Text

Proposed Tech Specs Permitting EDG TS Action Completion Time of Up to 14 Days for Div 1 or 2 EDG & Allowing Performance of EDG 24-hour TS SR Test in Modes 1 & 2
	ML20151V111
Person / Time
Site:	Perry
Issue date:	09/03/1998
From:	; CENTERIOR ENERGY
To:	;
Shared Package
ML20151V108	List: ML20151V111; PY-CEI-NRR-2319, Application for Amend to License NPF-58,permitting EDG TS Action Completion Time of Up to 14 Days for Div 1 or 2 EDG & Allow Performance of EDG 24-hour TS SR Test in Modes 1 & 2;
References
	NUDOCS 9809140078
	Download: ML20151V111 (13)
	v • d • e

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I Attachm:nt 3 PY-CEl/NRR-2319L Page 1 of 7 l

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i PROPOSED CHANGES TO j

TECHNICAL SPECIFICATIONS 1

9609140078 980903 PDR ADOCK O 4j0 P

i PY-CEl/NRR-2319L Page 2 of 7 gg 3

AC Sources--Operating 37 7 g 3 g y )I,g[

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W) h 3.8.1 W W t

3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources--Operating I

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LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a.

Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electric Power Distribution System; and b.

Three diesel generators (DGs).

I APPLICABILITY:

MODES 1,.2, and 3.

NOTE----------------------------

Division 3 AC electrical power sources are not required to be OPERABLE when High Pressure Core Spray System is inoperable.

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L ACTIONS-i CONDITION REQUIRED ACTION COMPLETION TIME A.

One required offsite A.1 Perform SR 3.8.1.1 1 aour circuit inoperable.-

for OPERABLE required offsite circuit.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter l

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i; PERRY - UNIT l' 3.8-1 Amendment No. 69

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PY-CEl/NRR-2319L Paga 3 of 7 AC Sources--Operating 3.8.1 ACTIONS CGNDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months offsite circuit to OPERABLE status.

AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power AND 17 HE days from discovery of failure to meet LCO B.

One required DG B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

for OPERABLE required offsite circuit (s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter l

l AND B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature (s), supported discovery of by the inoperable DG, Condition B inoperable when the concurrent with redundant required inoperability of feature (s) are redundant inoperable.

required feature (s)

AND (continued) 1 1

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h PERRY - UNIT 1 3.8-2 Amendment No. 69

Attachmant 3 PY-CEl/NRR-2319L Paga 4 of 7 AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

B.

(continued)

B.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG(s) are not inoperable due to common cause failure.

0.8 B.3.2 Perform SP,3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPEN' F DG(s).

AND B.4 Restore required DG 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months shhrom discovery of to OPERABLE status.

an inopefable Division 3 DG AND 14 days l

m discovery of failure to meet LCO i

C.

Two required offsite C.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable.

feature (s) inoperable discovery of when the redundant Condition C required feature (s) concurrent with are inoperable.

inoperability of redundant required feature (s)

AtLD C.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

(continued)

PERRY - UNIT 1 3.8-3 Amendment No. 69

PY-CEl/NRR-2319L Pago 5 of 7 AC Sources--Operating a

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3.8.1 ACTIONS '(continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One required offsite

NOTE-------------

circuit inoperable.

Enter applicable Conditions and Required Actions of AHQ LCO 3.8.7, " Distribution i

Systems--Operating," when any One required DG required division is de-inoperable.

energized as a result of Condition D.

D.1 Restore required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months offsite circuit-to OPERABLE status.

_0.8 D.2 Restore required DG 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to OPERABLE status.

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Two required DGs E.1 Restore one required '

2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .,

inoperable.

DG to OPERABLE status.

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24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if Division 3 DG l

is inoperable F.

Required Action and F.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time o' Condition A, ANQ B, C, D, or E not met.

F.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i

G..

Three or more required G.1 inter LC0 3.0.3.

Immediately AC sources inoperable.

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PERRY - UNIT 1 3.8-4 Amendment No. 69

PY-CEl/NRR-2319L Pagn 6 of 7 AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14

NOTES-------------------

1.

Momentary transients outside the load and power factor ranges do not invalidate this test.

2.

Tl-;; Sw ;ill;n;; ;h:l' n;t be orfor;;d in "00E 1 er 2.

" :::'/ c r,

redit may be taken for unplanned events that satisfy this SR.

Verify each DG operating at a power factor 18 months s 0.9 operates for 2 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a.

For 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 2 6800 kW and s 7000 kW for' Division 1 and 2 DGs, and 2 2860 kW for Division 3 DG; and b.

For the remaiping hourt at the test loaded 2 5600 kW and s 7000 kW for Division I and 2 DGs, and 2 2600 l'4 l

for Division 3 DG.

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- PERRY - UNIT 1 3.8-11 Amendment No. 69

Attachmsnt 3

-w PY-CEl/NRR-2319L jdSEP.T TdlS PAGE Paga 7 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13.1 Confiauration Risk Manaaement Program The Configuration Risk Management Program (CRMP) provides a risk-informed assessment to manage the risk associated with equipment maintenance activities. The program applies to those structures, systems, or components for which a Technical Specification risk-informed Completion Time has been granted. Specifically, this program applies to:

Required Action B.4 of LC0 3.8.1, "AC Sources-Operating" from 2 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after entering Condition B.

The program shall include the following:

a. Provisions for the control and implementation of the Probabilistic Safety Assessment (PSA) model and methodology. The PSA model shall be capable of performing assessments evaluating the applicable plant configurations.

b. Provisions for performing assessments for preplanned risk informed activities prior to entering the risk-informed Completion Time.

c. Provisions for performing an assessment after entering the risk informed Completion Time for an unplanned entry into the risk-informed Completion Time.

d. Provisions for assessing the need for additional actions after the discovery of subsequent equipment out of service conditions while in the risk-informd Completion Time.

e. Provisions for considering other applicabie risk significant contributors external to the preplanned activity such as weather conditions, qualitatively or quantitatively.

PERRY - UNIT 1 5.0 15b Amendment No.

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Page 1 of 6 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES "INFORMATION ONLY" a.'Y 2

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PY-CEl/NRR-2319L Page 2 of 6 AC Sources-Operating B 3.8.1 BASES ACTIONS A.2 (continued)

According to Regulatory Guide 1.93 (Ref. 6) operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Completion Time assumes sufficient offsite power remains to power the minimum loads needed to respond to analyzed events.

In the event one or more divisions are without offsite power, this assumption is not met.

Therefore. the optional Completion Time is specified.

Should two (or more) divisions be affected, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is conservative with respect to the Regulatory Guide assumptions supporting a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for both offsite circuits inoperable.

With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, w,ch attendant potential for a challenge to the plant safety systems.

In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to surnly eiectrical power to the onsite Class 1E distribution sy!Nem.

The Completion' Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The third Completion Time for Required Action A.2 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO.

If Condition A is entered while, for instance, a DG is ino

@daNbOPEMBLE perable and that DG is subsequently retur N-m@ This situation could lead to a total of Mdes)

W44 hour:3 since initial failure to meet the LCO to restore the offsite circuit. At this time, a DG could again become inocerable, the r.ircuit restored OPERABLE, and an additional (M deIpn hd(f r a total ofejaars) allowed prior to complete g restoration of the LCO.

ThelfrJoay completion Time provides a limit on the time allowed in a specified condition after le discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered _ toncurrently.

The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months andfftfday completion Times means that botn jl a

Completion Times apply simultaneously, and the more restrictive must be met.

(for Required Action A.23 (continued)

PERRY - UNIT 1 B 3.8-5 Revisicn No. 1

Attachm:nt 4 PY-CEI/NRR-2319L Page 3 of 6 AC Sources-Operating l

B 3.8.1 ACTIONS A.2 (continued)

The Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

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This exception results in establishing the " time zero" at i

the time the LCO was initially not met, instead of at the time that Condition A was entered.

B.1 1

To ensure a highly reliable power source remains, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis.

Since the Required Action only specifies " perform." a failure of i

SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1. it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e.. single division systems are not included, although, for this Required Action. Division 3 is considered redundant to Division 1 and 2 Emergency Core Cooling System (ECCS)).

Redundant required features failures consist of inoperable Natures associated with a division redundant to the division that has an inoperable DG.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

This Completion Time also allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

l In this Required Action, the Completion Time only begins on l

discovery that both:

a.

An inoperable DG exists; and b.

A required feature on another division is inoperable.

(continued)

PERRY - UNIT 1 B 3.8-6 Revision No. 0

-e PY-CEl/NRR-2319L Pago 4 of 6 AC Sources-Operating B 3.8.1 4

BASES ACTIONS 8.3.1 and B.3.2 (continued) t In the event the inoperable DG is restored to OPERABLE status prior to completing either Required Actions B.3.1 or B.3.2, the corrective actions program will continue to evaluate the common cause failure 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 fAcccrding to Regubtcry Cuide 1.93 'Ref. 6). Operction =y' l continuc i-Conditicr B for a ccried thct hould not c=cS

( 72 hcurs.J In Condition B. the remaining OPERABLE DGs ano offsite circuits are adequate to supply electrical power tn the onsite Class 1E distribution system.

Completion Tim 4] takes into account the capacity andThe 72 ho capability of the remaining AC sources, reasonable time for repairs and low probability of a DBA occurring during this period.

M Thec ccmc; Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence 6f failing to meet e

the LCO.

If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for uo to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Tb" 'ituation could lead

[ndaff to a total ofE ". cup since initial failure to meet the l

LCO to restore theI At this time, an offsite circuit could again become inoperable, the DG an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of tored OPERABLE, and g s) allowed prior to complete restoration of the LCO.

T ay completion g Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are Entered concurrently The "AND" connector between theC72 ". cur af E dif) Completion Times means thatMCompletion Times apply simultaneously, and the more/Fe_strictive Completion Time must be met.

(he ihres)

(continued)

PERRY - UNIT 1 B 3.8-8 Revision No. 1

PY-CEl/NRR-2319L Page 5 of G AC Sources -Operating

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BASES '

ACTIONS 8.4 (continued)

As in Required Action B.2 the Completion Time allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time the LCO was initially not met, instead of the time Condition B was entered.

C.1 and C.2 Required Action C.1 addresses actions to be taken..in the event of concurrent failure of redundant required features.

Required Action C.1 reduces the vulnerability to a loss of function. The rationale for the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE.

When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are designed with redundant safety related divisions (i.e.,

single division systems are not included in the list, although, for this Required Action, Division 3 is considered redundant to Division 1 and 2 ECCS).

Redundant required features failures consist of any of these features that are inoperable, because any ino)erability is on a division redundant to a division wit 1 inoperable offsite circuits.

The Com)letion Time for Required Action C.1 is intended to allow t1e operator time to evaluate and repair any discovered inoperabilities.

This Completion Time also allows for an except1on to the normal " time zero" for beginning the allowed outage time " clock."

In this Required Action, the Completion Time only begins on discovery that both:

a.

All required offsite circuits are inoperable; and b.

A required feature is inoperable.

If, at any time du"ing the existence of this Condition (two offsite circuits inoperable), a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

(continued)

PERRY - UNIT 1 8 3.8-9 Revision No. 0

_ _ _ -.-_=

PY-CEl/NRR-2319L Page 6 of 6 AC Sources -Operating 8 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS The reason for Note 2 is thatfdur%g c;cration "ith th:

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/ rcactor cr;t:c;

cricrmance of thic SR could c;u;c l

' pcrturb tion: te-tic electrical distribution cy;tcm; th;t t

would chclicagc continued :te:d'/ State coerction 2nd. c; ;,

trc ult clant : fet'/ cv:tems.) R edit may be taken for unplanned events tnat satisfy' this SR.

Examples of unplannedeventsmayinclude:@

1)

Unexpected operational events which cause the equipment to Surveillance, perform the function specified by this for which adequate documentation of the required performance is available; and 2)

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

SR 3.8.1.15 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 10 seconds for Divisions 1 and 2 and 13 seconds for Division 3.

The times are derived from the requirements of the accident analysis to respond to a design basis large break LOCA.

The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9),

paragraph 2.a.(5).

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 prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.

The load band for the Division 1 and 2 DGs is 3rovided to avoid routine overloading of these DGs.

While t11s Surveillance allows operation of the Division 1 and 2 DGs in the band of 5600 kW to 7000 kW. a rt ge of 5600 kW to 5800 kW will normally be used in order to minimize wear on the DGs.

This is the load range (continued)

PERRY - UNIT 1 B 3.8-26 Revision No. 1

v t e Letter Sequence Request
TAC:MA3537, (Open)
Initiation Request Acceptance... Supplement Administration Questions Answers Results Approval... Other:
MONTHYEAR1998-09-03 [Table View]

ML20151V111

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