ML20106E311
| ML20106E311 | |
| Person / Time | |
|---|---|
| Site: | Callaway |
| Issue date: | 10/30/1992 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2714, NUDOCS 9211060326 | |
| Download: ML20106E311 (15) | |
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'U. S. Nuclear Regulatory Commission
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Attn:
Document Control Desk Mail-Station F1-14 Washington, DC 2
Gentlemen:
'U'.4NRC-2 714 CALtAWAY. PLANT DOCKET NUMBER 50-483 ADDITIGNAL INFORMATION REGARDING k
REVISION TO TECHNICAL SPECIFICW2 ION TABLE 3.3-4,
" ENGINEERED SAFETY PEATURES ACTUATION SYSTEM
. l@TRUMEtG'ATION TRIP SETPOIfrPS" Ref:
1.
' Union Electric letter to U.S. Nuclear Regulatory Commission,'ULNRC-2539, December 20, 1991 Att:
1.
' Summary of Bechtel Power Corporation letter to Unicn Electric, BLUE-91-0004, "Callaway Nuclear-Power Plant /Callaway Degraded Voltage oc*uoints,"
November 14, 1991 2.
Summary of Design Inputs of Revised Degraded-Voltage Safety Analysis and Uncertainty Breakdowns-3.
Summary of Union Electri_c Suggestion, Occurrence, and Solution (SOS). Report, SOS 91-0469-In Reference 1 Union Electric' Company submitted the subject application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant This amendment application-requests a revision to_ Technical Specification Table'3.3-4, Functional Unit 8.b, to revise the trip setpoint,__ allowable.
va!ue, total allowance, sensor error,1and?"Z"-value-of the "4 kV Undervoltage - Grid Degraded Voltage"
-protection function to agree with the. required design
. values.
4 Union Electric helewith formally transmits
'information r:egardinglthe change to-the plant degraded voltage setpoints.
This' additional iriformation is -
- provided at-the request of Mark Pratte and Frank Ash of,tha'NRC staff concerning the reascns for the change g
and. impact on plant voltages.
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- October 30,-1992
, is a summary of Bechtel letter BLUE 91-0004.
This letter describes the root cause, documents the safety significance.of the error, and describes some of. the analysis performed to produce theLnew setpoint.
This analysis included performing-new load-flow analyses which examined relationship-between the limiting voltages on the lower voltage' 4
levels,-to the higher voltage level at-which the degraded voltage sensing is present.
Further.inuly11s was performed by Union Electric l to calculate the setpoints by a detailed analysis of-the loop uncertainties.
The uncertaintjes were analyzed using ISA Standard DRP 67.04.
includes a summary of the important design. inputs,-a graph showing.the degraded voltage loop uncertainty breakdown and'a diagram of the setpoint_ uncertainty-breakdown.
Union Electric'also performed plant wide load flows.tx) ensure that the plant voltages were coordinated with the new setpointe.and the loop uncertainties., SOS 91-0469, is the occurrence report of the setpoint error and documents analysis;of the impact on the operability of the plant, interim actions, and subsequent corrective actions.
If you have any-questions regarding the subject amendment application or this additional information, 7
s please contact.us.
t Very truly-yours,
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b c >1 Donald F. Schnell 4-GAC/kea Attachments-e Ii'_
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STATE OF MIS 90URT
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Passwater, of lawful age, being firat' duly sworn upon cath says that be is' Manager, Licensing _and-Fuels (Nuclear) for-Union Electric Company; that he has read the foregoing document and.
- knows the content thereof; that he has executed the same for and on-
-behalt of said company with full power and authority to-do-so; 1 d that the facts therein stated are true and correct to the oest'of.his-Knowledge,-information and belief.
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By [8, din,/ b,/q&wW4W 3-Alan C.
Passwater
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Manager, Licensing.and' Fuels.
Nuclear SUBSCRIBED andcsworn to before me~this 4?b
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Baxter, Esq<
Shaw, Pjttman, Potts & Trowbridge 2300 N.
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Washington, D.C.
20037 Dr. J.
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Cermak CFA, Inc.
18225-A Flower Hill _Way Gaithersburg, MD 20879-5334 L.
Robert Greger Chief, Reactor Pro-ject Branch 1-U.S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinoic 60137 Bruce Bartlett' Callaway Resident Office U.S.
Nuclear Regulatory Commission-RR#L Steedman, Missouri 65077:
b L. R. Wharton-(2)
Office of Nuclear Re?.ctor Regulation U.S.
Nuclehr~ Regulatory Commission 1 White Flint,' North,-Mail Stop 13E21 L
11555 Rockville Pike ~
1 Fockvi'lle, -MD 20852 Manager,_Llectric Department Missouri Public Service:Commionien Q
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Box 13GO Jeffersun City,-HO 65101 Ron Kucara-Departmentiof Natural" Resources J,
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-Attachment 1-ULNRC-2 714 Page 1 of.3 4
SUMMARY
-.0F BECHTEL LETTER TO UNION ELECTRIC, BLUE-91-0004, NOVEMBER 14, 1991, "CALLAWAY NUCLEAR POWER PLANT /
CALLAWAY DEGRADED VOLTAGE SETPOINTS" The degraded voltage aetpoints for the Callaway Plant were established in Calculation H-8 using-Calculation _B-17 as a reference.
The basis for the setpoints was the minimum voltage at 4.16 kV-buses NB01 and NB02 which would provide-92% of n minal motor rated voltage on criticals Motor Control Centers (MCCs) as establishrJ in Calculation B-5.
Calculation B-5, Revisior 2 established the Load Center voltage needed to support the Motor Control Center voltage.
regttrements.
The load fluw calculation performed in Calculation B-17 Revision 0 showed that in order to meet those load center voltages identified in Calculation B-5, i
required voltages at NB01 and NB02-were 3656 kV each.
The degraded voltage setpoint was selected to be 3656/(4200/12s PT ratio) or 104.5 V.
Concurrent with the initial setpoint determination in March of.1984, the need to supply safety re3ated loads with one ESF transformer out of service was.also questioned.
Studies performed at that time-irdicated that such a contingency could be handled with load reduction and by changing the taps above-the'4.16kV level.
Since a change of ESF transformer taps docs not impact the relation between 4.16 kV-and'480 V bus voltages, no alteration-to the Load
'T Shedding'and Emergency Load Sequencing (LSELS) setpoints would have been required, and-therefore, no change to the LSELS setpoint'was required to address the contingency.
The load flcw studies were later revised in. December 1984 (Calculation B-17, Revision 1) to.show that with a higher design minimum switchyard voltage, safety relatedLloads could be supported from one ESF. transformer-without the
-extensive load shedding dictated by_ Calculation B-17, Revision 0.
Concerns over_overvoltages during plant outages and. revised load data-dictated that the optimal-tap settings, as determined in Calculation-B-17,-Revision:1, included _-a change,in-the-load center taps, which did change the 4;16 kV-4c3 V bus voltage relationship.-
h Load flow studies _ performed as part.of Calculation B-17, Revision 1,: indicated that with the revised tap 1
settings and design. minimum voltage at the switchyard, adequate voltage would be maintained at the 480 V buses.
The icad flow ~results showed=however, that the voltage on r
4.16 kV buses NB011and NB02-necessary.to support the 480 V system had increased to-3704 V.
The degraded voltage
- setpoint calculation (i.e.,
Calculation H-8) should have
' been revised to reflect this higher value.
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-Attachment.1 ULNRC< 2 714 -
Page 2 of 3 The required setpoint for the exieting7 tap conditions determined in B-17 Revision 1 were calculated using load data provided by UE.
The Class 18 distribution system was modeled from the 4.16 kV buses down to the 480 V motor control centers using Bechtel's load flow program.
The voltage at the 4.16 kV bus was adjusted until any one motor control center rem bad its voltage limit.
These values were determined to be 3720 V u.0:
V LSELS input) for NB01 and 371C V (106.2 V LSELS input) for NB02.
This value of voltage represents the desired degraded voltage setpoint.
The components comprising the degraded voltage sensing 7
circuit were examined to obtain the tolerance which should be applied to the setpoint.
The errors associated with the analog sensing module of the LSELS panel are less tha:1.25%
(setting accuracy) plus 0.5% (drift, power supply and thermal effects).
The potential transformer was specified F
te have an adequacy of 0.3% at standard burdens.
In accordance with ISA guidelines (ISA DRP 67.04), the total uncertainty of these unrelated terms was determined ing _ root-
)'
mean-square methodology,' yielding a total uncertainty of
.63%.
In order to ensure that the LSELS bistable-is set above:the desired minimum, the recommended setpoint is 106.3
- 1.0063 or 106.97 for NB01 and 106.2
- 1.0063 or 106.87.for NB02.
The LSELS bistables had previously been setLat approximately 105.9 V (104.5 plus tolerance).
The significance of this discrepancy is that if a degraded voltage condition occurred wherein the 4.16 kV bus voltage dropped below 3704 V but not=below 3656 V, with the bus loading uaed in Calculation B-17,-the voltage availabla-at the 480 V load centers motor control centers could fall below the baseline valuc3 used to establish that motors were
-operating within their-rating and that MCC control circuits had sufficient-voltage to pickup.
Ghould motors be-operated' at less than.90% of nominal voltage,-the. currents drawn by the motors would increase proportionally.
Since the-difference in voltage in-this_ case is very-small_, the effect,'if any, would bc a slight' increase in motor temperature.
As power plant motors generally do not 7perate at their nameplace values and1since the effect, if-any,'of the reduced voltage would be long term and_not sudden or catastrophic,_the impact of the degraded setpoint on-motor operability is. considered insignificant.
In order to evaluate.the impact of MCC voltages less than 92%, the calculation performe<
establish raximum control circuit lengths _(Calcula 6-10) and the study to check control circuits against the c61culated lengths, were reexamined as part of this-evaluatian.
Neu permissible
x Athachmentil-
-ULNRC 2714 Page'3;ofn3 lengths were calculated to: correspond to the-lower voltage which could exist at an MCC should the 4.16 kV buses reach the previous degraded voltage-setpoint.
The new lengths.
were-then compared to the totalized lengths-for_. safety related circuits compiled in _tlua earlier study.
With-one exception. all the scheduled circuit lengths were below the new permissible lengths.
The single exception, the circuit for diesel generator room supply fan DCGM01B had subsequently been modified by Union Electric for other reasons, at which time the eddition of an auxiliary relay effectively reduced the critical control circuit length to a negligible-value.
In= order to determine if, prior to the UE modification, a possible safety concern existed, the circuit in place prior tx) the modification was examined in detail.
The actual cable lengths (determined by field verification)' for this-circuit wera compared to those used in the circuit study._ The study-had used scheduled cable lengths known to often be conservatively long.
The cable lengths determined through a field walkdown were significantly less than the scheduled lengths.
The total control circuit length when recalculated with the actual cable 3engths was well below the new-c permissible length discussed above.
To further ascertain proper operation of this circuit,.
a load flow care which modelled the system condition before the fan was starting was studied.
The results of this. case demonstrated that with 4.16 KV bus NB02 at the previous degraced voltage setpoint,.the MCC loading without the-DG room fan running was such that'the voltage at MCC NG04D-was greater than 92%.
~
Based upon the analyses' described above, it.was confirmed that the setpoint discrepancy-did not cause a safety concern'and, therefore, is not reportaole to the NRC-under the provisions of 10 CFR Part 21.
In conclusion, we feel that the failure to revise-the M
LSELS setpoint calculation:in response'to a1 revision of a' l
referenced-calculation wastan isolated-instance of-an-
.cversight and:ia-not representative of a-genericLproblem.
As discussed above this isolated setpoint discrepancy _does not represent a reportable deficiency under 10 CFR-21.
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ULNRC. 2714 _
- Pagec1 of 3 I
DEGRADED VOLTAGE SETPOINT REVISION AND VOLTAGE S_AFETY LIM!T_ ANALYSIS DESIGN CilANGE CMP 91-1034 REVISES THE DEGRADED VOLTAGE SETPOINT AND THE TOLERANCE FROM 104.5 +2.6/ - 0 VOLTS TO 107.47 +/-
0.38 VOLTS. Tills CllANGE INVOLVES A C!!ANGE TO THE PLANT TECilNICAL SPECIFICATIONS.
Tills SETPOINT CIIANGE INCLUDES:
- 1) A REVISION IN Ti1E ANALYSIS OF THE LOOP TOLERANCES USING ISA STANDARD DRP 67.04.--- CALLAWAY USES PROCEDURE J-U-GEN TO PERFORM THIS ANALYSIS.
- 2) A REVISION OF THE LOWER LIMIT OF THE DEGRADED VOLTAGE VOLTAGE SETPOINT B AND.--- Tills IS CONSIDERED AS A SAFETY' LIMIT. THIS VOLTAGE LIMIT IS PRODUCED USING LOAD FLOW TECHNIQUES, THE LOAD ~
FLOW CONSERVATISMS B ASED ON INITIAL DESIGN ASSUMPTIONS ARE BEING REVISED USINJ ACTUAL COMPONENT DATA AND OPERATIONAL CONSIDERATIONS.
TIIE RESULTS OF THIS ANALYSIS IS USED AS THE SAFETY LIMIT.
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Page 2 ofl3:
1:
DEGRADED VOLTAGE LOOP UNCERTAINTY BREAKDOWN-AND PLANT LOAD FLOW ALLOWANCE System Allowable l-4
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-1 Operation Band Safety Ops.
Limit -
Ur.acc ep table
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Safety 106.3 107.09 107.47 108.06
.f Limit Old Band Safety 107.85; i
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ULNRC-2714 Parte 3 of 3
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- IO Appendix A Job BALANCE OF PLANT sh e i or i SETPOINT UNCERTAINTY BREAKDOWN
'h 2 SAFETY LIMIT (ON CONTROL LOGIC DIAGR AM) c en J U AC. O t A DBA AND / OR jf cAtc. No.
SEISMIC EFFECTS.
11 REV.
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8i osicINAToR _ %.((M PROCESS AND PROCESS o
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MEASUREMENT catcnto '/.k(/A %
CON SIDERATIONS o
ji o9 DATI9 0 4' SENSOR BASIC ACCURACY 8
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,j RACK EASIC ACCURACY v TA = "LU RACK ENVIRONMENTAL v EFFECTS. g,. RACK POWER SUPPLY T =LU+SA+RA t.u EFFEC TS. y si MEASUREMENT AND H a* TEST EQUIPMENT lle UNCERTAINTY (M &TE) o y %ij SYSTEM SENSOR DRIFT ]j ALLOWABLE VALUES bh SENSOR SETTING TOLERANCE o o E l *. RACK ~ ~ RACK DRIFT y8j ALLOWABLE VALUE u h RACK SETTING j l* a TOLERANCE FINAL SETPOINT2 y y y dI $1
- 1. TECHNICAL SPECIFICATION ALLOWABLE VALUE.
- 2. TECHNICAL SPECIFICATION TRIP SETPOINT.
'Ii THIS Of AGRAM tS %LY INTENDED TO ILLUSTRATE THE COMPONENT '1 NOTE: yfl THE INSTRUMENT LOOP UNCERTAINTY AND THEIR RELATIONSHIP TRIP VALUES.AND FINAL SETPOINT. UNDER NO CIRCUNSTANCE 15 THIS INTENDED TO IMPLY THE SPECIFIC COMBINATION OF THE COMPONEN 3eg 2:$; - - - - - ~ - - - _ _ _ _ _ _, _. _ _, _ _ _ _
-. -. ~,--- -n 4,' 7 EAttachments3- ..'~ - ULNRC-2 714 Page-11of.4
SUMMARY
OF UNION ELECTRIC SOS 91 0469 q DESCRIPTION -l During Union Electric's Electrical Distribution Safety-i Functional Assessment (EDSFA) of the Callaway Nuclear Plant, a concern was raised regarding the setting of the degraded voltage setpoint, The setting at that time was'104;5 volts whereas a setting of 106.2 volts was appropriate. A degraded voltage setpoint of 104.5 volts was calculated lin_ Calculation E-H-0 based on data taken from load studies in-Calculations'E-L-17 and E-B-S which provide the_NB bus voltage level at which the Motor Control Center (MCC) _ control circuits.would be capable of functioning properly. Subsequent to the original issue of Calculation E-H-8, the NB bus voltage level data of Calculation E-B-17 was. revised', but the revised data was not reflected in a revision'to Calculation E-H-8. This-failure to revise the degraded-e voltage setpoint means that given the specific abnormal equipment line-ups and assumptions of-the_ load flow: study case, a degraded voltage condition could exist on'the.MCC-control circuits before the automatic protection functions to remove that source, This condition would not meet the requirements of NRC Branch Technical Position BSP-1-,-_Using the values from the latest approved load flow = analysis, Calculation ZZ+62 Revision 0, the setpoint should-more appropriately-be.106.2 volts. ~ -QEE8 ABILITY The plant is ;consideret operable for all past operations'. M This is demonstrated byLan analysis of.the plant electrical 1 system-using load flow techniques which shows, with_the current. analyzed loads, that at no time would the voltage at ~ any:. service ~ level drop to;the point at.which any1 component would become inoperable, Calculations-ZZ-62 Revision:0,4 E-B-5LRevision 3,'E-B-17 Revision 1, and E-B-18 Revision 10 .present;the analyzedLload cases,. They show>that the minimum 1 design switchyard-voltage of 345'kV would'be adequate =when- . the :NP busses-are-not tied together when LOCA loads are on the busses. The calculations show that if site'loadsfare. not t ransferred ' prior to tying the busses _to one-ESF transformer, a-switchyard = voltage of 350.4 kV would.be - adeqt ate to support operability of all components. _ (This is a wot it case abnormal.line-up in which the plant: enters ' a . Tech Spec action statement because operation on the emergency diesel generator is not preferred and the bus'~ normal ESF transformer in not available). The followingu m e r rv y n u w m y w,
ULNRC-2714 Page 2 of 4 provides additional detail for the determination of past operability: Per Calculation E-B-17, the switchyard design values are currently 345.0 kV to 372.6 kV. Calculations ZZ-62 Revision 0, E-B-17 Revision 1, E-B-18 Revision 0 shows that the switchyard may be operated in that range, provided that the site load is transferred prior to tying both NB busses to one ESF transformer. Per Calculation E-B-18 Revision 1, the switchyard minimum voltage required would be 350.4 kV if no load transfers are completed prior to tying both NB busses to XNB02 and the minimum is 346.5 kV if no load transfers are completed prior to tying both NB busses to XNB01. At no time has Callaway entered action statement 3.6.3.1.A in which both busses are fed from one ESP transformer during Modes 1, 2, 3 of 4. At no time has Callaway failed the monthly surveillance in which-the switchyard voltage is inspected .o see that the voltage is between 353.62 to 372.6 kV, This lower value of 353.62 kV is conservative for the current design during any plant configuration. l This value had been the minimum allowed in 1985 when l transformer taps-were being adjusted. It had not been-changed to the lower value of 350.4'kV because '.he tolerances of the devices measuring were large for measuring-the switchyard voltage. A better indication has since been provided but this conservatism'has not yet been reduced. Logs of the switchyard voltage were reviewed for voltages recorded for the past two years. These logs show an' hourly integrated averaged. voltage for' data read every two seconds. At no time was the voltage seen to-drop below the required minimum switchyard vol tage was 353. 62 kV. The lowest indicated switchyard vo2 tage was 355. 6 kV. This indicates that the degraded voltage oistables would not have been challenged. The. indicated mean voltage was 362.0 kV'with a. standard deviation of 1.87 kV.- The lower confidence limit is 362.68 kV for a confidence factor of 99.9999426t. This indicates that the-voltage would have been below-352.68 kV for a total of 2.3 minutes over a 7.5 year time span. The' time needed to produce a trip on
Attachment'3' ULNRC-2 714 Page 3 of.4 degraded voltage is approximately two minutes so it is very unlikely-that a trip would have occurred. The requirement to have a device to detect and remove the bus off of the degraded sour ' is from NRC Branch Technical Position P3B-1. This equipment provides additional i protection against circumstances not designed for, which nay i create inoperable equipment when a degraded' voltage is present_that is not sufficient for equipment to_ operate. Loss of this function would be a loss of a safety function and an improper setpoint would present a substantial safety hazard if found not to function before any equipment important to safety was made inoperable. This would be reportable under 10 CFR Part 21. -Currently Bechtel believes that the old setpoint was adequate, however,- most normal conservatisms would be removed or greatly reduced in demonstrating the adequacy of the.old setpoint. Other mitigating factors are: One safety-related 480 -V bus undervoltage alarm.cn1 each train is currently set so that it would have alarmed prior to any equipment becoming inoperab)2. These are on busses NG01 and NG02. At no time have the existing degraded-voltage bistables been actuated during normal service. This would have produced an ESF actuation that would have shed the loads from the affected train, started the emergency diesel generator and sequenced loads on the bus. The facts and data presented above show that'at no time would any device have misoperated.due to low voltage. 'This means that all components providing a-safety function were operable whether or not the bistable degraded voltage-setpoint_were proper. Also, at no time should the bistables have been_ called upon to operate. CORRECTIVFmA_CTION TO PREVENT RECURRENCE-A-recalculation of1the degraded voltage setpoints was performed'and shows that the minimum allowable voltage sensed off the NB busses must ba-at least 106.3 volts versus the old value of 104.E volts. 2 As an interim solution, work requests were generated to increase the setpoint to be in the range of both_ tolerance bands. The settings were'specified to be set from 106.3 to 107.1 volts, i.e., it was still in the current licensed values and in_the new calculated values. Also, procedures were revised to contain the interim band, as a desired band,_ 7
p-Attachmenth32 + ULNRC 2714 P a g e 4 _ o f._' 4-to which the overall loops should be_ calibrated. This was noted to be in effect until a dasign change could be completed which approved and licensed new values for the-degraded voltage setpointr. While thO problem was not created from a-UE design program,' the UE program was checked for possible improvements. lit appr.ared that the problem occurred when one calculation was revised, but another affected-calculation was-not. A design basis program has been instituted that'placed in a computer database sortable information that can cross-reference the design calculations to identifyLother affected calculations. 'is would aid the existing procedural requirement tu -iew for and change any impacted e calculation as necessary during the -design change process. This was-developed due to an earlier QA-audit _--. finding and-has been found acceptable. Addiiionally, management is implementing-a program in which design guides are produced for those designs which are commonly'made. These will present_ interfaces which-may not be readily apparent, to supplement existing procedures and-knowledge.. It is expected that l oad flow,. voltage drop and ^q the degraded voltage setpoints will.be addressed in one of these_ guides. A modification-ia being. implemented to change-the LSELS: bistable'setpoints. A Tech Specichar.ge vill'be; processed-and approved with'the modification. The-modification-is- - expected to-be: final pending1NRC approval of the. Tech Spec-y change. q ] o a q ? j 1 r l-H LI .q 1 l 1 i 1 r P 4 e .n. e a w 1
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