Text

Discusses Current Status of Util Action Items Re Final Draft Upgrade Electrical Tech Specs,Per 861218 Meeting.Responses to NRC 870218 & 0506 Ltrs & Revised Draft Electrical Tech Specs Encl
	ML20237L485
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/24/1987
From:	Brey H; PUBLIC SERVICE CO. OF COLORADO
To:	Calvo J; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
	P-87272, NUDOCS 8709080419
	Download: ML20237L485 (75)
	v • d • e

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1 Public Service- :=g;L l 2420 W. 26th Avenue, Suite 200D, Denver, Colorado 80211 August 24, 1987 Fort St. Vrain Unit No. 1 P-87272 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 ATTN: Mr Jose Calvo, Director

' Project Directorate IV Docket No. 50-267

SUBJECT:

Final Draft Upgrade Technical Specification Sections 3/4.8, dated November 30, 1985.

REFERENCES:

1) NRC letter, Heitner to Williams, dated 2/18/87,(G-87056)

2) NRC letter, Heitner to Williams, dated 5/6/87,(G-87161)

Dear Mr. Calvo:

A meeting on the subject final draft Electrical Technical Specifications was held December 18, 1986. The NRC provided meeting minutes which summarized the meeting and assigned action items (Reference 1). Subsequently, a Request for Additional Information was submitted to Public Service Company of Colorado, (PSC) on the ,

final draft Electrical Technical Specifications (Reference 2). PSC !

has reviewed the NRC comments and has made appropriate changes to the revised draft Electrical Technical Specifications.

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P-87272 August 24, 1987 fi o' l

f^ This letter provides the current scatus of PSC action items.

l Comments from the reference documents shich require PSC's response are resolved in Attachments 1, 2, and .3. The proposed PSC

. categorization ofthe.NRC, comments is contained in Attachment 4.

Additianal- . changes to the final draft Electrical Technical

- > Specifications not discussed in the, Decenber 18, 1989 meeting are identified in Attachment 5. The l revised draf t Electaital T'e chnical ;

Specificatu.)ns,are contained in Attachment 6. The references nade ii1 i Attachments are identifsed in Attachment 7.

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PSC would l'Ke to clarify that this submittal is not a final closecut I package on the NRC comments, as the revised draft Electrical !

Technical $ specifications in Attachment 6 have not received a final j plant managen:ent; review. It is recognized that additional changes may be identif'ed during further review efforts by both PSC and the NRC.

4 If you have any questions en this information.., riease c'>atact Mr. M.

H. Holmes at (303) 480-6960.

t Very truly yours, si 3%m 0 H. L. Brey . Manager Nuclear Licensing

.ana Fuels Division HLB /JAC/imb Attachments cc: Re.gional Administrator, Region IV

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Attention Mr. J. E. Gagliardo, Chief Reactor Projects Branch

'L Mr. R. E. Tarrell Senior Resident inspector Fort: St. Vrain r

Mr. Alan Udy T!G&G Idaho, Inc.

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O ATTACHMENT 1 TO P-87272 4

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6 ATTACHMENT 'l LC Contained- herein are responses to Action items identified in the December 18, ~1986 meeting minutes (Reference 1). .Unless noted' otherwise, those commen;3 which . identify PSC's action to provide clarification have been incorporated into the revised draft Electrical . Technical Specifications (revised draft Attachment 6) and are not addressed in this attachment.

PSC accepts the raeting minutes (Reference 1) as documented with the following. exceptions and as clarified in the PSC responses:

a) The first comment of the meeting minutes references a consumption rate of 95 gallons / hour. This shculd be 96 gallons / hours per the FSAR, Section 8.2.

b) The second comment of the meeting minutes references 16,000 gallons as the consumption of fuel for a single Standby Diesel Generator in a week. This should be 16,150 gallons per the FSAR, Section 8.2.

c) The comment for load rejection test requirements references the bearing water pump (175 kw) as the largest single load to be considered. .

Per FSAR section 8.2, Tables 8.2-6 and 8.2-7, this should be the Circulating Water Pump (202 kw). The applicable surveillance has been revised to verify the capability to reject a load of greater than or equal to 202 kw.

NRC Comment (3.8.1.1 Action a 2 and a.4):

"The:. licensee will check and follow up on the addition of 'or both' in 'with either.or both' of the above required offsite AC electrical 1 power. sources."

PSC Response: ;

The NRC has accepted PSC's position that the inclusion of "or both" is not required as this is covered by the general action statement q 3.0.3 per Reference 2, Enclosure 2, item 28b. .,

NRC Comment (4.8.1.1.2a.5):

"Instead of the requirement for the Standby Diesel Generators to reach rated spee'd within 10 seconds 'after .the start signal, as specified in the STS, (Reference 4) the licensee will propose a site specific time limit due to the non-safety significance of this time limit."

PSC Response:

The Standby Diesel Generators (SDGs) are required to reach rated speed, voltage and frequency within 60 seconds after the start signal. Surveilling the starting time provides another parameter from which signs of degradation can be determined.

NRC Comment'(4.8.1.1.2c.2):

"The fuel' oil sample analysis differs from the Standard Technical Specifications. The analyses called out (ASTM-D270-1975, water and sediment content,- and ASTM-D975-1977, kinematic viscosity) are available locally.- The NRC should verify that these analyses are equivalent -to those listed in the Standard Technical Specifications.

PSC is to provide justification for this deviation."

PSC Response:

PSC provided justification for the proposed level of testing in letter P-85448, Attachment 2. This proposed level of testing for the diesel fuel oil, consistent with past experience and test facilities available locally,'is being addressed separately by the NRC per i Reference 2, Enclosure 2, item 28c.

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NRC' Comment (4.8.1.1.2f):

"The licensee is to look at. including a pressure test of portions of the diesel fuel oil system (similar to the surveillance in' Reference 4)."

PSC. Response:

The diesel; fuel oil system is not designed to Section III, subsection

- ND of the ASME code as referenced in the STS. The system is a low pressure system designed in accordance with PSC design. specification

' l-M-2. PSC does not consider the performance of this surveillance would. provide.any.significant additional information which would not be observed during normal operation and surveillance of'the SDGs. In

. addition, the system does not provide test points to readily. allow for testing. Based on the above, PSC considers sthis test to be outside the scope of the Upgrade Program.

NRC Comment (4.8.1-1):

"In. Table 4.8.1-1, the column labeled "Last 20 Valid Tests *" was questioned. This is in agreement with the sample table in -Generic

- Letter 84-15 and acceptable. The licensee will add "At least once per seven days ** and" to Test Frequency column.for GTE 3."

PSC Response:

The "2" in the " Number of Failures in Last 20 Valid Tests" column has been changed to "> 2" to be consistent with Ge neric' Letter 84-15 in the-revised draft, Table 4.8.1-1.

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!L y NRC Comment (Figure 3.8.1-1): i "The licensee will change, to the as-built configuration, the suction piping of the diesel fuel oil. transfer pumps from one line per pump to a single tank outlet line that splits into two pump suction lines.

Also to be added are recirculation. lines from each diesel (IA, IB, 10,!10) to the. corresponding day tank." l PSC Response:

l The -comment has been incorporated into Figure 3.8.1-1, but only one 'j recirculation line is shown as typical for all. four engines in the s revised draft. In addition to these changes, Figure 3.8.1-1 has been further~ modified to reflect actual plant conditions from separate

' suction lines from each fuel oil storage sank to a common line ,

between the tanks, after the feed lines to the ACM and the Auxiliary i Boiler Fuel Oil Feed Pumps, and from .two separate feed lines to the ;

.. Auxiliary, Boilers'with a cross-connect line to the ' Standby Diesel ;

Generators to a single feed line to the Auxiliary Boiler with a cross connect line to the Standby Diesel Generators.

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p ' NRC C'omment'(3.8.2.1 Action a)i

. "The ' licensee will clarify '0PERABLE D.C. electrical source'.

Section 4.6.3 of the existing Technical Specifications presently ;

allows the .two divisions of D.C. power to be tied tcgether while a i battery and its charger are isolated, performing an. equalizing '

charge. It was agreed that this practice was not acceptable. The ;

L licensee will modify the wording to ensure that the buses will not be tied .together. In providing bases for alloung 5 days for an )

equalizing charge, the licensee will address. emergency operating procedures and training in restoring the isolated battery to its bus and the. positive prevention of bus ties'." )

PSC Response:

l " Energize the Dt bus with another OPERABLE D.C. electrical source" has been replaced with " verify the associated DC load is energized with . a dedicated sattery charger" for Action a under Section 3.8.2.1 in.the revised draft. .

- Clarific.ation is provided in the. basis regarding the requirement to maintain independence between the D.C. buses in Section 3/4.8.2 of >

the. revised draft. In addition, the tie breakers between redundant buses are required to remain open per Sections 3.8.3.1 and 3.8.3.2.

In an emergency situation in which the batteries would be relied upon, administrative controls will be in place to ensure a battery receiving an equalizing charge would be returned to service as 1cng as the Category A requirements from Table 4.8.2-1 of the revised draft .were met. The' administrative controls will be maintained through procedures and training.

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i ATTACHMENT 2 TO P-87272 i

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j ATTACHMENT 2 Contained herein are the PSC responses to the Request for Additional l Information on the final Electrical Technical Specifications !

(Reference 2), Enclosure 1, which compared the final Draft Electrical i Technical Specifications (Reference 3) to the Proposed Technical l Specification Changes (Reference 7). The Proposed Technical l Specification changes were withdrawn by PSC, but the purpose of the j review was to identify any requirements that had to be carried over to the upgraded Electrical Technical Specifications. Unless stated I' otherwise, the NRC comments are referencing sections of the Proposed l Technical Specifications changes. l l

NRC Comment (1):

" Tables 4.4.5 and 5.4.5 and associated notes were to be added to the Technical Specifications. Reference [3] included these tables as Tables 3.3.1.5 and 4.3.1.5. We note that the time dial setting for ;

Functional Unit 3 changed from 6 to 5 in the process...The licensee !

should verify the correct settings of these undervoltage relays and commit to having these tables and notes in the upgraded Electrical Technical Specifications. It should include nominal setpoints and allowable limits (where voltage and time tolerances exist)."

i PSC Pesponse:

This comment is associated with the PPS Technical Specification amendment and will be addressed as part of the PPS submittal.

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NRC Comment (2):

"LCOs 4.6.1.1.b) and 4.6.1.2.b) parts 4) one starting air compressor and receiver, and 5) One Boiler Fuel Oil pump operable between the auxiliary- fuel supply and the diesel fuel oil day tank (s), were not 1

included in Reference [3]. The licensee should include these requirements in the corresponding sections."

PSC Response:

- The operability of. the starting air compressor and receiver is verified per. Surveillance Requirement 4.8.1.1.2.a.9 in the revised draft. Electrical Technical' Specifications (revised draft, Reference

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. The . Boiler Fuel. 011 Pumps (Auxiliary Boiler Fuel Oil Feed Pumps) are

. not specifically required to operate in the revised draft. There are- )

two limiting conditions of operation, LCOs 3.8.1_.1.b and 3.8.1.1 b.2 which require a minimum quantity of fuel in the day tanks. and the capability to transfer fuel from the underground storage tanks to the Diesel ' Fuel Oil Day' Tanks.

PSC' considers-the surveillance requirement and the LCOs to adequately meet the intent-of the operability requirements for the referenced

l. equipment in the existing Technical Specifications.

NRC Comment (3):

"LC0 4.6.1.1.d)3) requires the. DC bus to be energized from its associated battery. The corresponding section, 3.8.3.2c of Reference

- [3]. does -not include the words ' energized from its associated battery'. The wording should be-revised to include a battery that is connected to its DC bus during shutdown."

PSC Response:

PSC concurs with the NRC comment.

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- Section 3.8.3.2.c of the revised draft' reads "One 125 Volt D.C. bus energized from its associated battery / battery charger."

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> NRC Comment (4):

j' "LCO: 4.6.1.2.c) and d) require bus tie breakers to be open between buses with.different power sources. 'The corresponding section in

- Reference. .[3] does. not' include this restriction. A similar-

- restriction in'Section'4.6 2.f) for the DC system prohibits closed

- connections .between the DC sources. Corresponding sections of the Upgraded Technical Specifications should prohibit the use of bus tie-breakers that. could prevent division independence and redundancy of the Class IE distribution system." 1 PSC Response:

. In ' Sections 3.8.3.1.and 3.8.3.2 of the upgraded Electrical Technical Specifications is a requirement to maintain tie breakers open between redundant buses. Per design of the plant, this is not applicable to the 4160 volt buses. If the applicable bus is not energized in the required manner, 'the. action statements under Sections 3.8.3.1 and 3.8.3.2 apply.

~1 NRC Comment (5.2):

"One hour is specified to demonstrate the operability of the associated battery versus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months specified in [ Reference 3] Action b under 3.8.2.1. The licensee should either continue the one hour requirement or justify extending the limit to 2 hcurs."

PSC Response:

The existing Technical Specifications (Reference 5) allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore a batte ry charger to operable status. The one hour requirement in Reference 7 to initially verify operability of the associated battery and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, is to ensure the capability of the battery is not degrading. The upgraded Electrical Technical Specifications allow two hours to perform the initial surveillance and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter per Action b under Section 3.8.2.1. The two hours to perform the initial surveillance does not compromise the safety of the plant as the battery would immediately supply the DC load and the continued surveillance would verify there is no degradation.

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NRC Comment (5.6 & 11):

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" Reference [3] does' not verify that 1) the engine driven fire pump is operable or 2) that the emergency condensate. header. is operable as specified (in LC0 4.6.1, note 6 and 11). The. licensee should either continue this operability verification or justify its deletion."

pSC Response:

The engine driven fire water pump and the emergency condensate header-operability is specified in the. upgraded Technical Specifications

' Sections 3/4.5.4 and 3/4.5.3, respectively.

NRC Comment (5.7):

"The requirement to shutdown the auxiliary boiler upon reaching the minimum fuel level is not carried over to Reference [3]. The licensee should' continue this requirement."

PSC Response:

The purpose- of the Auxiliary Boiler system is'to supply steam to.

equipment _during those periods when steam from the cold reheat header-and/or bypass flash tank is unavailable or insufficient such as during shutdown. If less than 20,000 gallons of fuel was available in' storage, Action b applies and .the plant is required to be in-

. shutdown if the fuel cannot be repleni.shed during the conditional restoration period. If the plant is required te be shutdown, it is desirable to have the Auxiliary Boilers available to perform an orderly shutdown. Therefore, this requirement has been deleted from the revised draft.

NRC Comment (5.8):

"The conditioned allowance for the boiler fuel oil pumps to be

. inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not carried over to ' Reference [3]. The licensee may want to continue this conditioned allowance."

PSC. Response:

Refer to the PSC response to NRC Comment (2).

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l NRC Comment (5.10):

l l "The action requirement on operability of the 4160 V buses is not entirely covered by action a of 3.8.3.1 of Reference [3]. The i licensee should justify those differences."

PSC Response:

The 4160. VAC buses are not specifically called out in the upgraded Electrical Technical Specifications, as these buses are not saftty related. However, if the 4160 VAC buses are not supplying the 480 l

VAC buses as specified in Section 3.8.3.1 of the revised draft, the plant is required to reenergize the 480 VAC buses in the required manner within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The existing Technical Specifications and Reference 7 allow for a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period to restore a 4160 VAC bus to service versus the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed under the upgraded Electrical Technical Specifications. The upgraded Electrical Technical Specifications provide a more stringent requirement based on the reduced conditional restoration time.

NRC Comment (5.11):

The action requirement on the operability of these 480 VAC essential buses is not entirely covered by action a of 3.8.3.1 of Reference

[3]. The licensee should either justify these differences or continue these requirements."

PSC Response:

The existing Technical Specifications and Reference 7 allow 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to return the inoperable bus to service or be in shutdown if certain conditions are not met. The upgraded Electrical Technical Specifications, Section 3.8.3.1 allow 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to reenergize the bus in the required manner or be in shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Therefore, the upgraded Electrical Technical Specifications provide a more stringent requirement based on the reduced conditional restoration time.

l NRC Comment (5.13, 14, 15):

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"The' 24 h'ours'for an equalizing charge is currently under discussion as Reference [3] would allow' 5 days as required by the present battery design. The licensee should provide a satisfactory resolution-to this issue." )

PSC Response:

m, The' revised draft Electrical Technical Specifications section 3.8.3 l allows 5 days to ' perform an equalizing charge as required per design. i

~However, per-. Action 1 under Section 3.8.2.1 when a. battery is j inoperable for any cause other than an equalizing change being' performed, it is required to be returned to operable status within 24 i

' hours'or be.in shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is consistent !

'with the existing Technical Specifications.

l PSC -has stated in the December 18, 1986 meeting (Reference 1) that a battery receiving an equalizing charge would be returned to service ,

under emergency conditions via administrative controls. l I

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.NRC Comment (6.2):

"The requirement to verify the operability of the boiler fuel oil pumps is not carried over to Reference [3]. The licensee should continue this requirement."

FSC' Response:

Refer to the PSC response to NRC Comment (2). ;

i NRC Comment (6.4):

"The requirement to verify the battery charger current supplying ,

capability is not carried over to Section 4.8.2.1. The licensee '

should provide f', r this test in the upgraded Electrical Technical Specifications."

pSC Response:

Section 4.8.2.1.c.4 in the revised draf t verifies the battery charger

capability to supply current limited load at 125 Volts D.C. for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for each battery charger.

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.NRC Comment (6.5):

"The' operation of either a manual start or an undervoltage relay test

' actuation signal start is not carried over. to Reference [3]. The licensee'should explainLwhy this option is deleted."

PSC Responsei i

.The StandbyLDiesel Generators (SDGs) can be started manually or via a simulated'or actual'undervoltage relay actuation signal. This option is. not- .specified in the surveillance as this is controlled administrative 1y.

Presently, the manual test is performed via the manual start switch, the six month' loss of voltage test is performed via a simulated loss

.of xvoltage relay actuation signal,.and the 18 munth loss of voltage test is performed via an actual loss of. voltage = relay actuation signal, l NRC Comment (6.c):

"The impurity test per ASTM-D2274-70 (impurity > 2'mg insolubles per

-100 ml) is not carried over to Section 4.8.1.1.2c.2. The licensee should either provide .this requirement or justify its deletion."

PSC Response:

In PSC letter, P-85448, Attachment 2, . justification for the proposed level of testing was provided. Per Reference 2, Enclosure 2, item 28c, this proposed level of testing for the diesel fuel oil, consistent' with past ' experience and test facilities available locally, is being addressed separately by the NRC.

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, NRC' Comment (6.d): .

'.'T h e specified test [5.6.1.2.d)3).] is with the generator operating in parallel with the offsite power. system. The corresponding section i of Reference [3] (4.8.1.1.2d.4) does not specify parallel operation. J The licensee should resolve this discrepancy."

PSC Response-l The reference to the SDG operating in parallel in Reference-7 is with

. respect to the governor. mode of operation, i.e., isochronous versus parallel. -The governor mode of operation _can either be parallel or isochronous. During the weekly surveillance required per. - the existing Technical Specification the SDG is placed in the parallel 3 mode of operation in order to syncronize it with offsite power and to l place the, required load on the SDG. Normally, the governor is in'the isochronous mode of operation in the event of an L.O.E.P. The mode of operation -is not specified in Section 4.8.1.1.2.e.4 as this is controlled administratively via the applicable surveillance procedures.

NRC Comment (6.6):

"The. verification of the diesel generator capability to transfer loads to offsite power and to be restored to standby status is not carried over_ to Reference [3]. The licensee _should justify this deletion of requirements."

PSC Response:

The above referenced requirements have been incorporated into the revised draft, Section 4.8.1.1.2.e.7.

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NRC Comment (6.8):

"The verification of the accuracy of the load sequence timers (load sequencing programmers) is not carried over to Reference [3]. The licensee should provide for this test in the Upgraded Technical Specifications, for both sequence A and B and the determination of which diesel generator is first in service."

PSC Response:

PSC concurs with the NRC comment. Section 4.8.1.1.2.e.9 of the revised draft verifies the accuracy of the load sequence timer.

The verification of the sequence "A" and sequence "B" loads is controlled administratively as part of the simulated undervoltage actuation surveillance procedure.

NRC Comment (7.c):

"The requirement to check the temperature difference of each cell-to-cell and terminal connection is not carried over to Section 4.8.2.1.c of Reference [3]. The licensee should justify this deletion."

PSC Response:

The surveillance requirements in Section 4.8.2 of the upgraded Electrical Technical Specifications are consistent with IEEE 450-1980 and the STS and will provide PSC with a better assessment of the conditions of the DC power sources.

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l ATTACHMENT 3 TO P-87272 4

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f. ATTACHMENT 3 Contained- herein are 'the responses to Request 'for Additional l Information on the Upgrade' Program final draft Electrical ~ Technical

-Specifications, (Reference 2), Enclosure 2. The. comments in the Enclosure are' based on the final draft Electrical Technical

. Specifications: (Reference 3) compared against various other ;

documents, as referenced.

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NRC Comment (1).

...The surveillance section does not call out instrumentation, nor

. channel afunctional . tests 'or a calibration- check on the instrumentation used for{ minimum fuel levels] measurement. If instrumentation is used (rather than sight glass or dip stick), it should -be included by the licensee in surveillance requirements for channel: functional ~ tests and calibration checks."

PSC Response:

There is _ no applicable. instrumentation as a sight glass is used to measure the' fuel level in the day tanks and dip sticks are used to

-measure fuel level in underground storage.

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l NRC Comment (2):

"Section 3.8.1.lb does not have the following requirements for Section 4.6 of the existing Technical Specifications: one starting air compressor and receiver per diesel generator set, [ operable]; I should the diesel fuel quantity be less than 20,000 gallons, the auxiliary boiler is to be shut down, and at least one Boiler Fuel Oil

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4 Feed Pump [ operable] between the auxiliary boiler fuel supply and the l day tanks."

I PSC Response:

Surveillance Requirement 4.8.1.1.2.a.9 in the revised draft Electrical Technical Specifications (revised draft, Reference 6) verifies the operability of the starting air compressor and receiver.

The purpose of the Auxiliary Boiler system is to supply steam to equipment during those periods when steam from the cold reheat header and/or bypass flash tank is unavailable or insufficient such as during shutdown. If less than 20,000 gallons of fuel was available instorage, Action b applies and the plant is required to be in shutdown if the fuel cannot be replenished during the conditional restoration period. If the plant if required to be shutdown, it is desirable to have the Auxiliary Boilers available to perform an !

orderly shutdown. Therefore, this requirement has been deleted from the revised draft.

The Auxiliary Boiler Fuel Oil Feed Pumps are not specifically required to operate in the revised draft. Limiting Conditions for Operation 3.8.1.1.b.1 and 3.8.1.1.b.2 require a minimum quantity of fuel in the day tanks and the capability to transfer fuel from the underground storage tanks to the diesel fuel oil day tanks.

PSC considers the surveillance requirement and LCOs to adequately meet the intent of the operability requirements for the referenced equipment in the existing Technical Specifications.

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NRC Comment (3):

"Section 3.8.1.Ib.4 was added per the Westinghouse Standard Technical Specifications [STS, Reference 4] requiring 150 gallons of lubricating oil. We understand that this lubricating oil is hand fed, and storage is in shipping drums. We find this acceptable, l however, the licensee should indicate that this is 150 gallons per diesel generator set."

PSC Response: .

l Consistent with the requirement for a 1 week supply of diesel fuel oil and information received from the manufacturer, it has been determined that a supply of approximately 60 gallons of lubricating oil is adequate for 1 week of SDG operation. Therefore, the quantity of lubricating oil required per Sections 3.8.1.1 and 3.8.1.2 in the revised draft is 100 gallons in storage.

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NRC Cr1 ment (4c):

"The licensee had deleted the NRC comment regarding loss of both offsite [AC electrical] power sources. Discussion with the licensee in December 1986 (Reference 1) leaves this item to be resolved by the >

I licensee by having some requirement regarding the loss of both offsite AC electrical power sources."

PSC Response:

Per Reference 2, Enclosure 2, item 28b, the NRC has accepted PSC's position that the inclusion of the above condition is not required as this is covered by the general action statement 3.0.3.

NRC Comment (5):

"Section 4.8.1.1.Ib should read, per Reference [4], 'At least once per 18 months during shutdown', instead of 'At least once per 18 1 months'." )

PSC Response:

PSC concurs with the NRC comment and the comment has been incorporated in Section 4.8.1.1.1.b of the revised draft.

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NRC Comment (6.a.3):

"The capability to transfer fuel oil from the storage system to the day tanks should include the Boiler Fuel Oil Feed Pumps."

PSC Response:

Refer to the PSC response to NRC Comment (2).

J NRC Comment (6.a.6):

"The amount of lubrication oil in storage should be consistent with comment 3 above."

PSC Response:_

Refer to the PSC response to NRC Comment (3).

' NRC Comment (8):

"Section 4.8.1.1.2c should also include the existing SR 5.6.1d functional test of the diesel engine exhaust temperature " shutdown" and "declutch" functions on a 31 day basis."

PSC Response:

The Standby Diesel Generators (SDGs) are designed such that each generator is driven by two engines. If one engine fails it is disengaged by the " shutdown" and "declutch" feature and the generator continues at one-half of unit capacity powered by the remaining engine.

Per surveillance requirement 4.8.1.1.2.d in the revised draft, the

" shutdown" and "declutch" functional check will be performed on a 31 day basis, consistent with existing Technical Specification.

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- NRC Comment (9):

"Per Reference [4], Section [4.' 8.1.1. 2d . 4] should readwithout tripping' rather than 'without- tripping the diesel engines' ."

PSC Response: 1 PSC~ concurs with' the NRC comments and. the comment has been incorporated in the revised draft, Section 4.8.1.1.2.e.4 accordingly.

NRC C'omment (10):

"Section 4.8.1.1.2d.5, .concerning the simulated undervoltage relay actuation signal,-[should address] the following: The words' '

- ' energize the. autosequenced loads,' should be ' energize the autosequenced loads through the load sequencer,' and ' OPERATE' should be '0PERATES.with permanently connected loads within 10 seconds'."

PSC Response:

" Energize the 480 Volt A.C. essential. buses" has been modified by adding "within 60 seconds," consistent.with the SDG starting time throughout Section- 4.8.1.1.2 of the revised draft Electrical

- Technical Specifications. The permanently connected -loads are not

.'specified' since energizing the 480 VAC buses energizes the permanently connected loads.

" Energize the auto sequenced loads" has been changed to " start the autosequenced loads through the load sequencer".

NRC Comment (11):

"Section 4.8.1.1.2d.7, per Reference [4], should be divided into l Section a) be synchronized ..., and have added b) transfer its loads I to the offsite power source and c) be restored to its standby !

status." {

1 PSC Response: l PSC concurs and the NRC comment has been incorporated into the

. revised draft Section, 4.8.1.1.2.e 7, accordingly.

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NRC Comment (12):

"Section 4.8.1.1.2d, should have the following additional sections:

(a) Verify that the diesel fuel oil transfer pumps IA & IB and ,

the Auxiliary boiler fuel oil feed pumps 1A & IB each transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines; (b) Verifying that the automatic load sequence timer is OPERABLE '

with the interval between each load block within 10% of its design interval; (c) Verifying diesel generator lockout features prevent diesel generator starting only when required; and (d) Verifying that with all diesel generator air start receivers pressurized to less than or equal to psig and the compressors secured, the diesel generator starts at least (5) times from ambient conditions and accelerates to at .

least ( ) rpm in less than or equal to (10) seconds." i PSC Response:

Item (a) is accomplished via surveillance 4.8.1.1.2a.3, which verifies the capability to transfer fuel from the underground storage system to the diesel fuel oil day tank. Item (b) has been added to the revised draft, Section 4.8.1.1.2.e.9. Item (c) is not applicable at Fort St. Vrain as there are no lockout features associated with the SDGs. Item (d) has been added to the revised draft, Section 4.8.1.1.2.a.9.

NRC Comment (12e): i "Due to the relaying used to enercize [480 Volt AC essential] bus 2 from the first up diesel generator, a paragraph should be added to test the capability of this mechanism."

PSC Response:

Per surveillance 4.8.1.1.2.e.5 the capability to pickup 480 Volt AC essential bus 2 is verified by the SDG under surveillance when

" energizing the associated 480 VAC essential buses",

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m NRC Comment (13):

- "Section 4.8.1.1.2 per Reference [4] should have a pres:ure test added on applicable portions of the diesel fuel oil system." j PSC Response: ,

.1 The diesel fuel oil system is not designed to Section III, subsection ND of the ASME code as Referenced in the STS. The diesel fuel oil system is low pressure system designed-in accordance with PSC design

. specification 1-M-2. PSC does not consider.the performance of. this surveillance to provide.any significant. additional information which would not be observed during normal operation and surveilling of the SDGs. Additionally, the system does not readily_ provide test points.

Based on the above, PSC considers this test to be outside 'the scope of the Upgrade Program.

NRC Comment (14b):

"In Table 4.8.1-1, for GTE 3, the test frequency should be 'at least once per 7 days and see Table 4.8.1-2'."

.PSC Response:

PSC concurs -with the intent of the NRC comment. In the revised draft, Table 4.8.1-1 has been modified by changing the "2" in the "Last 20 valid tests" column to ">2" to be consistent with generic letter 84-15.

NRC Comment (15):

"Section'3.8.1.2b--Comment 2 also applies here, modified for startup, shutdown and refueling modes, even though existing Technical Specifications do not address AC power sources for these modes."

. PSC Response:

Refer to the PSC response to NRC comment (2).

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NRC Comment (16):

"Section;-3.8.1.2, 3.8.2.2 and 3.8.3.2, ACTION a, does not' require ldepressurization and venting of.the reactor.. coolant. system _ as does

~Refe'rence '[4], nor suspension of crane operetton with loads over the- i fuel; storage pool. Theseactionsareto'be;iitmediatewithno6 houi

grace- period. The standard technical' specification 1 " positive s reactivity changes" has been changed Lto " control rod movements 'h resulting in positive reactivity changes." This ACTION statemenu/ ~

should more. closely resemble that in Reference [4]." ju

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PSC Response: <

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The- ' revised draft has deleted 'the grace periods referenced;above.

Section 3/4.7 addresses: PCRV'. pressurization' and depressurization requirements. . There is no fuel ' storage pool at ' FSV. Therefore, depressurization and venting 'of the _ reactor coolant' system. and-suspension of crane operations with loads over.the fuel' storage pool' are not included. Finally,.PSC use of- the statement- " control : rod .

r movements resulting in positive reactivity changes" has been accepted by the NRC per Reference 8. .. /

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7 NRC Comment (17):

"In. Section 3.'8.2.1 and 3.8.2.2, the 2 hrs to demonstrate the operability of the associated battery bank in ACTION b should be 1 hr per Reference 4 and the. licensee's 5 days to restore a battery due to an . equalizing charge is not awquate should the battery be inc9erative due to other causes. Also there should be a cumulative limi.t on the number of 5 days inoperative actions each battery can use in a cycle."

't pSC.Respons_el Thq existing Technical Specifications allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore a

, battery charger to operable status. The upgraded Electrical Technical Specifications allow two hours to perform the initial '

surveillance and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter per Action b under Section 3.8.2.1. The two hours to perform the initial surveillance does not compromise the safety of the plant as the battery would immediately supply the DC load and it is the continued surveillance that would verify any degradation. This is consistent with the existing Technical Specifications.

r, FVse days is required to perform an equalizing charge per design.

However, the action statements in the revised draft indicate "if a battery is inoperable for any cause other than an equalizing charge being performed, restore the inoperable battery to operable status within 24 houes," consistent with the existing Technical s Specifications.

PSC has not identified a cumulative limit on the number of 5. days inoperative actions each battery can use in a cycle. As stated in the December 18, 1986 meeting (Reference 1) a battery receiving an equalizing charge would be returned to service under emergency conditions as long as the Category A limits in Table 4.8.2-1 were not exceeded.

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NRC Comment (19):

"Section 4.8.2.la does not measure the temperature of the cells adjacent to the pilot cell as presently required in [ existing Technical Specification] SR 5.6.2a. The licensee should justify this deletion. or incorporate it into the upgraded technical specifications."

PSC Response:

The battery surveillance have been revised to be consistent with IEEE 450-1980 and the STS. Performing the surveillance in accordance with these standards provides PSC with a better assessment of the condition of the batteries. Those surveillance in the, existing Technical Specifications are being superceded by the surveillance spe'4fied in IEEE 450-1980.

NRC Comment (20):

"In Section 4.8.2.1b.2, ' abnormal corrosion' should be ' visible corrosion' per Reference 4."

PSC Response:

PSC concurs with the NRC comment and the comment has been incorporated in the revised draft accordingly.

NRC Comment (21):

"Section 4.8.2.lc, per Reference [4], the following surveillance should be added: 'The battery chargers will supply at least (200) amperes at (129) volts for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ' ."

PSC Response:

PSC concurs with the NRC comment. Surveillance Requirement 4.8.2.1.c.4 in the revised draft verifies the capability to supply its current limited load at 125 volts for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

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, NRC Comment (22): s "Section 4.8.2.1d., the words 'all of the emergency lo& W 5,hould be

f. 'all of the actual or simulated emergency loads' per Reference [4]'." i I

j PSC Response:

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This surveillanceispe-formedtodemonstratethecap(.;bilityofeach battery to supply and maintain in an operable st.at us all of the i emergency loads for the- design duty cycle. Etthor actual or simulated loads car. be used during the surveillance, a.s long as!'the

-battery is subjecW d to the applicable load profile. .Therefore, PSC

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, NRCComment(23}:

" Table 4.8.2-1 in this Electrolyte Level row, 'ab:vt ' indication mark' should be 'above max',raum level indication mark' per Reference [4]."

_P,SC Response:

PSC concurs with the NRC comment. The comment has been incorporated

.into the revised draft accordingly.

NRC Comment (24):

"Section 3.8.3.la, b, & c, the requirement for the tie breakers to be opan between redundant buses is appropriate, however, for the 4160 V buses, our understanding i s. that one tie must be established when using the unit auxiliary transfore r and two ties must be established when' using the startup tran sfortner. The 4160 V AC buses 'shcaid

, j therefore be addressed separately from the 480 V AC, the 120 V' AC non - hnerruptible and the 125 V DC essential buses which must have the tie 1 breakers open."

PSC Ilesponse:

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The,NRC understandirsg of the tie breakers associated with the 4160 volt buses is correct. Tha revised draft, Sections 3.8.3.1 and 3.8.3.2, indicate that..the requirement for the tie breakers between redundant buses to be open does not apply to the 4160 VAC buses.

NRC Comment (25a):

"The following must be met according to [ existing] technical '

specifications: the 4160 VAC bus IB must be operable (LCO 4.6.10.2);

the diesel generator (s) supplying the remaining 480 VAC essential buses must be operable (LC0 4.6.10,5); the equipment supplied by the operable essential buses associated with safe shutdown cooling must be operable (LC0 4.6.1C.6); [and] the reactor building exhaust fans supplied by the operable essential buses must be operable (LC0 4.6.10.7). The licensee should include these requirements or justify their deletion."

PSC Response:

The referenced requirements in the existing Technical Specification have been relocated in the Upgraded Technical Specifications as follows: the 4160 V bus IB is identified in Section 3.8.3.1.b; the operability of th. SDGs is addressed in Section 3.8.1.1.b; the equipment supplied by the operable essential buses is verified per ,

action 3.8.1.1.d; and the reactor building exhaust fans are addressed in section 3/4.6.5.2.

NRC Comment (25b):

"The wording 'from the alternate source' should be deleted per Reference [4]. This would allow the repair of the inverter and reenergizing the bus from it. The wording 'the following' should be deletedperReference[4]."

PSC Response:

The wording "from the alternate source" has been replaced with "from the 480 VAC, backup source" in Section 3.8.3.1 under Action b.1 of the revised draft. The use of the backup source through the inverter / static transfer switch to energize the non-interruptible bus is a design feature of the distribution system. The AC non-interruptible bus may be energized in this manner for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the AC non-interruptible bus can not be reenergized by its preferred source in that time period, the plant is required to be in at least shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is consistent with the existing Technical Specifications.

PSC concurs with the NRC comment, "the following" should be deleted.

The wording has been removed from the section 3.8.3.1 under Action b.2 of the revised draft.

- NRC Comment-(25c):

"The [ existing] Technical Specifications (LCO 4.6.le) allow a DC bus !

to' be_ inoperable for'12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if 5 conditions are met. A battery may be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is less restrictive than the proposed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months /5 days. This limit needs to be resolved."

i PSC Response:

The 12: hours allowed for .one of the DC buses to be inoperable is i based on 5 conditions being met by the operable DC bus and_ its associated hardware. The upgraded Technical Specifications allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .if a DC bus is'not energized in the required manner based on the period allowed.for. an inoperable battery. However, Action 3.8.2.1.a requires the DC loads to be reenergized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by a ,

dedicated battery charger during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . period. Therefore, the upgraded Technical Specifications provide a more reliable system by ensuring. the loads _ for both DC buses are energized-within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months versus 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in the existing Technical Specifications.

Five days is required to perform an equalizing charge per design.

However, the action statements in the revised draft indicate "if a batte ry. is inoperable for any cause other than an equalizing charge being performed,' restore the inoperable battery' to operable status

-within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ," consistent with the existing ' Technical Specifications.

NRC Comment (26):

"Section 3.8.3.2b, ends ' connected to their respective battery banks, and' versus the Reference [4], ' connected to their respective DC buses, and'. Due to .120 - V bus IC/1C-1 connection to battery IC rather than a bus we suggest the following wording .as the battery banks may be. disconnected for an equalizing charge: ' connected to their respective DC bus (or battery bank for 120 V AC bus IC/1C-l'."

PSC Response: l The . wording in the revised draft reads "from their preferred power sources" versus " connected to their respective battery banks".

" Preferred power sources" are identified in Section 3.8.3.1 of the revised draft.

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ljs NRC Comment (27): 1 "Section .3.8.3.2b, to be consistent with Reference [4], should be changed from 'One 125 volt DC bus' to 'One 125 volt DC bus energized from its-associated battery bank'."

PSC. Response:

PSC: concurs' with the intent of the NRC comment. The wording in the revised draft reads "One 125 Volt DC bus energized from its ;

associated battery / battery charger". Battery / battery charger is the

- appropriate source from which the bus is energized as identified in .

.Section 3.8.3.1. I i

l NRC Comment (28f):

"The battery equalizing. charge requires more than 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The issue of 5 days versus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for an inoperable battery is .to be.

' further addressed 'by-the licensee. Inoperable batteries for.causes other than equalizing charges should not be allowable per action statements for this length of time."

- PSC Response: -

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Refer to the PSC response to NRC Comment (17).

NRC Comment (28g):

"An ACTION statement proposed concerning 2 or more inoperable battery banks is stated to be covered by LCO [3.0.3], which would reduce the mode within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if existing LCOs cannot be met by existing action statements."

PSC Response:

LCO 3.0.3 is applicable in the case where 2 or more batteries are inoperable. In this case at least one battery would have to be restored within one hour or the mode of operation would be required to be in at least shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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ATTACHMENT 4 TO P-87272 i

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T ATTACHMENT 4 The . following is' the Categorization ~ of- Electrical Technical Specifications . comments transmitted to PSC by the- NRC in the referencedcletters, G-87056 and G-87161 ' Categorization symbols,used are the same'as used in previous meetings and correspondence:

A Incorporate comment as is-

-A# - PSC action' item.

B - No action needed (resolved by discussion)

C'- PSC'to explain in proposed TSUP amendment safety evaluation D' .PSC/NRC discussion needed to resolve L D* - NRC action item-E - Outside TSUP. scope - no further discussion planned F - Outside TSUP scope - further discussion possible.

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t R NRC PSC Comment. Categorization Categorization G-87056 3.8.1.lb.1 B B enclosure 1 3.8.1.lb.2(a) B B (Note 1) 3.8.1.lb.2(b) A A 3.8.1.1b.3- B' B t: .3.8.1.lb.4 . B- B i 3.8.1.1 actions (a.1) E E 3.8.1.1 actions'(a.2) :D B 3.8.1.1 actions (a.3) B B 3.8.1.1 actions (a.4) D B'

'3.8.1.1 actions (a.5) D* D*

3.8.1.1Lactions (b.1) D* .D*

3.8.1.1-' actions (b,2) A A-3.8.1.1 actions (f) B B 4.8.1.1.Ib.2 8 8 4'.8.1.1.2a.5 D A 4.8.1.1.2c.2 D* D*

4.8.1.1.2c.2f. A A' 4.8.1.1.2d.2- B B 4.8.1.1.2d.3 B B 4.8.1.1.2d.5&8 B B 4.8.1.1.2d.10- A# A#

4.8.1.1.2f D B Table 4.8.1-1 A A 3.8.1.2~ action D* B (see ref. 8)'

Figure 3.8.1-1 A A 3.8.2.1- .

A#- A#.

action 3.8.2.1.a A# A action 3.8.2.1.b A# A#

4.8.2,'1.d (4.8.2.1c.4) A# A# .i Table'4.8.2.1 A# A#

3/4.8.2. basis A# A#

3.8.3.1d/e/f- A# .A#

3.8.3.2b A# A#

G-87161 1 D A#

enclosure 1 2 D D*,B (Note 2)- 3 D A

. 4 D B 5.2,6 & 11 D B 5.7 D C '

5.8,10,11 D B 5.13,14,15 D D*

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NRC PSC Comment Categorization Categorization G-87161 6.2 D D*

enclosure 1 6.4 D A (con't) 6.8 (Table 4.8.2-1) D A#

6.5 0 8 6e D B 6.c D D*

6.d D B 6.6 0 A 6.8 D A 7 D D*

G-87161 1 B B enclosure 2 2 D D*,C,8 (Note 2) 3 D A 4a,b B B 4c D B (see 28b) 4d,e B B 5 0 A 6.a.3 D B 6.a.4 D B 6.a.6 D A 7 D* D*

8 D A 9 D A 10 D A 11 D A 12a D B 12b D A 12c D B 12d D D*

12e D B 13 D B 14a F F 14b D A 14c D A 15 D D*,C,B l

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i NRC PSC Comment Categorization Categorization G-87161 16 D B enclosure 2 17a D B (con't) 17b D D*

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19 0 D*

20 D A 21 D A 22 D B 23 D A 24 D A 25a D B 25b D A 25c D D*

25d B B 26 D A l 27 D A 28a D* D*

28b B B 28c D* D*

28d,e B B 28f A# D*

28g D B 28h B B 281 A# D* i 28j B B ;

Note 1: NRC categorization as interpreted from document.

Note 2: NRC categorization per NRC letter, Heitner to Williams, dated July 2, 1987, (G-87217).

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.1 ATTACHMENT 5 i TO P-87272 1

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,1 ' ATTACHMENT 5 Additional changes to the November 30,-1985 draft not discussed in

the December 18,.1986' meeting with the NRC, 318.1.1.a The' requirement to maintain two offsite sources of AC electrical.

power has been deleted. This requirement is inconsistent with the STS, which requires two independent. circuits between the-offsite nettfor.k and.the onsite class-3E distribution system, -but does not include the offsite network. .The FSV means of providing offsite-power is through the Reserve Auxiliary Transformer (RAT) or the Unit Auxiliary Transformer (UAT) which are' re' quired to be operable. These. circuits are not physically independent as both circuits' istilize the 4160 VAC buses. The conditional restoration time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the STS has been reduced.to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months wheti one circuit is inoperable, as a compensatory measure for the interdependence. Note .that the 'UAT and the RAT have been redefined as offsite sources.

3.8.1.1.b'.4 -j, The 150 gallon requirement has been changed to 100 gallons. The lubricating oil requirement is based on the seven day operating.

requirement for one SDG. Based on manufacturer's information, approximately 60 gallons of oil for 1 SDG running at rated

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capacity is requir'd for 1 week. Since the oil is contained in 55 gallon drums, the requirement has conservatively been set at 100 gallons.

3.8.1.1 Action b and Action c With .one SDG inoperable, the remaining SDG must be demonstrated operable,.if not so demonstrated within Lne previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , with initiation of the action within I hour per Operation Order 83-19. This means the SDG will be tested once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months versus once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

3.8.1.1 Action c With one offsite source (the UAT or RAT) and one SDG inoperable, at least one source must be restored within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , both offsite sources must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and both SDGS l must be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The previous draft potentially I alloweo 72 hours to restore an offsite source which is !

inconsistent with Action a.

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4.8.1.1.2a.4 i

The waterjacket heaters are considered operable so long as the !

coolant water temperature is maintained at greater than or equal. l to 100 degrees F. Based on present operating /mainti v nce procedures. The previous draft indicated 120 degrees F whicn is inconsistent with present plant practice.

4.8.1.1.2.e.6 q The SDG load has been changed from 1200 kw to 1210 kw since this is a capacity surveillance. l Table 4.8.1-1 The statement "When the test is done on a once per 7 day basis, 1 it need not be done on a Staggered Test Basis." has been deleted.

This would cause a loss in redundancy.

Table 4.8.1-2 The conditional clause, "If the cause of the failure cannot be found and remedied," has been deleted, as requalification is required based on the number of failures.

Table 4.8.1-2, Attachment 2, note d The requirement to be in shutdown within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months has been changed to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months consistent with the FSV time requirement for an orderly shutdown. ;

i 3.8.3.2 Consistent with 3.8.1.1, the offsite poser source has been deleted. The RAT or UAT is required to be operable. This would provide one means of supplying offsite power consistent with the STS.

3.8.1.2.b.2 l

The minimum 10,000 gallon requirement has been changed to 20,000 i gallons since this is based on 1 SDG icad requirements. There is I no basis for the fifty percent reduction in the level of fuel in l storage.

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l 3.8.1.2.b.4 This requirement has been changed to 100 gallons consistent with ,

3.8.1.1.b.4. !

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'4.8.2.1.a.2 Total terminal voltage of 129 volts has been changed to 121.5 volts. This is based on the acceptable performance of the battery at this voltage when subjected to a service discharge- l test. j 4.8.2.1.b.2

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Abnormal corrosion has been changed to visible corrosion !

consistent with the STS. 1 l

4.8.2.1.b.2 and 4.8.2.1.c.3 Connection resistance "is less than 150 E-6 ohms: has been changed to "does not exceed the average installation value by more than 20 percent" consistent with IEEE 450-1980. .

"With the exception of inter-rack" has been added to cell-to-cell {

connections, as the inter +ack connection resistance is not applicable.

4.8.2.1.b.3 l

"A representative simple" has been deleted as 20 percent of the )

cells is a representative sample.

3.8.3.2 "With tie breakers open between redundant buses" has been added consistent with 3.8.3.1.

I ATTACHMENT 6 TO P-87272 I

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Amendment No, Page 3/4 8- 1 nrwAFT Oe*

I AUG 2 41987 L

AUXILIARY ELECTRIC POWER SYSTEMS 3/4.8.1 A.C. POWER SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. The Unit Auxiliary Transformer (UAT), with or without the generator output links installed, and the Reserve Auxiliary Transformer (RAT).

b. Two separate and independent Standby Diesel Generators (SDGs) with:

1. Each diesel fuel oil day tank containing a minimum of 325 gallens of fuel,

2. A minimum of 20,000 gallons of diesel fuel in underground storage and an OPERABLE flow path (s) capable of transferring fuel oil from storage to each day tank,

3. An OPERABLE water-jacket heater for each SOG diesel engine, and

4. Lubricating oil storage containing a minimum total volume of 100 gallons of lubricating oil.

APPLICABILITY: POWER, LOW POWER, STARTUP*, and SHUTDOWN *

Whenever CALCULATED BULK CORE TEMPERATURE is grer.ter than 760 degrees F.

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AUG 2 41987 ACTION:

a. With either .the VAT. or the RAT of the above required o f f-'si te A.C. electrical power sources inoperable, demonstrate the .0PERABILITY 'of the remaining off-site

'A.C. electrical power source by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ~and at least once i

per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If either Standby Diesel

!Y -Generator- (SDG) has not been successfully tested within the' past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , demonstrate its OPERABILITY by performing Surveillance Requirements 4.8.1.1.2.a.5 and 4.8.1.1.2.a.7 for each such SDG, separately, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Restore the inoperable off-site source to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be i n' at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With either SDG inoperable, demonstrate the OPERABILITY

-of the' above required A.C. off-site- sources by ,

performing Surveillance Requirement 4.8.1.1.1.a within 1 !

hour, and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 'thereafter. If SDG-became inoperable due to any cause other than preplanned preventive maintenance or testing and the remaining SDG has_ not been demonstrated OPERABLE in the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months demonstrate the OPERABILITY of the remaining SDG by performing Surveillance Requirements 4.8.1.1.2.a.5 and 4.8.1.1.2.a.7, initiating the surveillance within I hour *. ' Restore the. inoperable SDG to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. With either the VAT or the RAT, and one SDG of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining.off-site A.C. source by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If SDG became inoperable due to any cause other than preplanned preventive maintenance or testing and the remaining SDG has not'been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , demonstrate its OPERABILITY

. by performing. Surveillance Requirements 4.8.1.1.2.a.5 and 4.8.1.1.2.a.7 initiating the surveillance within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months *. Restore at least one of the inoperable A.C.

electrical power sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Restore the UAT and the RAT to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and both SDGs to OPERABLS status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of initial loss of OPERABILITY, or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This test is required to be completed regardless of when the inoperable SDG is restored to OPERABLE.

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l. Amendment No.

Page 3/4 8-3 ggg o

1' AUG 2 41987 i

E d. With one SDG inoperable as in ACTION b. or c. above, l l

perform the following in addition to ACTION b. or c.: ;

Verify .within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that all the required systems,

subsystems, trains, components, and devices.that depend on the remaining OPERABLE SDG as a source are also OPERABLE, or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . j

e. With both SDGs inoperable, demonstrate the OPERABILITY of two-off-site sources of the above required A.C. !

electrical power sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore at least one of the inoperable SDGs to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Restore both SDGs to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of initial loss of OPERABILITY, or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

f. If results from a fuel oil sample taken per Surveillance Requirement 4.8.1.1.2.c.2 are unacceptable, demonstrate the OPERABILITY of both SDGs, separately, by performing Surveillance Requirements 4.8.1.1.2.a.5 and 4.8.1.1.2.a.7 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , if not performed within the last 7 days. Resample the fuel oil per Surveillance Requirement 4.8.1.1.2.c.2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of receipt of the unacceptable result (s). If results from the second sample are unacceptable, drain the fuel oil from the ,

contaminated tank (s) and replace it with fresh fuel oil.

Sample the fresh fuel oil per Surveillance Requirement 4.8.1.1.2.c.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The SDGs and ACM diesel ,

generator shall be declared inoperable upon receipt of i the second fuel oil sample results confirming contamination.

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Amendment No.

Page 3/4 8-4 Dgp r-AUG 2 41987 SURVEILLANCE REQUIREMENTS 4.8.1.1.1 The required off-site sources of A.C. electric power !

shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying correct breaker alignments, indicated power availability, and

b. At'least once per 18 months during SHUTDOWN:

1. By verifying automatic transfer of house power supply from the Unit Auxiliary Transformer to the Reserve Auxiliary Transformer, and .

2. By verifying that the Unit Auxiliary Transformer generator links can be tagged out and removed within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . !

4.8.1.1.2 Each Standby Diesel Generator (SDG) shall be !

demonstrated OPERABLE:

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a. In accordance with the frequency specified in .

Table 4.8.1-1 on a STAGGERED TEST BASIS by: l

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1. Verifying the fuel level in each diesel fuel oil day tank is at least 325 gallons,

2. Veri fying the fuel oil quantity in underground storage is at least 20,000 gallons in addition to the day tanks, s

3. Veri fying the capability to transfer fuel oil from the underground storage system to the diesel fuel oil day tank,

4. Verifying the water-jacket heaters are OPERABLE by ensuring that the coolant water is being maintained at a temperature of greater than or equal to 100

. degrees F,

5. Verifying the SDG diesel engines start from the normal pre-heated condition and accelerate to 1200 rpm; the SDG voltage and frequency shall be 480 plus or minus 48 volts, and 60 plus or minus 1.2 Hz within 60 seconds after the start signal,

6. Verifying the lubrication oil inventory in storage is at least 100 gallons,

, ; Amendment No.

Page 3/4 8- S DRAFT .

. AUG 2 41987:

~7. Verifying the SDG is synchronized, loaded to greater than'or equal.to 1200 KW with'two diesel engines per SDG and operates for at least 60 minutes,;

8. Verifying the 'SDG_ is aligned to' provide standby power to the associated emergency buses', and 9 Verifying..both air start receivers of the SDG are pressurized.to greater than or equal to 120 psig. ;

b. At least once per 31. days, and after'each operation of the SDG. diesel engines where the period of operation was greater than .or. equalto I hour, by. checking for and removing accumulated water from the Standby Generator Day tank.

c. At least once per 31 days:

'1. By checking for and removing accumulated water from the fuel oil storage tanks,'and

2. By verifying: that. a sample of fuel oil drawn and i analyzed from each of the following tanks is <

obtained in accordance with ASTM-D270-1975 and has a water and sediment content of less than or equal to 0.05 volume percent, and.a kinematic viscosity at 40

' degrees 'C of greater than or- equal .to. 1.9 centistokes, but less .than or equal to 4.1 centistokes, when tested in 'accordance with ASTM-0975-1977:

a) Diese1 fuel oil storage tank (T-9201) l I

b) ' ' Fuel oil storage tank (T-8401) i c) Fuel oil storage tank (T-8402) d) . Standby generator day tank (T-9202X)

. e) Standby generator day tank (T-9203X) f) Alternate cooling method day tank (K-4801) l l

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Amendment No.

Page 3/4 8-6 ORAFT.

AUG 2 41987

d. At least once per 31 days by performing a CHANNEL FUNCTIONAL TEST of the SDG " shutdown" and "declutch" engine protective functions.

e. At least once per 18 months, during SHUTDOWN by:

1. Subjecting the SDG diesel engines to an inspection in accordance with the procedures prepared in conjunction with the manufacturer's recommendations,

2. Performing a CHANNEL CALIBRATION of the SDG

" shutdown" and "declutch" engine protective functions.

3. Veri fying the SDG capability to reject a load of greater than or equal to 202 KW while maintaining voltage at 480 plus or minus 48 volts and frequency at 60 plus or minus 1.2 Hz,

4. Verifying the SDG capability to reject a load of 1200 KW without tripping the SDG; the SDG voltage shall not exceed 552 volts during and following the load rejection,

5. Simulating an undervoltage relay actuation signal:

a) Verifying de-energization of the 480 voit A.C.

essential buses and load shedding from the 480 volt A.C. essential buses, b) Verifying the SDG diesel engines start on the l auto-start signal, energize the 480 volt A.C.

essential buses within 60 seconds, start the auto-sequenced loads through the load sequencer, and OPERATE for greater than or equal to 5 minutes while the associated SDG is loaded with the programmed loads; after energization, the steady state voltage and frequency shall be maintained at 480 plus or minus 48 volts and 60 plus or minus 1.2 Hz during this test, and c) Verifying the overload and antimotoring SDG trip functions are bypassed when the SDGs are in the auto-start mode.

6. Verifying that the auto-sequenced loads to each SDG do not exceed 1210 KW, with both SDG diesel engines operating, I

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' Amendment'No. .

l Page 3/4-8-7 Elft!;FT 4

AUG 2 419674

7. .Ver'ifying.the SDG's capability to:

, , a) Synchronize with the off-site power source while

' the SDG 'is loaded with its emergency loads upon a simulated restoration of off-site power, b) Transfer'its loads to the off-site power source, and 7 c) Be. restored to standby status.

I 8. Verifying the SDG operates for'at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; during the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the SDG shall

.be loaded to greater than or equal to 1320 KW, and during the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of-this test, the SDG shall be loaded' to greater than or equal to 1200 KW; the SDG voltage and frequency shall be 480 'plus or minus 48 volts and 60 plus'or minus 1.2 Hz within 60 seconds after the start signal; :Within 5 minutes

-after- completing the 24 hour -test, perform Surveillance Requirement 4.8.1.1.2.a.5, and

9. Verify lthat the load sequence timer is Operable with the interval between each load block within plus or minus 10% of its design interval.

f. At least once per 10 years, or after any modifications which could affect SDG interdependence, by starting both SDGs simultaneously, during SHUTDOWN, and verifying that both SDGs accelerate to 1200 rpm, in less than or. equal

.to 20 seconds.

g. At least once per 10 years by draining each underground storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or equivalent.

h. REPORTS -

Standby Diesel Generator (SDG) failures, as required by Table 4.8.1-2, shall be reported to the

, Commission in a Special Report pursuant to Specification 6.9.2. Additional reporting and requalification requirements shall be in accordance with Table 4.8.1-2.

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Amendment No.

Page 3/4 8-8 i

TABLE 4.8.1-1 DRAFT 1 STANDBY DIESEL GENERATOR TEST SCHEDULE Number of Failures in Last 20 Valid Tests

Test Frequency

$1 At least once per 31 days 12 At least once per 7 days **

33 See Table 4.8.1-2 Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide 1.108, Revision 1, August 1977, where the last 20 tests are determined on a per Standby Diesel Generator (SDG) basis.

This test frequency shall be maintained until 7 consecutive failure free demands have been performed and the number of failures in the last 20 demands has been reduced to 1 or less, l

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Amendment No. I Page 3/4 8-9 DRA._r {

AUG 2 4 937 l TABLE 4.8.1-2 ADDITIONAL RELIABILITY ACTIONS No. of Failures No. of Failures in Last 20 in Last 100 Valid Tests Valid Tests Action 3 6 Within 30 days, prepare and maintain a report for NRC audit, describing the SDG diesel ;

engine reliability improvement '

program implemented at the site.

Minimum requirements for the report are indicated in Attachment 1 to this table. '

5 11 Declare the SOG inoperable !

and perform a requalification test program for the affected- .

SOG diesel engine. Requalifi- !

cation test program requirements i are indicated in Attachment 2 to this table.

N/A N/A Submit a yearly data report on the SDG reliability.

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i 86 DRAFT u

AUS 2 41987 ATTACHMENT 1 TO TABLE 4.8.1-2 REPORTING REQUIREMENT -j I

As a minimum, the reliability improvement program report for NRC l audit shall include: !

A .- A summary of all tests (valid and invalid) that occurred within the time period over which the last 20/100 valid tests were performed.

B. An analysis of failures and determination of root causes of failures.

C. An evaluation of each of the recommendations of NUREG/CR-0660, " Enhancement of Onsite Emergency Diesel Generator Reliability in Operating Reactors," with respect to their application to the Plant. ;

D. An identification of all actions taken, or to be taken, to I correct the root causes of failures defined in B. above and to achieve a general improvement of SDG reliability.

E. The schedule for implementation of each action from D above.

F. An assessment of the existing reliability of electric power to essential equipment.

Upon completion of the initial report detailing the SDG reliability ;

improvement. program at the site, as defined above, prepare only a '

supplemental report within 30 days after each failure during a valid demand, for as long as the affected SDG diesel engine continues to violate the criteria (3/20 or 6/100) for the reliability improvement 1 program remedial action. The supplemental report need only update the failure / demand history for the affected SDG since the last report for that SDG. The supplemental report shall also present an. analysis )

of the failure (s) with a root cause determination, if possible, and j shall delineate any further procedural, hardware, or operational i changes to be incorporated into the SDG improvement program and the j schedule for implementation of those changes. j i

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, , .' Amendment No.

Page 3/4 8-11 DRAFT-ATTACHMENT 2'TO TABLE 4.8.1-2

-)..

' STANDBY DIESEL GENERATOR REQUALIFICATION PROGRAM A. Perform 7. consecutive successful' demands, as' specified in.

'. Surveillance Requirement 4.8.1.1.2.a,'without a failure within 30 days of the; SDG' being restored to' OPERABLE . status, and 14 consecutive successful demands without.~a failure within 75 days

~

-of.the SDG being.restoreJ to OPERABLE status.

B. 'If a failure occurs during the first 7 ' tests in the req' qualification test. program, perform 7 successful demands-without Tan additional failure 'within 30 days of the SDG being- '

restored to OPERABLE status and 14 consecutive successful demands without a. failure within.~75 days of-the SDG being restored to

?' OPERABLE status. 1 C. If a failure occurs during the second 7 tests (tests 8 through 14).of A., above, perform 14 consecutive demands without an

. additional failure within 75 days of ';he failure.

D. If :a 'second failure _. occurs during the requalification test sprogram', be.in at'least SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

El D'u ring requalification testing, the SDG should not be tested.more frequentlyLthan at 24-hour intervals.

F. After a SDG Thas .been successfully requalified, subsequent repeated requalification tests will not be required fer that SDG under the.following conditions:

1. The number of failures in the last 20 valid demands is less than 5.

2. The number of failures in the last 100 valid demands is less than 11. !

3. In the event that following successful requalification of a SDG, the number.of failures is still in excess of the remedial action criteria (1. and/or 2. above) the following j exception will be allowed until the SDG is no longer in 1 violation of the remedid action criteria (1. and/or 2. l above).:

Requalification testing will not be required provided that after each valid demand the number of~ failures in the last

.20 and/or 100 valid demands has not increased. Once the SDG is no longer in violation of the remedial action criteria above, the provisions of those' criteria alone will prevail.

g Amendment No.

L' Page 3/4 8-12 g.. l AUG 2 41987 AUXILIARYELEgTRICPOWERSYSTEMS 3/4.8.1 A.C. POWER SOURCES SHUTOOWN l

LIMITING CONDITION FOR OPERATION ;, I

/. '

3.8.1.2 As a minimum, the following A.C. electrical power sources i shall be OPERABLE:

a. Either the Reserve Auxiliary Transformer (RAT) or the !

Unit Auylliary Transformer (UAT); and i

b. One Staredby Diesel Generator (SDG) with:

1. The diesel fuel oil day tank containing a minimum of 325 gallons of fuel,

2. A minimum of 20,000 gallons of. diesel fuel in underground s to rage , and an OPERAP,LE flow path (s) capabh of transferring fue'l oil from i

storage to the day tank,

3. An OPERABLE wa te'r-j a c ke t heater for each SDG diesel engina, and s

4. Lubricating oil' storage containing a minimum total volume of 100. gallons of lubricating oil.

APPLICABILITY: STARTUP*, SHUTDOWN *,andREFUELINTi l 1

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Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F.

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l Amendment No. '

page u4 8-u DRAFT t

t AUG 2 41987 J ACT?LN: With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations l involving CORE ALTERATIONS, control rod movement resulting '

in positive reactivity changes, or movement of IRRADIATED I FUEL. Initiate ccrrective actions to restore the required I sources to OPERABLE status as soon as possible.

X SURVEILLANCE REQUIREMENTS 4.8.1.2 No additional surveillance requirements are required other

.th an those surveillance identified per Surveillance Requirements 4.8.1.1.1 and 4.3.1.1.2.

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Amendment No.

Page 3/4 8-14 DRAFT BASIS FOR SPECIFICATION LCO 3.8.1 / SR 4.8.1 AUG 2 41987 The OPERABILITY of the A.C. electrical power sources during i POWER, LOW POWER, STARTUP and SHUTDOWN (whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F) ensures )

that sufficient power will be available, as required to 1 perform the intended safety functions under postulated abnormal and accident conditions. The minimum specified requirements for independent and redundant A.C. electrical 1 power sources are adequate to satisfy the basis of General (

Plant Design Criteria No. 24 and No. 39 as stated in Appendix C of the FSAR.

In the FSV HTGR, the limiting parameter of interest is the 1 core inlet temperature. The CALCULATED BULK CORE TEMPERATURE is a conservative calculation of the maximum potential temperature in the core and surrounding components. The conservatism are such that if the CALCULATED BULK CORE TEMPERATURE is limited to 760 degrees F, then the design inlet q temperature of 760 degrees F is not exceeded. Systems used for accident prevention and mitigation are required to satisfy the single failure criterion whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. However, when CALCULATED BULK CORE TEMPERATURE is equal to or less than 760 degrees F, it is acceptable to require only one OPERABLE system for accident prevention and mitigation without single failure consideration, on the basis of the limited core cooling requirements.

All forced circulation may be interrupted for maintenance purposes provided that the time calculated for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F is not exceeded.

However, if forced circulation is temporarily restored, a j recalculation shall be performed, based on present conditions, to establish a new time period for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F. Redundant systems may also be taken out of service for maintenance or surveillance testing provided that forced circulation is maintained. The time to reach CALCULATED BULK CORE TEMPERATURE equal to 760 degrees F may be recalculated as of ten as required, under this condition. j The means of providing A.C. electrical power to plant auxiliaries during normal operation is through the Unit Auxiliary Transformer (UAT) energized by the main turbine- '

generator. The UAT can also be energized by the off-site j sources, after the generator links have been removed to isolate the main turbine generator. The UAT is connected to the 4160 volt A.C. volt Buses 1 and 3, which are connected to the 480 VAC Buses 1 and 3, respectively.

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< Amendment No.# ,- 1 SQ h Page 3/4 8-15 D @ p. g l 3 4

., AUG 2 4 G87

,0ff-site A.C. electrical power during STARTUP, SHUTDOWN or loss'of the UAT is supplied through the Reserve Auxiliary Transformer (RAT), energized by any of .the five off-site

. . sources availabla. The RAT is connected to the 4160 volt A.C.

/, Bus /2, which : connects' to the 480 VAC Bus 2. Upon loss-of-

, power from the' UAT, power supply to the plant auxiliaries is 3

autontic' ally transferred to the RAT..

Onmite #k.C. electrical power is supplied 'by two S$andby Dies?1 G u erators (SDGs), either of ahich hei the- capability to power~ all electrical auxiliaries that are' essencial for

~

Safe Shutdown Cooling. Each SDG supplin _ 48G ; VAC essential a Bus 1 or Bus 3, with the first-in SDG also energizing 480 VAC

, massential Bus 2. 4 r

A diesel fuel supply of-16,150 gallons is s adequate to provide for operation of one SDGr for one week, under- required load conditions. This reserve capacity' provides ample time for obtaining additional fuel fr off-r.ite sources.

The ACTION requirements fot . Various allen ble levels of degradation of the electrical power sources provide restrictions upon continuea facility op'eration commensurate with the level of degradation. The OPERABILITY of the power sources is consistent with the initial conditions / assumptions

' ], of the FSAR, and is based upon maintaining at least one of the J redundant sets of on-site A.C. and D.C. electrical power sources and a.csociated distribution systems operable durirg accident conditions which postulate the loss of all off-site power, compounded by a single failure of the other redundant 4 on-sice sources.

( The term verify as used in the ACTION statements means to

/ "/ administratively check by examining logs cr other information to determine if certain components are out-of-service for maintenance or other reasons.

The surveilla9te requirements are adequate tc demonstrate the OPERABILITY,of the off-s?,te and on-site A.C. electrical power sources, such that their intended safety functions under postulate ('/ abnormal and accident conditions can be performed.

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o Amendment No.

Page 3/4 8- 16 . DRAFT AUG 2 41987

.'In particular, the surveillance requirements for the Standby Diesel Generators are consistent with the intent of Regulatory-Guide 1.108 " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants",

Revision 1, August 1977 and Generic Letter 84-15 " Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability".

The SDG fuel oil sampling requirements are sufficient to assess fuel oil quality at Fort St. Vrain. With over 10 years of diesel generator operational experience, there have been no fuel oil related failures of the SDGs or ACM diesel generator.

' Fuel oil is distributed between a Diesel Fuel Oil Storage tank for the SDGs and a shared tank arrangement, the Fuel Oil Storage tanks, with the Auxiliary Boiler. See Figure 3.8.1-1, Diesel Fuel Oil Systems for tank and related piping

. arrangements.

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Amendment-No.

Page 3/4 8-18 DRAFT AUXILIARY ELECTRIC POWER SYSTEMS AUG 2 41987-3/4.8.2 D.C. POWER SOURCES OPERATING o

l1 LIMITING CONDITION FOR OPERATION l

3.8.2.1 As a minimum, the following independent 125 . volt D.C.

electrical power sources shall be OPERABLE:

a. Battery no. lA and 1 dedicated battery charger,

b. Battery no. 18 and 1 dedicated battery charger, and

c. Battery no. 1C and 1 dedicated battery charger.

APPLICABILITY: POWER, LOW POWER, STARTUP,* and SHUTDOWN

ACTION:

a. With one of the required batteries inoperable, verify -

the associated D.C. load is energized with a dedicated battery charger within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . If the battery is inoperable due to any cause other than an equalizing charge being performed, restore the inoperable battery to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With one dedicated battery charger inoperable, demonstrate the OPERABILITY of the associated battery 3 per Surveillance Requirement 4.8.2.1.a.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If any Category A limit in Table 4.8.2-1 is not. met, declare the battery inoperable.

Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. l l

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Amendment No.

Page 3/4 8-19 DRAFT l

1 AUG 2 41997 SURVEILLANCE REQUIREMENTS 4.8.2.1 Each 125 volt D.C. battery and dedicated battery charger shall be demonstrated OPERABLE:

.a . At least once per 7 days by verifying that:

1. The Category A limits in Table 4.8.2-1 are met, and

2. The total battery terminal voltage is greater than or equal to 121.5 volts on float charge.

b. At least once per 92 days, and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge (when equalizing) with battery terminal voltage above 150 volts, by verifying that:

1. The Category B limits in Table 4.8.2-1 are met,

2. There is no visible corrosion at either terminals or connectors, or the connection resistance (with the exception of inter-rack connections) of these items do not exceed the average installation value by more than 20 percent, and

3. The average electrolyte temperature of at least 20 percent of the cells is above 60 degrees F.

c. At least once per 18 months by verifying that: [

1. The cells, cell plates, battery racks, and cell-to-cell and terminal connections show no visual indication of physical damage or abnormal deterioration,

2. The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material,

3. The resistance of each cell-to-cell and terminal connection (with the exception of inter-rack connections) does not exceed the average installation value by more than 20 percent, and

4. The battery charger will supply at least:

a) 325 amperes at 125 volts for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for battery chargers 1A and IB,

. -- ~ - ~

L endgtNo. .

AUG 2 41987 b) 200 amperes at 125 volts for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for battery charger IC, and c) 370 amperes at 125 volts for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for battery charger ID.

d. At least once 'per 18 months, during SHUTDOWN, by verifying that the . battery capacity is adequate to supply and maintain in an OPERABLE status all of the emergency loads for the design duty cycle when the battery is subjected to a service discharge test.

e. At least once per 60 months, during SHUTDOWN, by:

1. A performance discharge test on batteries IA and 18, separately, (at an average discharge rate of 340 amps) over a period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or until the average battery terminal voltage reaches 1.75 volts / cell; the test shall be acceptable if, af ter 3.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the battery is capable of producing at least 340 amps, and the average battery terminal voltage is greater than 1.75 volts /rell, or

2. A performance discharge test on battery IC (at an average discharge rate of 195 amps) over a period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or until the average battery terminal voltage reaches 1.75 volts / cell; the test shall be acceptable if, after 3.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the battery is capable of producing at least 195 amps and the average battery terminal voltage is greater than 1.75 volts / cell.

Once per 60 month interval, the performance discharge tests may be performed in lieu of the battery service tests in Surveillance Requirement 4.8.2.1.d.

f. At least once per 18 months, during SHUTDOWN, by a performance discharge tests of battery capacity on any battery that shows signs of abnormal degradation or has ,

reached 85"4 of the service life expected for the '

application. Abnormal degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

I i

Amendment No.

Page 3/4 8-21 l DRAFT TABLE 4.8.2-1 ggg4ggg7 BATTERY SURVEILLANCE REQUIREMENTS I ll 1 I I ll (1) l (2) l l ll CATEGORY A l CATEGORY B l l ll l l l 11 I I l ll Pilot Cell l Connected Cell (s) l l 11 l l l ll l l (3) l l Parameter l l Limits l Limits l Allowable value l I ll l l l l ll 1 l I I ll 1 I I

. [ Electrolyte llGreater than l Greater than lAbove top of l l Level llminimum level l minimum level l plates, and not l l l vindication mark, l indication mark, l overflowing. l l lJand less than land less than l l l llone quarter inch lone quarter inch l l l llabove maximum Iabove maximum l l l ll level indication llevel indication l l l ll mark. l mark. l l 1 ll l- 1 I l ll l 1 l l Float ll3 2.13 volts. 13 2.13 volts. It 2,07 volts. l IVoltage (4) ll l l l l- ll l l l l 11 l 1 l l Specific ll3 1.205 (6) 13 1.195 for lEach connected l l Gravity (5) ll Jeach connected l cell not more l l ll l cell. lthan .020 below l l ll l lthe average of I l ll l lall connected l l ll l l cells. l l ll l l l l ll l 1 l l ll l Average of all IAverage of all l l ll l connected cells Jconnected cells l l ll l> 1.205. l> 1.195. (6) l l ll l 1 l Refer to footnotes '( )' on following page.

Amendmen?, No.

., Page 3/4 8-22

DR' AFT Footnotes for Table 4.8.2-1:

AUS 2 41987x (1) Fori any Category: A parameter outside-'the limit shown, the battery may be considered OPERABLE provided that within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s-C :all the' Category B measurements are._taken and found to be within their allowable. values, and provided .all Category .A and B--

[ .. .

u[. parameters are restored to within. limits within the;next 6 days.

l ?

-(2)-lFor-any Category B:.. parameter' outside the limit shown, the E"

battery may be considered OPERABLE provided that the Category B parameters are ~within their ALLOWABLE VALUES and provided the Category B parameters -are restored to within ' limits within

.7 days.

(3) If . -any Category B parameter is not within its ALLOWABLE VALUE, declare the battery inoperable.

-(4) Corrected for average electrolyte temperature.

(5) ' Corrected for electrolyte temperature and level.

-(6) Or battery charging current is less tha'n 2 amps :when on charge.

_ _ _ _ ___ __...____.-______.s U

Amendment No- .

Page 3/4 8-23 DRAFT AUXILIARY ELECTRIC POWER SYSTEMS M24 E 3/4.8.2 D.C. POWER SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION i

3.8.2.2 As a minimum, two of the following independent 125 volt D.C. electrical power sources shall be OPERABLE: )

a. Battery no. 1A and I dedicated battery charger,

b. Battery no. 18 and 1 dedicated battery charger, and

c. Battery no. 1C and I dedicated battery charger.

APPLICABILITY: STARTUP*, SHUTDOWN *, and REFUELING ACTION:

a. With only one of the above batteries OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, control rod movement resulting in positive reactivity changes or movement of IRRADIATED FUEL. Initiate corrective action to restore the required batteries to OPERABLE status as soon as possible.

b. With only one dedicated battery charger OPERABLE, demonstrate the OPERABILITY of two batteiies by performing Surveillance Requirement 4.8.2.1.a.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months l thereafter. If any Category A limit in Table 4.8.2-1 is not met, declare the battery inoperable.

SURVEILLANCE REQUIREMENTS 4.8.2.2 .The required 125 volt D.C. electrical power sources shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.1

Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F.

l e_ - _ . _ _ _ _ _ . . _ _ .

' Amendment No.

Page 3/4 8-24 ];

r DRAFT BASIS FOR SPECIFICATION LCO 3.8.2 / SR 4.8.2 AUA 2 4 m7 The OPERABILITY 'of the D.C. electrical power sources during POWER, LOW POWER, STARTUP, and SHUTDOWN (whenever CALCULATED BULK CORE TEMPERATURE is greater than 760' degrees F) ensures

. that sufficient power will be available, as required to perform the intended safety functions undr postulated abnormal and accident conditions. Batteries 1A and IB are each adequate to supply the required safe shutdown D.C. loads f- for not less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , while battery IC supplies a D.C.

power source for one channel of the PPS loads, following the loss of all A.C.' power. The batteries provide the source of power, through the inverters and static transfer switches, to the A.C. . instrument power buses. The minimum specified requirements for independent and redundant D.C. electrical power sources are adequate to satisfy the basis of General

. Plant Design Criteria No. 24 and No. 39 as stated in- Appendix

. C of.the FSAR.

]

In the FSV HTGR, 'the limiting parameter of interest is the core inlet temperature. The CALCULATED BULK CORE TEMPERATURE is a conservative calculation of the maximum potential temperature.in the core and surrounding components. The conservatism -

are such that if the CALCULATED- BULK CORE TEMPERATURE 41s limited to 760 degrees,-then the design inlet

-temperature of 760 degrees F is not exceeded. Systems used for accident prevention and mitigation are required to satisfy the single failure criterion whenever CALCULATED BULK CORE

- TEMPERATURE is greater than 760 degrees F .. However, when CALCULATED BULK CORE TEMPERATURE is equal to or less than 760 degrees F, it is acceptable to require only one OPERABLE system for accident prevention and mitigation without single failure consideration, on the basis of the limited core cooling requirements.

All forced circulation may be interrupted for maintenance purposes provided that the time calculated for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F is not exceeded.

However, if forced circulation is temporarily restored, a recalculation shall be performed, based on present conditions, to establish a new time period for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F. Redundant systems may also be taken out of service for maintenance or surveillance testing provided that forced circulation.is maintained. The time to reach CALCULATED BULK CORE TEMPERATURE equal to 760 degrees F may be recalculated as often as required, under this conditio'n. l l

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Amendment No.

Page 3/4 8-25 DRAFT

~AUG 2 41987 The FSV D.C. . electrical power system consists of three batteries .and four battery :hargers. Two batteries, IA and 18, are connected to D.C. buses, 1A and 18, respectively, and the third battery, 1C, is connected directly to inverter / static transfer switch, IC. Three battery chargers, 1A, IB, and IC, energized from the 480 VAC essential buses, maintain F4tteries 1A, 1B, and IC, respectively, on float charge di' ing normal operation. The fourth battery charger,

10. is utilized to supply bus 1A, or bus 18 or inverter 1C, through bus ties, while maintaining independence between the other D.C. power sources and the D.C. loads. The use of either battery chargers, IA, 1B, or 1C or backup battery charger, ID to supply the associated D.C. load, constitutes a dedicated battery charger.

The ACTION requirements for various allowable levels of degradation of the electrical power sources provide restrictions upon continued facility operaticn commensurate with the level of degradation. The OPERABILITY of the power sources .is consistent with the initial conditions / assumptions of the FSAR, and are based upon maintaining at least one of the redundant sets of on-site A.C. and D.C. electrical power sources and associated distribution systems operable during accident conditions which postulate the loss of all off-site power, compounded by a single failure of the other redundant on-site sources.

The Surveillance Requirement for demonstrating the OPERABILITY of the IA,1B and 1C batteries is based on the recommendations of Regulatory Guide 1.129, " Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Lars i.ead Storage Batteries for Generating Stations and Substatkas."

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage on float charge, connection resistance values, and the performance of battery service discharge and performance

, discharge tests ensures the effectiveness of the charging system, the ability of the battery to handle high discharge rates, and the adequacy of the battery capacity with respect to the rated capacity and emergency load requirements.

l I

Amendment No.

Page 3/4 8- 26 DRAFT AUG 2 41987 Table 4.8-2 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage, and specific gravity. The limits for the iesignated' pilot celle float voltage and specific gravity, greater than or equal to 2.13 volts and 0.010 below the manufacturer's full charge specific gri <ity is characteristic of a charged cell with adequate capacity.. The normal limits for each connected cell for float voltage and specific gravity, greater than or equal to 2.13 volts and not more than 0.020 below the full charge specific gravity of 1.215 with an average specific gravity of all the connected cells not more than 0.010 below the full charge specific gravity of 1.215, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days. During this 7-day period: (1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than 0.020 below the recommended full charge specific gravity, ensurea that the decreases in rating will be less than the safety margin provideC in sizing; (3) the allowable value for an individual cell's specific gravity, not more than 0.040 bulow the full charge specific gravity, ensures that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability to perform its design function.

i

Amendment No.

Page 3/4.8-27' DRAFT 1 AUG 2 41997 AUXILIARY ELECTRIC POWER SYSTEMS 3/4.8.3 DN-SITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION 3.8.3.1 The following electrical buses shall be energized in the specified manner with tie breakers open between redundant buses

a. 480 volt A.C. essential bus 1 energized from the 4160 volt A.C. bus 1,#

b. 480 voit A.C. essential bus 2 energized from the 4160 volt A.C. bus 2,#

c. 480 voit A.C. essential bus 3 energized from the 4160 volt A.C. bus 3,#

d. 120 volt A.C. non-interruptible bus 1A/1A-1 energized through their respective inverter / static transfer switch from the preferred power source, D.C. bus 1A,

e. 120 volt A.C. non-interruptible bus 18/18-1 energized through their respective inverter / static transfer-switch from the preferred power source, D.C.- bus 18,

f. 120 volt A.C. non-interruptible bus 1C/1C-1 energized through their respective inverter / static transfer switch from the preferred power source battery / battery charger No. IC,

g. 125 volt D.C. bus 1A energized from associated battery / battery charger No.1A, and

h. 125 volt D.C. bus 1B energized from associated battery / battery charger No.18.

APPLICABILITY: POWER, LOW POWER, STARTUP*, and SHUTDOWN *

Whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F.

The requirement for the tie breakers to be open between redundant buses is not applicable with respect to the 4160 volt buses.

Amendment No'.

Page. 3/4 8- 28 DRAFT AUS 2 4 gr/

-ACTION:

a. With one of the required 480 volt A.C. buses not energized in the required manner, reenergizs the bus in the required ,

manner within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in.at least SHUTDOWN within i the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

)

'b. With cne A.C. non-interruptible bus'not energized in the i required manner from its preferred source *: 1

1. 'Reenergize the. A.C. non-interruptible bus from the 480 VAC essential bus backup source- via the inverter / static transfer switch within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

2. Reenergize the A.C. non-interruptible bus through the inverter / static transfer switch .from its preferred source within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 'or be in at least SHUTDOWN ;

within the next.24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . I

c. With- one O.C. ' bus .not energized in the required manner from its associated battery / battery charger, reenergize the D.C. bus from its associated battery / battery charger within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " or be in at least SHUTOOWN within- the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . . -

SURVEILLANCE REQUIREMENTS 4.8.3.1 The specified buses shall be determined energized in the 1

-required manner at least once per 7 days by verifying ,

correct breaker alignment and indicated voltage on the 1 buses, j

- A battery / battery charger can be disconnected from the distribution system for up to 5 days, if an equalizing charge is being performed.

)

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.- 1

Amendment No.

Page 3/4 8-29 DR/sF~r'

'7 .

AUG 2 4 27 AUXILIARY ELECTRIC POWER SYSTEMS 3/4.8.3 ON-SITE POWER DISTRIBUTION l

SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.3.2 As a minimum, the following electrical buses shall be energized in the specified manner with tie breakers open between redundant buses:

a. Two 480 volt A.C. essential buses energized from the associated 4160 volt A.C. buses,#

b. Two 120 volt A.C. non-interruptible buses energized through their respective inverter / static transfer switch from their preferred power sources, and

c. One 125 volt 0.C. bus energized from its associated battery / battery charger.

APPLICABILITY: STARTUP*, SHUTDOWN *, and REFUELING ACTION: With any of the above minimum required electrical buses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, control rod movements resulting in positive reactivity changes, or movement of IRRADIATED FUEL and initiate corrective action to reenergize the required bus as soon as possible.

SURVEILLANCE REQUIREMENTS 4.8.3.2 The specified buses shall be determined energized in the required manner at least once per 7 days by verifying correct breaker alignment and indicated voltage on the buses.

Whenever CALCULATED BULK CORE TEMPERATURE is less than or equal to 760 degrees F.

# The requirement for the tie breakers open between redundant buses is I not applicable with respect to the 4160 volt buses.

i 1

1 J

Amendment No.

Page 3/4 8- 30 DRAFT AUG 2 41987 BASIS FOR SPECIFICATION LCO 3.8.3 / SR 4.8.3 The OPERABILITY and surveillance requirements of the on-site distribution systems ensures adequate power will be available to supply essential equipment required for the safe shutdown of the facility and to mitigate and control postulated accident conditions. The BASIS for Specifications 3.8.1 and 3.8.2 contains additional information.

In the FSV HTGR, the limiting parameter of interest is a core inlet temperature greater than 760 degrees F. The CALCULATED BULK CORE TEMPERATURE is a conservative calculation of the maximum potential temperature in the core and surrounding components. The conservatism are such that if the CALCULATED BULK CORE TEMPERATURE is limited to 760

' degrees F, the design inlet temperature of 760 degrees F is not exceeded. Systems, used for accident prevention and mitigation are required to satisfy the single failure criterion whenever CALCULATED BULK CORE TEMPERATURE is greater than 760 degrees F. However, when CALCULATED BULK CORE TEMPERATURE is equal to or less than 760 degrees F, it is acceptable to require only one OPERABLE system for accident prevention e- mitigation without single failure consideration, on ue basis of the limited core cooling requirements.

All forced circulation may be interrupted for maintenance purposes previded that the time calculated for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F is not exceeded. Huever, if forced circulation is temporarily restored, a recalculation shall be performed, based on present conditions, to establish a new time period for CALCULATED BULK CORE TEMPERATURE to reach 760 degrees F.

Redundant systems may also be taken out of service for maintenance or surveillance testing provided that forced circulation is maintained; and the time to reach CALCULATED BULK CORE TEMPERATURE equal to 760 degrees F may be recalculated as often as required, under this condition.

In Action 3.8.3.1.b.2, battery / battery charger 1C and in Action 3.8.3.1.c, battery / battery charger 1A or 18 can be inoperable for 5 days if an equalizing charge is being performed. An equalizing charge per the manufacturer requires a nominal 3 to 5 days for completion. At FSV a battery / battery charger is disconnected from the distribution system when an equalizing charge is being performed to preclude damage to the D.C. loads. Due to the fact a battery / battery charger can readily be placed back in service by reconnecting it to the system, this configuration is not considered a significant degradation of the D.C.

power sources or the on-site distribution system.

(:

ATTACHMENT 7 TO P-87272 f

l 1

3

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_______.___._____m m_________- _ - - _ _ _

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f

. ATTACHMENT 7 >

l '

References NRC. letter, " Summary of December 18,- 1986 meeting on Draft

. 1. .' Technical Specifications Section,3/4.8 and Request for Additional Information," Heitner to Williams, February 18,1987,'(G-87056).

. 2. NRC. letter, " Draft Updated Technical ' Specification, Section

'3/4 8. , Request' for ' Additional Information",. Heitner to Williams,.

!, . May'6,'1987,(G-87161). .

' 3. " Final Draft Upgrade Technical Specifications" for.the. Fort St.

VrainL Nuclear. Generating Station,. dated' November .30, 1985, Section 3/4.8.

4. Standard' Technical Specifications for Westinghouse Pressurized i Water Reactors, NUREG-0452, Revision 5 draft.

5. Fort .St. Vrain No. 1 Technical Specifications, Amendment No. 54 dated.May 20, 1987, Sections 4.6, 5.6.

6. " Revised . Draft . Upgraded Technical Specifications", for the Fort L St. Vrain Nuclear Generating Station, dated.. August 24, 1987, Section 3/4.8 (Attachment 6). -

7. 'PSC letter, " Proposed Technical Specification Changes - Fort St.

Vrain Electrical System Requirements," Lee to Collins, ' December 30,1983,-(P-83415).

- 8. 'NRC:. letter, . " Request for Additional Information for Technical Specification Upgrade Program for Fort St. Vrain Nuclear Generating Station," Heitner to Williams, dated July 2, 1987, (G-87217).

L

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ML20237L485

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