ML20153D932

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Proposed Tech Specs,Extending Interval for Type B & C Containment Leakage Rate Testing to First Refueling Outage & Clarifying Allowable Surveillance Interval for Diesel Generator Insp
ML20153D932
Person / Time
Site: Waterford Entergy icon.png
Issue date: 02/19/1986
From:
LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20153D918 List:
References
NUDOCS 8602240303
Download: ML20153D932 (26)


Text

8 NPF-38-13 f

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-13 This is a request to revise Technical Specification 3.5.1.2, Containment Leakage to extend the interval for Type B and C containment leakage rate testing to the first refueling outage.

Existing Specification See Attachment A Proposed Specification See Attachment B Description Surveillance Requirement 4.6.1.2.d requires that Type B and C containment leakage rate tests be conducted at intervals no greater than 24 months.

Surveillance Requirement 4.6.1.2.f requires, in part, that the bypass leakage rate be determined through Type B and C testing at least once per 24 months. The proposed change would allow for extension of the above Type B and C testing intervals to the refueling outage for the first cycle of operation only.

LP&L successfully completed the pre-operational Type A integrated leak rate testing (ILRT) on May 1, 1983, and the Type B and C local leak rate testing (LLRT) on April 22, 1984. The ILRT results were submitted to the NRC via W3P83-2399 dated July 19, 1983. The LLRT results demonstrated a low level of leakage. Against the allowable Technical Specification leakage limit of 630,697 cc/ day, testing revealed an actual leakage of 15,952 cc/ day. The current leakage is 21,547 cc/ day, a minor increase. Similar results were obtained for the bypass leakage - against an allowable limit of 63,069 cc/ day, bypass leakage was demonstrated to be 5,490 cc/ day, with a current leakage of 6,150 cc/ day.

(Note: The Technical Specifications use the term L to define allowable leakage. L (in %/24 hours) is the maximum ailowable leakage rate at peak con 8ainment DBA pressure.

In the Technical Specifications 0.60L corresponds to 630,697 cc/ day and 0.06L corresponds a

a to 63,069 cc/ day.)

The performance of the pre-operational ILRT/LLRT testing was scheduled to be consistent with what appeared, at the time, to be a reasonable fuel load date. The intent of the scheduling was to allow adequate time for the first cycle of operation so as to satisfy the 24 month Type B and C testing requirements of Surveillance Requirements 4.6.1.2.d/f at the first refueling outage. Due to various factors the full power licensing of Waterford 3 was delayed to March 16, 1985 and commercial operation of the facility occurred in September, 1985. Therefore, LP&L is faced with an extended mid-cycle outage in order to perform the Type B and C testing.

Containment leakage rate is primarily affected by equipment wear and maintenance. During periods of inactivity little, if any, increase in leakage rate would be expected. From the-time of performance of the ILRT/LLRT testing, to receipt of the low power operating license in December, 1984 (a period of approximately 8 months), LP&L was primarily occupied with addressing licensing issues rather than exercising plant systems.

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o Thua Type B cnd C cquipment wIs subjcct to only tinimal w:Cr during thit time.

I To determine the effect on Type B and C equipment due to maintenance, LP&L has conducted a review of the LLRT logbook. This review has determined that maintenance was performed on only a few components out of a total of 117 and that in these cases acceptable Type B testing was performed post-maintenance.

Given the low burden placed on Type B and C components during a significant portion of the time since ILRT/LLRT testing, and the low level of maintenance on these componants it would be expected that increases in the containment and. bypass leakage rates would.be minor. This is borne out by Waterford 3's history of minor problems with containment pressure control.

With a fairly tight Technical Specification on containment pressure, 14.9-15.4 psia depending on containment temperature, LP&L has found it necessary to frequently " burp" containment to maintain pressure at an acceptable level. Presently pressure control is required every 1-2 days.

The containment air locks and the containment purge system (supply and exhaust) are systems exercised on a fairly frequent basis and provide potential leakage paths. However, operability and leak testing of these systems are required separately through Technical Specifications 3.6.1.3 and 3.6.1.7, respectively. The proposed change has no effect on the leakage rate testing of the air locks and containment purge system.

Precedents for the proposed change exist. On September 26, 1985, in response to an August 26, 1985 requast, the NRC granted an exemption to Appendix J to allow one nuclear unit to continue operation to their scheduled refueling. The request was primarily based on the presence of-a four month outage during which leakage-sensitive components were not exercised.

In the third quarter 1985, another nuclear plant received a two year extension on their third Type A test, effectively allowing a six year Type A testing interval, and deleting one Type A test over the lifetime of the plant. The proposed change for Waterford 3 will only realign the scheduling to be consistent with the first refueling outage, which is anticipated to start between D.ecember 15, 1986 and March 1, 1987.

In summary, the proposed change is supported by:

1.

The large margin to Technical Specification limits demonstrated during the pre-operational LLRT, 2.

The low component usage factor prior to low power licensing, 3.

The minimal component maintenance and successful post-maintenance testing of a minor number of components, 4.

The continued leakage rate testing of the air locks and containment purge system, as already required.

5.

Granting of similar requests to other operating nuclear plants.

6.

The believed intent of Standard Technical Specifications to require LLRT only at refueling intervals, as long as refueling takes place within a reasonable period of time.

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i Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: NO The FSAR Chapter 15 safety analyses assume the maximum allowable Technical Specification leakage in calculating off-site dose consequences. As demonstrated above, a very large margin exists between the LLRT and current leakage values, and the allowable Technical Specification leakage. Problems with containment pressure control would be minimal under conditions of maximum allowable leakage. With the need for pressure control, the long outage period prior to start-up testing and the lack of maintenance on Type B and C components the leakage rate of containment is clearly below the allowable leakage. Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

2.

Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: NO The proposed change introduces no new systems, modes of operation, failure modes or other plant perturbations.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: NO As noted above, the margin is quite large between the LLRT results and the allowable Technical Specification leakage. The actual period of plant operation is well within the allowable two year period. The low level of required maintenance and successful post-maintenance testing, combined with the performance of leakage rate testing during the remainder of Cycle 1, give adequate assurance that any reduction in safety margin is minimal compared to the total margin that exists. Therefore, the proposed change will not involve a significant reduction in a margin of safety.

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i b;-t The Commission has.provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples-(48 CFR 14870) of amendments that are

-considered not likely to involve significant hazards considerations.,

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Example (vi) relates to a change which may reduce in some way a safety margin, but.where the-results of the change are clearly within all acceptable criteria specified in the Standard Review Plan.

In this case, the proposed change described above constitutes credit for the outage time between LLRT testing and plant licensing. Current plant performance indicates little, if any, degradation in containment leakage.

Given the large margin available for containment leakage, plant operation '

to the first refueling cycle, while presenting a potential for minor loss of margin, will clearly meet applicable acceptance criteria. Therefore, the proposed change is similar to Example -(vi).

Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that:

(1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.91, and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change, and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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CONTA!!#4ENT SYSTEMS CONTAINMENT LEAXAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be limited to:

An overall integrated leakage rate of:

a.

1.

Less than or equal to L 0

containmentairper24So,urs.56perseni.'us..*g.t:fth:

at P,, 44 psig, or 2.

Less than or erJa1 to L, 0.25 percent by weight of the containment air per 24 Ilours at a reduced pressure of P.

g 22 psig.

b.

A combined leakage rate of less than or equal to 0.60 L for all penetrationsandvalvessubjecttoTypeBandCtestsalidentified in Table 3.6-1, when pressurized to P,.

c.

A combined bypass leakage rate of less than or equal to 0.06 L for all penetrations identified in Table 3.6-1 as secondary contatAment bypass leakage paths when pressurized to P,.

APPLICA8ILITY: MODES 1, 2, 3, and 4.

ACTION:

With either (a) the measured overall integrated containment leakage rate exceeding 0.75L,allpenetrItionsandvalvessubjecttoTypesBandCtests or 0.75 L, as applicable, or (b) with the measured combined leakage rate for exceeding 0.60 L, or (c) with the combined bypass leakage rate exceeding 0.06 L, restore,the overall integrated leakage rate to less than or equal i

to0.78L or less than or equal to 0.75 L leakageriteforallpenetrationsandvalvIs,asapplicable,andthecombined subject to Type 8 and C tests to less than or equal to 0.60 L and the bypass leakage rate to less than or equal to 0.06 L, prior to in8r, easing the Reactor Coolant System temperature

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above 200*F.

i SURVEILLANCE REQUIREMENTS 4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determined.in conformance with the criteria specified in Appendix J of 10 CFR Part 50 using the methods and provisions of ANSI N45.4-1972:

a.

Three Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at 40 + 10 month intervals during

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WATERFORO - UNIT 3 3/4 6-2

CONTAINMENT SYSTEMS-i i -

SURVEILLANCE REQUIREMENTS (Continued)

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shutdown at either P, 44 psig, or at P, 22 psig, during each g

j 10-year service period. The third test of each set shall be l

conducted during the shutdown for the 10-year plant inservice l

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inspection.

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b.

If any periodic Type A test fails to meet either 0.75.L,' or 0.75 L,

g the test schedule for subsequent Type A tests shall be reviewed and i

,j, approved by the Commission.

If two consecutive Type A tests fail to j.

seet either 0.75 L, or 0.75 L, a Type A test shall be performed at t

l 1 east every 18 months until two consecutive Type A tests meet either j

0.75 Lg or 0.75 Lt at which time the above test schedule may be l

resumed.

j The accuracy of each Type A test shall be verified by a supplemental c.

test which:

1 1.

Confirms the accuracy of the test by verifying that the supple-mental test result, L, minus the sum of the Type A and the j.,

superimposed leak, L,e, are equal to or less than 0.25 L,.

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Has a duration sufficient to establish accurately the change in j

leakage rate between the Type A test and the supplemental test.

3.

Requires the quantity of gas injected into the containment or

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bled from the containment during the supplemental test to be

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between 0.75 L, and 1.25 L,.

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Type B and C tests shall be conducted with gas at P, 44 psig, at intervals no greater than 24 months except for testi involving:

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Air locks, i

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Purge supply and exhaust isolation valves with resilient l

material seals.

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Purge supply and exhaust isolation valves with resilient material 1

seals shall be tested and demonstrated OPERA 8LE per Surveillance Requirement 4.6.1.7.2.

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a CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) f.

The combined bypass leakage rate shall be determined to be less than' or equal to 0.06 L, by applicable Type B and C tests at least once per 24 months except for penetrations which are not individually testable; penetrations not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurized to P,, 44 psig, during each Type A test.

g.

Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.

h.

The provisions of Specification 4.0.2 are not applicable.

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ATTACHMENT B l

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CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) shutdown at either P,, 44 psig, or at P. 22 psig, during each t

10 year service period. The third test of each set shall be conducted during the shutdown for the 10 year plant inservice inspection.

b.

If any periodic Type A test fails to meet either 0.75 L, or 0.75 L,

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the test' schedule for subsequent Type A tests shall be reviewed and approved by the Commission.

If two consecutive Type A tests fail to 1

meet either 0.75 L, or 0.75 L. a Type A test shall be performed at t

i least every 18 months until two consecutive Type ~A tests meet either 0.75 L, or 0.75 Lg at which time the above test schedule may be l

resumed.

j c.

The accuracy of each Type A test shall be verified by.a supplemental test which:

i 1.

Confirms the accuracy of the test by verifying that the supple-mental test result, L, minus the sum of the Type A and the superimposed leak L,e, are equal to or less than 0.25 L,.

I 2.

Has a duration sufficient to establish accurately the change in leakage rate between the Type A test and the supplemental test.

3.

Requires the quantity of gas injected into the containment or bled from the containment during the supplemental test to be j

between 0.75 L, and 1.25 L,.

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.i d.

Type B and C tests shall be conductgd with gas at P, 44 psig, at i

intervalsnogreaterthan24monthsexceptfortestlinvolving:

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Air locks, i

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Purge supply and exhaust isolation valves with resilient material seals.

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Purge supply and exhaust isolation valves with resilient material seals.shall be tested and demonstrated OPERA 8LE per Surveillance Requirement 4.6.1.7.2.

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SURVEILLANCE REQUIREMENTS (Continued) i f.

The combined bypass leakage rate shall be determined to be less than' 4

or equal to 0.06 L, by appitcable Type B and C tests at least once per24 month [exceptforpenetrationswhicharenotindividually l

testable; penetrations not individually testable shall be determined 1

to have no detectable leakage when tested with soap bubbles while the containment is pressurized to P,, 44 psig, during each Type A test.

g.

Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.

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The provisions of Specification 4.0.2 are not applicable.

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NPF-38-14 l

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o DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-14 This is a request to revise Technical Specification 3.8.1. A.C. Sources.

Specifically, Surveillance Requirement 4.8.1.1.2.d.1 would be revised to

. clarify the allowable surveillance interval for diesel generator inspection.

Existing Specification See Attachment A Proposed Specification See Attachment B Description Surveillance Requirement 4.8.1.1.2.d.1 requires that "at least once per 18 months during shutdown" the emergency diesel generators will be subjected "to an inspection in accordance with procedures prepared in conjunction l

with its manufacturer's recommendations for this class of standby service."

The proposed change will clarify the surveillance interval by specifying l

that the inspection be performed at refueling outages.

The Standard Review Plan and the Technical Specification Bases cite various Regulatory Guides as the basis for operability denonstration of the diesel l

generators. Functional testing is primarily addressed by Regulatory Guide i

1.108 Periodic Testing of Diesel Generator Units as Onsite Electric Power i

Systems at Nuclear Power Plants. This Regulatory Guide discusses most of the testing requirements of Surveillance Requirements 4.8.1.1.2.d.2-13 however, the Regulatory Guide, the Standard Review Plan and the Waterford 3 Technical Specification Bases are silent on th'e subject of diesel generator inspection as described in Surveillance Requirement 4.8.1.1.2.d.1.

It is apparent that in satisfying Surveillance Requirements 4.8.1.1.2.d.2-13 the operability of the diesel generators has been adequately demonstrated and that no additional safety benefit is to be gained through a mid-cycle outage solely for the purpose of inspection of the diesel generators to satisfy an 18 month surveillance.

l Nonetheless, LP&L recently retained the services of the diesel manufacturer, Cooper-Bessemer, to perform on-line diagnostic analyses of the diesel generator operation. Cooper-Bessemer determined that no significant deficiencies were present and that those areas identified as recommendations would not adversely affect the operation of the diesel generators.

In fact, Cooper-Bessemer recommends that a refueling cycle interval is adequate for inspection purposes. Although Surveillance Requirement 4.8.1.1.2.d.1 appears to allow flexibility with respect to manufacturer's recommendations (i.e. perform inspections, "in accordance with... manufacturer's recommendations"), LP&L is taking the conservative approach in requesting this Technical Specification change.

Regardless of the Technical Specification surveillance inspection interval, LP6L intends to vigorously pursue any diesel generator deficiencies.

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o LP&L also will utilize the EN-SPEC 2000 Engine Analyzer to perform periodic l

diagnostic testing on the diesel generators. The 2000 Engine Analyzer is a multi-purpose test instrument designed to evaluate the performance of l

reciprocating engines and compressors.

By comparing current operational characteristics with previously recorded baseline data, any appreciable performanco degradation should be detected, and remedied.

Therefore, based on the Cooper-Bessemer results and planned preventive maintenance, a full plant outage to satisfy Surveillance Requirement 4.8.1.1.2.d.1 is not technically justified and would serve only to fine tune the diesels and increase electrical costs to LP&L ratepayers.

j Safety Analysis l

l The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: NO The bases for diesel generator operability requirements are l

contained in the Standard Review Plan, Regulatory Guide 1.108 (among others), and the Technical Specification Bases. Through Surveillance Requirements 4.8.1.1.2a-c and 4.8.1.1.2.d.2-13 Waterford 3 continues to fully demonstrate operability of the

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diesel generators. Therefore, the proposed change will not i

involve a significant increase in the probability or consequences of any accident previously evaluated.

2.

Will operations of the facility in accordance with this proposed change create the possibility of a new or different kind of I

accident from any accident previously evaluated?

Response: NO The proposed change introduces no new systems, modes of operation, failure modes or other plant perturbations.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Responses NO Emergency diesel generator operability is assured through functional testing conducted in accordance with Surveillance Requirements 4.8.1.1.2a-c and 4.8.1.1.2d.2-13.

Functional testing provides an objective demonstration of operability as mandated by the Standard Review Plan. Therefore, the proposed change will not involve a significant reduction in a margin of safety.

2

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The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 CFR 14870) of amendments that 1re considered not likely to involve significant hazards considerations.

Example (i) relates to a purely administrative change to Technical Specifications:

for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature, In this case, the proposed change is similar to Example (i) in that it clarifies ambiguity concerning the surveillance interval associated with Surveillance Requirement 4.8.1.1.2.d. l.

Absent any guidance in the Standard Review Plan, Regulatory Guide 1.108 and the Technical Specification Bases, the conservative approach with respect to this Surveillance Requirement is to implement a clarification.

Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that:

(1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.91, and (2) there is a reasonable assurance that the health l

and safety of the public s ill not be endangered by the prooosed change, and (3) this action will not result in a condition which sigt.f ?icantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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ATTACHMENT A 4

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3/4.8 ELECTRICAL POWER SYSTEMS O

j 3/4.8.1 A.C. SOURCES OPERATING j

LINITING CONDITION FOR OPERATION i

3.8.1.1 As a minimum, the following A.C. electrical power sources shall be i

0PERA8LE:

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i a.

Two physically independent. circuits between the offsite transmission j

network ar.1 the onsite Class 1E distribution system, and j

b.

Two separate and independent diesel generators, each with:

i 1.

Diesel oil feed tanks containing a minimum volume of 337 gallons j

of fuel, and 2.

A separate diesel generator fuel oil storage tank containing a minimum volume of 38,760 gallons of fuel, and 1

3 3.

A separate fuel transfer pump.

f APPLICA81LITY: MODES 1, 2, 3, and 4.

ACTION:

I a.

With either an offsite circuit or diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERA 81LITY of the remaining A.C. sources by performing Surveillance j

Requirements 4.8.1.1.la and 4.8.1.1.2a.4. within I hour and at j

least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least two offsite circuits and two diesel generators to OPERA 8LE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least H0T STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLO j

SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

j b.

With one offsite circuit and one diesel generator of the above l

j required A.C. electrical power sources inoperable, demonstrate the l

OPERASILITY of the remaining A.C. sources by performing Surveillance j

Requirements 4.8.1.1.la. and 4.8.1.1.2a.4. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at:

j least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the I

1 inoperable sources to OPERA 8LE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at i

least HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN j

within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Restore at least two offsite circuits and two diesel generators to 0PERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from i

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the time of initial loss or be in at least HOT STAN08Y within the j

next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following 30-hours.

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c.

With one diesel generator inoperable, in addition to ACTION a. or b.

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above, verify that; t

(1) All required systems, subsystems, trains, components, and j

devices that depend on the remaining OPERA 8LE diesel generator j

as a source of emergency power are also OPERA 8LE, and i

l (2) When in MODE 1, 2, or 3, the steam-driven emergency feed pump

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is OPERA 8LE.

If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least

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HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the-j following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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ELECTRICAL POWER SYSTEMS ACTION (Continued) 1 l

d.

With two of the above required offsite A.C. circuits inoperable, i

demonstrate the OPERA 81LITY of two-diesel generators by performing Surveillance Requirement 4.8.1.1.2a.4. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least.

once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, unless the diesel generators'are already-operating; restore at least one of the inoperable offsite sources.to L

OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STAN08Y within j

the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With only one offsite source restored, restore at-l l

1 east two offsite circuits to OPERA 8LE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from j

time of initial loss or be in at least'H0T STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

I e.

With two of the above required diesel generators inoperable.

- t demonstrate the OPERA 8ILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.la, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and-at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERA 8LE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be i

in at least HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 'in COLD SHUTDOWN j

within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Restore at least two diesel generators-l to OPERA 8LE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial-loss or be in at least HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and.in COLD SHUTDOWN i

within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, l

SURVEILLANCE REQUIREMENTS I

}

4.8.1.1.1 Each of the above required independent circuits between the offsite i

transmission network and the onsite Class 1E distribution system shall be:-

l a.

Determined OPERA 8LE at least once per 7 days by verifying correct breaker alignments, indicated power availablity, and i

b.

Demonstrated OPERABLE at least once per 16 months by transferring i

manually and automatically unit power supply from the normal circuit j

to the alternate circuit.

1 1

4.8.1.1.2 Each diesel generator shall be demonstrated OPERA 8LE:

I i

a.

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

1.

Verifying the fuel, level in the die'sel oil feed tank, l

2.

Verifying the fuel' level in the diesel generator fuel oil storage tank, 3.

Verifying the ' fuel transfer pump can be started and transfers j

fuel from the ' storage system to the diesel oil feed tank, WATERFORD - UNIT 3 3/4 8-2

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ELECTRICAL POWER SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

4. -. Verifying the diesel starts fros' ambient condition and accelerates..

j to at least 600 rps (60.1 1.2 Hz) in less than orLequal to 10 seconds.*

The generator voltage and frequency shall be'4160 1 420 volts and 6011.2 Hz within 10 seconds

  • after the start signal. ~ The diesel generator shall be started.for this test by using one of the following signals:

j a)

Manual.

b)

Simulated loss-of-offsite power by itself.

j j

c)

Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.-

j' d)

An ESF actuation test signal by itself.

t 5.

Verifying the generator is synchronized, loaded to greater.than or equal to 4400 kW in less than or equal to 176 seconds,* and

!)

operates with a load greater than or equal to 4400 kW for at least an additional 60 minutes, and 6.

Verifying the diesel generator is aligned to provide standby j

power to the associated emergency busses.

h, b.

At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to I hour by checking for and removing accumulated water from the diesel oil feed i

tanks.

I c.

At least once per 92 days and from new fuel oil prior tc addition to the storage tanks, b'y obtaining a sample of fuel oil in accordance

{

with ASTM-0270-1975, and by verifying that the sample meets the i

following minimum requirements and is tested _within the specified j

time limits:

1 l

1.

As soon as sample is taken (or prior to adding new fuel to the storage tank) verify in accordance with the test specified in l

ASTM-0975-77 that the sample has:

1 a)

A water and sediment content of less or equal to 0.05 i

volume percent.~

4

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b)

A kinematic viscosity 9 40*C of greater than or equal to l

1.9 centistokes, but less than or equal to 4.1 centistokes.

c)

A specific gravity as specified by the manufacturer 9 j'

60/60*F of greater than or equal to 0.80 but less than or.

equal to 0.99 or an API gravity 9 60*F of greater than or equal to 11 degrees but less than or equal to 47 degrees.

f j

  • The diesel generator start (10 sec) and subsequent loading (176 sec) from ambient conditions shall be performed at least once.per 184 days in these surveillance tests. All other engine starts ano loading.for the purpose of j

this surveillance testing may be preceded by an engine prelube period and/or-other warmup procedures recommended by the manufacturer so that mechanical.

stress and wear on the diesel engine is minimized.

i WATERFORD - UNIT 3 3/4 8-3 i

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 2.

Verify an impurity level of less than 2 mg of insolubles per 100 ml when tested in accordance with ASTM-02274-70; analysis shall be completed within 7 days after obtaining the sample but may be performed after the addition of new fuel oil;.and 4

3.

Verify the other properties specified in Table 1 of ASTM-0975-1977 -

and Regulatory Guide 1.137, Revision 1, October 1979, Position 2.a., when tested in accordance with ASTM-0975-1977; analysis shall be completed within 14 days after obtaining the sample but i

may be performed after the addition of new fuel oil.

d.

At least once per 18 ~ months during shutdown by:

1.

Subjecting the diesel to an inspection in wcordance with l

procedures prepared in conjunction with its manufacturtr's recom&end'tions for this class of standby service.

2.

Verifying the generator capability to reject a load of greater j

than or equal to 498 kW (HPSI pump).while maintaining voltage-at-4160 + 420 volts and frequency at 60 +4.5, -1.2 Hz.

3.

Verifying the generator capability' to reject a load of 4400 kW without tripping. The generator. voltage shall not exceed 4784 volts during and following the load rejection.

4.

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

a)

Verifying deenergization of the emergency busses and load shedding from the emergency busses.

b)

Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanentTy connected loads within 10 seconds after the auto-start signal, i

energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads..After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 1 420 volts and 60 + 1.2, -0.3 Hz during this test.

5.

Verifying that on an SIAS actuation test signal (withcut loss-of-offsite power) the diesel generator starts on the auto-start signal and operates on standby.for greater;than or equal to 5 minutes. The steady-state generator voltage and frequency shall be 4160 1 420' volts and 60 i 1.2 Hz within 10 seconds i

after the auto-start signal; the generator voltage and frequency-shall be maintained within these limits during this test.

i

l i

WATERFORD - UNIT 3 3/4 8-4

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ELECTRICAL POWER SYSTEMS i

SURVEILLANCE REQUIREMENTS (Continued) 6.

Simulating a loss-of-offsite power in conjunction with an SIAS actuation test signal, and a)

Verifying deenergization of the emergency busses and load

' shedding fron'the emergency busses.

b)

Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds after the auto-start signal, energizes the auto-connected emergency loads.through the l

load sequencer and operates for greater than or equal to 5 minutes. After energization. the steady-state voltage I

and frequency of the emergency busses shall be maintained at 4160 i 420 volts and 60 + 1.2, -0.3 Hz during this t

test.

c)

Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emer-gency bus concurrent with a safety injection actuation s i g-ln.

7.

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be _ loaded to greater thart.or equal to 4840 kW and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to greater than or equal to 4400 kW.

The generator-voltage and freqency shall be 4160 1 420 volts and 60 2 1.2 Hz within 10 seconds after the start signal; the st'eady-state generator voltage and frequency shall be 4160 1 420 volts and 60 + 1.2, -0.3 Hz during this test. Within 5 minutes after-completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2.d.4b.

1 l

8.

Verifying that the auto-connected loads to each diesel generator do not exceed the 2000-hour rating of 4400 kW.

9.

Verifying the diesel generator's capability to:

a)

Synchronize with the offsite power source while the generator I

is loaded with its emergency loads upon a simulated restora-

' i tion of offsite power, b)

Transfer its loads to the offsite power source, and c)' -Be restored ta its standby status.

10.. Verifying that with the diesel generator operating in a test mode.(connected to-Its bus), a simulated safety. injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (k) automatically energizes j

the emergency loads with offsite powr.-

j WATERFORD - UNIT 3 3/4 8-5

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3 7

ELECTRICAL POWER 5YSTEMS,

.t SURVEILLANCE REQUIREMENTS (Continued)-

1 L

o

11. Verifying that the fuel transfer pump transfers. fuel from each i

fuel storage tank to the diesel oil feed tank of each diesel via the installed cross connection lines.

12. Verifying that the automatic load sequence timer is OPERABLE with the time of each load block within +10% of the sequenced load block time.
13. Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:

3 a) turning gear engaged j

b) emergency stop l

c) loss of 0.C. control power d) governor fuel oil linkage tripped l

e.

At least once per 10 years or after any modifications which could i

affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 600 rps (60 1 1.2 Hz) in less than or equal to 10 seconds.

4 j

f.

At least once per 10 years by:

1.

Oraining each diesel generator fuel oll storage tank, removing 1

the' accumulated sediment, and cleaning the tank using a s' odium.

hypochlorite solution or equivalent, and 2.

Performing a pressure test of those portions of the diesel fuel

\\

oil system designed to Section III, subsection ND of the ASME Code at a test pressure equal to 110% of the system design i

pressure.

g.

By performing a visual inspection' of the interior of the diesel j

generator fuel oil storage tanks each time the tank is drained and, i

if necessary, clean the tank with a sodium hypochlorite solution, or equivalent.

~

4.8.1.1.3 Reports - All diesel generator failures,. valid or nonvalid, shall i

be reported in a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days. Reports of diesel generator failures shall include the.

i information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, i

Revision 1, August 1977. If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater than or equal to 7, the report shall 6

be supplemented to include the additional.information recommended in Regulatory j

Position C.3.b of ' Regulatory Guide 1.108, Revision 1, August 1977.

l i

WATERFORD - UNIT 3 3/4 8-6 1

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TABLE 4.8-1 OIESEL GENERATOR TEST SCHEDULE NUMBER OF FAILURES IN LAST'100 VALID TESTS.*

TEST ~ FREQUENCY

<1 At least once.per 31 days 2

At least once per 14 days 3

At least,once'per 7 days-14 At least once per 3 days 4

" Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the last 100 tests are determined on a per nuclear unit basis.

For.the purposes of this test schedule, only valid tests conducted after the Operating License issuance date shall be included in the computation of the "last 100 valid tests".

Entry into this test schedule shall be made at the 31 day test frequency.

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ELECTRICAL POWER SYSTEMS.

SURVEILLANCE REQUIREMENTS (Continued) 2.

Verify an impurity level of less than 2 mg of insolubles per

~

100 ml when tested in accordan o with ASTM-02274-70; analysis shall be completed within 7 days after obtaining the sample but may be performed after the addition of ncw fuel oil; and 3.

Verify the other properties specified in Table 1 of ASTM-0975-1977 and Regulatory Guide 1.137, Revision 1, October 1979, Position 2.a., when tested in accordance with ASTM-0975-1977; analysis shall be completed within 14 days after obtaining the sample but may be performed after the addition of new fuel oil.

d.

At least once per '.8 ' months during shutdown by:

I 1.

Subjecting the diesel to an inspection in accordance with i

procedures prepared.in conjunction with its manufacturer's recommendations for this class of standby servicey (To SE.

&noverch bawk RefaGu M4 Ournt.Es Ouuy).

2.

Verifying the generator capability to' reject a load of greater than or equal to 498 kW (HPSI pump) while maintaining voltage at 4160 + 420 volts and frequency at 60 +4.5, -1.2 Hz.

3.

Verifying the generator capability to reject a load of 4400 kW without tripping. The generater voltage shall not exceed 4784 volts during and following the load rejection.

i 4.

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

a)

Verifying deenergization of the emergency busses and load shedding from the emergency busses.

b)

Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanentTy connected loads within 10 seconds after the auto-start signal, energizes the auto-connected shutdown loads through the load sequencer and operates'for <Jreater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at l

4160 1 420 volts and 60 + 1.2, -0.3 Hz during this test.

S.

Verifying that on an SIAS actuation test signal (without loss-of-offsite power) the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The steady-state generator voltage and frequency shall be 4160 t 420 volts and 60 i 1.2 Hz within 10 seconds after the auto-start signal; the generator voltage and frequency shall be maintained within these. limits during.this test.

f i

4 WATERFORD - UNIT 3 3/4 8-4

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