Text

Technical Specification Bases 3.8
	ML20134H953
Person / Time
Site:	Grand Gulf
Issue date:	05/12/2020
From:	Siva Lingam; NRC/NRR/DORL/LPL4
To:	;
	Lingam S
References
	Download: ML20134H953 (119)
	v • d • e

AC Sources Operating B 3.8.1 BASES ACTIONS B.3.1 and B.3.2 (continued)

Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) are declared inoperable upon discovery, and Condition E and potentially Condition H of LCO 3.8.1 is entered. Once the failure is repaired, and the common cause failure no longer exists, Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DG(s).

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the Corrective Action Program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable time to confirm that the OPERABLE DG(s) are not affected by the same problem as the inoperable DG.

B.4 In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E distribution system. Although Condition B applies to a single inoperable DG, several Completion Times are specified for this Condition.

Division 3 DG The first Completion Time applies to an inoperable Division 3 DG. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period. This Completion Time begins only upon discovery of an inoperable Division 3 DG and, as such, provides an exception to the normal time zero for beginning the allowed outage time clock (i.e., for beginning the clock (continued)

GRAND GULF B 3.8-8 LBDCR 16007

AC Sources Operating B 3.8.1 BASES ACTIONS B.4 (continued) for an inoperable Division 3 DG when Condition B may have already been entered for another equipment inoperability and is still in effect). As discussed in the APPLICABILITY SECTION a NOTE for Division 3 DG is provided allowing an exception to be taken to the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months completion time. By declaring the HPCS System inoperable, the Division 3 DG allowed outage time could be extended up to 17 days (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months plus ECCS allowed outage time of 14 days). Use of this extension could be warranted for an unplanned DG inoperability and for voluntary planned maintenance or inspections. Any voluntary maintenance or inspection of the Division 3 DG shall be performed using a risk-informed process as required by 10CFR50.65(a)(4).

Additional contingencies are to be in place for the duration of the extended AOT duration (greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and up to 17 days) as follows:

1. Weather conditions will be evaluated prior to entering an extended DG allowed outage time for voluntary planned maintenance. An extended DG allowed outage time AOT will not be entered for voluntary planned maintenance purposes if official weather forecasts are predicting severe conditions (hurricane, tropical storm, tornado, or snow/ice storm) that could significantly threaten grid stability during the planned outage time.

2. The condition of the offsite power supply and switchyard will be evaluated.

3. No elective maintenance will be scheduled within the switchyard that would challenge offsite power availability during the extended Division 3 DG allowed outage time.

4. Operating crews will be briefed on the DG work plan whenever the extended allowed outage time period is used, with consideration given to key procedural actions that would be required in the event of a loss of offsite power or station blackout.

(continued)

GRAND GULF B 3.8-8a LBDCR 16007

AC Sources Operating B 3.8.1 BASES ACTIONS B.4 (continued)

5. The RCIC high pressure injection system and the Division 1 and 2 DGs will not be taken out of service for planned maintenance while the Division 3 DG is out of service during the extended allowed outage time.

Division 1 and 2 The second Completion Time (14 days) applies to an inoperable Division 1 or Division 2 DG and is a risk-informed allowed outage time (AOT) based on a plant specific risk analysis. The extended AOT would typically be used for voluntary planned maintenance or inspections but can also be used for corrective maintenance.

However, use of the extended AOT for voluntary planned maintenance should be limited to once within an operating cycle (24 months) for each DG (Division 1 and Division 2).

Additional contingencies are to be in place for any extended AOT duration (greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and up to 14 days) as follows:

1. Weather conditions will be evaluated prior to entering an extended DG AOT for voluntary planned maintenance. An extended DG AOT will not be entered for voluntary planned maintenance purposes if official weather forecasts are predicting severe conditions (hurricane, tropical storm, tornado, or snow/ice storm) that could significantly threaten grid stability during the planned outage time.

2. The condition of the offsite power supply and switchyard will be evaluated.

3. No elective maintenance will be scheduled within the switchyard that would challenge offsite power availability during the proposed extended DG AOT.

4. Operating crews will be briefed on the DG work plan whenever the extended AOT period is used, with consideration given to key procedural actions that would be required in the event of a loss of offsite power or station blackout. It is expected that the Division 3 DG can be cross-connected and ready to power required shutdown equipment on either Division 1 or Division 2 ESF bus within two hours of determining a need to cross-connect.

(continued)

GRAND GULF B 3.8-8b LBDCR 16007

AC Sources Operating B 3.8.1 BASES ACTIONS E.1 (continued) remaining inoperable. However, with a Division 1 or 2 DG remaining inoperable and the HPCS declared inoperable, a redundant required feature failure exists, according to Required Action B.2.

F.1 Each sequencer is an essential support system to both the offsite circuit and the DG associated with a given ESF bus. Furthermore, the sequencer(s) is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus. Although loss of an ESF bus's sequencer potentially affects the major ESF systems in the division, a design basis event with the worst single failure would not result in a complete loss of onsite power function (DGs) and would be mitigated to some extent by the redundant onsite sources. In addition, operator action to start the DG affected by the inoperable sequencer and manually connect the required ESF loads to either the affected DG or an available offsite source represents a significant benefit justifying an extended Completion Time over the condition of one DG and one offsite circuit inoperable. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident requiring sequencer OPERABILITY occurring during periods when the sequencer is inoperable is minimal.

G.1 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the unit must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action G.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment (continued)

GRAND GULF B 3.8-13 LBDCR 14043

AC Sources Operating B 3.8.1 BASES ACTIONS G.1 (continued)

(continued) addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, GDC 18 (Ref. 9). Periodic component tests are supplemented by extensive functional tests during refueling outages under simulated accident conditions. The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), and Regulatory Guide 1.137 (Ref. 11).

Where the SRs discussed herein specify voltage and frequency tolerances, the minimum steady state output voltage of 3744 V and 4576 V respectively, are equal to +/- 10% of the nominal 4160 V output voltage. The specified maximum and minimum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively, are equal to +/- 2% of the 60 Hz nominal frequency. The specified steady state voltage and frequency ranges are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

(continued)

GRAND GULF B 3.8-14 LBDCR 14043

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.1 REQUIREMENTS (continued) This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.1.2 and SR 3.8.1.21 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by Notes (the Note for SR 3.8.1.21 and Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading.

For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations for DG 11 and DG 12. For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

In order to reduce stress and wear on diesel engines, the manufacturer recommends that the DGs be gradually accelerated to synchronous speed prior to loading. These modified start procedures are the intent of Note 3 of SR 3.8.1.2, which is only applicable when such procedures are used.

(continued)

GRAND GULF B 3.8-15 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.21 (continued)

REQUIREMENTS (continued)

SR 3.8.1.21 requires that, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The DG's ability to maintain the required voltage and frequency is tested by those SRs which require DG loading. The 10 second start requirement supports the assumptions in the design basis LOCA analysis (Ref. 5).

The start requirements may not be applicable to 3.8.1.2 (see Note 3 of SR 3.8.1.2), when a modified start procedure as described above is used.

If a modified start is not used, the start requirements of SR 3.8.1.21 apply.

Since SR 3.8.1.21 does require a 10 second start for each DG, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.

This is the intent of Note 1 of SR 3.8.1.2. Similarly, the performance of SR 3.8.1.12 or SR 3.8.12.19 also satisfies the requirements of SR 3.8.1.2 and SR 3.8.1.21. In addition to the SR requirements, the time for the DG to reach steady state operation is periodically monitored (data is taken once per 6 months during the performance of SR 3.8.1.21) and the trend evaluated to identify degradation of governor and voltage regulator performance.

The DGs are started for this test by using one of the following signals:

manual, simulated loss of offsite power by itself, simulated loss of offsite power in conjunction with an ESF actuation test signal, or an ESF actuation test signal by itself.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.8.1.3 This Surveillance demonstrates that the DGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

(continued)

GRAND GULF B 3.8-15a LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3 (continued)

REQUIREMENTS Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.9 lagging and 1.0.

The 0.9 value is conservative with respect to the design rating of the machine, while 1.0 is an operational limitation to ensure circulating currents are minimized. The load band for DG 11 and 12 is provided to avoid routine overloading of the TDI DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

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

Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.

Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test.

Note 3 indicates that this Surveillance shall be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.

Note 4 stipulates a prerequisite requirement for performance of this SR.

A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 This SR provides verification that the level (expressed as an equivalent volume in gallons) of fuel oil in the day tank is at or above the level which ensures adequate fuel oil for a minimum of 30 minutes of DG operation at the maximum expected post LOCA load.

(continued)

GRAND GULF B 3.8-16 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.4 (continued)

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

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Periodic removal of water from the fuel oil day tanks eliminates the necessary environment for bacterial survival. This is an effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support the continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

(continued)

GRAND GULF B 3.8-17 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.6 (continued)

REQUIREMENTS The design of the fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks during or following DG testing. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.1.7 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents. The load sequencing ensures that sufficient time exists for the bus power supply to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

This Surveillance is a manual test of the load shedding and sequencing panels and verifies the load shedding and sequencing panels respond within design criteria to the following test inputs: LOCA, bus undervoltage, bus undervoltage followed by LOCA, and LOCA followed by bus undervoltage.

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

SR 3.8.1.8 Transfer of each 4.16 kV ESF bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

GRAND GULF B 3.8-18 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.8 (continued)

REQUIREMENTS This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load while maintaining a specified margin to the overspeed trip. The referenced load for DG 11 is the 1314 kW low pressure core spray pump; for DG 12, the 686 kW residual heat removal (RHR) pump; and for DG 13 the 2411 kW HPCS pump. The Standby Service Water (SSW) pump values are not used as the largest load since the SSW supplies cooling to the associated DG. This Surveillance may be accomplished by:

1) tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest load while paralleled to offsite power, or while solely supplying the bus, or (continued)

GRAND GULF B 3.8-19 LBDCR 15046

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

REQUIREMENTS

2) tripping its associated single largest load with the DG solely supplying the bus.

If this load were to trip, it would result in the loss of the DG. As required by IEEE-308 (Ref. 13), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower. For the Grand Gulf Nuclear Station the lower value results from the first criteria.

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR has been modified by two Notes. Note 1 states; Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of 0.9 for DG 11 and DG 13 and 0.89 for DG 12. These power factors are representative of the actual inductive loading the DGs would see under design (continued)

GRAND GULF B 3.8-20 LBDCR 18127

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

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR has been modified by a two Notes. Note 1 states that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of 0.9 for DG 11 and DG 13 and 0.89 for DG 12. These power factors are representative of the actual inductive loading the DGs would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor above the limit. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to within the limits results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to the limit while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage (continued)

GRAND GULF B 3.8-22 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.11 (continued)

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations for DG 11 and DG 12.

For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

Note 2 is not applicable to DG 13. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

(continued)

GRAND GULF B 3.8-23 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 REQUIREMENTS (continued) This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d ensures that emergency loads are energized from the offsite electrical power system on an ECCS signal without loss of offsite power.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the loading logic for loading onto offsite power. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the offsite power system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

(continued)

GRAND GULF B 3.8-24 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 (continued)

REQUIREMENTS that could challenge continued steady state operation and, as a result, plant safety systems. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.13 This Surveillance demonstrates that DG non-critical protective functions:

Generator loss of excitation, Generator reverse power, High jacket water temperature, Generator overcurrent with voltage restraint, Bus underfrequency (DG 11 and DG 12 only),

Engine bearing temperature high (DG 11 and DG 12 only),

Low turbo charger oil pressure (DG 11 and DG 12 only),

Deleted High lube oil temperature (DG 11 and DG 12 only),

Low lube oil pressure, High crankcase pressure, and Generator ground overcurrent (DG 11 and DG 12 only) are bypassed on an ECCS initiation test signal. The non-critical trips are bypassed during DBAs and provide alarms on an abnormal engine conditions. These alarms provide the operator with necessary information to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against (continued)

GRAND GULF B 3.8-25 LBDCR 14026

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.13 (continued)

REQUIREMENTS minor problems that are not immediately detrimental to emergency operation of the DG.

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

(continued)

GRAND GULF B 3.8-25a LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.13 (continued)

REQUIREMENTS The SR is modified by a Note. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.14 Regulatory Guide 1.9 (Ref. 3) requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of which is at a load equivalent to the continuous rating of the DG, and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of which is at a load equivalent to 110% of the continuous duty rating of the DG. An exception to the loading requirements is made for DG 11 and DG 12. DG 11 and DG 12 are operated for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at a load greater than or equal to the maximum expected post accident load. Load carrying capability testing of the Transamerica Delaval Inc. (TDI) diesel generators (DG 11 and DG 12) has been limited to a load less than that which corresponds to 185 psig brake mean effective pressure (BMEP). Therefore, full load testing is performed at a load 5450 kW but < 5740 kW (Ref. 15). The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor (continued)

GRAND GULF B 3.8-26 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience. During the test the generator voltage and frequency is 4160 +/- 416 volts and 58.8 Hz and 63 Hz within 10 seconds after the start signal and the steady state generator voltage and frequency is maintained within 4160 +/- 416 volts and 60 +/- 1.2 Hz for the duration of the test.

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

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. The DG 11 and 12 load band is provided to avoid routine overloading of the TDI DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 2 stipulates that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of 0.9 for DG 11 and DG 13 and 0.89 for DG 12. These power factors are representative of (continued)

GRAND GULF B 3.8-27 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.15 (continued)

REQUIREMENTS and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.

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

This SR has been modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at full load conditions or until operating temperatures stabilized prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. The DG 11 and 12 load band is provided to avoid routine overloading of the TDI DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

SR 3.8.1.16 As required by Regulatory Guide 1.9 (Ref. 3) this Surveillance ensures that the manual synchronization and load transfer from the DG to each required offsite source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the undervoltage logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the load sequence logic is reset.

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related (continued)

GRAND GULF B 3.8-28 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.17 (continued)

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.

Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.18 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the bus power supplies to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

(continued)

GRAND GULF B 3.8-30 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.18 (continued)

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

(continued)

GRAND GULF B 3.8-30a LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.18 (continued)

REQUIREMENTS This SR is modified by a Note. The reason for the Note is that performing the Surveillance during these MODES would challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR.

Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

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

This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. For the purposes of this Surveillance the DG 13 autoconnected emergency loads are verified to be energized in 20 seconds. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

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

Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related (continued)

GRAND GULF B 3.8-31 LBDCR 18127

AC Sources Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.20 (continued)

REQUIREMENTS This surveillance is performed when the unit is shut down. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DG 11 and DG 12. For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

SR 3.8.1.21 (See SR 3.8.1.2)

(continued)

GRAND GULF B 3.8-33 LBDCR 18127

AC Sources Operating B 3.8.1 BASES (continued)

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. UFSAR, Chapter 8.

3. Regulatory Guide 1.9, Revision 3.

4. UFSAR, Chapter 6.

5. UFSAR, Chapter 15.

6. Regulatory Guide 1.93.

7. Generic Letter 84-15, July 2, 1984.

8. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

9. 10 CFR 50, Appendix A, GDC 18.

10. Not used.

11. ANSI C84.1, 1982.

12. ASME, Boiler and Pressure Vessel Code,Section XI.

13. IEEE Standard 308.

14. Not used.

15. Letter from E.G. Adensam to L.F. Dale, dated July 1984.

16. GNRI-96/00151, Amendment 124 to the Operating License.

17. Generic Letter 94-01, May 31, 1994.

18. GNRI-98/00016, Amendment 134 to the Operating License.

19. GNRI-2000/00065, Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment Re: Generic Changes to Improved Standard Technical Specifications, Amendment 142 to the Operating License.

20. ER-GG-2002-0466, Evaluation of P75 Standby Diesel Generators to Regulatory Guide 1.9, Rev. 3.

GRAND GULF B 3.8-34 LBDCR 18127

AC Sources Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 4 SAFETY ANALYSES and 5 and during movement of recently irradiated fuel assemblies in the primary or secondary containment ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling accidents involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

In general, when the unit is shut down the Technical Specifications (TS) requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs), which are analyzed in MODES 1, 2, and 3, have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses (continued)

GRAND GULF B 3.8-35 LBDCR 18128

AC Sources Shutdown B 3.8.2 BASES APPLICABLE result in the probabilities of occurrence significantly SAFETY ANALYSES reduced or eliminated, and minimal consequences. These (continued) deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCOs for required systems.

During MODES 1, 2, and 3, various deviations from the analysis assumptions and design requirements are allowed within the ACTIONS.

This allowance is in recognition that (continued)

GRAND GULF B 3.8-35a LDC 00070

AC Sources Shutdown B 3.8.2 BASES LCO support, assuming a loss of the offsite circuit. Similarly, (continued) when the high pressure core spray (HPCS) is required to be OPERABLE, a separate offsite circuit to the Division 3 Class 1E onsite electrical power distribution subsystem, or an OPERABLE Division 3 DG, ensure an additional source of power for the HPCS. This additional source for Division 3 is not necessarily required to be connected to be OPERABLE.

Either the circuit required by LCO Item a, or a circuit required to meet LCO Item c may be connected, with the second source available for connection.

Together, OPERABILITY of the required offsite circuit(s) and DG(s) ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving recently irradiated fuel).

Automatic initiation of the required DG during shutdown conditions is specified in LCO 3.3.8.1, LOP Instrumentation.

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESF bus(es),

and accepting required loads during an accident. Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the plant. The offsite circuit consists of incoming breakers and disconnects to the ESF transformers and the respective circuit path including feeder breakers to all 4.16 kV ESF buses required by LCO 3.8.8.

The required DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads. This sequence must be accomplished within 10 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as: DG in standby with the engine hot and DG in standby with the engine at ambient conditions. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

(continued)

GRAND GULF B 3.8-37 LBDCR 18128

AC Sources Shutdown B 3.8.2 BASES LCO an integral part of offsite circuit and DG OPERABILITY since (continued) its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8.

It is acceptable for divisions to be cross tied during shutdown conditions, permitting a single offsite power circuit to supply all required AC electrical power distribution subsystems.

As described in Applicable Safety Analyses, in the event of an accident during shutdown, the TS are designed to maintain the plant in a condition such that, even with a single failure, the plant will not be in immediate difficulty.

APPLICABILITY The AC sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary or secondary containment provide assurance that:

a. Systems that provide core cooling;

b. Systems needed to mitigate a fuel handling accident involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

(continued)

GRAND GULF B 3.8-38 LBDCR 18128

AC Sources Shutdown B 3.8.2 BASES ACTIONS A.1 (continued)

An offsite circuit is considered inoperable if it is not available to one required ESF division. If two or more ESF 4.16 kV buses are required per LCO 3.8.8, division(s) with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and movement of recently irradiated fuel. By the allowance of the option to declare required features inoperable with no offsite power available, appropriate restrictions can be implemented in accordance with the affected required feature(s) LCOs' ACTIONS.

A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required divisions, the option still exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, and movement of recently irradiated fuel assemblies in the primary and secondary containment.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to initiate action immediately to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

(continued)

GRAND GULF B 3.8-39 LDC 18128

AC Sources Shutdown B 3.8.2 BASES ACTIONS A.1 (continued)

An offsite circuit is considered inoperable if it is not available to one required ESF division. If two or more ESF 4.16 kV buses are required per LCO 3.8.8, division(s) with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and movement of recently irradiated fuel. By the allowance of the option to declare required features inoperable with no offsite power available, appropriate restrictions can be implemented in accordance with the affected required feature(s) LCOs' ACTIONS.

A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required divisions, the option still exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, and movement of recently irradiated fuel assemblies in the primary and secondary containment.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to initiate action immediately to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

(continued)

GRAND GULF B 3.8-39 LBDCR 18128

AC Sources Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 (continued)

Pursuant to LCO 3.0.6, the Distribution System ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization.

Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a division is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized division.

C.1 When the HPCS is required to be OPERABLE, and the additional required Division 3 AC source is inoperable, the required diversity of AC power sources to the HPCS is not available. Since these sources only affect the HPCS, the HPCS is declared inoperable and the Required Actions of the affected Emergency Core Cooling Systems LCO entered.

In the event all sources of power to Division 3 are lost, Condition A will also be entered and direct that the ACTIONS of LCO 3.8.8 be taken. If only the Division 3 additional required AC source is inoperable, and power is still supplied to HPCS, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the additional required AC source to OPERABLE. This is reasonable considering HPCS will still perform its function, absent an additional single failure.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required (continued)

GRAND GULF B 3.8-40 Revision No. 0

AC Sources Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by two Notes. The reason for the Note 1 is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

Note 2 states that SRs 3.8.1.12 and 3.8.1.19 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE. These SRs demonstrate the DG response to an ECCS signal (either alone or in conjunction with a loss-of-power signal). This is consistent with the ECCS instrumentation requirements that do not require ECCS signals when the ECCS system is not required to be OPERABLE.

REFERENCES None.

GRAND GULF B 3.8-41 LBDCR 18128

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel oil capacity sufficient to operate that DG for a period of 7 days while the DG is supplying its surveillance testing capacity as prescribed by Technical Specifications (5740 KW for Division 1 and 2, 3300 KW for Division 3). This capacity exceeds the maximum post loss of coolant accident load demand (Ref. 1). The maximum load demand is calculated using the assumption that at least two DGs are available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from each storage tank to its respective day tank by a transfer pump associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result in the loss of more than one DG. All outside tanks, pumps, and piping are located underground. The fuel oil level in the storage tank is indicated in the control room.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref.

3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation.

Each engine oil sump contains an inventory capable of supporting a minimum of 7 days of operation under design basis load and vendor specified consumption rates.

(continued)

GRAND GULF B 3.8-42 LDC 99083

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS E.1 (continued)

With a Required Action and associated Completion Time not met, or the stored diesel fuel oil, lube oil or starting air subsystem not within limits for reasons other than addressed by Conditions A through D, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for 7 days at its surveillance testing capacity as prescribed by Technical Specifications (5740 KW for Division 1 and 2, 3300 KW for Division 3). This capacity exceeds the maximum expected post LOCA loading. The 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

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

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of maximum expected post LOCA load operation for each DG. This requirement is based on the DG manufacturer's consumption values for the run time of the DG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG when the DG lube oil sump does not hold adequate inventory for 7 days of maximum expected post LOCA load operation without the level reaching the manufacturer's recommended minimum level.

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

(continued)

GRAND GULF B 3.8-46 LBDCR 18127

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.3 REQUIREMENTS (continued) The tests of fuel oil prior to addition to the storage tanks are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate detrimental impact on diesel engine combustion and operation. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s). The limits and applicable ASTM Standards for the tests listed in the Diesel Fuel Oil Testing Program of Specification 5.5.9 are to verify in accordance with the tests specified in ASTM D975 (Ref. 6) that the sample has a water and sediment content of 0.05 v/o, and a kinematic viscosity at 40qC of 1.9 centistokes and 4.1 centistokes.

These tests are required every 92 days for fuel oil in the storage tanks and prior to addition for new fuel oil by Specification 5.5.9. Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks.

Following the initial new fuel oil sample, the fuel oil is analyzed to establish an impurity level of < 2 mg/100 ml when tested in accordance with ASTM 2274-70 (Ref. 6). These additional analyses are required by Specification 5.5.9, Diesel Fuel Oil Testing Program, to be performed within 7 days following addition. The 7 day period is acceptable because the fuel oil properties of interest, even if not within stated (continued)

GRAND GULF B 3.8-47 LBDCR 14050

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.3 (continued)

REQUIREMENTS limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long term storage shows up as an increase in insolubles, mostly due to oxidation. The presence of insolubles does not mean that the fuel oil will not burn properly in a diesel engine. However, the insolubles can cause fouling of filters and fuel oil injection equipment, which can cause engine failure.

The Frequency of these Surveillances on the stored fuel oil takes into consideration fuel oil degradation trends indicating that overall fuel oil quality is unlikely to change between Frequency intervals.

SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. For DG 11 and DG 12 the starting air system is required to have a minimum capacity for one emergency DG start attempt above the air pressure interlock, and multiple manual start attempts below the interlock, without recharging the air start receivers. For DG 13 the starting air system is required to have a minimum capacity for five successive DG start attempts without recharging the air start receivers. The pressure specified in this SR reflects the value at which this can be accomplished, but is not so high as to result in failing the limit due to normal cycling of the recharge compressor.

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

This Surveillance Requirement is met for a given division when one of the two starting air trains for the respective diesel generator meets the pressure specified in the Surveillance Requirement.

(continued)

GRAND GULF B 3.8-48 LBDCR 18127

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.5 REQUIREMENTS (continued) Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Periodic removal of water from the storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is for preventative maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of the Surveillance.

REFERENCES 1. UFSAR, Section 9.5.4.

2. Regulatory Guide 1.137.

3. ANSI N195, Appendix B, 1976.

(continued)

GRAND GULF B 3.8-49 LBDCR 18127

DC Sources Operating B 3.8.4 BASES ACTIONS C.1 (continued)

If one of the required Division 1 or 2 DC electrical power subsystems is inoperable for reasons other than its associated battery charger inoperable, the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

D.1 If a Division 1 or 2 DC electrical power subsystem is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

GRAND GULF B 3.8-55 LBDCR 14043

DC Sources Operating B 3.8.4 BASES (continued)

ACTIONS E.1 With the Division 3 DC electrical power subsystem inoperable for reasons other than its associated battery charger inoperable, the HPCS System may be incapable of performing its intended functions and must be immediately declared inoperable. This declaration also requires entry into applicable Conditions and Required Actions of LCO 3.5.1, "ECCS Operating."

F.1 and F.2 If the Division 3 DC electrical power subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each inter-cell, inter-rack, inter-tier, and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

(continued)

GRAND GULF B 3.8-56 LBDCR 18127

DC Sources Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.2 (continued)

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

SR 3.8.4.3 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not necessarily represent a failure of this SR, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function).

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

(continued)

GRAND GULF B 3.8-56a LBDCR 18127

DC Sources Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.4 and SR 3.8.4.5 REQUIREMENTS (continued) Visual inspection and resistance measurements of inter-cell, inter-rack, inter-tier, and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anti-corrosion material is used to ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.

The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance. For the purposes of this SR oxidation is not considered corrosion provided the resistance of the connection(s) is within limits.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.8.4.6 Battery charger capability requirements are based on the design capacity of the chargers (Ref. 4). According to Regulatory Guide 1.32 (Ref. 10),

the battery charger supply is required to be based on the largest combined demands of the various 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 unit during these demand occurrences. The minimum required amperes and duration ensure that these requirements can be satisfied.

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

(continued)

GRAND GULF B 3.8-57 LBDCR 18127

DC Sources Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.7 REQUIREMENTS (continued) A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Division 1 and Division 2 and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Division 3) correspond to the design duty cycle requirements as specified in Reference 4.

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

This SR is modified by two Notes. Note 1 allows the once per 60 months performance of SR 3.8.4.8 in lieu of SR 3.8.4.7. This substitution is acceptable because SR 3.8.4.8 represents a more severe test of battery capacity than SR 3.8.4.7. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages. Credit may be taken for unplanned events that satisfy the Surveillance.

SR 3.8.4.8 A battery performance test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 9) and IEEE-485 (Ref. 12). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

(continued)

GRAND GULF B 3.8-58 LBDCR 18127

DC Sources Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.8 (continued)

REQUIREMENTS The normal Surveillance Frequency is controlled under the Surveillance Frequency Control Program. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's rating. Degradation is indicated when the battery capacity drops by more than 10% of rated capacity relative to its capacity on the previous performance test or is below 90% of the manufacturer's rating. These Frequencies are based on the recommendations in IEEE-450 (Ref. 9).

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages. Credit may be taken for unplanned events that satisfy the Surveillance.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE Standard 308, 1978.

4. UFSAR, Section 8.3.2.

5. UFSAR, Chapter 6.

6. UFSAR, Chapter 15.

7. Regulatory Guide 1.93, December 1974.

8. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

9. IEEE Standard 450, 1987.

10. Not used.

11. Regulatory Guide 1.129, December 1974.

12. IEEE Standard 485.

GRAND GULF B 3.8-59 LBDCR 18127

DC Sources Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources Operating."

APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref.

2), assume that Engineered Safety Feature systems are OPERABLE.

The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 4 and 5 and during movement of irradiated fuel assemblies in the primary or secondary containment ensures that:

a. The facility can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling accidents involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

The DC sources satisfy Criterion 3 of the NRC Policy Statement.

(continued)

GRAND GULF B 3.8-60 LBDCR 18128

DC Sources Shutdown B 3.8.5 BASES LCO 1 or 2 onsite Class 1E DC electrical power distribution (continued) subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown" is required to be OPERABLE. Similarly, when the High Pressure Core Spray (HPCS) System is required to be OPERABLE, the Division 3 DC electrical power subsystem associated with the Division 3 onsite Class 1E DC electrical power distribution subsystem required to be OPERABLE by LCO 3.8.8 is required to be OPERABLE. In addition to the preceding subsystems required to be OPERABLE, a Class 1E battery or battery charger and the associated control equipment and interconnecting cabling capable of supplying power to the remaining Division 1 or 2 onsite Class 1E DC electrical power distribution subsystem(s), when portions of both Division 1 and 2 DC electrical power distribution subsystem are required to be OPERABLE by LCO 3.8.8. This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving recently irradiated fuel).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary or secondary containment provide assurance that:

a. Required features to provide core cooling;

b. Required features needed to mitigate a fuel handling accident involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4.

(continued)

GRAND GULF B 3.8-61 LBDCR 18128

DC Sources Shutdown B 3.8.5 BASES (continued)

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

A.1 Condition A represents one division with a loss of ability to completely respond long term to an event, and a potential loss of ability to remain energized during normal operation. Since eventual failure of the battery to maintain the required battery cell parameters is highly probable, it is imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division. The additional time provided by the Completion Time is consistent with the capability of the battery to maintain its short term capability to respond to a design basis event.

A Note is added to take exception to the allowance of LCO 3.0.4 to enter MODES or other specified conditions in the Applicability. Even though Condition A Required Actions do not in themselves require a plant shutdown, or require exiting the MODES or other specified conditions in the Applicability, the condition of the DC system is not such that extended operation is expected. Therefore, the Note would require restoration of an inoperable battery charger to OPERABLE status prior to starting up or commencing recently irradiated fuel movement. This exception is not intended to preclude the allowance of LCO 3.0.4 to always enter MODES or other specified conditions in the Applicability as a result of a plant shutdown.

B.1 If the battery cell parameters cannot be maintained within the Category A limits, the short term capability of the battery is also degraded and the battery must be declared inoperable.

(continued)

GRAND GULF B 3.8-62 LDC 00070

DC Sources Shutdown B 3.8.5 BASES ACTIONS C.1, C.2.1, C.2.2, and C.2.3 (continued)

If more than one DC distribution subsystem is required according to LCO 3.8.8, the DC subsystems remaining OPERABLE with one or more DC power sources inoperable for reasons other than an inoperable battery charger may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, and recently irradiated fuel movement. By allowing the option to declare required features inoperable with associated DC power source(s) inoperable, appropriate restrictions are implemented in accordance with the affected system LCOs' ACTIONS. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, and movement of recently irradiated fuel assemblies).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.8. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required (continued)

GRAND GULF B 3.8-63 LBDCR 18128

DC Sources Shutdown B 3.8.5 BASES SURVEILLANCE SR 3.8.5.1 (continued)

REQUIREMENTS power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

GRAND GULF B 3.8-64 LDC 00070

Battery Cell Parameters B 3.8.6 BASES ACTIONS A.1, A.2, and A.3 (continued)

Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. Taking into consideration that while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable for operation prior to declaring the DC batteries inoperable.

B.1 When any battery parameter is outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as not completing the Required Actions of Condition A within the required Completion Time or average electrolyte temperature of representative cells falling below 60°F, also are cause for immediately declaring the associated DC electrical power subsystem inoperable.

SURVEILLANCE SR 3.8.6.1 REQUIREMENTS The SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 3), which recommends regular battery inspections including float voltage, specific gravity, and electrolyte level of pilot cells.

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

SR 3.8.6.2 The inspection of specific gravity and voltage is consistent with IEEE-450 (Ref. 3). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. In addition, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of a battery overcharge > 150 V, the battery must be demonstrated to meet Category B limits. This inspection is also consistent with IEEE-450 (Ref. 3), which recommends special inspections following a severe discharge or overcharge, to ensure that no significant degradation of the battery occurs as a consequence of such overcharge.

(continued)

GRAND GULF B 3.8-67 LBDCR 18127

Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.3 REQUIREMENTS (continued) This Surveillance verification that the average temperature of representative cells (every sixth connected cell) is t 60qF is consistent with a recommendation of IEEE-450 (Ref. 3).

Lower than normal temperatures act to inhibit or reduce battery capacity.

This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer's recommendations.

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

Table 3.8.6-1 This table delineates the limits on electrolyte level, float voltage, and specific gravity for three different categories. The meaning of each category is discussed below.

Category A defines the normal parameter limit for each designated pilot cell in each battery. The cells selected as pilot cells are those whose level, float voltage, and level, float specific gravity approximate the state of charge of the entire battery.

The Category A limits specified for electrolyte level are based on manufacturer's recommendations and are consistent with the guidance in IEEE-450 (Ref. 3), with the extra 1/4 inch allowance above the high water level indication for operating margin to account for temperature and charge effects. In addition to this allowance, footnote a to Table 3.8.6-1 permits the electrolyte level to be above the specified maximum level during equalizing charge, provided it is not overflowing. These limits ensure that the plates suffer no physical damage, and that adequate electron transfer capability is maintained in the event of transient conditions. IEEE-450 (Ref. 3) recommends that electrolyte level readings should be made only after the battery has been at float charge for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The Category A limit specified for float voltage is 2.13 V per cell. This value is based on the recommendation of IEEE-450 (Ref. 3), which states that prolonged operation of cells below 2.13 V can reduce the life expectancy of cells.

(continued)

GRAND GULF B 3.8-68 LBDCR 18127

Distribution Systems Operating B 3.8.7 BASES ACTIONS B.1 (continued) providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC division could again become inoperable, and DC distribution could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

C.1 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, the plant must be bought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

(continued)

GRAND GULF B 3.8-77 LBDCR 14043

Distribution Systems Operating B 3.8.7 BASES ACTIONS C.1 (continued)

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

GRAND GULF B 3.8-77a LBDCR 14043

Distribution Systems Operating B 3.8.7 BASES ACTIONS D.1 (continued)

With the Division 3 electrical power distribution system inoperable, the Division 3 powered systems are not capable of performing their intended functions. Immediately declaring the high pressure core spray inoperable allows the ACTIONS of LCO 3.5.1, "ECCS Operating," to apply appropriate limitations on continued reactor operation.

E.1 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS Meeting this Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

3. Regulatory Guide 1.93, December 1974.

4. UFSAR, Section 8.3.

5. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

GRAND GULF B 3.8-78 LBDCR 18127

Distribution Systems Operating B 3.8.7 Table B 3.8.7-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE NOMINAL DIVISION 1* DIVISION 2* DIVISION 3*

VOLTAGE AC Electric 4160 V 15AA 16AB 17AC Power Distribution 480 V LCCs 15BA1, 15BA2, 16BB1, 16BB2, ---

System 15BA3, 15BA4, 16BB3, 16BB4, 15BA5, 15BA6 16BB5, 16BB6 480 V MCCs 15B11, 15B21, 16B11, 16B21, 17B01, 17B11 15B31, 15B41, 16B31, 16B41, 15B51, 15B61 16B51, 16B61 120 V Dist. 15P11, 15P21, 16P11, 16P21, 17P11 Panels 15P31, 15P41, 16P31, 16P41, 15P51, 15P61 16P51, 16P61 DC Electric 125 V Bus 11DA Bus 11DB Bus 11DC Power Distribution Dist. Panels 1DA1, 1DA2 1DB1, 1DB2 1DC1 System

Each division of the AC and DC electrical power distribution systems is a subsystem.

GRAND GULF B 3.8-79 LBDCR 10010

Distribution Systems Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Distribution Systems Shutdown BASES BACKGROUND A description of the AC and DC electrical power distribution systems is provided in the Bases for LCO 3.8.7, "Distribution Systems Operating."

APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref.

2), assume Engineered Safety Feature (ESF) systems are OPERABLE.

The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC and DC electrical power distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC and DC electrical power sources and associated power distribution subsystems during MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary or secondary containment ensures that:

a. The facility can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving recently irradiated fuel. Due to radioactive decay, AC and DC electrical power is only (continued)

GRAND GULF B 3.8-80 LBDCR 18128

Distribution Systems Shutdown B 3.8.8 BASES (continued)

LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of Technical Specifications' required systems, equipment, and components both specifically addressed by their own LCOs, and implicitly required by the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents involving recently irradiated fuel).

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the primary or secondary containment provide assurance that:

a. Systems that provide core cooling;

b. Systems needed to mitigate a fuel handling accident involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown or refueling condition.

The AC and DC electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LCO 3.8.7.

(continued)

GRAND GULF B 3.8-81 LBDCR 18128

Distribution Systems Shutdown B 3.8.8 BASES (continued)

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

A.1, A.2.1, A.2.2, A.2.3, and A.2.4 Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, and recently irradiated fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS and movement of recently irradiated fuel assemblies in the primary and secondary containment).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal shutdown cooling (RHR-SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR-SDC ACTIONS (continued)

GRAND GULF B 3.8-82 LBDCR 18128

Distribution Systems Shutdown B 3.8.8 BASES ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 (continued) would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR-SDC inoperable, which results in taking the appropriate RHR-SDC ACTIONS.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the required AC and DC electrical power distribution subsystems are functioning properly, with the buses energized. The verification of proper voltage availability on the required buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

GRAND GULF B 3.8-83 LBDCR 18127

ML20134H953

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