ML20198F966

Proposed Tech Specs Section 3/4.8.1, AC Sources, Clarifying EDG Fuel Oil Storage Requirements by Addition of Term Usable & Increasing EDG Largest Single Load Rejection Test Requirements

ML20198F966
Person / Time
Site:	Beaver Valley
Issue date:	12/24/1998
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20198F963	List: L-98-241, LARs 258 & 129 to Licenses DPR-66 & DPR-73,modifying TS 3/4.8.1, AC Sources for Units & Associated Bases to Clarify EDG Fuel Oil Storage Requirements by Addition of Term Usable ML20198F966
References
NUDOCS 9812280259
Download: ML20198F966 (32)

Text

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i ATTACHMENT A-1 1

Beaver Valley Power Station, Unit No. 1 l License Amendment Request No. 258 1

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l The following is a list of the affected pages:

I i Affected Pages: 3/4 8-1

! 3/4 8-4 3/4 8-4a i

3/4 8-5 B 3/4 8-1 B 3/4 8-3 l

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1 1

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! l 9812280259 981224 PDR ADOCK 05000334 P PDR

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', l DPR-66 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.a.1 A.c. Sotmcas OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and 1

b. Two separate and independent diesel generators each with:

1. Separate day and engine-mounted fuel tanks containing a minimum of 900 allons of l

2. A separate fuel storage system containing a minimum of 17,500 gallons of fuel, and CasiblD

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within l the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one diesel generator

• inoperable, demonstrate the OPERABILITY of the A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the diesel generator became inoperable due to any cause other than an independently testable component, testing or preplanned preventative maintenance, demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing oil contained in the storage tanks not meeting the (1) Fuel properties in accordance with 4.3.1.1.2.d.2 or 4.8.1.1.2.e shall be brought within the specified limits within 7 days.

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BEAVER VALLEY - UNIT 1 3/4 8-1 Amendment No.- %

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( h?.0f'OSED WOR DIt)Cy)

,J ..

• DPR-66

ELECTRICAL POWER SYSTE)tS SURVEILLANCE REQUIREMENTS (Continued) i

) 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

l a. At least once per 31 days on a STAGGERED TEST BASIS by:

i

! 1. Verifying the fuel level in the day and engine-mounted i fuel tank, l 2. Verifying the fuel level in the fuel storage tank, i

j. 3. (Deleted) i

. 4. Verifying the fuel transfer pump can be started and

{ transfers fuel from the storage system to the day and

engine-mounted tank, i

! 5. Verifying the diesel starts from standby conditions,"'

! and can be . gradually accelerated to synchronous speed I with generator voltage

• 2 4106 volts and 5 4368 volts j and frequency

• 2 58. 8 Hz and 1 61. 2 Hz ,

f 6. Verifying the generator is synchronized, loaded

• to i 2 1425 kw, and operates for 1 60 minutes, and i

7. Verifying the diesel generator is aligned to provide acandby power to the associated emergency busses.

b. At least once per 18 months during shutdown by:

1. Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service,

2. Verifying the generator capability to reject a load of 2 45+ kw without tripping a.r we'$$1ca.$ exceed (f,g y ')

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(3) The values for voltage and frequency are analysis values. These value bands shall be appropriately reduced to account for measurement uncertainties.

(4) All diesel generator starts may be followed by a warmup period prior to loading.

(5) ' Diesel. generator loadings may include gradual loading as recommended by the mant.facturerg _

resbuek 0 accon.)

D) Tl1e. tkLlut hor hegneMy Slull be affriY hoV N e M ar! ^ % $ u w eykw dier BEAVER VALLEY - UNIT 1 3f4 8-4 Amendment No. &.

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(PVOPOSCD O]o?Dsd G)

4 DPR.66 ,

ELECTRICAL POWER SYSTEMS I

j SURVEILIANCE REQUIREMENTS (Continued) 2 ,

i i 3. Simulating a loss of offsite power in conjunction with

, a safety injection signal, and:

4 .

i a) Verifying de-energization of the emergency busses and load shedding from the emergency busses.

] b) Verifying the diesel starts from standby conditions l

on the auto-start signal, energizes the emergency busses with permanently connected loads in 5 10 j seconds, energizes the auto-connected emergency a loads through the load sequencer and ' operates for l 1 5 minutes while its generator is loaded with the i emergency loads. After energization of these loads,

.the steady state voltage'" and frequency'" shall be j maintained at 1 4106 volts and 5 4368 volts, and j 148 + Hz and 5 44,4- Hz .

! 4. Verifying that on a oss of power to the emergency l busses, all diesel generator trips, except engine i overspeed, generator differential and overcurrent, are

( automatically disabled,

! 5. Verifying the diesel generator operates for 2 60 minutes

, while loaded to 2 2750 kw,

6. Verifying that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 2850 kw, j and

7. Verifying that the automatic load sequence timer is i OPERABLE with each load sequence time within i 10% of its j required value.

f c. Check for and remove accumulated water:

4

1. From the day tank, at least once per 31 days and after

each operation of the diesel where the period of operation was greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and

{

! 2. From the fuel oil storage tank, at least once per 92 3 days.

i-1 The values for voltage and frequency are analysis values. These

(3) j value bands shall be appropriately reduced to account for 1 measurement uncertainties.

(6) The frequency limits apply for the diesel ganarator at full l

accident loading. An engineering evaluation of the test data at lower loads can be performed to demonstrate operability.

- BEAVER VALLEY - UNIT 1 3/4 8-4a Amendment No.-IZ (PPoPomp wogofd

= _ _ _ _ _ . _ . . _ _ _ _ _ _ _ . . . _ . . _ . _ _ . _ _ _ _ ~ . _ . . _ ;.

i DPR-66 i RTECTRICAL POWER SYSTEMS j .

SHUTD'OWN A

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LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources

! shall be OPERABLE:

One circuit between the of fsite transmission network and l a.

i the onsite Class 1E distribution system, and  ;

One diesel generator with: l

! b.

1. Day and engine-mounted fuel tanks containing a minimum of 900pg allons of_ fuel, j MSd/c)

2. A fuel storage system containing a minimum of 17,500 i gallons of fuel, and

Mafp)-

i 3. A fuel transfer p Mp.

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APPLICABILITY: MODES 5 and 6, AND During movement of irradiated fuel l i with no fuel assemblies in the reactor vessel, and l 4

[ During movement of loads over irradiated fuel with no fuel assemblies in the reactor vessel, i

4

) ACTION:

Wi*h less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE i ALTERATIONS, positive reactivity changes, movement of irradiated.

4 fuel, and movement of loads over irradiated fuel until the minimum j required A.C. electrical power sources are restored to OPERABLE status.

l SURVEILLANCE REQUIREMENTS 1 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement j,

4.8.1.1.2.a.6.

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- BEAVER VALLEY - UNIT 1 3/4 8-5 Amendment No. 4+F-

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(Pilof'osED wogpIOG)

1 DPR-66 4 3/4.8 ELECTRICAL POWER SYSTEMS j BASES i 3/4.8.1, 3/4.8.2 A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS

') The OPERABILITY of the A.C. and D.C. power sources and associated 3

distribution systems during operation ensures that sufficient power i j will be available to supply the safety related equipment required for i i 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility. The minimum

specified independent and redundant A.C. and D.C. power sources and l distribution systems satisfy the requirements of General Design l

{

1 Criterion 17 of Appendix "A" to 10 CFR 50.

i l The ACTION requirements specified for the levels of degradation ,

i of the power sources provide restriction upon continued facility '

l operation commensurate with the level of degradation. The l

OPERABILITY of the power sources are consistant with the initial condition assumptions of the safety analyses and are based upon maintaining t'. least one redundant set of onsite A.C. and D.C. power i i sources and i sociated distribution systems OPERABLE during accident 1 conditions tncident with an assumed loss of offsite power and j single failu.a of the other onsite A.C. source.

l The ACTIvN requirements specified in MODES 5 and 6 address the i condition where sufficient power is unavailable to recover from 1 postulated events (i.e. fuel handling accident). Implementation of the ACTION requirements shall not preclude completion of actions to I establish a safe conservative plant condition. Completion of the requirements will prevent the occurrence of postulated events for

,! which mitigating actions would be required.

The OPERABILITY of the minimum specified A.C. and D.C. power i sources and associated distribution systems during shutdown and i refueling ensures that 1) the facility can be maintained in the

! shutdown or refueling condition for extended time periods, 2)

! sufficient instrumentation and control capability is available for l monitoring and maintaining the unit status, and 3) sufficient power is available for systems (i.e. Supplemental Leak Collection and j Release System) necessary to recover from postulated events in these

! MODES, e.g. a fuel handling accident.

pg "I " The Surveillance Requirement for demonstrating the OPERABILITY of

I the station batteries are based on the recommendations of Regulatory j Guide 1.129, " Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating l Stations and substations."

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B 3/4 8-1 Amendment No. I BEAVER VALLEY - UNIT 1 ^ '

(PPoPosso worbuxd

Attachm2nt A-1 Bsavar Valley Powar Station, Unit No. 1 License Amendment Reauest No. 258 I SERT'1 In Modes 1 through 4, the specified quantity of 17,500 usable gallons required in each storage tank (35,000 total gallons) ensures a sufficient volume of fuel oil that, when added to the specified 900 usable gallon volume in the day and engine-mounted tanks, provides the fuel oil necessary to support a minimum of 7 days continuous operation of one diesel generator at full load (UFSAR Sections 8.5.2 and 9.14). The total volume in each of the tanks is greater due to the tank's physical characteristics.

In Modes 1 through 4, the specified fuel oil volumes of both fuel oil storage tanks are required to ensure 7 days continuous operation of.a single diesel generator at full load. Should the quantity of fuel oil in either fuel oil storage tank or either day and engine-mounted tank fall below the amount required in the technical specifications the technical specification Action Statement for the associated diesel generator is applicable and provides adequate assurance that fuel oil is restored to within the required limit (s) in a timely manner.

In Modes 5 and 6, a single diesel generator with 900 usable gallons of fuel oil in the day and engine-mounted tank and a single fuel oil storage tank with 17,500 usable gallons are required operable. These requirements ensure the capability to support the systems required during a loss of offsite power when the plant is in a cold shutdown or refueling condition, i

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l DPR*66 ELECTRICAL POWER SYSTEMS BASES A.C. SOURCES. D.C. SOYMCES AND ONSITE POWER DISTRTRUTION SYSTEMS (Continued)

Footnote (6) permits an engineering evaluation to be performed if the frequency limits of SR 4. 8.1.1. 2.b.3.b are not met. The frequency limits prescribed in SR 4.8.1.1.2.b.3.b are based on full load conditions. Since SR 4.8.1.1.2.b.3.b is normally performed at less than full loading conditions, the resultant generator frequency may exceed the required frequency value range due to the design of the diesel generator governor, especially during lower loading. Under these conditions, it is acceptable to examine the frequency responsa vs. loading and by an engineering evaluation, determine that the governor is responding properly and would fall within the required frequency band while at full accident loading. The engineering evaluation consists of comparing previous voltage, frequency and power plots with the current plots of these same parameters. By comparing the above data, proper governor response can be verified. Based on governor response and the current governor droop setting, frequency value obtained during performance of SR 4.8.1.1.2.b.3.b,.the can be evaluated to ensure the frequency limits of SR 4.8.1.1.2.b.3.b at full accident loading would be met.

ADD ItJSER.T i.2)

BEAVER VALLEY - UNIT 1 B 3/4 8-3 Amendment No.I=

(PROPosCO WORDnWi)

Attach = nt A-1 Beaver-Valley Power Station, Unit No. 1

- License Amendment Recuest No. 258 INSERT *2 The frequency of 66.2' Hz specified in Surveillance Requirement

- 4.8.1.1.2.b.2 corresponds to 993 rpm.

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(Proposed Wording)

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ATTACHMENT A-3 4

i Beaver Valley Power Station, Unit No. 2 i

J License Amendment Request No. 129 4

1

! The following is a list of the affected pages:

Affected Pages: 3/4 8-1

3/4 8-4 1 3/4 8-5 j 3/4 8-5b i 3/4 8-6

B 3/4 8-2 i B 3/4 8-3 i

i d

NPF-73 3/4.8 ELFCTRTcAL POWER SYSTEMS 3/4.a.1 A.c. SouncES

. .r .

- OPERATINd LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPI:RABLE: ,

\

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution I system, and

b. Two separate and independent diesel generators each with: ,

1. Separate day tank containing a minimum of 350 umdQ allons of fuel, l

2. A separate fuel storage system containing a minimum of  ;

53,225 gallons '

3. A separate fuel T.ransrer pump,

4. Lubricating oil storage containing a minimum total volume  !

of 504 gallons of lubricating oil, and l

. 5. Capability to transfer lubricating oil from storage to the diesel generator unit.

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

ACTION:

a. With one offsite circuit inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one diesel generator

• inoperable, demonstrate the OPERABILITY of the A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the diesel (1) Fuel oil contained in the storage tanks not meeting the properties in accordance with 4.8.1.1.2.d.2 or 4.8.1.1.2.e shall be brought within the specified limits within 7 days.

BEAVER VALLEY - UNIT 2 3/4 8-1 Amendment No N

( pro Pon D ' w4 undo )

NPF-73 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by:

1

1. Verifying the fuel level in the day tank,

2. Verifying the fuel level in the fuel storage tank,

3. (Deleted)

4. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank, )

5. Verifying the diesel starts from standby conditions,"'  !

and achieves steady state voltage 883 of 2 3994 volts and 1 5 4368 volts and frequency of 2 50,+ Hz and 5 46-rt Hz, I

6. Verifying the . generator is synchronized, loaded

• to 2 4,239 kw, and operates for 2 60 minutes,

7. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses, and

8. Verifying the lubricating oil inventory in storage.

b. At least once per 18 months during shutdown by:

1. Subjecting the diesel to an inspection in accordance f b M [## with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby gO kf service, NY [b 2. Verifying the generator capability to reject a load of j fo 2 825 kw without tripping: _

1. ped & Y g". 3. Simulating a loss of ffsite power in conjunction with i%f excedim 69'.Y H2 asafety injection signal, and:

a) Verifying de-energization of the emergency busses and load shedding from the emergency busses.

4

-(3) The values for voltage and frequency are analysis values. These value bands shall be appropriately reduced to account for measurement uncertainties.

(4) All diesel generator starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Diesel generator loadings may include gradual loading as (5) recommended by the manufacturer.

BEAVER VALLEY'- UNIT 2 3/4 8-4 Amendment No.M M E.b w oi W II M )

NPF-73  !

ELRCTRICAL POWER SYSTEMS

, SURVEILLANCE REQUIREMENTS (Continued) b) Verifying ") the diesel starts from standby conditions on the auto-start signal, energizes the emergency busses with permanently connected loads in i s 10 seconds, energizes the auto-connected emergency loads through the load sequencer and operates for 1 5 minutes while its generator is loaded with the emergency loads. After energization of these loads, '

the steady state voltage"' and frequency"' shall be  ;

maintained at 2 3994 volts and S 4368 volts, and i 1 -68,4 Hz and 1 4tvG- z. l

57. 60.3 -

4. Verify ng that on a ss of power to the emergency  ;

busses, all diesel generator trips, except engine I overspeed, backup phase fault detection, generator differential current, and generator overexcitation are automatically disabled, )

i

5. Verifying the diesel generator operates for 1 60 minutes while loaded to 2 4,238 kw,

6. Verifying that the auto-connected loads to each diesel generator do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 4,535 kw, and

7. Verifying that the automatic load sequence timer is OPERABLE with each load sequence time within 110% of its required value.

c. Check for and remove accumulated water:

1. From the day tank, at least once per 31 days and after each operation of the diesel where the period of operation was greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and

2. From'the fuel oil storage tank, at least once per 92 days.

d. By sampling new fuel oil in accordance with ASTM D4057-81 prior to addition to the storage tanks and:

(3) The values for voltage and frequency are analysis values. These value brnds shall be appropriately reduced to account for measurement uncertainties.

(6) All diesel generator starts may be preceded bi an engine prelube period.

BEAVER VALLEY - UNIT 2 3/4 8-5 Amendment No. O (PE.oPOSEE workg) .

= .- .. - - . . . . - . - - - - .-

l NPF-73 ELFCTRICAL POWER SYSTEMS l

SURVEILLANCE REQUIREMENTS (Continued) f.' At least once per 10 years or after any modifications which I could affect diesel generator interdependence by starting l from standby conditions"8 both diesel generators l simultaneously, during shutdown, and verifying that each i diesel generator achieves, in 5 10 seconds, voltage'" 2 3994 volts and 5 4368 volts, and frequency'U 2 40 re- Hz and 5 -64,4-77 60,3

g. At least once per 10 years by draining each main fuel o l

storage tank, removing the accumulated sediment, and cleaning the tank using a sodium hypochlorite solution or other appropriate cleaning solution.

(3) The values for voltage and frequency are analysis values. These value bands shall be appropriately reduced to account for measurement uncertainties.

(6) All diesel g'enerator starts may be preceded by an engine prelube period.

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BEAVER VALLEY - UNIT 2 3/4 8-5b Amendment No.M (PRDro.sEDuxwidq) l

-7 NPF-73 ELECTRICAL POWER SYSTEMS 5HUTDOWN LIMITING CONDITION FOR OPFRATION

.=

3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and

b. One diesel generator with:

1. Day tank containing a minimum of 350Vgallons of fuel,

2. A fuel storage system containing a minimum of 53,225 '

gallons of fuel,

3. A fuel transfer pump.

APPLICABILITY: MODES 5 and 6, AND During movement of irradiated fuel with no fuel assemblies in the reactor vessel, and During movement of loads over irradiated fuel with no fuel assemblies-in the reactor vessel.

ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity c;;anges, movement of irradiated fuel, and movement of loads over irradir*ed fuel until the minimum required A.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS

-::==

4.8.1.2 The above required A.C. electrical power sources shall bc.

demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.B.1.1.2.a.6.

i BEAVER VALLEY - UNIT 2 3/4 S-6 Amendment No.t3-( PR.opoSED to$ Djt)q)

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i NPF-73 j 3/4.8 ELECTRICAL POWER SYSTEMS BASES

. 3/4.8.1, 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION j (Continued)

Appendix A to Generic Letter 84-15 and Generic Letter 83-26,

" Clarification of Surveillance Requirements for Diesel Fuel Impurity Level Tests."

j . ADD QWEET *3 The Surveillance Requirement for demonstrating the OPERABILITY of s

the Station batteries are based on the recommendations of Regulatory Guide 1.129, " Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE  !

Std a

450-1980, "IEEE Recommended Practice for Maintenance, Testing, l I 'nd Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

l verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage on float i i charge, connection resistance values and the performance of battery j

service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates and compares the battery capacity at that time with the rated capacity.

l Table 3.8-1 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage and specific gravity. The limits for the designated pilot cells float j voltage and specific gravity, greater than 2.13 volts and 0.015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adequate capacity. The normal limits for each l

connected cell for float voltage and specific gravity, greater than i

2.13 volts and not more than 0.020 below the manufacturer's full charge specific gravity with an average specific gravity of all the 4

connected cells not more than 0.010 below the manufacture a full '

charge specific gravity, ensures the OPERABILITY and capa.1 11ty of

} the battery.

Operation with a battery cell's parameter outside the normal limit i but within the allowable value specified in Table 3.8-1 is permitted for up to 7 days. During this 7 day period: (1) the allowable values i for electrolyte level ensures no physical damage to the plates with i an adequate electron transfer capability; (2) the allowable value for the-average specific gravity of all the cells, not more than 0.020 i- below the manufacturer's recommended full charge specific gravity, 6 ensures that the decrease in rating will be less than the safety margin provided in sizing; 3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific BEAVER VALLEY - UNIT 2 B 3/4 8-2 Amendment No.4F (PP o/bsED woRDips)

Attachment A-2 Beaver Valley Power Station, Unit No. 2 License Amendment Recuest No. 129 IhSERT'3 The quantity of 350 usable gallons in the day tank represents the analytical value of fuel necessary to run the diesel for at least 60 minutes at a load of 100% of continuous rating plus a minimum margin of 10% in accordance with ANSI N195 -

1976 which is referenced in Regulatory Guide 1.137 Rev. 1. The total tank volume is greater due to the tank's physical characteristics.

The quantity of 53,225 usable gallons is the analytical value required in the fuel storage tank that, when added to the 350 gallons, makes up the fuel necessary to support a minimum of 7 days continuous EDG operation at its rated load. This is in compliance with Regulatory Guide 1.137, Rev. 1. The total volume in this tank is greater due to the tank's physical characteristics.

(Proposed Wording)

l NPF-73 3/4.s EttcTRIcAL powrR systems BASES l

3/4.8.1. 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTIQR 1

(Continued)

I l gravity will not be more than 0.040 below the manufactcrer's full charge specific gravity and that the overall capability of the battery l will be maintained within an acceptable limit; and 4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, '

ensures the battery's capability to perform its design function.

Note (1) provides clarification of Specification 3.8.1.1 Action l requirements when the diesel generators are inoperable as a result of l Surveillance Requirements 4.8.1.1.2.d.2 and 4.8.1.1.2.e in accordance with' Regulatory Guide 1.137, Revision 1, Position C.2.a.

For the purposes of SR 4.8.1.1. 2. e .5, 4.8.1.1.2.b.3.b and 4.8.1.1.2.f testing, the diesel generators are started from standby conditions.

Standby conditions for a diesel generator mean that the diesel engine coolant and oil are being continuously circulated and temperatures are being maintained consistent with manufacturer recommendations'.

ZMW #

l BEAVER VALLEY - UNIT 2 B 3/4 8-3 Amendment No. 4 (PR.pPosED wacDI&i)

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AttSch00nt A-2 Ceaver Valley Power Station, Unit No. 2 License Amendment Reauest No. 129 l

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l The frequency of 64.4 Hz specified in Surveillance Requirement I 4.8.1.1.2.b.2 r;orresponds to 552 rpm.

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ATTACHMENT Te Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request No. 258 and 129 l REVISION OF SPECIFICATIONS 3.8.1.1 TITLED "A.C. SOURCES" A. DESCRIPTION OF AMENDMENT REQUEST 1

Technical assessments performed by the Beaver Valley Multidisciplinary Action Team (MDAT) during the recent extended forced outage highlighted several instances involving Emergency Diesel Generator (EDG) Technical Specifications that were less conservative than applicable design analyses and engineering assessments. The outcome of the applicable MDAT and engineering assessments are the proposed revisions contained in License Amendment Request 1A-258/2A-129.

The intent of this proposed amendment request is to ensure that EDG requirements contained in Technical Specification 3/4.8.1 for both units are consistent with assumptions contained in design analyses and requirements of plant procedures. In achieving this outcome, License Amendment Request 1A-258/2A-129 revises Technical Specification 3/4.8.1 "A.C. Sources," for both units j and their associated Bases concerning the EDG. Revisions l contained in this amendment provide more conservative limiting conditions for operation (LCO) and surveillance requirements that affect EDG fuel oil storage volume, EDG load rejection and overspeed testing, and EDG operating frequency requirements. The applicable bases for each unit were also refined, as necessary, to strengthen the explanations regarding EDG fuel oil storage systems and provide the EDG overspeed in terms of Hertz and RPM.

The revisions contained in the proposed license amendment are categorized and described as follows:

EDG Fuel Oil Storace Volume Regarding EDG fuel oil storage volume, Limiting Condition For Operation (LCOs) 3.8.1.1.b and 3.8.1.2.b have been clarified by adding the term " usable" to describe minimum fuel oil storage volume requirements in existing storage, engine-mounted (Unit 1) and day tanks. Bases 3/4.8.1 and 3/4.8.2 have been revised to more accurately define the usable volume associated with diesel fuel oil storage requirements. The term " usable" is synonymous with the term " deliverable" used in NUREG 1431, provided Technical Specification acceptability criteria such as fuel oil viscosity, water content, etc. are met.

EDG Sinale Larcest Load Reiection and Overspeed Verification Durina Surveillance Testina Surveillance Requirement (SR) 4.8.1.1.2 for the operating parameters and conditions specific to each unit was changed:

SR 4.8.1.1.2.b.2 for both Units was changed. Unit No. 1 load rejection value has been changed to "2 615 kW without tripping

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e i ATTACHMENT B, continund Licance Amandmant Request Non. 258 and 129 Page 2

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j and without exceeding 66.2 Hz" from "A 450 kW without tripping";

l Unit No. 2's surveillance was revised to "2 825 kW without tripping and without exceeding 64.4 Hz" from "2 825 kW without tripping". The Bases for both Units were revised to show l overspeed value in terms of RPMs and Hz. The revised load

! rejection value makes Beaver Valley Unit 1 (BV-1) Technical Specifications consistent with existing design analyses.

Revision to the Bases was a clarification.

A footnote was added to both Units' SR 4.8.1.1.2.b.2 stating that the value for frequency shall be appropriately reduced to account for measurement uncertainties. This footnote is intended as a l clarification.

l EDG Frecuency Rance Reauirements for Operatina and Surveillance Conditions SR 4.8.1.1.2.a.5 was revised for Unit 2 only. For Unit 2, the frequency range was changed from the range of "2 58.8 Hz and 5 61.2 Hz to "2 59.9 Hz and 5 60.3 Hz. The justification for this change is presented in Item C, " Justification".

l In SR 4.8.1.1.2.a.5, the frequency range for Unit i remained unchanged. Justification for this is contained in Item C,

" Justification."

l Surveillance 4.8.1.1.2.b.3.b was changed for both Units. For l

Unit No. 1 tN present frequency range was changed, from "2 58.8 Hz and 5 61.2 Hz", to require surveillance testing at a frequency

" 2 60.0 Hz and 5 60.6 Hz." For-Unit 2, the frequency range was changed from the range of "2 58.8 Hz and s 61.2 to "2 59.9 Hz and l 5 60.3 Hz." Surveillance 4.8.1.1.2.f (Unit 2 only) was also

! revised to reflect the range of "2 59.9 Hz and s 60.3 Hz."

Revising the frequency range will ensure that the EDG operates in a narrower frequency band for both Units and minimize the l potential for pump run out and operating motors in an unanalyzed condition. It will also prevent the EDG loading from exceeding the analyzed full load value.

B. DESIGN BASES l

Backaround EDG Desian Information Unit Nos. 1 and 2 have two sets of EDGs fully dedicated to each unit, with one EDG assigned to each of the redundant electrical power divisions of each unit. With the exception of the specific station blackout breaker alignment, there is no sharing of EDGs between the units.

1 Each unit's design provides for sufficient power from one diesel to one electrical division of each plant to supply required safe i shutdown loads or accident loads, to assure the successful B-2 1

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ATTACHMENT B, continutd License Amendment Request Nos. 258 and 129 Page 3 completion of the EDG's safety function in the event of a loss of offsite power (LOOP).

4 The Unit No. 1 emergency power system is designed in accordance with IEEE Std. 308-1971 and is in accordance with AEC Safety Guide 6 and 1971 General Design Criteria (GDC) 17 and 18 and the intent of Safety Guide 9, as noted in Unit No. 1 UFSAR Section 8.5.1). Unit No. 2 diesel generators were designed and procured to the guidance of Regulatory Guide 1.9, Rev. 0 (March 1971) and IEEE Standard 387-1972 (revision status at time of l design / procurement); however, the Class 1E diesel generators were manufactured to IEEE Standard 387-1977, with clarifications to environmental / seismic qualification methods and manufacturer's performance of 2-hour short-time /22-hour continuous rating test (which was performed on site), as noted in Unit No. 2 UFSAR Section 1.8.

The EDGs at Unit No. 1 vere manufactured by General Motors Electro-Motive Division, and the Unit No. 2 EDGs were manufactured by Fairbanks Morse Engine Division of Colt Industries. Differences exist in each unit's EDG design specification, configuration, and operation (consistent with previously docketed licensing commitments / descriptions). Notable differences which are relevant to this amendment request include:

Emeraency Diesel Generator Fuel Oil System This system is required to supply fuel oil to the emergency

. diesel generator day tanks for proper operation of the emergency

- diesel generators. The emergency diesel generator fuel oil system is divided into two separate redundant mechanical and electrical trains. This dual train concept provides sufficient redundancy that will prevent failure of an active or passive component from impairing the system's capability to supply fuel oil to at least one of the diesel engines.

i' Unit 1 has two diesel generator fuel oil storage tanks, located underground, each with a storage capacity of 20,000 gallons.

These tanks are built and stamped to ASME Section VIII Code. The capacity of both tanks is adequate for more than seven days rated load operation of one diesel generator. Each tank has approximately four days capacity.

For Unit 2, each fuel oil storage tank has a capacity of approximately 58,000 gallons. A day tank is included with each diesel, with a capacity of 1,100 gallons. Each diesel generator fuel oil storage tank has two full capacity transfer pumps that i are operated automatically at preset level points in the corresponding day tank. The volume of a storage tank is capable of providing seven days of operation for one EDG at rated load.

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, ATTACHMENT B, continusd

. Licnnte Amsndment Rsqusst Nos. 258 cnd 129 Page 4 The quantity of fuel for the Unit i day / engine-mounted tank differs from that of the Unit 2 day tank due to differences in

, design and fuel consumption rates.

EDG Governor / Controls Unit 1 EDGs utilize Woodward Model UG-8 mechanical governors, which have a configuration characteristic in which engine speed and generator frequency are not constant with load. The l operating speed drops from a preset "no-load" value at the high l speed stop setting to a value at " full-load" which is dependent on the droop setting. This ' droop mode' of operation is an operating characteristic of the governor configuration. The high i speed stop setting is set by the manufacturer and not adjusted

, onsite. The droop setting can be adjusted onsite, but is interactive with the high speed stop setting.

Unit 2 EDGs use a Woodward electronic / mechanical governor, Model EGB-50C. The governor operates in both " droop" and "isochronous" modes. When paralleled with the grid, the EDGs operate in the

" droop" mode. When operating isolated from the offsite power system, the EDGs operate in the isochronous mode. EDG engines maintain a constant engine speed and frequency with changes in load.

C. JUSTIFICATION EDG Fuel Oil Storace Volure: LCOs 3.8.1.1, 3.8.1.2; Bases 3/4.8.1, 3/4.8.2 4

A Condition Report (CR) identified that non-conservative wording I was used in describing the volume of emergency diesel fuel oil I

, contained in LCO 3.8.1.1 for Unit 2. It noted that LCO 3.8.1.1 did not present the number of gallons given in this Specification l as " usable" volume. The CR noted further that LCO 3. 8.1.1 was "

non-conservative with respect to the design basis analysis which identified fuel oil volume as usable fuel. While additional evaluation of this issue determined that non-conforming conditions did not exist, it was essential to assure that a non-conservative interpretation was not utilized for this Specification. A revision to include the word " usable" in the applicable LCOs was made for both units, as it was later determined that this problem also existed for Unit 1.

Revising LCOs 3.8.1.1 and 3. 8.1. 2 for both Units to include the term " usable" in reference to the number of gallons of fuel oil is an essential measure to prevent a possible misinterpretation.

i Further, revising the Bases for each Unit to give additional l background information regarding fuel oil values enhances the

understanding of each LCO. Ultimately, these changes will assure l that required fuel oil volumes will always be present to complete the EDG safety-related operation during its required operating duration.

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ATTACHMENT B, continued Licance Amandasnt Raquast Non. 258 and 129 Page 5 l

Based on findings in the Unit 2 Condition Report and the l engineering analysis of Unit 2 EDG fuel oil volumes, LCOs 3.8.1.1 and 3.8.1.2 for both Units were revised to include more conservative wording regarding EDG fuel oil volumes.

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BV-1 and BV-2 EDG Sinale Laraest Load Reiection and Oversueed Verification SR 4.8.1.1.2.b.2 A Unit 1 Problem Report (PR) identified that SR 4.8.1.1.2.b.2 was non-conservative. In response to this PR, an engineering '

evaluation identified a more conservative single largest load

! rejection value. Criteria for largest single load (or the kW

! load to be rejected) was revised and based on the brake l horsepower value for a high head safety injection (HHSI) pump l l

operating at a frequency of 61 Hz. This resulted in a load of 612 kW on an EDG. The 612 kW value was increased to 615 kW for added conservatism. The last performances (fall 1997) of the load rejection test verified that 2 700 kW was rejected for each diesel. Criteria for maximum speed that should not be exceeded l after load rejection is also provided. The proposed revision to

! SR 4.8.1.1.2.b.2 will require a load of 2 615 kW without tripping.

For Unit 1, Safety Guide 9 provided criteria for maximum speed that should not be exceeded after load rejection. It specified that "During recovery from transients caused by step load l

increases or resulting from the disconnection of the largest single load, the speed of the EDG should not exceed 75 percent of l the difference between nominal speed and the overspeed trip l setpoint or 115 percent of nominal, whichsver is lower." Given a nominal speed of 900 rpm and the lowest allowable setting for the overspeed trip setpoint of 1025 rpm, the maximum EDG overspeed l value for the Unit No. 1 Technical Specification SR was calculated as follows: (900 + (0.75)(1025-900)) or 993 rpm.

l This relater :o a maximum frequency value of (993 rpm)(60 Hz/900 rpm) or 66. Hz. In this case, 66.2 Hz was the lower value.

Addition of this overspeed criteria makes the SR consistent with Safety Guide 9.

I For Unit No. 2, the existing SR 4.8.1.1.2.b.2 verified that EDGs had the capability to reject the largest single load (specified l as 2 825 kW) without tripping. Regarding EDG operating frequency requirements, Unit No. 2 UFSAR Section 8.3.1.1.15 states that EDG unit speed will not exceed 109 percent of rated speed for all load rejection conditions. The license unendment request would

require that EDGs have the capability to reject the largest

single load (of 2 825 kW) without exceeding a maximum speed (or frequency) that is based on a percentage of the EDG overspeed

trip setpoint. In accordance with Regulatory Guide 1.9, Rev. 2, given s nominal EDG speed of 514 rpm and the lowest allowable B-5

ATTACHMENT B, continund Licenza Amsndmant R quest Nos. 258 cnd 129 Page 6 overspeed trip setpoint of 565 rpm, a maximum speed which should not be exceeded after load rejection has been calculated as (514

+ (0.75)(565-514)] or 552 rpm. This relates to a maximum frequency of (552 rpm) (60 Hz/514 rpm) or 64.4 Hz. This maximum speed of 552 rpm equates to 107.4 percent of rated speed. The addition of the EDG overspeed acceptance criteria for Unit 2 is consistent with the UFSAR and RG 1.9 guidance.

This license amendment request provides a more conservative EDG load rejection value for SR 4.8.1.1.2.b.2 for Unit 1 and adds EDG speed related criteria to this SR for both Units. The proposed Technical Specification revisions will ensure that SR 4.8.1.1.2.b.2 for both Units is conducted using conservative load rejection and EDG overspeed criteria. A footnote was added for each Unit to indicate that EDG frequency would be reduced to account for measurement uncertainties. This clarification was necessary to show that overspeed values must be adjusted for instrument uncertainties.

Administrative controls are in place for both Units to maintain the design analysis requirements. Surveillance procedures will ,

be revised to incorporate the revisions proposed in this license amendment request.

BV-1 EDG Operatina Frecuency SR 4.8.1.1.2.b.3.b A Condition Rep 3rt identified a discrepancy between the EDG frequency limit required by the Technical Specifications and an engineering analy sis assumption for high head safety injection (HHSI) pumps during safety injection. Analyses were performed to evaluate the adequacy of the HHSI pumps when the EDG is lightly loaded. HHSI pumps were evaluated for mitigating a DBA, with loss of offsite power (LOOP), operating at 61 Hz. The outcome of the engineering analysis and the CR is that the frequency range in SR 4.8.1.1.2.b.3.b was revised to 2: 60.0 Hz and 5 60.6 Hz.

This action eliminated the discrepancy and made the Technical Specifications more conservative.

In addition to the above discrepancy, an evaluation concerning the variation of EDG operating frequency showed that the maximum calculated EDG load exceeded the UFSAR limit of 2,745 kW. The 2,745 kW value was based on the guidance of Safety Guide 9 and represents 90% of the 30 minute EDG rating; the EDG loading for mitigation of a design basis accident (DBA). This maximum loading value was calculated for the DBA loss of coolant accident (LOCA) scenario with a LOOP as 2,791.51 kW (at 60.6 Hz), which remained below the EDG 2000-hour rating of 2,850 kW as stated in Surveillance Requirement 4.8.1.1.2.b.6. This loading value was analyzed to exist only during Quench Spray Pump operation (i.e.,

approximately one to two hours, based upon pump stoppage once the j refueling water storage tank is emptied).

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ATTACHMENT B, continutd Licanze Amsndm2nt Request Nos. 258 and 129 Page 7 l

The BV-1 EDG governor is configured such that the resulting i generator speed is not constant but - varies with load. The l operating speed drops from a preset "no load" value at the high '

speed stop settirg to a value at " full load" which is dependent on the droop setting. This " droop mode" of operation is an operating characteristic of the governor configuration. The high speed stop setting is set by the manufacturer and not adjusted onsite. The droop setting can be adjusted onsite, but is interactive with the high speed stop setting.

The maximum calculated diesel loading value of 2,791.51 kW which exceeds the UFSAR limit of 2,745 kW is a temporary limit permitted by a Basis for Continued Operation (BCO) that is based on an engineering analysis. Modifications are planned including the implementation of any necessary administrative controls that will return the maximum loading value to below the UFSAR limit of j 2,745 kW. The maximum calculated value has been found acceptable '

for use for one cycle of operation. The plant is currently in i operating Cycle Number Thirteen. Modification activities will be completed prior to plant restart from the 13th refueling outage.

SR 4.8.1.1.2.a.5 The frequency range specified in SR 4.8.1.1.2.a.5 was unchanged, given the current configuration of the EDG governor control system. The manual control is used to adjust EDG frequency f rom idle to synchronous speed during -this surveillance. Without modification, the current governor control system will not automatically adjust to achieve this frequency range. The current control scheme allows for idle starts of the engine which reduces the stresses on the turbocharger gear drive train.

Therefore, the narrower frequency range was determined not appropriate for the monthly test.

In performing Surveillance 4.8.1.1.2.a.5, the EDJs are not operated in isochronous mode. The engine speed is manually increased from IDLE to 900 rpm (synchronous speed). At 900 rpm, the EDG is synchronized with the grid. Once synchronized with the grid, loading and unloading an EDG will not result in a frequency change.

Performance of SR 4.8.1.1.2.a.5 is intended to demonstrate the EDG's starting and loading capacity. This surveillance also demonstrates that EDGs can be brought to synchronous speed. The monthly test was not intended to simulate " fast start" or emergency operations conditions. Fast start capability is demonstrated in SR 4.8.1.1.2.b.3.b.

Finally, the Unit 1 EDG governor was evaluated for the present frequency band (i.e., 60.0 to 60.6 Hz) and was found to be capable of loading the anticipated loads while maintaining the frequency within the required band. The ability to operate B-7

ATTACHMENT B, continuzd Licznza Ausnd:snt R quest Nos. 258 and 129 Page 8 w'ithin the narrower frequency band is demonstrated in SR 4.8.1.1.2.L.3.b which is the 18 month surveillance that verifies automatic control under simulated accident conditions.

For these reasons, the frequency range for SR 4.8.1.1.2.a.5 was not revised.

BV-2 EDG Ooeratina Frecuency SR 4.8.1.1.2.a.5. 4.8.1.1.2.b.3.b. 4.8.1.1.2.f An evaluation of BV-2 frequency limits was performed resulting from the previously mentioned Unit 1 Condition Report.

Unlike the BV-1 EDGs where the engine speed and frequency varied with load, the BV-2 EDGs essentially maintain a constant speed and frequency with changes in load except for the short period of time when a load is added or shedded.

Because of the inherent deadband of the motor-operated potentiometer (MOP), which automatically adjusts the EDG speed and frequency setting when operating.in the isochronous mode, the frequency can vary from the nominal value of 60 Hz. If the frequency is below the setpoint, the MOP responds to automatically raise the setting and the cam-operated limit switch will open stopping the potentiometer when the " increasing" limit is reached. If the frequency is above the setpoint, the MOP responds to decrease the frequency until it reaches the setpoint.

Because of the deadband associated with limit switches, frequency settings are slightly different when resetting to the nominal

> 60 Hz from above or below 60 Hz. The frequency setting will e reset automatically on either an emergency start or shutdown of the EDG if outside the limits. When the EDG is shut down after performance of a surveillance test, it is shut down at a frequency higher than 60.1 Hz to assure the operating frequency stops at the MOP upper limit switch deadband.

An engineering evaluation for Unit 2 determined that within the frequency limits of 2: 59.9 Hz and s 60.3 Hz, there was no effect on system or component operation. This narrower frequency range is proposed as a revision to Surveillance Requirements 4.8.1.1.2.a.5, 4.8.1.1.2.b.3.b, and 4.8.1.1.2.f. This narrower frequency limit reduces the potential for operating ESF equipment at increased pressures and flows beyond evaluated conditions.

Administrative controls established for EDG surveillance tests verified the operating frequency of the EDG units following automatic sequence loading of equipment.

D. SAFETY ANALYSIS The A.C. electrical power sources are desigand to provide sufficient capacity, capability, redundancy, and reliability to B-8

1 ATTACHMENT B, continusd l License Amandasnt Rsqusst Nos. 258 and 129 Page 9 l e'nsure the availability of power to engineared safety feature 9

(ESF) systems so that the fuel, reactor coolant system, and i containment design limits are not exceeded. The proposed TS

, changes will continue to assure that the alternate A.C.

electrical power sources will perform as designed. The margin of i safety derived from the requirements of Technical Specification  ;

j 3/4.8.1 will not be significantly reduced as a result of the 1

revisions contained in the proposed amendment. EDG operating i

frequency ranges were narrowed to ensure ESF components would 1 perform as anticipated in the event of a DBA. Though the )

j temporary Unit 1 EDG loading limit of 2791.51 exceeds the Safety I i Guide 9 value of 2745, it still is below the EDG 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating j limit of 2850 kW contained in Surveillance Requirement i

4.8.1.1.2.b.6. Further, the loading value of 2791.51 kW does not j exceed the design loading capability of the EDG. EDG load j rejection values for Unit 1 were revised to conform with 1

engineering analyses, overspeed criteria were added for both l j units to ensure compliance with Regulatory Guide 1.9. The word 1 i " usable" was added in the limiting conditions for operation (LCO)  !

i for both Units to clarify fuel oil storage requirements. I

Further, an explanation of fuel oil storage requirements provided I

in the bases substantiates operations criteria contained in the l i LCOs. Therefore, EDG capacity, capability, redundancy, and '

l reliability are not affected by these proposed revisions. These j revisions will serve to assure that EDGs perform in a manner consistent with safety analysis assumptions. The proposed changes in this license amendment request are more conservative i and do not affect the design bases of the plant. Therefore, this change will not adversely affect the safety of the plant.

5 E. NO SIGNIFICANT HAZARDS EVALUATION 4

The no significant hazard considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92 (c) as quoted below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

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Licanza Amsndmant Raqusst Non. 258 and 129 l Page 10 k . l l T'he following evaluation is provided for the no significant )

. hazards consideration standards.

1 l 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

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I i The addition of the term " usable" to LCO 3.8.1.1 and 3.8.1.2 l

! for both Units will assure that the required quantity of fuel j oil will be available to operate the diesel during emergency

conditions. This revision including the discussion contained l in the Technical Specification Bases has no physical impact on the diesels or their setpoints. These revisions also do not delete any function previously provided by the diesels.

There are no design bases accidents for which failure of the diesel is considered an initiating event. Therefore, the

} probability of an accident previously evaluated in the safety

] nnalysis is not increased by this change. The proposed i changes do not involve an increase in the consequences of an accident previously analyzed, as they make the limiting

! condition for operation and associated bases more j conservative and involve no physical changes to the diesels.

! The revised EDG single largest load rejection and overspeed criteria do not involve an increase in the probability or the j consequences of accidents previously analyzed. The surveillance tests impacted by the proposed revision are performed only during shutdown when the opposite train EDG 1 and its connected AC power system are relied upon as the emergency AC power source. Further, there are no design j basis accidents for which changes to EDG load rejection test 4 acceptance criteria can be an initiating event. The proposed

! changes affect the diesel testing requirements but do not affect the operating or design parameters. The changes also i do not affect the diesels' ability to mitigate the  ;

consequences of an accident. They serve to ensure the ability of the diesel to reject the largest load. The overspeed criteria ensures that diesel frequency does not exceed a certain value subsequent to a load rejection. This criteria also ensures compliance with the guidance of Safety Guide 9 for Unit 1 and Regulatory Guide 1.9 for Unit 2. It does not involve an increase in the consequences of an accident previously analyzed. The revision does not impact accidents previously analyzed and would not, therefore, affect the consequences of accidents previously analyzed.

Revising the EDG operating frequency as discussed in the proposed amendment protects ESF pumps from runout conditions and motors from operating in an unanalyzed ' condition. The narrower frequency limits are more restrictive and have no adverse effect on the diesel generator operability. The proposed revision to decrease the EDG operating frequency limit does not involve an increase in the probability of an B-10

ATTACHNENT B, continuad Licants A22ndaant Rsquest Nos. 258 and 129 Page 11 accident as described in the UFSAR. There are no design basis accidents for which failure of the diesel is considered an initiating event. A narrower operating frequency does not increase the probability of a design basis accident; it ensures that equipment perform their intended function. This change is intended to prevent the diesel from being loaded

, beyond analyzed loading limits and protect ESF equipment. I l The more conservative surveillance requirements being applied to operating limits will provide greater assurance that the diesels will be operable and that greater performance requirements are not imposed on ESF equipment. This change, therefore, will not result in an increase in the consequences of an accident previously described.

2. Does the change create the possibility of a new or different l kind of accident from any accident previously evaluated?

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!. The proposed revisions do not create the possibility of a new l or different kind of accident from any accident previously i evaluated. They also will have no adverse impact on the l design basic accidents previously evaluated in the UFSAR.

l The revisions contained in the proposed amendment are more i restrictive to assure that diesel and ESF equipment are available.and fully operable to perform their intended safety function following a design basis accident and a loss of offsite power. The proposed changes do not involve physical changes to plant equipment or the AC power system configuration. New failure modes are not introduced as a l result of the proposed revisions. A revision of the diesel

( frequency will prevent motors and pumps from being subjected to over-frequency conditions which could reduce the life of j the equipment. Increasing the load rejection criteria for l

Unit 1 and including overspeed criteria for both units i revises surveillance test criteria for verifying load rejection capability. This does not affect the probability of malfunction of a diesel or its connected emergency AC power system. Further, it does nct create a new failure mode. Revising diesel fuel oil storage requirements to include the term " usable" reduces the potential for misinterpretation of this specification; it does not create a new kind of accident from any accident previously evaluated.

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The revisions contained in this license amendment have the effect of making the BVPS Technical Specifications more conservative than previously. This license amendment request will not create the possibility of a new or different kind of accident from any accident previously evaluated.

1 3. Does the change involve a significant reduction in a margin i of safety?

The margin of safety is not reduced as a result of the proposed revisions. The margin of safety depends on the B-11

ATTACHMENT B, continusd Licansa Amsndmant Request Nos. 258 and 129 l Page 12 l .

! maintenance of specific operating parameters within design limits. The margin of safety derived from limiting condition for operation 3.8.1.1 and 3.8.1.2 for both Units is enhanced I by adding " usable" in these requirements. This revision reduces the possibility of misinterpreting Technical

Specification requirements. The addition of diesel overspeed criteria (both units) and increasing load rejection criteria I for Unit 1 does not reduce the margin of safety. Diesel l reliability and performance during a loss of offsite power L

and a design basis accident are enhanced by this more l conservative surveillance test requirement. Revision _of diesel operating frequency limits protects engineered safety features equipment from overfrequency conditions; this would not be a significant reduction in the margin of safety.

Though the temporary Unit 1 EDG loading limit of 2791.51 exceeds the Safety Guide 9 value of 2745, it still is below I the EDG 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating limit of 2850 kW contained in Surveillance Requirement 4.8.1.1.2.b.6. Further, the loading i value of 2791.51 kW does not exceed the design loading i capability of the EDG. Based en engineering analyses, the )

revisions contained in the proposed amendment will not  ;

significantly reduce the margin of safety. Engineered safety  !

l features equipment will continue to function, as assumed in the safety analysis, to ensure that fuel, reactor coolant i system and containment design limits are not exceeded.

Therefore, this change will not involve a significant reduction in a mar.;in of safety due to the continued availability and reliability of the A.C. electrical power sources.

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that the activities associated with this license amendment request satisfy the requirements of 10 CFR 50.92 (c) and, accordingly, a no significant hazards consideration finding is justified.

G. ENVIRONMENTAL CONSIDERATION This license amendment request changes a requirement with respect to the installation or use of a facility component located within the restricted-area as defined in 10 CFR Part 20. It has been determined that this license amendment request involves no significant increase in the amounts, and no significant change m the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational. radiation exposure. This license amendment request may change requirements with respect to installation or use of a facility component located within the restricted area or change an inspection or surveillance requirement; however, the category of this licensing action does not individually or cumulatively have.a significant effect on the human environment. Accordingly, B-12

I ATTACHMENT B, continugd Licnngo Am:nd2Ont R:qusct Nos. 258 and 129 l Page 13 I l

l this license amendment request meets the eligibility criteria for )

categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this license amendment request.

H. UFSAR CHANGES No UFSAR changes are required.

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