ML20126C753
| ML20126C753 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/10/1985 |
| From: | SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | |
| Shared Package | |
| ML20126C750 | List: |
| References | |
| NUDOCS 8506140517 | |
| Download: ML20126C753 (11) | |
Text
6-a 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
Two physically independent circuits between the offsite transmission a.
network and the onsite Class IE distribution system, and b.
Two separate and independent Emergency Diesel Generators (EDG), each l with:
1.
A separate day tank containing a mininum of 300 gallons of fuel, l and 2.
A separate fuel storage system containing a mininum of 42,500 l
gallons of fuel, and 3.
A separate fuel trans fer pump.
APPLICABILITY:
MODES 1, 2, 3 and 4.
ACTION:
a.
With one offsite circuit of 3.8.1.1.a inoperable:
1.
Demonstrate the OPERABILITY of the remaining offsite A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter and, 2.
If either EDG has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Survelliance Requirement 4.8.1.1.2.a.3 separately for each such EDG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the diesel is already operating and, 3.
Restore the of fsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b.
With one EDG of 3.8.1.1.b inoperable:
1.
Demonstrate the OPERABILITY of the A.C. of fsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter and, 2.
Demonstrate the OPERABILITY of the remaining EDG by performing Surveillance Requirement 4.8.1.1.2.a.3 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and, 3.
Verify that required systems, subsystems, trains, components and devices that depend on the remaining EDG as a source of emergency power are also OPERABLE and in MODE 1, 2, or 3, that the Turbine l
Driven Emergency Feed Pump is OPERABLE within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SUMMER - UNIT 1 3/4 8-1$1N P
r-T i
ELECTRICAL POWER SYSTEMS ACTION:
(Continued) 4.
Restore the EDG to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SKUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c.
With one offsite circuit and one EDG inoperable:
1.
Demonstrate the OPERABILITY of the remaining offsite A.C. source by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter and, 2.
Demonstrate the OPERABILITY of the remaining EDG by performing Surveillance Requirement 4.8.1.1.2.a.3 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and, 3.
Verify that required systems, subsystems, trains, components and devices that depend on the remaining EDG as a source of emergency power are also OPERABLE and in MODE 1, 2, or 3, that the Turbine Driven Emergency Feed Pump is OPERABLE within 2 h ours.
If th<.ae condittons are not satis fied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the.next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
4.
Restore one of t;ie inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and, 5.
Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 Action Statement a. or b., as appropriate, with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperdble A.C. power s ou r ce.
d.
With two of the required offsite A.C. circuits inoperab le:
1.
Demonstrate the OPERABILITY of the two EDG's by sequentially performing Surveillance Requirement 4.8.1.1.2.a.3 on both within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the EDG's are already operating and, 2.
Restore one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 h ou rs.
3.
Following restoration of one of fsite source, follow Action Statement a. with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable offsite A.C. circuit.
e.
With two of the above required EDG's inoperable:
1.
Demonstrate the OPERABILITY of two of fsite 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 <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter and, 2.
Restore one of the inoperable EDG's to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
3.
Following restoration of one EDG, follow Action Statement b.
with the time requirement of that Action Statement based on the l time of initial loss of the remaining inoperable diesel l
generator.
3/4 8-2 SUMMER - UNIT 1
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be:
a.
Determined OPERABLE at least once per 7 days by verifying correct breaker alignment and indication of power availability, and b.
Demonstrated OPERABLE at least once per refueling outage by manually l transferring the onsite Class 1E power supply from the normal circuit to the alternate circuit.
4.8.1.1.2 Each EDG shall be demonstrated OPERABLE:
l 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 and fuel storage tank.
l 2.
Verifying the fuel transfer pump can be started and transfers l
fuel from the storage system to the day tank.
3.
Verifying the diesel generator can start
- and accelerate to synchronous speed (504 rpm) with generator voltage and frequency at 7200 1 720 volts and 601 1.2 Hz.
4.
Verifying the generator is synchronized, gradually loaded
- to an indicated 3900-4100 kW** and operates for at least 60 minutes.
b.
At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to I hour by removing accumulated water from the day tank.
By obtaining a sample of fuel oil in accordance with ASTM-D270-1975 c.
at least once per 92 days and prior to the addition of new fuel oil to the storage tanks and verifying that the sample meets the following minimum requirements and is tested within the specified time limits:
1.
As soon as the sample is taken (or prior to adding new fuel to l
the storage tank) verify in accordance with the tests specified in ASTM-D975-77 that the sample has:
a) A water and sediment content of less than or equal to 0.05 volume percent.
b) A kinematic viscosity @ 40'C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes.
- This test shall be conducted in accordance with the manuf acturer's recommen-dations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations.
i
- This band is meant as guidance to avoid routine overloading of the engine.
Loads in excess of this band shall not invalidate the test.
SUMMER - UNIT 1 3/4 8-3 l
l :.
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c) A specific gravity as 'specified by the manuf acturer 9 60/60'F of greater than or equal to 0.83 but less than or equal to 0.89 or an API gravity 8 60*F of greater than or equal to 27 degrees but less than or equal to 39 degrees..
2.
Within 1 week after obtaining the sample, verify an impurity
-level of less than 2 og of insolubles per 100 m1 when tested in accordance with ASTM-D2274-70.
3.
Within 2 weeks of obtaining the sample, verify that the other properties specified in Table 1 of ASTM-D975-77 and Regulatory Guide 1.137 Position 2.a are met when tested in accordance with ASTM-D975-77.
d.
At least once per 184 days by:
1.
Starting and accelerating the EDG to synchronous speed (504 rpm) with generator voltage and frequency at 7200 + 720 volts and 60 +
(
1.2 Hs within 10 seconds after the start signal. The EDG shal1 ~
be started for this test by using one of the following signals:
a) Sissalated loss of offsite power by itself.
b) Simulated loss of offsite power in conjunction with an ESF actuation test signal.
c) An ESF actuation test signal by itself.
i~
d) Simulated degraded offsite power by itself.
e) Manual.
2.
The generator shall be manually synchronized, loaded to an i.
indicated 3900-4100** kW in less than or equal to 60 seconds, and operate for at least 60 minutes.
At least once per refueling outage by:
l e.
1.
Sub'jecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manuf acturer's recommendations for this class of standby service.
2.
Verifying that, on rejection of a load of greater than or equal to 729 kW the voltage and frequency are maintained with 7200 +
720 volts and 60 + 1.2 Hz.
3.
Sissalating a loss of offsite power by itself, and:
l a) Verifying de-energisation of the emergency busses and load shedding from the emergency busses.
b)- Verifying the diesel starts on the auto-start signal, energises the emergency busses with permanently connected j
loads within 10 seconds, energises the auto-connected shut-down loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. Af ter energisation of these loads, the steady state voltage and frequency shall be maintained at 7200 + 720 volts and 60 + 1.2 Hz.
j
- This band is meant as guidance to avoid routine overloading of the engine.
l Loads in excess of this band shall not invalidate the test.
SUMIER - UNIT 1 3/4 8-4
7-ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.
Verifying that on an ESF actuation test signal, without loss of l
offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be 7200 + 720
~
volts and 60 + 1.2 Hz within 10 seconds after the auto-start signal [* the steady-state generator voltage and frequency shall be l mainta ned within these limits during this test.
S.
Simulating a loss of of fsite power in conjunction with an ESF l
actuation test signal, and a) Verifying de-energization of the emergency busses and load shedding from the emergency busses.
b) Verifying the EDG starts in the emergency mode, energizes the l emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes and maintains the steady state voltage and frequency at 7200 + 720 volts and 60 + 1.2 Hz.
c) Verifying that all EDG trips, except engine overspeed, generator differential and low lube oil pressure are automatically bypassed upon loss of voltage on the emergency bus and/or a safety injection actuation signal.
l 6.
Verifying the EDG operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
a) During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the EDG shall be loaded to an indicated target value of 4676 kW (between 4600-4 700 kW)**.
b) During the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the EDG shall be loaded to an indicated 3900-4100 kW**.
c) During this test the steady state voltage and frequency shall be maintained at 7200 + 720 volts and 60 + 1.2 Hz.
d) Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2.e.3.b.
7.
Verifying that the auto-connected loads to each EDG do not exceed l the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 4548 kW.
8.
Verifying the EDC's capability to:
l a)
Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a sinulated restora-tion of offsite power, b) Transfer its loads to the offsite power source, and c) Be restored to its standby status.
- This band is meant as guidance to avoid routine overloading of the engine.
Loads in excess of this band shall not invalidate the test.
SUMMER - UNIT 1 3/4 8-5
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 9.
Verifying that with the diesel generator operating in a test l
mode, connected to its bus,(a simulated safety in;ection signal overrides the test mode by 1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with of fsite power.
- 10. Verifying that the fuel transfer pump transfers fuel from each l
fuel storage tank to the day tank of each diesel via the installed cross connection lines.
- 11. Verifying that the automatic load sequence timer is OPERABLE with l the interval between each load block within + 10% of its design interval.
- 12. Verifying that the following diesel generator lockout features l
prevent diesel generator starting only when required a) Barring Device b)
Remote-Local-Maintenance Switch f.
At least once per 10 years or after any modifications which could l
affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 504 rpm in less than or equal to 10 seconds.
g.
At least once per 10 years by:
l 1.
Draining each fuel oli storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or its equivalent, and 2.
Performing a pressure test of those portions of the diesel fuel oli system designed to Section III subsection ND of the ASME Code at a test pressure equal to 110 percent of the system design pressure.
SUMMER - UNIT 1 3/4 8-6 l
l
n i
TABLE 4.8-1 DIESEL CENERATOR TEST SCHEDULE Number of Failures Number of Failures in in Last 100 Valid Last 20 Valid Tests
- Tests
- Test Frequency
$1 14 Once per 31 days
>2**
>5 Once per 7 days
- Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108,
[
but determined on a per diesel generator basis.
For the purposes of determining the required test frequency, the previous test failure count may be reduced to zero if a complete diesel overhaul to like-new conditions is completed, provided that the overhaul, including appropriate post-maintenance operation and testing, is specifically approved by the manufacturer and if acceptable relisbility has been demonstrated. The reliability criterion shall be the successful completion of 14 coasecutive tests in a single series. Ten of these tests shall be in accordance with Surveillance Requirement 4.8.1.1.2.a.3; fair tests, in accordance with Surveillance Requirement 4.8.1.1.2.d.
If this criterion is not satisfied during the first series of tests, any alternate criterion to be used to transvalue the failure count to zero requires NRC approval.
- The associated test frequency shall be maintained untti seven consecutive f ailure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one.
SUMMER - UNIT 1 3/4 8-7 l
l
i ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
a.
One circuit between the of fsite transmission network and the onsite Class IE distribution system, and b.
One diesel generator
- with:
l 1.
A day tank containing a minimum volume of 300 gallons of fuel, 2.
A fuel storage sys tem containing a minimum volume of 30,000 gallons of fuel, and 3.
A fuel transfer pump.
. APPLICABILITY:
MODES 5 and 6.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive l
reactivity changes, movenent of irradiated fuel, or crane operation with loads over the fuel storage, pool.
In addition, when in MODE 5 with the Reactor Coolant loops not filled, or in MODE 6 with the water level less than 23 feet above tFa reactor vessel flange, immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible.
SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C electrical power sources shall be demonstrated OPERABLE by the performance or verification of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2.
l
- ESF Load Sequencer may be deenergized in Mode 5 and 6.
l SUMMER - UNIT 1 3/4 8-8 l
l
d 3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1, 3/4.8.2 AND 3/4.8.3 A.C. SOURCES, D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C and D.C. power sources and associated distribution systems during operation ensures that suf ficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility. The mininum specified independent and redundant A.C. and D.C. power sources and distribution sy'A" to 10 CFR 50. stems satisfy the requirements of General Design Criterion 17 of Appendix The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source. The A.C. and D.C. source allowable out-of-service times are based on Regulatory Guide 1.93,
" Availability of Electrical Power Sources," December 1974. When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required sys tems, subsys tems, trains, components and devices, that depend on the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE. This requirement is intended to provide assurance that a loss of offsite power event will not result in a complete loss of safety function of critical systems during the period one of the diesel generators is inoperable.
The term verify as used in this context means to administratively check by examining logs or other information to determine if certain components are l
out-of-service for maintenance or other reasons.
It does not menn to perform the surveillance requirements needed to demonstrate the OPERABILITY of the i
l component.
1
(
The OPERABILITY of the mininum specified A.C. and D.C. power sources and I
associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) suf ficient instrumentation and control capability l
I is available for monitoring and maintaining the unit status.
SUMMER - UNIT 1 B 3/4 8-1 l
4 ELECTRIC POWER SYSTEMS
~
BASES A.C. SOURCES, D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS (Continued)
The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are based on the recommendations of Regulatory Guide 1.129,
" Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended j
Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."
Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage onfloat charge, connection
.i resistance values and the performance of battery service and discharge tests i
ensures the effectiveness of the charging system, the ability to handle high j
discharge rates and compares the battery capacity at that time with the rated f
capacity.
Table 4.8-2 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage and specific gravity. The limits for the designated pilot cells float voltage and specific
. k gravity, greater than 2.13 volts and.015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adequate capacity.
The normal
. limits for each connected cell for float voltage and specific gravity, greater than 2.13 volts and not more than.020 below the manufacturer's full charge specific gravity with an average specific gravity of all the connected cells Q, r.
not more than.010 below the manufacturer's full charge specific gravity, j-ensures the OPERABILITY and capability of the battery.
Jhg.y,w
' Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table-4.8-2 is permitted for up to 7 days.
During this 7 day period:
(1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron g.g~,
transfer capability; (2) the allowable value for the average specific gravity
' eer of all the cells, not more than.020 below the manufacturer's recommended full
- jY,@'
charge specific gravity, ensures that the decrease in rating will be less than i
the safety margin provided in sizing; (3) the allowable value for an indi-vidual cell's specific gravity, ensures that an individual cell's specific s
gravity will not be more than.040 below the manufacturer's full charge specific G,(,
gravity and that the overall capability of the battery will be maintained f.'ju within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability f&].S to perform its design function.
SUMMER-UNIT 1 B 3/4 8-2
\\s
.g.
.n.
a, ATTACHMENT "B" No Significant Hazards Consideration The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated because the only change is a reduction in frequency and severity of diese1' generator test starts which will result in less wear and stress on engine parts..This will decrease the probability of an. accident due' to failure of engine parts, and the consequences of an accident will not change.
The proposed amendment does not create the possibility of a new kind of accident from any accident previously evaluated because the design and function of the diesel generator will not change.
The proposed amendment does not involve a significant reduction in the margin of safety because there will be no change in response times or emergency loads assumed in the accident analysis.
L-