Text

Proposed Revs to Previously Submitted Tech Specs with LAR Related to RAI Re Conversion to Its,Chapter 3.8
	ML20206F442
Person / Time
Site:	Farley
Issue date:	04/30/1999
From:	; SOUTHERN NUCLEAR OPERATING CO.
To:	;
Shared Package
ML20206F438	List: L-99-180, Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI; ML20206F432; ML20206F442;
References
	NUDOCS 9905060124
	Download: ML20206F442 (100)
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Restore the in g q g within 10 day etable emergency diesel generator set to Op(RA8LE status n in COLO $HUTDOW within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . f sne previstens o f3peciricT.L.,..v.s are <>v6 .ppincesse ir only one of the three bg

\ individual emergency diesel generators is inoperable,r t ggfg, p.n.

000b ICD D T With one offpte A.C. circuit and one escreencv distal errratar set ineseratie _..w ... l sne urtnasiurT or the rematalag A.C. sources sy' I

ff#$5A.TC. perroming Surveillance Requirceent 4.8.1.1.1.s en the remaining effsite W S. I Mg .y O s

g C o n t) TicO D ether than emergens preefanned diesel prever.tive generator set became inoperable raintenance eue to any cause ..

% [ Op RASILITY of the reestatng emergency die 2

~$ g 3*g performing Survelliance beguirement 4. . 2.generater set by a.4 en the remainini emergency diesel generater set within rs, unIess such survell ance.

$ has been perfereed within the previews 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months e_c the emereenc 10 g p'g l'Anaratars nemaran a a.c.noe already,ameratinar s nestere as seass one er sne

[na f311aulneercas to OPEmiet gnef other status within sewrce24 tl heurtsT 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .fAestore A.G. # (erfsste H.L A.C to OptRASLE status in circuit accordance er with emergency the previsions siesel generator set)3.8.l.1 Actionl statements of Section

b. as appropriate, with the time requirement of the actlen statement ke3 based en the time of initial less of the remaining inoperable A.C.

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'(Ith both of3 effsite A.C. circuits inoperabledd trate tu e" remaint a.6. s rces sy ref Survel ace 4r t 4.8. 1.2.a.4 en both e emerge A wi in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , less s dies genera e se

survel ance has pe reed w< fn t a p vlev 24 han er the . - d" anal - r itt n re at ~ '

m um .i nestere at w est one .f th. ineo.nno orrsit" A.L. eirsih.p ca.

INT D f to ur,.nasu ttae.us within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sene na in at oost isT :

n e . .r 1 =1 within enou e.s m, w- e e enne,er i n aniy one errsit. A.c. c ruu i ros a seeoW.C. ci,cuit to Opimte statu

, ressere M g..g-Ltime of instini is. .ithin n h.un A,3wes%

j..- . ene la COLD $lElT00lat r .e in within as the follewleg ieass noi 30 ->hours.

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th un thi hours, unless such surveillance has been W 4 err,. - visnin previews 24 hears or the emergency diesel I Lgeneratorsa ready eseratine.J Restore 45 seass one er sne g p : :rasisjoergency ciesei generator sets to OptAA8LE status: i g,

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9905060124 990430 DR ADOCK O 38

g FNP TS Conversion {

Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems l

CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC EQ SHE DISCUSSION .

may be without power and STS support / supported system conventions (LCO 3.0.6) do not require that supported system LCOs be entered unless specified in the support system LCO. The Note provides guidance when STS Condition D (CTS action statement "c") is entered with an ESF bus 4 without AC power and specifies that the applicable Condition of STS LCO 3.8.9, " Distribution Systems - Operating," (the supported system) be entered. The STS LCO 3.8.9 provides the appropriate actions and restrictions for a de-energized ESF bus. The use of the STS note clarifi~ es that LCO 3.8.1 Condition D provides the actions and restrictions appropriate for the loss of the AC Sources and STS LCO 3.8.9 provides the actions and restrictions appropriate for a de-energized ESF bus. The note is necessary given the support /supponed system conventions of the STS as l stated in LCO 3.0.6. As such, the addition of this STS Note is made to i conform with the conventions and format requirements of the STS and is l considered an administrative change.

I1 L CTS 3.8.1.1 Action statements "c" and "e" contain requirements intended to verify that no common-mode DG failure exists when one or more DGs are inoperable. The CTS Actions require starting the remaining operable DGs within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless performed in the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These CTS Actions are effectively replaced by the STS Required Actions B.3.1 and B.3.2 as explained in another DOC. However, the STS Required Actions allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to make the determination of no common-mode failure or stan the operable DGs. The STS Completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been identified by NRC Generic Letter 84-15 as a reasonable time in which to confirm the operable DG(s) are not affected by the same problem as the ;

moperable DG(s). As such, the revision to the CTS time allowed to perform this verification or start the operable DG(s) is consistent with the 1 STS and NRC generic guidance.

12 A The CTS 3.8.1.1 Action statement "e" for two inoperable DG sets is revised by the deletion of the action requirement to test the required offsite circuits j consistent with the STS. In the STS, the actions for an inoperable AC '

i source are not typically repeated in other Conditions involving

[ ,o-a combinations of AC sources. This is due to the STS convention that l 3 multiple Conditions may be applicable at one time (see STS Section 1.3, 3.$

Completion Times) and therefore the STS actions for an inoperable AC source are always applicable when that source is inoperable and need not be Chapter 3.8 E2-6-A April,1999 1

l FNP TS Conycrsion Enclosure 2 - Discussion of Changes to CTS j Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING 'I

' FNP ITS 3.8.1 AC SOURCES - OPERATING DOC HQ SHE DISCUSSION repeated in each Condition that has the same inoperable source in it. When Condition E is entered for two inoperable DG sets, Condition B is also pt y entered for each inoperable DG set individually. Therefore, the CTS g,p requirements to demonstrate the operability of the offsite circuits under these circumstances are covered under Condition B in the ITS and are deleted from CTS 3.8.1.1 Action statement "e" consistent with the STS.

13 A The CTS 3.8.1.1 Action statement "e" for two inoperable DG sets is revised by the deletion of the reference to both units. As one DG set is common to both units and the FNP ITS 3.8.1 is a common TS for both units, the corresponding STS Required Actions B.3.1 and B.3.2 would be applicable to each unit individually when the Common DG set becomes inoperable.

As such, the common-mode failure assessment or DG start requirements of the STS Required Actions are applicable to each unit and the specific instructions included in the CTS regardmg the application of this action to both units is unnecessary. This change conforms to the format of a single TS for both units and the convention that the actions apply individually to each unit. As such this charge is considered administrative in nature.

13a M A new Actions Condition is added to CTS 3/4.8.1 consistent with the STS.

STS Condition G addresses the condition of one automatic load sequencer inoperable. This STS Condition is intended for plants where the electrical system design is such that the operability of the sequencer affects the operability of the associated offsite circuit and DG in that train. The Completion Time for this sequencer Condition is based on the time allowed to restore ifone offsite circuit and one DG are inoperable at the same time (CTS Action 3.8.1.1.c). The FNP electrical system is designed such that the sequencer is required to sequence loads en the DG when no offsite power is available. In addition, when offsite power is available, the sequencer functions to actuate the required ESF loads simultaneously on the offsite circuit upon receipt of an SI signal. As such, the basis for this STS Condition is consistent with the FNP electrical system design and this Actions Condition is included in the FNP ITS. The Completion Time selected for this new Actions Condition (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )is consistent with the CTS 3.8.1.1.c restoration time for an inoperable offsite circuit and an inoperable DG set. The condition of one DG set and one offsite circuit inoperable effectively corresponds to the result of the associated FNP sequencer being inoperable. Therefore, the pmposed FNP Completion Chapter 3.8 - E2-7-A April,1999

r FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.8 - Electrical Power Systems i III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING 12:L (Deleted) l l

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f Chapter 3.8 E3-4-A April,1999

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC HQ SHE DISCUSSION error by increasing the number of separate test evolutions. As such, the deletion of the staggered testing requirement for the FNP DG related testing is also acceptable.

18 L CTS 3/4.8.1.1 surveillance 4.8.1.1.2.4 is revised consistent with the STS.

The CTS surveillance ' requires monthly testing of the DGs to verify they r start and come up to speed and voltage within 12 seconds. In the STS, this surveillance requirement is contained in two separate surveillances (SR-3.8.1.2 and SR 3.8.1.6). The STS surveillance SR 3.8.1.2 continues the monthly start requirements (which provide reliability data for the DGs) but contains a Note that provides the allowance to gradually accelerate the DGs to synchronous speed before verifying steady state voltage and frequency.

The voltage and frequency requirements of the STS have been adopted in the FNP ITS SR 3.8.1.2. The range of values provided by the STS for this slow start test of the DG is appropriate and applicable to FNP. The provision of the SR 3.8.1.2 Note for gradually accelerating the DGs is an option that may or may not be used. If the slow start option is not used for the 31 day surveillance, the Note requires that the time, voltage, and frequency requirements of SR 3.8.1.6 (DG fast start) be applied to the performance of the surveillance. SR 3.8.1.6, is required to be performed every 6 months (184 days) and also verifies the DGs start and come up to speed and voltage but requires that speed and voltage be achieved within 12 seconds (as required by CTS 4.8.1.1.2.4 now) and contains no provision for gradual acceleration of the DGs. The voltage and frequency requirements of the FNP ITS SR 3.8.1.6 are consistent with the DG fast start requirements for these parameters in CTS 4.8.1.1.2.4. This change will ;

potentially reduce the number of fast starts required to be perfonned on ]'

each DG (if the allowance provided by the note is exercised). The proposed change continues to verify DG start reliability monthly and requires that the design basis accident fast start capability of each DG be verified operable ;

every 184 days.

The reduction in fast start testing of the DGs is consistent with the STS and Regulatory Guide (RG) 1.9, Revision 3. Paragraph 2.2.1, " Start Test" of RG 1.9, Rev. 3, states that for these tests the emergency diesel generator can be slow started and reach rated speed on a prescribed schedule that is selected to minimize stress and wear. NRC sponsored aging research work on nuclear service diesel generators, documented in NUREG/CR-5057, March,1998 l Chapter 3.8 E2-10-A 1

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC EQ' SHE DISCUSSION

" Aging Mitigation and Impmved Proy.us for Nuclear Service Diesel Generators," has identified fast starting and fast loading tests of DGs as an aging stressor. Section 2.4.1 of this report states that a correctly managed monthly testing program involving slow starting and loading would induce little aging effects in the emergency DG. By contrast, a fast starting and loading test prognim can produce substantial harm and significant aging effects through the production oflarge mechanical and thermal stresses, inadequate lubrication during initial acceleration, high rotating and sliding pressures, overspeedmg, etc. The slow start is also consistent with recommendations of ASME/ ANSI Operations and Maintenance Standards and Guides Part 16. In addition, NUREG-1366, Improvements to Technical Specification Surveillance Requirements, Section 10 Electric Power, identifies several additional ways that fast DG starts are detrimental to the diesel engines and states, in part, that fast starting has the potential to accelerate the degradation of DGs.

FNP plans to implement the slow start option by cutting out the excitation system and manually adjusting the governor speed settmg to gradually accelerate the DG to operating speed. After reaching operating speed, the generator excitation will be reset to achieve operating voltage. The slow start will be accomplished in a manner and schedule consistent with the individual DG manufacturers recommendations to minimize stress and wear on the DGs. Daring a slow start, the DG protective features (i.e., engine overspeed, low-lube oil pressure, high-lube oil temperature, etc.) will operate in the same manner as during a fast start and the DG will remain pmtected. However, dunng the time the DG is being slowly accelerated to full speed , the capability of the DG to automatically respond to an ESF or LOSP signal will be impacted. If an ESF or LOSP demand occurs during a I surveillance test while slowly accelerating the DG, the operators performing the test must restore the DG speed control to the automatic setting and reset the excitation system to allow the DG to reach full speed and voltage.

Therefore, a potential delay in the time it takes the affected DG to reach full speed and voltage exists when slow acceleration of the DG is taking place.

Once the excitation system is reset and the mechanical governor speed control is adjusted to the Hi speed stop position, the DG is retumed to the same condition as if a fast start had occurred. Since the slow acceleration is accomplished manually, an operator is always present to restore the DG cot tmls to normal in the event the DG is required by an ESF or LOSP Chapter 3.8 E2-11-A March,1998 i 1

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n FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems i 1

CTS 3/4.8.1.1 AC SOURCES - OPERATING j l

g FNP ITS 3.8.1 AC SOURCES - OPERATING !

Y DOC T DISCUSSION 9

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, signal. However, the potential exists that the DG response to an ESF or LOSP signal could be delayed due to the slow start testing. Therefore, the DG is considered inoperable with respect to response to ESF or LOSP signals during the brief duration of modified starts, r The STS allowance to perform slow starts of the DGs with the accompanying inoperability during testing is acceptable considering that only one DG is tested at a time and the remaining DGs are available to -

supply emergency power, an operator is always at the DG controls in continuous communication with the control mom while slow starting a DG, and the small likelihood of a design basis accident occurring during a test when slow starting a DG. In addition. the expected benefits due to reduced wear and aging of the DGs and the resulting potential to increase the reliability and availability of the DGs offsets the potential delay in the DGs capability to respond to an ESF or LOSP signal that may occur during the slow acceleration portion of a DG test.

19 A CTS 3/4.8.1.1 surveillance 4.8.1.1.2.a.4 is revised consistent with the STS.

The CTS surveillance requires monthly testing of the DGs to verify they start and come up to speed and voltage. The CTS surveillance is modified by the addition of two STS Notes. The STS Notes are intended to provide clarifications. STS Note 1 allows the performance of SR 3.8.1.6 to satisfy

)

j this surveillance requirement. SR 3.8.1.6 requires the same DG verifications be performed as this surveillance but requires the DG come up to speed and voltage within 12 seconds and therefore is more restrictive than this surveillance. STS Note 2 states that all DG starts may be preceded by an engine prelube period and followed by a warm-up period prior to loadmg. This note is a further clarification of the accepted procedure for starting and loading the DGs. As such, the addition of these two notes is considered an administrative change to incorporate the clarifications provided by the STS.

20 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.a.4 is revised consistent with the STS.

The CTS surveillance specifies the required DG engine speed in rpms as well as the required Frequency in Hz. The STS specifies only one parameter, the required frequency. Therefore, the CTS engine speeds requirad to achieve the specified gerierator frequency (60Hz) are moved into the bases for this SR. The required frequency for the DG fast start (FNP Chapter 3.8 E2-12-A April,1999

958 AC Sources - Operating 8 3.8.1 BASES E SURVEILLANCE SR 3.8.1.2 and SR 3.8.1 (continu REQUIREMENTS' for a DG sean that the diesel engin coolant and oil are being continuously circulated and emperature is being maintained consistent with manuf turer recommendations.

In order to reduce stress and ar on diesel engines, some

( ' manufacturers recommend a ified start in which the 6,

starting speed of DGs is ited, warmup is limited to this lower speed, and the DGs re gradually accelerated to synchronous speed prio to loading. These start procedures C are the intent of M 3, which is only applicable when'such

/6 modified start pr edures are recommended >y the 1

]manuf rer.

N pG M -

be verpecb SR 3. . requires tha , at a 184 day Frequency, the DG '

g &gcete starts from standby itions and achjAves required voltage h .:4, IM and frequency within seconds. The(p)second start l

y Q c<. requirement supports e assump ons or the design basis g LOCA anal s in the FSAR, Cha p15Qef.5),

d 5 (rp The secoTd start requi t is not applicable to QW@

g Li g,f,[,y,g,4 SR 3.8.1.2 (see Note 3) who a modified start procedure as desc d above is used. ' a modified sta is not used, the start qui nt 3.8.1 es.

pertndwe for to h Oeged ince SR .1 sa start, it more I W re # strictive than SR .1.2, a it may no performed in lieu

f SR 3.8.1.2.

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T is the intent of Note 1 of SR 3.8.1.2.

@ M5W normal 31dayFrequencyfor3R3.8.1.2IsE FTapie 3.s.1-1, uiesel senerator Tant Sch M ale," in um g

( lare - -vinn train s consistent with Regu'a3o Guide .9 -

' ffg (Ref.f', 3. "he 184 day Frequency for SR 3.8. is a reductl on in cold testing consistent with Ge eric b Letter 84-15 (Ref. 7). These Frequencies provide adequate 9 assurance of DG OPERASILITY, while minimizing degradation resulting from testing.

SR 3.8.1.3 m & M* #

This Surveillance veri- les thata,he DGs are capable of synchronizing with the4ffsite X ectrical system and accepting loads M eater than or a = 1 tothemauivalentof) the maximum expected accident loads. A minimum run time of (continued)

WOG STS 8 3.8-17 Rev1,04/07/95

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7 55h CHAPTER 3.8 INSERT ZZ TO STS 3.8.1 SURVEILLANCE REQUIREMENTS BASES SECTION PAGE B 3.8-18 FNP SPECIFIC GUIDANCE TO CLARIFY THE EFFECTS OF USING THE MODIFIED START TEST METHODOLOGY During a modified start, a DG will not respond to -a ESF or LOSP signal automatically.

Therefore, the DG is considered inoperable with respect to response to ESF or LOSP signals during the brief duration of modified starts. If necessary, Operator action is required to place the speed control in automatic and reset the excitation system. This will immediately allow the DG to achieve normal voltage and frequency.

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m FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC N_Q SHE DISCUSSION 36 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.6 is removed from the TS consistent with the STS. CTS surveillance 4.8.1.1.2.c.6 verifies the DG loads do not

., exceed the 2000-hour kW rating of the DGs. This CTS surveillance exists to verify the design ESF bus loading is within the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months limits of the

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DGs and does not test any system capability or verify any system functional performance. It is proposed that the requirement to verify that the 3- permanently connected and the auto-connected loads to each emergency diesel generator do not exceed the 2000-hour rating be moved to the TRM Reliance on requirements contained in the TkM is acceptable since changes to the information in the TRM will be controlled in accordance with the guidance provided in 10 CFR 50.59. In addition, it is proposed that the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months load limits be incorporated into the TS bases with other system background information describing system operability and design, including applicable short term overload limits, consistent with the location of such information in the STS. Reliance on the information contained in the STS Bases for details related to system design is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS. Therefore, details of system design do not need to be included in the TS to be adequately I controlled and the incorporation of this information to the TS bases is acceptable.

37 M CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.7 which verifies the DG capability to l synchronize with an offsite power source and transfer ESF loads to that source is revised consistent with the STS. The CTS surveillance is -

modified by an STS note. The STS note restricts performance of this surveillance to Modes of operation other than 1,2,3, or 4. As this CTS surveillance requires that power to an ESF bus be transferred between the DG and an offsite source while supplying the ESF loads, it is e reasonable restriction that the performance of this surveillance not be planned in Modes 1,2,3, or 4 when the ESF bus is required operable. As such this restriction is appropriate for, and applicable to, FNP. However, since this STS note introduces a restriction in the performance of this surveillance that is not specified in the CTS, the introduction of this STS note is considered a more restrictive change.

38 M CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.8 which verifies the capability of an Chapter 3.8 E2-20 A April,1999

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CHAPTER 3.8 INSERT Z STS BASES PAGE B 3.8-1 In addition to providing a pre-determined sequence ofloading the DGs, the train A and train B automatic load sequencers also function to actuate the required ESF loads on the offsite circuits.

When offsite power is available, the automatic load sequencers function to simultaneously start the required ESF loads upon receipt of an SI actuation signal.

The onsite standby power source is provided from 4 DGs (1-2A, IB,2B, and 1C). The DGs are of two different sizes. The IB,2B, and 1-2A DGs are rated at 4075 kW and the 1C DG is rated

- at 2850kW. DG l-2A and 1-C are assigned to the raduad=at load group train A. The train A load group is supplied from 4160V emergency busses F, H, and K. The 4160V H bus does not supply any design basis required loads by itself but is required to support the operation of DG 1C '

to supply the emergency busses F and K which in tum supply design basis required loads. DGs IB and 2B are assigned to the redundant load group train B. The train B load group is supplied from 4160V emergency busses G, J, and L. The 4160V bus J does not supply any design basis required loads and is only required for the response to a station blackout which is not a design basis accident. ,

DGs IB and 2B are dedicated to train B of Unit I and Unit 2, respectively and each DG comprises a required DG set for it's associated unit. DGs 1-2A and IC are dedicated to train A but are shared between both units and together comprise a required DG set for both units.

However, there are no design basis events in which DG l-2A or IC are required to supply power to the sa'ety loads of both units simultaneously. In all events, DG l-2A and IC are assigned to only one of the two units depending on the event.

The 4.16kV emergency busses required to supply equipment essential for safe shutdown of the plant are F, G, H, J, K and L for each unit. These are supplied by two startup transformers on )

each unit connected to'the offsite source during normal and emergency operating conditions. In ] '

the event one startup transfonner on a unit fails, three of the emergency busses on that unit will be de-energized with their loss annunciated in the Main Control Room. The respective busses Diesel Generators will start and LOSP loads will be sequenced on to those busses. In the event Diesels fail, manual action will be required to re-energize the affected busses from the other startup transformer for that unit, g[

Chapter 3.8 Insert Page v.;

4 Associated Package Changes for RAI-3.8.1 12 1

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FNP TS Conversion' Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES -OPERATING DOC ,

NQ SHE DISCUSSION

'36 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.6 is removed from the TS consistent with the STS. CTS survaitI= ace 4.8.1.1.2.c.6 verifies the DG loads do not exceed the 2000-hour kW rating of the DGs. This CTS surveillance exists to verify the design ESF bus loading is within the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months limits of the r -

DGs and does not test any system capability or verify any system functional perfar==ae* It is proposed that the requimment to verify that the per=maantly connected and the auto connected loads to each emergency diesel generator do not exceed the 2000. hour rating be moved to the TRM.

Reliance on requirements ca=*=inad in the TRM is acceptable since d e to the information in the TRM will be contmtled in accordance with the guidance provided in 10 CFR 50.59. In addition, it is proposed that the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months load limits be incorporated into the TS bases with other system background information ?=E system 5 operability and design, including applicable short term overload limits, eaanieraat with the location of such information in the STS. Reliance on the information caatainad in the STS Bases for details related to system design is acceptable since ek a.=== to the information in the bases is controlled by the Bases Control Program speci5ed in the administrative controls section of the TS. Therefore, details l ofsystem design do not need to be included in the,TS to be adequately controlled and the liw=Moc of this ininnation to the TS bases is acceptable.

37 M CTS 3/4.8.1.1 surveillance 4.8.1 J .2.c.7 w!dch verifies the DG capability to synchmaize with an offsite pown wurce sad transfer ESF loads to that source is revised consistent with te STS. 'Ibe CTS surveillance is modinA by an STS note. The S'i$ note restricts perfonmance of 6 surveillance to Modes ofoperation otEx than 1,2,3, or 4. As this CTS surveillance requites that power to an ESF bus be transferred L c.s the DG and an offsite tource while supplying the ESF Icads, it is a reasonable restriction that the performance of tMs surveillance not be pr=aad in Modes 1,2,3, or 4 when the ESF bus is required operable. As such &

A mstriiction is appropriate for, and applicable to, FNP. However, since this g, d 33 STS note introdurm a restriction in the pafwir. -uce of ahis surveillance that is not specified in tte CTS, the introduedon of this STS note is considered a r man: sestrictive chage.

38 ' Nottsed.

Chuptr 3.8 El-20.A Apri!!,1999 j hy W I I\ '[ q l < -"

/ '75 ACsources-oP*rjti"i g SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1 -------------- NOT E------ ----------- p T5TF-8 c 4 4.t.I.l.1.c.1 This Surveillance shall not be nerfsmed ;

in MODE 1. 2. 3. nr 4.IHowever, cred' t may i taaen for unplanned events 'that satisfyj this SRJ' .

Verify each DG: 18 months

a. Synchronizeswithofisitepowersource while loaded with emergency loads upon .

a simulated restoration of offsite <

power;

b. Transfers loads to offsite power source; and

$ c. Returns to ready-to-load operation.

W J l 3.8.1. - I-cm is surveillance s'h ali not be performedf 4 M 4 h ce8 n MD)E 1. 2. 3. or 4.JHowever, credit may i T36-6 (Lthis SR.rse sauen for unplannirsvents that satg'i "' '

/

Verify, with a DG operating in test made 18 months and connected to its bus, an actual or simulated ESF actuation signal overrides -

j the test mode by g j O h turning DG to ready-to-load

^

O operationp; and i b. Automatically energizing the emergency l

( loadfromoffsitepower]. j 5 .-

(continued)

I I

WDG STS -

3.8-14 Rev 1, 04/07/95

FNP TS Conversion l Enclosure 5 -JD from STS j Chapter 3.8 - Electrical Power Systems 1 STS 3.8.1 AC SOURCES - OPERATING l

FNPITS 3.8.1 AC SOURCES -OPERATING I I

.TD j NUMBER JUSTIFICATION i giorm this surveillance after the DG is shutdown. The 10 minuta allowance is l consistent with the m.=+,= 4=g CTS survaillmaca requirement. Herefore, this change inmintains the requirements of the FNP CTS.

28 The STS surveillance SR 3.8.1.15 is revised consistent with the FNP CTS. The

upper kW load and frequency limits of the STS surveillance are deleted. These !

siing FNP CTS requirements. Therefore,rthis change maintains the S.. =ts of the FNP CTS.

[ g$ 3,fV limits do not appear in the w.w .".

1

. 28a STS surveillance SR 3.8.1.17 Note 1 is deleted consistent with the FNP CTS. The STS Note which precludes pfc ===ce of the DG test which verifies the capability of an ESF actuation to override the DG test mode by 4e =5 the DG to ready to

. load condition in Modes 1,2,3, and 4 is an operating restriction that is not part of the FNP CTS. Herefore, deletion of this note maintaina the requirements of the FNP CTS. , ,

l 29' De STS surveillance SR 3.8.1.18 is revised consistent with the FNP ITS. The note !

modifying this STS surveillance precludes the gf( === of this surveillance in j Modes 1-4. This~notew.a an cg41sg restriction that is not present in the j FNP CTS and is deleted from the FNP ITS. As such, this change maintains the I' requirements of the FNP CTS 30 The STS surveillance SR 3.8.1.18 is revised consistent with the FNP ITS. De surveillance is revised to incorporate the FNP CTS altammte criteria (0.5 secaaA=)

I for the sequencer load block time interval verification. This change maintai,ns the requiremante of the FNP CTS. f

)

31 The STS surveillance SR 3.8.1.20 (FNP ITS SR 3.8.1.19 simultaneous DG fast start test) is revised consistent with the acc=p =e criteria for other DG fast start tests in FNP ITS 3.8.1 and with the DG fast start test requirements in the CTS (4.8.1.1.2.a.4). The upper voltage and neqsescy limits are deleted consistent with the CTS surveillance 4.8.1.1.2.a.4 and the guidance provided in Regulatory Guide 1.9, Rev 0,3/71 for " start test". His change maint2ina the FNP CTS rgs-ents for the DG fast start test and makes the r%4-. 3 for this type of test consistent within the FNPITS.

32 STS Table 3.8.1-1 is deleted consistent with the guidance provided in NRC Generic Letter (GL) 94-01. GL 94 01 provides' guidance that allows removal of the j accelerated testing requirements specified in the TS (STS Table 3.8.1 1) provided i Chapter 3.8 E5-8-A April,1999 !

. l

l 27R AC Sources - Operating 8 3.8.1 I II w/

BASES SURVEILLANCE SR 3.8.1. ' continued)

REQUIRENENTS f / -

1 This testing may include any series of sequential, l overlapping, or total steps so that the entire connection I and ding sequ nce is verified.

Theh18 month Frequency is consistent with the gp recossendations of Regulatory Guide 1.108JRef. 9),

paragraph 2.a.(8)f tates into consiaeresion unit conditionh

[ j r 3,$.1

, /ferquireo so perrors the Surveillance, and is intended to hel { l

iEonsistent with. expected fuel cycle length 3. '

x _. -

fisSRismodifiedbyaNote. The reason for the Note is that performing the Surveillance would remove a required -

>L j

offsite circuit from service, perturb the electrical _

gps wistribution system. and chaiie, p.y oe taran rar uanimaand evenus e <><

tiat + tvitems.fer.di)tT satisfy this SR.

j SR 3.8.1.

h 1 p h Underaccidntkndlossofoffsitepower)c itions loads g.@ are sequen ally cenneuse so sne sus oy i.no automatic load se pencer . The sequencing logic controls the permissive l ana w ng signals to motor breakers to prevent I or 0.!I195tortk& overl of the DGs due to high motor starting currents.

w Q ever The oad sequence time interval tolerance ensures that su m cient time exists for the DG to restore frequency and a hmier . voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delan are not violated. Reference 2 provides a sussary of the -

aujonatic loading of ESF. buses. .

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

pa.ragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. p fThis is modifi a Note. e reason for Note 1 that rforming t Surveillanc uld remove a utred

- 23 off te circuit service, urb the el ical di ribution sys . ad

= ch=11 as <= Fat" sys

. I'C@t t )

l isaf a taken forf unplanned eve 6ts that satisfy this S{. J nTF-8 (continued)

WOG STS 8 3.8-30 Rev1,04/07/95 l

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i Associated Package Changes for RAI - 3.8.1-17 i f

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22.mcTnIc1L DOWER SYSTEMS

)

EURVE8MCE REQtTIREMElffS (Continued)

) Coolant Temperature Eigh (CTN) IW~~

c) Coolant Pressure Low (CPL) 4 1 l

d) Crankcase Pressure Eigh (CCPH) g7

11. Verifyingthecapabilitytorejectaloadofgreahrthanor equal to the largest single load associated with Ahat emergency diesel generator d==raintely 1000 kwD while maintaining voltage between 374o and 4580 volta and speed less than or equal to 75% of the difference between nominal gf speed and the oversneed trio setpoint. -

0 d & 3R3A af At least once per lo yearsfr aft.or any modificati_ons which coul)

(arrect emergency diesel generator interdepaad scelby starting the gg

//1fqf/ emergency diesel generators simultaneously, and verifying that _th Sf 3f /,/f emergency diesel generators accelerate to at leastJoo rpm, for the asso kw generator =ad su rne for the 4075 kw venerators in jn/p/~5 less than or equal to 12 see d . as gr.],

/ LA e.

At least once per 5 years 7@ a staooered h==isTDy veriffing N3 the emergency diesel generator can reject a load of 1200-2400 kw without tripping. JThe emitgency asesel generator output

/Freaker(s) must remain closed such that the emergency diesel 4y generator is connected to at least one emergency bus. Verify tha I all fuses =ad breakers an the eneraised emergency bus (es) are no 4/

i ripped] The generator ve,1tage shall remain wi 3330 and 4990 4.4 l voltaT during and following the load rejection. ** l I

_ d[.J,d //8' Q '.S R 3.3.l.lf M Chr. a,nd, 3152h.

(p t

4 l'*

f I

e gA p ). SR 3.F.1.17 M p Y ____

r** Testing of the shared Emergency Diesel Gonarator (EDG) Jet (EDG 1-2A or n EDG 1C) on Unit 2 may be used to satisfy this surveillance require 1nent for}

those EDGs. '

j FARLEY-tBf1T 1 3/4 8-6 AMEMDMENT No. 57,191,129 e 9

I- - - _ __ - . _ . _ _ _ _ . _ _ _ _ _ . _ _ . _ _ . _ _ _ _ . _ _ _ __.___ _ . - -

r.

FNP TS Conversion Enclosure 2 - Discussion of Changes'to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES OPERATING

-DOC N.Q jiHE DISCUSSION scheduling), in most cases has negligible impact on component reliability, j may result in more frequent reductions in system radundancy for testing 1 purposes, and increases the likelihood of human error by increasing the number of separate test evolutions. As such, the deletion of the staggered

, testing requirement for this DG surveillance is consistent with the STS and also acceptable, i 43 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.e is revised consistent with the STS.

This CTS surveillance for DG large load rejection test contains details of a procedural nature involving specific equipment checks (fuse and breaker status). This procedural infonnation represents a type of detail that is not O typically included in the corresponding STS surveillance. It is proposed that the CTS surveillance procedural information be moved into the i

')9,V corresponding ITS surveillance SR 3.8.1.18 bases. The removal from the CTS of descriptive guidance inclusion of this information in the ITS bases is consistent with the format and presentation of such information in the STS. In addition, reliance on the information contained in the ITS bases for guidance in performing the associated surveillances is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

43a A CTS 3/4.8.1.1 surveillance 4.8.1.1.2.e is modified by a ** footnote which provides guidance regarding the testing of the shared DGs. The CTS footnote allows testing on either unit to satisfy the shared DG surveillance ,

requirements for both units such that redundant testing is not perfonned on p the shared DGs. The CTS footnote is consistent with the intent of the ITS load rejection surveillance test which is to test the DGs and not the 3,q.V associated unit loads or buses. Therefore, this note is incorporated into the FNP ITS as a note for SR 3.8.1.18. As this change merely affects the format of the note and not the content, it is an administrative change.

4 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.11 is revised consistent with the STS.

This CTS surveillance for DG single load rejection test contains detail not included in the corresponding STS surveillance. The CTS surveillance contains the approximate kW load that corresponds to the single largest ;

load. The STS requires the specific load that is identified as the single largest be named and ius horsepower identified in the STS bases. For FNP this load is a charging pump. As such, this CTS information is effectively Chapter 3.8 E2-22-A April,1999

y I70 AC Sources - Oporating ,

3.8.1 j SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

B _ _

SR 3.8.1.5 ------------------ NOT E S ---------------- ' - -

1. s Surveillance shall not 4,g,i,1,1,c., g l per E . owever M *N aNsbths W rmed with the DG sonchsentred with otr m . --- d I be Verify each DG rejects a load greater tha'n" 18 month .

or equal to its associated single largest post-accident load, and: ,

g, 75 % ,

a. Following load re;ection, the < d M C. S f8 O I

)

(requency is s [eaj nz; F g g norni d

b. Within[3]second]/dllowingload 6@f a m. '

tage is 203740 V ove,rSpeO:b b.P rejection, a$ s j 584lthe V; vo' and mt; I x m

6. Ithi [3] econd foll ing 1 ad

@ rej ion, he f m( .8] and [61.

en is Hz. a~

l{,

- ia

_ _ _' A at~<<g g v g 3

- SR 3.8.1. --

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

nce shall not c.T3 4 8.l.l.1.e. This in MODE 1 or N . ,

ormed redit may be / TyfAIS (1f' I

.g n r unpi - e that satisfy )

-hy-Mifh

[Ich V o

e Ve i fv (peraune at a power facto [

T.9] oes et trJgrand vo tage is s q,5gg) V duri nd following N {8 months q .malnta' a load 1 tion of a k sf55W kW. 200 19 w- -

(continued) 7 W s.i y GT 4 u-o terva L(Tyem ~-

WOG STS 3.8-9 Rev 1, 04/07/95

^'

c .

\70%

CHAPTER 3.8 INSERT YY TO STS PAGE 3.8-9 NEW ITS SR 3.8.1.18 NOTE i

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

l Testing of the shared Emergency Diesel Generator (EDG) set (EDG 1 2A or EDG 1C) on j either unit may be used to satisfy this surveillance requirement for these EDGs for both l

units. j l

9"\

\

)

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Chapter 3.8 Insert Page

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING JD NUMBER JUSTIFICATION 18a FNP ITS SR 3.8.1.18 is modified by a note consistent with the CTS 3/4.8.1.1 surveillance 4.8.1.1.2.e " footnote which provides guidance regarding the testing of the shared DGs. The CTS footnote allows testing on either unit to satisfy the l shared DG surveillance requirements for both units such that redundant testing is

[g y not performed on the shared DGs. The CTS footnote is consistent with the intent of the ITS load rejection surveillance test which is to test tne DGs and not the 3g associated unit loads or buses. Therefore, this note is incorporated into the FNP ITS as a note for SR 3.8.1.18. This change maintains the requirements of the FNP CTS.

19 The STS surveillance SR 3.8.1.10 power factor requirement is deleted consistent with the FNP CTS. The STS surveillance specifies a power factor requirement for the performance of the DG large load rejection test. This requirement represents an additional TS restriction that is not part of the FNP CTS. Therefore, deletion of this STS requirement maintains the requirements of the FNP CTS.

19a Note 2 in STS surveillance SR 3.8.1.12 (FNP ITS SR 3.8.1.10) is revised consistent with the corresponding CTS surveillance requirements (4.8.1.1.2.c.3). The current FNP surveillance does not prohibit the start of the EDGs on a simulated ESF signal in Modes 1 and 2. The fast start to standby condition of an EDG on a simulated ESF signal does not introduce any perturbation to the onsite 4160 kV buses and per the current FNP technical specifications may be performed at any time to confirm

]

the EDG response to an ESF actuation signal. The STS Note which prohibits the performance of this surveillance in Modes I and 2 is revised to apply only to that part of the surveillance which would cause a perturbation to the affected E.SF buses (SR 3.8.1.10.d and e). The intent of SR 3.8.1.10.d and e is to verify the correct ESF bus loading from offsite power on a simulated or actual ESF actuation signal. To avoid an unnecessary perturbation to the ESF buses during operation, SR 3.8.1.10.d and e should not be performed in Modes 1 and 2. The proposed revision of the STS Note 2 accomplishes this and confonns with the current FNP licensing basis as specified in the CTS.

20 The STS surveillance SR 3.8.1.12 is revised consistent with the corresponding FNP CTS (4.8.1.1.2.c.3 as modified by applicable DOCS). The upper voltage and -

frequency limits are deleted from the 12 second start requirements and included in i the steady state 5 minute operation requirement. This change is consistcnt with the l FNP CTS and maintains the current requirements.

Chapter 3.8 ES-6-A April,1999 l

l l

r 2W CHAPTER 3.8 INSERT VV TO STS BASES PAGE B3.8-22 d FNP SPECIFIC GUIDANCE TO CLARIFY THE t

SI REQUIREMENTS REGARDING SHARED DGs Y

This surveillance is modified by a note which states that testing of the shared Emergency Diesel Generator (EDG) set (EDG l-2A or EDG l C) on either unit may be used to satisfy this surveillance requirement for these EDGs for both units. The surveillance requirement consists of sufficient testing to demonstrate that each DG, the DG output breaker, and bus fuses and breakers can succeufully withstand a 1200-2400 kW load rejection on each unit. This does not require, however, that each shared DG be aligned to each unit and a load rejection be performed in a redundant fashion. This surveillance is intended to assure the correct performance of the DG c- voltage regulators and governors.

c)

Chapter 3.8 Insert Page

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Associated Package Cb.anges for RAI- 3.8.1-18 l

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9 CHAPTER 3.8 INSERT C TO CTS PAGE 3/4 8-2 NEW STS NOTE AFFECTING CTS ACTION C (STS CONDITION D)

. NOTE- ---- --

Enter applicable Conditions and Required Actions of LCO 3.8.9," Distribution Systems - Operating," when Condition D is entered with no AC power source to any train.

INSERT D TO CTS PAGE 3/4 8-2 NEW STS ACTION C.1 ,

C.1 Declare required feature (s) inoperable when its 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of redundant required feature (s) is inoperable. Condition C concurrent with inoperability ofredundant required feature (s)

AND INSERT TT TO CTS PAGE 3/4 8 2 NEW ACTIONS CONDITION F FOR INOPERABLE SEQUENCER G. One automatic load sequencer G.1 Restoreautomaticload 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable. . sequencer to OPERABLE status.

WG 3,g.1 Chapter 3.8 Insert Page

b .

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC HQ SHE DISCUSSION repeated in each Condition that has the same inoperable source in it. When Condition E is entered for two inoperable DG sets, Condition B is also entered for each inoperable DG set individually. Therefore, the CTS requirements to demonstrate the operability of the offsite circuits under these circumstances are covered under Condition B in the ITS and are deleted from CTS 3.8.1.1 Action stdement "e" consistent with the STS.

13 A The CTS 3.8.1.1 Action statement "e" for two inoperable DG sets is revised by the deletion of the reference to both units. As one DG set is common to both units and the FNP ITS 3.8.1 is a common TS for both units, the corresponding STS Required Actions B.3.1 and B.3.2 would be applicable to each unit individually when the Common DG set becomes inoperable.

As such, the common-mode failure assessment or DG start requirements of i the STS Required Actions are applicable to each unit and the specific instructions included in the CTS regarding the application of this action to both units is unnecessary. This change conforms to the format of a single TS for both units and the convention that the actions apply individually to each unit. As such this change is considered administrative in nature.

13a M A new Actions Condition is added to CTS 3/4.8.1 consistent with the STS.

STS Condition G addresses the condition of one automatic load sequencer inoperable. This STS Condition is intended for plants where the electrical system design is such that the operability of the sequencer affects the

] operability of the associated offsite circuit and DG in that train. The FNP electrical system is designed such that the sequencer is required to sequence 4 loads on the DG when no offsite power is available. In addition, when p

psp / offsite power is available, the sequencer functions to actuate the required ESF loads simultaneously on the offsite circuit upon receipt of an SI signal.

As such, the basis for this STS Condition is consistent with the FNP electrical system design and this Actions Condition is included in the FNP l1 ITS. The basis for this new Actions Condition is consistent with the FNP electrical system design and the addition of this new Condition provides an appropriate action for a specific inoperability not previously addressed in the CTS. As such, this STS Condition is applicable and appropriate for FNP. However, the inclusion of this STS Condition represents the addition of a new TS requirement not specified in the CTS. Therefore, this change is considered more restrictive.

Chapter 3.8 E2-7-A April,1999

16 6 ACSources-Operatihg 3.8.1 ACTIONS (continued)

CONDITION g REQUIRED ACTION COMPLETION TIME G. k--REVIEWER'SNOTE RestoreCrequiredD hours

.This Condition may be Nautomatleload deleted if the unit sequencer t design is such that , OPERABLE s @tatus.

any sequencer failure mode will only affect fy40 the ability of the ,

gS- associated DG to power its respective safety .

Ioads following a '

loss of offsite power independent of, or coincident with, a Design Basis Event.

one frequiredD Nautomaucinad sequencer inoperable.

N' Required Action and Bo in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated C tion

)' Ti B,

f Condi , SQ H

or t . Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. '

I I

$1 Enter LC0 3.0.3. Immediately V_$kIhreeorhre grequired inoperable.

sources p '

WOG STS 3.8-5 Rev1,04/07/95

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING JD NUMBER JUSTIFICATION Completion Times are consistent with the times provided in CTS 3.8.1.1 Action Statement (e) which addresses the Condition of both DG sets inoperable. The CTS

[ [ ,0 action times provide a more flexible response consistent with the 3 DG design of FNP.

l 7a Not used.

8 The STS 3.8.1 Conditions are revised by the addition of a new Condition F containing a Required Action and Completion Time consistent with the FNP CTS.

The new FNP ITS Condition F which provides the default action for Conditions C and E replaces the default FNP ITS Condition H for those Conditions. Conditions C and E provide actions for 2 inoperable offsite circuits (C) and 2 inoperable DG j sets (E) and correspond to CTS Action Statements (d) and (e) in CTS 3.8.1.1. The default action of the proposed FNP ITS Condition requires the unit be placed in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and does not require that the unit be placed in Mode 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months as required by the STS. This action and Completion Time are the same as specified in CTS Action Statements (d) and (e) for the same unit conditions. Although the immediate CTS default actions for 2 inoperable offsite circuits and 2 inoperable DGs only requires a power reduction to Mode 3, the requirement to restore one offsite circuit (FNP ITS Condition A) or one DG set (FNP ITS Condition B) continue to be spplicable with two offsite circuits or two DGs inoperable and do require entry into Mode 5 if the inoperable offsite circuit or l '

DG set is not restored. The Completion Times of these Conditions to reach Mode 5 commence from the initial loss of a DG or offsite circuit (Condition A or B entry).

Since Conditions A and B would remain applicable as long as any required offsite j circuit or DG is inoperable, these Conditions effectively require both offsite circuits I i

or DGs be restored to operable status or that the affected unit (s) be placed in Mode

5. Therefore, the Completion Times of FNP ITS Conditions A and B will govem the time to reach Mode 5 for FNP ITS Conditions C and E as well. This change is consistent with the FNP CTS as specified in CTS 3.8.1.1 Action Statements (d) and (e) which effectively contain the actions for 1 and 2 inoperable offsite circuits or DG sets.

9 The STS surveillance requirement SR 3.8.1.7 (FNP ITS 3.8.1.6) is revised consistent with the CTS. The upper voltage and frequency limits are deleted consistent with the CTS surveillance 4.8.1.1.2.a.4 and the guidance provided in Regulatory Guide 1.9, Rev 0,3/71 for " start test". This change maintains the FNP CTS requirements for the DG fast start test.

Chapter 3.8 E5-3-A April,1999 l

l

1

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. 954 AC Scurc'es - Operating 8 3.8.1 8ASES ACTIONS E.J (continued) 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 T6C i power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the

.g.g y p time allowed for continGed 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. gg g.$> (Becordina to Reference 6J h both _ noperab e, operation may continue for a periWan snouia not exc A

q hour M E-PS MD W"O 81F, 31

%g l$*re@ @i_ den he.~$LE or%r2 rromngoPER3 _

EM%M56WOx 4 ggJ an ~ The sequencer ( essential support systes to 5 th th offsite circuit a the DG associated with a given dSF bus .

B24 Furthennore. the sequencer is on the primary success path or most sab AC electrically powe safety systems powered from the a ed ESF bus.: herefore, loss of an M' n TESFbussepanc acts every ma;or ESF system in the 4 aivision F The - our Completion. Time provides a period of time to corr e problem commensurate with the importance of maintaining sequencer OPERASILITY. This time period also ensures that the probability of an accident -

,7 .l A (requiring sequencer OPERA 8ILITY) occurrinci during periods when the sequencer is inoperable is minisa' .

'This Condition is preceded by a llote Inst allows the N A Condition to be deleted if the unit design is such that anyT sequencer failure mode will only affeci, the ability of the

. associated DG to power its respective safety loads under an)

C conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety; Jsduringaneventandtherebycausesitsfailure. Also f _

(continued)

WOG STS B 3.8-14 Rev 1, 04/07/95 m-m

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{

l Associated Package Changes for RAIs 3.8.1-19,3.8.120, and 3.8.126 1

. R FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC NQ. SHE DISCUSSION these particular requirements in the bases is acceptable considering that the DG voltage and frequency requirements of this surveillance are verified in other surveillances and continue to be in the TS (SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.17). In addition, reliance on the information contained in the STS bases for guidance in performing the associated surveillances is acceptable

. since changes to the infonnation in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

33 'A. CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.5 is revised consistent with the STS.

This CTS surveillance for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months full load run of the DGs is modified with a note consistent with the STS, modified to reflect FNP requirements far the surveillance. The note provides a clarification that momentary g[(% transients below the minimum load specified do not invalidate the surveillance test and does not significantly impact this CTS surveillance as performed currently at FNP. In addition, the STS Note does not change the j technical intent of the surveillance. Therefore, the addition of this note is l considered an administrative change to incorporate the STS guidance for performing this surveillance.

34 A CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.5 is revised consistent with the STS.

This CTS surveillance consists of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months full load DG run followed by a hot restart. test of the DG. In the STS this DG surveillance is divided into two separate surveillances, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run and a hot restart test. The STS hot restart test requires that the DG be run 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at full load prior to the restart. The DG run time specified in the STS (2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at full load) is sufficient to ensure the DG has achieved hot conditions and the operating temperature is stabilized, additional run time will not affect DG operating temperatures. The separation of these two surveillances provides operational flexibility and is specifically recommoded by the NRC in Section 10, Electrical Power, of NUREG-1366, "Iraprovements to Technical Specification Surveillance Requirements". The separation of )

I these two surveillances is not intended to introduce a technical change, the hot restart is still required to be performed at hot DG conditions and two l hours run time at full load is sufficient to ensure stable hot DG temperatures. The separate STS hot restart test satisfies the technical intent of the surveillance test as effectively as the CTS requirement. Therefore, this change is considered an administrative change to conform with the Chapter 3.8 - E2-18-A April,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.fi.1 AC SOURCES - OPERATING DOC hlQ Sig QISCUSSION l format of these surveillances in the STS. i 35 A- CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.5 is revised consistent with the STS, l modified to reflect FNP requirements for the surveillance. The hot restart portion of this CTS surveillance is modified by STS notes similar to the' y notes included in the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run portion of this CTS surveillance. The STS notes for this portion of the surveillance include the new run time criteria of;t 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at full load, the fact that momentary transients below . ,

the minimum load specified do not invalidate the test, and that DG stans N

[3iy ~

may be preceded by an engine prelube. The notes provide clarifications that do not significmtly impact this CTS surveillance as performed currently at FNP. In addit!.on, the STS Notes do not change the technical intent of the I I

surveillance. Therefore, the addition of these notes is considered an administrative change to incorporate the STS guidance for performing this surveillance.

36 LA CTS 3/4.8.1.1 surveillance 4.8.1.1.2.c.6 is re:noved from the TS consistent l with the STS. CTS surveillance 4.8.1.1.2.c.6 verifies the DG loads do not I exceed the 2000-hour kW rating of the IX3s. This CTS semeillance exists I to verify the design ESF bus loading is within the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months limits of the DGs and does not test any system capability or verify any system functional performance. It is proposed that the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months load limits be moved into the TS bases with other system background information describing system operabilitty and design, including applicable short term overload limits, consistent with the location of such information in the STS. The design of the facility is required to be described in the FSAR by 10 CFR 50.36, however, in the STS, the TS bases also contain information regarding system design and operability. In addition, The quality assurance (QA) requirements of Appendix B to 10 CFR Part 50 require that plant design be docwnented in controlled procedures and drawings, and maintained in accordance with an NRC-approved QA plan. 10 CFR 50.59 specifies controls for changing the facility as described in the FSAR,10 CFR 50.4 for changing the QA plan, and the Bas es Control Program for changes made ,

to the TS bases. Therefore, details of system design do not need to be f included in the TS to be adequately controlled and the movement of this information to the TS bases is acceptable.

37 M- CTS 3/4.8.1.1 surveillance 4.3.1.1.2.c.7 which verifies the DG crpability to j Chapter 3.8 E2-19-A April,1999 l

174 AC Sources - Operating 3.8.1 4 beb &c, mm.m 2g SpRVEILLANCEREQUIREMENTS (continued) , (**A 5984 L R.

SURVEILLANCE [ [ FREQUENCY SR 3.8.1. --

--NOTE --

---------[

C TS 4 6.l.l. 1.C. 5 .

Momentary ransient_sfuts'detheload) i (24Aowrun) dind namer factar8(ggggfdo not )

<nya'idate this test.

p )

-rst-S

DodE!P:WN V a s 2

3 3l00 W l Vai fw ach DG enerating at a power facto 18 months hr g L @ [0.9:IoperatesforaZ4nours:

g N a. For k hoyrs loaded a W anC forhe.4075

. For the rema<n ni hours of the test kg DGs oud.h2.BSC ,

g loaded a d45(0; .cW and s [5000] WJ kw for%e,285o= R.g n 5* W 13 to' SR 3.'8.1 ---

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

{

05 4,$,1,1,2..C.s 1. This Su 111ance shall be performed '

Qer stu.7) wifpin nutes of shutting down the 1 DG7after the DG has o wratod Rs a hMFwars loaded m{4500; m.

WJ sin "

g _ (s ;500% ggy Ag gee l j i Nome ry transients ma " E a do not invalidate this test.

a' =m

)k-

} 2. All DG starts may be preceded by an engine prelube period. 73 I' i Ve Leach DG starts and ar vs n 18 months Q st > neconds. voltage a 6740 nd3 V and Hz. @

js 61.2' Hz. (Jfrequency mi'58.8

%['4510: . go I'

(continued)

WOG STS 3.8-13 Rev 1, 04/07/95

. I FNP TS Conversion I Enclosure 5 - JD from STS !

Chapter 3.8 - Electrical Power Systems STS 3.8.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING JD NUMBER JUSTIFICATION 21 The STS surveillace SR 3.8.1.13 is revised consistent with the FNP CTS. The STS note which modifies this surveillance is deleted. The STS note precludes the performance of the automatic trip bypass verification surveillances in Modes I and

2. This STS note represents an operating restriction that is not present in the FNP CTS. As such, this change maintains the requirements of the FNP CTS.

22 The STS su. ceillance SR 3.8.1.13 is revised consistent with the FNP CTS. The STS phrase " concurrent with"is replaced by the FNP CTS wording of"and/or".

The FNP CTS term more accurately describes the operation of the auto trip bipass ;

function which operates when either the ESF or the loss of power actuation signals are present or when both are present. As such, this change maintains the

)

i requirements of the FNP CTS.

f1 23 The STS surveillance SR 3.8.1.13 is revised consistent with the FNP CTS. The STS surveillance list of trip exceptions for the trip bypass function test is revised consistent with the trips listed in the FNP CTS. As such, this change maintains the ;

requirements of the FNP CTS.

24 The STS surveillance SR 3.8.1.14 is revised consistent with the FNP CTS. The STS surveillance Note 2 is deleted. STS Note 2 precludes performing the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

. DG run test in Modes I and 2. This note represents an operating restriction that is not present in the FNP CTS. As such, this change maintains the requirements of the FNP CTS.

25 STS surveillance SR 3.8.1.14 is revised to delete the power factor requirement consistent with the FNP CTS. The STS surveillance specifies a power factor requirement for the performance of the DG 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run. This requirement represents an additional TS restriction that is not part of the FNP CTS. ' Therefore, deletion of this STS requirement maintains the requirements of the FNP CTS.

25a Notes for STS surveillances SR 3.8.1.14 and SR 3.8.1.15 are modified to reflect FNP requirements for the surveillance. ITS SR 3.8.1.12 and Note 1 for ITS SR

[6 pY o 3.8.1.13 do not specify a load range, they specify minimum allowable valu.s. The notes are revised to provide a clarification that momentary transients below the g.\y rninimum load specified do not invalidate the surveillance test. This change is T' made to maintain the intent of the notes based on FNP requirements for the surveillances.

26 The STS surveillance SR 3.8.1.14 is revised consistent with the FNP CTS. The Chapter 3.8 ES-7-A April,1999

. O AC Sources - Operating B 3.8.1 BASES SURVEILLANCE Sf 3.8.1. continued)

REQUIREMENTS y -

The$18 month Frequency is consistent with the recommendaticas of Regulatory Guide 1.108 (Ref. 9), i paragraph 2.a.(3), takes into consideration unit conditions I required to perforin the Surveillance, and is intended to be consistent with expected fuel cycle 1 h ge,

, This Surveillance is modified by . %te s )

that momentary transien_ts due to anging bus loads do not h !

invalidate this testd simi riy, tary p ractor 1

~transi ts anove he power actor lie t will invali te the t t. The ason for to 2 is at duri operat n j with he react critical performa e of thi Surveil anc

%"Iq }

coul cause sys urbation to the el trical < stribut on that ould chal nge conti ved stea state ation a . an a ca. 1+ unit fety sys isJCrpdit pay p I haItakan for/uno' annedInvaa+= M **

=Q3h's SR. p g4 SR 3.s.1 12, This Surveillance demonstr s that tio iesel engine can restart from a hot condit n, such as su to shutdown from normal Surveillant.aj and achieve fred voltage and frequency within(To seconds. The second time is i derived from the requPresents of the acc ana respond to a design basis large break LOCA. The 8 monthdr is to M Frequency is consistent with the recommenda.tions f l Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5). l l

This SR is modified by two Notes. Note 1 ensures that the I test is performed with the diesel sufficiently hot. e I g Toad cana is provicea to avvia rvvi.ine overloacing of the [ l Routine nspections overloads may in accordance result with ver. dam inrev morendations_in-frequent teardo)wn M g> rder to main +=in ne opFRAnfiTTYJ requirement that the usi diesel has operated for at least hours at full load G conditions prior to performance o this Surveillance is $,f aser fa manufacturer recommendations for achieving hot cond t<ons. Momentary transients due to changing bus loads

$yp 5 do not invalidate this test. Note 2 allows all DG starts to '>3 be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

(continued)

WOG STS 8 3.8-28 Rev 1, 04/07/95 l l

1 Associated Package Changes for RAI 3.8.1-22 I

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l 8ASES l l

ACTIONS C.1 and C.2 (continued) continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If two offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition A. .

D.1 and 0.2 i 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 D are modified by a Note to indicate .

that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for LC0 3.8.9,

" Distribution Systems -0perating," must be immediately entered. This allows condition 0 to provide requirements for the loss of one offsite circuit and one DG, without regard to whether a train is de-energized. LCO 3.8.9 es the appropriate restrictions for a de-energized (According to Regulatory Guide 1.93 (Ref. 6)l peration may 24 s unue in conaiuon u ror a p.noa snas snouid not exceed l hours.

In Condition D, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by g (, ,

two diverse sources of power, however, the reliability of I the power systems in this Condition may appear higher than that in Condition C (loss of both required offsite -

g circuits). This difference in reliability i set by the susceptibility of this power system en ration to a single bus or switching failure. The . hour Completion Time takes into account the capacity and c ability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. _

[ Q % 58f 3 ,,7 WithkrainA nd Train operable, Ehere are w -

remaining standby AC sourc y Thus, wi)h an assumed loss of (SC offsite electrical power, emcientistandby AC sources 39 9 3 -

@ '3. k kh N *i""*d)

WOG STS t n & is:c ~Rev 8 3.8-131, y g

= 1,=04/07/95 Wee)<O l

~

cNh AC Sources - Operating B 3.8.1 BASES ACTIONS Ed (continued) f

% k', are availab 3 to power the minimum required ESF functions.

- d M 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 inmediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC TSC. power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the pgg time allowed for continued operation is severely restrict The intent here is to avoid the risk associated with an Zustut.T immediate controlled shutdown and to minimize the risk FT-J6 2;t associated with this level of degradation. ,

y TAccording to Reference 6, with DoEn a s inoperaole, operation may continue for a period that should not exc 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . 7 -

p3 , ,

e ..

.. ... p.

t '

B1F j Bl$

ggJ 4,nd., The sequencer (s is essential support system to ' yboth th offsite circuit a theDGassociatedwithagivendSFbush-B2G O Furthermore, the sequencer is on the primary success path or most major AC electrically powe safety systems a

powered from the a ed ESF bus. erefore, loss of an M TESFbusseguenc ects every major ESF system in the c 4aivision r The .

~

. our Completion Time provides a period of time to correc problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probabliity of an accident -

(requiring sequencer OPERABILITY) occurrinti during periods when the sequencer is inoperable is minima' .

'This Condition is preceded by a Note that allows the N,,,A ,

Condition to be deleted if the unit design is such that anyT ,

sequencer failure mode will only affect the ability of the l !

(E\ associated DG to power its respective safety loads under an)

W/ conditions. IrplicitinthisNoteistheconceptthatthe ,

Condition must be retained if any sequencer failure mode j results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety; Jsduringaneventandtherebycausesitsfailure. Also f _ j i

(continued)

WOG STS B 3.8-14 Rev1,04/07/95 l l

1

7

, 2.65 CHAPTER 3.8 INSERT F0le

.$' STS BASES PAG r. * - M With all or part of each train of DG sets inoperable, wip % wy continue for a given unit for different periods of time depending on the combinatiord.+ vidual DGs that are inoperable.

The leogth of time allowed increases with decreasing emig ut the combinations ofinoperable DGs. One set must be restored to operable status in 2 has if DGs 1-2A,1C and IB on Unit 1 or DGs 1-2A, IC and 2B on Unit 2 are inoperable. Operability of one set must be restored in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if DGs 1-2A and IB on Unit 1 or DGs 1-2A and 2B on Unit 2 are inoperable. Operability ofone set must be restored in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if DGs IC and IB on Unic 1 or DGs 1C and 2B on Unit 2 are inoperable.

INSERT FF STS BASES PAGE B 3.8-14 El Condition F provides the default Required Actions for the Conditions which address two inoperable offsite circuits or two inoperable DG sets. If the inoperable AC Sources can not be restored to OPERABLE sutus within t!.e applicable Completion Time, Required Action F.1

_ specifies that the unit be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Once shutdown, the unit is in a more stable condition and the time allowed to remain in MODE 3 is ultimately limited by the

~

Required Actions and Completion Times applicable to a single inoperable AC Source based on the time that an AC Source initially became inoperable. In addition, the Required Actions applicable to one inoperable DG set or offsite circuit would rammin applicable until both i inoperable DG sets or offsite circuits are restored to OPERABLE status or the unit is placed in a MODE in which the LCO does not apply (MODE 5). The allowed Completion Times are raWie to reach the required unit conditions from full power in an orderly manner and without challenging plant systems. .

I l

l l

Chapter 3.8 Insert Page 1

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Associated Package Changes for RAI 3.8.1-23

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. ACTIONS **-f;i- (c.aritinued) -

s ----- _ _ /

. implicit in the Nite is not a@s-Ar-any-Gain is.that M.does

, not hava a se nees..

~

. Ia i If the inoperablo AC electric power sources cannot be restored to OPER/ ALE status within the required Completion Time, the unit mist be brgught to a MODE in which the LCO does not apply. To achtete this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are .

reasonable, basel on operating experience, to reach the required unit coaditions from full power conditions in an

.,, orderly manner and with nalncL .

3 i s-m Sn,m %. c44f;w w oc.o 3.9.t

) %M hw s - % . a 4 o er w n.a..

w IY Condition all redu co i s

onds to a level of degradation in which in the AC electrical power supplies has been v

lost. t 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 LC0 3.0.3 to commence a controlled shutdown.

SUfWEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all importsr.t areas and features, especially -

those that have a standby functim, 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). Psc.,

The SRs for demonstrating the OPEAA8ILITY of +ka DGs are in-accordance with the recommendations of@latory Guide 1.9 l l Ref. 3),1Raoulatory Guide 1.108 (Ref. 9), and Regulatory J (TSC.- @ % utde 1.137 (ner. au g as addressed in the r un.

l

/

Where the SRs discussed he in pecify voltage and frequency l tolerances, the followin< s plicable. The minimum steady state output voittge of L374 V is 905 of the nominal 4160 V output voltage. 'his value, which is specified in (continued)

WOG STS B 3.8-15 Rev 1, 04/07/95

\

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1 Associated Package Changes for RAI 3.8.3 01 l

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FNP TS Conytrsion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR FNP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR JD NUMBER EJJTIFICATION 1 The STS 3.8.3 Condition B is revised to reflect the two types of DG required operable at FNP. This char;ge maintains the CTS requirements regarding the DGs, but incorporates the STS requirements to malatain sufficient tube oil for those DGs.

I 2 The STS 3.8.3 Condition E for DG starting air receiver pressure is revised

- consistent with the FNP design. The different type DGs utilized at FNP have different starting air receiver pressure requirements. In addition, each DG is I equipped with redundant air receivers only one of which is required to perform the DG start function. Therefore, the STS Condition is revised to incorporate the different starting air receiver ptesaure regtdrements of the FNP DGs and the fact that only one receiver is required. This change is consistent with the FNP specific DG design.

3 The STS surveillance SR 3.8.3 A is :evised consistent with the FNP design. The different type DGs utilized at FNP have different starting air receiver preare requirements. In addition, each DG is equipped with redundant air receiven, only one of which is required to pcfo In the DG start function. Therefore, the STS surveillance is revised to incorpcate the differrat starting air receiver pressure requirements of the FNP DGs and the fact that only one receiver is required. This change is coruistent with the FNP specific DG design.

4 The STS surveillances SR 3.8.3.5 and SR 3.8.3.6 are deleted consistent with the FNP CTS. Theae STS surveillances are eot requirements of the CTS. Therefore, l this change maictains the requirements of the FNP CTS.

5 STS LCO 3.8.3 is revised consistent with the corresponding CTS LCO requirement 3.8.1.1.b.3. The required quantity of DG fuel specified in STS LCO 3.8.3 l I

Condition A and Surveillance SR 3.8.3.1 is revised by the addition of the term

[/ " useable" to describe the specified amount of fuel. Useab!e fuel in a storage tank is the amount above the tank transfer pump suction nozzle available for transfer from a storage tank to a DG day tank. The additica of this description clarifies the STS requirement consistent with the CTS. Therefore, this change maintains the current FNP licensing basis regarding the required amount of DG fuel as specified in the CTS.

Chapter 3.8 ES-1-C April,1999

984 Diesel Fuel 011, Lube oil, and Starting Air 8 3.8.3 8 3.8 ELECTRICAL POWER SYSTEMS 8 3.8.3 Diesel Fuel 011 Lube Oil, and Starting Air sqc, ah.

tra.nsfe,r-q'sksproyI in e, thee,afbrye BASES M

(M D BACKGROUND Each diesel generator (DG) is(providedfrith a storage tank h (Navino a ruel oi' capacitv enMisientdto operate that diesJ e for a period of J days while the DG3 G supplying maximum g,7,1, l .7 mst loss ofJ:oolant accident load demand discussed in the ISAR, SectiotrE9.5.4.2])(rey. 1) . The maximum load demand ' {

is caleylated using sne assumption that a minimum of any two DG favailabld. This onsite fuel oil capacity is :

u < cient to operate the DGs' for longer than the time t '* M 4

p replenish the onsite supply from outside sources. ',.] ]

34 Fuel o is transferred from storage tank to day tank by NY ,

eithe of two transfer pumps associated with each storage y w '!

tank. Redundancy of pumps and piping precludes the failure >nele44 of one pump, or the rupture of any pipe, valve or tank to 35 d@

result in the loss of more than one DG. b +w4r

_ _ pumps, and piping are located underground.All outside tanks, b W M~]

D270-45, For prope ration of the standby DGs, it is necessary t ad*1 bk +.

ensure t roper quality of the fuel oil. (Regulatorn-4lL ,

M'iutdeI.

m- m 3 supplemented hv.GUISI N19U(Ref. 3). The fuel ASTM .

D975. JEYTGs as(Ref.

ou prop 4PtTE governeo oy thse SRs are the water and 2) addres specific gr.avity )

1 sediment content, (or API gravity), the kinematic gnd impurity leveg viscosity, Q

5 The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions. The syst:sm is required to -

circulate the lu5e oil to the diesel engine working surfaces

' and te rensva excess heat anna.ated Iw friction durino ,

onoratig.JEach engine oil sump con 1ains an inventory' l OPSc l

%@reaanla w onsite storage of<nmunoortino addition to the engine a minimum ol' sump sufficient to ensure 7 days of continuous operation.(y y, j of r71 l rn s supply is sufficient to allow the operator to replen sh lube oil from outside sources.

Each DG has an air start system with adequate capacity for L five successive start att ts on the DG without recharging the air start y t iver(sl. _ _ .--

t

6 su Wrn h >I6h 6} ( b fearNec vers O \

sent c^pMit tope.r th The rejusreel nurnleer o h,y,d (continued)

WDG STS 8 3.8-41 Rev 1, 04/07/95 k.

ei Associated Package Changes fw FAI 3.8Ji-02 l

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electr;ctl Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1.AC SOURCES - OPERATING DOC ;

I MQ SHE DISCUSSION available, the sequencer functions to actuate the required ESF loads simuhaneously on the offsite circuit upon rece:pt of an SI signal. As such, the basis for this STS LCO requirement is consistent with the FNP electrical system design and the STS requiremmt is included in the FNP ITS LCO. The addition of this LCO requirement and the astmiated Actions (discussed in another DOC) pmvide appropriate operability and Action requirements for required FNP equipm.mt which was not specifically addressed in the CTS. However, the inclusion of this STS LCO requirement represents the addition of t new 'I S requirement not specified in the CTS. Threfore, this change is considerud more restrictive.

3 A The CTS 3.8.L1 LCO requirements regiuding the DG auxiliary systems 1 (b.1, b.2, b.3) are moved into the appropriate uurveillance requirements or other TS requirements (as noted) consistent with the STS. The operability l

i requirements for this equipment are not diminished but re-organized within j the TS in accordance with the STS. As such, the changes to these CTS LCO requhements are considered administradve made to conform with the format and presentation of this information in the STS. i 3a L The CTS' LCO 3.8.1.1.b3 and SR 4.8.1.1.2.a.2 requirements regarding DG fuel oil storage volume requirements are moved to STS LCO 3.8.3 and SR

! 3.8.3.1 respectively consistent with the STS. The CTS 4.8.1.1.2.a.2 SR to verify fuel level in the storage tanks is maintained in the ITS SR 3.8.3.1 j which requires verification of greater than 25,000 gallons of useable fuel in each storage tank. The existing CTS minimum DG hel oil volume of 25,000 gallons (the amount required for 7 days oreration of the DG at 4 required post LOCA load) is the upper value in the fuel range specified by {

ff STS LCO 3.8.3 Condition A. The value of 21,000 gallons (the amount required for 6 days operation of the DG at required post LOCA load) is the lower value of the LCO 3.8.3 Condition A range. Condition A has no+ j equivalent in the CTS addressing situations in which fuel supply is reduced j below the minimum level required for 7 days but remaining above that j required for six days of DG operation. ITS LCO 3.8.3 Action A.1 for this condition is to restore fuel level to within limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The CTS LCO 3.8.1.1.b.3 requires each DG to have a minimum of 25,000 gallons of useable fuel to remain OPERABLE. CTS LCO 3.8.1.1 Action b. requires restoration of an inoperable DG within 10 dsys. ITS 3.8.3 Action A.1 requires fuel level be restored to above 25,000 gallons within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If

~

Chapter 3.8 E2-2-A April,1999

L !

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING DOC MQ SHE DISCUSSION level is not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the DG must be declared inoperable.

The new ITS LCO 3.8.1 Action A.1 provides an additional 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore fuel level to above the minimum before declaring a DG inoperable.

As stated in the STS Bases, this is acceptable based on the remaining capacity (6 days), the fact that procedures will be initiated to obtain

p replenishment, and the low probability of an event during this brief period.

((g of As such, it is applicable to and appropriate for Farley. However, since ' l additional time is allowed before declaring the diesel inoperable, this change is considered less restrictive.

4 A The CTS 3.8.1.1 Action statement "a"is revised consistent with the STS. 1 The CTS Action statement is divided into STS Required Actions A.1, A.2, A.3, H.1 and H.2. Editorial changes are made to the Action statement in order to conform with the presentation and format of this information in the STS. Technical changes to this CTS Action statement are discussed elsewhere in this document. As such this change is considered ,

administrative. i

)

5 L The CTS 3.8.1.1 Action statement "a" for an inoperable offsite circuit and !

. the CTS Action statement "d" for two inoperable offsite circuits are revised by the deletion of the action requirement to test the required DG sets. 'Ibe deletion of this requirement is consistent with the STS. The normal ,

required surveillance testing of the DGs provides adequate assurance that j the required DGs will be capable of performing their intended safety l functions. The inoperability of a required offsite circuit does not impamne j reliability of the DGs as previously demonstrated by the normal required ;

surveillance testing. In some cases, the inoperability of an offsite circuit i

~

may cause an automatic start of the associated DG. In these cases, the DG 1 will already be supplying the ESF bus. In any case, the reliability and l availability of the DGs are not adversely affected solely as a result of the loss of an orTsite circuit. Therefore, the CTS requirements to start the DGs under these circumstances are deleted consistent with the S lS. !

6 M The CTS Actions for inaperable AC sources are revised by the addition of '

" cross train" equipment operability verifications consistent with the STS.

The new STS actions are intended to provide assurance that when a required AC source is inoperable, an event coincident with a single failure of a remaining AC source will not result in a complete loss of function of I

Chapter 3.8 E2-3-A April,1999 !

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.8 - Electrical Power Systems III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS

'ob' CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING in-L

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

The proposed change involves the addition of actions to take in the event that the stored volume of fuel oil for a 6iesel Generator'(DG) drops to a level equivalent to > 6 days but < 7 r days supply to more closely agree with the STS and does not result in any hardware changes.

The DGs are used to support mitigation of the consequences of an accident; however, they are not assumed to be an initiator of any previously analyzed event. As such, the addition of steps to restore fuel oil storage level when > 6 days but < 7 days supply is available will not increase the probability of any accident previously evaluated. The proposed action requirements do not diminish existing surveillance requirements to verify the operability of the DGs which continue to provide =A~n2=M assurance that the DGs will perform their required function to support limiting the consequences of design basis events as describal in the FSAR and that the results of the analyses in the FSAR remain bounding. Additionally, the proposed change does not impose any new safety analyses limits or alter the plants ability to detect and mitigate events. Therefore, this change does not involve a significant increase in the consequences of an accident previously evaluated.

2. Does the change crest $c possibi'by of a new or different kind of accident from any accident previously eviduated?

The proposed change involves the addhion of actions to take in the event that the stored volume of fuel oil for a Diesel Generator (DG) drops to a level equivalent to > 6 days but < 7 days supply to more closely agree with the STS and does not necessante a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change, which involves the addition of actions to take in the event that the stored volume of fuel oil for a Diesel Generator (DG) drops to a level equivalent to > 6 days but < 7 days supply to more closely agree with the STS does not involve a significant reduction in a margin of safety. The proposed change does not diminish existing surveillance z

requirements to verify the operability of the DGs which continue to provide adequate assurance that the DGs will perform their required function to support limiting the consequences of design basis events as described in the FSAR and that the results of the i i

analyses in the FSAR remain honadiag. Since sufficient fuel remains to supply the DGs for

> 6 days, and fhel oil level must be restored to the 7 day supply level within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the Chapter 3.8 E3-1-A April,1999

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.8 - Electrical Power Systems III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.8.1.1 AC SOURCES - OPERATING FNP ITS 3.8.1 AC SOURCES - OPERATING proposed change provides equivalent assurance of the capability of the DGs to perform their safety function. .

ov

. W4 .s. .

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i N . e 3.8 E3-2-A Apnl,1999

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1 Associated Package Changes for RAI 3.8.3-03 1

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i FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.83 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR FNP ITS 3.83 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR l

sD ;

NUMBER JUSTIFICATION 1 The STS 3.83 Condition B is revised to reflect the two types ofDG required operable at FNP. This change maintains the CTS requirements regarding the DGs, but incorporates the STS requirements to maintain sufficient lube oil for those DGs.

2 The STS 3.83 Condition E for DG starting air receiver pressure is revised consistent with the FNP design. The different type DGs utilized at FNP have i

different starting air receiver pressure requimnents. In addition, each DG is equipped with @ ant air receivers only one of which is required to perform'the DG start func D$ compressors, tion. Each DG starting air system consists of

((f sufficient volume to supply air to start its respective DG five times. Since either r**at system associated with a DG is capable of providing air for five starts, restoration of at least one receiver to above the minimum pressure restores the ;

system operability. Therefore, the STS Condition is revised to incorporate the different starting air receiver pressure requirements of the FNP DGs and the fact that only one receiver is required. This change is consistent with the FNP specific j DG design.

3 He STS surveillance SR 3.8.3.4 is revised consistent with the FNP design. He different type DGs utilized at FNP have different starting air receiver pressure requirements. In addition, each DG is equipped with mbmdant air receivers only one of which is required to perform the DG start function. Therefore, the STS surveillance is revised to incorporate the different starting air receiver pressure requirements of the FNP DGs and the fact that only one receiver is required. This change is consistent with the FNP specific DG design. l 4 The STS surveillances SR 3.83.5 and SR 3.83.6 are deleted consistent with the FNP CTS. These STS surveillances are not requirements of the CTS. Therefore, this change maintains the requirements of the FNP CTS.

5 STS LCO 3.83 is revised consistent with the cussyonding CTS LCO requirement 3.8.1.1.b3. He required quantity of DG fuel specified in STS LCO 3.83 Condition A and Surveillance SR 3.83.1 is revised by the addition of the term

" useable" to describe the specified amount of fbel. Useable fuel in a storage tank is the amount above the tank transfer pump suction nozzle available for transfer from a storage tank to a DG day tank. The addition of this description clarifies the STS requirement consistent with the CTS. Therefore, this change meintains the current FNP licensing basis regarding the required amount of DG fuel as specified in the Chapter 3.8 ES-1-C Apnl,1999

Associated Package Changes for RAI 3.8.3-04

2 86 Diesel Fuel 011, Lube Oil, and Starting Air B 3.8.3 BASES APPLICA8ILITY. and starting air are required to be within limits who the (continued) associated DG is required to be OPERA 8LE. '~

ACTIONS The ACTIONS Table is modified by a Note indicating that-separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each condition-provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, .

and subsequent inoperable DG subsystem (s) are governed by separate Condition entry and application of associated Required Actions. -

M ge requlted 4 na _ _-

In this Condition, the 7 day fuel oil supply for 1 DG6s not available. However, the Condition is restricted ;o fuel oil level reductions that maintain at least a 6 day supply.

These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable.

This period is acceptable based on the remaining capacity

(> 6 days), the fact that procedures will be initiated to -

obtain replenishment, and the low probability of an even during this brief period. ~ ~ -

C.hl.c. fe o. L.a. DCr oe d /67 plon 4M. to-lOM*801 2.38 _ s With lobe oil inventory < 01 gal sufficient lubricating

, oil to support 7 days of continuous DG operation at full load conditions may not be available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day suppl This restriction allows sufficient time to obtain the visite replacement volume.

A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is consid sufficient to complete s/n-94 -/069-002, a for G.,La.q t D b t43 94.// ens for 6 &wwu I)(r) b) (continued)

WOG STS 8 3.8-43 Rev 1, 04/07/95

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l Associated Package Changes for RAI 3.3.3 06 f

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c28 8 Diesel' Fuel Oil, Lube Oil, and Starting Air 8 3.8.3 on L tG gg b BASES ==

3f0 Er the yo758%s att,s o QACTIONS (continued)

L.L h ' -

[R300P*'AbrD9%"jr P y D Cr j

[ /50 With starting air receiver pressurch 225 psig[rs icien capacity for five successive LG start a ts d not f.c; d e p g % s tee,

%)However, thereas long as6iE receiver "or ataressure

> L25 psi is adequate capacity least one 4 M3 of.yM,f sta i t, and the:DG can be considered OPERA 8LE while for DG #C # sne air receiver pressure is restored to the required limit.

V A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete gg ,,g . restoration to the required pressure prior to declaring the g -80/ DG inoperable. This per.iod is acceptable based on the remaining air start capa~ city; the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

f.d With a Required Action and associated Completion Time not met, or one or more DG's fuel oil, lube oil, or. starting air subsystem not within limits for reasons other than addressed by conditions A through D, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

M m SURVEILLANC SR 3.8.3.1 ege, @

REQUIREMENT This SR prov es verification that there s an adequate %j g inventory of g 6 cil in the storage tanks to supporty,ac 00's onerauem for 7 days at full load. The 7 day per' is g*r1li'ficient time to place the unit in a safe shutdown -

condition and to bring in replenishment fuel from an offsite

' location.

h. 3 The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of full load (continued)

WOG STS B 3.8-45 Rev 1, 04/07/95 4

I Associated Package Cnanges for RAIs 3.8.4-01 and 3.8.9-03 l

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M in order to conform with the Ibemet of the electrical requirements in the STS. this FNP LCO must be divided into 3 separet) LCOs. In addition. the requirements of the Auxiliary Building and Service Water Building DC Dietnbution System LCOs are combined into the foNowing 3 STS LCOs: 3.8.9. Dietnbution Systems . Operating. 3.8A. OC Sources . Operating. and 3.8.6. Bettery Ceu Parameters. The fot: awing markup provides more detail Ss 3 8 ELECTRICAL POWER SYSTEMS g

RVICE WATER SUILO!NG 0.C} O!$TR!BUTION _0P(RATING _ $

LIMITING CONDITION FOR OP(RATION ludri d eW h O'b' g, jgggjon systems shall be OPERABLE, 2 Tral (3.8.2.5 Ghe fa1%fuO 88885 Abi,adi, L' rain gng "A" consistine of 125-volt 0.C. Distribution Cabinet IM3 LZ5-volt hattery tant No. I and a ruli capacity cnarge Q Wt,tS g,g 3,g,y l

' rain u eenstatsma of In-valt e e ointrhtien cabinet is.1 Grs-voit battery bank No. 2 and a fell capacity /

i BEES gg APPLICAftLITY: M00($ 1. 2, 3 and 4. ,

m 3,84 ACTION: Wf th one of the 125-volt distributton tref as inoperabidkA- -

M L,p th52 hours e in a $ $f AN00' wb[t at

LCO 3 6 9 deurs and in C0(0 SielT00W within the followine 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

t SuRyerLLAmCt RroUIRcMcNT deilire nea.ss6aade:L servTce sA3*kertMn (popersbh iwr*W T [ECortidien-sR3.6.9.1 tco s.g,4f s-d.8 2.5.13 tach 0.C. train shall be deterufned OPEAAILE and energfred at M Coed.ibn E

ivest. ence per 7 days by verifying correct breaker alignment and indicatedge availability.

g Each 125-volt 0.C. battery bank and_ rh'ame shall be "d"^"' $

c e ASMG

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yu.o 3,S.b T#g E As ieast once p.c 7 days by v.cf f f g tser

/ .5A 36.6,I i

1. ters fa Table t the Category LCO 3 8, jt. The total battery terminal voltage is greater than or equal y gg3,$. .I to 127.8 irelts en float charge

b. At least once per 92 days and within 7 days after a battery discharge with battery teraf nel volta below 110 volts. or L,LO 3 8.b batte overcharge with battery terst_1 voltage above -

150 ve ts, by verifying that: S I'0* b' g g4

1. The parameters in Table . et tegory 8 Itsf u I ' cept ring ' rfo e ' surve lance Requi nts 4.8. 5.2.3

.2.5 .e, a 4.0. 5.2. 5. ng this te . ene traf any be r le un I the tte is berged fell , fag couple of tte disch rge te .

j f

FARLEY. UNIT 1 3/4 3 12 AM00ENT NO. 59 M

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.2.5 SERVICE WATER BUILDING DC DISTRIBUTION - OPERATING FNP ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.6 BATTERY CELL PARAMETERS DOC MQ SE DISCUSSION reliance on the information contained in the STS bases is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of:he TS.

l 4 Not Used.

5 L The CTS 3/4.8.2.5 Actions are revised consistent with the SWIS DC distribution and battery systems design and safety function. At FNP the Service Water System DC control power is supplied by a separate DC distribution and battery system which is independent of the main DC distribution and battery system in the Auxiliary Building. The primary purpose of the SWIS DC distribution and battery system, and the reason for which it has been included in the CTS, is to supply DC control power to the associated train of Service Water. The SWIS DC distribution and battery

system does not supply any other TS related or required loads. The CTS ge'I 3/4.7.4 (and STS 3.7.8) requirements applicable to an incperable Service d gj Water train allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore that train to operable status before p.S requiring a plant shutdown. As the SWIS DC distribution and battery systems are required in TS solely to support the associated Service Water system train, the CTS allowance ofonly 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore the SWIS DC distribution and battery systems to operable status before requiring a plant shutdown is overly conservative. If an entire Service Water train may be inoperable for any reason for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months per CTS 3/4.7.4, it is

, unreasonable to require a plant shutdown to begin in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if the DC control power to the same Service Water train is inoperable The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time associated with distribution and battery systems is based on the fact that these systems typically support many TS required ESF systems and the loss of the supporting distribution or battery system impacts many required systems. This is not the case for the FNP SWIS DC distribution '

and battery system. Therefore, a change is proposed to the (.;."S and STS Action requirements applicable to this unique FNP system. A revision to ]

the CTS actions is proposed that is similu to other STS actions for support l systems when that suppart system becomes inoperable (declare the l

supported system inoperable). It is proposed that the existing 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months l

Chapter 3.8 E2-2-G April,1999 L . J l

l FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.2.5 SERVICE WATER BUILDING DC DISTRIBUTION - OPERATING FNP ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.6 BATTERY CELL PARAMETERS DOC EQ SHE DISCUSSION l restoration time and default action to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months be replaced with an action to declare the associated Service Water train inoperable immediately. Thus, the g,4 g.

j Completion Time for the support system becomes more reasonable and-consistent with the Completion Time for the supported system. The CTS 4

hY i

action to restore the inoperable distribution or battery system to operable status is always an unstated option in the STS. The proposed change impacts 2 STS LCOs where the requirements of CTS 3/4.8.2.5 are moved to. In the STS, the requirements for distribution systems are separated from the requirements for battery (source) systems, therefore, both STS LCO 3.8.9, " Distribution Systems-Operating" and STS LCO 3.8.4, "DC Sources- i Operating" are affected by this change.

6 A The CTS 3/4.8.2.5 surveillance 4.8.2.5.2 is revised consistent with the STS.

The CTS battery surveillance is separated into two different STS LCOs (3.8.4, DC Sources and 3.8.6, Battery Cell Parameters) as indicated in the Enclosure I markup. The separation of this CTS surveillance conforms to the format and presentation of this information in the STS and does not represent a technical change. Therefore, this change is considered administrative.

i 7 M The CTS 3/4.8.2.5

footnote is deleted consistent with the STS. The CTS I footnote provides an exception to the action requirements for an inoperable

. DC train to allow the performance of surveillance requirements which render the associated DC train inoperable. The SWIS DC subsystems consist of(2) 100% capacity battery / battery charger sets per train. Either battery / battery charger set may be selected to supply the associated train.

As the affected surveillances may be completed by performing them on each battery / battery charger set when that set is aqt aligned to supply the associated train or be performed during shutdown, this CTS note is not required and has been deleted consistent with the presentation of these requirements in the STS. As this change deletes an exception to the requirements of the CTS, this change is considered more restrictive.

Chapter 3.8 E2 3-G April,1999

D CHAPTER 3.8 INSERT S TO STS PAGE 3.8-24 FNP SPECIFIC DC SOURCES ACTIONS ACTIONS CONDITIONS REQUIRED ACTIONS COMPLETION TIME A. One Auxiliary Building DC . A.1 Restore the Auxiliary 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power subsystem Building DC electrical inoperable, power subsystem to OPERABLE status.

i B. One Auxiliary Building DC B.1 Restore the battery 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months l electrical power subsystem connection resistance to with batteryconnection within limit.

resistance not within limit.

C. Required Actionand C.! Se in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Cornpletion Time l of Condition A or B not AND met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i l

D. One required SWIS DC D.1 Restore the battery 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months l electrical power subsystem connection resistance to l battery connection resistance within the limit. j not within limit. l M' E. One required SWIS DC E.1 Declare the associated hnmediately j 3

f electricalpowersubsystem -

inoperable, Service Water System train inoperable.

QB Required Action and asrociated Completion Time of Condition D not met.

l l

Chapter 3.8 Insert Page

GO.1 Olstribution Systems - Operating 7 . 3.8.9 l.'iSEff'LL' 4W W]il . =i% % biSN Oi ACTIONS l continued)

O CONDITIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Requirad Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completto Time nc,t met.__ _ Ag c F Cond.Ife A, g, , p D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i

F. Two traitis with inoperab'le

[1 Enter LCO 3.0.3. Indediately

)

7*

distribution subsystess that result in a loss of safety

'g r function.

9,3

,$,9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY C/

SR 3.8.9.1 Verify co ct breake alignments and 7 days voltage to requir AC, DC, and AC vital bus electr al power distribution subsystems. .

)

l 1

if0G STS 3.8-39 Rev 1, 04/07/95

,_ 2.o 3 CHAPTER 3.8 i l

INSERT U i TO STS 3.8.9 PAGE 3.8-39 NEW FNP SPECIFIC CONDITIONS FOR SERVICE WATER INTAKE STRUCTURE DC DISTRIBUTION SUBSYSTEMS l

CONDITION REQUIRED ACTION COMPLETION TIME g - E. One Service Water Intake E.1 Declare the associated Immediately r Structure (SWIS) DC Service Water train .

gj,4 electrical power inoperable.

distribution subsystem inoperable.

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l Chapter 3.8 Insert Page 1

i 301 P

. ocsources-Ograt,i]

BASES i APPLICA8ILITY b. Adequate core cooling is provided, and containment (continued) integrity and other vital functions are maintained in l the event of a postulated DBA. '

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sourcas - l Shutdown."

1

. , . . t.

~

Condition A' represents one trairfFwith a loss of ability to completely respond to an event, and a potential loss of -

ability to remain energized during normal operation. It is, therefore, imperative that the operator's attention focus on l stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC

,og distribution system train.

M' If one of the required DC electrical power subsystems is inoperable (e.g., inoperable battery, inoperable battery charger (s), or inoperable battery charger and associated I d5C,-2]. inoperable battery), the remaining DC electrical power l subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst i n O e. case single failure would, however, result in the complete we of- _ loss of the resninina 125 VDC electripal power subsystems witn attendant 'oss of ESF function Ts,ontinued power N Ru.

08 g "

d&r operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 8) and reflects DC Powfr a reasonable time to assess unit status as a function of the . -2 Sube/6 M inoperable DC electrical power subsystem and, if thepC -

electrical power subsystem is not restored to OPERA 8U. . -

status, to prepare to effect an orderly and safe unit WI shutdown. Buil33" TN6ER.T LL .

Sc:rloN 81 d. d2C-5)

M s'.1 and Q ' q- SvidLinh lu' D.I .2 If the inoperable electrical power subsystem cannot be

&N restored to OPERA 8LE status,within the required Completion Time,theunitmustbebro@httoaMODEinwhichtheLC0 does not apply. To achievy this rtatus, the unit must be brought to at least MODE 3f within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MOOR _

yh[connh,tiofs blO E te6t;oftd. 60 . .i (continued)

~

^

WOG STS 8 3.8- a Rev 1, 04/07/95

3oL CHAPTER 3.8 INSERT LL STS BASES PAGE B 3.8-53

.f 33 B.1 and D.1 Conditions B and D, represent one Auxiliary Building or SWIS DC electrical power subsystem with connection resistance not within the specified limit. Consistent with the guidance in IEEE-450, connection resistance not within the limit is an indication that the affected tattery requires attention to restore the resistance to within the limit but is not a basis on which to declare the tan.ery inoperable. Therefore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time allowed to restore the battery connection resatance to within the required limit is a reasonable time considering that variations in connection resistance do not mean the battery is incapable of performing its required safety function, but is an indication that the battery requires maintenance. i l

l l

)

(

Chapter 3.8 Insert Page

'id 3 DC Sources - Operating The % d vol .F 2.2.V per ce, er 132 V BASES in" pot to a Yoh y, -

ACTIONS I.1andf.2 (continued) within_36 hours. The allowed Completion Times are reasonable, baced on operating experience, to reach the

[@,/ required unit conditions from full power conditions in an orderly manner and without challenging plant systems. The completion Time to bring the unit to MODE 5 is consistent IN6ER.T M W wit.) the time required in Regulatory Guide 1.93 (Ref. 8).

l Achon E.1 &

SURVEILLANCE SR 3.8.4.1 :

RE00fammTs NMs'4sa-tqqd) Verifying battery terminal voltage while on float charge for-m - the batteries helps to ensure the effectiveness of the

,0 L , a,wLyt charging system and the ability of the batteries to perform 4, their intended function. . Float charge is the condition in h he which the charger is suppiying sne svininuous cnarge FM nha d' E .** requirva to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell I co@%+iers '

g d.ur.3n a fu11v charaad utate., ine voitage requ'raments are ned epemk#)l based on the nomina' design voltage of the battery and are.

consistent with the initial voltaaes ass'-4 in the battery ZE8E 08E *f Jizine calculations.J The 7 day Frequency is consistent wiSh

- 4 * . Caanufacturer recommonaations an6JEEE-450 (Ref. 9). ,

p SR 3.8.4.2 j t,W@

g SE cts 4.8.2.3.2.b L M

P rgt c.rs v.s. 2.s.2.b.2 v

1

- =

VisualAnsooction to detect corrosiot batter)

I g, had connect oiiRJ6r measuremont of th sistance.of

---A ntercei er, ana terminai connect.1 -

Ng s, interract, intert provides an tnaication or rpnysical damage or,abnorea' ceterioration_rnas cousa l >otentially degrade battery)W-g performance.1 b"C'Y'%The11 ts establ hed for is SR su be"no e than 05 54 W *C . abov he rests ce as se .ured duri retoysin8f aE. the cell g value ablished instal ation o not the ufactur ._

'M D

te.4 input The' Surveillance Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This frequency is considered acceptable based on operating experience related to detecting corrosion trends.

(continued)

WOG STS 8 3.8-54 Rev 1, 04/07/95

M CHAPTER 3.8 INSERT MM STS BASES PAGE B 3.8-54 P' @^p\

u If a required SWIS DC electrical power subsystem is inoperable or the connection resistance is not restored to within the limit and the associated Completion Time has expired, the Service Water System train supported by the atYected SWIS DC electrical power subsystem must be declared inoperable. The capsbility of the affected SWIS DC electrical power subsystem to fully support the associated train of Service Water is not assured. Therefore, consistent with the definition of OPERABILTIY, the associated train of Service Water must be declared inoperable l' ,- immediately, thereby limiting operation in this condition to the Completion Time associated with the affected Service Water System train.

\

Chapter 3.8 Insert Page

l 357 Distribution syst,,,_0,,,, tin, B 3.8.9 l

BASES l ACTIONS C.d (continued)

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsysi. ems to be inoperable during any single contiguous occurrence of failing to meet the LC0. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LC9, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERA 6LE.

This could continue indefinitely. .

This Completion Time allows for an exception to the normal

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

This will result in establishing the " time zero" at the time the LC0 was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fall to meet the .

LC0 indefinitely.

Tec.-J _ _ _

D.1 and D.2 (S) a OMetedb r . ris A ,8 ,e . 1 If the inoperable distribution subsystenh:annot be restorec to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within T6C#8 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner WsERT oo and without challenging plant systems.

E E./ gl .

A With two trains with inoperable distribution subsystems that

[ g,M result in a loss of safety function, adequate core cooling, atainment OPERA 8ILITY and other vital functions for D8A d igation would be compromised, and immediate plant shutdown in accordance with LCO 3.0.3 is required. .

(continued)

WOG STS B 3.8-86 Rev 1, 04/07/95

s m NO CHAPTER 3.8 INSERT 00 y STS BASES PAGE B 3.8-86 L1 .

I With one SWIS DC electrical power distribution subsystem inoperable, the Service Water System train supported by the affected SWIS DC electrical power distribution subsystem must be declared inoperable. The capability of the affected SWIS DC electrical power distribution subsystem to fully support the associated train of Service Water is not assured. Therefore, consistent with the definition of OPERABILITY, the associated train of Service Water must be declared inoperable immediately, thereby limiting operation in this condition to the Completion Time associated with the affected Service Water System train.

r I

Chapter 3.8 Insert Page g

Associated Package Changes for RAI- 3.8.4 02 i

- 1<

i l

l 1

1

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.4 DC SOURCES OPERATING JD bEIMBER JUSTIFICATION STS 3.7.8), has a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an inoperable train. Each train of SWIS batteries supplies the associated Service Water train DC control power.

Considermg that either unit or both units at the same time may have one train of Service Water inoperable for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (in the CTS or STS) for reasons other than the DC control power, the Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months with a plant shutdown required if the Completion Time is not met is imyymydate and overly conservative for an inoperable SWIS battery train. As such, separate Actions Conditions for the SWIS battery are proposed which if not met, default to a Condition which requires the associated train of Service Water be declared inoperable. This Actions -

Condition format is consistent with that used in the STS where similar support / supported system relationships exist. Therefore, this change introduces a revision to the CTS and STS to provide reasonable Actions Conditions for the SWIS batteries. The proposed change is consistent with the FNP specific design, and the format and presentation of similar information in the STS.

3 The STS 3.8.4 Battery connection resistance surveillance requirements are revised consistent with the FNP CTS. At FNP, cell-to-cell connectors are bolted to the terminal posts of adjacent battery celljars. A connection on one battery cell terminct post does not constitute the complete cell to cell connection; rather, the

[S,o gS v conne tor (s) and both bolted connections to the termi=1 posts of the adjacent cell jars do. The resistance is measured from " post to post" to ensure the total resistance of each bohi connector to terminal post interface snd the connector itselfis reflected in the measurement. The terminology used in the surveillance requirement and the resistance values specified are revised to be consistent with the language and connection resistance limits used in the FNP CTS. As such, this change maintains the requirements of the FNP CTS. -

4 The STS surveillance SR 3.8.4.4 is revised consistent with the guidance provided in

. the reviewers note in the STS Bases for surveillance SR 3.8.4.4 and IEEE Standard P1106. The STS surveillance requirement to verify termi=1s " clean and tight" applies only to nickel cadmium batteries (per IEEE-450 guidance). The FNP Auxiliary Building and Service Water Intake Structure batteries are lead calcium type batteries. The requirement to verify tightness may result in unnecessary stress to each connection if torque is applied to confirm tightness. In addition, if the connection resistance is _within the specified limits, it may also be assumed the connections are sufficiently tight. As such, the existing connection resistance verification and visible corrosion removal requirement performed at the same frequency provide adequate indication and assurance of clean and tight connections.

Therefore, this requirement is removed from the STS survedlance requirements Chapter 3.8 E5-2-D April,1999 h- - - . . .

I88 DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.2 Verify no visible corrosion at h tter 92 days terminals and connectors. wh ceu-off' 3

O3NE_____ os+ +. g__--

mA

"* g *at Ve"lfy batter:r connection resistat:0 is 150 msuchms

&' s "It- o "or nte cell onn :T on , forne AmLW j

[M 1

'l 5o '

for inte' rac con cti , l Iv M'ldd-4 kttereds

fo int $-tie con cti s, jQrne. smIS #500bs.deries.

micabms

[1 5' o for/ters al: nnec ons)

~

SR '3.8.4.3 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnotinal deterioration.

A 18' SR 3.8.4.4 Remove visible teminal corrosion verify [12 nont s battery cell to cell and temin A ---

connections are cisan una 11oht. andlare with t1-corrosion material.

g g g,( g 4

I fpoet to post]

SR 3.8.4.5 Veridy batteFr connection resistance is & [12 months sl l1f-5ohn? T r inter- ell connec tons, PY for inter ack conne ions. '

s $lR-5ohn'(forinto E-5ohnl tier conn tion _

and s (IE-fiohn) for erminal e necti s1L ,

? ,

iso Microhmsker +%e Ru (**" **

Is.Heries M i $coMsuchen e tic SL2b Wes - -

j -

3 i WOG STS 3.8-25 Rev1,04/07/95 l

r- j i

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Associated Package Changes for RAI- 3.8.4-04 t

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING l

JD i NUMBER JUSTIFICATION !

consistent with the above cited references. j 5 . The STS SR 3.8.4.6 is revised by the deletion of the surveillance note that prohibits performance of this surveillance in Modes 1-4. The deletion of this note is consistent with the CTS. The FNP design is such that any battery charger may be i

[/A4 tested operationalwhile amaintains flexibility spareTS(or readaat operability battery of the applicable battery/ and charger)

DC r is 3g train. The additional Auxiliary Building battery charger may be aligned to supply either train which allows flexibility in testing the associated chargers. The SWIS battery designincludes a read =at battery and charger for each train. The design of the SWIS DC system is such that either battery / battery charger set may be selected to supply the associated SWIS DC train. Thaefore, this change maintains the requirements of the FNP CTS and is consistent with the FNP electrical system i design which includes more battery chargers than the n:inimum required and allows i testing of the chargers without impacting the operability of the TS required battery / battery charger.

6 The STS surveillance SR 3.8.4.6 is revised to incorporate the FNP design which includes two types of battery chargers with different ampere ratings. In addition, the surveillance is revised to include the word " required" for each specified charger since the FNP design includes an additional rahad*at charger for the Auxiliary Building batteries and redundant battery chargers for each train of the SWIS DC system. Therefore, this change maintains the requirements of the FNP CTS consistent with the FNP electrical system design.

]

7 The STS surveillance SR 3.8.4.7 note 1 is revised consistent with the FNP. CTS.

The STS requirement for a " modified" performance discharge test is revised to delete the word " modified" consistent with the requirements of the FNP CTS. The CTS do not require that a modified test be performed. The FNP CTS allow a i performance discharge test to be substituted for a service test once per 60 months. l Therefore, this change maintains the requirements of the FNP CTS. !

8 The STS surveillance SR 3.8.4.7 note 1 is revised consistent with the FNP electrical r system design. This STS net.e is not part of the FNP CTS. The STS note precludes j performance of this batten test in Modes 1-4 as the test renders the battery j inoperable. Since the SWIS DC system contains two redundant battery / battery l charger sets per train, the limitation imposed by this note is not required for the !

SWIS batteries. One SWIS battery may be tested in each train while the other battery / battery charger set supplies the required DC train. Therefore, the STS note Chapter 3.8 ES-3-D April,1999 l

i O I

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{

1 4

1 1

Associated Package Changes for RAls - 3.8.4-05 and 3.8.4-07 j j

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems 1 CTS 3/4.8.2.3 AUXILIARY BUILDING DC DISTRIBUTION - OPERATING i

FNP ITS 3.8.9 DISTRIBUTION SYSTEMS OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.6 BA'ITERY CELL PARAMETERS i

DOC l NQ SHE DISCUSSION r : The Service Water Intake Structure DC subsystems consist of two 100% ;

capacity sets of battery / battery charger per train. Either battery / battery charger set may be selected to supply the required train. This design would always allow one battery / battery charger set to be tested in each train while maintaining two 100% operable trains. Therefore, theSTS note is not required for the Service Water Intake Structure batteries. However, since this restriction on the Auxiliary Building batteries is not explicitly stated in j the CTS, the addition of this STS note is considered a more restrictive {

Change. )

16 L The CTS surveillance requirement 4.8.2.3.2.d is revised consistent with the STS. The STS SR 3.8.4.8 allows the option of either performing a performance discharge test or a modi 6ed performance discharge test every 60 months. The STS also allows the modified performance discharge test in SR 3.8.4.8 to be performed in lieu of the service test in SR 3.8.4.7 once per 60 months. IEEE-450 allows use of modified performance tests in lieu of service tests at any time. This is due to modified performance tests subjecting batteries to higher current profiles than those of service tests as di.scussed in the Bases for SR 3.8.4.7. Therefore, consistent with IEEE 450, the STS and CTS are revised such that modified performance tests may be g

g, used to satisfy SR 3.8.4.8 and 3.8.4.7 simultaneously at any time. The modified performance dishge test is a simulated duty cycle consisting of jF g

' 4,k 4' just two rates; the one minute rate published for the battery or the largest 4r current load of the duty cycle, followed by the test rate employed for the i*

f performance test, both of which envelope the duty cycle of the service test.

Since the ampere-hours removed by a rated one-minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test The addition of the option to use a modified performance discharge test to comply with the 60-month testing l requirement in CTS 4.8.2.3.2.d is acceptable since the modified l performance discharge test provides comparable results to the performance I discharge test. Use of the modified performance test in lieu of a service test at any time is acceptable since the modified performance tests subject l Chapter 3.3 E2-7-E April,1999

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.2.3 AUXILIARY BUILDING DC DISTRIBUTION - OPERATING FNP ITS 3.8.9 DISTRIBUTION SYSTEMS OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.6 BATTERY CELL PARAMETERS DOC HQ S.HE DISCUSSION batteries to higher current profiles than the design load current profile

> g,0 requirements of service tests. However, as this adds an option for testing ,

33 .

not currently contained in the CTS it is seen as a less restrictive change.

~

17 LA The CTS 3/4.8.2.3 surveillance 4.8.2.3.2.e is revised consistent with the STS. This CTS surveillance for a performance discharge test contains a description of battery degradation. The correspaaAng STS SR 3.8.4.8 contains the same description in its associated bases discussion not in the SR itself. Therefore, consistent with SR 3.8.4.8, the CTS description of battery degradation is removed from the surveillance 4.8.2.3.2.e. Reliance on the information contained in the STS bases is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

18 A The CTS 3/4.8.2.3 Table 4.8-2, Battery Surveillance Requirements is revised consistent with the STS. This CTS table contains smveillances and actions relating to battery cell parameters. In the STS, this Table is contained in a separate TS, LCO 3.8.6, Battery Cell Parameters, as Table 3.8.6-1. Information from the CTS Table that required action or specified a Completion Time is incorporated into the Action Conditions of STS LCO 3.8.6. The movement of this Table into the STS LCO 3.8.6 and translation of CTS Table notes into Action Conditions is made solely to conforrn with the format and presentation of this information in the STS and is therefore considered an administrative change.

19 A The CTS 3/4.8.2.3 Table 4.8-2, Battery Surveillance Requirements, Category B column is revised consistent with the STS. The Category B column is divided into 2 columns Category B and Category C. The new !

column Category C consists of the former Category B allowable values.

The former Category B allowable values become the Category C limits in .

the STS. Since this change only affects the name of the column and does not revise the limits, it is considered an administrative change made to conform with the format of this information in the STS. l 1

Chapter 3.8 E2-8-E April,1999 L

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.8 - Electrical Power Systenu III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.3.8.2.3 AUXILIARY BUILDING DC DISTRIBUTION - OPERATING FNP ITS 3.8.9 DISTRIBUTIO'N SYSTEMS OPERATING 6 FNPITS 3.8.4 DC SOURCES -OPERATING g,[b,cfl FNP ITS 3.8.6 BATTERY CELL PARAMETERS 3% &L

r

1. Does the change involve a significant increase in the probability or comwaces of an ~

accidentpreviously evaluated?

The pwposed change updates the current FNP battery capacity surveillance requirements, with modification, to be consistent with the STS and guidance provided in IEEE-450.

Modified performance tests are added as acceptable alternatives to service tests performed at 18-month intervals. In addition, modified performance tests are added as attematives to the aviding requirement to subject the batteries to performance tests every 60-months. The DC electrical sources are used to support mitigation of the consequences of an accident; however, they are not considered the initiator of any previously analyzed accident. As such, the addition of the modified testing option will not increase the probability of any accident previously evaluated. The use of the modified performance tests in lieu of service tests or performance tests will continue to demonstrate battery capability required in the mitigation of design basis accidents. Therefore, the proposed change does not involve an increase in the consequences of any accident previously evaluated.

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

The proposed change introduces no new mode of plant operation, and it does not involve physical modification to the plant. The existing and new surveillance requirements will ensure sufHeient battery capacity and capability exist to perform the intended function.

Therefore, this change does not create the possibility of a new or different kind of accident from anypreviously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

' Ibis change does not involve a significant reduction in a margin of safety. The use of the modified performance discharge test will continue to ensure that battery capacity and capability exist to perform the intended function. The modified performance discimise test is an -ehle attemative per IEEE-450 and provides w-y.sble results to the performance discharge test.

Chapter 3.8 E3-4-D Apni,1999

/B7 DC Sources - Operating 3.8.4 1

SURVEILLANCE REQUIRENENTS (continued)

{

SURVEILLANCE FREQUENCY l W '

I.8.4.6 ----- --------- -NOTE

~

SR - ----- -

(-his T S rveillancshall oth-e-rfo p in r i gdb!S MO)E , 2. 3. o 4. Riowevef, credit y oe 'j l g gw er ta te forunplafnedevents/thatsatis / Yg

'g M ,5) U ' d

p,yhoors Veri g !i?;f w st di r e ttrn-d each*batteryg hgp'ger suppl i I months l

k s at = (125# V for a cur *. 7 I

% m A # ' '

z,we sfpdMe ]

f SR 3.8.4. -----

[ NOTES----------------- M a % s

4 ik j gg ,p '] . The WifiniD performance discharge 9.1.1P.45 m W j 33 test in SR 3.8.4.8 may be performed in tw4 4. M h 1

,3 lieuoftheservicetestinSR3.8.43 4 A s se d a 4414- !

p,, the AumlJAr 'once per 60 months. d. we ,

]

@M'ag This Su, e111ance shall not be l v inrfo in MODE _1, 2, 3, or 4.

(nowever, crecit may De samen for M

7 ,fSTF -8 Lunplanned events that satisfy this SR.f

@ . l Verify battery capacity is adequate to 18 months supply, and maintain in OPERA 8LE status, the required emergency loads for the desi filuty cycle wnen suDjectea to a Dattery[gn (ervicetest.f V

i 1-_ - .

(continued) lo A pi fde; Aeseksd in A N I q Sa.Ah en.l&yk Ret.4, se.chn S.%E by ejechy 6.Weg +n sedu 4es4. '

4 WOG STS 3.8-26 Rev 1, 04/07/95

l90

_ DC Sources - Operating lO ' " - -

3.8.4 for Oe kukbe.tf %$nf SURVEILLANCE REQUIREMENTS (continued) e5y SURVEILLANCE I

FREQUENCY e il SR 3.8.4.8 ------------------NOTE--------------- , $

" #U This Survet11ance shall not be perfornec kn MQ)E 1. 2. 3. or 4.JHowever, credit may be) L[d'E**DesAA ir$+ 1 76TF-g aten for unplanned events that satisfy F -

,. l this SR.T ll Verify battery capacity is = of the 60 months manufacturer's rating when subjected to a k'$ ,00 performance-discharge test or a modified Ig AlE :

3, fl performance discharge test.

I D, sonths when -

battery snows f pqdationor teached fl of expected life A gunn capacity)

< 10015 of manufacturer's rating ale 24 months when battery has

@ reached (85]%

of the expected life with' capacity k 100% of - 1

( manufacturer's) rating i

WOG STS 3.8-27 Rev 1, 04/07/95

s FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING JD NUMBER JUSTIFICATION consistent with the above cited references.

l 5 The STS SR 3.8.4.6 is revised by the deletion of the surveillance note that prohibits l performance of this surveillance in Modes 1-4. 'Ibe deletion of this cote is I consistent with the CTS. The FNP design is such that any battery charger may be l tested while a spare (or radundant battery / darger) is in service in its place. This operational flexibility maintains TS operability of the applicable battery and DC train. The additional Auxiliary Buildircg battery charger may be aligned to supply either train which allows flexibility in twting the associated chargen. The SWIS battery design includes a raduadant battuy and charger for each train. The design of the SWIS DC system is such that either battery / battery charger set mcy be selected to supply the associated SWIS DC train. Themfore, this change maintains the requirements of the FNP CTS and is cotcsistent with the FNP electrical system design which includes more battery chargera than the minimum required and allows J testing of the chargers without impacting the operability of the TS required I battery / battery charger.

6 The STS surveillance SR 3.8.4.6 is revised to hcorporate the FNP design which I

includes two types of battery chargers with diffent ampere ratings. In addition, the surveillance is revised to include the word "itquired" for een specified charger l since the FNP design includes an additional reduadant charger for the Auxiliary Building batteries and redundant battery chargers for each train of the SWIS DC

,, 4 system. Therefore, this change maintains the requkements of the FNP CTS consistent with the FNP electrical system design.

T7 The STS surveillance SR 3.8.4.7 Note 1 is revised consistent with the FNP CTS.

The STS permissive for a " modified" performance discharge test is revised to delete l l

the word " modified" consistent with the requis,:ments of the FNP CTS. The FNP CTS allow a performance discharge test to be substituted for a service test once per 60 months. Therefore, this change maintains the requirements of the FNP CTS.

1 A new Note 2 is added, consistent with the original STS Note 1 with the exception that the 60-month limitation is removed. This change is consistent with the wording in IEEE-450. IEEE-450 states "A modified performance test can be used in lieu of a service test at any time." The modified performance test is a test that envelopes the service test. Thus, the successful completion of the modified performance test completes the requirements of the service test. The limitation in the original STS Note 1, with respect to the modified performance test, is inconsistent with IEEE-450 and has been removed.

Chapter 3.8 E5-3-D April,1999

FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.4 DC SOURCES - OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING JD NUMBER JUSTIFICATION 8 The STS surveillance SR 3.8.4.7 note 1 is revised consistent with the FNP electrical system design. His STS note is not part of the FNP CTS. The STS note precludes performance of this battery test in Modes 1-4 as the test renders the battery inoperable. Since the SWIS DC system contains two rdnadant batteryhattery charger sets per train, the limitation imposed by this note is not required for the SWIS batteries. One SWIS battery may be tested in each train while the other battery / battery charger set supplies the required DC train. Therefore, the STS note is revised such that it applies only to the Auxiliary Building batteries. As such, this change is consistent with the FNP specific DC system design.

9 The STS surveillance SR 3.8.4.7 is further revised by the addition of a reference to the FSAR section describing the design load profile consistent with the requirements of the FNP CTS. As this reference is part of the FNP_ CTS, this change maintains the requirements of the FNP CTS. ;

10 The STS surveillance SR 3.8.4.8 note is revised consistent with the FNP electrical system design. This STS note is not part of the FNP CTS. The STS note precludes performance of this battery test in Modes 1-4 as the test renders the battery inoperable. Since the SWIS DC system contains two rdnad=at battery /bauery charger sets per train, the limitation imposed by this note is not required for the SWIS batteries. One SWIS battery may be tested in each train while the other l battery / battery charger set supplies the required DC train. ' Therefore, the STS note )

is revised such that it applies only to the Auxiliary Building batteries. As such, this change is consistent with the FNP specific DC system design.

I 11 The STS surveillance SR 3.8.4.8 is revised consistent with the FNP CTS. He surveillance frequency is revised to be consistent with the requirements of the FNP CTS. As such, this change maintains the requirements of the FNP CTS. )

yA 3 ,1 4 o'7 i i

Chapter 3.8 E5-4-D April,1999

367 DC Sources - Operating 1

8 3.8.4 BASES SURVEILLANCE SR 3.s.4.7 (continued) b y V.S.L3-REQUIREMENTS /

This SR is modified by 8M4tes. Note I allows the performance of a(ood1Fiedfierformance discharge test in lieu of,a service test once per 60 months.

g . a#" s !

r The modified performance discharge test is a simulated duty' cycle consisting of just two rates; the one minute rate p#gi published for the battery or the largest current load of the i TA duty cycle, followed by the test rate employed for the f performance test, both of which envelope the duty cycle of the service test. Since the ampere-ho ws removed by a rated i

' one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for .

the performance test without compromising the results of the e ' performance discharge test. The battery terminal voltage

[M E MM for the modified performance discharge test should remain above the miraimum battery terminal voltage specified in the

>

PFbW^d ' battery service test for the duration of time equal to that of M 844 j ; of the service test.

'pedemt I gg, Qw A modified discharge test .fs a test of the battery capacity m b, **- ' d * ;and its ability to provide a high rate, short duration load I

'(usually the highest rate of the duty cycle). This will sewk.a M often confirm the battery's ability to meet the critical y 9 g* period of the load duty cycle, in addition to determining

.its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical

'to those specified for a service test. -

The reason for Note at performing the Surveillance would perturb the electrical Mis';ribution system and W l

isfy snat uis sR_.fchal'anoe .1CredF; may be samen for unplanneSj safe': v svs f57F-8 --evenus sa j.

SR 3.8.4.s Su N A battery performance discharge test is a test of canthat current capacity of a battery,Giornally done in the as found) neitions after having been in service, to detect any enange in the capacity determined by the acceptance test.

The test is intended to determine overall battery degradation due to age and usage.

(continued)

! WOG STS 8 3.8-57 Rev 1, 04/07/95

g 308 DC Sources - Op3 rating b et y

a e L e . M se.6 o 4e * [ hu.u L BASES + s gg % c,pg g 3g 3,,,,,,y ora pv (,o m%, ,

SURVEILLANCE SR 3.8.4.8 (continued) -

REQUIREMENTS A battery modified performance discharge test is described in the Bases for SR 3.8.4.7. Either the battery performance discharge test or the modified perfo d ince discharpe te acceptable for satisfying SR 3.8.4.8(.Dowever. only th

,jg mod' fled performance discharge test may be used to sati

=- satisfying the requirements of SR 3.8.4.7 The acceptance criter a c rMs Surve111ance are cons ont with IEEE p (Ref. Gnc LEEE-455(Ref.5]. T references recommen that the battery _og_. replaced i its capacity is below 805 of the manufacturer's rating'. A .

j capacity of 805 shows that the battery rate of deterioration i is increasing, even if there is ample capacity to t Ahe- _

load requirements. orh 6 l

mas :

The Surveillance Frequency for this test is 11 r I 60 months. If the battery shows degr ation or if the is j battery has reached 855 of its expec ife I capacity u7 - ;

1993 or une manufacturer's rating the Suryn 1 ince i

g Frscc ::V is i- ssw.v sa m mvietnz.

., . no ver, ' 9 tle ha ter

.W ., v ~.! 7. ned 55 of i ; expo I

1

.v.

TSC.,,11 11 , t Su ill ce F quen is nly red to ths or ter t reta n e= =aity n of a nuf ture s ra no.Ipegradation' i d'cated, according to Itu-450 (Ref.' 9), when the batt pacity drops by more than 105 relative to its ca the previous S -

performance test or when it 1s]g) 05 below the manufacturer's rating. These Frequencies are consistent Y'Se2dl4 with the recommendations in IEEE-450-(Ref. 9).

1 This SR is modified by a Note. The reason for the Note is that performing the Surveillanc hwould perturb the Y electrical distribution system shd challen<ae safety systems.

gyp.g J creciT. may be taken for unplant ea events tiat satisfy this) oh nubtil.is.r SuiIcl REFERENCES 1. 10 CFR 50, Appendix A, GDC 1

2. Regulatory Guide 1.6, March 10,1971.

3. IEEE-3 8 TI Y (continued)

WOG STS 8 3.8-58 Rev 1, 04/07/95

. Associated Package Changes for RAI-3.8.4 09 i

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2W -

CHAPTER 3.8 INSERTII t

V,[g STS BASES PAGE B 3.8-51 The Auxiliary Building batteries are stationary type consisting of 60 individual lead-calcium cells l electrically connected in series to establish a nominal 125VDC power supply. Under both normal and accident conditions the baueries are capable ofproviding the required voltage for ,

camaaaaat operation considering an aging factor of 25% and minimum electrolyte temperature of 60*F. The battery float voltage is 2.20V per cell average and 132V total terminal voltage.

During an LOSP or LOSP with SI, the Auxiliary Building batteries supply safety-related loads for a period ofless than one minute duration without charger support. The design is such that subsequent to LOSP, the battery chargers are re-energized by the Diesel Generators within one minute.

9 Although not a requirement for the mitigation of design basis events, each battery is capable of providing LOSP or LOSP plus SI loads for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months assuming the single failure loss of the battery charger aligned at the onset of the event. During such an occurrence, the re aA=at train battery with its connected c~ trger remains fully capable ofpmviding DC power to redundant train safety-relatedIc . The batteries also have the capacity to supply nonnal operatingloads for a period of. Jurs without charger support as discussed in the FSAR Chapter 8.3 (Ref. 4). The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months perio ~ f time is adequate to allow alignment of the spare battery charger to the affected battery wahout disrupting continued operation.

The SWIS batteries are stationary type consisting ofindividual lead-calcium cells electrically M u=tei in series to establish a naminal 125VDC power supply. They are sized to furnish the anticipated vital loads without dropping below a total battery voltage of 105V. Under both normal and accident conditions the batteries are capable ofpmviding the required voltage for component operation considering an aging factor of 25% and a minimum electrolyte tepeanne of 35'F. The battery float voltage is 2.20V per cell average and 132V total. Each SWIS battery subsystem has adequate capacity to carry its loads without charger support for a period of at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as diam in the FSAR, Chapter 8.3 (Ref. 4).

t INSERT JJ STS BASES PAGE B 3.8-51 Each battery charger has adequate capacity to restore its battery to full charge after the battery has been disseisM while canying steady-state normal or emergency loads. The time required to recharge the battery to full charge is compatible with the recommendation of the battery manufm,Lua (Ref. 4).

Chapter 3.8 Insert Page

Associated Package Changes for RAI- 3.8.4-10 l

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DC Scurces - Operating i

4 The 914 voty .F 2.2.V per er132V

ovem.H ss thenom elese hv'olf e, oft 25V BASES inP*t and.as w e enam NJ Ws

_ for _ nfr 6 -

Tre. W M W h t.w w w)9. h 1

f- - p e - is i tr7 6 yrov4<.s e.ume M ACTIONS I.1andf.2 (continued) 'Ny eM can wohs b aWad

@ h 2, ov. M*A=

i S t 4-within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed ;

reasonable, based on operating experience, to reach t r

V % "j ]2V P8' P ired unit conditions from full power conditions in an C8" h '.

o rly manner and without challenging plant systems. Th "f 7 j, Completion Time to bring the unit to MODE 5 is consistent IN6ER.T m with the time required in Regulatory Guide 1.93 (Ref. 8).

knoooE.If-+

SURVEILLANCE SR 3.a.4.1 RE0urnamTs

&888'" 45n-indVerifying battery terminal voltage while on float charge for- ,

the batteries helps to ensure the effectiveness of the i

,0L , s,wl, charging system and the ability of the batteries to perform p t, their intended function. . Float charge is the condition in

'Y A . rnI1N"[f $$tYry(or if battery cell) and maintain the battery (or a battery cell I ce%MDW 8% d.

dur,% in a fully charaad ntate., sne voitage requirements are necmd epemfC based on the nomina' design voltage of the battery and are consistent with the initial voltaaes assu=ad in the battery moen F Jizina calculations.JThe 7 day Frequency is consistent wi".h

N' Omanufacturer recommenaations aneJEEE-450 (Ref. 9). , ,

l p SR 3.8.4.2 j@ SE CT8 4.9.2.3.2.b.L

e. m .s.2.i.2.t.2 Visualynsoectiontodetectcorrosi 4to "**"

htersnOdr e batter e I e, Ond connectioTn )tfr mensuremont of th sistance.of a i l

ntert' er, ana terminal connect 1 My Mmnten:es provides i, interract.

an indication oripnysical damage or abnorma't,A -

ceterioration_ snas cousa Dotentially degrade batteryJ -

g .

performance.J h r c. p g EThe 1 ts establ hadfort41sSRsus be"no than 0% sc5.

he resist ce as seplured dur instal ation o not 'M NC.['abov M*T*'88 ,a the cell g value aphablished, the ufactu .

b sc.s input The'Surve111ance Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This Frequency is considered acceptable based on operating experience related to detecting corrosion trends.

(continued)

WOG STS B 3.8-54 Rev 1, 04/07/95

Associated Package Changes for RAI . 3.3.5-01 1

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/9/ DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown 3 F,,4 oi (O

LC0 3.8.5 DC electrical power subsyst hall be OPERA 8LE to support the DC electrical power distribution subsystem (s) required by LC0 3.8.10, " Distribution Systems - Shutdown."

APPLICA8ILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS

~

CONDITION REQU TION COMPLETION TIME A. One or more required A.1 lare affected Immediately DC electrical power required feature (s) subsystems inoperable. inoperable.

E A.2.I Suspend CORE Ismediately ALTERATIONS.

81E1 A.2.2 Suspend movement of Ismediately ,

irradiated fuel '

assemblies.

g - I 1

l A.2.3 Initiate action to Immediately I suspend operations ;

involving positive )

reactivity additions. !

I M \

(continued) ;

i I

i WOG STS 3.8-28 Rev 1, 04/07/95 e

C___

i FNP TS Conversion Enclosure 5 -JD from STS Chapter 3.8 - Electrical Power Systems I

STS 3.8.5 DC SOURCES - SHUTDOWN FNP ITS 3.8.5 DC SOURCES - SHUTDOWN (

l JD I NUMBER JUSTIFICATION j 1 The STS 3.8.5 Action A.I.1 is revised consistent with the correct use oflogical l connectors in the STS. ' Ibis change deletes the extra .1 from the Required Action {

numeric identifier consistent with the appropriate Required Action numbering

. format for this Action. The STS Required Action A.I.1 consists of a single action with no associated follow-up action (s). Therefore, the correct numbering of this j Action is A.I. As such, this change corrects a minor typo in the STS. , i I

2 The Note modifying STS surveillance 3.8.5.1 is revised editorially for clarity. The )

Note is revised to clearly state the surveillances listed in the Note "are applicable". l This editorially enhancement is completely consistent with the detailed STS bases !

l explanation of this Note. The inclusion of this enhancement will help users to understand the intent of the Note more readily. The exception provided by the Note g does not except the requirement for the DO to be sagable of performing the )

[ P ,6'g particular function,just that the capability need not be demonstrated while that source of power is being relied on to meet the LCO.

j l

3 The statement of the LCO is modified to reflect the fact that more than one DC electrical power subsystem may be required OPERABLE to support the DC electrical power distribution subsystem (s) required by LCO 3.8.10 (for example, a SWIS DC electrical power subsystem and an Auxilivy Building DC electrical power subsystem). This adds intemal consistency to the LCO and the FNP ITS.

I l

1 Chapter 3.8 ES-1-E April,1999

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Associated Package Changes for RAI- 3.8.6-06 1

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FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.8 - Electrical Power Systems CTS 3/4.8.2.3 AUXILIARY BUILDING DC DISTRIBUTION - OPERATING FNP ITS 3.8.9 DISTRIBUTION SYSTEMS OPERATING FNP ITS 3.8.4 DC SOURCES - OPERATING I

FNP ITS 3.8.6 BATTERY CELL PARAMETERS j DOC l ND SHE DISCUSSION I from the TS and placed in the applicable bases discussion for Table 3.8.6-1.

The requirement to correct specific gravity readmgs for electrolyte f

temperature remains in the TS (STS note b to Table 3.8.6-1). The removal of this detail from the TS is consistent with the STS. Reliance on the information contained in the STS bases is acceptable since changes to the information in the bases is controlled by the Bases Control Program 3 specified in the administrative controls section of the TS.

23 L The CTS 3/4.8.2.3 Table 4.8-2, Battery Surveillance Requirements footnote I i

(b) is revised consistent with the STS. This CTS footnote which allows the use of charging current in place of specific gravity readings at all times for I

Category A limits (applicable to pilot cells) is revised and re-labeled consistent with the corresponding footnote (c) in the STS. The CTS value of 2 amps associated with this note is retained and is consistent with the current FNP licensing basis as specified in the CTS. The corresponding STS footnote (c) restricts the use of charging current in place of specific gravity to 7 days after battery recharges only. However, the STS footnote allows the use of charging current in lieu of specific gravity for Category B U and C limits which apply to all connected cells as well as Category A limits 3.h,0 applicable to pilot cells. The allowance provided by the STS note (c) is acceptable since a stabilized charger current is an acceptable alternative to specific gravity measurement for determining the state of battery charge within 7 days following a recharge. In addition, the use of charging current l

in place of specific gravity may increase the battery availability by allowing a quicker restoration to service after required charging evolutions.

24 A The CTS 3/4.8.2.3 Table 4.8-2, Battery Surveillance Requirements footnotes 1-4 represent Required Actions and are stated as such in the STS 3.8.6, Battery Cell Parameters. These Actions are modified by a note J consistent with the STS 3.8.6. The STS note clarifies that separate I Condition entry is made for each affected battery. The use of this type of STS note is explained in example 1.3-5 in Section 1.0 in the STS. The clarification provided by this note is consistent with the intent of the battery cell parameter Actions which provide adequate remedial measures for each !

Chapter 3.8 E2-9-E April,1999 u __ ___

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FNP TS Conversion Enclosure 5 - JD from STS Chapter 3.8 - Electrical Power Systems STS 3.8.6 BATTERY CELL PARAMETERS FNP ITS 3.8.6 BATTERY CELL PARAMETERS JD.

NUMBER JUSTIFICATION 3/4.8.2.3, Auxiliary Building DC Distribution - Operating. The incorporation of

. this additional action into the STS maintains the requirements of the FNP CTS.

5 The STS surveillance SR 3.8.6.2 is revised consistent with the CTS. 'Ibe STS surveillance frequency is revised from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 7 days consistent with the CTS 4.8.2.3.2.b surveillance interval. Therefore, this change maintains the requirements of the FNP CTS.

6 The STS surveillance SR 3.8.6.3 is revised to incorporate the two temperature, l limitations for the two different battery types used at FNP. This change is f consistent with the design specifications, as discussed in the FSAR, for each type of TS required battery at FNP. The inclusion of the two temperatures limits accurately incorporates the FNP specific design into the STS.

7 The STS Table 3.8.6-1, Battery Cell Parameters Requirements, are revised consistent with the corresponding FNP requirements in C TS Table 4.8-2. The Floa*

Voltage and Specific Gravity sections of this STS Tr.ble are revised to incorporate the FNP CTS requiremems. These changes maintain the reqmrements of the FNP CTS.

The Category A limit specified for float voltage is 22.08V per cell. This value is less than the 2.13V which IEEE 450 (Ref. 3) recommends for optimum life expectancy ofcells. The lower FNP value is based on the following: 1) cell float

[gloA voltage is not, by itself, the only indicator of the state of charge; 2) a single cell I' voltage can be s2.13V while the battery itselfis still capable of performing design function; 3) a cell is not be considere4otendally degraded unless 52.07V,per IEEE 450. In addition, operating experience has shown that for numerous instances at FNP with at least one cell below 2.13V, the minimum average specific gravity for the battery equated to capacity well above that required by the design load profile.

The STS limits for specific gravity at the time the FNP CTS were approved were based on manufacturers recommended full chstge value of 1.215. The STS ,

Category A and B test criteria based on thtt value was 1.200 and 1.195 respectively.

[$ FNP batteries have manufacturers recommended specific gravity of 1.210 for the SWIS and 1.215 for the Auxiliary Building batteries. As a result, the specific gravity criteria of 1.195 knd 1.190 for Category A and B respectively were approved for use in the CTS for both batteries. ,

Chapter 3.8 ES-2-F April,1999

.. . . ,...m . . . . .. }

1 J/9

attery Cell Parameters BASES opemhgpQ 8' SURVEILLANCE Table 3.8.6-1 (continued)

REQUIRENENTS suffer no physical damage, and t at adequate electron transfer capability is maintaine in the event of transient conditions. IEEE-450 (Ref. 3) r comends that electrolyte level readings should be made on1 r after the battery ha p 3,q//'g been at float charge for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

. ?$C- The Category A limit specified fqafloat voltage is a: 2 V ner cell. This value is based on3hi recommendations pgf Ittt-gov (Ref. 3), which states that prolonged operation of cells < 2.13 V can reduce the life exoectancy of cells.

MA ;

e Categor Ty imit s fied for specific aravity far each pilot co'1 is E fl.200A O.u n puisw sne manufacturer ful'y __

S ,y V cnarg nuisinas sym.ir c gravity or a battery ciaroinn leurrei.t that had stabilizac at a Irw value).1 T1's va ue is Q[

6g ig# EP.W acteristic of a charge cell<w'th adequate capacity. g0

/, / 75, According to IEEFC0 (Ref. 3), the specific gravity readings are basd on a temperature of 77'F (25'C).

N The specific gravity readings are corrected for actual electrolyte temperature and level. Foreach3*F(1.67'C) above 77'F (25*C),1 poir.t (0.001) is added to the reading; 1 point is subtracted for each 3'F below 77'F. The specific gravity of the electrolyte in a cell ine eases with a loss of water due to eleci,trolysis or evaporatbn.

Category 8 defines'the normal parameter limits for each connected cell. The term ' connected cell" excludes any battery cell that may be jumpered out.

f op. g,[ ? efloat Category vo tage areB limits specified the same for electrolyte as those specified for Category level A q and _

Ipunti-9 and have been discussed above. The Category 8 limit sPeci ed for soecific gravity for each connected cell is 5d T a:f[1.;,15] (0.020 below the. manufacturer fully charged, a

)O{ t) with the average of all connected prominal'specificgravity)lowthemanufacturerfullycha ed cells >(1:205](0:0~10be I nominaT".specificgravity). These valuss are based on l

, , ,t aanufacturor's recomeendations. 1The minimum s scific !

gravity va'ue equireo for eacn cell ensures t1at the !

,e effects of a highly charged or newly installed cell will not 1 mask overall degradation of the battery. i (continued) f WOG STS B 3.8-68 Rev 1, 04/07/95 i l

l i

m 1 3

CHAPTER 3.8 f

INSERT AAA

,V TO STS BASES PAGE B 3.8-68 4' FNP SPECIFIC BASES FORTABLE 3.8.6-1 This experience has shown numerous instances when at least one cell was measured at less than 2.13 volts DC at FNP. In such instances, the minimum average specific gravity was 1.197 equating to approximately 90% capwity which is well above that required by the design load profile. In addition, the float voltage limit of 2.08V is acceptable based on: 1) float voltage by 4 itself not being a comprehensive indicator of the state of charge of a batterv; 2) pilot cells exhibiting s 2.13V not elimia*iag battery capability to perform design function; and 3) IEEE 1 450-1980 Appaadir Cl does not consider a cell potentially degraded unless its voltage on float !

charge is s 2.07V.

: J INSERT BBB j TO STS BASES PAGE B 3.8-68

$y ;

$ FNP SPECIFIC BASES FOR TABLE 3.8.6-1 J The manufacturers recommended fully charged specific gravity is 1.215 for the Auxiliary Building and 1.210 for the SWIS batteries. The value of 0.015 below the manufacturers re:w==M_ fully charged value for SWIS batteries has been adopted as the Category A ,

mir.imum for both the Auxiliary Building and SWIS batteries. (

}

l 1 INSERT CCC TO STS BASES PAGE B 3.0-68 FNP SPECIFIC BASES FOR TABLE 3.8.61

~

1.190 with the average for all a+=Nei cells 2: 1.195 The manufacturers recommended fully charged specific gravity is 1.215 for the Auxiliary Building and 1.210 for the SWIS batteries.

The value of 0.020 below the manufacturers recommended fully charged value for SWIS batteries has been adopted as the Category B minimum for each wied cell for both the Auxiliary Building and SWIS batteries.

Chapter 3.8 Insert Page

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- Associated Package Changes for RAI- 3.8.9-05 l

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Nd Distribution Systems - Operating 8 3.8.9 8 3.8 ELECTRICAL POWER SYSTEMS 8 3.8.9 Distribution Systems - Operating i BASES BACK The onsite class IE AC, DC, and AC vital b actrica

@ power distribution systems are divided av urain7into t redundantpower electrical and independent distributionAC, DC. and Hubsyst pgg.MO{p

__ g aT hus _ _

N Ar electrica r each train con ts of a prima y Feature (ESF) 4.16 kV and secondary buses, distributionm s, actor gg controjen d centers. Each gt.15 TV ESF bu ,

has atjTeast eparate a apendedtoffsite source of

' % o6 powergaswel( a maaicates te diesel generator (DG) 39A source. Each d .16 kV EW W is normally connected to a M preferred offs'te source. I M ter a loss vi 6e v..rs un m e power source to a 4.16 kV ESF bus, a transfer to the3 alternate offsite source is accomo:1shed bv milizine a th delavod bus undervoluane relu rF all of"s ne sources are

% unava'lanie, tae onstte emergency DG supplies power to the 4.16 kV ESF Me Control power for the 4.16 kV breakers is supplied from the Class IE batteries. Additional (gs) description of this system may be found in the Bases for LC0 3.8.1, "AC Sources - Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."

The secondary AC electrical power distribution system for each train includes the safety related load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.

The 120 VAC vital buses are arranged in two load g wups per train and are poreally powered from the inverters. The alternate power supply for the vital buses are Class IE constant voltage source transformers powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, " Inverters - Operating." Each constant voltage source transformer is powered from a Class IE AC bus.

There are two independent 12 25 VDC electrical power distribution subsystems (one oreachtrain).

The list of all required distribution buses is' presented in Table B 3.8.9-1.

(continued)

WOG STS 3 3.8-79 Rev 1, 04/07/95

_._.__.__.__A

ML20206F442

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