ML20216G701

Proposed Tech Specs,Revising Engineered Safety Feature Actuation Sys Instrumentation Table 3.3-3,action 34 & Associated Bases Section

ML20216G701
Person / Time
Site:	Beaver Valley
Issue date:	03/17/1998
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20216G667	List: L-98-046, Application for Amends to Licenses DPR-66 & NPF-73,revising Engineered Safety Feature Actuation Sys Instrumentation Table 3.3-3,action 34 & Associated Bases Section ML20216G701
References
NUDOCS 9803200067
Download: ML20216G701 (19)

Text

• ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1

, Proposed License Amendment Request No. 249 The following is a list of the affected pages:

Affected Pages: 3/4 3-21 B 3/4 3-lb l

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9803200067 980317 PDR ADOCK 05000334 P PDR

DPR-66

, TABLE 3.3-3 (Continued) _

ACTION STATEMENTS ACTION 33 - With the number of OPERABLE Channels one less than the Total Number of Channels, the Emergency Diesel Generator associated with the 4kV Bus shall be declared inoperable and the ACTION Statements for Specification 3.8.1.1 or Specification 3.8.1.2, as appropriate, shall apply.

ACTION 34 - bith the numb;r Of OPEP'.EI.E ch nn:10 On: 100: thir the Tetal NuFber of Channele, STMTUF and/or FCUCR OPEP3_TIOF y pretted pr:vided the f:llering senditi:n: Or: ::ti:fi:d; gyt. Ac E'  :. T3: in per:31, 23 __ 1 1_ p1 : e 1 . es trip _ e g fA -- < conditien within 5 heur=, and it it ggg((~[ [\ L. The Miniana Channele CFERABLE requirement ie I

I et; he':?ever , the inep:::ble ch:rn:1 ::y b hypsered for up t0 2 heur:. f:r curv;illen :

terting ef Other ;hannele per 0pecification 4.3.2.1.1.

ACTION 36 - The block of the automatic actuation logic introduced by a reset of safety injection shall be removed by resetting (closure) of the reactor trip breakers within one hour of an inadvertent initiation of safety injection providing that all trip input signals have reset due to stable plant conditions. Otherwise, the requirements of ACTION statement 13 shall have been met.

ACTION 37 - Not applicable.

ACTION 38 - With less than the Minimum Number of Channels OPERABLE, within one hour determine by observation of the associated permissive annunciator window (s)

(bistable status lights or computer checks) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.

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(frepo3d W O BEAVER VALLEY - UNIT 1 3/4 3-21 Amendment No..HH. l n

Attachment to Table 3.3 ACTION STATEMENTS

.INSE'RT "A"

a. With the number of OPERABLE channels one less than the Minimum Number of Channels, place the inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; otherwise, immediately enter the applicable ACTION statement (s) for the associated Emergency Diesel Generator made inoperable by the degraded voltage start instrumentation.

b. With the number of OPERABLE channels two less than the Minimum Number of Channels, restore at least one of the two channels to OPERABLE status and place the other in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; otherwise, immediately enter the applicable ACTION statement (s) for the associated Emergency Diesel Generator made inoperable by the degraded voltage start instrumentation.

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BEAVER VALLEY - UNIT 1 (Proposed Wording)

ol 1DPR-66 INSTRUMENTATION.

BASES 3/4.3.1 and 3/4.3.2 PROTECTIVE AND ENGINEERFn SAFETY FEATURES (ESF)

INSTRUMENTATION (Continued)

Below'the setpoint P-11 allows the manual block of safety injection actuation on low pressurizer pressure, allows manual block of safety injection'and steamline isolation on low : steamline pressure '(with Loop Stop Valves Open) and enabling steamline isolation on high steam pressure rate, automatically ' disables auto actuation of the pressurizer PORVs unless the Reactor Vessel Over Pressure Protection System is in service. j P-12 Above the setpoint P-12 automatically reinstates an arming signal to the steam dump system. .Below the setpoint P-12 1 blocks steam' dump and allows manual bypass of the steam dump  ;

block to cooldown condenser. dump valves.

Table 3.3-1 Action 2 has been modified by two notes. Note (4)  !

allows placing the inoperable channel in the bypass condition for up i t o '4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while performing: a) routine surveillance testing of i other channels, and b) setpoint adjustments of other channels when I required to reduce the setpoint in accordance with other technical specifications. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit'is justified in accordance.

with WCAP-10271-P-A, Supplement 2, Revision 1, June l1990. Note (5) only requires SR 4.2.4 to be, performed-if a Power Range High Neutron Flux channel input to QPTR becomes inoperable. Failure of a component in the Power Range High Neutron Flux channel which renders

' the- High Neutron Flux trip function inoperable may not affect the capability to monitor QPTR. -

As such, determining QPTR using the movable inccre detectors once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may not be necessary.

4 @00 .INSEAT "C"

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J BEAVER VALLEY UNIT 1 B 3 / +' 3-lb Amendment No. 499 (99 4WorbQ)) ,

Attachment to Bases Section for 3/4.3.1 and 3/4.3.2 Reactor Trio System and Encineered Safety Features (ESP) Instrumentation IfiSERT HC" The following discussion pertains to Table 3.3-3, Functional Units 6.b and 6.c and the associated ACTION 34. The degraded voltage protection instrumentation system will automatically initiate the separation of the offsite power sources from the emergency buses.

This action results in an automatic diesel generator start signal being generated as a direct result of the supply breakers opening between the normal and emergency buses. The failure of the degraded voltage protection system results in a loss of one of the automatic start signals for the diesel generator. Therefore, the ACTION statement requires the affected diesel generator to be declared inoperable if the required actions cannot be met within the specified time period.

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BEAVER VALLEY - UNIT 1 (Proposed Wording)

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ATTACHMENT A-2

. Beaver Valley Power Station, Unit No. 2 Proposed License Amendment Request No. 118 The following is a list of the affected pages:

Affected Pages: X 3/4 3-22 B 3/4 3-4 l

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UPF-73 INDEX BAS.ES SECTION PAgg 3/4.2 POWER DISTRIBUTION LIMITS 3/4.2.1 AXIAL FLUX DIFFERENCE (AFD) . . . . . . . . B 3/4 2-1 3/4.2.2AND3/4.2.3HEATFLUXANDNUCLEARENTgALPY HOT CHANNEL FACTORS Fg(Z) AND F H . . . . . B 3/4 2-2 3/4.2.4 QUADRANT POWER TILT RATIO . . . . . . . . . B 3/4 2-5 3/4.2.5 DNB PARAMETERS. . . . . .......... B 3/4'2-5 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION . . . . B 3/4 3-1 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION. .......... B 3/4 3-1 3/4.3.3 MONITORING INSTRUMENTATION

'3/4.3.3.1 Radiation Monitoring Instrumentation. . . . B 3/4 3-4 3/4.3.3.2 Movable Incore Detectors. . . . . . . . . . B 3/4 3-M'hh k

3/4.3.3.3 Seismic Instrumentation . . . . . . . . . . B 3/4 3-5 3/4.3.3.4 Meteorological Instrumentation. . . . . . . B 3/4 3-5 3/4.3.3.5 Remote Shutdown Instrumentation . . . . . . B 3/4 3-5 3/4.3.3.7 Chlorine Detection Systems. . . . . . . . .- B 3/4 3-ykkh 3/4.3.3.8 Accident Monitoring Instrumentation . . . . B 3/4 3-6 3/4.3.3.11 Explosive Gas Monitoring Instrumentation. . B 3/4 3-6 .

3/4.3.4 TURBINE OVERSPEED PROTECTION . . . . . . . B 3/4 3-6 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION . . . . .. .......... B 3/4 4-1

-3/4.4.2 AND 3/4.4.3 SAFETY VALVES . . .......... B 3/4 4-2 3/4.4.4 PRESSURIZER . . . . . . .......... B 3/4 4-2 BEAVER VALLEY - UNIT 2 X Amendment No, te (hts WOb"

NPF-73 i TABLE 3.3-3 (Continued)

ACTION STATEMENTS ACTION 33 -

With the number of OPERABLE Channels one less than the Total Number of Channels, the Emergency Diesel Generator asscciated with the 4kV Bus shall be declared inoperable and the ACTION Statements for Specifications 3.8.1.1 or 3.8 1.2, as appropriate, shall apply.

ACTION 34 - "ith the " ':r Of OPE??."LE charn:1: en: 1::: th:n t Tet:1 M" 'er Of Ch;nn:1, OT=TLT Fe e and/ m.

GNHWPION  ::y  ; ::: d prefided the felle. fin; I cenditirn tre enticfi:d:

y gTQ  ; '* 2 3 2 d__2552 ..N-2_42 2_ ..-3b.$

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• II Il 7Nsuf 6 s. The

==*; Mini h e="=r, th-

=== ch- rel: errez tr :: uir=== e i:

incper:51'e charn:1 :y b; by; :::d f:: up t: h:::: f:: : rc;ill;n :

t:: ting of Oth:r ch:nn:1: pt  !; :if12:ti:n 4 . 3 . 2 .1. b.

s ACTION 36 - - The block of the automatic actuation logic introduced by a reset of safety injection shall be removed by resetting (closure) of - the reactor trip breakers within one hour of an inadvertent initiation of safety injection previding that all trip input signals have reset due to stable plant conditions. Otherwise, the requirements of ACTION Statement 13 shall have been met.

ACTION 37 - (This ACTION is not used)

ACTION 38 - With less than the Minimum Number of Channels l OPERABLE, within one hour determine by observation of '

the associated. permissive annunciator window (s)

(bistable status lights or computer checks) that the interlock is in its required state for the existing ,

plant condition, or apply Specification 3.0.3. l ACTION 41 - With the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5.

(hbp $cd W O N m BEAVER VALLEY - UNIT 2 3/4 3-22 Amendment No.f+

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.A'ttachment to Table 3.3 ACTION STATEMENTS INSERT "B" With the number of OPERABLE channels one less a.

than the Minimum Number of Channels, place the inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; otherwise, immediately enter the l

applicable ACTION statement (s) for the associated Emergency Diesel Generator made inoperable by the degraded voltage start instrumentation.

i b. With the number of OPERABLE channels two less l

than the Minimum Number of Channels, restore at least one of the two channels to OPERABLE status and place the other in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; otherwise, immediately enter the l applicable ACTION statement (s) for the associated

Emergency Diesel Generator made inoperable by the degraded voltage start instrumentation.

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i BEAVER VALLEY - UNIT 2 (Proposed Wording)

. .w NPF-73 314.3 INSTRUMENTATION

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' BASES 3/4.3.1 and 3/4.3.2 REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTxUMENTATION (Continued)

. Table 3.3-1 Action 2 has been modified by two notes.

allows placing the inoperable channel in the bypass condition Note (4) for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while performing: a) routine surveillance testing of other channels, and b) setpoint adjustments of other channels when required to reduce the setpoint in accordance with other technical specifications.

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The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit is justified in  !

accordance with WCAP-10271-P-A, Supplement 2, Revision 1, June 1990. Note (5) only requires SR 4.2.4 to be performed if a Power Range High Neutron Flux channel input to QPTR becomes inoperable.

Failure of a component in the Power Range High Neutron Flux channel which renders the High Neutron Flux trip function inoperable may not affect the capability to monitor QPTR. As ,

such, determining QPTR using the movable incore detectors once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may not be necessary. ]

( gg 8p 3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that:

1) the radiation levels are continually measured in the areas served by the individual channels; 2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded; and 3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of NUREG-0737, " Clarification of TMI Action Plan Requirements," October, 1980. I 3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of I this system is demonstrated by irradiating each detector used and  !

determining the acceptability of its voltage curve. l 8

For the purpose of measuring Fg(Z) or FfH , a full incore flux map is used. Quarter-core flux maps, as defined in WCAP-8648, June I 1976, may be used in re-calibration of the excore neutron flux  !

detection system, and full incore flux maps or symmetric incore '

thimbles may be used for monitoring the Quadrant Power Tilt Ratio when one Power Range Channel is inoperable.

BEAVER VALLEY - UNIT 2 B 3/4 3-4 Amendment No.60-(ft p2tci W O

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Attachment to Bases Section for 3/4.30 1 and 3/40 3.2 Reactor Trio System and Enaineered Safety Features (ESP) Instrumentation INSERT "D"-  ;

The following discussion pertains to Table 3.3-3, Functional Units 6b and 6.c and the associated ACTION 34. The degraded voltage j protection instrumentation system will automatically initiate the l separation of the offsite power sources from the emergency buses.

This action results in an automatic diesel generator start signal being generated as a direct result of the supply breakers opening between the normal and emergency buses. The failure of the degraded {

voltage protection system results in a loss of one of the automatic j start signals for the diesel generator. Therefore, the ACTION l statement requires the affected diesel generator to be declared inoperable if the required actions cannot be met within the specified ,

time period. j l

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BEAVER VALLEY - UNIT 2 (Proposed Wording)

ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed License Amendment Request No. 249 and 118 REVISION OF ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TABLE 3.3-3, ACTION 34 AND ASSOCIATED BASES A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise Engineered Safety Feature ,

Actuation System (ESFAS) Instrumentation Table 3.3-3, Action 34. l This action applies to Functional Units 6.b and 6.c, Degraded Voltage on the 4160 volt and 480 volt emergency buses. The proposed revision to Action 34 consists of revising the wording to allow one or both channels to be inoperable for one hour. The proposed wording will require that the inoperable channel be placed in the tripped condition within one hour. When two channels are inoperable, at least one of the two channels will be required to be restored to operable status and the other channel placed in the tripped condition within one hour. If these requirements are not completed within one hour, the proposed Action 34 will require that the associated diesel generator to be declared inoperable and the required action statement (s) be entered. The Bases section for 3/4.3.2 would be revised to provide additional clarification on the interaction between the failure of the degraded voltage protection system and the resultant inoperability of the affected diesel generator. The BVPS Unit No. 2 Index page X would be revised to reflect the shifting of text due to the addition of wording to the Bases section.

B. DESIGN BASES The 4160 volt emergency bus degraded voltage protection consists of two undervoltage relays in series per electrical bus. These relays are set to ensure at least 90 percent voltage is available at the emergency bus load terminals. The relays operate a time delay relay which is set long enough to ride through any expected voltage transients while preventing damage to the emergency loads. The relays are configured in two out of two logic to preclude spurious separation of the plant from the offsite power sources. The time delayed actuation is designed to preclude thermal damage to the safety related equipment power by the respective emergency bus. The degraded voltage protection automatically initiates the disconnection from the offsite power sources whenever the voltage setpoint and time delay limits have been exceeded. This action initiates load shedding of the emergency buses and starting of the emergency diesel generator.

Upon establishing diesel generator rated voltage and frequency, the diesel generator breaker closes and permits sequential application of the loads to the diesel generator.

The 480 volt emergency bus degraded voltage protection is configured and functions in a similar manner as the 4160 volt emergency bus degraded voltage protection.

ATTACHMENT B, continusd Proposed Licenna Amsndmant Raquest Nos.-249 and 118

+ Page-2' C. ' JUSTIFICATION Action 34 was revised by Amendment Nos. 181 and 61, (TAC Nos.

M88613 and M88614), for Beaver Valley Power Station (BVPS) Unit Nos. 1.and 2, respectively. These amendments revised the technical specifications relating to surveillance test intervals and allowed outage time for analog instrumentation channels 'of the reactor' trip system and ESFAS.

The worCing of Action 34 prior to these . amendments was as follows: "With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may.

proceed until the ' performance of the . next required Channel Functional Test provided the inoperable channel is placed in the trip condition within' 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." The current . wording allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place Additionally, the~an inoperable wording channel requires that in a tripped the minimumcondition.

channels operable requirement be met. Action 34 applies to Functional Units 6.b and.6.c. For both of these functions, the total number of channels is two and the minimum number of channels operable is-two. With one channel inoperable, the requirement to maintain the minimum number of channels operable cannot be ' met. When a channel is inoperable due to equipment failure or due to surveillance testing, for example, -Action 34 cannot be met.

Limiting Condition for Operation (LCO) 3.0.3 must be applied for this. condition. Based on guidance provided in NRC Inspection and Enforcement Manual Part 9900 : Technical Guidance, voluntary entries ~ into LCO 3. 0.3 are considered as violations of technical specification requirements. As such, surveillance requirements shall not place the unit in LCO 3.0.3.

The proposed revision to Action 34 will require, for the condition where one channel is inoperable, that the inoperable channel be placed in the tripped condition within one hour. This i action will place the trip actuation in a one out of one logic.

This logic will permit accomplishment of the trip function. The proposed wording of Action 34 will also require, for a condition where both channels are inoperable, that'at least one of the two inoperable channels be restored to operable status and the other channel placed in .the tripped condition within one hour. The time frames contained in proposed Action 34, for the condition where both channels are inoperable, are the same as the condition where only' one channel is inoperable. In both of these conditions, the degraded voltage protection on the affected emergency' bus will not function unless the inoperable channel (s) are in the tripped condition or returned to operable status.

With a one out of one or two out of two logic, a single active failure could result in that train failing to actuate. The degraded voltage protection on the opposite bus provides the redundancy necessary to meet single failure criteria. Once the inoperable channel is placed in the trip condition within one B-2

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ATTACHMENT B, continusd Proposed Licance Amsndmsnt Raquant Nos. 249 and 118

. Page 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and the other channel on the same emergency bus is restored to operable status within one hour, the ability to provide protection from a degraded voltage condition on the emergency j bus, assuming a single active failure, is restored. Therefore, j it is appropriate to allow continued plant operation with only '

one channel operable provided that 'the other inoperable channel on the same emergency bus has been placed in the tripped condition. If these conditions cannot be met, guidance has been provided to declare the emergency diesel generator inoperable that is associated with the affected emergency bus. The Action statement (s) for an inoperable diesel generator would then be entered. For the condition where both trains of emergency bus degraded voltage protection are inoperable and cannot be restored to at least a one out of one logic within one hour, the proposed action will require that both diesel generators be declared inoperable. The action statement for both diesel generators being inoperable requires that at least one diesel be restored to operable status within two hours or the plant be placed in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action requirement provides adequate compensatory measures if a loss of the degraded voltage function would exist on both trains of emergency buses.

The time frames and required actions contained in the proposed Action 34 are consistent with NUREG 1431 Revision 1 titled

" Standard Technical Specifications For Westinghouse Plants" (ISTS), LCO 3.3.5 Action B.1, for two or more channels inoperable for the diesel generator start instrumentation. Both of the conditions contained in the proposed Action 34 are equivalent to the ISTS Action B.1. Both conditions represent a loss of ' the ability of the degraded voltage protection to actuate. The 1 proposed one hour time period to complete the required actions is j consistent with the previous wording of Action 34. The provision to allow an inoperable channel to be bypassed for up to two hours for surveillance testing would be deleted. By deleting this bypass testing provision, the degraded voltage protection on the affected emergency bus will not be permitted to be defeated for ,

more than one hour without the associated diesel generator being declared inoperable. i 1

The Bases section for 3/4.3.2 would be revised to provide additional clarification on the connection between the failure of the degraded voltage protection system and the resultant inoperability of the affected diesel generator. This -Bases change will provide an explanation as to why it is appropriate to declare the diesel generator inoperable when the degraded voltage protection is not operable. This additional clarification is necessary.since the degraded voltage protection system does not provide a direct start signal to the diesel generators.

The proposed revision to Index page X is editorial in nature and is necessary due to changes in the Bases wording.

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l A'TTACHMENT B, continus'd Propossd Licansa Amandmsnt Rsquant Non. 249 and 118 Page 4 D. SAFETY ANALYSIS The proposed amendment will ensure that protection from a degraded voltage' condition on the 4160 volt emergency buses'and 480 volt emergency buses is consistent with the design bases of system. The method of providing this protection for a degraded voltage condition, consists of providing two under voltage sensing relays in series per emergency bus. Both of these relays l are required to actuate in order to provide the required' actions j to separate the' emergency bus from the normal bus. The proposed

revisions to Action 34 will require that the affected emergency l bus has adequate protection for" a degraded voltage condition, assuming no single active failure, within one hour of discovery of the inoperable degraded' voltage channel (s). The one hour completion time allows for repairs of most failures and takes into account the- low probability of an event requiring the l ' emergency bus to be separated from the normal bus and the l subsequent starting of the diesel generator. Adequate bus l protection will be required to be restored within one hour of the discovery of one inoperable channel by placing the inoperable channel in the trip condition. For the condition where both channels are inoperable, at least one of the two inoperable channels will be required to be restored to operable status and the other channel placed in the tripped condition within one hour. Once these actions are accomplished, adequate protection, l e.ssuming a single active failure, will be provided to ensure that at least one of the two redundant 4160 volt or 480 volt emergency buses will separate from the normal bus if a degraded voltage condition would exist. The proposed addition of the requirement i to enter the action statement for the diesel generator made '

inoperable, if the one hour requirements of Action 34 cannot be  ;

met, will require adequate compensatory actions to ensure plant safety. These actions include the demonstration of the i operability of the A.C. offsite sources by performing a specific surveillance within one hour and at least once per eight hours thereafter. For the condition where both trains of degraded voltage protection are inoperable for longer than one hour and are not capable of providing emergency bus protection, both diesel generators will be declared inoperable. This condition requires that at least one diesel generator must be restored to operable status within two hours or the plant must be placed in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The loss of emergency bus degraded voltage protection is similar to the loss of the ability of an emergency diesel generator to provide electrical power to the safety related loads on the emergency buses. In both situations, a loss of offsite power, due to a total loss or a degraded condition, will result in the safety related loads not being capable of mitigating a design basis accident.

The proposed bases change ~ provides. additional clarification of the requirements of Action 34. The proposed change does not affect the ability of the degraded voltage" protection to perform B-4

' ADACHMENT B, continund Proposed Lic2nne Amendment Request Nos. 249 and 118 4 -

Page 5 its intended function. Therefore, the bases change does . not affect plant safety.

The proposed changes to the Index page are editorial in nature and do not affect plant safety.

.Therefore, this change is considered safe based on the ability of the A.C. electrical _ power sources to provide sufficient capability, redundancy, and reliability to ensure 'the availability of power to Engineered Safety Feature (ESF) systems.

The proposed changes will continue to require that the 4160 volt and 480 volt emergency buses be protected from a degraded voltage-condition. The ability of the degraded voltage protection system to ensure that the electrical loads powered from the emergency buses are not damaged, due to a sustained bus undervoltage condition, remains unchanged. If this protection cannot be provided, appropriate compensatory measures will be required to  ;

assure plant safety.  !

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

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

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or -

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

The following evaluation is provided for the no significant i hazard consideration standards.

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

evaluated?

Engineered Safety Feature Actuation System (ESFAS) will continue to function in a manner consistent with the plant tdesign basis. The' proposed changes will not affect any of the analysis assumptions for any of the accidents previously evaluated. The proposed changes will not affect the B-5

ATTACHMENT B, continund Proposed Licance Amsndment Requent Nos. 249 and 118 Page 6 probability of any event initiators. There will be no change to normal plant operating parameters. The emergency bus degraded voltage protection system is utilized for accident mitigation and is not considered to be the source of accidents previously evaluated.

Implementation of the proposed changes will now provide viable corrective actions which do not significantly increase the probabili e of failure of safety related equipment to perform -its utended function. The proposed Action 34 permits a one hour time frame before the affected diesel generator (s) is required to be declared inoperable. This cne hour period allows for repairs of most failures and takes into account the low probability of an . event which would require the degraded voltage protection system to function.  :

If adequate protection is'not restored within this one hour period, the diesel generator (s) allowable outage time is invoked. The diesel generator (s) allowable outage time has been previously evaluated and determined to be an acceptable period of time during which plant operation may continue without an emergency backup power source. The loss of emergency bus degraded voltage protection is similar to the loss of the ability of an emergency diesel generator to provide electrical power to the safety related loads on the emergency buses. In both situations, a loss of offsite power, due to a total loss or a degraded condition, will result in the safety related loads not being capable of mitigating a design basis accident. The proposed changes to the Index page are administrative in nature and do not affect plant safety.

Therefore, the proposed changes do not result in a significant increase in probability or consequences of an accident previously evaluated.

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

The emergency bus degraded voltage protection system is utilized for accident mitigation. The proposed changes will I now provide viable corrective actions which do not result in a change in the manner in which the emergency bus loads are protected from a degraded voltage condition. These changes do not alter the function of the degraded voltage protection system. The proposed changes will continue to require that

' at least one of the two redundant 4160 volt or 480 volt emergency buses is protected from a degraded voltage condition assuming a single active failure of the opposite emergency bus degraded voltage protection system. This action will ensure that at least one train of engineered safety feature (ESP) equipment is not damaged due to a sustained bus undervoltage condition. The proposed addition of the requirement to enter the action statement for the B-6 J

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RTTACHMENT B, continuad Propossd Lictnne Amandannt Raquest Nos. 249 and 118 Page 7.

inoperablea diesel generator, if the one hour requirements of Action 34 cannot be met, will ensure that adequate compensatory actions to assure plant safety are taken. These requirements include the demonstration of the operability of the A.C. offsite sources by performing a specific surveillance within one hour and at least once per eight hours thereafter. If both diesel generators are inoperable, at least one diesel generator must be restored to operable status within two hours or the plant must be placed in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

No new accident scenarios, failure mechanisms, or limiting ,

single failures are introduced as a result of these changes. '

There will be no adverse effect or challenges imposed on any safety-related system as a result of these changes. ,

l Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The margin of safety is not significantly reduced because the  ;

A.C. electrical power sources will continue to provide sufficient capability, redundancy, and reliability to ensure availability of necessary power to ESF systems. The ESF systems will continue to function, as assumed in the safety analyses, to ensure that fuel, reactor coolant system and containment design limits are not exceeded. The proposed revisions to Action 34 will continue to require that at least one of the two redundant 4160 volt or 480 volt emergency buses is protected from a degraded voltage condition assuming a single active failure of the opposite emergency bus degraded voltage protection system. This action will ensure that at least one train of ESF equipment is not damaged due to a sustained bus undervoltage condition. The emergency loads, which are powered from that train of emergency buses, will continue to be available to perform their safety related functions. If the one hour requirements of Action 34 cannot be met, the affected emergency diesel generator will be declared inoperable. This will ensure that adequate compensatory actions to ensure plant safety are taken. The loss of emergency bus protection from a degraded voltage condition is similar to the loss of the ability of an emergency diesel generator to provide electrical power to the safety related loads on the emergency buses. In both situations, a loss of the offsite power, due to a total loss or a degraded condition, will result in the safety related loads not being capable of mitigating a design basis accident.

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RTTACHMENT B, continusd Propossd Lic0n2e Amsndmsnt Raquant Non. 249 and 118 i Page 8 I Therefore, the proposed change does not involve a significant reduction in a margin of safety.

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that the activities associated with this license amendment request satisfy the requirements of 10 CFR 50. 92 (c) and, accordingly, a no significant hazard consideration finding is justified.

G. ENVIRONMENTAL CONSIDERATION It has been determined that this license amendment- request involves no significant hazards consideration, no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. This . license amendment request changes an Action requirement, 'and associated Bases section, and an Index Page; however, this licensing action does not individually or cumulatively have a significant effect on the human environment.

Accordingly, this license amendment request meets the eligibility criteria for categorical exclusion set forth in- 10 CFR

51. 22 (c) (9) . Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this license amendment request.

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