ML20207S971

Proposed Tech Specs Re Transfer of Containment Penetration Conductor Overcurrent Protective Devices from Tech Spec Table 3.8-1 to Separate Document & Fuse Testing Requirements

ML20207S971
Person / Time
Site:	Mcguire, McGuire
Issue date:	03/16/1987
From:	DUKE POWER CO.
To:
Shared Package
ML20207S970	List: ML20207S969 ML20207S971 ML20207S975 ML20207S977
References
NUDOCS 8703230006
Download: ML20207S971 (10)

Text

ELECTRICAL POWER SYSTEMS 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION 3.8.4.1 All containment penetration conductor overcurrent protective devices

. . . _ _ . ...,, .. . shall be OPERARLE.

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

ACTION:

With one or more 39:4We containment penetration conductor overcurrent '

protective device (s) s N inoperable:

a. Restore the protective device (s) to OPERABLE status or de-energize the circuit (s) by tripping the associated backup circuit breaker or racking out or removing the inoperable circuit breaker within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, declare the affected system or component inoperable, and verify the backup circuit breaktr to be tripped or the inoperable circuit breaker racked out or removed at least once per 7 days thereafter; the provisions of Specification 3.0.4 are not applicable to overcurrent devices in circuits which have their backup circuit ,

breakers tripped, their inoperable circuit breakers racked out, or ~

removed, or

b. Be in at least HOT 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 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.8.4.1'- All containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:

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a. At least once per 18 months:

1) By verifying that the medium voltage (4-15 kV) circuit breakers are OPERABLE by selecting, on a rotating basis, at least 10% of the circuit breakers of each voltage level, and performing the following:

a) A CHANNEL CALIBRATION of the associated protective relays, b) An integrated system functional test which includes simulated automatic actuation of the system and verifying that each relay and associated circuit breakers and control circuits function as designed 2nd er "=c"W hW3est98:*1El, and 0703230006 E70316 PDR ADOCK 05000369 P PDR McGUIRE - UNITS 1 and 2 3/4 8-18 .

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SURVEILLANCE REQUIREMENTS (Continued) c) For each circuit breaker found inoperable during these

functional tests, an additional representative sample of at least 105 of all the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.

2) By selecting and functionally testirg a representative sample of at least 10% of each type of lower voltage circuit breakers.

Circuit breakers selected for functional testing shall be j selected on a___rot,ating basis. ?;r "__; 1; 7 ;; ^:; ;i =f t m___u___ m_ __, ._>__ ,_.__2_. 2 _ . . _ _ _ . . . _______.

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-fi;d by ": _.._f..^ .. ..g Circuit breakers found inoperable during functional testing Thall be restored to OPERA 8LE status prior to resuming operation. For each circuit breaker found l

inoperable during these functional tests, an additional repre-sentative sample of at least 105 of all the circuit breakers of ' ,

the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested; and

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b. At least once per 60 months by subjecting each circuit. breaker to an inspection and preventive maintenance in accordance with procedures prepared in conjunction with its manufacturer's recommendations. ,

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3) A fuse inspection and maintenance program will be maintained to ensure that: ,

1. The proper size and type of fuse is installed,

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2. The fuse shows no signs of deterioration, and 5 fi

3. The fuse connections are tight and clean.

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ELECTRICAL POWER SYSTEMS I BASES 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES '

s Containment electrical penetrations and penetration conductors are protected by either deenergizing circuits not required during reactor operation or by ,

I demonstrating the OPERABILITY of primary and backup overcurrent protection circuit breakers during periodic surveillance.

The Surveillance Requirements applicable to lower voltage circuit breakers

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provide assurance of breaker encieve reliability by testing at l least one representative sample of each manufacturer's brand of circuit breaker  !

-f.':r fu;;.+ Each manufacturer's molded case and metal case circuit breakers

-f.':r 7 ;;; are grouped into representative samples which are then tested on a rotating basis to ensure that all breakers and/or fuses are tested. If a 1 wide variety exists within any manufacturer's brand of circuit breakers -assWer h , it is necessary to divide that manufacturer's breakers ..~/ . . . , .

into groups and treat each group as a separate type of breaker ;r f;;;; for surveillance purposes.

7he nomma.0 trap se.tpornfs anc/ cvercorrenf respotus

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th "E~/ecrricab Con tm /s System ~~D escrip rion. , E7ectntch .

~~}i?netintion Circurls ." f~or lln't l> this 0 // Con dit so n l clocumen t h num ber MCSb - 0010 .30 .0 0 ; U n ov 2 MCS D -

002.o -3c.00. Testing of Nese ciYcuit brea lfer,s cha l/

Consist of thjectiny a current- in excess of tko. brea A'ery nomina / sutpaurt ano' measuriny tbt. response f&ne , ~)la_

measurec/ nsponse. Hme wi// b e. comporecl fo tka rnanu facWer's c6+a. to ensure, rbat /t IS /e.TS on 6 r agua l -to a VQlWe Specified $y tie inanufacfyar.

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Fuse test 9g) it in a ccoec/oncc with Ier sronobec/

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or i:mpropec/y . s9ec/ fuses. Saley is facidi, assuceo/ ty rh.

" fail are irasure 0,t fases, rk e g, if +4 fuse 4;/s, &

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l McGUIRE - UNITS 1 and 2 B 3/4 8-3 $mendtnern do. her:

Amendmeor No. _ _( .une

AITACHMENT 2 JUSTIFICATION AND SAFETY ANALYSIS

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Justification and Safety Analysis The proposed changes of Technical Specification 3/4.8.4 seek to transfer the tables (3.8-la and 3.8-1b) listing the Containment Penetration Conductor Over-current Protective Devices out of the Technical Specifications'and into a system

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description; the change would also change fuse testing requirements to conform to IEEE Standard 242-1975.

! Transferring the tables out of the Technical Specifications is an administrative matter that would allow a more efficient and timely upkeep of the tables. Pres-cutly, it is necessary to seek a license amendment to update the tables as a

. result of modifications. As a QA Condition 1 document (Attachment 4) referenced i-by_the Technical Specifications, the table could be readily kept up to date while under appropriate controls for its QA condition. Similar relief was suggested by the NRC for snubbers in Generic Letter 84-13.

This ' area (removing tabular data from the Technical Specifications) is a part of~

the Technical Specifications Improvement Project sponsored by the AIF. Maintain-ing the tables as a separate, referenced document would reduce technical workload cad review for Duke and NRC as no license amendment would be required to maintain the table up to date.

l The proposed change to fuse testing would simplify fuse testing and conform the IEEE Standard 242-1975. The Standard, Recommended Practice for Protection and

! Coordination of Industrial and Commercial Power Systems, states: " Maintenance of i fuses is limited by nature of the device to an inspection to ensure that the '

proper size fuse is installed, that it shows no signs of deterioration, and that

! the enclosure is clean and the connections are tight. The size and type of fuses i chould comply with those specified by the engineering department." The failure rode for fuses is "open", so a fuse which degrades to the point of failure would -t L still protect the equipment. The " fail-safe" mode ensures that a degraded fuse

would not result in damage to the enclosure, conductor, penetration assembly, or l load during a fault or overload condition. Resistance testing as now required i under Specification 4.8.4.la.3 does not accomplish anything and can be counter-

! productive. Resistance of the fuses varies significantly with temperature and

! would have to be drastically higher than normal to indicate degradation. The

! variance of resistance with manufacturer's lot and with temperature has resulted i in'some fuses not meeting requirements and being needlessly removed from service.

The proposed change td the fuse testing would provide for identification of any problems such as arcing in the enclosure, conductor insulation breakdown, bad I connections, as well as providing verification that the correct fuse is installed.

l This change would provide proper fuse maintenance with reduced down time.

Technical reviews at Duke in accordance with 10CFR 50.59 (the criteria for which i is similar to the significant hazards considerations criteria of 10CFR 50.92) will cusure the safety of any modifications of containment penetration circuits or the

! cdditions/ deletions thereof. Management involvement in the process is assured as review by the stacion manager or a previously designated superintendent and their subsequent approval is required by Technical Specification 6.5.1.3 prior to the rodification of any nuclear safety related structures, systems, or components; this applies to the penetration circuits.

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l ATTACDfENT 3 ANEYSIs OF SIGNIFICANT HAZARDS CONSIDERATION

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- Analysis of Significant Hazards Considerations As required by 10CFR 50.91, this analysis provides a determination that the proposed changes to the Technical Specifications do not involve any significant hazards consideration as defined by_10CFR 50.92.

The transfer of the tables from the Technical Specifications to a controlled document is an administrative matter that does not affect any accident scenario.

The Limiting Condition for Operation (LCO) remains in force for the devices as do the surveillance requirements for the circuit breakers to ensure operability. The proposed change to the required fuse testing would still ensure fuse reliability as the proposed program would detect any significant deterioration of fuses.

Resistance testing of fuses as presently required is counterproductive as discussed in Attachment 2. Additionally, fuses are, by nature, " fail-safe", thus safety function is assured. As breaker operability is unaffected and fuse safety function is assured, the proposal does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposal does not involve or-allow any significant design changes. Any system modifications must proceed through the modification process and, in accordance with 10CFR 50.59, must not involve an unreviewed safety question. This process ensures that the change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed fuse testing requirements would not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed program is in conformance with IEEE Standard 242-1975 and would detect any significant fuse degradation while preventing the disposal of good fuses. No design or hardware changes are permitted by this change which would affect or create any accident scenarios.

The transfer of the tables out of the Technical Specifications is an administrative matter. While future updates to the tables as a result of modifications will not require NRC review, Duke is required, under 10CFR 50.59 to conduct and document a thorough review as previously discussed.

i The proposed change would not involve a significant reduction in a margin of j safety. The transfer of the tables is an administrative matter as fuse and l- breaker safety function is fully assured, thus no safety margins are affected.

, The proposed change in the fuse testing program will maintain safety margins by

[ assuring fuse operability. Any significant degradation of fuses will be detected I by this program while the of ten counterproductive resistance test (as discussed in

Attachment 2) is eliminated. The fail-safe nature of fuses provides additional

! assurance that safety function is fulfilled, thus assuring that margins of safety are maintained.

i Based upon the preceding analysis, Duke Power Company concludes that the proposed l

amendments do not involve any significant hazards considerations.

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ATTACHMENT 4 SYSTEM DESCRIPTIONS I

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