ML20206U910
| ML20206U910 | |
| Person / Time | |
|---|---|
| Site: | Callaway |
| Issue date: | 09/29/1986 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20206U853 | List: |
| References | |
| NUDOCS 8610080452 | |
| Download: ML20206U910 (40) | |
Text
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PROPOSED TECHNICAL SPECIFICATIONS - MARKED-UP Page 3/4 8-1 Page 3/4 8-2 Page 3/4 8-3
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Page 3/4 8-4 Page 3/4 8-5 Page 3/4 8-6 Page 3/4 8-7 Bases page B 3/4 8-1 Insert page 1 Insert page 2
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REVIStay y
3/4.8 ELECTRICAL PCWER SYSTEMS m
3/4.8.1 A.C. 500RCE5 OPERATING LIMITING CONDITION FOR OPERATICN 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
Two physically independent circuits'between the of fsite transmission a.
network and the Onsite Class 1E Distribution System, and b.
Two separate and independent diesel generators, each with:
1)
A separate day tank containing a minimum volume of 390 gallons of fuel, 2)
A separate Fuel Oil Storage System containing a minimum volume of 85,300 gallons of fuel, and 3)
A separate fuel transfer pump.
's APPLICABILITY: MODES 1, 2, 3, and 4.
9 ACTION:
O n<. oEbe Csecuit snoprable. :
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a.) With-e44.%w an offsite circuit er dic::? g:ncr:ter of the above
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required A.C. electrical p g n sources inoperable, demonstrate the u
OPERABILITY of the remainingAA.C. sourceX by performing Specifica-tionx 4.8.1.1.1 :nd *.S. ' 1.22. 9 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once 7 g per5hoursthereafter;4bstoreatleasttwooffsitecircuitsand two diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HCT STANOBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUT 00WN wilhic the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />..
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'one' cirWik dccult and Ons Diesd 6sne rder Inope=W !
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';!ith one of f site circuit and one diesel generator of the above required A.C. electrical pc en sources inoperable, demonstrate the j
OPERABILITY of the remainin 44.C. sourcex by performing Specifica-we 'c" tionx 4.8.1.1.1 : d *. 3. ' 1. 22. 4-) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per8hoursthereafterrtbstoreatleastoneoftheinoperable i
sources to CPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT j
- s' ___ STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUT 00WN within the j
c w,,7 fellowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. RestoreVat ! : :c t ti:0 ef' tite ci c"f*: r d tt:0 i
di : ' ;;;n;r t;r; t^ PEUSL5 :t * :
ith'- 72 h:27
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cf initi;l 10:: cr 5: ' at 1:::t "CT ST'MOSY wi th'- th; n;xt C M.. ;
- nd ir COLO SHL'TCCU" u'th'- the f0!! uing 20 heure, b
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With one diesel generator inoperable in addition to ACTION A. or R.
above, verify that:
1.
All required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and
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REVISlay y
ELECTRICAL PCWER SYSTEMS
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LIMITING CONDITION FOR OPERATION 7
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, ACTION (Continued)
When in MODE 1, 2, or 3, the steam-driven auxiliary feedwater 2.
pump is OPERABLE.
If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, Tu oMrs% tirtMs Incperallc l
e )(.pWith two of the above required of fsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by performing
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8 Specification 4.8.1.1.2t.4) within % houm:nd it ?:::t :n:: ;;r 3 n;;rs thereafter, unless the diesel generators are already operat-ing; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within JNsanT 'E" the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.4 L'ith :nly re Of f:it: ::;r:: rc:t:r:d, r::t:r: It least two ;ffsite ciccuits ;; OPE 0AOL: ;tatu; withia 72 he c; fr;c time ;f initisi !;;; ;r :: 'n et ?:::: "0T ST*"CSY with'- th: ::t 6 huu. a sod... COLO CM'JT00'4" within the f;? ?: wing 30 heur:.
oies.l (.enecabrs Inogera4fc '
f X.[ LeWith two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by perform-ing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT
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Insagr p' STANDBY within the_ next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withi'n the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.N Re:t r at 1:::t tw; di:::1 gener:t:r: t:
0?CRACLC atstes ithia 72 h;srs f ce-tiac ;f !;itici 1;;; ;r 5: 'n 4eest "0T STANOSY within the next C h;urs and in COLO 5""TOCLN withi-the f;il: wing 20 h:ur:,
SURVEILLANCE REQUIREMENTS 4.8.1.1.1 f ach of the above required independent circuits between the offsite transmission network and the Onsite Class lE Distribution System shall be determined OPERABLE at least once per 7 days by verifying correct breaker -
l alignments indicated-power availability.
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ELECTRICAL power SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
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4.8.1.1.2 Each diesel generator shall be demonstrated CPERABLE:
a.
In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:
- 1)
- Verifying tne fuel level in the day tank, 2)
Verifying the fuel 1.evel in t,he fuel storage ta'nk, 3)
Verifying the fuel transfer pump starts and transfers fuel from the storage system to the day tank, 4)
Verifying the diesel starts 'r:: P!:nt ::nditieft and accele-rates to at least 514 rpm in less than or equal to 12 seconds."'*
The generator voltage and frequency shall be 4000 1 320 volts and 60 1 1.2 Hz within 12 seconds **after the start signal. The l,
diesel generator shall be started for this test by using one of the following signals:
a)
Manual, or b)
Simulated loss-of-offsite power by itself, or c)
Safety Injection test signal.
yg 5)
Verifying the enerator is synchronized ^1oaded' to greater tpan or equal to kW in is:s than er equal to CO ;c; sad A % erates with a load greater than or equal to-63% kW for at least 60 minutes, and N
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6)
Verifying the diesel generator is aligned to provide standby power to the associated emergency busses, b.
At least once per 31 days and after each operation of the diesel where the period of operation was ' greater than or equal to I hour by checking 2
for and removing accumulated water from the day tanks; c.
At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks; d.
By sampling new fuel oil in accordance with ASTM-04057 prior to addition to storage tanks and:
1)
By verifying in accordance with the tests specified in ASTM-0975-81 prior to addition,to the storage tanks that the sample has:
4 *The5e diese! geneceter 3terts fces e Lient cenditiens shell be pecfu.mW e,,1y enc; p;r 1"? d:- : :- thch; :ur;;ilicaca tests and al-1 ether engine ste ts 'es j
-the purp;;e of'This ;ur;;i'?cnt: testifwy shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
(.h CALLAWAY - UNIT 1 3/4 8-3 t
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ELECTRICAL POWER SYSTEMS
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SURVEILLANCE REQUIREMENTS (Continued) a)
An API Gravity of within 0.3 degrees at 60*F, or a specific gravity of within 0.0016 at 60/60*F, when compared to the supplier's certificate, or an absolute specific gravity at 60/60*F of greater than or equal to 0.83 but less than or equal to 0.89, or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees; b)
A kinematic viscosity at 40*C of greater than or equal to 1.9 centistakes, but less than or equal to 4.1 centistakes, if gravity was not determined by comparison with the supplier's certification; c)
A flash point equal to or greater than 125'F; and+
r d)
A clear and bright appearance with proper color when tested in accordance with ASTM-04176-82.
2)
By verifying within 30 days of obtaining the staple that the other properties specified in Table 1 of ASTM-0975-81 are met when tested in accordance with ASTM-0975-81 except that the analysis for sulfur may be performed in accordance with ASTM-01552-79 or ASTM-02622-82.
At least once every 31 days by obtaining a sample of fuel oil in e.
accordance with ASTM-02276-78, and verifying that total particula:e contamination is less than 10 mg/ liter when checked in accordance i
with ASTM-02276-78, Method A;
- f. # At least once per 18 months, d" ia" ^ " + d-a, by:
~ll 1)
Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service; 2)~
Verifying the diesel generator capability to reject a load of greater than or equal to 1352 kW (ESW pump) while maintaining a
voltage at 4000 1 320 volts and frequency at 60 5.4 Hz;
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'3)
Verifying the diesel generator capability to reject a load of
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6201 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection; 4)
Simulating a loss-of-offsite power by itself, and:
a)
Verifying deenergization of the emergency busses and load shedding from the emergency busses, and se i
b)
Verifying the diesel starts on the auto-start sigril, l
energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the shutdown sequencer and operates for greater than or equal to 5 minutes while its generator
- The specified 18 month frequency may be waived for Cycle I provided the surveillance is performed prior to restart following the first refueling outage or June 1, 1986, whichever occurs first. The provisions of Specification 4.0.2 are reset from performance of this surveillance.
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bbEVfStoy ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) l
!s loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 2 320 volts and 60 2 1.2 Hz '
during this test.
Verifying that on a Safety Injection test signal without loss-l 5) of-offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to
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5 minutes; and the offsite power source energizes the auto-connected emergency (accident) load through the LOCA sequencer.
4000 2 320 volts The generator voltage and frequency shall be and 60 21.2 Hz within 12 seconds after the auto-start signal; the generator steady-state generator, voltage and frequency shall be maintained within these limits duringithis test; Simulating a loss-of-offsite power in conjunction with a y
6)
Safety Injection test signal, and Verifying deenergization of the emergency husses and. load
^
a) shedding from the emergency busses; a
Ae Verifying the diesel starts on the auto-start signal, l'
b) energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-con _nected emer-
_)
gency (accident) loads through the LOCA sequencer and
_,j operates for greater than or equal to 5 minutes whfie its After energiza-generator is loaded with emergency loads.
tion, the steady-state voltage and frequency of the emer-4000 1 320 volts and
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gency busses shall be maintained at 60 1.2 HZ durihg this test; and Verifying that all automatic diesel generator trips, except c) high jacket coolant temperature, engine overspeed, low lube oil pressure, high crankcase pressure, start failure relay, and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal.'
Verifying the diesel generator operates fo'r at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
7)
During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to greater than or equal to 6821 kW and during the.
remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to greater than or equal to 6201 kW.
The ' generator voltage and frequency shall be 4000 2 320 volts and 60 + 1.2,-3 Hz within 12 seconds after the start signal; the steady-state generator voltage and frequency shall be maintained within 4000 1 320 volts 1.2 Hz during this test. Within 5 minutes after complet-and 60 1 ing this.24-hour test, perform Specification 4.8.1.1.2f.6)b)*;
"If Specification 4.8.1.1.2f.6)b) is not satisfactorily completed, it is not Instead the diesel generator necessary to repeat the preceding 24-hour test.
may be operated at 6201 k'W for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until operating temperature has stabilized.
y 3/4 8-5 CALLAWAY - UNIT 1 This t<d All be preen. led by u eny n c, prclohc. perIo6 aal[or o +her-w mn Achur so hi A
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SURVEILLANCE REQUIREMENTS (Continued) l 8)
Verifying that the auto-connected loads to each cLiesel generator do not exceed 6201 kW; 9)
Verifying the diesel generator's capability to:
a)
Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restora-
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tion of offsite power, b)
Transfer its loads to the offsite power source, and-c)
Be restored to its standby status.
Verifying that with the diesel generator operating in a test mode, 10) connected to its bus, a simulated Safety Injection signal overrides the test mode by: (1) returning the diesel generator to standby operation, and (2) automatically energizing the emergency loads with offsite power; Verifying that the fuel transfer pump transfers fuel from eac!'
fuel storage tank to the day tank of each diesel via the installed cross-connection lines; and 12)
Verifying that the automatic LOCA and shutdown sequence timer is OPERABLE with the l~nterval between each load block within t 10%. of its design interval.
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At least once per 10 years or after any modifications which could
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affect diesel generator interdependence by starting %oth diesel generators simultaneously, during shutdown, and verifying that both diesel generators. accelerate to at least 514 rpm in less than or equal to 12 seconds; and h.
At least once per 10 years by:
1)
Draining each fuel oil storage tank, removing the accumulated sediment and cleaning,the tank using a sodium hypochlorite solution or equivalent, and 2). Perfonning a pressure test of those portions of the diesel fuel
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nil system designed to Section III, subsection ND of the ASME Code at a test pressure equal to 110% of the system design pressure.
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INseni G-Reports - All diesel generator failures, valid or nonvalid, shall
- 4. 8.1.1. 3 be reported in a Special neport to the Commission pursuant to Specifica-tion 6.9.2 within 30 dr.fs.
Reports of diesel generator failures shall include the information reco.aended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1,. August 1977. If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1,
.J August 1977.
CALLAWAY - UNIT 1 3/4 8-6
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2 TABLE 4.8-1 4t' a
OIESEL GENERATOR TEST SCHEDULE Mouss A.a FAstwess taJ NUMBER OF FAILURES IN Lasr 2o vauo Tests ^ cm.LAST 100 VALIO TESTS" TEST FREQUENCY
$1
<X4 At least once per 31 days Atleastonceperkdays 2 2." "
lX5 s
X
- a. : i::: :::: per ' d y:
K At 1::: :n:: p r 2.d;y:
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Cde,.4 n s o4 his b.bla,
bo4 d<.kt<mine b on o-Psr diessl jentrakor loasts.
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" Criteria for determining umber of failures and number of valid tests shall be in accordance with Re ulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977,,.5.:r: the !::t 100 te:t: :r: d:ter 'ned en : pee
^ucie:r un!t 5 :!:. For th: purp::: f thi: ::h dule, caly v lid te:ts
- nd::ted eft:r th: ::;pi:ti:n :f the pre:p;r:ticaci te:t requi ;..;nt sf Reguintory Cuf de 1.100, Revi:!:n 1,.*ugu:0 1077, :h i' b: includ;d in the
- =put: tion of th: "L::t 100 '!c. lid Ta ::."
regs;rea 4 e.4 f rego.oc.y,4h preutout 4<sk k.,itvet.
Fee M<. pu rpose.s d 4 dum".d.og +h.
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cowel my u es.%vu.h to le.ro '6 v a. c.amglsk. diud ovsrh64l b lih-new conEk.*.as is
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anl fe d.'na, is perker m l p<v 4 M rusno4*dut<fs ku b n'5 56l m snu ds, a n h '.7 Accef -
k aW tc.t:sut h has been 44.rn n64rskb. A f4*Wtify cihr/on skal L. +k sucess*%w l c.amptsE *n of 14 : : - N" ~ ca^ s.c Mist, tests in o iengk, 6tedd. Ten of ecw. tab ccor4=nu, v'Ih [pw Cod.% 48.441s.4),*4*st 4eds ~'d A"' 'd *d 4 ' 'h dhR 44. To a
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J/4 j dLEC1RICAL POWLH SYSTEMS r..
BASES
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A.C. SOURCES. 0.C. SOURCES, and ONSITE P WER 3/4.8.1, 3/4.'8.2, and 3/4.8.3 OLSTRIBUTION R BILITY of the A.C. and 0.C power sources and associated The-OPE A distribution systems during operation ensures that sufficient power will be (1) the safe available to supply the safety-related equipment required for:
shutdown of the facility,.:nd (2) the mitigation and control of accident condi.
The minimum specifled independent and redundant-tions within the facility.
A.C.
- and 0.C. power sources and distributf ort systems satisfy the requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50.
t The ACTION' requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate The OPERASILITY of the power sources are with the level of degradation.
consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and 0.C.
,i i
ident
, power sources and associated distribution systems OPERA 8LE dur ng accloss-of-offsite
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conditions coincident with an assumedThe A.C. and 0.C. source allowable out-of-of the other onsite A.C. source.
service times are based on Regulatory Guide 1.93, " Availability of Electrical I
Power Sources," December 1974. When one diesel generator is inoperable, there 4 ";
is an additional ACTION requirement to vepify that all required systems.
subsystems, trains', components and devices, that depend on the remaining OPERA 8LE diesel generator as a source of emergency power, are also OPERA 8LE, This require-and that the steam-driven auxiliary feedwater pump is OPERABLE.
ment is intended to provide assurance that a loss-of-offsite power event will not result in a complete loss of safety function of critical systems during The term verify as used the period one of tne diesel generators is inoperable.
in this context means to administratively check by examining logs or other information to determine if certain components are out-of-service for maintenance It does not mean to perform the Surveillance Requirements or other reasons.
rieeded to demonstrate the OPERA 8JLITY of the component.
The OPERABILITY of the minimum specified A.C. and 0.C. power sources and associated distribution systems during shutdown and refueling ensures that:
(1) the facility can be maintained in the shutdown or refueling condition for extended time periods, and (2) suf ficient instrumentation and control capability are available for monitoring and maintaining the unit status.
The Surveillance Requirements for demonstrating the OPERA 8ILITY of the
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cliesel generators are in accordance with the recommendations of Regulatory Guides 1.9, " Selection of Diesel Generator Set Capacity for Standby Supplies", March used as Unsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977; and 1.137, " Fuel-Oil Systems for Standby Oiesel Ganerators,"
Revision 1. October 1979.
No.
insed mdddl by Anwdru.d c.5 8 3/4 8-1 CALLAWAY - UNIT 1
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i INSERT PAGE 1 INSERT
'A' "If either diesel generator of the above required a.c.
electrical power sources has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate OPERABILITY by performing Specification 4.8.1.1.2a.4) for that diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
INSERT
'B' "b.
One Diesel Generator Inoperable With one diesel generator of the above required a.c. electrical power sources inoperable, demonstrate the OPERABILITY of the offsite a.c.
sources by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> I
thereafter.
Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by perfgrming Specification 4.8.1.1.2a.4) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and rectore the inoperable diesel generator to OPEhABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT ST3NDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
In addition perform ACTION d."
INSERT "C" and Specification 4.8.1.1.2a.4) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the remaining diesel generator.
INSERT "D"
. the remaining inoperable a.c. electrical power source (offsite circuit or diesel generator) inoperable to OPERABLE status in accordance with the Specification 3.8.1.1 ACTION a.
or ACTION b., as j
applicable, with the time requirement for the ACTION based on the time of the initial loss of the remaining inoperable a.c. electrical power source.
A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4) under this ACTION for an OPERABLE diesel generator satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a or ACTION b. for an OPERABLE diesel generator.
In addition perform ACTION d."
INSERT
'E' "Following restoration of one offsite a.c. electrical power source, follow ACTION a.
above with the time requirement of ACTION a. based on the time of the initial loss of the remaining inoperable offsite a.c.
l l
a 4
INSERT PAGE 2 electrical power source.
A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4) under this ACTION for the diesel generators, satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a."
INSERT'F' "Following restoration of one diesel generator, follow i
ACTION b. with the time requirement of the ACTION based on the time of initial loss of the remaining inoperable diesel generator.
A successful test of diesel generator OPERABILITY performed in accordance~with Specification 4.8.1.1.2A.4 under this ACTION for the OPERABLE diesel generators, satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION b."
INSERT
'G' "1.
At least once per,184 days the diesel generators shall be started and accelerated to at least 514 rpm in less than or equal to 12 seconds.
The l
generator voltage and frequency shall be 4000 1 320 volts and 60 1.2 Hz within 12 seconds after the start signal.
Subsequently verify the generator is loaded to greater than or equal to l
6201 kW in less than or equal to 60 seconds and operates with a load greater than or equal to 6201 kW for at least 60 minutes."
! to ULNRC-1376 l
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PROPOSED TECHNICAL SPECIFICATIONS - TYPED i
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I 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C.
SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
a.
Two physically independent circuits between the offsite transmission network and the Onsite Class IE Distribution System, and b.
Two separate and independent diesel generators, each with:
1)
A separate day tank containing a minimum volume of 390 gallons of fuel, 2)
A separate Fuel Oil Storage System containing a minimum volume of 85,300 gallons of fuel, and 3)
A separate fuel transfer pump.
APPLICABILITY:
MODES 1, 2,
3, and 4.
ACTION a.
One Offsite Circuit Inoperable:
With_an offsite circuit _of.the above required A.C.
electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. source by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either diesel generator of the above required a.c. electrical power sources has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate OPERABILITY by performing Specification 4.8.1.1.2a.4) for that diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Restore at least two offsite circuits and two diesel generators to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30
- hours, i
3/4 8-1
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b.
One Diesel Generator Inoperable:
With one diesel generator of the above required A.C.
electrical power sources inoperable, demonstrate the OPERABILITY of the offsite A.C. sources by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Specification 4.8.1.1.2a.4) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
- and restore the inoperable diesel generator to OPERABLE status with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
In addition perform ACTION d.
c.
One Offsite Circuit and One Diesel Generator Inoperable:
With one offsite circuit and one diesel generator of j
the above required A.C. electrical power sources inopecable, demonstrate the OPERABILITY of the remaining offsite A.C.
source by performing Specif.' cation 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8-hours thereafter,-and Specification 4.8.1.1.2a.4) within U hours for the remaining diesel generator.
Restore.it least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT l
STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Restore the remaining inoperable A.C.
electrical power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the Specification 3.8.1.1 ACTION a. or ACTION b.,
as applicable, with the time requirement for the ACTION based on the time of the initial loss of the remaining inoperable A.C. electrical power source.
A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4) under this ACTION for an OPERABLE diesel generator satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a. or ACTION b.
for an OPERABLE diesel generator.
In addition perform ACTION da d.
With one diesel generator inoperable in addition to ACTION b. or c. above, verify that:
1.
All required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and This test is required to be completed regardless of when the inoperable diesel generator is restored to OPERABLE status unless the diesel was declared inoperable due to preventive maintenance or maintenance to correct a deficiency that would not by itself have made the diesel generator inoperable.
3/4 8-2
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2.
When in MODE 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.
If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
i e.
Two Offsite Circuits Inoperable:
With two of the above required offsite A.C.
circuits inoperable, demonstrate the OPERABILITY of two diesel
)
generators by performing Specification 4.8.1.1.2a.4) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the diesel generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or i
be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Following restoration of one offsite A.C. electrical power source, follow ACTION a.
above with the time requirement of ACTION a. based on the time of the initial loss of the remaining inoperable offsite A.C.
electrical power source.
A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4) under this ACTION for the diesel generators satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION a.
f.
Two Diesel Generators Inoperable:
With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Following restoration of one diesel generator, follow ACTION b.
with the time requirement of the ACTION based on the time of initial loss of the remaining inoperable diesel generator.
A successful test of diesel generator OPERABILITY performed in accordance with Specification 4.8.1.1.2a.4 under this ACTION for the OPERABLE diesel 3
generators, satisfies the subsequent testing requirement of Specification 3.8.1.1 ACTION b.
SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the Onsite Class 1E Distribution System shall be determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicating power availability.
3/4 8-3
4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:
a.
In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:
1)
Verifying the fuel level in the day tank, 2)
Verifying the fuel level in the fuel storage tank, 3)
Verifying the fuel transfer pump starts and transfers fuel from the storage system to the day
- tank, 4)
Verifying the diesel starts _and accelerates to at least 514 rpm in less than or equal to 12 seconds.**
The generator voltage and frequency-shall be 4000 + 320 volts and 60 + 1.2 Hz within 12 seconds ** after the start signal.
The diesel generator shall be started for this test by using one of the following signals.
a)
Manual, or b)
Simulated loss-of-offsite power by itselr, or c)
Safety Injection test signal.
5)
Verifying the generator is synchronized, gradually loaded to greater than or equal to 3721 kW and, operates with a load greater than or equal to 3721 kW for at least 60 minutes, and 6)
Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.
b.
At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the day tanks; At least once per 31 days by checking for and removing c.
accumulated water from the fuel oil storage tanks; d.
By sampling new fuel oil in accord'ance with ASTM-D4057 prior to addition to storage tanks and:
1)
By verifying in accordance with the tests specified in ASTM-D975-81 prior to addition to the storage tanks that the sample has:
- This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
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3/4 8-4
a)
An API Gravity of within 0.3 degrees at 60*F, or a specific gravity of within 0.0016 at 60/60*F, when compared to.the supplier's certificate, or an absolute specific gravity at 60/60*F of greater than or equal to 0.83 but less than or equal to 0.89, or an' API gravity of greater than or equal to 27 degrees but less than or equal to.39 degrees; b)
A kinematic viscosity at 40*C of greater, than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes, if gravity was not determined by comparison with the supplier's certification; c)
A flash point equal to or greater than 125*F; and d)
A clear and bright appearance with proper color when tested in accordance with ASTM-D4176-82.
r 2)
By verifying within 30 days of obtaining the sample that the other properties specified in Table 1 of ASTM-D975-81 are met when tested in accordance with ASTM-D975-81 except that the analysis for sulfur may be performed in accordance with ASTM-D1552-79 or ASTM-D2622-82.
e.
At least once every 31 days by obtaining a sample of fuel oil in accordance with ASTM-D2276-78, and verifying that total particulate contamination is less than 10 mg/ liter when checked in accordance with ASTM-D2276-78, Method A; f.#
At least once per 18 months __ by:
1)
Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service; 2)
Verifying the diesel generator capability to reject a load of greater than or equal to 1352 kW (ESW pump) while maintaining voltage at 4000 1 320 volts and frequency at 60 1 5.4 Hz;
- The specified 18 month frequency may be waived for Cycle I provided the surveillance is performed prior to restart following the first refueling outage or June 1, 1986, whichever occurs.first.
The provisions of Specification 4.0.2. are reset from performance of this surveillance.
3/4 8-5
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3)
Verifying the diesel generator capability to reject a load of 6201 kW without tripping.
The generator voltage shall not exceed 4784 volts during and following the load rejection; 4)
Simulating a loss-off-site power by itself, and:
a)
Verifying deenergization of the emergency busses and load shedding from the emergency busses, and b)
Verifying the diesel starts ** on the auto-start signal, energizes the emergency tusses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the shutdown sequeacer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads.
After energizabion, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 + 320 volts and 60 +
1.2 Hz during this test.
5)
Verifying that on a Safety Injection test signal without loss-of-offsite power, the diesel generator starts ** on the auto-start signal and operates on standby for greater than or equal to 5 minutes; and the offsite power source energizes the auto-connected emergency (accident) load through the LOCA sequencer.
The generator voltage and frequency shall be 4000 1 320 volts and 60 1 1.2 Hz within 12 seconds after the auto-start signal; the generator steady-state generator voltage and frequency shall be maintained within these limits during this test; 6)
Simulating a loss-of-offsite power in conjunction with a Safety Injection test signal, and a)
Verifying deenergization of the emergency busses and load shedding from the emergency busses;
- This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
3/4 8-6
l b) verifying the diesel starts ** on the auto-start signal, energizes the emergency bussas with permanently connected loads withi.n 12 seconds, energizes the auto-connected emergency (accident) loads through the LOCA sequencer and operates for t
greater than or equal to 5 minutes while its generator is loaded with' emergency loads.
After energization, the steady-state voltage and frequency of the emergency busses shall l
be maintained at 4000 1 320 volts and i
60 1 1.2 Hz during this test; and c)
Verifying that all automatic diesel generator trips, except high jacket coolant temperature, engine overspeed, low lube oil pressure, high crankcase pressure, start failure relay, and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection' Actuation signal.
7)
Verifying the diesel generator operates for at
'least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to greater than or equal to 6821 kW and during the remaining 22. hours of this test, the diesel generator shall be loaded to greater than or equal to 6201 kW.
The generator voltage and. frequency shall be 4000 + 320 volts and 60 + 1.2,-3 Hz within 12 seconds after the start signal; the steady-state generator voltage and. frequency shall be maintained within 4000 + 320 volts and 60 1 1.2 Hz during this test.
WIthin 5 minutes after completing.this 24-hour test, perform Specification 4.8.1.1.2f.6) b) *;
8)
Verifying that the auto-connected loads to each diesel generator do not exceed 6201 kW:
If Specification 4.8.1.1.2f.6) b) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test.
Instead diesel-generator may be operated-at 6201 kW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until operating temperature has stabilized.
- This test shall be preceded by an engine-prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
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9)
Verifying the diesel generator's capability to:
(
a)
Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b)
Transfer its loads to the offsite power source, and c)
Be restored to its standby status.
10)
Verifying that with the diesel generator operating in a test mode, connected to its bus, a simulated Safety Injection signal overrides the test mode by:
(1) returning the diesel generator to standby operation, and (2) automatically energizing the emergency loads with offsite power; 11)
Verifying that the fuel transfer pump transfer fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines; and 12)
Verifying that the automatic LOCA and shutdown sequence timer is OPERABLE with the interval between each load block within + 10% of its design interval.
g.
At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting ** both diesel generators simultaneously, during shutdown, and verifying that both diesel generators accelerate to at least 514frpm in less than or equal to 12 seconds; and h.
At least once per 10 years by:
1)
Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or equivalent, and 2)
Performing a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code at a test pressure equal to 110%-of the system design pressure.
This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
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At least once per 184 days the diesel generators shall t
be started ** and accelerated to at least 514 rpm in
(
less than or equal to 12 seconds.
The generator voltage and frequency shall be 4000 + 320 volts and 60
+ 1.2 Hz within 12 seconds after the start signal.
Subsequently verify the generator is loaded to greater than or equal to 6201 kW in less than or equal to 60 seconds and operates with a load greater than or equal' to 6201 kW for at least 60 minutes.
t l
4.8.1.1.3 Reports - All diesel generator failures, valid or l
nonvalid, shall be reported in a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days.
Reports of diesel generator failures shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108, Revision 1, August 1977.
If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater 1
than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position j
C.3.b of Regulatory Guide 1.108, Revision 1, August 1977.
[
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This test shall be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is 4
minimized.
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TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE #
NUMBER OF FAILURES IN NUMBER OF FAILURES IN LAST 20 VALID TESTS
- or LAST 100 VALID TESTS
- TEST FREQUENCY 1 1 1 4 At least once per 31 days i
1 2**
1 5 At least once per 7 days i
I i
- Tne most limiting test frequency should be applied from the two columns of this table.
- Criteria for determining number.of failures and number of 4
I valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, but determined on a per diesel generator basis.
For the purposes of determining the required test frequency, the previous test failure count may be reduced to zero if a complete diesel overhaul to like-new conditions is completed, provided that the overhaul, including appropriate post-maintenance operation and testing, is performed per the manufacturer's technical manuals, and if acceptable reliability has been demonstrated.
The reliability criterion shall be the successful completion of 14 consecutive tests-in a single series.
Ten of these tests shall be in accordance with Specification 4. 8.1.1. 2a. 4) ; four tests in accordance with Specification 4.8.1.1.2a.5).
- The associated test frequeypy shall be maintained until seven consecutive failure free-demands have been performed and the number of failures in the last 20 valid demands has been reduced to one.
3/4 8-7c
i 3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1, 3/4.8.2, and 3/4.8.3. A.C.
SOURCES, D.C.
SOURCES, and ONSITE POWER DISTRIBUTION The OPERABILITY of the A.C. and D.C.
power sources and i
associated distribution systems during operation ensures that sufficient power will be available to supply the safety-related equipment required for:
(1) the safe shutdown of the facility, and (2) the mitigation and control of accident conditons within the facility.
The minimum specified independent and redundant A.C. and D.C.
power sources and distribution system satisfy the requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50.
The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation.
The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite 3.C.
and D.C.
power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss-of-offsite power and single failure of the other onsite A.C.
source.
The A.C.
and D.C.
source allowable out-of-service times are based on Regulatory Guide 1.93, " Availability of Electrical Power Sources," December 1974.
When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE.
This requirement is intended to provide assurance that a loss-of-offsite power event will not result in a complete loss of safety function of critical systems during the period one of the diesel generators is inoperable.
The term verify as used in this context means to administrative 1y check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons.
It does not mean to perform the Surveillance Requirements needed to demonstrate the OPERABILITY of the component.
The OPERABILITY of the minimum specified A.C.
and D.C.
power sources and associated distribution systems during shutdown and refueling ensures that:
(1) the facility can be maintained in the shutdown or refueling condition for extended time periods, and (2) sufficient instrumentation and control capability are available for monitoring and maintaining the unit status.
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The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9,
" Selection of Diesel l
Generator Set Capacity for Standby Power Supplies",
t March 10, 1971; 1.108,-" Periodic Testing of Diesel Generator i
l Units Used as Onsite Electric Power Systems at Nuclear Power j
Plants," Revision 1, August 1977 as modified by Amendment No.
l issued
- and 1.137, " Fuel-Oil Systems for Standby Diesel l
Generators," Revision 1, October 1979.
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. to ULNRC-1376 SAFETY EVALUATION This amendment request revises Technical Specification 3/4.8.1.1 in accordance with the annotated pages provided in.
These revisions and their respective safety evaluations are discussed hereinafter.
The request consists of seven categories of changes as identified in the transmittal letter.
The categories are identified below in the " Description of Change" for cross reference purposes.
I.
PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action a A.
Description of Change (Category 1,2)
This action statement provides the actions to be taken with one offsite circuit of the required a.c. electrical power sources inoperable.
The actions required when one diesel generator (D/G) is inoperable are being separated from this action statement and incorporated into an individual action statement (proposed Technical Specification 3.8.1.1. Action b.).
Specification 4.8.1.1.2a.4), demonstration of D/G operability, will be performed once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for each D/G unless a D/G has been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The existing Specification requires demonstration of D/G operability pursuant to 4.C.1.1.2a.')
Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter regardless of when the last D/G test was performed.
B.
Evaluation Performing D/G operability tests following the loss of one offsite circuit is to verify the availability of a backup power source.
The D/G's are designed and are intended to be standby power sources.
The present Technical Specifications require that both D/G's be tested initially within the first hour and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, regardless of how recently a test has been successfully completed.
In a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period, an initial test within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and a followup test every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter results in a total of nine D/G tests.
This contradicts manufacturer recommendations that the D/G's be tested with a maximum frequency of 7 days and introduces accelerated D/G wear.
However, it is understood that when an offsite power source
2 is lost D/G availability becomes more essential and the D/G's should be tested if they have not been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
If a D/G has been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an additional test provides little further assurance of D/G operability than what was provided in the previous successful test.
D/G testing within the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will, in addition to providing assurance of starting capability, also provides additional time for inspection and prelube and other warmup procedures recommended by the manufacturer to minimize the mechanical stress and wear on the D/G's.
Furthermore, l
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permits sequential testing of the D/G's rather than the simultaneous testing of both.
1 Repetitive testing increases the likelihood of a D/G failure rather than providing continued assurance of starting capability especially since loss of an offsite source does not directly imply a failure of the D/G's.
Based on the above, the tests required for one inoperable D/G are being separated from this action statement.
The present D/G testing requirements have been identified as a contributing factor to inducing premature diesel engine wear.
Consistent with Generic Letter 84-15, one test per D/G provides assurance of D/G operability in the event of a loss of an offsite power source.
These changes have been previously approved as described in the staff response to Amendment No. 48 for North Anna Power Station, Unit No. 2, pages 24 and 25.
II.
PROPOSED TECHMICAL SPECIFICATION 3.8.1.1.
Action b.
A.
Description of Change (Category 1,2)
This action statement provides the actions required when declaring one D/G inoperable.
Making this a separate action statement is an administrative change.
Specification 4.8.1.1.2a.4), demonstration of D/G operability, will be performed once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of declaring a D/G inoperable.
This test will be required to be l
l l
~--.
~
3 l
completed regardless.of when the inoperable D/G is restored to an operable status unless the D/G was declared inoperable due to preplanned' preventive maintenance.
The j
present requirement'is to perform a D/G l
operability test within.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least i
once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
If the inoperable D/G is not returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the action will require the unit to be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
i l
B.
Evaluation 1
The purpose of performing a D/G test per Specification 4.8.1.1.2.a.4) following the i
loss of a D/G is to verify the operability of the. remaining a D/G.
Specifically, an operability test provides assurance that the remaining D/G is not subject to a common mode failure.
Testing the operable D/G by verifying D/G starting capability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is in accordance with manufacturer i
recommendations.~ The discussions in the justification for Specification 3.8.1.1 Action a. are applicable to this action also.
III.
PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action c A.
Description of Change (Category 1,2)
This action statement provides the required actions to be taken when declaring one offsite a.c.~ source and one D/G inoperable.
This is Action b. of the existing Technical Specifications.
Specification 4.8.1.1.2a.4 will be performed once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of declaring both a.c. electrical power sources inoperable.
The present requirement is to demonstrate D/G operability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Clari-fication is also provided regarding required actions to subsequently entered action statements.
When a D/G or an offsite a.c.
circuit is returned to service, either the proposed Action a. or Action b. is entered.
B.
Evaluation
_ Performing a D/G test _per Specification 4.8.1.1.2.a.4) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of declaring'an offsite source and a D/G inoperable provides adequate assurance of the operability of the
4 remaining D/G while eliminating unnecessary D/G starts.
Since the allowable outage period for this action is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, followup D/G starts are not applicable.
A successful D/G operability test performed pursuant to this action also satisfies the subsequent requirement to verify D/G operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under action a. or action b.
This transfer statement prevents having to retest a D/G just because a new action is entered when the D/G has previously been tested as part of this action.
This will aid in eliminating unnecessary D/G starts.
These changes are consistent with Generic Letter 84-15.
IV.
PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action d.
This action provides the required response when a D/G is inoperable in addition to the requirements of Action b. or Action c..
In the existing Specifications this is Action c. and refers to Actions a. or b.,
There are no substantive changes to this action, only a relabeling of action statements.
V.
PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action e.
A.
Description of Change (Category 1,2)
This action provides the required response in the event of a loss of both offsite a.c.
circuits.
Specification 4. 8.1.1. 2a. 4) will be performed once within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the D/G's are already operating.
The existing Specification requires the D/G's to be tested within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the loss of both offsite a.c. electrical power sources and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
B.
Evaluation The proposed change is consistent with those made for Actions a, b and c above.
As previously noted, loss of an-offsite a.c.
electrical power source does not suggest that the D/G's have become less reliable than noted by a previous surveillance test.
Given the significance of losing both offsite a.c.
electrical power sources, one test per D/G within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides adequate assurance of D/G operability.
This proposed change is consistent with Generic Letter 84-15.
m 5
2 VI.
PROPOSED TECHNICAL SPECIFICATION 3.8.1.1 Action f 4,
~
A.
Description of Change This action provides the required response when both D/G's are inoperable.
This is Action e. of the existing Specifications.
Following the restoration of a D/G, Action b.
would be entered and will require restoring the remaining D/G within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of the initial loss _or be in hot standby within the next'6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown q
r within the following_30 hours.- There are no substantive changes proposed, only clari -
fication of the required action as D/G's are returned to operable status.
B.
Evaluation See description above.
VII.
PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2a.4)
A.
Description of Change (Category.5)
This surveillance requirement has been revised to relocate D/G tests followed by
)
fast loading (to 6201 kW) performed once per 184 days, as a separate surveillance requirement (proposed Specification 4.8.1.1.2i, Item IX of this evaluation).
j B.
Evaluation See description above.
No substantive changes are proposed.
VIII.
PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2a.5)
A.
Description of Change (Category 3,4)
The present surveillance requirement demonstrates D/G operability by verifying the D/G-is-synchronized and loaded to greater than or equal to 6201 kW (continuous rating) in less than or equal to 60 seconds and operates with a load greater than or equal to 6201 kW for at least 60 minutes.
The proposed changes modify the test requirement to permit gradual loading of the D/G's during routine surveillance and action statement operability testing.
The proposed change a
also reduces the loading requirement of 6201 A
6 kW to greater than or equal to 3721 kW (60%
of continuous rating) any time the D/G is routinely operated.
B.
Evaluation To reduce wear and minimize the severity of thermal transients on the D/G's, the manufacturer has recommended gradual loading of the D/G's to greater than or equal to 60%
of continuous rated load (which corresponds to 3721 kW) any time a D/G is routinely tested.
This reduced loading better represents the actual load if all the associated safety-related loads were powered from their particular D/G.
Also, in accordance with manufacturer recommendations, the D/G's are normally run for at least 20 minutes on every D/G start.
The manufacturer has recommended gradual loading of the D/G's during routine surveil-lance / maintenance situations as a means of engine preconditioning and to avoid subjecting the D/G to the severe thermal transients which result from fast loading.
Reaching the continuous rated load within 60 seconds is based on FSAR analysis assumptions for a design base Loss of Coolant Accident (LOCA) concurrent with a Loss of Offsite Power (LOOP).
In the event the diesel is actually required during the surveillance test, the test will be automatically over-ridden and a fast load will commence.
Requiring the D/G to be routinely tested to design base conditions is excessive and unwarranted and against manufacturer recommendations.
A design base accident test performed every 184 days is sufficient to ensure the D/G's can withstand design base accident loads (proposed Specification 4.8.1.1.2f.
Routine surveillance tests should be used as a meanr of implementing manufacturer's testing Cec-mmendations and verifying load accertP>ce 'apability, not accident simulatior. t -x t ' s.
Accordingly, the proposed changes have eliminated the 60 second requirement from this surveillance and included it into the 184 day surveillance testing pursuant to the proposed Specification 4.8.1.1.2f.
These changes are in accordance with Generic Letter 84-15 and the staff response to Amendment No.
48 for North Anna Power Station, Unit No.
2, page 14.
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IX.
PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.21 l
A.
Description of Change (Category 3,5)
This Specification is proposed to encompass the 184 day test requirement as discussed earlier in the proposed changes to Specifications 4.8.1.1.2a.4) and 4.8.1.1.2a.5).
This surveillance demonstrates D/G operability by verifying the D/G's can be started and loaded under design base accident conditions.
The D/G's will be verified to start and accelerate to at least 514 rpm in less than or equal to 12 seconds.
The generator voltage and frequency will also be verified to attain 4000 i 320 volts and 60 1.2 Hz, respectively, within 12 seconds after the start signal.
In addition, the generator is verified to be loaded to greater than or equal to 6201 kW (continuous rating) within 60 seconds after the start signal and operates for at least 60 minutes.
This surviellance requirement includes engine prelube and warmup.
B.
Evaluation This surveillance encompasses the same requirements of the existing Specifications 4.8.1.1.2a.4) and 4.8.1.1.2a.5) with the exception of reducing the surveillance interval.
These tests will be performed every 184 days and will be independent of the l
testing frequency of Table 4.8-1.
This test is intended to provide assurance that the D/G's will operate in the event of a LOCA concurrent with a LOOP.
These changes are consistent with manufacturer recommendations and Generic Letter 84-15.
X.
PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2f A.
Description of Change This change is being submitted concurrent with the other proposed changes in order to
]
reduce Technical Specification change l
submittals.
This change is not related to Generic Letter 84-15 or manufacturer recommendations.
This change deletes the requirement to perform 18 month surveillances only during shutdown.
8 B.
Evaluation The "during shutdown" requirement of current Specification 4.8.1.1.2f pertains to all 1
items under that section (1 through 12).
While it is necessary to perform some of these tests with the plant shut down, there are tests that could be performed with the plant "on-line" thereby reducing the number
-of surveillances required during an outage and prevent requiring a plant shutdown for a l
surveillance that could be performed "on-line" (i.e. Sections 2, 3,
11, etc.).
i For those surveillances requiring shutdown, the surveillance procedures identify the appropriate mode of operation for performance as initial conditions.
l XI.
PROPOSED TECHNICAL SPECIFICATION 4.8.1.1.2f.4),. 5),.6) and 4.8.1.1.2g These surveillance requirements verifiy the D/G starting capabilities for various auto-start signals and 10 year simultaneous D/G test.
A footnote has been added stating that D/G starts pursuant to these Specifications shall be conducted in accordance with manufacturers j
recommendations regarding engine prelube and warmup procedures.
This is consistent with the guidance provided in Generic Letter 84-15 as updated in the changes. approved for North Anne Power Station, Unit No. 2 in April, 1985.
(Category 5)
XII.
PROPOSED TECHNICAL SPECIFICATION TABLE 4.8-1 A.
Description of Change (Category 6, 7)
This table provides the required D/G surveillance test frequency for Specification 4.8.1.1.2a.
The existing. test frequency is based on the number of valid failures experienced in the last 100 valid tests per-nuclear unit in accordance with Regulatory Guide 1.108, Revision 1, August 1977.
The proposed test frequency is based on a matrix of the number of valid failures in the last 20 and 100 valid tests on a per D/G basis.
In addition, the proposed changes provide for a restart in counting failures provided successful corrective actions have been implemented.
~
E o' --
9 O-B.
The existing Specifications require.
accelerated surveillance testing of the D/G's based on the number of failures in the last 100 valid tests in accordance.with Regulatory Guide 1.108.
The' test schedule is based on a i
l reactor unit basis rather than a D/G basis.
The current test. frequency. proceeds from i
testing the D/G's at least once per 31 days,
-14' days, 7~ days or 3 days when the number of l
D/G failures is less than or equal to 1 fail-ure, 2 failures, 3-failures, or greater than or equal to 4 failures, respectively.
The proposed changes provide a'different test schedule adapting the general. criteria of' Regulatory Guide 1.108 and Generic Letter' 84-15 with the exception that a reset in the number of failures to zero is. permitted l.
following a complete diesel generator overhaul and successful post-maintenance, operability verification and subsequent surveillance' testing.per manufacturer techni-cal manuals.
Post-maintenance testing.will be established on a case specific basis dependent on the extensiveness of the overhaul (i.e. it is anticipated that if replacement of major, parts is needed, a more extensive test program including a break-in run of the diesel generator and power run to i
~
re-baseline trending parameters would be required).
Operability testing will remain per common practice (Specification-
- 4. 8.1.1. 2a. 4 ) )'.
The concept of resetting the number of.
failures to zero is included to encourage corrective actions which enhance reliability rather than maintain a punitive testing schedule following corrective action that is counterproductive to diesel reliability.
1 The 100 valid test criteria has also been-revised to reflect the Generic Letter'84-15 concept of reliability goals.
In addition, the proposed change'provides accelerated testing based on the number of' failures in-the last 20 valid. tests.
Two D/G. failures in the last 20 valid starts may be. indicative of-affailure' rate of 0.1 (90% reliability).
Accelerated testing at this point in time would provide better. sensitivity to the possibility of abrupt D/G degradation and
10 initiate prompt corrective actions.
Increasing the test frequency would provide a faster accumulation of test data upon which to judge D/G reliability.
This additional data can be used to distinguish between failures which occur in a short period of time simply due to coincidence and such failures that are indicative of an abrupt decline in the actual reliability.
The 7 day test frequency would be continued until 7 consecutive tailure-free tests have been performed and the number of failures in the last 20 valid tests have been reduced to one.
Seven successful tests indicate a reliability of at least 0.90/ demand but only at the 50% confidence level.
Continued accelerated testing until the number of failures is 1 out of 20 provides further assurance that the D/G has not degraded below the 0.90/ demand level.
This is consistent with the recommendations of Generic Letter 84-15 and the staff response to Amendment No.
48 for North Anna Power Station, Unit No.
2, page 19.
XIII.
PROPOSED TECHNICAL SPECIFICATION 3/4.8 BASES This change is administrative in nature and indicates that D/G testing per Regulatory Guide 1.108, Revision 1, August 1977 is modified by the Technical Specification amendments proposed herein.
In summary, this amendement request revises the technical specification requirements for emergency diesel generator testing, to increase engine reliability and to prevent undue stress and wear.
The changes are consistent with the manufacturer's recommendations and are based on the guidance provided in Generic Letter 84-15 and the changes previously approved for North Anna Power Station, Unit.
No. 2.
No changes are being made to the diesel generators or their starting components or circuitry, therefore the original design bases are met.
Based on the preceeding discussions, 1) the probability and consequenses of an accident or malfunction of equipment important to safety is not increased, 2) a new accident from those previously described in the FSAR is not created, and 3) the margin of safety as described in the bases of the Technical Specifications is not decreased.
I 11' Pursuant to the above information,-this amendment-request.does not adveraly affect or endanger the health or safety of the general public and does not involve an unreviewed safety question.
l l
1 to j
ULNRC-1376 SIGNIFICANT HAZARD EVALUATION This amendment request consists of seven categories of changes to Specification 3/4.8.1.1 as identified in the transmittal. letter.
The following discussions address these changes and their corresponding significant hazard evaluations in the same order as'the transmittal letter.
1.
For action statement tests, the initial D/G test would be performed within either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depending on the actual degraded condition.
a)
This change does not involve a j
significant increase in the probability or consequences of an accident previously evaluated.
The proposed test requirements provide adequate assurance of diesel generator operability and also l
provides additional time for inspection i
and prelube and other warmup procedures recommended by the manufacturer.
b)
This change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged and the revised requirement is.tx) enhance diesel generator reliability.
c)
This change does not involve a significant reduction in a margin of safety.
This is based on the fact that no design change is involved, but surveillance testing is being revised to enhance reliability.
2.
For action statement tests, there would be no repeat starting of the D/G after the initial start test.
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed test requirements provide adequate assurance of diesel generator availability and decreases the likelihood of D/G failure attributed to accelerated wear from too frequent starting.
l
o 2
b)
The change does not create the possibility of a new or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged and the revised requirement is to enhance diesel i
generator reliability.
c)
This change does not involve a l
significant reduction in a margin of l
safety.
This is based on the fact that no design change is involved, but surveillance testing is being revised to enhance reliability.
3.
Fast loadings (60-seconds) would be deleted except for one per 6 months and during the 18-month (refueling) tests.
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The engine manufacturer has recommended gradual loading of the D/G's during routine surveillance testing as a means of engine preconditioning and to avoid subjecting the D/G to the severe thermal transients which result from fast loading.
A fast loading performed every 184 days is sufficient to ensure diesel generator load acceptance capability.
b)
This change does not create the possibility of a new or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged and the revised loading rate will provide for increased engine life.
i c)
The change does not involve a significant reduction in a margin of safety.
This is based on the fact that no design change is involved.
In the event of a diesel start signal being generated during a test, the test will be over-ridden and a fast load will commence.
o 3
a 4.
For routine surveillance testing,.the D/G's would be loaded to 60% of continuous rated load (3721 kw).
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Loading the engines to 60% of rated load is consistent with the manufacturer's recommendation and the reduced loading better represents the actual loading if all associated safety-related loads were powered from their associated D/G.
b)
This change does not create the possibility of a new or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged.-
The D/G will still accept all ESF loads if actually required during a test sequence.
1 c)
This change does not involve a significant reduction in a margin of safety.
This is based on the fact that no design change is involved and the D/G will still accept all ESF loads if actually required during a test sequence.
5.
Engine prelube and other manufacturer recommended warmup procedures would be added as a requirement for all D/G test starts.
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Prelube and warmup are considered to enhance D/G reliability and are recommended in NRC Generic Letter 84-15 and by the NUMARC Station Black-out Working Group.
Callaway test requirements currently incorporate reduced cold starts, so this would serve to eliminate all remaining cold starts.
b)
This change does not create the possibility of a new or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant
o 4
l operation is unchanged and the revised requirement is to enhance reliability.
c)
This change does not involve a significant reduction in a margin'of safety.
This is based on the fact that no design change is involved, but surveillance testing is being revised to enhance reliability.
6.
The accelerated frequency for routine tests l
(based upon accumulated test results) would be changed to reduce the amount of accelerated testing by basing.such testing on a reliability goal of 0.95 per D/G.
a)
This change does not involve a significant increase in the probability or consequences of an accident i
previously evaluated.
The proposed test l
schedule provides adequate assurance of diesel generator operability without maintaining a punitive testing schedule following corrective action that is counter-productive to diesel generator reliability.
b)
This change does not create the possibility of a new or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged and the revised test schedule is to enhance diesel generator reliability.
c)
This change does not involve a significant reduction in a margin of safety.
This is based on the fact that no design change is involved, but surveillance testing is being revised to enhance reliability.
7.
An incentive would be added that' reduces the failure count to zero if a major engine overhaul is performed.
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The resetting of the number of failures to zero following a major engine overhaul and associated post-maintenance tests encourages
- o j.
.g*
S i
l corrective actions which enhance reliability.
b)
This change.does not_ create the possibility ofLa new'or different kind of accident from any previously evaluated.
This is based on the fact that the method and manner of plant l'
operation is unchanged ~and the revised provision is to enhance reliability.
c)
This change does not involve a significant reduction in a margin of__
safety. ~ This is based on:the fact that no design change is involved.
I
SUMMARY
Based on the previous discussions, this amendment request.
does not involve a significant. increase in the probability or consequences of an accident previously evaluated; nor create the possibility ~of a new or different kind of accident from any accident previously evaluated; nor involve a reduction in the required margin of safety.
Based on the foregoing, the requested amendment does not present a significant hazard.
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m
- m