Specifications' meet the Category B limits, 2) there is no~ visible corrosion at either terminals or connectors, or the connection resistance of-these items is less than 150 x 104 ohms, and 3) the average electrolyte temperature of six connected cells.is above 60*F.

Surveillance Requirement 4.8.2.1.c requires the verification, at least once per 18' months, that 1) the cells, cell' plates, and battery racks show no visual indication of physical damage or abnormal deterioration, 2) the call-to-cell and terminal connections are clean, tight, and coated with anticorrosion material, 3) the resistance of each cell-to-cell4 and terminal connection is less than or equal to 150 X

10 ohm, and 4) each battery charger will supply at least the amperage indicated in Table 4.8-2b of the Millstone Unit No. 3 Technical Specifications for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Surveillance Requirement 4.8.2.1.d requires the verification,

, at least once per 18 months, that the battery charger is adequate to supply and maintain in operable status all of the actual or simulated emergency loads for the design duty cycle l when the battery is subjected to a battery service test.

t Surveillance Requirement 4.8.2.1.e requires the verification, at least once per 60 months during shutdown, that the battery.

capacity is at least 80 percent of the manufacturer's rating when subjected to a performance discharge test.

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U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 19 f June 14, 1995 j

' - Surveillance Requirement 4.8.2.1.f requires the performance,of discharge at least once per 18 months, capacity for any battery that shows signs of degradation or has reached 85 percent of the service life expected for the application.

frequency of Surveillance NNECO is proposing to change the and f to a frequency of at least once each Requirements c, d, The components covered by these surveillance refueling outage. In addition, the phrase 4.8.2.1.d, requirements are listed in Attachment Surveillance 1. Requirements "during shutdown" in is being deleted. Because the terms 4.8.2 1.e, and 4.8.2.1.f

" Hot Shutdown" and " Cold Shutdown" are Specifications as defined operatingin modes the Millstone or Unit No. 3 Technical to perform certain conditions, the added restrictionsThe proposed deletion of surveillances may be misinterpreted.

the term "during shutdown" is consistent with the recommendations of GL 91-04. technical GL 91-04, the NRC has concluded that the In specifications need not restrict However, surveillances the NRC indicated as only thatbeing ift performed during shutdown.the performance of a refueling the licensee shouldinterval surveil operation would adversely affect safety, postpone the surveillance until the plant is shut down for refueling or in a condition or mode consistent agrees with the withNRC safeinconduct its NNECO of that surveillance.

conclusion. NNECO believes no safety thatimpactthe deletion as long of the as words the "during shutdown" has surveillances are conducted inBased any mode on this, or condition the term "during without d,

impacting the plant safety.

shutdown" may be removed from Surveillance Requirement 4.8.2.1.

4.8.2.1.e, and 4.8.2.1.f. 4.8.2.1.d, The proposed andchanges 4.8.2.1.fto do Surveillance alter Requirements notconducted, the intent or method any by 4.8.2.1.e, are do not involve any way which the surveillances to the plant, do not alter the physical changes structure, system, or component is operated.

functions,Asand such,do not themodify theproposed manner in which the plant 4.8.2.1.d, 4.8.2.1.e, and changes to Surveillance Requirements 4.8.2.1.f will not degrade the ability of the Class 1E DC power system to perform its safety function.

over the last four operating cycles wasf Equipment performance evaluated to determine the impact of extending d, and f.

the frequency oThis evaluation Surveillance Requirements 4.8.2.1.c, records, and the frequency and type of corrective mai last For the surveillances that have been to comply with performed Surveillanceduring the Requirements four operating cycles the equipment for the Class 1E DC power system 4.8.2.1.c and d,

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U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 20 j June 14, 1995 1

have met the acceptance criteria of the surveillances. In one 2

case, a bolt on a battery was corroded. This degradation would l have been discovered during a quarterly surveillance. ,

i There have been- no surveillances performed. to comply with j Surveillance Requirement 4.8.2.1.f, since the batteries..were only placed in the degraded condition after the fourth refueling i outage. This surveillance was performed during the .-fifth ;

j' refueling outage to comply with Surveillance Requirement !

j 4.8.2.1.f and the batteries met the acceptance criteria.

i l The only preventive maintenance-that is performed on an 18-month i frequency for the Class 1E DC power system is.the application of j an equalizing charge. Equalizing charges may be performed on a

! quarterly basis if required by the quarterly surveillance. Since i the need for equalizing charges is established each quarter, the.

I 18-month pre'ventive maintenance may be extended to at least once j aach refueling outage (nominal 24 months).

j Corrective maintenance performed on the batteries during the last l l four cycles has included installing bubblers, replacing intercell I i connectors, investigating alarms, and other minor actions. I j Corrective maintenance performed on the battery chargers during l l the last four cycles'has included installing new control boards, l replacing relays, investigating alarms, and other minor actions. i In each case, repairs were made with no' adverse impact on plant

operation.

I l l The surveillance results, preventive maintenance activities, and i

! corrective maintenance activities demonstrate that the Class 1E DC power system is a very reliable system. Based on this, the l

frequencies for Surveillance Requirements 4.8.2.1.c, d, and f can j be extended without adversely affecting public health and safety.

i A PRA review of the proposed change concluded that there is j negligible impact on public health and safety.

l Significant Basards Consideration i

i NNECO has reviewed the proposed changes in accordance with j 10CFR50.92 and concluded that the changes do not involve a SHC.

The basis for this conclusion is that the three criteria of

10CFR50.92(c) are not compromised. The proposed changes do not 1 j involve a SHC because the changes would not

1 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

l NNECO is proposing to modify the frequency of Surveillance j Requirements 4.8.2.1.c, d, and f of the Millstone Unit No. 3 j Technical Specifications from at least once per 18 months to j at least once each refueling interval. NNECO is also 1 proposing to delete the term "during shutdown" contained in Surveillance Requirements 4.8.2.1.d, 4.8.2.1.e, and l

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_ ._y . _ . _ . __ . _. __ _ _ __ . _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ - _ . _ . . ._

1 l- U.S. Nuclear Regulatory Commission d

'B15245/ Attachment-4/Page 21 June 14, 1995 l

4.8.2.1.f.- These surveillance requirements verify the l

! operability of components of the Class 1E DC power' system.

. Additional assurance of the operability . of the . Class- 1E DC power system is provided by Surveillance. Requirements 4.8.2.1.a, b, and e. .Also, battery voltage level for. each.

battery is continuously monitored and displayed in the control room, and low voltage and low. charging current alarms are provided in the control room.

i- The proposed changes do not alter the intent . or method by !

~

which the surveillances are conducted, do ~ not involve any.

physical changes to the plant, ' do not alter the way any structure, system, or component functions, and do not modify the ' manner. in which the plant is operated. As such, the'.

proposed changes in the frequency of Surveillance

Requirements 4.8.2.1.c, d, and f will-not degrade the ability of .the Class 1E DC power system to perform its intended safety function. Also, the Class 1E . DC power system is designed to perform its' intended safety function even in the event of.a single failure. l Equipment performance over the last~four operating cycles was evaluated to determine the impact of extending the' frequency.

of Surveillance Requirements 4.8.2.1.c, d and f. This evaluation included a review of surveillance: .-results, preventive maintenance records, and the frequency and type of corrective maintenance. It~ concluded ~that the-Class 1E DC power ' system is highly reliable, and that there is no indication that the proposed extension- could cause deterioration in the condition or performance of any of the subject Class 1E DC power system components.

The deletion of the phrase "during shutdown" in Surveillance Requirement 4.8.2.1.e is acceptable. The phrase COLD 2

Shutdown and Hot Shutdown are defined in the Millstone Unit No. 3 ' Technical Specifications as operating modes or conditions and may be misinterpreted with the term during shutdown contained.in the Surveillance Requirement.

j Based on the above, the proposed changes to surveillance Requirements 4.8.2.1.c, d, e, and f of the Millstone Unit No.

3 Technical Specifications does not involve a significant increase in the probability or ' consequences ' of an accident previously analyzed.

2. Create the possibility.of a new or different kind of accident from any accident previously evaluated.

NNECO is proposing to modify the frequency of Surveillance 2

Requirements 4.8.2.1.c, d, and f of the Millstone Unit No. 3 Technical Specifications from at least once per 18 months to at 'least once each refueling . interval. NNECO is also

i. .

4 U.S. Nuclear Regulatory Commission i- B15245/ Attachment 4/Page 22 June 14, 1995

. proposing to delete-the term "during shutdown" contained:in Surveillance Requirements 4.8.2.1.d, 4.8.2.1.e,. and 4.8.2.1.f. These surveillance . requirements verify' the operability of components of the Class-.1E DC power system.

The proposed changes do not alter. the intent or method by.

which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way~ any structure, system, or component functions, and do not modify the manner in which the plant is operated. As such, the proposed changes to Surveillance Requirements - 4.8.2.1.c,- d, e, and f will not introduce a new failure mode.

Based on the above, the proposed changes to Surveillance Requirements 4.8.2.1.c, d, e, and f of the Millstone Unit No.

'3 Technical-specifications will'not create the possibility of a new or different kind of accident from any' previously evaluated.

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

NNECO is proposing to . modify the frequency of Surveillance Requirements 4.8.2.1.c, d, and f of the Millstone Unit No. 3 Technical Specifications.from at least once.per 18 months to at' least once each refueling. interval. NNECO is also proposing to delete the term "during shutdown" contained in Surveillance Requirements 4.8.2.1.d, 4.8.2.1.e, and 4.8.2.1.f. These surveillance requirements ~ verify the i operability of components of the Class 1E DC power system.

Equipment performance over the last four operating-cycles was evaluated to determine the impact of extending the frequency '

of Surveillance Requirements 4.8.2.1.c, d and f. This evaluation included a review of surveillance results,

preventive maintenance records, and the frequency and type of corrective maintenance. It concluded that the Class 1E DC 4 power system is highly reliable, and that there is no indication that the proposed extension could cause deterioration in the condition or performance of any of the subject Class 1E DC power system components.

Additional assurance of the operability of the Class 1E DC

power. system is provided by surveillance Requirements 4.8.2.1.a, b, and e. Also, battery voltage level for each battery is continuously monitored and displayed in the control room, and low voltage and low charging current alarms are provided in the control room.

, since decreasing the surveillance frequency does not involve a significant increase in the consequences of a design basis accident previously analyzed, the proposed changes to Surveillance Requirements 4.8.2.1.c, d, -a, and f of the'

i U.S. Nuclear. Regulatory Commission:

B15245/ Attachment 4/Page 23 June 14, 1995 Millstone Unit No. 3 Technical Specifications do not involve a significant reduction in the margin of safety.

B. contai--=t ' Penetration conductor Overourrent Protection Devices. surveillance Requirement 4.s.4.1.a i

safety Assessment NNECO has met the requirements of General Design. Criterion -

(GDC) 50, " Containment Design Bases," with= respect to electrical penetrations containing- circuits of the safety-related and-nonsafsty-related onsite power . systems through the installation of coordinated ' fault _ current interrupting devices. GDC 50 requires, in part, that the reactor containment structures, including penetrations, be' designed so that the containment

structure and its internal compartments can ' accommodate the calculated pressure and temperature conditions resulting from any loss-of-coolant accident without exceeding the design leakage :

rate and with sufficient margin. !

NNECO has addressed this requirement based-on the' fact that all i circuits that pass through- containment electrical penetrations have primary and backup protection. This is consistent with the guidance of Regulatory Guide 1.63, and in compliance with GDC 50.

Millstone Unit No. 3 has four .~ medium ' voltage' (4-15 kV) _ circuit

, breakers that supply' power into the containment for-the reactor coolant pump motors and has 305 low voltage- containment penetrations that require testing. ;

surveillance Requirements 4.8.4.1.a.1, 4.8.4.1.a.2, and:4.8.4.1.b of the Millstone Unit No. 3 Technical' ' Specifications contain o

]

provisions to demonstrate the operability of the containment penetration conductor overcurrent protection devices.

Surveillance Requirement 4.8.4.1.a.1 requires that at least ,

once per 18 months that the medium voltage circuit breakers l are verified to be operable, by selecting, on a rotating j

1. basis, at least a 10 percent sample and performing a channel I calibration on the associated protective - relays; an integrated system functional test; and for each circuit found inoperable'during the functional tests, additional circuits of that type shall be tested.

J' Surveillance Requirement 4.8.4.1.a.2 requires that a i representative sample of- the lower voltage circuit breakers

i. have a functional test performed on . them. In addition,

, testing .shall include air circuit breakers and molded case circuit breakers.

Testing of air circuit breakers shall consist of injecting-a-current with 'a value equal to 300 percent of the pickup . of the long-time delay trip element and 150 percent of the b

i 1-- - __ _ , . _ . . . . , _ _ , . . . . - - - . _ , , - - ,

. - - - - . ~.

l<s.

[ U.S.-Nuclear Regulatory _ Commission i- - B15245/ Attachment 4/Page 24

' June:14, 1995 l

1. , -

! pickup of the short-time delay trip element, and verifying that tho' circuit breaker operates w;. thin the time delay band i width for that current specified by the. manufacturer. .The j instantaneous-element shall be tested'by! injecting a current l equal to't 20 percent of the pickup value of the' element and

verifying that the. circuit. breaker trips instantaneously with i no intentional time delay.

i i

Molded case circuit breakers and unitized starters (a frame size of 250 amps'or less) shall be: tested for long time delay l

! at 300 percent as described above and, in addition, tested l

! for the instantaneous trip by injecting a current value which

, falls within +40 percent (of the upper limit) and -25 percent-(of the lower limit) of the manufacturers instantaneous trip:

1 current range and verifying the breaker trips instantaneously

! with no intentional time delay. For 'those molded case-circuit breakers / unitized starters used'in 480V circuits, if single-pole instantaneous test results fall outside these h tolerances, . additional instantaneous testing shall' be l l conducted using two poles in' series, including A-B, B-C, and l

C-A phase combinations. All combination test results shall

fall within the specified tolerances.

1 i For each circuit breaker found inoperable during these

! functional tests, an additional representative sample-of at j- least 10 percent of all the- circuit breakers of the

inoperable type shall also be functionally-tested until no i more failures are found or all circuit breakers'of that type

{ have been functionally tested.

c

! Surveillance Requirement '4.8.4.1.b requires that at least >

! once per 60 months each circuit breaker shall be subjected to

!. an inspection and preventive maintenance. 'in accordance with I

the manufacturers' recommendations.

) NNECO is proposing to change the frequency of Surveillance

{

Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 from its current

interval of once per 18 months . to once each refueling interval.

l The components covered by Surveillance Requirement 4.8.4.1.a.1 4 and identified in Table 2, and the components covered by

! Surveillance Requirement 4.8.4.1.a.2 are listed in the Millstone

! Unit No. 3 Technical Requirements Manual.

The proposed changes to Surveillance Requirement 4.8.2.1.a do not

alter the intent or method by which the surveillances are L

conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions,

! and do not modify the manner in which the plant is operated. As

! such, the proposed changes to surveillance Requirement 4.8.4.1.a

will not degrade the ability of the containment penetration

{

conductor overcurrent protection devices to perform their safety y- function.

4 5

i .- ,,- ,.

-t

'U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 25 June 14, 1995 Medium voltage containment penetration conductor overcurrent protection is achieved by eight IAC overcurrent relays on each of the four reactor coolant pump circuit ' breaker cubicles. These relays measure the A, B, and C phase currents of the running reactor coolant pumps (RCP) motors. A trip of the individual _RCP breakers occurs if the primary protection operates. If . the backup protective relay operates, the entire 6. 9' kV- bus is tripped to prevent an overload condition from causing damage to the penetration assembly.

A manual switch on the front of the panel of~each RCP breaker ,

selects the hot or cold protection scheme that is active'and is

. changed according to operating procedures when the RCP running-current is over or under 500 Amperes.

1 The medium voltage (8,000 volts) penetration ~ assemblies are durable devices that nmet the specification requirements for the ,

fault currents and starting inrush current. )

l The IAC overcurrent relays used for this protection feature are reliable and stable devices. Previous surveillance data for the l "as-found" setpoints that were recorded were compared to the protectior. 1urve given in the specification to determine if penetration protection was achieved. A system functional test !

was also successfully conducted at each. surveillance test.

1 In 1991, the surveillance test calibration and relay data sheets i were revised to require recording of the "as-found" setpoint. ]

The relay data sheets required the "as-left" value to be within 5 percent of the trip value, while the acceptance criteria-is i 10 percent of the desired trip valve. This procedure of maintaining a closer tolerance on-the "as-left" setting assures that the trip-value will be within the acceptance criteria on a future surveillance.

I This fact coupled with the known stability of the IAC overcurrent

! relays provides confidence that an increase in the test interval to a maximum of 30 months will not affect the performance of the

containment penetration protection.

Two corrective maintenance adjustments were made to the hot trip settings in 1992. A review of service records. revealed no adverse conditions that would prevent the protective relays from

operating as designed.

The lower voltage circuit breaker histories were also reviewed, focusing on the results of operational surveillances, review of'

preventive maintenance needs, review of corrective maintenance and' frequency, Nuclear Plant Reliability Data System reviews, and'

. vendor consultation as required to justify the extension of.the surveillance from 18 months i 25 percent to 24 months (i 25 percent).

-1

\

U.S. Nuclear Regulatory Commission j B15245/ Attachment 4/Page 26 1 . June 14, 1995.

j The Technical Specification Surveillance Requirement 4.8.4.1.a.2 !

requires that at least 10 parcent of each type of breaker be tested. During the last four cycles, Millstone Unit No.-. 3 has

, tested significantly more than the required 10 percent. During j the first refueling 265 out of the 285 low valtage containment 4

penetration breakers were tested with no documented failures.

I During the 'second refueling outage 102 out of 309 low voltage i containment penetration breakers were tested with four failures.

. Two of ' the failures were with breaker type THJK4. In both i instances, the as-found setpoint breaker failed to trip within )

. the required current range (844-2012 Amps). The other two 1 i failures occurred on the HE43 breakers. One of the failures 4

involved the as-found setpoint breaker failed to trip within the required number of cycles ($ 7 cycles) . In the second instance, 4 Millstone Unit No. 3 did not test the "C" phase in an as-found j l condition.

J In the third refueling outage, 116 out of 303 low voltage containment penetrations were tested with only one recordable failure. This failure was noted on the THJK4 breaker type and involved the failure of the breaker to trip on a long time delay (35-110 seconds).

In the fourth refueling 214 out of 305 low voltage containment penetration breakers were tested with only three recordable J failures. One of the failures involved breaker type THJ4K and was caused by the early tripping of a breaker during a long time delay test of the "C" phase of thermal overload. The other two failures involved breaker type AMPCAP which, in one instance, the "A" phase thermal overload did not trip within:the required time, .

and in the other instance, the "A" phase thermal overload tripped !

prior to the required time interval.

When a breaker failed during the performance of the surveillance, it was replaced and the new breaker was tested. For each breaker that failed the required extra 10 percent of that breaker type was tested. It was determined that from a review of previous failures that these failures do not have a common root cause.

Meeting the requirements of Surveillance Requirement 4.8.4.1.a.2 ansures that the containment penetration low voltage circuit breaker are operable and provides data to trend the operation of each breaker type.

Surveillance Requirement 4.8.4.1.b requires that each circuit breaker be subject to inspection and preventive maintenance at least once per 60 months. A review of the preventive maintenance records revealed that preventive maintenance activities currently are performed on a 36-month basis and a few are performed on an

18-month basis. These intervals will be revised for the nominal 24-month fuel cycle' to 24 months and 48 months basis for preventive maintenance but are still more frequent than the

a i

l U.S. Nuclear Regulatory Commission i_ B15245/ Attachment 4/Page 27

June 14, 1995 required 60-month preventive maintenance interval specified in j Surveillance Requirement 4.8.4.1.b.

Corrective maintenance work performed.- on the containment penetration low ~ voltage circuit breakers during the last four

cycles involved resetting tripped breakers, replacing broken-j breakers and handles, testing new breakers, and replacing charging motors, as well as other minor . corrective maintenance actions. In all cases, the repairs were able to be made with no adverse impact to plant operation.

Extension of the 18-month containment penetration low voltage' l

circuit breaker surveillance can be justified by considering the j surveillance history, the preventive maintenance, and the fact !

that many of these surveillances and preventive maintenance ,

activities may be conducted on-line. !

The above reviews have shown no significant equipment failures for the past_four operating cycles (since commercial operation June 1986 to March 1994). Since the proposed change does not affect the operation or design of the containment penetration low voltage circuit breakers, a decrease in the frequency of testing i

(consistant with 24-month operating cycles) is considered to have a minimal impact on safety.

.; On the basis of the above evaluation, there is reasonable )

assurance that the frequency of testing for Surveillance Requirement 4. 8. 4.1. a. 2 can be extended from at least once per 18 months to at least once each refueling interval.

4 Based on a review of the function of the containment protection overcurrent devices and their operating history, the PRA review concluded that the impact of the proposed changes on the public safety is negligible.

. Significant Easards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and concluded that the changes do not involve an SHC.

The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

L NNECO is proposing to modify the frequency of Surveillance Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 of the Millstone Unit No. 3 Technical Specifications from at least once _ per 18 months to at least once each refueling interval. These surveillance requirements verify the operability of the containment penetration conductor overcurrent protective devices.

- ~ - - - - -

e i

i l_ U.S. Nuclear Regulatory CommissionL j

, B15245/ Attachment 4/Page 28 L June-14, 1995 1 .

i. The proposed changes l do not alter the . intent or method' by ;

l- which the . _ surveillances are conducted, _ do _ not : involve any 3 physical changes to the plant, do not alter . the way any structure, system,'or component functions,.-and do not modify L the manner in < which the - plant is operated. _ As such, the I proposed changes .- in .the frequency of. Surveillance i l' Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 will not degrade.the j ability of the containment penetration conductor overcurrent i protection devices to perform their intended safety function.

i- Also, the containment- penetration' conductor overcurrent l protection devices are designed to ~ perform ' their intended' i

safety function even'in the event of a-single failure through ,

the use of.two-fault ~ current interrupting devices in series. I j Equipment performance over the last four operating cycles was

evaluated to determine the impact of extending the frequency of Surveillance Requirements' 4.8.4.1.a.1 and ' 4. 8. 4 .1. a . 2. 1 j' This evaluation ' included a _ review of sutveillance results,- 1 l preventive maintenanca records, and the frequency and type of i corrective maintenance. It ~ concludes that the containment

! penetration conductor overcurrent protection devices system j is reliable, and that there is no ' indication that the

'j proposed extension could cause deterioration in the condition .

or performance of any of the subject containment _ penetration 1 conductor overcurrent protection devices. l

Based on the above, the proposed changes to Surveillance l l Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 of: the Millstone t- Unit No. 3 Technical Specifications ~ does not involve a i significant increase in the_ probability or consequences of an j accident previously analyzed.

4 j 2. Create the possibility of a new or different kind of accident from any accident'previously evaluated.

j NNECO is proposing to modify the frequency of ' Surveillance

! Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 of the Millstone

] Unit No. 3 Technical Specifications from at least once per'18

! months to at least once each refueling interval. These l surveillance requirements verify the operability of components of the containment penetration conductor j overcurrent protection devices.

J - -

l The proposed changes do not alter the intent or method by 1 which the surveillances are conducted, do not involve any

physical changes to the plant, do not ' alter the way any

j. structure,' system, or component functions, and do not modify i the manner in which the plant is operated. As such, the j -proposed changes in the frequency of Surveillance j Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 will not introduce-a new failure mode. Also, the containment penetration

conductor overcurrent protection devices are designed to-j perform their intended safety function even in the event of a 1

4-7 i

)j U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 29

June 14, 1995

! single failure-through the use of two fault current limiting j devices in series.

3. Based on the above, the proposed changes to surveillance

! -Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 of the Millstone j Unit No. 3 Technical Specifications will 'not create the j possibility.of a new-or different kind of accident from any-j previously evaluated.

i

~ 3. Involve a significant reduction in a margin of safety.

j NNECO is proposing to modify the frequency of Surveillance Requirements 4. 8. 4 .1. a .1 . and 4.8.4.1.a.2 of the. Millstone Unit No. 3 Technical _ Specifications from at.least once ' per j 18 months to at least once each refueling interval. These i surveillance requirements verify the operability of l containment penetration conductor overcurrent protection devices.

Equipment performance over the last four operating cycles wasL y evaluated to determine the impact of-extending the frequency

of Surveillance Requirement 4 . 8 . 4 .1. a '.1 - and it.8.4.1.a.2.

2 This evaluation included a review of surveillance results, I j preventive maintenance records, and the' frequency and type of '

! corrective maintenance. It is concluded that the containment j penetration conductor overcurrent protection devices are

-j reliable, and that there is'no indication that the proposed extension could cause deterioration in the condition or

! performance of any of the containment penetration conductor i overcurrent protection devices.

i

! Since decreasing the surveillance frequency does not involve j a significant increase in the consequences of a design basis accident previously analyzed, the proposed changes to l ~ Surveillance Requirements 4.8.4.1.a.1 and 4.8.4.1.a.2 of the

! Millstone Unit No. 3 Technical Specifications do not' involve j a significant reduction.in the margin of safety.

C. Motor-Operated Yalves Thermal Overload Protection (Bypassed /

) Mot Bypassed) i j safety Assessment 3

The motor-operated valve protection- consists of a thermal

overload device and a magnetic device.- Regulatory Guide 1.106,

" Thermal Overload Protection .for Electric Motors on Motor-

' operated Valves," requires that, in order to ensure completion of

, ths valve safety function, thermal overloads on safety-related.

! valves must be either bypassed under accident conditions, or the

' trip setpoint of the thermal overloads should be established with

all uncertainties resolved in favor of completing the safety-

!- related function. In . that latter ~ case, the thermal' overloads-l

U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 30 June 14, 1995 should be periodically tested to interrupt electrical faults that might cause the failure of a containment penetration seal.

The proposed change to- the Millstone Unit No. 3' Technical. ;

Specifications 4.8.4.2.1 and 4.8.4.2.2 will increase the. interval l between surveillance from 18 ' months (* 25 percent) to 24' months-(i 25. percent) . The plant technical specification requirement that'will-be changed by this application is:

Surveillance Requirement-4.8.4.2.1 requires that the thermal overload protection for those protection devices bypassed under accident conditions shall be verified to be bypassed by-the appropriate accident signal (s) by performance of a trip actuation device operational test of the bypass ' circuitry during cold shutdown or refueling at least once per-18 months.

Surveillance Requirement 4.8.4.2.2 requires that the thermal overload protection'for those protection devices not bypassed under accident conditions shall be demonstrated operable at

{ least once per 18 months and following maintenance on the j ' motor starter by the performance of a channel calibration of

a representative sample of at'least-25 percent of the_above l devices.

! The components covered by these surveillance requirements are

j. listed in the Millstone Unit No. 3 Technical Requirements Manual.

l l The proposed changes to Surveillance Requirements 4.8.2.1.d, 4.8.2.1.e, and 4.8.2.1.f do not alter the intent or method by which the surveillances are conducted, do not involve any_

i physical changes to the plant, do not alter the way any i structure, system,'or component functions, and do not modify the j manner in which the plant is operated. As such, the proposed j changes to Surveillance Requirement 4.8.2.1.d, 4.8.2.1.e, and i j 4.8.2.1.f will not degrade the ability of the Class 1E DC power 4 system to perform its safety function.

i The motor-operated valves thermal overload protection (bypassed

and not bypassed) devices performance over the last four j operating cycles were considered in evaluating. the extension of the operating cycle from its current 18 months (i 25 percent) to

] its proposed value of 24 months (* 25 percent). The following i factors relating to equipment performance over the last four 1

operating cycles were considered in evaluating the extension of the operating cycle to 24 months (i 25 percent). To support this ,

s proposed request, the following parameters were evaluated i l including: operating surveillance results; protective

maintenance records; and corrective maintenance frequency and type.

l Surveillance Requirement 4.8.4.2.1 is accomplishad through the

! use of precedures. During the testing, the procedures require

I U.S. Nuclear Regulatory Commission B15245/ Attachment 4/Page 31 June 14, 1995 l the thermal overloads to be physically removed and the acceptance

criteria is proper operation of the valves during simulation of the accident signal (s).

Since plant startup, there have been six periods when the valves had been tested. During these six test periods, there have been 306 tests with only three test failures.- Two (2 out of 54) of l these test failures occurred during the first refueling outage.

~

The failure of 3SWP*MOV130AW during the first refueling outage was investigated, and it was concluded that the inability of the valve to open during the LOP /ESF testing appears to have been caused by external interlock not related to the bypass circuitry.

A retest of 3SWP*MOV50B was done based on its failure, and it required the addition of test jumpers t- simulate a CDA signal.

The last failure occurred during the fourth refueling outage (58 tested) when valve 3RSS*MOV23A failed to stroke from close to open in response to CDA signal. The failure was due to a blown

fuse on the secondary side of the control power transformer, because of a short in the~ wire on the close limit switch to 3

ground. The wiring was repaired, and the valve was retested and performed satisfactorily.

Motor-operated valves that are skipped on the normal surveillance are tested on a retest form. During the research and review for the nominal 24 month fuel cycle, the following valves were missing documentation of a retest surveillance form. Valves 3CHS*LCV112E and 3SWP*MOV54A (during the first refueling outage) and Valve 3CHS*MV8111B during the second refueling outage.

In each case, the valves were documented as tested during the

! next refueling outage surveillance. The absence of this data has no bearing on the technical evaluation to increase the time interval for conducting this surveillance.

The extension of the 18 month safety-related valve thermal

, overload bypass technical specification can .be justified considering the surveillance history.

The above reviews have shown minimal failures cince. initial plant I startup. Since the proposed technical specification change does not affect the operation or design of the thermal overload bypass of the safety-related valves, a decrease in the frequency of i testing (consistent with a nominal 24-month operating cycles) is I considered to have no impact on safety.

On the basis of the above evaluation, there is reasonable assurance that the frequency of testing for Technical Specification Surveillance Requirement 4.8.4.2.1 can be extended from 18 months (i 25 percent) to 24 months (i 25 percent) .

l l

l

I .

U.S. Nuclear Ro.gulatory Commission B15245/ Attachment 4/Page 32 June 14, 1995 requires that the thermal Surveillance Requirement 4.8.4.2.2 overload protection for the valven per in Attachment 18 months or1 following shall be demonstrated operable at least once This should be accomplished by maintenance the performance on theof amotor channelstarter. calibration of a representative l

sample of at least 25 percent of all thermal overloads.

l The technical specification requires that a representative samplelisted in Attachm I

of at least 25 percent of the valves Millstone Unit No. 3 has I

tested. During the last four cycles, than the required minimum.

f substantially more maintenance is performed on tested

(

Additionally, in almost all cases, i

the motor starter in accordance with procedures prior to the surveillance test.

tests performed over Since initial startup there have been 170 six outages (four refueling, 1 operations outage (1987); 1 forced These 170 tests have produced 10 failures.

shutdown [1992]).

1991 time frame. The The first three failursts occurred in theduring the performance of first failure occurr6, in March 1991

i. Valve SIH*MV8802B was found with a bad preventative maintena'. aad heater was replaced and the valve was overload heater. The Also in March 1991 valve 3SIH*MV8802A was successfully tested. to have a bad thermal identified during corrective maintenanceThe bad thermal overload was replaced an overload. In August 1991, during the performance of preventative retested.

maintenance on valve 3SWP*MOV102B the phase C heater was found to be bad and was rep? aced and retested, and determined to be In Canuary 1992, valve 3CHS*MV8507B hadThe a broken valve acceptable.

thermal overload heater which required replacement.

was repaired, retested, and returned to service.

During the 1993 outage, five valves failed their 3RSS*MOV38B, operational had the "C" phase surveillance. The first valve, fail to trip after 68 seconds. The heater was replaced and the j Valve 3SIL*MV8804A valve was ratested and returned to service.This heater was replaced had a bad weld on the "A" phase heater. Valve 3SWP*MOV24D had and the valve was made returned to the valve to service.

housing and was returned to minor repairs servics. Valve 3SWP*MOV57A had two defective heaters replaced. Valve The valve was - retested and was returned to service. The heater 3SWP*MOV102A was replaced, the valvewas found was retested to have aand broken heater block.

was returned to service.

1993 during the performance of corrective In September maintenance, an overload heater in a starter was replaced and retested and returned to service.

As is shown above, the types and nature of the failures have not been significant.

The extension of the, 18 month safety-related thermal overload justified considering the requirement can be surveillance

-- - - ~ - - _ _ _ _ _

t i U.S. Nuclear Regulatory Commission l B15245/ Attachment 4/Page 33 June 14, 1995 surveillance history, and the preventive and corrective maintenance history and the acceptable- performance of the component.

The above reviews have shown minimal failures since 1987. Since the proposed technical specification change does not affect the operation or design of the thermal overload protection of the l safety-related valves, a decrease in the frequency of testing .

(consistent with nominal 24-month operating cycles) is considered I to have no impact on safety.

On the basis of the above evaluation, there- is reasonable assurance that the frequency of testing for Technical-Specification Surveillance Requirement 4.8.2.2 can be extended from 18 months to a maximum of 30 months without adversely affecting safety.

A PRA review of the proposed surveillance frequency extension' i concluded that the impact on the public safety is negligible. l j Sianificant Hazards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and concluded that the changes do not involve an SHC.

The basis for this conclusion is that the three criteria of 10CFR50. 92 (c) are not compromised. The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

NNECO is proposing to modify the frequency of Surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2 of the _ Millstone- Unit No. 3 Technical Specifications from at least. once per 18 months to at least once each refueling interval. -These ;

. surveillance requirements verify the ~ operability of motor- ,

operated valves thermal overload protection (bypassed and not bypassed).

5 The proposed changes do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. As such,.the i proposed changes in the frequency of Surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2 will not degrade t.lis ability of the motor-operated valves thermal overload

, protection (bypassed and not bypassed) to perform. its intended safety function.

Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of Surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2. This

L U.S. Nuclear Regulatory Commission i i B15245/ Attachment 4/Page 34 l

June 14, 1995 l

l 4 evaluation included a review of surveillance results, !

i preventive maintenance records, and the frequency and type of

, corrective maintenance. It concluded that the motor-operated

! valve thermal overload protection (bypassed and not bypassed)

! system is highly reliable, and that there is not indication l that the proposed extension could cause deterioration in the

condition or performance of any of the subject motor-operated

j. valves.

i Based on the above, the proposed changes to surveillance i Requirements 4.8.4.2.1 and 4.8.4.2.2 of the Millstone Unit i No. 3 Technical Specifications does not involve a significant increase in the probability or consequence of- an accident previously analyzed.

2

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

NNECO is proposing to modify the frequency of Surveillance Requirements 4. 8. 4. 2.1. and 4.8.4.2.2 of the Millstone Unit No. 3 Technical Specifications from at least once .per 18 months to at -least once each refueling interval. These surveillance requirements verify the operability of components of the motor-operated valve thermal overload protection (bypassed and not bypassed).

The proposed changes do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the. plant is operated. As such, the proposed changes . in the frequency of Surveillance F.equiremants 4.8.4.2.1 and 4.8.4.2.2 will not introduce a new failure mode.

Based on the above, the proposed . changes to surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2 of the Millstone Unit No. 3 Technical Specifications will not create the possibility of a new or different kind of accident from any previously evaluated.

1

3. Involve a significant reduction in a margin of safety. )

J NNECO is proposing to modify the frequency of Surveillance 4

Requirements 4.8.4.2.1 and 4.8.4.2.2 of the Millstone Unit No. 3 Technical Specifications from -at lasst once per 18 months to at least once each refueling interval. These surveillance requirements. verify the operability of components of the motor-operated valves thermal overload protection (bypassed and not bypassed).

Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency

1 i .

I l

U.S. Nuclear Regulatory Commission l B15245/ Attachment 4/Page 35 June 14, 1995 of Surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2. The evaluation included a review of surveillance results,

preventive maintenance records, and the frequency and type of i corrective maintenance. It concluded that the motor-operated valves thermal overload protection (bypass and not bypassed) 4 system is reliable, and that there is no indication that the i proposed' extension could cause deterioration in the condition or-performance of any of the subject motor-operated valves thermal- overload protection (bypassed and not bypassed) components.

~

{ since decreasing the surveillance frequency does not involve

a significant increase in the consequences of a design. basis

accident previously analyzed, .the proposed changes to surveillance Requirements 4.8.4.2.1 and 4.8.4.2.2 of the Millstone Unit No. 3 Technical Specifications do not involve

a significant reduction in the margin of safety.

a l

l I

l i

a e t - , _ ~ _

_ . . ., ,m - -, .- --

Table 1 l

~

' Equipment Covered by Surveillance Requirement-4.8.1.1.2.g.11 EQUIPMENT DESCRIPTION CCleSRTS -

33GF*F1A Fuel transfer pump Traia 'A' Mone 33GF*F1C Fuel transfer pump Traia 'A' None 35GF*F15 Fuel transfer pump Train '0' Nome 33Gr*FID Fuel transfer pug Traia.'n' Mose

, 35GF*V13 Cross connect valve Manual valve 33GF*V14 Cross comaect vsive Manual' valve 35GF*V11 CommeA pump discha'go isol. valve Train 'B' Manual valve J

35GF*V6 Common pump dischargs isol.' valve Train 'A' , Manual valve 33GF*F983 Retura to sump isol. Train 'B' Manual valve i-35GF*V5 Common pump discharge isol. valve Train 'A' Manual valve

. 35GF*V12 Common pump discharge isol. valve Train *D' .

Manual valve 35GF*V982 Return to sump isol. Train 'A' Manual valve E

a C

,~_,.-r- - -- _. ,m, , _ - - - _ . . -

. _ , . . . - , . .. . - . . , , . . _ , _ _ -~ _ _ . - ,

l l

\ ..

Table 2 Equipment Tested per surveillance Requirements 4.8.2.1.c, d, and f Equipment Description

301A-1 125.VDC Batttry Red 301A-2 125 VDC Battery Blue 301B-1 125 VDC Battery White 301B-2 125 VDC Battery Yellow 3BYS*CHGR1 Battery Charger for Battery 301A-1 3BYS*CHGR3 Battery Charger for Battery 301A-2 3BYS*CHGR7 Swing Battery Charger for.

Batteries 301A-1 and 301A-2 3BYS*CHGR2 Battery Charger for Battery 301B 3BYS*CHGR4 Battery Charger for Battery 301B-2 l

3BYS*CHGR8 Swing Battery Charger for i Batteries 301B-1 and 301B-2 Equipment Tested Per Surveillance Requirements 4.8.4.1.a.1 Reactor Coolant Pump A a

50/51-PC Phase B 50/51-BC Phase A 50/51-PH Phase B 50/51-BH Phase A 50/51-PC Phase C 4 +

50/51-PH Phase C

+

51-PCH Phase C

+

51-BCH Phase A i

P = Primary B = Backup C = cold > 500A H = Hot < 530A

w r- -

Table 2 (cont'd.)

Reactor Coolant Pump B

+

50/51-PC Phase B

+

50/51-BC Phase A

+

50/51-PH Phase B.

+

50/51-BH Phase A.

50/51-PC Phase C

+

50/51-PH Phase C 51-PCH Phase C

+ 51-BCH Phase A P = Primary B = Backup C = cold > 500A H = Hot <:530A-4 Reactor Coolant Pump C

+

50/51-PC Phase B- I

+

50/51-BC Phase A 1

+

50/51-PH Phase B !

+

50/51-BH Phase A

+

50/51-PC Phase C

+

50/51-PH Phase C 1

+ 51-PCH Phase C !

+

51-BCH Phase A P = Primary B = Backup C = cold > 500A H =_ Hot < 530A i

Reactor Coolant Pump D

+

50/51-PC Phase B

+

50/51-BC Phase A

+

50/51-PH Phase!B

+

50/51-BH' Phase A

+

50/51-PC Phase C 50/51-PH Phase C

'51-PCH Phase C

+

51-BCH Phase A l

P = Primary B = Backup C = cold >1500A H = Hot < 530A

)

- _

ML20085G543

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