ML20199A413

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Proposed Tech Specs Adding Conditions for DG for Extended DG Completion Time of Fourteen Days
ML20199A413
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 01/22/1998
From:
SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20199A407 List:
References
NUDOCS 9801270210
Download: ML20199A413 (48)


Text

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Enclosure 5 Vogtle Electric Generating Plant Request to Revise Technical Specifications,"AC Sources - Operating" Emergency Diesel Generator Extended AOT Request Hand - Marked Pages l

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t AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME-A. (continued) A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from feature (s) with no discovery of no offsite power offsite power to available it. operable one train when its redundant concurrent with required feature (s) inoperability of is inoperable. redundant required feature (s)

A.3 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> offsite circuit to OPERABLE status. 3 51 ys from

  1. discovery of failure to meet LCO (continued)

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Vogtle Units 1 and 2 3.8-2 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

5.

AC Sources - Operating g 382 L/NSB27 f FOR Co/uo/noA) @

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the required offsite circuit (s). Al(Q t w" Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AtID Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from B.[3 feature (s) supported by the inoperable DG discovery of Condition B inoperable when its concurrent with required redundant inoperability of feature (s) is redundant inoperable, required feature (s)

Atin B. 1 Determine OPERABLE DG 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not inoperable due to comon cause failure.

QB B./.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 4 for OPERABLE DG, 4

/^l54472) ,AtID Restore DG to -7 '::=

B./ .

COM O/7/dN g OPERABLE status.

L 6 e<M m J /daysfrom discovery of failure to meet LCO (continued)

Vogtle Units 1 and 2 3.8-3 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

IN S E RT 2 FOR CONDI TION 5

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e AC sources - Operating g36(7 Mbn/ C0Ald17/0A/C - - - - - -- d 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

/. Two requirdd offsite circuits inoperable.

/.l. Declare required feature (s) inoperable 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery p p when its redundant Condition required f;ature(s) concurrent with is inoperable. inoperability of redu ',snt requised features AtiD

/.2 Restore one required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> n offsite circuit to

  1. OPERABLE status.

/. One required offsite ------ l--- NOT E-----------

circuit inoperable. Enter at licable Conditions

- h and Requ~ red Actions of 6E LCO 3.8.', " Distribution Systems O erating," when One DG inoperable. Condition is entered with

- no AC power source to one or more trains.

/.1 Restore required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

{ offsite circuit to OPERABLE statur.

E

/.2 Restore DG to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OPERABLE status.

g

. Two DGs inoperable. Restore one DG to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

[.1 OPEPABLE status.

F F (continued)

Vogtle Units 1 and 2 3.B-4 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

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f AC Sources - Operating l 3.8.1 ACTIONS (continued)

REQUIRED ACTION COMPLETION TIME CONDITION

[ Onesequencer automatic load [1 Restore autcmatic load sequencor to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> g inoperable. g OPERABLE status.

/.

g equired Action and associated Completion

.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of Conditi A. AND i C, D, E,a or et

/.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

t. i,p g

" .4 Innediately

/. Three or more required AC sources inoperable,

[1 Enter LCO 3.0.3.

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OR

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Vogtle Units 1 and 2 3.8-5 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

Programs and Manuals i 5.5 S.5 Programs and Manuals -

5.5.17 Containment teakaoe' Rate Testino Prooram (continued)

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

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-IN S EILT NLvd 5. 5. I B Conf /ravig pcm eo, c utz mgj dis K Man.3* e r 4

Vogtle Units 1 and 2 5.0-27 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

)

5.5.18 Con 6guration Risk Management Profum The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk informed allowed outage time has been granted. The program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at power intemal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.
b. Provisions for performing an assessment prior to entering the LCO Action Statement for preplanned activities,
c. Provisions for perfomling an assessment after entering the LCO Action Statement for unplanned entry into the LCO Action Statement.
d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action Statement.
e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

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AC Sources - Operating B 3.8.1 BASES LCO train. For the DGs, separation and independence are (continueo, complete.

Fur the offsite AC sources, separation and independence are to the extent practical. A circuit may f>e connected to more than one ESF bus while the bus is being transferred to the other circuit.

APPLICABILITY The AC sources and sequencers are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS M To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining raquired offsite circuit on a more frequent basis. Since the Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Recuired Action not met.

However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition /, for two offsite circuits inoperable, is entered.

U Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

(continued)

B 3.8-5 Revision No. 0 Vogtle Units 1 and 2

AC Sources - Operating I B 3.8.1 l

BASES ACTIONS M (continued) ^

These features are powered from the redundant AC electrical power train. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time In zero" for this Required beginning the allowed outage time ' clock."

Action, both:

the Completion Time only begins on discovery thatfY9 The train has no offsite power supplying i loads; and a.

b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class IE Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associa.ted with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and Dbs are adequate to supply electrical power to Train A and Train 8 of the onsite Class lE Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature.

Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

(continued)

B 3.8-6 Revision No. 0 Vogtle Units 1 and 2

AC Sources - Operating B 3.8.1 BASES ACTIONS Q (continued) , operation may According to Regulatory Guide 1.93 (Ref. 6)hould not exceed '

continue in Condition A for a period that s 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one required offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class IE Distribution System.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occ'1~1ng during this period. mIgggg, 3 The second templetion Time for Rs. quired Act on A.3 establishes a limit on the maximum time all >wed be inoperable for any combination of required AC power sources to during any single contiguous occurrence of Pailing to meet the LCO. If Condition A is entered while, For instance, a DG is inoperable and that DG is subsequent 1 / returned

.0PERABLE, the LCO may already have been not met for up to This could lead to e total of W Mmmes, since gg%3Messee. initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />sj

@H days ' allowed orior to comoiete restoration of the LCO. The F day Completion Tima provides s

depeec%, ott .11mit on the time allowed in a specified condition after disccvery of failure to meet the LCO.. This limit is g g l g fj h// I considered rsasonable for situations in which Conditions A

- J and B are entered concurrently. The "g D" connector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and Completion Times means that both Completion Times pply simultaneously, and the more restrictive Comp etion Time must be met.

l4 /YWe9 Tracking the) day CompTetion Time is a requirement for beginning the Completion Time " clock" that is in addition to the normal Completion Time requirements. With respect to the / day Completion Time, the " time zero" is specified as lY (continued)

B 3.8-7 Revision No. 0 Vogtle Units I and 2

AC Sources - Operating B 3.8.1  :

~

BASES-l ACTIONS M (continued) commencing at the time LCO 3.8.1 was initially not met, This instead of at the time Condition A was entered.

i results in the requirement when in this Condition to track the time elapsed from both the Condition A ' time zero" and-i A the ' time zero" when LCO 3.8.1.wa. initially not met.

l &stlT F0K RJ i g W fi9Weia To ensure a highly reliable power source remains with an

$7/0 A 8,2 inoperable DG, it it necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perfom," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperabla. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

i a s Required Action B./ is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety .

p function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included.- Redundant s quired feature failures consist of i

inoperable feature: associated with a train, redundant to the train that has an inoperable DG.

The Com>1stion Time for Required Action B. is intended to allow tae operator time to evaluate and repair any

' discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning thei allowed outage time ' clock." In this Required Action, the Completion Time only begins on discovery that both:

I a. An inoperable DG exists; and i

b. A required fsature on the other train (Train A or L

Train B) is inoperable.

i

' (continued) t l-B 3.8-8 Revision No. 0-Vogtle Units 1.and 2.

INSERT FOR NEW REQUIRED ACTION B.2 IL2 The 13.8/4.16 kV Standby Auxiliuy Transformer (SAT)is a qualified offsits circuit that may be connected to the onsite Class lE distribution system independently of the RATS and may be utilized to meet the LCO 3.8.1 requirements for an offsite circuit. Its availability permits an extension of the allowable out of-service time fc.r a DG to 14 days from the discovery of failure to meet LCO 3.8.1. The SAT is available when it is:

  • Operable in accordance with plant procedures;
  • Not already being applied to any of the four 4.16 kV ESF buses for Units I and 2 in accordance with Specification 3.8.1 as either an offsite source or to meet the requirements of an LCO 3.8.1 Condition; and,
  • Not providing power to the other unit when that unit is in MODE 5 or 6 or defueled.

Furthermore, the SAT can be applied to only one of the four 4.16 kV ESF buses at any given time for Units I and 2 to meet the requirements of an LCO 3.8.1 Condition.

When one or more of these criteria are not satisfied, the SAT is not available. These criteria are structured to ensure that the SAT is available as an alternate offsite source to support the extended DG Completien Time of 14 days. Therefere, when a DG is inoperable, it is necessary to verify the availability of the SAT within one hour and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If Required Action B.2 is not met or the status of the SAT changes aller Required Action B.2 is initially met, Condition C must be entered concurrently.

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AC Scurces - Operating-B 3.8.1 1

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BASES ACTIONS (continued)

If at any time during the aristence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering one required DG inoparable coincident with one or more inoperable required s'ipport or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action.

Four hours from the discovery of these events existing concur ently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to l

- transients associated with shutdown.

l In this Condition, the remaining OPERABLE DG and offsite-c" circuits are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's

function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable.

required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

k, BJ .1 and B.).2 g Required Action Bd .1 provides an allowance to avoid unnecessary testing of the OPERABLE DG. If it can be-detemined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be

. performed. If the cause of inoperability exists on the other DG, the other DG would be declared inoperable upon discovery and Condition F of LC0 3.8.1 would be entered.

Once the failure is repaired, the c n cause failure no longer exists, and Required Action B 1 is satisfied. If the cause of the initial inoperabl cannot be confirmed not to exist on the remaining DG, rformance of SR 3.8.1.2 suffices-to provide assurance of c ntinued OPERABILITY of that DG..

v (continued)

Vogtle Units 1 and 2 B 3.8-9 Revision No. O

AC Sources - Operating B 3.8.1 l

l BASES I

ACTIONS B./.1andB.,.2 (continued) q gy In the event the inoperable DG is ris, cred t. PERABLE

- status prior to completing either B.7.1 or B .2, the  :

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' applicable plant procedures will continue to require the evaluation of the common cause possibility. This continued NfW MSWAdd evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

g gg,j I' 8 . 6 2- # According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE DG is not affected i

by the same problem as the inoperable DG.

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ThnLCMikb Ny InConditionB,theremainingOPERABLEDGan<fo l pq g7 gg I circuits are adequate to supply electrical power to the

  1. /f add ///.Ms//6 onsite Class IE Distribution System. The J44 tour Completion Time takes into account the capacity and capability of the SdW(d (#4/M . '

remaining AC cources, a reasonable time for repairs, and the

/ #MV/N0[ M/M low probability of a DBA occurring during this period.

IM Completion Time for Required Action also establishes a limit on the maximum time allowed for any combination of A g/pg,/ /p f required AC power sources to be inoperable during any single

@pg/ /gf gg' contiguou., occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite

[/ > C//)ca circuit is inoperable, the LCO may already have been not met for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the offsite circuit is restored J

0[N/MN within the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, this could lead to a total of hr :, since initial failure to meet the LCO, to restore Appg/ ,$ [ C Og..I = compliance,with the LCO (i.e., restore " thM

u. the DG).

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We-tet. However, the f day Completion Time provides a

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', .84 (continued)

~ Vogtle Units 1 and 2 8 3.8-10 Revision No. 0

INSERT FOR NEW REQUIRED ACTION 11.5.1 AND D.5.2 11.5.1 and 11.5.2 Required Action H.5.1 provides assurance that an enhanced black start combustion turbine generator (CTO) is functional when a DG is out of sen ice for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action D.5.1 is modified by a Note that states that it is only applicable provided that the two enhanced black start CTOs and black start diesel generator have a combined reliability of 2 95% based on a minimum of 20 tests per enhanced black start CTO and quarterly testing thereafter. This quarterly testing will subject each enhanced black start CTO to a start and load run test. The blacbstart diesel generator will also be tested quarterly, but separately from the enhanced black start CTOs Required Action 0.5.1 may be met by starting either of the enhanced black start CTOs and the black start diesel generator and verifying that they achieve steady state voltage and frequency. The blhek start diesel generator may be started separately.

If a DG is to be removed from service voluntarily for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it may be advantageous to test an enhanced black start CTO prior to taking the DG out of service.

In such cases where advance notice of removing a DG from service is available, Required Action D.5.1 may be performed up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to entry into Condition D. In other cases, Required Action 11.5.1 must be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> aner entry into Condition D.

If the combined reliability of the enhanced black start CTOs has not been demonstrated or maletained 195%, the option of starting and ruruting any one of the sin CTOs while 1 Condition B is available in the form of Required Action 0.5.2. In the event of preplanned maintenana that would exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, any one of the six CTGs must be started prior to entr"into Condition B and allowed to run for the duration of Condition D. Othetwise, any one of the six CTGs must be started within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (end allowed to run) aner entry into Condition B if the DG is to be out of service for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the running CTO should fall while in Condition B, any one of the remaining CTGs must be started within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, if one of the six CTGs cannot be started witnin 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Condition C  ;

becomes applicable. Note that Required Action D.5.1 requires that one of the two enhanced black start CTGs be started, but any one of the six CTGs could be started to  !

satisfy Required Action B.S.2. Since a CTO is started and running while the DG is ,

inoperable, it is not necessary that the CTG have enhanced black start capability. l I

s AvoGTLl3voGT11 Kvl3TTCilSPLB14DYlXrrs\leDYU AS2 Doc l

INSERT FOR REQUIRED ACTION 11.6 in addition, the Configuration Risk hianagement Program (CRhiP) is used to assess changes in core damage frequency resulting from applicable plant condgurations. The CRhiP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assenment model to evaluate the risk of removing equipment from service based on current plant con 0guration and equipment conditien. The CRhiP is used when a DO is intentionally taken out of service for a planned activity exemding short duration activities (e.g., perfomiirig an air roll on the EDO prior to a routine surveillance). In addition, the CRMP is used for unplanned maintenance or repairs of a DO.

Planned ac'vities involving an extended DO AOT will be synchronized with other maintenance activities as much as possible in order to mnimize equipment reliability while minimizing the time equipment is unavailable, in addition, Required Action B.3 req.ilres that features suppeted by the inoperable DO be declared inoperable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery when redundant features are discovered to be inoperable. The combination of planned maintenance centered around the extended DG AOT, Required Action 11.3, and use of the CRhiP provides an appropriate level of assurance that risk significant activities with an unacceptable risk achievement worth will be minimized during an extended DG AOT.

s mxntuvoonxxyrmenstrot4tnyxnsu4ovnAstooc 1

AC Sources - Operating B 3.8.1 j 8ASES l

ACTIONS (continued) l

' limit on time allowed in a specified condition after I discovery of failure to meet the LCO. This limit is considered reasonable for situation; in which Conditions A andB(andconsequentlyConditionf)areentered ,

concurrently. g '

Tracking the# day Completion Time is a requirement for beginning the Completion Time " clock' that is in' addition to the nomal Completion Time requirements. With respect to i

the completion Time, the " time zero' is specified as commencing at the time LC0 3.8.1 was initially not met, instead of at the time condition 8 was entered. This

' results in the requirement when in this condition to track '

' - the time elapsed from both the Condition 8 ' time zero" and the " time zero" when LCD 3.8.1 was initially not met. ,

/4.544 7 fed 1

NEW Onoff C 9,D **d & l Required Action .1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not resc1t in a complete loss of redundant required safety functions. . The completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (#ef. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for ,

+

two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE.

When a concurrent redundant required feature failure exists, i this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps. Single train features, such as turbine driven auxiliary pumps, are not inc in the list.

' The Comaletion Time for Required Action .1 is intended to -

allow tie operator time to evaluate and repair any -

discovered inoperabilities. This Completion Time also allows for an exception to the nomal " time zero" for (continued) i 8 3.8-11 Revision No. O Vogtle Units 1 and 2 I- j

..,-,.-... - -.._... .,, - r -_,,.~m_, . _ - - ~ . _ . _ _ _ , _ _ . . . , _ . . . , . . _ . _ . _ . . . _ . . -....,...,...,.....-4m.&

INSERT FOR NEW CONDITION C Cl if the availability of the SAT cannot be verilled, or if no CTO meets the requirements of either Required Action B.5.1 or B.S.2, the DG must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hout Completion Time begins upon entry into Condition C.

Ilowever, the total time to restore an inoperable DG cannot exceed 14 days (per the Completion Time of Required Action D.6).

The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (in the absence of the SAT)is consistent with Regulatory Guide 1.93 (Ref. G). The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Tirne takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and low probability of a DBA occurring this period.

1 sWOGTLEWoo111 KvDTreitsPIDl4DYlXIrs\l4DVDA52 doc

AC Sources - Operating 8 3.8.1 BASES ACTIDNS 1 and 2 (continued)

In this Required beginning the allowed outage time ' clock."

Action the Completion Time only oegins on discovery that both:

a. All required offsite circuits are inoperable; and
b. A required feature is inoperable. p IfatanytimeduringtheexistenceofCondition/(two a required feature becomes offsite inoperable, circuits inoperable) this Comp 1 Time begins to be tracked.

According to Regulatok uide 1.g3 lRef. 6), operation may continue in Condition for a period that should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This level f degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to 4 total loss of the 1:enediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable. However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power syste's that remains available is not susceptible to a single bus or switching failure; and
b. The time -equired to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain tha unit 13 a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were (continued) 8 3.8-12 Revision No. 0 l Vogtle Units 1 and 2 l

i i

AC Sources - Operating l i

B 3.8.1 i i

BASES l i I

QEl and j f.2 ACTIONS (continued)

postulated as a part of the design basis in the safety  :

! analysis. Thus, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an  !

AC electrical power system capable of meeting its design i criteria. l j According to Reference 6, with the available offsite AC  !

. sources, two less than required by the LCO, operation may ,

continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If two offsite sources are restored ,

4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unrestricted operation may continue. If i only one offsite source is restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, power operation continues in accorda with Condition A. 1 hg1andf.2 f $ i i

j ,

l Pursuant to LC0 3.0.6 the Distribution System ACTIONS would not be entered even if il AC sources to it were inoperable, resulting in de-energiJi on. Therefore, the Required Actions of Condition F modified by a Note to indicate  :

' that when Condition s entered with no AC source to one or more trains, the Conditions and Required Actions for

  • " must k LCO3.8.g.' Distribution-Systems-Operating immediately entered. This allows Condition /,toprov'Je requirements for the loss of one offsite circuit and one DG, without regard to whether a train is de-energized.

LCO 3.8 g provides the appropriate restrictions for a de-energized train.

, operation may According to Regulatory Guide 1.g3 (Ref. 6)hould not exceed continueinConditiongforaperiodthats i j' 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, g

~

In Condition , individual redundancy is lost in both the offsite electrical power system and the onsite AC ele.-trical power system. Since power system redundancy is prov Hed by  !

two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher thar, l that in Condition (loss of both required offsite j circuits). This fference in reliability is offset by the susceptibility o- this pcwer system configuration to a )

~

(continued)

I

~

vogtle Units 1 and 2 8 3.8-13 Revision No. O

'-,-------2.~m,

AC Sources - Operating B 3.8.1 i 8ASES E 4 MTIONS X.1 and Ljt (continued) single bus or switching failure. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Covietion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

F ,

4 With Train A and Train 8 DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generatcr trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted.

The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

According to Reference 6, with both DGs inoperable, operation may continue for a period that should net exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The sequencer (s) is an essential support system to both the offsite circuit and the DG associated with a given ESF bus.

Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus. The sequencers are required to provide the system response to both an SI signal and a loss of or degraded ESF bus voltage signal.

Therefore, loss of an ESF bus sequencer affects every major ESF system in the train. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer (continued) .

Revision No. O s

Vogtle Units 1 and 2 B 3.8-14

l I

AC Sources - Operating B 3.8.1 l BASES ACTIDNS (continued)

OPEMBILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is __

of hfyIrvClk&AML

'e * *! ' *

/

.1 and 2

\

f #l & c/f pot & M t M M ' N C '

If the inoperable AC electri pem A n W irf' N tinn Wa load sequencer cannot be res red to OPERABLE status within the required Completion Time, the unit r.ast be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Tir'.s are reasonable, based on operating .

experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Condition corresponds to a level of degradation in which all redun ancy in the AC electrical power supp,ies has been lost. At this severely degraded level, any further losses '

in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to connence a controlled shutdown.

SURVEILLANCE The AC sources are designed to pemit inspection and testing REQUIREMENTS of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 8). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance v' ~ h the recommendations of Regulatory Guide 1.9 (Ref. 3),

Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as addressed in the FSAR.

(continued)

  • B 3.8-15 Revision No. O Vogtle Units 1 and 2

AC Sources - Operating 3.8.1 ACTIONS .

< CONDITION REQUIRED ACTION COMPLETION TIME i'

A. (continued) A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from feature (s) with no discovery of no

. offsite power .

offsite power to i

? available inoperable one train l when its redundant concurrent with  :

required feature (s) inoperability of ,

a is inoperable. redundant  ;

required feature (s) ,

8ND I A.3 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> offsite circuit to ,

i OPERABLE status. ANQ i

14 days from l discovery of failure to meet

LC0 i

(continued) 1 i  ;

h

(

.r g ;-

[

Vogtle Units 1 and 2- 3.8-2 Amendment No. (Unit 1)

Amendment No.. (Unit 2)

-  ?

m- *-r*u-fr-V 50- 4- p Tv " st e-W'y# y4s.ygy,.mw- 9 4i e b y*-gr e e &g.ye-ep w--ms4ywer *Mg. t1-1yy,-+1 w a .-ms -ymr,=. @ h.mg re f-W_-.w gy g -epg-n3-H -- -- .yyw='$'et- g-m

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the required offsitecircuit(s). E Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter M

B.2 Verify SAT 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> available.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter B.3 Declare requitad 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from l-feature (s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with required redundant inoperability of feature (s) is redundant inoperable, required

, feature (s)

B.4.1 Determine OPERABLE 2A hours l DG is not inoperable due to common cause failure.

DB B.4.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l for OPERABLE DG.

M' (continued)

Vogtle Units 1 and 2 3.8-3 Amendment No. (Unit:1)

Amendment No. (Unit 2) 1

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) .- -.-..-..--NOTE -----------

Required Action B.5.1 is only applicable if the combined reliability of ,

the enhanced black-start combustion turbine generators black-start (dieselCTG) and the generator is 1 95%.

Otherwise. Required Action B.5.2 applies.

B.5.1 Verify an enhanced 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> black-start CTG is functional by QB verifying the CTG and the black-start Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> diesel generator prior to entry starts and achieves into Condition B steady state voltage and frequency.

08 B.S.2 Start and run at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> least one CTG while in Conditon B. QB Pric,r to entry into Conditon B for preplanned maintenance 8H0 (continued)

Vogtle Units 1 and 2 3.8-3a Amendment No. (Unit 1)

Amendment No. (Unit 2)

g. g ---g  % 9 -ni,- -._m n w wm- -

g-- 4-c. ,,s-smg+, m.p-e w ogr gwg-p- ,--,,,.a TT~-'r

-AC Sources - Operating 3.8.1 ACTIONS (continued)-

N 2

i' This Page Intentionally L l' Blank e

q

[

.Vogtle Units 1 and -

3. 8-3') Amendment-No. (Unit 1)

Amendment No. .(Unit-2) h- u imm ai i . ..: - _.._,m.__. _ _ _ _ . . _ . _ _ _ _ _ _ _ , _ _ . __

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

AC Sources -- Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.6 Restore DG to 14 days from l OPERABLE status, discovery of failure to meet LCO C. Required Actions B.2, C.1 Restore DG 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.5.1, or B.S.2 and to OPERABLE associated Completion status.

Times not met.

=0. Two rv.uired offsite D.1 Declare required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from l circuits inoperable, feature (s) discovery of inoperable when its Condition D l redundant feature (s) concurrent with is inoperable. inoperability of redundant required features MD D.2 Restore one required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l offsite circuit to OpiRABLE status.

E. One required offsite -----------NOTE------------- l circuit inoperable. Enter applicable Conditions and Required Actions of 6NQ LC0 3.8.9, " Distribution Systems -- Operating," when One DG inoperabic. Condition E is entered with l no AC power source to one or more trains.

(continued)

Vogtle Units 1 and 2 3.8-4 Amendment No. (Unit 1) ,

Amendment No. (Unit.2)

AC Sources - Operating l 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I

E. (continued) E.1 Restore required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l offsite circuit to OPERABLE status.  ;

QB E.2 Restore DG to OPERABLE 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l status.

-F. Two DGs inoperalsle. F.1 Restore one DG to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> l OPERABLE status.

G. One automatic load G.1 Restore automatic load 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l sequencer inoperable, sequencer to OPERABLE status.

H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Cs.1dition A. AND C, D, E, F, or G not I met. H.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 08 Required Action B.1, B.3, B.4.1, B.4.2, or B.6

and associated Completion Time not met.

I. Three or more I.1 Enter LCO 3.0.3. Immediately l required AC sources inoperable.

Vogtle Units 1 and 2' 3.8-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

l Prcgra s and Manuals 5.5 ;

5.5 Programs and Manuals i 5.5.17 Containment Leakane Rate Testina Proots (continued) ,

The provisions of SR 3.0.2 do not apply to the test frequencies l specified in the Containment Leakage Rt.te Testing Program.

The provisions of SR 3.0.3 are applicable to the Contalement Leakage Rate Testing Program.

5.5.18 Confiauration Risk Manaaement Proaram The Configuration Risk Management Program (CRMP) provides a  !

proceduralized risk-informed assessment to manage the risk associated .sith equipment inoperability. The program applies to +

technical s)ecification structures, systems, or components for which a ris c-informed alle.ved outage time has been granted. The  ;

program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at power internal events PRA-informed methodology. The  !

assessment shall be capable of evaluating the applicable -

plant configuration,

b. Provisions for performing an assessment prior to entering the LCO Action Statement for preplanned activities.
c. Provisions for performing an assessment after entering the LCO Action Statement for unplanned entry into the LCO Action Statement.
d. Provisions for assessing the ne9d for additional actions i after the discovery of additional equipment out of service conditions while in the LC0 Action Statement. -

l

e. Provisions for considering other applicable risk significant I contributors such as Level 2 issues and external events. l qualitatively or quantitatively.

Vogtle Units 1 and 2 5.0-27 Amendment No. (Unit 1)

Amendment No. (Unit 2)-

AC Sources - Operating t B 3.8.1 BASES LCO train. For the DGs, separation and independence are (c'.sntinued) complete.

For the offsite AC sources, separation and independence are to the extent practical. A circuit may be connected to more than one ESF bus while the bus is being transferred to the other circuit. .

i APPLICABILITY The AC sources and sequencers are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
b. Adequate core cooling is provMed and containment OPERABILITY and other vital tunctions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LC0 3.8.2, "AC Sources - Shutdown."

ACTIONS M To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offstte circuit on a more frequent basis. Since the Required Action only specifies " perform, a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

However, if a second required circuit fails SR 1.8.1.1, the second offsite circuit is inoperable, and Condition D, l for two offsite circuits inoperable, is entered.

M Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide a.surance-that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function _of critical redundant required features.

(continued)

-Vogtle Units 1 and 2 B 3.8-5 Revision No.

1 w we-m-*T v --T'u --vi g p er, e m Fw**--P*5--wurgr-t ---m- +-----g-+-*-*v**w-r* -=e-w--- -

ye-e---m-v--p7es'- gr-=we-y-

AC Sources - Operating B 3.8.1 l l

BASES l i

4 ACTIONS M (continued)

These features are powered from the redundant AC electrical power train. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven  !

auxiliary feedwater pumps, may not be included, The Com)1etion Time for Required Action A.2 is intended to 4 allow tie operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both

a. The train has no offsite power supplying its loads; l  !

and

b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature 4

subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to on' train of the onsite Class IE Electrical Power Distribetion System coincident with one or more ino)erable reau' red support or susported '

features, or both, t1at are associated with the otler train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-Tour hours is ,

acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class IE Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature.

Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

(continued)

Vogtle Units 1 and-2 B 3.8-6 Revisio.i.No.

e-- - =

s e -v- , 2

AC Sources - Operating P 3.8.1 I

BASES  !

i J

ACTIONS bt)

(continued)  ;

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one required offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class IE Distribution System.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the ca)acity and capability of the remaining AC sources, a reasonaale time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, '

DG is inoperable and that DG is subsequently returned OPERABLE, the LCO may already have been not met for up to 11 days. This could lead to a total of 14 days, since initial failure to meet the LCO, to restore the offsite circuit. At this tine, a DG could again become inoperable, the circuit restored OPCRABlE, and an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or 14 days depending on SAT availability, allowed prior to complete restoration of the LCO. The 14 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which conditions A and B are entered concurrently. The "6NQ" connector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 14 da$' Completion Times means that both l Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

Tracking the 14 day Completion Time is a requirement for l beginning the Completion Time " clock" that is in addition to the normal Completion Time requirements. With respect to the 14 day Completion Tira. the " time zero" is specified as l (continued)

Vogtle Units 1 and 2 B 3.8-7 Revision No.

v -,M- ~*e -w

~ ~ '

AC Sources - Operating 8 3.8.1 BASES ACTIONS M (continued) commencing at the time LCO 3.8.1 was initially not met, instead of at the time Condition A was entered. This

esults in the requirement when in this Crmdition to track

~

the time elapsed from both the Condition a " time zero" and the " time zero" when LCO 3.8.1 was initially not met.

M To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the '

Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit 4 inoperability, additional Conditions and Required Actions  ;

must then be entered.

M is a 4 The 13.8/4.16 qualified kV circuit offsite Standbythat Auxiliary may be Transformer connected (SAT)he to t onsite Class IE distribution system independently of the ,

RATS and may be utilized to meet the LCO 3.8.1 requirements for an offsite circuit. Its availability permits an extension of the allowable out-of-service tima for a DG to 14 days from the discovery of failure to meet LCO 3.8.1.

The SAT is available when it is:

  • Operable in accordance with plant procedures;
  • Not already being applied to-any of the four 4.16 kV ESF buses for Units 1 and 2 in accordance with Specification 3.8.1 as either an off site source or to meet the requirements of an LCO 3.8.1 Condition;.and,  ;
  • Not providing power to the other unit when that unit is in MODE 5 or 6 or defueled.

(continued) iVogtle Units I and 2' B 3.8-8 Revision No. -

i .

AC Sources - Opeiating B 3.8.1 '

BASES ACTIONS L2_ (continued)

Furthermore, the SAT can be applied to only cne of the four 4.16 kV ESF buses at any given time for Units 1 and 2-to meet the requirements of an LCO 3.8.1 Condition.

When one or more of these criteria are not satisfied, the SAT is not available. These criteria are structured to ensure that the SAT is available as an alternate offsite source to support the extended DG Completion Time of 14 days. Therefore, when a DG is inoperable, it is necessary-

- to verify the availability of the SAT within one hour and once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s-thereafter. If Required Action B.2 is not met or the status of the SAT changes after Required Action  ;

B.2 is initially met, Condition C must be entered concurrently.  ;

B.d Required Action B.3 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety d function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of -

4 inoperable features associated with a train, redundant to the train that has an inoperable DG.

The Com>1etion Time for Required Action B.3 is intended to l

. allow tie operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists; and ,
b. A required feature on the other train (Train A or Train B) is inoperable. .

(continued)

Vogtle Units ILand 2- B 3.8-8a Revision ~No.

E ih 1 i;s

- -  ;,-... -+ 2 .. ._,... ~.._ . ._- _ - -_.__-.m. _ -_.a,-~__..---_,.--. - , _;. . - , _ - , - . - ,

AC Sources - Operating B 3.8.1

- BASES i 1

I l

i P

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This Page Intentionally left Blank-i I

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(continued)_

.t .

-l Vogtle; Units;Isand:2 B:3.8-8b Revision No.

f

+-

+ t 4 -m -, r v- , i t 9.,% ~,w.,,,.+-.,,ww-,,.w., n y m-, - - ,+-+,s.~..,.w, ,4,er d w, - ,e *,.,w..wa-ey.,,ree+.rw-w

l AC Sources - Operating l 8 3.8.1 l BASES ACTIONS H.J (continued) l If at any time during the existence of this Condition (one l DG inoperable) a required feature subsequently becomes i inoperable, this Completion Time would begin to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features. l or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Requited Action.

Four hours from the discovery of these a"Snts txisting concurrently is acceptable because it :.n timize risk while allowing time for restoration before sub ectin; the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class lE Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.4.1 and B.4.2 l Required Action B.4.1 provides an allowance to avoid unnecessary testing of the OPERABLE DG. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. -If the cause of inoperability exists on the other DG, the other DG would be declared inoperable upon discovery and Condition F of LCO 3.8.1 would be entered.

Once the failure is repaired, the common cause failure no longer exists, and Required Action B.4.1 is satisfied. If l the cause of the initial inoperable DG cannot-be confirmed not to exist on the remaining DG, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

{ continued)

Vogtle. Units 1 and 2- B 3.8-9 Revision No.

AC Sources - Operating B 3.8.1 BASES ACTIONS B.4.1 and B.4.2 (continued) l In the event the inoperable DG is restored to OPERABLE i status >rior to completing either B.4.1 or B.4.2, the l

l applica)1e plant procedures will continue to require the  !

evaluation of the common cause possibility. This continued l evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i constraint imposed while in Condition B.

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

B.5.1 and B.5.2 Required Action B.5.1 provides assurance that an enhanced black-start combustion turbine generator (CTG) is functional when a DG is out of service for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. <

Required Action 8.5.1 is modified by a Note that states that '

it is only applicable provided that the two enhanced black-start CTGs and black-start diesel generator have a combined reliability of 2 95% based on a minimum of 20 tests per enhanced black-start CTG and quarterly testing thereafter.

This quarterly testing will subject each enhanced black-start CTG to a start and load-run test. The black-start diesel generator will also be tested quarterly, but separately from the enhanced black-start CTGs. Required Action B.5.1 may be met by starting either of the enhanced black-start CTGs and the black-start diesel generator and verifying that they achieve steady state voltage and frequency. The black-start diesel generator may be started separately.

If a DG is to be removed from service voluntarily for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it may be advantageous to test an enhanced black-start CTG )rior to taking the DG out of service. In such cases w1ere advanced notice of removing a DG from service is available, Required Action B.5.1 may be performed up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to entry into Condition B.

In other cases, Required Action B.5.1 must be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after entry into Condition B.

(continued)

Vogtle Units 1.and 2 B 3.8-10 Revision No.

AC Sources - Operating B 3.8.1 BASES ACTIONS B.5.1 and 0.5.2 (continued)

If the combined reliability of the enhanced black-start CTGs l has not been demonstrated or maintained ?. 95%, the option of starting and running any one of the six CTGs while in Condition B is available in the form of Required Action B.5.2. In the event of preplanned maintenance that would exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, any one of the six CTGs must be started l prior to entry into Condition B and allowed to run ft"- the  !

duration of Condition B. Otherwise, any one of the six CTGs must be started within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (and allowed to run) after l entry into Condition B if the DG is to be out of service for )

more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the running CTG should fail while in Condition B, any one of the remaining CTGs must be started within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If one of the six CTGs cannot be started within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, Condition C becomes applicable. Note that Required Action B.S.1 requires that one of the two enhanced black-start CTGs be started, but any one of the six CTGs  !

could be started to satisfy Required Action B.5.2. Since a CTG is started and running while the DG is inope.able, it is not necessary that the CTG have enhanced black-start  :

capability.

l ILJi The availability of the SAT provides an additional AC source which permits operation to continue for a period not to exceed 14 days from discovery of failure to meet the LCO.

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class lE Distribution System. The 14 day Completion l Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

In addition, the Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting from applicable plant configurations. The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaldate the risk of removing equipment from service (continued)

Vogtle Units 1 and 2 B 3.8-10a Revision No.

. __ __ _. _ _ _ . ~ _ _ . _ __ _. _ _ _ _.

-' AC Sources - Operating B 3.8.1 i

BASES L

ACTIONS RJt (continued) l based on current plant configuration and equipment 4 condition. The CRMP is used when a DG is intentionally taken out of service for a planned activity excluding short duration activities (e.g., performing an air roll on the EDG prior to a routine surveillance). In addition, the CRMP is used for unplanned maintenance or repairs of a DG, Planned activities involving an extended DG A0T will be synchronized with other maintenance activities as much as possible in order to maximize equipment reliability while minimizing the time equipment is unavailable. In addition, Required Action B.3 requires that features supported by the '

inoperable DG be declared inoperable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery when redundant features are discovered to be inoperable. The combination of planned maintenance centered around the extended DG A0T. Required Action B.3, and use of the CRMP provides an appropriate level of assurance that risk significant activities with an unacceptable risk achievement worth will be minimized during an extended DG A0T.

The Completion Time for Required Action B.6 also establishes l a limit on the maximum time allowed for any combination of required AC pcwer sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable, the LCO may already have been not met for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if the offsite circuit is restored within the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, this could lead to a total of 17 days, since initial failure to meet the LCO, to restore compliance with the LCO (i.e., restore the DG). However, the 14 day Completion Time provides a (continued)

Vogtle Units 1 and 2 B 3.8-10b Revision No. i

AC Sources - Operating B 3.8.1 BASES ACTIONS L i (continued) l

. limit on time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B (and consequently Condition E) are entered l concurrently.

Tracking the 14 day Completion Time is a requirement for l beginning the Completion Time " clock" that is in addition to the normal Completion Time requirements. With respect to the Completion Time, the " time zero" is specified as commencing at the time LC0 3.8.1 was initially not met, instead of at the time Condition B was entered. This results in the requirement when in this Condition to track the time elapsed from both the Condition B " time zero" and the " time zero" when LC0 3.8.1 was initially not met. -

L1 If the availability of the SAT cannot be verified, or if no CTG meets the requirements of either Required Action B.5.1 or B.S.2, the DG must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time begins upon entry into Condition C. However, the total time to restore an inoperable DG cannot exceed 14 days (per the Completion Time of Required Action B.6).

The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (in the absence of the SAT) is consistent with Regulatory Guide 1.93 (Ref.6). The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and low probability of a DBA occurring this period.

D.1 and D.2 Required Action D.1, which appites when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationkle for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for (continued)

'Vogtle' Unit's 1 and 2 8 3.8-11 Revision No.

i

r AC S:urces -- Operating i B 3.8.1  !

BASES ACTIONS D.1 and D.2 (continued) l

two required offsite circuits inoperable, based upon the  !

assumption that two complete safety trains are OPERABLE.

When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered

-from redundant AC safety trains. This includes motor driven  ;

auxiliary feedwater pumps. Single train features, such as .

turbine driven auxiliary pumps, are not included in the list.

The Com:1stion Time for Required Action 0.1 is intended to l allow tie operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for f

a R

0 4

1 (continued)

VogtleUnits:lfandl2/ 8 3-8-lla

. Revision'No. -

t

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

O ACSourcos-Operatinf 8 3.8.

BASES l

l l

This Page Intentitonally left Blank (continued)

-Vogtle Units 1 and 2 8 3.8-llb Revision No.

  • AC Sources - Operating B 3.8.1 BASES ACTIONS D.1 and 0.2 (continued) l beginning the allowed outage time " clock." In this Required Action the Completion Time only begins on discovery that both:
a. All required offsite circuits are inoperable; and
b. A required feature is inoperable. -

If at any time during the existence of Condition D (two l offsite circuits inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (kef. 6), oper. tion may continue-in Condition D for a period that should not exceed l 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This level of degradation means that the offsite electrical power system does not have the capt.bility to effect a safe rhutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been

. degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

I- Because of the normally high availability nf the offsite sources, this-level of degradation may appear to be more sc"ere-that, other combinations of two AC sources inoperable that involve one or more DGs inoperable. However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that rerains available is not susceptible to a single bus or switching failure; and
b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source. .

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or 4 transient.- In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were (continued)

Vogtle Units-1 and 2 B 3.0-l? Revision No.

t

O AC Sources - Operating B 3.8.1 BASES ACTIONS D.1 and D.2 (continued). l postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides a-period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 ;,ours. If two offsite sources are restored within 24. hours, unrestricted operation may continue. If.

only one offsite source is restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, power 1 operation continues-in accordance with Condition A.

E.1 and E.2 l Pursuant to LC0 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition E are modified by a Note to-indicate that when Condition E is-entered with no AC source to one or more trains, the Conditions and Required Actions for LCO 3.8.9,_" Distribution Systems - Operating," must be immediately-entered. . This allows Condition E to provide l requirements for the-loss of one offsite circuit and one DG, without regard to whether a train is de-energized. LC0 3.8.9 provides_the appropriate _ restrictions for a de-energized train.

According to Regulatory Guide--1.93 (Ref. 6),. operation may continue in Condition E for a period that should not exceed l 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

In Condition _E, individual redundancy is lost in .both the l offsite electrical power system and the onsite AC electrical 1 power system. Since power system redundancy is vovided by two diverse sources of power, however, the reliasility of-the power' systems in.this' Condition may appear higher than that

in Condition 0 (loss of both required offsite circuits). l
This difference in reliability is offset by the susceptibility of-this power system configuration to a (continued)

' Vogtle Units IIand 25 B 3.8-13 LRevision.No.

p.

  • AC Sources - Operating B 3.8.1 BASES ACTIONS- E.1 and E.2 (continued) l single bus or switching failure._The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time-takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, t.nd the low probability of a DBA occurring during this period, f.d l With Train A and Train B DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with s continued operation for a very short time could be less than- V' that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also resuit in a total loss of offsite AC power, however, the time allowed for continued operation is= severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with-this level of degradation.

According to Reference 6, with both DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />..

L.1 The sequencer (s) is an essential support system to both the offsite circuit and the D3 associated with a given ESF bus.

Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus. The sequencers are required to provide the system response to both an SI signal and a loss of or_ degraded ESF bus vo.1tage signal. Therefore, loss of an ESF. bus sequencer _affects every major ESF system in the train. 'The-12 hour Completion Time provides a period of time -

to correct the problem commensurate with the-importance of maintaining sequencer (continued)

Vogtle Units-1.and 2, B 3.8-14 , Revision No.
gc

'o ,

AC Sources - Operating

.B 3.8.1 BASES ACTIONS L1 (continued) l OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

H.1 and H.2 l If the inoperable AC electric power sources nr an automati, load sequencer cannot be restored to OPERABLE status within the required Completion Time, or Required Actions B.1, B.3, B.4.1, B.4.2, or B.6 ca.inot be met within the required y Completion Times, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit avst be brought to at least M00E 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experictce, to rea.:h the-recuired unit conditions from full power conditions in an orterly manner and without challenging plant systems.

L1 l Condition I corresponds to a level of degradation in which l al'l redundancy in the AC electrica'l power supplies has been lost. At this severely degradedlevel, any further losses in the AC electrical power system will cause a loss of unction.

Therefore, no additional time is justified for continued operation. The unit is required by LC0 3.0.3 to commence a j

, controlled shutdown.

~

T SUAVEltLANCE The AC sources are designed to permit inspection and testing REQUlHEMENTS of all important areas and features, especially those that #

have a standby function in accordance with 10 CFR 50, Appendix-A, GOC 18 (Ref. 8). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). 'The SRs'for demonstrating th( OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide l.9 (Ref. 3),

Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137
(Ref. 10), as addressed in the FSAR.

m s (continued)

Vogtle Units 1-and 2 B 3.8-15 Revision No.

s E -m _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ __ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _- I