Text

Proposed Tech Specs Replacing 72 H AOT of TS 3.8.1.1,Action b,w/7 Day AOT Requirement for Inoperability of One EDG or One Train of EDGs
	ML20238F300
Person / Time
Site:	Sequoyah
Issue date:	08/27/1998
From:	; TENNESSEE VALLEY AUTHORITY
To:	;
Shared Package
ML20238F299	List: ML20238F298; ML20238F300;
References
	NUDOCS 9809030257
	Download: ML20238F300 (97)
	v • d • e

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ENCLOSURE 2

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TENNESSEE VALLEY AUTHORITY SEQUOYAH PLANT (SQN) i UNITS 1 and 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-96-08, REVISION 1 MARKED PAGES 1

l I. -AFFECTED PAGE LIST Unit l-Operating License Page 6 3/4 8-1 ;

3/4 8-6 3/4 8-8 B 3/4 0-2 B 3/4 8-1 B 3/4 8-la 6-13a .

6-14 -

Unit 2

' Operating License Page 5 3/4 8-1 3/4 8-7 3/4 8-9 B 3/4 0-2 B 3/4 8-1 B 3/4 8-la 6-14 6-15 i l

II , . MARKED PAGES i See attached.

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I 9809030257 980827 PDR ADOCK 05000327 P PDR l

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(c)- By no later than June 30,1982, all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of: Division of Operating Reactors " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactos" (DOR Guidelines); or, NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," December 1979.

, Copies of these documents are attached to the Order for Modification of Licence DPR-77 dated November 6,1980.

(13) Loss of Non-Class IE Instrumentation and Control Room System Bus Durina Ooeration (Section 7.10)

Prior to exceeding five percent power, TVA must complete revisions to plant emergency procedures to the satisfaction of the NRC.

(14) Enaineerina Safety Feature (ESF) Reset Controls (Section 7.11)

In conformance with IE Bulletin 80-06, TVA shall test the system to identify any further areas of concern, and TVA shall review the control schemes to determine that they are the best in terms of equipment control and plant safety. The results of these test and review efforts shall be provided to the NRC in ac r nc with the bulletin.

- (15)

? b?W,Y, r Y?n O

Prior to operation following the gh Tb a implement the following d

design and procedure mo s outlined in Section 8.3.1 of SER Supplem . ese include: (a) Moisture in Air Starting System; (b)

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(16) Fire Protection TVA shallimplement and maintain in affect all provisions of the approved fire l protection program referenced in Sequoyah Nuclear Plant's Final Safety Analysis l Report and as approved in NRC Safety Evaluation Reports contained in l NUREG-0011, Supplements 1, 2, and 5, NUREG-1232, Volume 2, NRC letters l dated May 29 and October 6,1986, and the Safety Evaluation issued on l R231 August 12,1997, for License Amendment No. 227, subject to the following l provision: l l

TVA may make changes to the approved fire protection program without l prior approval of the Commission only if those changes would not l adversely affect the ability to achieve and maintain safe shutdown in the l event of a fire. l l

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August 12,1997 Amendment 9,227 L - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

1 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES l OPERATING l LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE: ,

a. Two physically independent circuits between the offsite transmission l network and the onsite Class IE distribution system, and

b. Four separai: s.nd independent diesel generator sets each with:

1. Two diesels driving a common generator l

2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per ttnk

3. A separate fuel storage system containing a minimum volume of 62,000 gallons of fuel,

4. A separate fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel,125-volt D.C.

battery 6ank and associated charger.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite A.C. circuit of the above required A.C. electrical -

power sources inoperable, demonstrate the OPERABILITY of the remain- R209 ing offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour 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 two offsite circuits 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 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.# With diesel generator set (s) 1A-A and/or 2A-A or IB-B and/or 28-B of h209 the above required A.C. electrical power sources inoperable, demon-strate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and determining OPERABLE diesel genera- R209 tor sets are not inoperable due to common cause failure or performing

, Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; re least four diesel generator sets to OPERABLE status withi -7. h;ur:#

or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD Jai 41 SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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fhe 72-hour ;; tion statement ::y b; cxtended for an ;dditional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for en: tr in of dit:cl gener:ter: (either IA A :nd 2A A, er IB B :nd 2B B) during R141 l

-the erfor 0 cf Surve!' lance Requircrant d.8.1.1.2.f ? _ A temporary fuel l

t be cer.erted to the diece! generator cet that in Saving the bupp5yme:

ciat1 -fuel d man

tank: cicane4- --%-

Required actions, to verny DPERABLE diesel generator sets are not inoperable R209 due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.

l SEQUOYAH - UNIT 1 3/4 8-1 Amendment N b5, , 137, 205 I

L_________________

. ELECTRICAL POWER SYSTEMS

!- SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator 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 to 2.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and R177 between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be a 6800 volts and a 58.8 Hz within 10 seconds after the start signal. After R238 energization, the steady state generator voltage and frquency shall be maintained a 6800 volts and s 7260 volts and a 58.8 Hz and s 61.2 Hz during this test.

4. -Within 5 minutes of shutting down the diesel generator after it

! has operated a 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded between 3960 kw and 4400 kw and i between 2140 kvar and 2370 kvar, verify that the diesel. R238 generator starts within 10 seconds after receipt of the start signal-and operates for greater than or equal to 5 minutes.

After energization, the steady state voltage and frequency shall be maintained a 6800 volts and s 7260 volts and a 58.8 Hz and s 61.2 Hz'during this test.

4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and l associated charger fer each diesel generator shall be demonstrated OPERABLE:

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

1. That the parameters in Table 4.8-la meet the Category A limits.

2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge.

b. At least once per 92 days by:

l 1. Verifying that the parameters in Table 4.8-la meet the Category B limits, i l

2. Verifying there is no visible corrosion at either terminals or i connectors, or the cell to terminal connection resistance of '

! these items is less than 150 x 10 6 ohms, and l

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3. Verifying that the average electrolyte temperature of 6 ;

l connected cells is above 60*F. lR217

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

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

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

3. The resistance of each cell to terminal connection is less than crual toy 0 ' oh h b SHRfC/[Lyff;$Y n;;;:t; "

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4.8.1.1.4 .__ : ;:n:::t:r _ _lur: , ? lid r -^- lid, c'" 1 g RS6 5: ::;::t:d t; th: t ci::i:n pu nt t: rifi::t_:n C.

SEQUOYAH'- UNIT 1 3/4 8-6 Amendment Nos. 52, 137,. 173, 213, 234 L__________________ _ _ _ _ _ _ _ _

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[ ELECTRICAL POWER SYSTEMS f

SHUTDOWN LIMITING CONDITION FOR OPERATION l

3.8.1.2 As a minimum, the following A.C. electrical power sources shall be j OPERABLE: 1

a. One circuit between the offsite transmission network and the onsite

! Class 1E distribution system, and

b. Diesel generator sets 1A-A and 2A-A or 18-B and 2B-B each with:

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1. Two diesels driving a common generator,

2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, ,

3. A fuel storage system containing a minimum volume of 62,000 gallonsrof fuel,

4. A fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger.

APPLICABILITY: MODES 5 and 6.

. ACTION:

' With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS ,

l 4.8.1.2. The above required A.C. electrical power sourc j strated OPERABLE by the performance of each of the Surveillance Requirements !

4 p of xd 4.8.1.1.1

'.0.1 ' ' and 4.8.1.1.2 (except for requirement 4.8.1.1.2.a.5),b .8.1.1.3

4No f ,

l 1-SEQUOYAH - UNIT 1 3/4 8-8 i

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APPLICABILITY-BASES 3.0.5 This specification delineates what additional conditions must be satisfied to permit operation to continue, consistent with the ACTION statements for power sources, when a normal or emergency power source is not OPERABLE.

It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable and a system, subsystem, train, component or device in another division is inoperable for another reason.

The provisions of this specification permit the ACTION statements associated with individual systems, subsystems, trains, components, or devices to be consistent with the ACTION statements of the associateri electrical power

'_. source. It allows operation to be governed by the time limits:of the ACTION statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individual ACTION statements for each system,-subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source, j

For example, Specification 3.8.1.1 requires in part that fouramergency diesel generators be OPERABLE. The ACTION statement royides for a_ U.=r out-of-service time when one emergency diesel generator is not OPERABLCIf the definition of OPERABLE were applied without consideration of Specification 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source would also be inoperable. This would dictate invoking FP the applicable ACTION statements for each of the applicable Limiting Conditions for Operation. However, the provisions of Specification 3.0.5 permit the time limits for continued operation to be consistent with the ACTION statement for

,the inoperable emergency' diesel generator instead, provided the other specified

. conditions are satisfied. In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems, subsystems, trains, components, and devices must be OPERABLE, or otherwise satisfy Specification 3.0.5 (i.e. , be capable of performing their design function and have at least one normal or one emergency power source OPERABLE). If they are not satisfied, action is required in accordance with this specification.

As a further example, Specification 3.8.1.1 requires in part that two physcially independent circuits between the offsite transmission network and the onsite Class IE distribution system be OPERABLE. The ACTION satement provides a 24-hour out-of-service time when both required offsite circuits are not OPERABLE. If the definition of OPERABLE were applied without consideration of Specification 3.0.5, all systems, subsystems, trains, components and devices supplied by-the inoperable normal power sources, both of the offsite circuits, would also be inoperable. This would dictate invoking the applicable ACTION statements for each of the applicable LCOs. However, the' provisions of Specification 3.0.5 permit the time limit for continued operation to be consistent with the ACTION statement for th inoperable normal power sources SEQUOYAH - UNIT 1 8 3/4 0-2 SEP 171980 l

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3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distri-bution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensur-ate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C.

power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source.

R209 The footnote for Aj: tion b of LC0 3.8.1.1 requires completion of a determination that the OPERABLE diesel generators are not inoperable due to common cause failure or performance of Surveillance 4.8.1.1.R.a.4 if Action b is. entered. The intent is that all diesel generator inoperabilities must be l investigated for common cause failures regardless of how long the diesel generMr inoperability persists. l The action to determine that the OPERABLE diesel generators are not I inoperable due to common cause failure provides an allowance to avoid unnecessary testing of OPERABLE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE I l diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel generator (s), ,

the other diesel generator (s) would be declared inoperable upon discovery and 1 Action e of LC0 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the causa of the initial inoperable diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that

! the OPERABLE diesel generators are not affected by the same problem as the i

inoperable diesel generator.

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Sdditi0n:1 SCTIOM requircrrnts :re speci#ied f0r perfer'"ance of the R1 1 ch::ic:1 cle:ning required by Surveillance Require::nt '.8.1.1.2.#.1. The reter driven fuel purp: fer the dic:01 gencr:ter ::t with the t:nk; being

1::::d will be torper rily connected to the underground :ter:g t:nk: fer the other dia:21 g ncr:ter ::t with the :::: train de:ign: tion. in addition:1 f;;l 011 invent ry of :pprcxie:tely 58,000 g:llen: wi'l bc vail:ble " One of

.~ ~ M June 29, 1995 SEQUOYAH - UNIT 1 B 3/4 8-1 Amendment No. 12, 137, 173, 205

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3/4.8 ELECTRICAL POWER SYSTEMS i

BASES 1

1 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS I

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R141 NNb:bhbbubbbbbbahbbbnb Eithib "rbbbiba5 ldbitb, b5E bhbbic 5 $1b$n5Ng cf an f underground eterage te"A will be performed during a refueling er other l

- ech:duled cutzg: for th: :::::inted unit.

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The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) s the facility can be maintained in the shutdown or refueling condition for j extended time periods and 2) sufficient instrumentation and control capability )

is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9 " Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10, 1971, and 1.108 " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants,"

Revision 1, August 1977, and 1.137 " Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979. The surveillance requirements for the diesel-generator load-run test and the 24-hour endurance and margin test are in accordance with Regulatory Guide 1.9, Revision 3, July 1993, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as R177 Class 1E Onsite Electric Power Systems at Nuclear Power Plants." During the diesel generator endurance and margin surveillance test, momentary transients outside the kw and kvar load ranges to not invalidate the test results.

Similarly, during the diesl generator load-run test, monentary transients outside the kw load range do not invalidate the test results.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. 6800 volts is the minimum steady state output voltage and the 10 second transient value. 6800 volts is 98.6% of nominal bus voltage of 6900 volts and is based on the minimum voltage required for the diesel generator supply breaker to close on the 6.9 kV shutdown board. The R238 specified maximum steady state output voltage of 7260 volts is based on the degraded over voltage relay setpoint and is equivalent to 110% of the nameplate rating of the 6600 volt motors. The specified minimum and maximum frequencies of the diesel generator are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations given in regulatory Guide 1.9.

The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are based on the recommendations of Regulatory Guide 1.129 I

" 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 Large Lead Storage Batteries for Generating Stations and Substations."

l July 22, 1998 SEQUOYAH - UNIT 1 B 3/4 B-la Amendment No. 12, 137, 173 lR209 205, 234 I

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l ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (contiztued)

-6. WCAP-10054-P-A, Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code, August 1985, (W Proprietary)

(Methodology for Specification 3/4.2.2 - Heat Flux Hot Channel Factor) ;

7, WCdP-10266-P-A, Rev. 2, "THE 1981 REVISION OF WESTINGHOUSE EVALUATION R227 l MODEL USING BASH CODE", March 1987, (W Proprietary) .

'(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor).

6.9.1.14.b The core operating limits shall be determined so that all I applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.14.c THE CORE OPERATING LIMITS REPORT shall be provided within 30 days

! after cycle start-up (Mode 2) for each reload cycle or within 30 days of R159

' issuance of any.midcycle revision of the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

SPECIAL REPORTS 6.9.2.1 Special reports shall be submitted within the time period specified R76 for ea h r ccor ance with t o e-i +6.9.2.'2 7A:ue_

O_

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SC_'rn:r r - - - - - -A_M__tv#_rwe en:nt r v- Pr:rrer -

A$a'minimumtheReliabilityImprovementProgramreportforNRCaudit, re ed by LCO 3.8.1.1, Table 4.8-1, shall. include

, (a)- a summary of all tests (valid and invalid) that _-urred in the time l f periodoverwhichthelast20/100validtestqe '

ev rmed R5 l l (b) analysis of failures and determination auses of failures )

(c) '

evaluation of each of the recomme t s of NUREG/CR-0660, " Enhancement

! of Onsite Emergency Diesel Genera Reliability in Operating Reactors," j with respect to their applica to the Plant I (d) identification of all ions taken or to be taken to 1) correct the root causes of failures fined in b) above and 2) achieve a general ;

improvement of esel generator reliability !

i (e) the se ule for implementation of each action from d) above (f) n assessment of the existing reliability of electric power to engineered- ,

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April 21, 1997 SEQUOYAH - UNIT 1 6-13a Amendment No. 52, 58, 72, 74,

117, 155, 223

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ADMINISTRATIVE CONTROLS i

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-Dierel cenerator n eliability Improvement arecram (centinued) j A supplemental report shall be prepared within 30 days after each s quent failure during a valid demand for so long as the affected die enerator unit continues to violate the criteria (3/20 or 6/100) for t iability ;

improvement program remedial action. T suppleme

report need only update l the failure / demand history for th d ' se generator unit since the !

last report for that diesel gen r. ~. supplemental report shall also j present an analysis of th. with a root cause determination, if possible, and shall deline ly further procedural, hardware or operational changes to be incorpo into the diesel generator improvement program and the schedule for ementation of those changes.

In a on to the above, submit a yearly data report on the diesel generator RS6

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6.10 RECORD RETENTION (DELETED) R237 1

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July 1, 1998 SEQUOYAH - UNIT 1 6-14 Amendment No. 42, 52, 58, 74, 117, 148, 163, 174, 178, 233 l

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b. Complete and auditable records must be available and' maintained at a central location which describe the environmental qualifi-i cation method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DDR Guidelines or NUREG-0588. Such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified to document complete N compliance by June 30, 1982.

c. Within 90 days of receipt of the equipment qualification safety evaluation, the licensee shall either (1) provide missing doc-umentation identified in Sections 3 and 4 of the equipment qualification safety evaluation which will demonstrate compli-ance of the applicable equipment with NUREG-0588, or (ii) commit to corrective actions which will result in documentation of compliance of applicable equipment with NUREG-0588 no la4r than June 30, 1982. -

(11) Requirements For Modification To Or Addition Of Instrumentation R2 l Ant Controls (5ection 7.3.2)

a. Prior to startup after first refueling, TVA shall have installed instrument downscale failure alarms for the effluent monitoring

,- instrumentation channels for radioactive gaseous and radioactive .

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liquid effluents. Modifications to procedures and Technical Specifications 3.3.3.9 and 3.3.3.10 shall have been completed.

'.b Prior to startup after the first refueling, TVA shall have )

received NRC approval of an additional operable level of over/

l undervoltage protection including associated Technical Specifi-cations. The level of protection from the effects of power transients on safety-related equipment provided by Part I of

'the staff's " Degraded Grid Voltage Position", or equivalent, re ui .

M SPEt.t F1C.ATioM N% BETH DOETO (12) 0i...! 0:::r:t:r ":lictility (E:: tic: S.3.1) l Prior to operation following the , A shall implement the following design and pro ications as outlined in Section 8.3.1 of ement No. 2. These include: (a) Moisture y ystem; (b) Turbocharger Gear Drive Problem; and j

iw,ny e.

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Amendment 2

. 9/15/81

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! 3/4.8 ELECTRICAL POWER SYSTEMS I

j 3/4.8.1 A.C. SOURCFJi

, OPERATING j LIMITING CONDITION FOR OPERATION l 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be l OPERABLE:

a. Two physically independent' circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Four separate and independent diesel generator sets each with:

1. Two diesels driving a common generator j 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank

3. A separate fuel storage system containing a minimum volume of 62,000 gallons of fuel,

4. A separate fuel transfer pump, and ,

5. A separate 125-volt D.C. distribution panel,125-volt D.C. *

battery bank and associated charger, y APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

R195

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remain-ing offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour 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 two offsite circuits 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 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within th? following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

7 R195 ,

I b.# With diesel generator set (s) 1A-A and/or 2A-A or 18-B and/or 2B-B of l

\ the above required A.C. electrical power sources inoperable, l

( .

demonstrate the 0PERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and R195 at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; restore at least four diesel generator sets to OPERABLE status within 1 Days R : vu 7 or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and R123 in COLD SHUTDOWN within the following 30 h

_,,c_ ~__c_' Z a _a _ L _ , _

' "' E '!" " '_ ," M ' "", "" ? !"'? " ' '""L 7 ? " ^ ' 7 '!""" 2 " ' , "" . """ ' ' ' ;" " ' 2 " X " M Z ' u _ )

R. . .'r__' . .' ." .' "o." ' "o ' ." !v !. ' ., " ". ". T *.

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m? _ l' ' " ". '. m_

nmyu m^."m o ",...7" , " ' l'm , ' "e.7 ",. "".y_r ! ".- .". .!. 7. " ' ,.' "/

pply must be connected ts the diesel generetor 3et that is " "

having the f R195 k :;;; l;ted N 7 ::r.k; cle r W -

} FRequired actions, to verify 0PERABLE diesel generator sets are not inoperable l due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if 1 this action is entered. June 29, 1995 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, l 195 l

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

( "'. '

Tass Survgott.nNeg Hns Aetw Dez.e~nro

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4.B.1.1.4 - % ;rt: - ^1' di ::1 ;;r.;r:t:r f:i hr::,

t; r;prt;d t tr.; Ce.;...issier. porseert te ';poe;f-;uot.wii;;!!d :r n:r v: lid, ;h:11 6.3.2.2.

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l SEQUOYAH - UNIT 2 h 3/4 8-7 Men'((e57t $'o."4Y

_ _ _ _ - - - - - - _ - - _ - - _ _ - - - - _ - - - - - - - - - _ _ . --- a

i M. '

(w ELECTRICAL POWER SYSTEMS l

SHUTDOWN' LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be

OPERABLE

l

a. One circuit between the offsita transmission network and the onsite j Class 1E distribution system, and i

)

b. Diesel generator sets 1A-A and 2A-A or 18-8 and 28-8 each with:

1. Two diesels driving a common generator,

2. Two engine-mounted fuel tanks containing a minimum volume of

. 250 gallons of fuel per tank,

3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel,

4. A fuel transfer pump, and lf i 5. A separate 125-volt D.C. distribution panel, 125-volt 0.C. f battery bank and associated charger. t l

APPLICABILITY: MODES 5 and 6.

ACTION:

I- With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes. .

l SURVEILLANCEREQUIREMEETS y v v

4. 8.1. 2 The above required A.C. electrical power sources shall be demon-strated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1,and 4.8.1.1.2 (except for requirement 4.8.1.1.2.a.5), 4.8.1.1.3p

. . . . , . . . . . . . ' A MD i

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SEQUOYAH - UNIT 2 3/4 8-9 l

C _________._____________ __ ____ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ __ _

APPLICABILITY e-'

)

BASES 3.0.5 This specification delineates what additional conditions must be satisfied to permit operation to continue, consistent with the ACTION state-ments for power sources, when a normal or emergency power source is not OPERABLE.

It specifically prohibits operation when one division is inoperable because its nomal or emergency power source ~is inoperable and a system, subsystem, i

train, component or device in another division is inoperable for another reason.

The provisions of this specification permit the ACTION-statements associated i

with individual systems, subsystems, trains, components,-or devices to be i

. consistent with the ACTION statements of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for D M ration for the normal or emergency power source, not the individual ACTION statements for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source. !

Fr- =9 W~~ l For example, Specification 3.8.1.1 requires in part that four , emergency diesel '

generators be OPERABLE. The ACTION statement provides or. aM tr out of- T service time when one emergency diesel generator is not OPERABLNhe definition of OPERA 8LE were applied without consideration of Specification 3.0.5,

')

all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source would also be inoperable. .This would dictate invoking

- the applicable ACTION statements for each of the applicable Limiting Conditions j for Operation. However, the provisions of Specification 3.0.5 permit the time !

limits for continued operation to be consistent with the ACTION statement for- l the inoperable emergency diesel generator instead, provided the other specified l conditions are satisfied. . In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems, subsystems,

-i. rains, components,1nd devices must be OPERABLE, or otherwise satisfy Specifica; tion 3.0.5 (i.e., be capable:of performing their design function and have at ;

least one normal or one emergency power source OPERABLE). If they are not ;

satisfied, action is required in accordance with this specification.

As a further example. Specification 3.8.1.1 requires in part that two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system be OPERABLE. The ACTION statement provides a l 24-hour out-of-service time when both required offsite circuits are not OPERABLE.

If the definition of OPERABLE were applied without consideration of Specifica-tion 3.0.5, all systems, subsystems, trains, components and devices supplied ,

by the inoperable normal power sources, both of the offsite circuits, would i also be inoperable. This would dictate invoking the applicable ACTION statements L for each of the applicable LCOs. However, the provisions of Specification 3.0.5 I

permit the time limit for continued operation to be consistent with the ACTION -

statement for the inoperable normal power sources instead, provided the other {

r SEQUOYAH - UNIT 2 8 3/4 0-2 L

i 3/4.8 ELECTRICAL POWER SYSTEMS BASES _ ,

3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distri-bution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the l

facility and 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design i

Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the l power sources provide restriction upon continued facility operation connensur-ate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C.

l power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure

! of the other onsite A.C. source. R195 1

The footnote for Action b of LCO 3.8.1.1 requires completion of a e deternhation that the OPERABLE diesel generators are not inoperable due to l common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be investigated for common cause failures regardless of how long the diesel generater inoperability persists.

The action to determine that the OPERABLE diesel generators are not inoperable due to common cause failure provides an allowance to avoid -

unnecessary testing of OPERABLE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performeB. If~the causT of inoperability exists on other diesel generator (s)',

the other diesel generator (s) would be declared inoperable upon discovery and l Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE diesel generators are not affected by the same problem as the inoperable diesel generator. ,

s - -

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.dditin:1 "IT!" =;;ir: ::t: := :;=ift:d fr ;:rf: = =:: ef the R123 i cini=1 :1=:teg =;;t=d by 5:=:111== haci==:t t.S.I.1.2.f.1. Th; st= dri;= f=' ; : f:r th: di=:1 ;=:=t:r =t with th: t=h: b:in;

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d:=d M11 it tn :=rily :=:=ted t: the =d: ;rmd :t=; t=h: fr th:

Othr din:1 ;=:=tr =t with th: =- t=f: d=i;=ti=. M Mditi:=1 f=1 il in;=try :f :;;=:i=t:ly 50,000 ;:11 = will 5: = i hble 1: = Of th: grd :t;=;: t=h: prir t: th: :trt f th: ch=ic:1 ch=ing of =yj:

^ # ^ - M , 1995 SEQUOYAH - UNIT 2 B 3/4 8-1 Amendment No. 123, 164, 195

-3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 AND 3/4.8.2 A.C. SOURCES AND ON, SITE POWER DISTRIBUTION SYSTEMS xm < w v - v - -

und;;;;;^r-f cirr ; t:nh "it'! prn:ti 21 limit:, th ch:mir:1 :12:ning :f :n

f

rg: und :t:::;: t-' ::111 he perf:r :f during : ::fu: ling :: :th: R123

h:ful f ::::;; ft th: ::: v The OPERABILITY of the. minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown-and refueling ensures that

1) the facility can be maintained ~in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the j diesel generators are in accordance with the recommendations of Regulatory Guides 1.9 " Selection of Diesel Generator Set Capacity for Standby Power Supplies", March 10, 1971, 1.108 " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977, and 1.137 " Fuel-Oil Systems for Standby Diesel Generators," ,

Revision 1, October 1979. The surveillance requirements for the diesel generator load-run test and the 24-hour endurance and margin test are in accordance with Regulatory Guide 1.9,-Revision 3, July 1993, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power. Systems at Nuclear Power Plant." During the R164 diesel generator endurance and margin surveillance test, momentary transients outside the kw and kvar load ranges do not invalidate the test results.

Similarly, during the diesel generator load-run test, momentary transients outside the kw load range do not invalidate the test results. !

i Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. 6800 volts is the minimum steady state output voltage and the 10 second transient value. 6800 volts is 98.6% of nominal bus voltage of 6900 volts and is based on the minimum voltage required for the R224 diesel generator supply breaker to close on the 6.9 kV shutdown board. The specified maximum steady state output voltage of 7260 volts is based on the degraded over voltage relay setpoint and is equivalent to 110% of the nameplate rating of the 6600 volt motors. The specified minimum and maximum frequencies of the diesel generator are 58.8 Hz and 61.2 Hz, respectively. These values are equal to t 2% of the 60 Hz nominal frequency and are derived from the recommendations given in regulatory Guide 1.9.

l The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are are based en the recommendations of Regulatory Guide 1.129 " Maintenance Testing and Replacement of Large Lead Storage l Batteries _for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended Practice for Maintenance, Testing and Replacement of Large lead Storage Batteries for Generating Stations and Substations."

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July 22, 1998 SEQUOYAH - UNIT 2 B 3/4 8-la Amendment No. 123, 164, 195, lR195 224 L_____ _ _ _ _ _ . - . _ _ _ .

ADMINISTRATIVE CONTROLS l w &

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CORE OPERATING LIMITS REPORT (continued)

6. WCAP-10054-P-A, Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code, August 1985, (W_ Proprietary)

(Methodology for Specification 3/4.2.2 - Heat Flux Hot Channel Factor) R214

7. WCAP-10266-P-A, Rev. 2, "THE 1981 REVISION OF WESTINGHOUSE EVALUATION MODEL USING BASH CODE", March 1987, (W Proprietary). t (Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor).

6.9.1.14.b The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident' analysis limits) of the safety analysis are met.

R146 6.9.1.14.c THE CORE OPERATING LIMITS REPORT shall be provided within 30 days after cycle start-up (Mode 2) for each reload cycle or within 30 days of issuance of any midcycle revision of the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

SPECIAL REPORTS 6.9.2.1 Special reports shall be submitted within the time period specified for eac n cord with _10 rF 50 6.9.2.2 N E N8.MFE D fL b.- d. -. h. E---

-- - - _ _ - - - - - - - - W ___m

_~ m-A.- ,. ..inimu-- the ".clichilit-j Trp c:r :t "::;r:r ::; :t f:: "r dit , ::;u__;f by LCO 3.8.1.1, Table 4 8-1, shall include: R44 1

( (a) a summary of all tests (valid and invalid) that occurred withi le time i f period over which the last 20/100 valid tests were performa ..

(b) analysis of failures and determination of root ca - of failures (c) evaluation of each of the reco d ons NUREG/CR-0660, " Enhancement of Onsite Emergency Diesel Ge a r _ 1 ability in Operating Reactors,"

with respect to their $ o the Plant I (d) identification of allW ~ ns taken or to be taken to 1) correct the root causes of failures ned in b) above and 2) achieve a general improvement of .sel generator reliability (e) the se le for implementation of each action from d) above I

l (f n assessment of the existing reliability of electric power to engineered-

f ty f :tur: aquipm:nt A

1 April 21, 1997 SEQUOYAH - UNIT 2 6-14 Amendment Nos. 44, 50, 64, 66, 107, 134, 146, 206, 214 l

L - -- -- -- - ---- - _ _ _ _ _ _ _ _ _ _ _ . . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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1 ADMINISTRATIVE CONTROLS W V v v ricarl cc crrter 4 ^ilit" "rre"- _t rrr : r 'CertinuC R44 l A supplemental repc,rt shall be prepared within 30 days after each s uent f ai?.ure during a valid demand for so long as e affected diec enerator unit ;

continues to violate the criteria (3/20 0) for tb iability l improvement program remedial action. em report need only update the failure / demand history for t se generator unit since the ,

last report for that diesel .

.a supplemental report shall also !

present an analysis of the f with a root cause determination, if '

possible, and shall deline ny further procedural, hardware or operational changes to be inco into the diesel generator improvement program and the schedule f .plementation of those changes. I In , ion to the above, submit a yearly data report on the diesel generator

...-..n. _

6.10 RECORD RETENTION (DELETED) '

lR223 I

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July 1, 1998 SEQUOYAH - UNIT 2 6-15 Amendment No. 28, 44, 50, 66, 107, 134, 153, 165, 169, 223 l l

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ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN) ,

UNITS 1 and 2 I PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-96-08, REVISION 1 REVISED PAGES i I. AFFECTED PAGE LIST Unit 1 Operating License Page 6 3/4 8-1 3/4 8-6 3/4 8-8 B 3/4 0-2 B 3/4 8-1 B 3/4.8-la 6-13a 6-14 Unit 2 Operating License Page 5 l 3/4 8-1 3/4 8-7 l 3/4 8-9 j B 3/4 0-2 B 3/4 8-1 i B 3/4 8-la 6-14 I 6-15 II. REVISED PAGES See attached.

I E3-1

6-l (c) By no later than June 30,1982, all safety-related electrical equipment in j the facility shall be qualified in accordance with the provisions of: Division of Operating Reactors " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactos" (DOR Guidelines); or, NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," December 1979.

Copies of these documents are attached to the Order for Modification of Licence DPR-77 dated November 6,1980.

(13) Loss of Non-Class IE Instrumentation and Control Room System Bus Durina Operation (Section 7.10) l Prior to exceeding five percent power, TVA must complete revisions to plant emergency procedures to the satisfaction of the NRC.

(14) Enaineerina Safatv r:eature (ESF) Reset Controls (Section 7.11)

In conformar,ce with IE Bulletin 80-06, TVA shall test the system to identify any

, further areas of concern, and TVA shall review the control schemes to determine L

that they are the best in terms of equipment contro: and plant safety. The results of these test and review efforts shall be provided to the NRC in accordance with the bulletin.

l (15) This specification has been deleted l (16) Fire Protection TVA shall implement and maintain in affect all provisions of the approved fire l protection program referenced in Sequoyah Nuclear Plant's Final Safety Analysis l Report and as approved in NRC Safety Evaluation Reports contained in l NUREG-0011, Supplements 1, 2, and 5, NUREG-1232, Volume 2, NRC letters l-dated May 29 and October 6,1986, and the Safety Evaluation issued on lR231 August 12,1997, for License Amendment No. 227, subject to the following l provision: l l

TVA may make changes to the approved fire protection program without j prior approval of the Commission only if those changes would not l adversely affect the ability to achieve and maintain safe shutdow n in the l event of a fire. l l

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Amendment 9,227, l

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( 5/4.8 wuCTRICAL POWER' SYSTEMS a3/4.8.1 A.C. SOURCES' OPERATING LIMITING CONDITION FOR OPERATION

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

3.8.1.1 1As a minimum, the following A.C. electrical power sources shall be OPERABLE:.

a'. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and-b.

~

s Four' separate and independent diesel generator sets each with:

1. Two diesels driving a common generator p 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank

'3. A separate fuel storage' system containing a minimum volume of 62,000 gallons of fuel,

4. A separate fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:.

.a. With one offsite A.C. circuit of the above required A.C. electrical

. power source inoperable, demonstrate the OPERABILITY of the remaining ,

lR209 offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per.B. hours thereafter.

Restore at least two offsite circuits 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 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in

-COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .-

.b.# With diesel generator set (s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of- lR209

'the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and determining OPERABLE diesel R209

generator sets are not. inoperable due to comon cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ;

-restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , i

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- #' Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if R209 this action is entered.

SEQUOYAH - UNIT 1- 3/4 8-1 Amendment No. 100, 132, 137, l s

205,

ELECTRICAL POWER SYSTEMS

. SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator 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 to 2.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and R177 between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be a 6800 volts and a 58.8 Hz within 10 seconds after the start signal. After R238 energization, the steady state generator voltage and frquency shall be maintained a 6800 volts and s 7260 volts and a 58.8 Hz and s 61.2 Hz during this test.

1

4. 'Within 5 minutes of shutting down the diesel generator after it has operated a 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel R238 generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes.

After energization, the steady state voltage and frequency shall be maintained a 6800 volts and s 7260 volte and a 58.8 Hz and s 61.2 Hz during this test. :

4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and I associated charger for each diesel generator shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying:

1. That the parameters in Table 4.8-la meet the Category A limits.

2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge.

b. At least once per 92 days by:

1. Verifying that the parameters in Table'4.8-la meet the Category i B limits, I

2. Verifying there is no visible corrosion at either terminals or l connectors, or the cell to terminal connection resistance of these items is less than 150 x 10

ohms, and

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60'F. lR217

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

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

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

I

3. The resistance of each cell to terminal connection is less than I or equal to 150 x 10 6 ohms.

4.8.1.1.4 This surveillance has been deleted.

SEQUOYAH - UNIT 1 3/4 8-6 Amendment Nos. 52, 137, 173, 213, 234, L____________ -_______ _

ELECTRICAL POWER SYSTEMS EHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a .. One circuit between the offsite transmission network and the onsite Class IE distribution system,.and j

b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

1. Two diesels driving a common generator,

2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank,

3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel,

4. A fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger.

APPLICABILITY: MODES 5 and 6.

ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demon-strated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 4.8.1.1.2.a.5), and 4.8.1.1.3.

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l SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. l

APPLICABILITY BASES 3.0.5 This specification delineates what additional conditions must be satisfied'to permit operation to continue, consistent with the ACTION statements for power sources, when a normal or emergency power source is not OPERABLE. It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable and a system, subsystem, train, component or device in another division is inoperable for another reason.

The provisions of this specification permit the ACTION statements associated with individual systems, subsystems, trains, components, or devices to be consistent with the ACTION statements of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting condition for Operation for the normal or emergency power source, not the individual ACTION statements for each

. system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source.

For example,. Specification. 3.8.1.1 requires in part that four emergency diesel generators be OPERABLE. The ACTION statement provides for a 7-day out-of- l service time when one emergency diesel generator is not OPERABLE. If the definition of OPERABLE were applied without consideration of specification 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source wculd also be inoperable.

This would dictate invoking the applicable ACTION state.ments for each of the applicable Limiting Conditions for Operation. However, the provisions of Specification 3.0.5 permit the time limits for continued operation to be consistent with the ACTION statement for the inoperable emergency diesel generator instead, provided the other specified conditions are satisfied. In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems, subsystems, trains, components, and devices must be OPERABLE, or otherwise satisfy Specification 3.0.5 (i.e., be capable of performing their design function and have at least one normal or one emergency power source OPERABLE) . If they are not satisfied, action is required in accordance with this specification.

As a further exangle, Specification 3.8.1.1 requires in part that two l physically independent circuits between the offsite transmission network and the onsite Class IE distribution system be OPERABLE. The ACTION statement provides a 24-hour out-of-service time when both required offsite circuits are not OPERABLE. If the definition of OPERABLE were applied without consideration of' Specification 3.0.5, all systems, subsystems, trains, components and devices l supplied by the inoperable normal power sources, both of the offsite circuits, j would also be inoperable. This would dictate invoking the applicable ACTION i statements for each of the applicable LCOs. However, the provisions of Specification 3.0.5 permit the time limit for continued operation to be l consistent with the ACTION statement for the inoperable normal power sources i

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? l SEQUOYAH- UNIT 1 B 3/4 0-2 Amendment No, t__________. _ _ _ _ _ _ _ . , _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ .

t 3/4.8 ELECTRICAL POWER SYSTEMS i

BASES I 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS l

l The OPERABILITY of the A.C. and D.C power sources and associated distri- )

i bution systems during operation ensures that sufficient power will be available {

to supply the safety related equipment required for 1) the safe shutdown of the

facility and 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the ,

power sources provide restriction upon continued facility operation commen-surate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and !

are based upon maintaining at least one redundant set of onsite A.C. and D.C.

power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure 1 of the other onsite A.C. source.

The footnote for Action b of LCO 3.8.1.1 requires completion of a R209 determination that the OPERABLE diesel generators are not inoperable due to 1 common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be l

investigated for common cause failures regardless of how long the diesel generator inoperability persists.

The action to determine that the OPERABLE diesel generators are not inoperable due to common cause failure provides an allowance to avoid unnecessary testing of OPERABLE diesel generators. If it can be determined I

that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not

'have to be performed. If the cause of inoperability exists on other diesel generator (s), the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no. longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance to continued OPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE diesel generators are not affected by the same problem as the inoperable diesel generator.

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SEQUOYAH - UNIT 1 B 3/4 0-1 Amendment No. 12, 137, 173, 205, i

e___________-____.-____ _ _ _ _ _

3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS I

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability 4

is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9 " Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10, 1971, and 1.108 " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants,"

Revision 1, August 1977, and 1.137 " Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979. The surveillance requirements for the diesel generator load-run test and the 24-hour endurance and margin test are in accordance with Regulatory Guide 1.9, Revision 3, July 1993, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as R177 Class 1E Onsite Electric Power Systems at Nuclear Power Plants." During the diesel generator endurance and margin surveillance test, momentary transients outside the kw and kvar load ranges to not invalidate the test results.

Similarly, during the diesel generator load-run test, momentary transients outside the kw load range do not invalidate the test results.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. 6800 volts is the minimum steady state output voltage and the 10 second transient value. 6800 volts is 98.6% of nominal bus voltage of 6900 volts and is based on the minimum voltage required for the R238 diesel generator supply breaker to close on the 6.9 kV shutdown board. The specified maximum steady state output voltage of 7260 volts is based on the degraded over voltage relay setpoint and is equivalent to 110% of the nameplate rating of the 6600 volt motors. The specified minimum and maximum frequencies of the diesel generator are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations given in regulatory Guide 1.9.

The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are 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 Large Lead Storage Batteries for Generating Stations and substations."

SEQUOYAH - UNIT 1 B 3/4 8-la Amendment No. 12, 137, 173 lR209 205, 234, L

l ADMINISTRATIVE CONTROLS j

i CORE OPERATING LIMITS REPORT (continued)

6. WCAP-10054-P-A, Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code, August 1985, (H Proprietary)

(Methodology for Specification 3/4.2.2 - Heat Flux Hot Channel Factor) f

7. WCAP-10266-P-A, Rev. 2, "THE 1981 REVISION OF WESTINGHOUSE EVALUATION R227 MODEL USING BASH CODE", March 1987, (H Proprietary) .

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor).

6.9.1.14.b The core operating limits sha11 be determined so that all applicable limits (e.g., fuel thermal-meenanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.14.c THE CORE OPERATING LIMITS REPORT shall be provided within 30 days i after cycle start-up (Mode 2) for each reload cycle or within 30 days of R159 issuance of any midcycle revision of the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

SPECIAL REPORTS l'

l 6.9.2.1 Special reports shall be submitted within the time period specified R76 l for each report, in accordance with 10 CFR 50.4.

l 6.9.2.2 This specification has been deleted.

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SEQUOYAH - UNIT 1 6-13a Amendment No. 52, 58, 72, 74, 117, 155, 223,

ADMINISTRATIVE CONTROLS 6.10 l RECORD RETENTION (DELETED) R237 I

.SEQUOYAH - UNIT 1 6-14 Amendment No. 42, 52, 58, 74, 117, 148, 163, 174, 178, 233, L-____-____

J

b. Complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used-for all safety -

related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0588.. Such records should be updated and maintained current as equipment-is replaced, further tested, or otherwise further qualified to' document complete compliance by June 30,~1982.

c. Within 90 days of receipt,of the equipment qualification safety evaluation, the licensee shall either (i) provide missing documentation identified in sections 3 and 4 of the equipment qualification safety evaluation which will demonstrate compliance of the applicable equipment with j l

NUREG-0588, or (ii) commit to corrective actions which will result in documentation of compliance of applicable equipment with NUREG-0588 no later than June 30, 1982.

(11) Requirements For Modification To Or Addition Of Instrumentation And Controls (Section 7.3.2)

a. Prior to startup after first refueling, TVA shall have installed instrument downscale failure alarms for the effluent monitoring instrumentation channels for radioactive gaseous and radioactive liquid effluents. R2 Modifications to procedures and Technical' Specifications 3.3.3.9 and 3.3.3.10 shall have been completed,

b. Prior to startup after the first refueling, TVA shall have received NRC approval of an additional operable level of over/undervoltage protection including associated Technical Specifications. The level of protection from the effects of power transients on safety-related equipment provided by Part I of the staff's " Degraded Grid Voltaga Position", or equivalent, is required.

(12) This specification has been deleted.

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Amendment 2, 1 i

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3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Four separate and independent diesel generator sets each with:

1. Two diesels driving a common generator

2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank-

3. A separate fuel storage system containing a minimum volume of 62,000 gallons of fuel,

4. A separate fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite A.C. circuit of the above required A.C. electrical R195 power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour 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 two offsite circuits 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 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , b.# With diesel generator set (s) 1A-A and/or 2A-A or 1B-B and/or 2B-B R195 of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and R195 at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Required actions, to verify OPERABLE diesel generator sets are not inopersble due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if R195 this action is entered.

SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, i

L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQU.';REMENTS (Continued) 4.8.1.1.4 This surveillance has been deleted.

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1 SEQUOYAH - UNIT 2 3/4 8-7 Amendment No. 44, u______________________. - _ _ . _ _ _ _ _ - . _ . _ _ - . - - - - . . _ _ _ . _ - . -

l

' ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION.

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

a. I One circuit between the offsite transmission network and the onsite 1 Class lE distribution system, and

)

1

b. Diesel generator sets lA-A and 2A-A or 1B-B and 2B-B each with:

1. Two diesels driving a common generator,

2. Two engine-mountad fuel tanks containing a minimum volume of 250 gallons of fuel per tank, 1 1

3. A fuel. storage system containing a minimum volume of 62,000 '

gallons of fuel,

4. A fuel transfer pump, and

5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger.

APPLICABILITY: MODES 5 and 6.

1 ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demon-strated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 4.8.1.1.2.a.5), and 4.8.1.1.3.

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SEQUOYAH - UNIT 2 3/4 8-9 Amendment No.

I

_ _ _ - _ _ _ - _ _ _ _ _ _ _ _ . _- - - -- _. _ _ - _ - - __ ._ _ - - _ - - - _ - . . _ - - _ - _ _ _ _ - _ _ - -_--_--__---_-______--_-_---_-__O

BASES i

i 3.0.5 This-specification delineates what additional conditions must be satisfied to. permit operation to continue, consistent with the ACTION state-ments for' power sources, when a normal or emergency power source is not l -OPERABLE. It specifically prohibits operation when one division is inoperable because its normal or' emergency power source is inoperable and a system, subsystem, train, component or device in another division is inoperable for another reason.

L The provisions of this specification permit the ACTION statements' associated with individual systems, subsystems, trains, components, or devices to be consistent with the ACTION statements of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individual ACTION statements for each t system, subsystem, train, component or device that is determined to be l inoperable solely because of the inoperability of its normal or emergency power

[ source.

For example, Specification 3.8.1.1 requires in part that four emergency diesel generators be OPERABLE. The ACTION statement provides for a 7-day out-of- l service time when one emergency diesel generator is not OPERABLE. If the definition of OPERABLE were applied without consideration of Specification 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source would also be inoperable.

This would dictate invoking the applicable ACTION statements for each of the applicable Limiting Conditions for Operation. However, the provisions of Specification 3.0.5 permit the time limits for continued operation to be consistent with the ACTION statement for the inoperable emergency diesel generator instead, provided the other specified conditions are sa.tisfied. In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems,-subsystems, trains, components, and devices must be OPERABLE, or otherwise satisfy Specification 3.0.5 (i.e., be capable of performing their design function and have at least one normal or one emergency power source OPERABLE). If they are not satisfied, action is required in accordance with this specification.

As a further. example, Specification 3.8.1.1 requires in part that two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system be OPERABLE. The ACTION statement provides a 24-hour out-of-service time when both required offsite circuits are not OPERABLE. If the definition of OPERABLE were applied without consideration of Specification 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable normal power sources, both of the offsite circuits, would also be inoperable. This would dictate invoking the applicable ACTION statements for each of the applicable LCOs. However, the provisions of Specification 3.0.5 permit the time limit for continued operation to be consistent with the ACTION statement for the inoperable normal power sources instead, provided the other j.

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SEQUOYAH -' UNIT 2 B 3/4 0-2 Amendment No. )

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l 3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 AND 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident condi-l tions within the facility. The minimum specified independent and redundant '

A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation 1 commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety ,

i analyses and are based upon maintaining at least one redundant set of onsite l A.C. and D.C. power sources and associated distribution systems OPERABLE during 1 accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source.

The footnote for Action b of LCO 3.8.1.1 requires completion of a )

determination that the OPERABLE diesel generators are not inoperable due to i common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be i investigated for common cause fai2ures regardless of how long the diesel R195 l generator inoperability persists. i The action to determine that the OPERABLE diesel generators are not j inoperable due to common cause failures provides an allowance to avoid unnecessary testing of OPERABLE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel generator (s), the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable dier.el generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE diesel generators are not affected by the same problem as the inoperable diesel generator.

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l SEQUOYAH - UNIT 2 B 3/4 8-1 Amendment No. 123, 164, 195, l

l W-_ - . - _ _ _ . _ _

3/4.8

( ELECTRICAL POWER SYSTEMS i

I BASES 3/4.8.1 AND 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that

1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9 " Selection of Diesel Generator Set Capacity for Standby Power Supplies", March 10, 1971, 1.108 " Periodic Testing of Diesel Generator Units.

Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977, and 1.137 " Fuel-Oil Systems for Standby Diesel Generators,"

Revision 1, October.1979. The surveillance requirements for the diesel generator load-run test and the 24-hour endurance and margin test are in accordance with Regulatory Guide 1.9, Revision 3, July 1993, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plant." During the R164 diesel generator endurance and margin surveillance test, momentary transients outside the kw and kvar load ranges do not invalidate the test results.

Similarly, during the diesel generator load-run test, momentary transients outside the kw load range do not invalidate the test results.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. 6800 volts is the minimum steady state output voltage and the 10 second transient value. 6800 volts is 98.6% of nominal bus voltage of 6900 volts and is based on the minimum voltage required for the R224 diesel generator supply breaker to close on the 6.9 kV shutdown board. The specified maximum steady state output voltage of 7260 volts is based on the degraded over voltage relay setpoint and is equivalent to 110% of the nameplate rating of the 6600 volt motors. The specified minimum and maximum frequencies of the diesel generator are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations given in regulatory Guide 1.9.

The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are are based on the recommendations of Regulatory Guide 1.129 " Maintenance Testing and Replacement of Large Lead Storage l Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

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I SEQUOYAH - UNIT 2 B 3/4 8-la Amendment No. 123, 164, 195, lR195 224,

-______-_-_--_____w

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ADMINISTRATIVE CONTROLS t

l CORE OPERATING LIMITS REPORT (continued)

6. WCAP-10054-P-A, Westinghouse Small Break ECCS Evaluation Model Using j

the NOTRUMP Code, August 1985, (H Proprietary)

(Methodology for Specification 3/4.2.2 - Heat Flux Hot Channel

( Factor) R214 i 7. WCAP-10266-P-A, Rev. 2, "THE 1981 REVISION OF WESTINGHOUSE EVALUATION MODEL USING BASH CODE", March 1987, (H Proprietary).

(Methodology.for Specification 3.2.2 - Heat Flux Hot Channel l

Factor).

6.9.1.14.b The core operating limits xhall be determined so that all applicable limits (e.g., fuel thermal- w chanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

R146 6.9.1.14.c- THE CORE OPERATING LIMITS REPORT shall be provided within 30 days I after cycle start-up'(Mode 2) for each reload cycle or within 30 days of issuance of any midcycle revision of the NRC Document Control Desk with copies

- to the Regional Administrator and Resident Inspector.

SPECIAL REPORTS 6.9.2.1 Special reports shall be submitted within the time period specified

.- for each report, in accordance with 10 CFR 50 4.

6.9.2.2 This specification has been deleted. j j

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- SEQUOYAH - UNIT 2 6-14 Amendment Nos. 44, 50, 64, 66, 107, 134, 146, 206, 214, l

__m._ . - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . . _ . _ _ _ _ _ _ _ . _ _ . _ _ _ . . _ _ . _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ . - _ . .__ . . _ . . . _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ . . . _ _ _.

ADMINISTRATIVE CONTROLS 6.10 RECORD RETENTION ' (DELETED) lR223 l

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SEQUOYAH - UNIT 2 6-15 Amendment No. 28, 44, 50, 66, 107, j 134, 153, 165, 169, 223, j

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l ENCLOSURE 4 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN) l UNITS 1 and 2 l

l- PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-96-08, REVISION 1

( RESPONSES TO NRC REQUEST FOR ADDITIONAL INFORMATION t {

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r E4-1

ENCLOSURE 4 Responses to NRC's Request for Additional Information Regarding Technical Specification Change 96-08 Question la Provide the actual outage history (preventive and corrective maintenance) f or each of the four EDGs during CYs 1995 through 1997 (year-to-date) .

Response

Actual outage history for planned EDG outages for EDGs 1A-A, ,

IB-B, 2A-A, and 2B-B are shown in Tables 1 through 4, respectively. Actual outage history for unplanned outages for EDGs 1A-A, 1B-B, 2A-A, and 2B-B are shown in Tables 5 through 8, respectively.

Question 1b:

Provide the total annual unavailability (in hours and %) and reliability for each of the four EDGs during CYs 1995 through 1997 (year-to-date) .

Response

The total annual unavailability (in hours and percent) for each of the four EDGs is provided in the table below (please note the related values in Enclosure 1 are based on a 24-month interval):

1995 1A-A 1B-B 2A-A 2B-B j Planned hrs (%) 82.27(0.94) 67.2(0.77) 114.51(1.31) 95.39(1.09)

Unplanned hrs (%) 0 0 11.89(0.14) 25.00(0.29) ,

- Overall hrs (%) 82.27(0.94) 67.2(0.77) 126.30(1.44) 120.39(1.37) {

l 1996 j 1A-A 1B-B 2A-A 2B-B j Planned hrs (%) 66.32(0.76) 76.83(0.87) 59.73(0.68) 67.17(0.76) I Unplanned hrs (%)12.34 (0.14) 0 1.48(0.02) 3.25(0.04)

Overall hrs (%) 78.66(0.90) 76.83(0.87) 61.21(0.70) 70.42(0.80) 1997 1A-A 1B-B 2A-A 2B-B Planned hrs (%) . 72.33(0.83) 57.98(0.66) 93.60(1.07) 84.05(0.96)

Unplanned hrs (%)49.55(0.57) 51.25(0.59) 97.60(1.11) 36.45(0.42)

Overall hrs (%) 121.88(1.39)109.23(0.87)191.20(2.18) 120.49(1.38)

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The total annual reliability for each of the four EDGs is provided in the table below:

1995 1A-A 1B-B 2A-A 2B-B Demands 33 33 33 22 Valid Tests 18 16 23 13 Valid Failures 0 0 0 0 1996 1A-A 1B-B 2A-A 2B-B Demands 24 22 25 28 i Valid Tests 15 14' 16 16 Valid Failures 1 0 0 l

0 1 1

1997 1A-A 1B-B 2A-A 2B-B Demands 34 27 33 30 Valid Tests 16 14 20 16 Valid Failures 0 0 2 0 The data from 1995 through 1997 shows an increasing number of EDG unavailability hours. This increase is primarily the result of ,

repairs to the electrical portions of the EDGs.. This is an l indication that aging components in the electrical portions of !

the EDGs may need replacement. TVA has replaced degraded electrical components as necessary and have been able to perform such replacements in the current AOT. SON has also observed age degradation in the EDG electrical generators and recognizes the potential need to replace these components in the future. l However, replacement of the electrical generator would require a j duration of approximately six days. With the existing 72-hour i AOT, the options for correcting electrical generator degradations i are limited to in-place repairs without the ability to perform a j well planned replacement. j Question'1c:

i Provide a critical path schedule for the planned 12 year maintenance (showing total hours for each major step and for clearance process) assuming 1) a 72-hour AOT and 2) a 7-day AOT.

Show the number of LCO entries and the total elapsed tLme to ;

complete the maintenance for each case.

Response

TVA~has evaluated schedules considering a 72-hour and 7-day AOT for performing the 12- and 6-year maintenance activities. These schedules include the vendor recommended maintenance and E4-3 t.

I inspections that'are' performed on 2 , 6, and 12-year intervals.

These schedules _ assume that the inspections identify at least l one, but no more than eight, power. assemblies on each engine that

[T require replacement. The schedules also assume.thatLneither turbo charger of the EDG' set requires replacement. These assumptions are based on the'results of the first 12-year

-maintenance activities and periodic engine inspections.

Attachment 1 contains the summary activities;for.the 7-day and hour' schedules. . Attachments.2 and 3 contain the detailed

-activities for the 7-day and 72-hour AOT schedules, respectively.

The' schedules shown in the attachmentstutilize the same activities'but differ:infduration in many instances. . The primary reason'for this difference is that the 7-day activities are often longer.because they involve work on both engines of the EDG set.

. In addition, many: work activities that can be worked concurrently with-the 7-day effort are increased in duration because of interactions between activities. The 72-hour activities do not result inisimilar duration' increases because the short limiting condition for operation (LCO) time does not allow as much' concurrent work or the ability.to work on both engines at'the same time.

The 7-day. schedule-involves one-entry into the EDG LCO action and one set.of testing to return the EDG to service. The 72-hour schedule involves-five entries into the AOT and five sets of EDG testing. The testing for two of the EDG " return to service" test sequences will include additional manipulations of the EDG to break-in.new power assemblies. The comparison of these' schedules indicate that the 7-day effort will result in EDG unavailability

- of approximately 113 hours0.00131 days 0.0314 hours 1.868386e-4 weeks 4.29965e-5 months . The 72-hour effort results in approximately 215 hours0.00249 days 0.0597 hours 3.554894e-4 weeks 8.18075e-5 months of unavailability and is approximately 2 times: longer than the 7-day schedule. The 72-hour schedule

' includes 32. additional' hours of EDG clearance activities and 34! hours of additional testing, which includes 13 more EDG starts

-when compared.to the 7-day schedule.

. These schedules can increase in duration if more than 8 power

assemblies or any of the-turbo chargers require replacement.

Replacement of power assemblies involve the same duration of physical work as the maintenance activities for assemblies that are not replaced. However, replacement of more than 8 power assemblies, for~the 72-hour schedule, may result in work activities that cannot be achieved within the AOT. Power assemblies that' require replacement must be corrected prior to returning the EDG to operable status and the-72-hour schedule is limited regarding the number that can be worked. This situation, with a 72-hour AOT, would result in the need to request discretionary enforcement or shutdown the operating units. The same addition of power assembly replacements will not increase testing or duration of the 7-day schedule because activities E4-4

include work on all 32 cylinders within 1 AOT entry with break-in testing. In addition, the overall 72-hour schedule will not increase in testing or duration for additional power assemblies that can be replaced within the 72-hour A0T.

The 7-day schedule can be modified to accommodate the replacement of 1 turbo charger within the proposed A0T. The replacement activities are estimated to result in the addition of less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months in the 7-day schedule. If 2 turbo chargers require replacement, an additional entry.into a 7-day AOT will probably be required involving an additional LCO entry, clearance of the EDG, replacement of 1 turbo, and testing for operability.

Replacement of 2 turbo chargers would result in at least 120 additional hours of EDG unavailability. For the 72-hour schedule, the replacement of a turbo charger is not expected to be achievable. It is estimated to take an outage of approximately 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to implement the replacement of a turbo and perform testing to return the EDG to operable status.

Therefore, the replacement of a turbo under the current TS AOT requirements is not feasible without a 2 unit shutdown or NRC approval of enforcement discretion to extend the 72-hour AOT.

The comparisons between the schedule activities required to perform this maintenance indicate that the 7-day A0T schedule results in a significant reduction in EDG unavailability. The 7-day maintenance schedule involves major reductions in the number of clearance activities and return to normal test activities. In addition to these reductions, the 7-day schedule will reduce EDG idle starts.to approximately 32 percent of those required for the 72-hour AOT schedule. This is a significant benefit because EDG starts result in the greatest wear on units that are utilized for standby power. Therefore, the implementation of a 7-day AOT for EDG inoperability will significantly improve unavailability to support the Maintenance Rule requirements and reduce starts to maintain the reliability of the EDGs.

1 Question 2 !

Provide a discussion that expands upon the statement, "A 7-day AOT would also be consistent with the objective and intent of 10CTR50.65, Appendix A, 'The Maintenance Rule'."

, 1 l Response: 1 The Maintenance Rule unavailability performance criteria for the SON EDGs is 0.025 for a rolling 24-month average per EDG. This unavailability is bounded by the SON probabilistic safety assessment (PSA).

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( The table below compares the expected unavailability for each EDG

- resulting from performing the 12- and 6-year maintenance in a single 7-day AOT verses performing the maintenance over multiple periods within the current 72-hour AOT. The unavailability is based on the 24-month average (as of December 31, 1997) plus outage time.

Performance EDG 72-Hour AOT 7-Day AOT Criteria l 1A-A 0.024 0.018 0.025 1B-B 0.023 0.017 0.025 2A-A 0.027 0.021 0.025 2B-B 0.023 0.017 0.025 As can be seen from the above table, utilizing multiple 72-hour AOTs to perform.the 12- and 6-year maintenance will likely result in the 2A-A EDG exceeding the Maintenance Rule performance criteria. The 1A-A, 13-B, and 2B-B EDGs will be close to exceeding the criteria. In contrast, performing the 12- and 6-year maintenance.with a single 7-day AOT will not cause any of the 4 EDGs to exceed the performance criteria and is consistent with the objective and intent of 10 CFR 50.65, Appendix A, "The Maintenance Rule."

Question 3:

Discuss the reason that the Sequoyah technical specifications require a dual plant shutdown in the event that an emergency diesel generator is inoperable for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Response

SON TS 3/4.8.1 requires all four EDGs to be operable for either or both units due to the shared or common mechanical systems, which receive emergency backup AC power from the EDGs. Examples of systems shared between Unit 1 and Unit 2 are emergency gas treatment system (EGTS), auxiliary building gas treatment system (ABGTS), auxiliary control air, and the component cooling water system (CCS). Since the inoperability of 1 EDG results in the degradation of one train of safety-related system functions for both units, a dual unit shutdown is required if the inoperability period of any 1 of the 4 EDGs exceeds the 72-hour AOT.

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Question 4:

The Individual Plant Examination (IPE) submitted to the NBC in September 1992 stated that the contribution of loss of offsite power to core damage frequency (CDF) for internal events is approximately 6% (1.1E-5) of the total CDF of 1.7E-4/ year.

(a) The subject change request discussed several hardware and operational improvements that have been made at Sequoyah since submittal of the IPE to improve offaite power reliability. Discuss the quantitative change in loss of offsite power contribution to total CDF that resulted f' om r

these ispprovements.

(b) Also discuss any changes to the calculated CDF resulting from any other operational or design enhancement since submittal of the IPE. (It is the staff's belief that the total CDF is now thought to be approximately E-S/ year) .

(c) Discuss the plant-specific f' actors that result in the relatively small contribution of loss of offsite power to CDF.

Response

The initial issue of the Sequoyah Nuclear Plant Individual Plant Evaluation (SONIPE) determined the contribution to core damage frequency (CDF) from a loss of offsite power (LOOP) to be 1.1E-5/ year. This evaluation was submitted to NRC in September of 1992. The SONIPE was updated in September of 1995 to:

reflect changes in plant design, procedures, and training programs, e

remove conservatism and approximations to more accurately represent the current plant configuration, and update initiating event frequencies based on additional operating experience This updated SONIPE (SQNREV10) , which was submitted to NRC on February 20, 1998, has been used to evaluate the effect on CDF of the proposed change in EDG AOT for TS Change Request TS 96-08.

(a) The SONREV1U conservatively does not account for the operational and hardware changes described in TS 96-08, which improve offsite power reliability. The SONREV1U does account for a decrease in the LOOP initiating event frequency as a result of updated generic industry data and additional operating experience at SON. The LOOP initiating E4-7

i event frequency decreased from 5.5E-2 used in the SONIPE to 4.85E-2 used in the SQNREVlU.

As a result, the' LOOP contribution to CDF is 3.95E-6 or about 10% of the total CDF determined in the SONREVlU.

Since SONREV10 does not account for the offsite power improvements, incorporation of these changes would likely result in a decrease in the total CDF.

(b) The CDF determined in the SON 1PE is 1.7E-4. As discussed above, changes in plant design, such as the 480V Board Room 1A-A and 1B-B ventilation upgrade, changes in procedures and operating experience, as well as modeling refinements, have reduced the CDF to 3.8E-5 as documented in the SONREVlU.

Some of the specific improvements include the CCS, thermal barrier booster pump, safety injection pump, residual heat removal pump, centrifugal charging pump success criteria, operator alignment of high pressure recirculation, updating initiating event frequencies,. reactor trip breaker reliability update, and common cause failure updates for essential raw cooling water (ERCW) and CCS.

(c) The plant specific factors that result in the relatively small contribution of LOOP to CDF are:

1. The LOOP initiating frequency is relatively small, on the order of the initiating events, which are more likely to result in core damage (e.g., loss-of-coolant accidents

[LOCAs]). In SONREV1U, credit for operator recovery of offsite and onsite power sources within one hour of event initiation reduces the probability'of core damage (except for medium and large LOCAs). In addition, the size, diversity, and reliabi!ity of the switchyard is a large contributor to the relatively small LOOP initiating frequency.

2. The EOPs for SON are symptom based, which have a safety benefit. Specifically, site procedures for loss of all power define operator actions to depressurize the reactor coolant system (RCS) and inject into the steam generators with the turbine-driven AFW pump. This operator action reduces the CDF for the LOOP initiating event.

3. In addition, the reliability of the EDGs (to start and l run) are better than the industry average, which again, l reduces the potential for station blackout (SBO) induced core damage. The SONREV10 indicates that the plant has experienced only 2 diesel generator (DG) start failures in 522 demands and 2 run failures during the first hour of operation in 286 hours0.00331 days 0.0794 hours 4.728836e-4 weeks 1.08823e-4 months of run time. There were no E4-8 l

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I failures during the extended run test (for a total of 480 hours0.00556 days 0.133 hours 7.936508e-4 weeks 1.8264e-4 months of run time) for the DGs.

While the'above features (except for EDG reliability) are not necessarily unique to SON, they are important to reducing the effect of a LOOP on CDF.

Question 5:

The subject change request states that the expected EDG unavailability under the current maintenance schedule with the 72-hour AOT is 576 hours0.00667 days 0.16 hours 9.523809e-4 weeks 2.19168e-4 months per EDG per year, and would result in an overall.CDT of 3.936E-5. The change request also states that, with the 7-day AOT, the EDG unavailability will be 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months per EDG per year with a resultant reduction in overall CDT to 3.848E-5.

(a) It would appear that these long periods of unavailability would cause the EDGs to be classified in the A.1 category under the Maintenance Rule. Provide a discussion.

(b) How do these assumptions of EDG unavailability compare with those used in the IPE7 (c) Provide the values for the EDG reliability and availability used in the IPE to calculate the station bisckout (SBO) CDT values. Discuss these values in relationship to any goals associated with the implementation of the maintenance rule and in conparison to the actual past performance of the EDGs at the plant. Also, compare the values used in the IPE to the target values conunitted to for the SBO rule.

(d) Explain how EDG preventive maintenance and subsequent on-line operability testing is treated in CDT calculations.

(e)- Given the AOT plant configuration, what does your IPE indicate are the most risk-significant systems? Please explain the results.

(f)- Tor the systems you identified in the previous question, how would you ensure that no risk-significant plant equipment outage configurations would occur while the plant is subject l to the LCO proposed for modification? Are the bases for this assurance reflected in your procedures or TS?

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(g) Describe how PRA insights are used in the decision making process, specifically with respect to planning maintenance activities involving the EDGs.

Response

As discussed previously in the response to Question ic, TVA has performed detailed evaluations of the activities required to complete the 2~, 6, and 12-year. maintenance. These evaluations were used to determine the expected yearly EDG unavailability considering these maintenance activities. The result was a duration of 434'and 332 hours0.00384 days 0.0922 hours 5.489418e-4 weeks 1.26326e-4 months /EDG-year for the 72-hour and 7-day AOTs, respectively. These durations were derived by adding the Maintenance Rule unavailability limit of 219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months to the estimated maintenance activity duration for a 72-hour and 7-day AOT. This is a conservative estimate of the expected duration because SON history indicates typical yearly unavailabilities for the EDGs to be significantly less than the 219-hour limit. These duration estimates result in an EDG unavailability of 0.050 and 0.038 for the 72-hour and 7-day AOTs,.respectively. The CDF and change in CDF from the SQNREV1U for these two cases is given in the Table below:

Case CDF Change in (per year) CDF from SONREV1U ( % )

171-hours EDG unavailability 4.06E-5 --

(SONREV1U) (see Note) 332-hours EDG unavailability 4.13E-5 1.8 434-hours EDG unavailability 4.19E-5 3.1 Note:

These CDFs were determined using the SONREV10 model with a truncation value of 1.0E-12 (see response to Question 6). The SONREV1U report and the original submittal for this TS change used a truncation value of 1.0E-9. The use of a truncation value of 1.0E-12 results in a shift of the base case CDF from that reported in the SONREV10 report and in the original submittal for this TS change from 3.77E-5 to 4.06E-5 (see above). As a result, the CDFs for the EDG unavailabilities given above are greater than those reported in the original TS submittal, even though the estimates of EDG unavailability given above are lower than the estimates used in the original TS submittal. ,

i As requested in subsequent discussions with the NRC staff, the incremental conditional core damage probability (ICCDP) from a zero-maintenance case for a EDG being in maintenance for 72-hours

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1 and 7 days, which correspond to the current and requested AOTs for the EDGs, respectively, have been determined and are given in the Table below:

EDG being in maintenance for: ICCDP 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 2.14E-7 7 days 4.98E-7 (a). (See response to Question 2)

(b) In the.SQNREV10, EDG unavailability is 0.0195 (171 hours0.00198 days 0.0475 hours 2.827381e-4 weeks 6.50655e-5 months /EDG-year). This compares to a Maintenance Rule unavailability limit of 0.025 (219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months /EDG-year) . This deviation from the SONREV1U assumption was reconciled by a j sensitivity study, which concluded that the worst-case change in CDF was 9.9 percent, considered to be nonrisk-significant.

Consistent.with the NRC staff position in Question 15 of this request for additional information (RAI), and following the guidance in Sections 4.3.4 and 4.3.5 of Draft Regulatory Guide DG-1065 dated June 1997, two estimates of EDG unavailability have been made based on a permanent 7-day EDG AOT for the upcoming 12- and 6-year EDG maintenance.

In the first estimate, EDG unavailability is determined assuming the same priority is placed on future repairs / maintenance as in the current 72-hour AOT. The unavailability for each EDG is based on the EDGs being at their Maintenance Rule unavailability limit during the 12-and 6-year maintenance year (219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months /EDG-year), plus an additional unavailability equal to 1, 72-hour AOT per EDG in the and.6-year maintenance year for a total of 291 hours0.00337 days 0.0808 hours 4.811508e-4 weeks 1.107255e-4 months /EDG-year.

In the second estimate, EDG unavailability is determined L assuming a lower priority is placed on future repairs / maintenance than in the current 72-hour AOT. The unavailability for each EDG is based on the EDGs being at their Maintenance Rule unavailability limit during the 12-and 6-year maintenance-year (219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months /EDG-year) , plus an j

additional unavailability equal to 1, 7-day AOTs for each EDG in the 12- and 6-year maintenance year for a total of 387 hours0.00448 days 0.108 hours 6.398809e-4 weeks 1.472535e-4 months /EDG-year.

l' The second estimate of 387 hours0.00448 days 0.108 hours 6.398809e-4 weeks 1.472535e-4 months /EDG-year is coincidentally close to the 332 hours0.00384 days 0.0922 hours 5.489418e-4 weeks 1.26326e-4 months /EDG-year estimate of EDG L unavailability for the 12- and 6-year maintenance activities l with a 7-day AOT. The resulting CDF is 4.11E-5 and 4.16E-5 for the 291 and 387 hours0.00448 days 0.108 hours 6.398809e-4 weeks 1.472535e-4 months /EDG-year estimates, respectively.

These CDFs result in a worst-case CDF change of 1.2 and E4.l l 1 l

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2,5 percent, respectively. This increase in CDF from the base case CDF value of 4.06E-5 is not considered risk significant. It is important to note that the Maintenance Rule unavailability limit of 219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months /EDG-year is not expected to be exceeded during the non and 6-year maintenance years.

(c) The point estimate value for the total unavailability of an EDG in the SONREV10 due to random hardware failures and maintenance activicies is 4.99E-2. Maintenance unavailability amounts to approximately 40% of the total EDG unavailability. In the SONREV10, EDG reliability is composed of three measures of EDG failure. The complete statistics for these unreliability measures are listed in Table 3.3.2-10 of the SONIPE. The mean values are listed below:

Description mean value Diesel generators fail during 5.85E-3 the first hour of operation Diesel generators fail during 6.94E-4 the second hour of operation Diesel generators fail to start 5.26E-3 The EDG unavailability used in the SONREV1U is 0.0195 (171 hours0.00198 days 0.0475 hours 2.827381e-4 weeks 6.50655e-5 months /EDG-year) .

The Maintenance Rule performance criteria for the EDGs is 6 fail-to-start per 100 demands. (A sensitivity study of the effect of this EDG reliability on CDF was performed and found to result in a nonrisk-significant increase of 11.7%

in CDF. ) The Maintenance Rule unavailability limit is 0.025 (219 hours0.00253 days 0.0608 hours 3.621032e-4 weeks 8.33295e-5 months /EDG-year).

The Maintenance Rule unavailability limit is consistent with the 0.975 target value for EDG reliability in SON's SBO submittal.

(d)- The plant specific unavailability and unreliability parameters used in the SONREV1U, were generated using plant specific unavailability and unreliability data in a Bayesian update of generic failure and maintenance data. The time l period for preventative maintenance (PM) and subsequent l operability testing is treated as an unavailability. The SON EDG unavailability data used in the SONREV1U includes both the preventive and corrective maintenance activities associated with EDGs. Maintenance durations are taken from the time the component is tagged out of service until the time it is returned to service in an operable condition.

The process outlined above is described in detail in E4-12

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Section 3.3.2 of the SONIPE. Note that on-line operability testing of the EDGs does not disable the'EDGs or render them unavailable for emergency response to a LOOP event.

Therefore,1 operability testing of the EDG does not contribute to the unavailability of the EDG and is not included in the'model for the EDG.

(e) 'The Risk Achievement Worth (RAW) measured by top event / system is listed'in Table 9 for three cases of EDG l . unavailability. The tables list those top events / systems j with RAW value greater than 2.0. As can be seen from

' Table 9, the' risk significance of the top events / systems

-remains about the same for. cases of EDG unavailability that have been considered. Therefore, the risk significance of

.the top events / systems for the extended EDG AOT will remain essentially the same.

(f)- The results provided in the response to Question 5(e) show that the risk ~ significance of the top events / systems remain essentially unchanged in extending the EDG AOT. Therefore, l scheduling will-be the'same as for the 72-hour AOT:

The 12-week scheduling process is the first key element in SQN's risk management for on-line maintenance. Work has been automatically grouped by use of Functional Equipment Groups. This grouping is evaluated by qualified individuals. This grouping takes into account channels, trains, and the PSA risk matrix to ensure scheduled plant maintenance will~not enter risk-significant plant configurations and that.other activities receive the appropriate level of awareness. based <x1 increases in plant risk. Each Functional Equipment Group is electronically preassigned to a' specific work week in the cycle.

Additionally, System Engineering is responsible for ensuring that proper System Window scoping and work ranking is performed to-maximize system reliability. System Engineers

are also responsible for grouping work in order to minimize the number of times components / trains are removed from

, service.

The second key element for SON's risk assessment is the Work Week Manager. Each scheduled item is evaluated against the SON risk matrix or the SON computerized risk assessment tool (SENTINEL):. The risk level for any particular system is categorized by the following colors (which are consistent with those being utilized by the ORAM computer program for l plant. shutdown conditions)':

iGREEN: Configuration does not produce a significant Lincrease in risk and does not require any increased attention.

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f YELLOW: Configuration produces an elevated risk level which can be offset by reducing equipment outage time, equipment outage frequency or compensatory measures.

ORANGE: Configuration produces an elevated risk level which requires increased management attention and compensatory measures unless further evaluation determines acceptability.

RED: Configuration produces an undesirable level of increased plant risk and should be avoided. Actions should be taken to restore plant equipment to operable status.

Scheduling of daily activities should generally produce risk levels no higher than yellow in accordance with the risk evaluation. When risk significant equipment or combinations of such unavailable equipment cannot be found on the risk matrix or in SENTINEL, a knowledgeable risk engineer is consulted.

The third key element is the computer program SENTINEL.

Application of SENTINEL to SON is the result of development work by ERIN Engineering and Research, Inc., and subsequent review and development work conducted by SQN. The SON model originated from the SON PSA, the SQN site emergency and functional restoration guideline procedures, and the SQN TSs for operation. Plant configuration information input te SENTINEL includes:

equipment out of service e activities that can lead to plant transients (high risk evolutions)

safety significant alignments SENTINEL performs both probabilistic and deterministic j evaluations of this information. From the deterministic evaluation, SENTINEL outputs defense-in-depth posture for safety functions, as well as both the plant's transient mitigation status and likelihood of experiencing a plant transient. From the probabilistic evaluation, SENTINEL cutputs core damage frequency results based on the SON PSA for each plant configuration, as well as equipment " remain in service" and " return to service" priorities. SENTINEL is run on the schedule the week prior to implementation, and can be run more often for plant configuration changes resulting from emergent issues.

) !

j The fourth key element in SON's risk assessment is the l Operations Risk Senior Reactor Operator (SRO). This E414 l

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individual uses a copy of the frozen schedule and the risk matrix to evaluate each scheduled item. This'SRO has the benefit of current plant status to evaluate any emergent issues (equipment out-of-service) against the schedule. He works closely with the Work Week Manager to ensure that equipment outages are scheduled at optimum times to reduce risk and duration. When questions arise during the schedule review, the PSA engineer is consulted.

Emergent work is evaluated by the Work Week Manager against I the risk matrix or SENTINEL, taking into account any equipment currently out-of-service as well as any equipment scheduled in the near future to be removed from service.

This evaluation is documented and requires the signature of the Work Week Manager, the Shift Manager, and the j Maintenance Shift Supervisor. Minor maintenance is not 1 scheduled, but requires an evaluation by the on-shift Unit i Manager SRO prior to starting work. Work performed by the Fix-it-Now (FIN) teams are evaluated for risk by the-FIN Team SRO prior.to the start of work, and are not scheduled activities. Emergent work orders that are prioritized as immediate attention are-evaluated for risk by the on-shift Shift Manager prior to starting work.

The provisions described above are contained in the 12-Week Site Scheduling Process Manual at SQN.

(g) .The original layout of the 12-week schedule was designed to coincide with the program for maintenance activities. This schedule is then reviewed to ensure that the schedule is acceptable with respect to the risk matrix. If any questions arise during the building of the schedule, as described in Question 5(f), that are not defined in the PSA or are not clear, the SQN PSA engineer is consulted.

Question 6:

Provide the minimal cutset truncation cutoff used to quantify the plant CDT changes. In particular, indicate what efforts were made to avoid underestimation of the risk due to truncation.

Response

RISKMAN, the software used in the PSA analyses to support TS 96-08, constructs a single, large event tree by linking each successive event tree at the end of each sequence from the previous tree. In the quantification of the CDF, a sequence frequency truncation / cut-off value was employed to reduce the quantification run time to an acceptable level. For example, in imposing a frequency truncation value of 1.0E-11 on the sequence l

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l l .quantification process, a sequence will not be quantified any l further if its frequency value at any point in the quantification process is less than 1.0E-11. These sequences may or'may not lead to-core. damage at the point when their quantification process is terminated.

L The RISKMAN Program. keeps track of the number of such sequences (each with an assigned frequency value of 1.0E-11) and the sum l ' total of the' frequency value for these sequences is referred to as the unaccounted frequency. A sensitivity study was performed to. determine'the impact of changing the frequency truncation / cut-off value on the CDF of the base model. The results of the analysis are shown in the table below.

Frequency Truncation CDF per year-Value

-1.0E-10 3.9668E-05 1.0E-11 4.0339E-05 1.0E-12 =4.0577E-05 1.0E-13 4.0656E-05 Based on the results of'the above' sensitivity analysis, it was determined that the impact-on the CDF is not significant if the l frequency truncation value is 1.0E-12 or less. The change in CDF l when going from a frequency truncation value of 1.0E-12 to l 1.0E-13.is less than 0.2%, but the increase in the.run time is l substantial. Therefore, the frequency truncation value of 1.0E-12 was used in the quantification of the CDFs for all the.

other cases considered in the 7-day AOT evaluation. Sequences that were truncated are judged.to have insignificant contribution f to the CDF, and the calculated CDFs will therefore, not be underestimated due.to sequence truncation.

L In addition to the above sequence truncation criteria used in the l sequence quantification process, there is another level of .

I frequency truncation employed in.the PSA analyses._ A cutset frequency-truncation criterion was also used to limit the number of. minimum cutsets generated and to reduce the run time to an l acceptable duration during the cutset generation process. This l criterion was only imposed on the large fault tree models such as those developed for the AFW system, the EDGs, .and CCS. The

. frequency truncation value used varies from 1.0E-9 to 1.0E-15.

This implies that minimum cutsets with frequency values less than the frequency truncation.value were not retained for use in the calculation of the system unavailability. The cutset frequency truncation values used in the analyses were sufficiently small that only the minimum cutsets with very insignificant contribution to system unavailability were not retained for use inJthe calculation of the system unavailability. The cutset frequency truncation value used in the cutset generation process for the EDGs system model was 1.0E-12, and the split fraction E4-16

value for the unavailability of the four EDGs system is 2.3E-4.

Therefore, the cutset frequency truncation values used in the minimum cutset generation process of the system analysis do not result in an underestimation of the EDG unavailability split fraction.

Question 7:

Discuss your treatment of EDG common cause failure in the IPE.

Describe mechanisms which lead to common cause EDG failure to start, and failure to run.

Response

Because of the independence and separation of the individual EDGs l from one another, their are no common cause failures of the EDGs '

that are treated explicitly in the event or system models for the EDGJ. Instead, common cause failures to start and to run are accounted for implicitly using the Multi-Greek Letter (MGL) !

method (described in Section 3.3.4 of the SONIPE) for estimating '

the common cause failure factors. In this approach, industry common cause failure events were reviewed, and the events that are judged to be applicable to SON were retained and used in the development of the MGL factors for the common cause failure of two ( ), three (y), and four (S) EDGs to start and to run. These MGL factors were then used in the calculation of the failure probabilities of two, three, and four EDGs due to common causes.

The unavailability's of two, three, and four EDGs quantified in '

the IPE included contributions from the EDG common cause failures.

i Examples of mechanisms that were judged to have the potential to ;

lead to the common cause failure of EDGs to start are: I

Fuel rack binding resulting in over-crank. l

Fuel lines being valved out - misalignment of valves after fuel-filling operation.

Welding together of relay contacts due to arcing. Relays associated with the starting air system.

Examples of mechanisms that were judged to have the potential to lead to the common cause failure of EDGs to run are:

Water contamination of lube oil. Diesel tripped on high I

crankcase pressure.

-

Deterioration and subsequent failure of the speed control l spider couplings.

Loose screws on the voltage regulators, dirty switch contacts,

'and burned-out relay contacts.

l E417 i

l

Question 8:

Provide ~a discussion of the loss of offsite power (LOOP) events that have occurred at your facility. Also, provide an explanation of the data used to calculate the LOOP initiating event f requency.

Response

There has been no LOOP event at the SON site through July 1998.

This information is based on the data sources Nuclear Safety Analysis Center (NSAC)-144, NSAC-166, and plant records. In the original IPE (1992), the plant specific experience of zero events in 10.2 site years (as of December 31, 1991) was used in updating the generic LOOP frequency. The updated LOOP frequency was 5.50E-2 per calendar year. A second update of the frequency was performed in 1995 using an additional plant experience of zero events in 3.6 site years (from January 1, 1992,.through July 31, 1995), and the frequency from this update is 4.85E-02 per calendar year.

The methodology used to develop the LOOP frequency at the site is based on a two-stage Bayesian approach of incorporating plant-specific information into the generic industry data. The generic industry data for LOOP events was developed from the cumulative experience of a large population of nuclear power plants. A detailed discussion of the two-stage Bayesian approach of updating generic data with plant-specific experience is provided in the SONIPE report.

Question 9:

Explain the impact of severe weather on SBO-induced core damage and how this was addressed in the IPE.

Response

The effect of severe weather on SBO induced core damage is not explicitly accounted for in the SONREV1U. Explicitly accounting for the effects of severe weather on SBO induced core damage is expected to be negligible because the severe weather induced LOOP event initiating frequency is much lower than the normal LOOP event initiating frequency. Note that there have been no site specific. severe weather events that would provide input to the l SBO LOOP initiating frequency or input to the determination of i the likelihood of recovering offsite power.

E4-18

l anestion 10:

Discuss the impact of the AOT on accident mitigation capability, e.g., the ability to vent, isolate, or flood containment.

Response

During a phone conversation on June 25, 1998, NRC concluded that the response to this question was no longer necessary.

Question 11:

Provide a more detailed discussion of the measures taken during EDG maintenance outages to minimize Transients on the Offsite Power System.

Response

In addition to building the schedule to minimize risk (as I

described in the response to Question 5[f]), a site procedure is performed by the on-shift crew prior to making an EDG j inoperable for scheduled maintenance. This site procedure has the operators physically place "DO NOT INOP" tags on the hand switches of any component that should not be removed from service while any particular EDG is out of service. This procedure ensures that redundant equipment is operable and i verifies compliance with the requirements of TS 3.0.5 when an l emergency power source is inoperable. Also, in accordance with TSs, an SI is performed within an hour of removing a EDG from service, and every eight hours thereafter until that EDG is returned to service. This SI verifies the proper alignment of the offsite power sources. The unit SRO controls access to )

the switchyard and to the relay room at all times and limits J risk significant work activities during.a D/G outage. TVA's design and operation of the offsite power system also supports the minimization of transients. The combination of the eight 161-kV transmission lines connected to the 161-kV switchyard, the 500/161-kv intertie transformer bank, two 84 MVAR capacitor banks for the 161-kV switchyard, and the five 500-kV transmission lines yields a strong, redundant offsite power system . The two immediately available power circuits have sufficient capacity to supply the total required power to the plant's electrical auxiliary power system under normal, ;

shutdown, and loss of coolant (LOCA) conditions concurrent I with any single transmission system contingency. Two offsite power sources would also be available, even assuming a worst-case preexisting outage of one transmission system component and an additional loss of another worst-case component ;

l concurrent with a LOCA in one unit.

E4-19

___________-_____-__a

Since the evaluation for a 7-day LCO did not significantly change the PSA results, no additional measures are necessary to minimize transients on the offsite power system.

Question 12:

Provide a more detailed discussion of the measures taken during EDG maintenance outages to minimize CDF due to loss of other critical components.

Response

The SQN TSs require redundant safety-related components that are supplied by the EDGs to be operable when removing an EDG from service. If this provision cannot be satisfied, those components supplied by only an operable offsite power source, and without an operable redundant component, are considered inoperable. This condition will result in reduced action times for continued operation before requiring a unit shutdown. These TS requirements provide sufficient. limits on component availability to maintain adequate accident mitigation capability that will minimize CDF. Components that are critical to the mitigation of accidents will be verified to be available with sufficient ,

redundancy during EDG outages, in accordance with site !

procedures, as described in the response to Question 11.

These provisions, along with the actions described in the responses to Questions 5(f), 5(g), and 11, provide adequate measures to minimize CDF resulting from the loss of other ,

critical components. The results of the PSA evaluation for a l 7-day EDG action time did not require additional provisions to support the evaluation. Therefore, no additional provisions need ,

to be implemented to minimize CDF. l l

I Question 13:

Quantify the impact of the extended EDG AOT on instantaneous and !

average large early release frequencies (LERF) by calculating the change in LERT due to the proposed AOT. Provide your definition of LERT, an explanation of this inpact, and the initial and final values of LERT which are inputs into the change in instantaneous and average LERT.

FA-20

Response.

The large early release frequency (LERF) definition used in the PSA analysis is consistent with the definition used in the SQNIPE. Four groups of release categories were defined in the SONIPE to more easily interpret the results. All release categories that are assigned to Groups I and II are included in the definition of LERF used in this analysis. Group I sequences involve a large early release resulting from containment failure or large bypasses, while Group II release categories. Each involve a small, early release resulting from containment failures or small bypasses. Containment failure resulting from the alpha-mode, direct impingement of debris on the containment wall following high pressure melt ejection, and interfacing systems LOCA events are included in the Group I release categories. Steam generator tube rupture events that are coincident with a stuck open secondary side relief valve and resulting in core damage are assigned to Group II of the release categories, therefore, they are included in the LERF total.

The definition used for LERF may be conservative relative to that proposed later in the PSA Applications Guide (i.e., EPRI l TR-105396, August 1995). The PSA Applications Guide proposes that sequences only be assigned to LERE if the releases are unscrubbed. Some portion of the sequences assigned to LERF for this analysis may in fact involve scrubbing, therefore, it is conservative with respect to LERF. This conservatism in the definition used for LERF was not evaluated for this analysis.

The key plant damage states were input as initiating events and the containment event tree was run separately for each one. The frequencies of the key plant damages state were input as the initiating event frequency input into the containment event tree for quantification.

The release category frequencies were summed to obtain the LERFs for each quantification case. The release categories included in the summation were those listed in Table 4.9-2 of the SONIPE submittal that are assigned to major release Groups I and II.

The results of the LERF calculations are shown in the table l below- l l

Cases LERF per year Base Case (171 4.45E-06 hours /EDG-year) 72-hour AOT (291 4.50E-06 hours /EDG-year) 7-day AOT (387 4.54E-06 hours /EDG-year) 3 E4-21 a-_

L I Zero Maintenance Base 4.20E-06 Case L EDG 1A in Maintenance 5.30E-06 The increase in the LERF from the base case for the 72-hour AOT case is approximately 5.0E-08 per year (or about a 1% increase in LERF over the base case), and the increase in the LERF from the base case for the 7-day AOT case is approximately 9.0E-08 per year-(or a about a 2% increase in LERF over the base case).

These increases in LERF are nonrisk-significant. The instantaneous change in LERF from the zero maintenance case when an EDG is removed from service for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 7 days is 9.03E-9/ year and 2.10E-8/ year, respectively.

Question 14:

Have you thoroughly reviewed your TS to see if there are needs for any other changes to your TS or TS bases (in addition to the TS amendment items you are currently requesting) due to your request of EDG extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 7 days? Please identify any TS changes made to ensure that the plant will not enter a known risk-significant plant configuration while in the A0T.

Response

TVA revised the original TS change request, in accordance with NRC's request in Question 15 of the RAI, such that a permanent 7-day action is implemented for inoperable EDGs of the same train. This revised request includes all portions of the TSs and the associated bases that are required to be revised considering the results of the reanalysis of plant risk for a 7-day EDG AOT.

This revision will not require the revision of TS requirements other than the EDG specification because the analysis did not identify new risk-significant plant configurations. Additional changes are included in this revised request to address the deletion of TS reporting requirements related to accelerated i

testing of EDGs. These deletions could have been pursued as part j of the original change request, but were overlooked. NRC has already approved the portion of the original request that removed the EDG accelerated testing requirements and this additional ,

I l change will only serve to fully implement the revisions of sections associated with that change, i i

The current practice of not protecting specific equipment or implementing compensatory measures during EDG outages will continue to be acceptable. This is based on acceptable SON analysis results without utilizing any special conditions while considering a 7-day AOT for an inoperable EDG or inoperable EDGs E4-22

l in the same train. Since the analysis has not identified any new risk-significant plant configurations, there are no other TS requirements or bases that will require revision to support or implement a 7-day EDG AOT.

Question 15:

The change request proposed changing the EDG allowed outage time to seven days once per 18 months. The current staff position is i to not make such changes on a "once per" bases but to evaluate requested changes on a one-time or a pexmanent basis. Resnhm4t the change request to state the EDG AOT as seven days (either one-time or permanently) and make appropriate changes to the bases section of the technical specifications.

Response

TVA revised TS Change Request 96-08 to propose a permanent 7-day AOT to TS 3.8.1.1, Action b, for the inoperability of one EDG or one train of EDGs. This change is an extension of the current 72-hour LCO action time to a 7-day AOT. The revised change also deletes the current footnote that provides a 72-hour extension of this action for cleaning activities of the fuel oil storage tank.

This note will not be necessary after implementation of the 7-day AOT. These changes are included in Enclosures 2 and 3 of this submittal. The associated bases changes have been included as appropriate.

Other changes are incorporated into this request to fully implement the deletion of accelerated testing of the EDGs as approved by NRC on July 14, 1997. This includes the deletion of reporting requirements associated with EDG reliability and the annual EDG reliability report. These reporting requirements are not necessary because implementation of the Maintenance Rule, in :

accordance with 10 CFR 50.65, controls the EDGs such that acceptable EDG reliability is maintained or appropriate corrective actions are taken. The proposed change also deletes License Condition, 2.C.(15) for Unit 1 and 2.C.(12) for Unit 2, associated with the implementation of EDG design and procedure )

modifications that are no longer applicable. This License l

Condition was satisfied prior to operation following the first refueling outage of each unit and has no remaining actions

~

applicable to SON.

l l E4-23 i

I L _ . . _ _. _ _ . _ _ _ _

l Question 16:

The staff is aware that a spare diesel has been installed at Sequoyah but_has never been made operational. Bas consideration

been given to completing installation of this diesel and qualifying it as an alternate AC source as an option per the SBO rule?

Response

A separate diesel structure was built and a fifth diesel was partially installed in the early 1980's at Sequoyah. The fifth diesel building was constructed adjacent to the structure housing the four currently qualified EDGs. The original design concept of the fifth diesel was to provide an alternate qualified power source that could be manually connected to any of the four 6.9-kV shutdown boards as a fully qualified replacement in the event that an EDG outage exceeded 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, due to technical concerns about the design qualification of the interface between the fifth EDG set and the shutdown boards and the cost associated I

with resolving this issue and completing the modification, construction was halted and the modification closed out.

Although some consideration has been given over the succeeding years to completing the modification, the fifth EDG upgrade is not currently on the SON long-range project plan. SON does not anticipate completing the installation of the fifth EDG because of the technical problems and resolution cost and the current condition of the fifth EDG (the fifth EDG has not been maintained and has been used as a source of replacement parts).

l l

1 i

E4-24 i

I l

L _ _ _______ _

Table 1 Diesel Generator 1A-A (Planned) 1 Date Duration Description

.Jan 95 4.33 hrs Cleaning of EDG 480V auxiliary power boards.

Feb 95 44.3 hrs Cleaning of EDG 480V auxiliary power boards.

Mar 95- 0.17 hrs Surveillance testing.

May 95 -32.62 hrs 18-month mechanical maintenance outage.

-Jul 95 0.13 hrs Surveillance testing.

Nov 95 0.17 hrs Surveillance testing.

Dec.95 0.55 hrs Engine roll prior to testing.

Jan 96 20.08 hrs Engine roll prior'to testing (0.043hr) and scheduled monthly outage (19.65hr).

Feb 96 -37.74 hrs Scheduled monthly outage (11.48hr) 18-month electrical inspection / testing (26.26hr).

Mar l96 0.85 hrs Engine roll prior to testing.

Jun 96 1.15 hrs Engine roll prior to testing.

Sep 96 0.4 hrs Engine roll prior to testing.

Oct 96- 6.1 hrs Battery discharge testing'.

Jan 97 0.3 hrs Engine roll prior-to testing.

Feb'97 64.3 hrs 2-year and 4-year mechanical outage (see Note a).

Apr 97 0.98 hrs- Engine roll prior to testing.

Jul 97 0.233 hrs Engine roll prior to testing.

Aug 97 0.1 hrs Engine roll prior to testing.

Sep 97 0.95 hrs Engine roll prior to testing.

Oct 97 0.25 hrs Engine roll prior to testing.

Dec 97 5.217 hrs Battery discharge test (4.8 hrs) and engine roll-prior to testing (0.417 hrs).

Note a: Engine internal inspections and maintenance per the manufacturer recommendations; instrument calibrations; replace worn. parts; replace cylinder power assembly; perform generator winding DC resistance measurements; j inspect ERCW check valves and engine heat exchangers. j TI-l

L F Table 2-Diesel Generator 1B-B (Planned)

'Date . Duration Description Feb 95 25.1 hrs Cleaning 480V diesel auxiliary boards.

Marl 95 0.42 hrs Surveillance testing.

Apr 95 8.28 hrs Monthly maintenance outage.

May 95 27 hrs' -Monthly maintenance outage-(Note: Hours continued into June 1995).

Jun 95- 5.6 hrs Monthly maintenance outage (Note: Hours continued from May 1995).

Aug 95 0.8 hrs Engine: roll prior to testing.

Jan 96 35.5 hrs Monthly maintenance outage, replace emergency start relays, and replace hoses.

Feb 96 30.88 hrs Scheduled maintenance for 18-month electrical inspections and replace hoses.

Apr 96 -5.69 hrs Replace servo boosters on engine governor / actuators.

Jun 96 0.43 hrs Engine roll prior to testing.

Sep 96 3.33 hrs. Battery discharge testing.

Oct 96 0.1 hrs Engine roll prior to testing.

Nov 96 0.4 hrs Engine roll prior to' testing.

Dec 96 0.5 hrs Engine roll prior to testing.

Jan 97 45.8 hrs 2-year and 4-year mechanical outage (See Note a).

=Feb 97 'O.6 hrs Engine roll prior to testing.

Jun'97 0.033 hrs Engine roll prior to testing.

Jul 97 1.716 hrs Engine roll prior to testing.

Oct 97 0.017 hrs Engine roll prior to testing.

Nov 97 9.633 hrs Battery. discharge test and lockout feature verification testing.

Dec'97 0.183 hrs Engine roll prior to testing.

Note a: Engine internal inspections and maintenance per the !

manufacturer recommendations; instrument calibrations; replace worn parts for preventative maintenance; replace air compressor, 1B2 air pressure regulator pilot valve and receiver tank pressure relief valves; perform generator winding DC resistance measurements; inspect ERCW check valves and engine heat exchangers.

b 12-1

t Table 3 Diesel Generator 2A-A ' (Planned)

Date Duration Description Jan 95 0.73 hrs Surveillance testing (0.08 hrs), surveillance testing (0.20 hrs), _ surveillance testing (0.23 hrs), and surveillance testing (0.17).

(Note: 0.05 hrs appears to be a mathematical error).

Feb 95 29,8 hrs Cleaning of 480V diesel auxiliary boards.

Mar 95 2.39 hrs Replace a fuel oil line.

May 95 52.82 hrs Scheduled 2-year and 4-year mechanical outage.

Jun 95 27.2 hrs Power assembly replacement.

Aug 95 1.15 hrs Surveillance testing (0.97 hrs) and surveillance testing (0.18 hrs).

Dec 95- 0.42 hrs Engine roll prior to testing.

Jan 96 2.17 hrs Battery discharge test (2 hrs) and surveillance testing (0.17 hrs).

Feb 96 40.67 hrs 18-month electrical surveillance and replace hoses.

Mar 96 0.39 hrs Engine roll prior to testing (0.27 hrs) and surveillance testing (0.12 hrs).

Apr 96- 11.82 hrs Replace governor / actuator servo booster

.(11.72 hrs) and engine roll prior to testing (0.1 hrs).

Sep 96 .3.68 hrs Battery discharge test.

Oct 96 1hr Engine roll prior to testing.

Feb.97 50.7 hrs- Repair of generator pigtails.

Mar 97 31.2 hrs 2-year and 4-year mechanical outage (see Note a).

Jul 97 1.6 hrs Engine roll prior to testing and surveillance testing.

Aug 97 2.283 hrs Engine roll prior to testing.

Sep 97 1.07 hrs Engine roll prior to testing.

Nov 97 6.75 hrs Battery discharge test and lockout feature i

verification testing.

Note a: En'gine internal inspections and maintenance per the manufacturer recommendations; instrument calibrations; i L replace worn parts for preventative maintenance; cleaned 125-V DC battery.

i D*I

_ _ _ _ . _ _ _ _ _ _ _ _ ______-_-_____a

i -

Table 4 Diesel Generator 25-B (Planned)

Date Duration Description Feb 95 34.4 hrs Cleaning of EDG 480V' auxiliary boards.

May 95 58.41 hrs Scheduled 2-year and 4-year. mechanical outage (see Note a).

Jul 95 0.7 hrs Engine roll prior to testing.

Oct 95 0.6 hrs Engine roll prior to testing.

Nov 95 .0.53 hrs Surveillance testing. j Jan 96 31.75 hrs Monthly maintenance outage and replace hoses. j Feb 96 22.12 hrs Monthly maintenance outage.

Apr 96 -7.32 hrs Governor / actuator servo booster replacement.

Jun 96. 0.67 hrs Engine roll prior to testing.

Oct 961 4.6 hrs Battery discharge testing.

Nov 96 0.7 hrs Engine roll prior-to testing.

Jan 97 46.7 hrs 2-year and 4-year mechanical outage (See Note b).

May 97 11.43 hrs Battery discharge test.

Jul 97 0.133 hrs Engine-roll prior to. testing.

Sep 97- 21.05 hrs Replace governor actuators.

Octl97 0.833 hrs Engine roll prior to testing.

Nov 97- 3.9 hrs Lockout feature verification testing Note a: EDG 2B-B tripped on high crankcase pressure during an.

idle start for a maintenance outage functional test.

The pressure switch had drifted out of calibration and could not be recalibrates. The trip from this pressure switch is isolated during emergency mode operation, ,

therefore, it would not have prevented the EDG from performing its design function.

Note b: Engine internal inspections and maintenance per the manufacturer recommendations; instrument calibrations; :

replace worn parts for preventative maintenance; I replace air compressor and receiver tank pressure i relief valves; perform generator winding DC resistance ,

measurements; inspect ERCW check valves and engine heat exchangers. _

i l

T4-1

Table 5 Diesel Generator lA-A (Unplanned) l Date Duration Description Oct 95 0.0 hrs Invalid Failure - Generator tripped during TS surveillance testing (see Note a).

! Feb'96 12.34 hrs Valid Failure - Air boost cylinder failure during maintenance testing activity (see Note b).

Mar 97 0.0 hrs Invalid Failure - DR relay failure _during TS surveillance testing (see Note c).

May 97 49.55 hrs Invalid Failure - Generator output voltage increased to approximately 9000V AC during Surveillance Testing. Most likely cause identified to be high resistance on 86 LOR relay contacts (see Note d).

Note a: EDG 1A-A tripped while being loaded to 110 percent of l its rated load as required by SON TS SR 4.0.1.1.2.d.7.

l The trip was initiated by the Phase Imbalance (46)

Relay. The relay had been replaced approximately one i year earlier and the new relay's setpoint drifted. The trip capability of this relay is isolated during emergency mode operation, therefore, it would not have prevented the EDG from performing its design function (no unavailability hours assigned - unit in Mode 5).

Note b: The starting air system to the 1A2 engine air starters was isolated (off normal) as part of a maintenance o testing activity, in accordance with 0-SO-82-1, to l prove the integrity of the 1A1 engine air starters, j Neither air boost cylinder appeared to raise the fuel l rack and with only half of the normal starting torque, l- EDG 1A-A failed to develop adequate actuator pressure l to raise the fuel rack before the engine failure timer actaated. The air boost cylinder of each engine was replaced and EDG 1A-A was successfully tested.

1 l

T5-1

l- Table 5 l- .(continued).

Note c: During.the performance of 1-SI-OPS-082-026.A, EDG 1A-A

,was paralleled to the grid and-loaded to approximately 4840 kW and 2.4.MVAR. .Following-auvery short time frame'into the. test,Ean odor ~of heated electrical

' insulation was detected. Visual inspection revealed smoke trailing.from the reset coil of the droop relay (DR). EDG 1A-A was removed from serviceJfor-troubleshooting / repair. The performance of 1-SI-OPS-082-026.A was' continued following replacement of the DR and-the. associated-postmaintenance test.

The DR is. utilized to place the generator voltage regulator in the unit mode (operate position of the DR) or droop mode (reset position of the DR) . The emergency' mode for the relay is in the operate position. The DR is a Westinghouse Electric

< Corporation MG-6 auxiliary relay. Visual inspection of the-installed DR revealed. heavy oxidation on the edge of the latch plate and the shoulder of the latch screw resulting in the required reset force to' exceed the

' capability of the reset coil.

The EDG would have performed'its intended safety function since the operate; position of the DR is the-emergency mode.and does not require the' reset coil to !

achieve ~the operate position-(no unavailability hours assigned - unit in Mode 5).

Note d: During performance of 1-SI-OPS-0Bz-vu7.A, when the 86 LOR was reset, the generator output voltage increased to approximately 9000V AC. When the 86 LOR is in the ;

tripped (emergency) state, a Voltage Overshoot Reduction Device (VORD) 'is connected to the generator field circuit to suppress high excitation during !

l transient conditions by clipping the excitation ;

voltage. I r

Preliminary troubleshooting did not reveal any problems I with the voltage regulator or 86 LOR. Since electronic devices can operate intermittently providing similar problems, the voltage regulator card was replaced.

T5-2 l

u _-- _ _ _ _ _ _ - - . . - _ .-_ -- - - - - -_ _u

Table 5 (continued)

The original voltage regulator card was returned to the vendor (Bassler Electric Company) for testing. The vendor identified no deficiencies on any component on the card. The most likely cause of the high voltage was determined to be high resistance on the 86 LOR contact associated with the voltage regulator Motor Operated Potentiometer (MOP) circuitry since no other problems were identified. The contact high resistance would have been unknowingly corrected during troubleshooting activities because of multiple operations of the 86 LOR.

During subsequent monthly surveillance testing, the voltage regulator control current has been observed by the system engineer to be in the range of 1.0 to 2.5 Amps while the 86 LOR is in the tripped (emergency) j state. This observation confirms that the voltage {

regulator is operating properly with the VORD enabled.

Sased on the vendor evaluation of the voltage regulator card and adequate output voltage while the 86 LOR was tripped, the EDG would have performed the intended safety function.

i 1

i l

T5-3

Table 6 Diesel Generator 1B-B (Un-Planned)

Date' Duration Description Jun~95 2 hrs Invalid Failure - EDG 1B-B valid. test stopped due to' field ground (64) relay sticking (see Note a).

Apr 97 -51.25 hrs Invalid Failure - EDG 1B-B tripped during monthly TS surveillance testing due to start

' bus breaker problem (see Note b).

Note a: EDG 1B-B valid test was stopped to allow investigation of a field ground (64) relay actuation. This relay has a low threshold and actuated momentarily during-field flashing. Check out of the relay identified.the relay to be sticking. The relay was cleaned, calibration checked, and returned to service. This relay does not provide a trip signal (annunciation only), therefore, l

it would not have prevented the EDG from performing its design function.

Note b: During-the monthly performance of 1-SI-OPS-082-007.B, the EDG tripped on a phase imbalance relay operation while increasing' load. Troubleshooting checked the setting of the phase imbalance relay and the integrity of the emergency feeder breaker to 6.9-kV Shutdown Board 1B-B, EDG control functions, generator stator windings, and generator excitation system with no l problems identified. EDG lB-B was paralleled to 6.9-kV Shutdown Board 1B-B and the load applied in small i incremental values to approximately 4200 kW without tripping. j Based on the successful operation of EDG 1B-B with the incremental loading technique, EDG 1B-B was again paralleled to 6.9-kV Shutdown Board 1B-B and the load l increased using similar ramp rates as utilized in 1-SI-l . OPS-082-007.B with no problems identified. EDG 1B-B was declared operable based on the proven loading

( capability and successful performance of 1-SI-OPS-082- ,

L 007.B with no problems identified with any aspect of j l the EDG. !

i i

l l !

l TG1 I i i

l Table 6 I (continued)

The following day a voltage balance problem was identified on several of the plant auxiliary AC boards.

The problem was determined to be a single phase condition on 6.9-kV Start Bus Breaker 1614, which is j the alternate supply for 6.9-kV Start Bus lA. The {

6.9-kV Start Bus 1A was transferred to Breaker 1514 and I the voltage balance problem was corrected. Visual inspection of the main and auxiliary contacts on Breaker 1614 revealed indications of excessive overheating on two of the three poles. )

The EDG would have performed the intended safety function since the defective breaker is not included in the emergency power supply system.

l TG2

L 1

Table 7 Diesel Generator 2A-A (Unplanned)

Date Duration- Description Jul 95 1.78 hrs Problem with a check valve in the lube oil.

line to turbocharger.

Sep 95 4.81 hrs Head crab. nut retorqueing due to M&TE out of calibration.

Oct.95 5.3 hrs Invalid Failure - EDG 2A-A valid test terminated prior to a one-hour loaded run due to relay binding (see Note a).

Feb 96 1.48 hrs Invalid Failure - EDG 2A-A 86GA lockout relay actuation when trip coil indicating lamp blew (see Note b).

Feb 97 37.2 hrs Valid Failure - governor / actuator failure (see Note c).

Mar 97 4.75 hrs- Repair oil leak on engine 2A2 governor / actuator.

'Jul 97 54.15 hrs Valid Failure - Stator Winding failure (see Note d) .

Sep.97 1.5 hrs Adjust 2301A governor card.

Note a: EDG 2A-A was stopped prior to completing its one-hour loaded run to allow investigation of why voltage had appeared while in the 5-minute idle warm-up p0riod.

The test was stopped, not due to the inability of the-diesel to continue with the run, but to minimize the LCO~ time for the diesel. Troubleshooting and evaluation of the circuit identified that a relay binding problem prevented the exciter' field from being shunted. The relay binding would not have affected emergency mode operation, therefore, it would not have prevented the EDG from performing its design function.

Note b: EDG 2A-A experienced an actuation of its 86GA lockout relay when the associated trip coil indicating lamp burnt out. An instrument mechanic saw a flash immediately before the click (actuation) of the 86GA relay. The condition enunciated locally and in the MCR. No protective relaying flags were found dropped and the lamp in series with the 86GA relay was found to be burnt out. The lamp was theorized to have blown and a filament piece landed against the energized filament supports. The shorter filament length allowed adequate current to pass' (before burning up) to actuate the 86GA

-relay, locking out the EDG. This event was not counted l

T7-1 u________________________________

Table 7 (continued) as a failure based on: (1) The event being an enunciated condition (not a hidden failure found during maintenance or during a start attempt), and (2) the event would not have prevented the emergency diesel from being started and brought to load within a few minutes (i.e., without corrective maintenance or significant problem diagnosis), if needed. This capability would require an operator to be dispatched to the EDG and manually reset the 86GA relay.

Note c: During approximately the last 30 minutes of the postmaintenance test of a 4840-kW, 2-hour load run, the Governor Actuator Difference Alarm initiated repeatedly and the Woodward governor actuator on engine No. 2 appeared sluggish. Troubleshooting confirmed sluggish response of the actuator on engine No. 2 as it approached normal operating temperature. A failure analysis by the vendor identified a blister on the inside surface of the pilot valve's positioning coil.

The reduced clearance caused by the blister resulted in high frictional forces, causing the sluggish actuator response. The vendor determined the likely root cause of the blister was an exposure of the coil circuit to a high voltage spike.

Because System Engineering could not identify how the circuit could have been exposed to high voltage, the defective coil was sent for additional analysis to Failure Prevention International (FPI). FPI performed a root cause analysis for TVA-SON to determine what

{

caused the blister on the pilot valve positioning coil. !

FPI determined that the probable cause was a small void that formed during manufacturing. Over a period of q time, oil intrusion into the void with heating / cooling j cycles from equipment operation resulted in separation of the potting compound from the pilot valve positioning coil and reduction of the internal diameter of the pilot valve positioning coil. The findings ,

concluded the most probable cause for the blister on the internal diameter of the pilot valve positioning coil was defective workmanship in the application and l subsequent adhesion of the potting compound to the l pilot valve positioning coil. Research into FPI files and other databases did not reveal any similar f occurrences that were documented. FPI recommended the i

}

failure be considered an isolated event.

l T7-2 1

_a

Table 7 (continued)

The EDG could have failed to deliver its rated electrical load due to overloading of engine No. 1 if the actuator pilot piston had bound in low power position on engine No. 2. The EDG was delivering 110 of its continuous rating without exceeding the cylinder or turbocharger exhaust temperature limits at the time of discovery. However, remaining within the bounds of the cylinder and turbocharger exhaust temperature, limits could not be guaranteed for a postulated accident.

Note d: During the performance of 2-SI-OPS-082-007.A, the EDG tripped on Device 50 (instantaneous overcurrent) and 87 (current differential) relay operation 24 minutes into the loaded run at 4050 kW. Troubleshooting revealed a fault had occurred between an A-phase series electrical connection and a C-phase line side terminal connection.

The fault was directly attributed to inadequate installation of support ties during the pigtail cable replacement on EDG 2A-A in February 1997, and is considered a Maintenance Preventable Functional Failure. The EDG would have tripped and locked out on the differential relay operation had this winding failed during a postulated accident.

i l

l T7-3 l

Table 8 Diesel Generator 28-B (Unplanned)

Date Duration Description Feb 95 25 hrs Invalid Failure - 2B-B valid test stopped on low lube' oil pressure annunciation (see Note a).

JanH96 3.25 hrs EDG 2B-B was manually tripped open by Operations to prevent the EDG from overloading during a maintenance run as a result of problems associated with the EDG 2B-B's governor gain.and reset adjustment (see Note b).

May 97- 1.73 hrs Replaced battery cell and low jacket water temperature switch.

Jun 97 34.717 hrs Invalid Failure - EDG 2B-B tripped on instantaneous overcurrent (see Note c).

Note a: EDG 2B-B valid test.was emergency stoppec prior to

-loading for the'one-hour run due to a low-lube oil pressureLannunciation. The pressure switch had drifted out of calibration and could not be recalibrates. The trip from_this pressure switch is isolated during emergency mode operation, therefore, it would not have prevented the EDG from performing its design function.

Note b: The emergency breaker.for EDG 2B-B was manually tripped open by Operations to_ prevent the EDG from overloading during a maintenance run. This condition was determined to be associated with EDG 2B-B's governor gain and reset adjustment. While EDG 2B-B governor gain and reset adequately met voltage-and frequency requirements for load sequencing during 2-SI-OPS-082-026.B testing, it allowed a type of " reset windup" to develop when ramping up to. rated load in a single step under droop mode operation. The gain and reset values for the governor were adjusted to correct this condition. Testing indicated this condition existed on the other EDGs as well, but to a lesser degree and did not require adjustment. Based on this having no impact on.the asynchronous operation, and the safety functions of the_EDG, this event was determined to be an invalid failure.

T8-1

l Table 8 (continued)

Note c: EDG 2B-B emergency feeder breaker tripped on Instantaneous Overcurrent (IOC) relay operation at the instant when EDG was paralleled to 6.9-kV Shutdown Board 1B-B during performance of 1-SI-OPS-082-007.B.

The IOC relay setpoint is adjusted to actuate at 600-Amps primary. The problem was determined to be :

inadequate instructions provided to the operator. If the EDG is paralleled to the 6.9-kV Shutdown Board at ,

5 minutes before the 12 o' clock position, the inrush )

current detected by the IOC relay is in excess of the !

600-Amp setpoint. The instructions for the OAC have j been revised to require the initiation of the breaker i closure signal at approximately the 12 o' clock position !

on the synchroscope. '

The EDG would have performed the intended safety function since the IOC relay is not active in the control circuits when the EDG is in the emergency mode and the EDG runs in the asynchronous mode during an accident condition.

T8-2

Table 9 Risk Achievement Worth Importance (By Top Event)

TOP EVENT

SYSTEM RISK ACHIEVEMENT WORTH 171 291 387 171 291 387 171 291 387 HE HE HE ERCW ERCW ERCW 2784.5366 2747.7000 2712.2769 RT RT RT CRDM CRDM CRDM 972.6476 956.1700 940.9827 AE AE AE ERCW ERCW ERCW 954.1228 941.5200 930.1437 AA AA AA 6.9KV SD 6.9KV SD 6.9KV SD 528.4749 520.6600 513.3159 BD PWR BD PWR BD PWR RW RW RW RWST RWST RWST 390.1651 385.0100 380.0401 AF AF AF AFW AFW AFW 346.1224 341.6000 337.3098 RR RR RR SIS SIS SIS 138.5251 136.7100 134.9562 Al Al A1 480V SD 480V SD 480V SD 117.7532 116.3300 114.9506 BD PWR BD PWR BD PWR RL RL RL SIS SIS SIS 117.7289 116.1700 114.6738 B1 B1 B1 480V SD 480V SD 480V SD 117.4531 116.0300 114.6573 BD PWR BD PWR BD PWR SO SU SU CONT SUMP CONT SUMP CONT SUMP 111.9710 110.4900 109.1027 DE DE DE ERCW ERCW ERCW 108.1305 107.3300 106.0564 CE CE CE ERCW ERCW ERCW 100.1348 98.9420 97.7846 BA BA BA 6.9KV SD 6.9KV SD 6.9KV SD 91.2459 90.2930 89.3987 BD PWR BD PWR BD PWR DB DB DB 125V DC 125V DC 125V DC 90.5142 89.5900 88.7027 PWR PWR PWR BE BE BE ERCW ERCW ERCW 81.3790 80.3200 79.2993 GE GE GE ERCW ERCW ERCW 77.2938 76.2720 75.2880 V3 V3 V3 AFW/CCS AFW/CCS AFW/CCS 76.1526 74.3870 72.8271 AREA VENT AREA VENT AREA VENT DA. DA DA 125V DC 125V DC 125V DC 73.1791 72.4870 71.8230 PWR PWR PWR SE SE SE RCP SEALS RCP SEALS RCP SEALS 62.3935 61.5820 60.8003 AC AC AC CCS CCS CCS 47.1305 46.5200 45.9378 EE EE EE ERCW ERCW ERCW 34.3823 33.9280 33.4915 RF RF RF SIS SIS SIS 15.8549 15.6580 15.4695 MA MA- MA AFW AFW AFW 12.0515 11.9160 11.7871 PR PR PR RCS RCS RCS 11.9545 11.8100 11.6702 CL CL CL SIS SIS SIS 11.2864 11.1500 11.0195 MB MB MB AFW AFW AFW 11.2597 11.1360 11.0168 V1 V1 V1 SD BD RM SD BD RM SD BD RM 9.6203 9.5055 9.3950 VENT VENT VENT RVA RVA RVA SIS SIS SIS 7.5208 7.4344 7.3511 DS DS DS MAIN MAIN MAIN 6.8012 6.7229 6.6477 STEAM STEAM STEAM l

RH RH RH SIS SIS SIS 6.1603 6.0921 6.0264 LCL LCL LCL RHR RHR RHR 6.1536 6.0854 6.0199 l RA RA RA RHR RHR RHR 5.8181 5.7551 5.6964 RRL RRL RRL RHR RHR RHR 5.5798 5.5193 5.4610 T9-1

Table 9 Risk Achievement Worth Importance (By Top Event)

TOP EVENT

SYSTEM RISK ACHIEVEMENT WORTH 171 291 387 171 291 387 171 291 387 PD PD PD STATION STATION STATION 5.5750 5.5145 5.4563 CONTROL CONTROL CONTROL AIR AIR AIR RVB RVB RVB SIS SIS SIS . 5.3699 5.3120 5.2561 MU MU MU MAKEUP TO MAKEUP TO MAKEUP TO 5.2332 5.1772 5.1233 RWST RWST RWST BC BC BC CCS CCS CCS 5.0286 4.9761 4.9224 AB AB OG 6.9KV SD 6.9KV SD OFFSITE 4.2333 4.1781 4.1685 BD PWR BD PWR POWER TP OG AB AFW OFFSITE 6.9KV SD 3.2474 3.7661 4.1248 POWER BD PWR B2 TP TP 480V SD AFW AFW 3.1636 3.2430 3.2455 BD PWR OG B2 B2 OFFSITE 480V SD 480V SD 2.9844 3.1346 3.1066 POWER BD PWR BD PWR B2U2 DC DC 480V SD 125V DC 125V DC 2.5989 2.5932 2.6457 BD PWR PWR PWR DC B2U2 FA 125V DC 480V SD FUEL OIL 2.5844 2.5651 2.5385 PWR BD PWR DCAC DCAC B202 120 VAC 120 VAC 480V SD 2.4894 2.4830 2.5330 VITAL VITAL BD PWR INST BD INST BD FE FA DCAC ERCW FUEL OIL 120 VAC 2.3521 2.3812 2.4833 VITAL INST BD RB FE RB RHR ERCW RHR 2.3305 2.3215 2.2994 FA RB FE FUEL OIL RHR ERCW 2.2628 2.3136 2.2924 EB EB GB CVCS CVCS DIESEL 2.1830 2.1674 2.1540 GENERATOR EB CVCS 2.1523 l

l'

see Table 10 for descriptions of Top Events.

T9-2

TABLE 10 TOP EVEMf DESCRIPTIONS TOP EVENT DESCRIPTION HE ERCW DISCHARGE HEADER-B VALVES RT REACTOR TRIP AE ERCW TRAIN A PUMPS AA 6.9-kV SHUTDOWN BOARD 1A-A RW RWST AF AFW DISCHARGE TO STEAM GENERATORS RR RHR SWITCHOVER FROM RWST TO CONTAINMENT SUMP Al 480V SHUTDOWN BOARD 1Al-A RL RWST AND CONTAINMENT WATER LEVEL SIGNALS ,

B1 480V SHUTDOWN BOARD 1B1-B '

SU CONTAINMENT SUMP DE ERCW TRAIN 1B CE ERCW TRAIN 1A BA 6.9-kV' SHUTDOWN BOARD 1B-B DB 125V DC BUS II BE ERCW TRAIN B PUMPS GE ERCW DISCHARGE HEADER-A VALVES V3 ,

CCS & AFW PUMP AREA COOLING DA 125V DC BUS I SE RCP SEAL INJECTION AC CCS TRAIN 1A EE ERCW TRAIN 2A '

RF 3/3 COLD LEG INJECTION PATHS (LOCA)

MA AEW PR RCS PRESSURE RELIEF l CL 2/3 COLD LEG ACCUMULATORS (MEDIUM LOCA)

MB AEW j V1 U1 SHUTDOWN BOARD VENTILATION

! RVA RHR TRAIN A SWAPOVER VALVE, FCV-63-72 DS SECONDARY COOLDOWN AND RCS RELIEF i RH RHR HOTLEG RECIRCULATION

! LCL 3/3 COLD LEG ACCUMULATORS (LARGE LOCA)

RA RHR PUMP 1A RRL SUMP RECIRCULATION (LARGE LOCA)

PD CONTROL AIR RVB RHR TRAIN B SUMP SWAPOVER VALVE, FCV-63-73 MU MAKEUP TO RWST BC CCS TRAIN B AB ij.9-kV SHUTDOWN BOARD 2A-A TP AFW B2 480V SHUTDOWN BOARD 1B2-B OG 161-kV LOSS OF OFFSITE POWER B2U2 480V SHUTDOWN BOARD 2B2-B T10-1

TABLE 10 TOP EVENT DESCRIPTIONS DC 120V AC INSTRUMENT BUS I DCAC 120V VITAL INSTRUMENT BOARD 1-III FE ERCW TRAIN 2B RB RHR PUMP TRAIN B FA U1 TRAIN A FUEL OIL EB EMERGENCY BORATION GB DIESEL GENERATOR 1B-B FB U1 TRAIN B FUEL OIL l

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T10-2

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