ML20196A094

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Proposed Tech Specs Re Div 3 Diesel Generator Droop Issue
ML20196A094
Person / Time
Site: Clinton Constellation icon.png
Issue date: 11/20/1998
From:
ILLINOIS POWER CO.
To:
Shared Package
ML20196A088 List:
References
NUDOCS 9811270051
Download: ML20196A094 (18)
v • d • e


Text

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, , . Attachment 3 1

' CPS-USAR to U-603092 t

LS-98-010 l Page 4 of 16 1

Reculatorv Guide 1.9) Rev. 2 (Decemlier 1979)

! -Selection, Design and Qualification of Diesel-Generator Units Used as Onsite Electi-ic Power' Systems at Nucidar Power Plants _

l Pro-lec<:bPosition - The projec't complies witil NRC Re*gula ry Guide

'1. 9[ wi1:II)clarification following (except where noted in Subsection ^8.3.1.'1.2. the

Reference:

arid 8.3.l.2.7.

Paragraph C.7 - Isolation valves are not included on instrument . sensing lines, so that. calibration df instrument se'nsors cannot be accomplished without disconnecting the sensor from the sensed variable.

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USXR'Subsset' ion - 83.1.1.2.1,8.3.1.2.2

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i 1.8-22 9811270051 981120 PDR ADOCK 05000461 p PDR a

' CPS-USAR' Attachment 3 to U-603092 LS-98-010 Page 5 of 16

. Reculatory Guide 1.32, Rev. 2 (February, 1977)

Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants Proiect Position -

Comply, with the following-exception

Reference:

Paragraph C.1.c - once per 60-month. intervals the performance discharge test may be performed in lieu of the battery service test.

USAR Subsections - 7.1.2.6.8, 7.3.2.1.2.1.6, 7.4.2.1.2.1.6, 8.1.6.1.6,g 8 .3.1.2.2., 8.3.2.1.2.1, 8.3.2.2.2.2.

6. 3. l . l .2. l 4

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1.8-46

. _ _ _ - - _ . . --- ~ ~ - - - - - " ~ ~ ~ ^^^' ~ ' " ' " ^ ' ^ ' ^ ~ ^ ^ ^ ' ^ ^ ~ ~

. , Attachment 3

, CPS-USAR Revision 6 to U-603092 LS-98-010 February 1995 l

Page 6 of 16 Reculatory Guide 1.108. Rev. 1 (August 1977) i

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Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants' ,

Proiect Position -

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f Comply with clarification to Section C 2: .

l l diesel generator units Specifications. will be as required by the TechnicalPeriodic testing of will be as required by the Operational Requirements Manual. Reporting USAR Section/ Subsection - 8.3.1; TS3.8.1, 3.8.2; ORM 6.9.2.1

  • R$ PLACE WITH ATTACHED To INCLUDE NEW, ADDITIONAL TEXT 9

1.8-134

Attachment 3 )

to U-603092 LS-98-010 Page 7 of16 l

INSERT for USAR Section 1.8 (Project Position Regarding Regulatory Guide 1.108)

(USAR page 1.8-134) i Project Position - Comply with the following clarifications:

1)

Reference:

Section C.l.b(3)-The Division 3 diesel generator design includes override capability to ensure automatic switchover from the test mode to ready-to-load operation in response to a loss-of-coolant-accident (LOCA) initiation signal.

However, during testing with a non-zero droop setting in effect (to support paralleling the diesel generator with the offsite power source), in the event of a l

LOCA initiation signal concurrent with a loss of the offsite power source to the bus, operator action may be required (in addition to the automatic actions) to reset l the governor and thus ensure bus frequency is within required limits when the

. diesel generator alone is subsequently supplying power to the Division 3 bus.

2)

Reference:

Section C.2 -Periodic testing of diesel generator units will be as  !

required by the Technical Specifications. Reporting of diesel generator unit test failures will be as required by the Operational Requirements Manual.

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, . .- Attachment 3

. to U-603092 CPS-USAR LS-98-010 Page 8 of 16 8.1.6.2.13 IEEE 387 " Standard Criteria for Diesel Generator l Units Applied as Standby Power Supplies for l Nuclear Power Generatina Stations" The design of the Clinton Power Station Division 1 and 2 diesel generator units is in accordance with the requirements of IEEE 387 as clarified in Subsection 8.3.1.2.2, which discusses l compliance with Regulatory Guide 1.9.

jdie HPCS (Division 3) diesel-generator unit meets the applicable requirements of IEEE 387 to:

a. Operate in its service environment during and after any design-basis event without support from the preferred power supply.

ib. Start, accelerate, and be loaded with the design

! Excepg as agso load within an acceptable time,

/ clarihed in 1. from the normal standby condition; l

Subsedian 8.3.1.2.23 l

.) 2. with no cooling available, for equivalent to that required to a time bring the cooling equipment into service with energy from the diesel generator unit; an'd

.3. on a restart with an initial engine temperature equal to the continuous rating, full load engine temperature.

c. Carry the design load for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />.
d. Maintain voltage and frequency within limits that will not degrade the performance of any of the loads composing the design load below their minimum requirements, including the duration of transients caused by load application or load removal.
e. Withstand any anticipated vibratior, md overspeed conditions. There is no flywheel coupled with the HPCS diesel-generator. The generator and exciter are designed to withstand 25% overspeed without damage.

The HPCS diesel-generator has continuous and short term ratings consistent with the requirements of IEEE 387.

I 8.1-20

Attachment 3 to U-603092 )

LS-98-010 l CPS-USAR Revision 5 Page 9 of 16 4 Th.e diesel generators operate unloaded only during a LOCA when offsite power is available. They can operate for four (4) hours in a no-load condition without reducing the engine availability.

By operating procedure, during extended periods of standby operation at synchronous speeds, the diesel generators will be paralleled one at a time with offsite power (test mode) and loaded to 40% of their rated load for a period of 30 minutes to remove excess fuel deposits from the exhaust ports. (Q&R 040.45) While the Divisions 1 and 2 diesel generators are in the test mode, diesel generator lockout is precluded for overloads on subsequent loss of offsite power. The design of Division 3 is as follows:

Periodic testing of the HPCS Diesel Generator is performed from the control room by manual initiation or simulation of LOCA.

This testing does not impair the capability of starting the HPCS pump within the re ulrod 11mWe* ronAolspa pyarriddelt by the LOCA even excepf ES desdbed in Subsechds 8.3.1.1.2.1 ud 6.3,l.2.2.

The local Engine Control Switch is usually in the automatic position to allow operation and periodic testing from the control room. The local engine control switch also provides a maintenance and test position. The maintenance position places the'HPCS diesel generator in "out of service". The test position is used only for test after maintenance prior to transferring to automatic operation. The LOCA signal will not start the engine when the engine control switch is in the test position.

The diesel-generator sets selected are qualified in accordance with Regulatory Guides 1.6 and 1.9 as follows:

a. At least two tests were performed on each diesel generator not previously qualified to demonstrate the start and load capability of these units with some margin in excess of the design raargin.
b. Prior to initial fuel loading, a total of 300 start and load tests were performed on each diesel generator.

The start and load test consists of 270 starts from warm standby conditions and 30 tests from normal operating temperatures with loading to at least 50% of the nameplate continuous rating within the requested time interval and continued operation until temperature equilibrium is attained.

c. Further testing will be performed if the failure rate is greater than one per hundred.

Qualification of the diesel generators is per the requirements of IEEE 344, Regulatory Guide 1.100 add 10 CFR 50.49.

8.3-23

mm attacWment 3J 2

No CHANCES TO THIS PAGE t PROVIDED F06 CCNTINUITY CPS-USAR Page 10 of 16 Revision 4 September 1992

( The Class 1E a-c power system is' designed to" permit inspection and testing of all important areas and features, especially those whose operation is not normally demonstrated. As detailed I in Chapter 16, Technical Specifications, periodic component  !

tests are supplemented by extensive functional tests during l refueling outqges, the latter based on actual accident simulated i conditions. These tests demonstrate the operability of diesel ,

generator, station battery system components, and logic systems,  !

and thereby verify the continuity of the systems and the operation of components. i 8.3.1.1.2.1 Hich-Pressure Core Sorav System (HPCS) Power System l The HPCS power supply system is self-contained except for the initiation _ signal source and access to both offsite power j

sources through the plant a-c power distribution system. It has  ;

j a dedicated diesel generator and is operable as an isolated  ;

l system independent of electrical connection to any other system. l l The standby auxiliary equipment such as heaters, air compressor, l and battery charger are supplied from the same power source as  ;

the HPCS motor. Voltage and frequency of the HPCS diesel i generator is compatible with that available'from the. plant a-c power system.

The General Electric HPCS system power supply unit Licensing Topical Report, NEDO 10905, gives the, starting and accelerating characteristicr of the diesel generator set with the various

. loads in the proper sequence. Although the voltage and frequency characteristics do not meet NRC Regulatory Guide 1.9, justification for this is given because of the unique requirements of the system. The HPCS diesel generator is unique in that its load is composed predominantly of one large motor whose horsepower is approximately the same as the diesel-engine. I The analytical results from a digital dynamics stability i program, and prototype tests performed, demonstrate the capability of the diesel generator and of the equipment i associated with the system to meet all necessary requirements.

The NRC has previously accepted this analysis which is contained in the NEDO 10905 document. (Q&R 040.15) i i All safety related continuous _ duty motors have the ability to deliver their rated horsepower continuously without damage when the voltage at the terminals is 10% above or below rated voltage with rated frequency. These motors can also deliver their full load torque without damage when the voltage at the terminal drops to 75% for infrequent one-minute intervals.

, .The starting sequence provides for containing HPCS diesel l

generator voltage drops down to 62% of rated voltage. This dip

in voltage lasts for 1 second and would recover to 75% volts

. after this time frame. This time frame is short enough to prevent the loss of flux to the field. Therefore no motor damage i

, 8.3-24

_ .__ _ _ - ~ - -_

.- It4sEI:.T NEW/ADDITloNAL Attachment 3 to U-603092 l

ATT ACHED TEXT CPS-USAR Revision 7 LS-98-010 June 1997 Page 11 of 16 l or malfunction will occur and the present supply to the motor is adequate., A similar motor is being utilized at LaSalle and other plants and performance is covered by NEDO 10905 and is l accepted by the NRC. (Q&R 040.16)

The division 3 HPCS diesel generator is capable of starting the i HPCS motor within the required time in accordance with _

l NED0-10905 although voltage and frequency drop will exceed the l

limits specified in NRD Regulatory Guide 1.9.

l Mechanical safety trips recommended by the Division 3 diesel generator vendor and the electrical protective tripping scheme (identified on drawings E02-1HP99 sheets 101 through 114 and referenced in Section 1.7) are consistent with the Division 1 and 2 diesel generator tripping schemes and meet the requirements of Regulatory Guide 1.9. All trips except overspeed and generator differential are bypassed on a LOCA.

(Q&R 040.14)

The NSPS power supply is in full compliance with Regulatory Guide 1.75, and no deviations will be taken.- The final NSPS power supply design was available by November of 1981. (Q&R 430.92)

In this way, the diesel generator availability is fully assured during an offsite power loss.

8.3.1.1.3 Instrument Power System The NSPS power supply will be in full compliance with Regulatory Guide 1.75, and no deviations will be taken. (Q&R 430.92)

The instrument power system consists of the followin'g major components:

a. (4) - 120-Vac nuclear system protection system uninterruptible power supplies and buses.
b. (2) - 120-Vac nuclear system protection system RPS uninterruptible power supplies and buses.
c. (2) - 120-Vac computer uninterruptible power supplies.
d. (2) - 120-Vac BOP instrument buses (120-Vac MCC distribution panels with regulating transformers).

l e. (3) - 120-Vac Class lE instrument buses (120-Vac MCC distribution panels with regulating transformers).

The subsystem consisting of the (4) NSPS UPS's and associated buses, (divisional) the (2) RPS UPS's excluding associated buses, (nondivisional) and the (3) 120-Vac instrument buses are l Class 1E. The remainder of the subsystems listed above are non-safety related.

8.3-25 i

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i Attachment 3 to U-603092 LS-98-010 Page 12 of 16 INSERT for USAR Subsection 8.3.1.1.2.1 (USAR page 8.3-25)

In addition, and as also stated in Subsection 8.3.1.2.2, the HPCS diesel generator design includes override capability to ensure automatic switchover from the test mode to ready-to-load operation upon receipt of a LOCA initiation signal consistent with the requirements ofIEEE 308 and 387.

However, the HPCS diesel generator is equipped with a mechanical governor that operates only i in a droop mode. Normally, the droop setting is set to zero, but during testing (i.e., while the l l diesel generator is in the test mode) a non-zero droop setting may be utilized to support l paralleling the diesel generator with the offsite power source. Under such conditions, the droop l may be set such that, if a LOCA initiation signal were received concurrent with no offsite power available to the Division 3 bus, operator action may be required to reset the governor and thus

, ensure bus frequency is within required limits when the diesel generator alone is supplying power

! to the bus.

The droop mode, as described above, is utilized only during testing, and the potential need for i operator action to reset the governor after receipt of a LOCA signal (concurrent with a loss of I offsite power) exists only during that portion of the test when the diesel generator is unloaded or l lightly loaded while paralleled to the offsite source. A risk assessment performed for this condition demonstrates that the associated risk is very small. On this basis, the Division 3 diesel generator design, with respect to automatic switchover capability from the test mode to ready-to-load operation, has been determined to be acceptable.  !

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A CPS-USAR Attachmsnt 3 NO CHA*l6ES-TO Tnifi FACE I to,U-603092 i

ffLOVIDED Folt. coNTIHo:1Y [s 8jloor 16 j ' ('] Th'e NSPS power su ly system is designed to permit inspection and testing of all importaht equipment and features. This capability li / 1 is provided by the inclusion of alternate power to each bus.

Provision is.made for periodic testing of all switching functions in both activation directions.

8.3.1.2.2 Conformance with NRC Reaulatorv Guides Reaulatorv Guide 1.6. "Indeoendence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems"

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Conformance with this regulatory guide is described as follows for each regulatory position:

Position C.1

,_ Each Class lE lo,ad is assigned to a Division 1, 2, or 3 load group. Assignment is determined by the nuclear safety functional redundancy of the load.

L Usually one (two at the most) division load group is required to perform safety functions. I I 1 i The four divisions of essential power of the NSPS power supply l system are each fed by a 480-Vac essential power supply.

l , G %' . Division 1 is fed by the Division 1 480-Vac essential power l( ) supply; Divisions 2 and 4 are fed by the Division 2 480-Vac power P supply, and Division 3 is fed by the Division 3 480-Vac power supply. , I Position C.2 Each division'a-c load group has a feed from two auxiliary-transformers. RAT and ERAT (offsite) and one diesel generator (onsite) as shown in Figure 8.3-1.

The diesel-generator breaker can be closed automatically only if , .

l the other source breakers to that load group are open, as shown on drawings E02-1AP02 sheets 11 and 12 listed in Section 1.7.

-The diese;l generators have no connections to any other redundant l load group.

Position C.3 Not applicable. Position C.3 addresses d-c load groups, whereas this subsection addresses a-c power. .

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, plo CHANGE % 'r0 TNIS PAGB *

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" *f03f92 U-PROVIDED foK CottflWWT( LS-98-010 l

Page 14 of 16 l

! Position C.4 -

a.

The diesel-generator breaker can be closed to its associated load group automatically only if the other source breakers to that load group are open, as shown on drawing E02-1AP02 listed in

,Section 1.7. . _ _

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b. When the diesel-generator breaker is closed, no i

' other source breaker can be closed automatically as shown on drawing E02-1AP02 listed in Section l

1.7. No other means exist for connecting l redundant load groups with each other.

c. Each of the redundant load groups is fed from only one diesel generator, as shown in Figure 8.3-1. No means are provided for transferring loads between the redundant diesel generators.
d. Sufficient interlocks are provided to prevent paralleling the diesel generators manually by operator error as previously discussed in Subsection 8.3.1.1.2.

Position C.5

' Division 1 and 2 diesel generators have tandem prime moyers for each generator.

i Reaulatorv Guide 1.9 " Selection. Desian, and Oualification of Diesel-Generator Units Used as Onsite Electric Power System at l Nuclear Power Plants"

, Conformance with this regulatory guide is described as follows i

for each regulatory position. (Information regarding the conformance of Division 3 components and design to Regulatory Guide 1.9 May be found in General Electric Topical Report i NEDO-10905.)

l Position C.1 The following tabulation compares the maximum expected coincidental loads with the diesel generator ratings:

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!' Maximum Condition for Continuous Coincidental Maximum Diesel Rating Load Coincidental Generator (kW) (kW) Load 1A 3869 3865

[ 1B LOCA (Table 8.3-13) 3875 3368 LOCA (Table 8.3-13) 1C 2200 2014

{ LOCA (Table 8.3-13) e 8.3-32' l

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.' Attechmant 3 CPS-USAR Revision 5 f[f'00 8

Page 15 of 16 Position C_._2 Predicted loads do not exceed the continuous rating of the diesel i generators.

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Position C.3 See Subsection 8.3.1.2.2, Conformance with NRC Regulatory Guide I 1

1.32.

Position C 4 1 1

During the loading sequence,'the diesel generator has the  !

capability of. frequency restoration to within 2% of normal and I voltage restoration to within 10% of nominal within 2 seconds after loading is applied, which is within 60% of th'e load sequence time l interval.

During recovery from transients caused by step load increases or  ;

resulting from the disconnection of the largest single load, the 1 speed of the diesel generator will not exceed the nominal speed plus 75% of the difference between nominal speed and the overspeed i trip setpoint or 115% of nominal, whichever is lower. J Position C.5 ,

see Subsection 8.1.6.1.16, Conformance with NRC Regulatory Guide 1.89.

Position C.6 The diesel generators are designed to be testable during the operation of the plant as well as during shutdown. The diesel generator instrumentation sensors will be tested by disconnecting instrument lines and i er estin in place or at remote location.

? INSERT NE.W/ADDtYloNAL ATTACHED TEXT Position C.7 je f Section 5.6.2.2(1) of IEEE-387-77 (endorsed by Regulatory Guide 1.9

. Revision 2) requires that a start-diesel signal shall override all other operating modes and return control of the diesel-generator

(g, unit to the automatic control system.

yfbeCPSdieselgeneratorcontrolschemesmeetthisrequirement except that upon receipt of LOCA signal all protective trips are bypassed'except generator differential, engine overspeed and engine overcrank for Divisions I and II diesel generators and generator

' differential and engine overspeed for Division III diesel l generator. (Q&R 430.134]

l The design of the bypass circuitry satisfies the requirements at j the diesel generator level and includes the capability for (1) 8.3-33

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l t . 1 Attachment 3 l to U-603092 l LS-98-010 l ,

. Page 16 of16 l

INSERT for USAR Subsection 8.3.1.2.2 (USAR page 8.3-33) l With respect to this requirement, which is consistent with the requirement of Section 5.6.1.4 (of l the same standard) regarding governor operation for a diesel generator, the Division 3 diesel generator design is provided with automatic switchover capability from the test mode to automatic operation upon receipt of a LOCA initiation signal. However, as further discussed in Subsection 8.3.1.1.2.1, during testing with a non-zero droop setting in effect (to support paralleling the diesel generator with the offsite power source), in the event of a LOCA initiation signal concurrent with a loss of the offsite power source to the bus, operator action may be required (in addition to the automatic actions) to reset the governor and thus ensure bus frequency is within required limits when the diesel generator alone is subsequently supplying power to the Division 3 bus.

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Attachment 4 to U 603092 LS98-010 Page 1 of 5 Proposed Changes to Clinton Power Station (CPS) l Technical Specification Bases ma The attached, proposed changes to the Technical Specification Bases are consistent with, but supersede, the proposed Bases changes provided in IP's application for license amendment dated August 24,1998 (IP letter U-603067).

These proposed Bases changes are consistent with the proposed USAR changes i described and provided in Attachment 3, as additionally supported by Attachment I

2. Justification for these proposed Bases changes can therefore be found in those attachments, as well as in IP's August 24 application for amendment.

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't 30 AC Sources-Operating LS-98-010 B 3.8.1 ,

i Page 2 of 5 BASES (continued) ~

l SURVEILLANCE The AC sources are designed to permit inspection and j- REQUIREMENTS 1 testing of all impo. tant areas and features, especially those that have a standby function, in accordance with l' 10 CFR 50, GDC 18 ( M . 8). Periodic component tests are i

' supplemented by extensive functional tests during refueling outages under simulated accident conditions. The SRs for 4

i 2 demonstrating the OPERABILITY of the DGs are in t.ccordance j~

with the recommendations of Regulatory Guide 1.9 (Ref. 3),

Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137

(Ref. 10) . '

4 l

Where'the SRs discussed.herein specify voltage and frequency

tolerances, the minimumiand maximum steady state output
- i voltages of 3870 V and 4580 V respectively, are equal to j

- 7% and + 10% of the nominal 4160 V output. voltage. The '

specified minimum and maximum frequencies of the DG is

58.8 Hz and 61.2 Hz, res 60 Hz nominal frequency.pectively, are equal The specified steadytostate i 2%voltage of the and frequency ranges are derived from the recommendations  ;

j given in Regulatory Guide 1.9 (Ref. 3). However, the ,

minimum voltaga was increased to ensure adequate voltage to l l INSERT operate all safety-related loads during a DBA (Ref.14).

i NEW, ATTACMD >

TEXT SR 3.8.1.1 ,

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1 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 i . 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 7 day Frequency:Js adequate since breaker position is i

not likely to change without the operator being aware of it

and because its status is displayed in the centrol room.

i SR 3.8.1.2 and SR 3.8.1.7 l

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i These SRs help to ensure the availability of the standby l

! electrical power supply to mitigate DBAs and transients and  ;

j_ maintain the unit in a safe shutdown condition.

(continuedl 4

CLINTON B 3.8-13 Revision No. 2-11

Attachment 4 .

to U 603092 LS-98-010 l , Page 3 of 5 l

INSERT for SURVEILLA.NCE REQUIREMENTS Section (Middle of Bases Page B 3.8-13)

In general, surveillances perr med for each of the required DGs are similar, with one notable l difference due to the fact that the Division 3 DG utilizes a mechanical governor, while the Division 1 and 2 DGs utilize an electronic governor. As such, the Division 1 and 2 DGs are capable of operating in both an isochronous mr.de as well as a " droop" mode for when the DGs l are paralleled to the offsite source during testing. The Division 3 DG, on the other hand, is j capable of operating only in the droop mode (thougn a droop setting of zero can be utilized).

l This difference may affect the Division 3 DGs capability to achieve rated frequency following automatic switchover from the test mode to ready-to-load operation upon receipt of a LOCA l

initiation signal (as verified per SR 3.8.1.17).

For the Division 1 and 2 DGs, DG operation is returned to the isochronous mode upon switchover such that rated speed / frequency is automatically attained. For the Division 3 DG, however, with the DG governor initially operating in the droop condition during the test mode, operator action may be required to reset the governor for ready-to-load operation at the required l frequency. This difference is acknowledged in the Bases for SR 3.8.1.17 to address compliance l with that SR. Notwithstanding, the condition also requires the Division 3 DG to be considered ,

inoperable ifit cannot be ensured that the required frequency would be attained in the event of a l LOCA and a loss of offsite pos.er concurrent with the Division 3 DG being operated or tested with the existing droop setting in effect. Thus, the Division 3 DG is generally considered inoperable while the droop setting is in effect during the performance of SRs that require the DG to be paralleled to the offsite source.

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  • Attachmmnt 4 to U-603092 AC Sources-Operating j LS-98-010 B 3.8.1 l l Page 4 of 5 l

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BASES SURVE1LLANCE SR 3.8.1.16 (cont inued)

REQUIREMENTS

.1) Unexpected operational events which cause the-- l 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 l OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.1.17 Demonstration oh he test mode override ensures that.the DG availability unde cident conditions is not compromised as the result of testin . JfnterlockstotheLOCAsensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation signal is received during operation in the test mode. Ready-to-load 1 operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13),

j Inscri new, paragraph 6.2.6(2)3 t, Insert /c.nh e d% a4Whed fext attachecl

>Therequirementtoautomaticallyenergizetheemergency l ParagrnPh loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the rewirement associated with SR 3.8.1.17.b is to show that the emergency loading is not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential,

overlapping, or total steps so that the entire connection l and loading sequence is verified.

, The 18 month Frequency is consistent with the

! recommendations of Regulatory Guide 1.108 (Ref. N, l paragraph 2.a.(8); takes into consideration plant conditions (continued) 4 CLINTO B 3.8-27 Revision No. 0

.- .~. . .. - - --- -_. - . - . - _ . -- ..~ . . . - . . - . -

m .-

Attaclunent 4

to U-603092

, LS-98-010 Page$ of 5 l

4 INSERTS for SR 3.8.1.17 l as further amplified by IEEE 387, sections 5.6.1 and 5.6.2. (Clarification regarding conformance  !

! of the Division 3 DG design to these standards is provided in the USAR, Chapter 8 (Reference I 2).)

Automatic switchover from the test mode to ready-to-load operation for the Division 3 DG is also

demonstrated, as described above, by ensuring that DG control logic automatically resets in j response to a LOCA signal during the test mode and confirming that ready-to-load operation is

'j attained (as evidenced by the DG running with the output breaker open). However, with the DG l governor initially operating in a " droop" condition during the test mode, operator action may be

required to reset the governor for ready-to-load operation in order to complete the surveillance i for the Division 3 DG. Resetting the governor ensures that the DG will supply the Division 3 bus

. at the required frequency in the event of a LOCA and a loss of offsite power while the DG is in a

+

droop condition during the test mode. l I

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