ET 22-0012, Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating

Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating

ML22193A323
Person / Time
Site:	Wolf Creek
Issue date:	07/12/2022
From:	Boyce M Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 22-0012
Download: ML22193A323 (39)

Text

{{#Wiki_filter:W o If Cree k...,"Ui'iil'U-Nuclear Operating Corporation

Michael T. Boyce Vice President Engineering July 12, 2022 ET 22-0012

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

1) Letter ET 21-0004 dated September 29, 2021, from S. L. Smith, WCNOC, to USNRC, License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, "AC Sources -Operating"

2) Electronic mail dated February 23, 2022, from S. A. Lee, USNRC, to J. Turner, WCNOC, "Request for additional information -Wolf Creek request to revise diesel generator completion time (EPID: L-2021-LLA-0173)"

3) Letter ET 22-0005 dated April 13, 2022, from M. T. Boyce, WCNOC, to USNRC, Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, "AC Sources -Operating"

Subject:

Docket No. 50-482: Supplement to License Amendment Request

- Diesel Generator Completion Time Extension for Technical Specification 3.8.1, "AC Sources -Operating"

Commissioners and Staff:

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application for an amendment to the technical specifications (TS) for the Wolf Creek Generating Station (WCGS). The proposed amendment would modify WCGS TS 3.8.1, "AC Sources -Operating," by removing requirements associated with the Sharpe Station gensets and extend the Completion Time for one inoperable diesel generator (DG) from 72 hours to 14 days based on the availability of a supplemental power source (i.e., Station Blackout DG System). Reference 2 provided a request for additional information (RAI) related to the license amendment request. Reference 3 provided WCNOC's response to the RAI.

P.O. Box 411 I Burlington, KS 66839 I 620-364-8831 ET 22-0012 Page 2 of 3

Further review of the TS Condition C changes provided in Reference 3 determined that additional changes to Condition C are necessary. Attachment I provides supplemental information associated to the response to RAI EEEB-1. Attachment 11 contains proposed markups of WCGS TS 3.8.1 which supersede the TS markups provided in Reference 1 and Reference 3. Attachment Ill provides revised (clean) TS pages which supersede the revised TS pages in Reference 1. Attachment IV contains proposed markups of the WCGS TS 3.8.1 Bases (for information only) which supersede the TS Bases markups provided in Reference 1 and Reference 3.

The information provided in this submittal does not expand the scope of the application and does not impact the significance hazards consideration determination presented in Reference 1. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," Section (b)(1), a copy of this amendment application is being provided to the designated Kansas State official.

The letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-8831 x8687, or Ron Benham at (620) 364-4204.

Sincerely,

Michael T. Boyce

MTB/

Attachment I: Supplemental Information Associated to the Response to RAI EEEB-1 Attachment II: Revised WCGS Technical Specification 3.8.1 Pages (Markup) Attachment Ill: Revised WCGS Technical Specification Pages Attachment IV: Revised WCGS Technical Specification 3.8.1 Bases Pages (Markup) (for information only)

cc: S. S: Lee (NRC), w/a S. A. Morris, (NRC), w/a K. S. Steves (KDHE), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a ET 22-0012 Page 3 of 3

STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Michael T. Boyce, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for anc:t on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By __________________ _ U1ll!J~v-

Michael T. Boyce Vice President Engineering

SUBSCRIBED and sworn to before me this / ;t-1-ii day of J ~, 2022. . NotaryY1~~ blic

Expiration Date _ "1~1_J_4--'--,/.r--c, d_o_J._3=-- Attachment I to ET 22-0012 Page 1 of 6

Su pp lemental Information Associated to the Res p onse to RAI EEEB-1

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application for an amendment to the technical specifications (TS) for the Wolf Creek Generating Station (WCGS). The proposed amendment would modify WCGS TS 3.8.1, "AC Sources - Operating," by removing requirements associated with the Sharpe Station gensets and extend the Completion Time for one inoperable diesel generator (DG) from 72 hours to 14 days based on the availability of a supplemental power source. At WCGS, the supplemental power source being credited is the Station Blackout (SBO) DG System. Reference 2 provided a request for additional information (RAI) related to the license amendment request. Reference 3 provided WCNOC's response to the RAI. This letter provides supplemental information associated with RAI EEEB-1. The Nuclear Regulatory Commission (NRC) request is provided in italics.

RAI EEEB-1

Section 2.3. 1 of Attachment I to the LAR describes the proposed TS changes to Conditions A, B, C, and Hof TS 3.8.1.

As stated in Section 2. 3. 1. 2 of Attachment I to the LAR, the licensee proposed to add a new Required Action B.2 to verify the availability of the required SBO DGs:

CONDITION REQUIRED ACTION COMPLETION TIME

B. One DG inoperable.

B. 2 Verify the required Station 1 hour Blackout (SBO) DGs AND are available. Once per 8 hours thereafter

As stated in Section 2.3.1.3 of Attachment I to the LAR, the licensee proposed to revise Condition C to reflect the unavailability of the required SBO DG(s) when a DG is inoperable. Attachment I to ET 22-0012 Page 2 of 6

CONDITION REQUIRED ACTION COMPLETION TIME

C. Required Action 8.2 and C.1 Restore DG to OPERABLE 72 hours from associated Completion Time no t status or restore required SB C discovery of met. to available status. unavailability of required SBO DGs

OR

24 hours from discovery of Condition B entry

= {J!.J 48 hours concurrent with unavailability of required SBO DGs

As stated in Section 2.3.1.3 of Attachment I to the LAR, the licensee proposed to revise Condition H to reflect the changes to Condition B. Attachment IV to the LAR shows the licensee's proposed revision to Condition H:

H. Required Action and H. 1 Be in MODE 3. 6 hours associated Completion Time of Condition A, C, D, AND E, F, or G not met. H.2 Be in MODE 5. 36 hours OR

Required Actions B.1, B.3, B.4.1, B.4.2, and B.5 and associated Completion Time not met.

Section 2.3.1.2 of Attachment I to the LAR states:

Unavailability of the required SBO DGs does not, by itself, result in the LCO not being met.

However, BTP 8-8 states, in part, that the plant should start shutting down the unit within 24 hours if the supplemental source becomes unavailable any time during the extended AOT. Attachment I to ET 22-0012 Page 3 of 6

The licensee used "OR" to connect the two CTs for Condition C, meaning these CTs apply alternatively. The first alternate CT states "72 hours from discovery of unavailability of required SBO DGs." The NRG staff understands that if the S80 DGs becomes unavailable during the extended CT, the DG could remain inoperable for an additional 72 hours instead of 24 hours from discovery of unavailability of S80 DGs before the plant would enter Condition H to start shutting down when the DG cannot be restored to operable status. This does not appear consistent with the recommendations of BTP 8-8.

The licensee proposed an alternate Required Action C. 1 to "restore required SBO DGs to available status" within the alternate CTs of Condition C. The NRG staff understands that the plant would continue operating (1) with an inoperable DG and unavailable S80 DGs for more than 24 hours up to 72 hours affer discovery of SBO DGs unavailability during the extended CT instead of shutting down affer 24 hours, as recommended by BTP 8-8, and (2) with an inoperable DG for a period of up to 14 days including a 72-hour period of S80 DGs unavailability affer restoring the SBO DGs to available status. This also does not appear consistent with the recommendations of BTP 8-8.

Please address the following:

a. Provide justifications for (1) the proposed first CT (72 hours from discovery of unavailability of required S80 DGs) of Condition C and (2) the proposed alternate Required Action C. 1 to "restore required S80 DGs to available status," each of which would allow the plant continued operation with an inoperable DG for more than 24 hours up to 72 hours affer discovery of S80 DGs unavailability during the extended CT. Alternatively, provide TS CT that would allow 24 hours of continued operation from discovery of SBO DGs unavailability, consistent with BTP 8-8.

b. The proposed CT for Required Action C.1 does not appear to require appropriate remedial measures within an appropriate time when the LCO is not met. In addition, the proposed CT appears too long compared to the CT recommended by BTP 8-8.

Please provide a discussion of other remedial measures, taken in CTs shorter than 24 hours, that may be appropriate. Attachment I to ET 22-0012 Page 4 of 6

Su pp lemental Information for RAI EEEB-1

Reference 3 proposed to revise the new Condition C as follows:

CONDITION REQUIRED ACTION COMPLETION TIME

C. Required Action B.2 and C.1 Restore DG to 72 hours from associated Completion Time OPERABLE status. Condition B entry not met. OR

24 hours from Condition B entry

~ 48 hours concurrent with unavailability of required SBO DGs

OR

C.2 Restore required SBO 72 hours from DGs to available status. Condition B entry

OR

24 hours from Condition B entry .:?: 48 hours concurrent with unavailability of required SBO DGs Attachment I to ET 22-0012 Page 5 of 6

Upon further review of the Condition C changes proposed above, additional changes are necessary based on the guidance in TSTF-GG-05-01, Revision 1, "Writer's Guide for Plant Specific Improved Technical Specifications," and Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Source Allowed Outage Time Extensions." Specifically, logical connectors are used in the TS to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances and Frequencies. However, it is noted that the logical connector "OR" is not utilized in the Completion Times column of the ACTIONS Table. As such, Condition C is revised to eliminate the use of the logical connector "OR" in the Completion Times column. Additionally, use of the 24 hour Completion Time in Condition C is revised based on the guidance in BTP 8-8. Condition C is proposed to be revised as follows:

CONDITION REQUIRED ACTION COMPLETION TIME

C. Required Action B.2 and C.1 Restore DG to 72 hours from associated Completion Time OPERABLE status. Condition B entry not met. OR

C.2 Restore DG to --------NOTE-------- OPERABLE status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry OR

C.3 Restore required SBO 72 hours from DGs to available status. Condition B entry

OR

C.4 Restore required SBO --------NOTE------ DGs to available status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry Attachment I to ET 22-0012 Page 6 of 6

Attachment II contains proposed markups of WCGS TS 3.8.1 which supersede the TS markups provided in Reference 1 and Reference 3. Attachment IV contains proposed markups of the WCGS TS 3.8.1 Bases (for information only) which supersede the TS Bases markups provided in Reference 1 and Reference 3.

References:

1. WCNOC letter ET 21-0004 from S. L. Smith, WCNOC, to USNRC, "License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, "AC Sources - Operating"," September 29, 2021. ADAMS Accession No. ML21272A369.

2. Electronic mail from S. A. Lee, USNRC, to J. Turner, WCNOC, "Request for additional information - Wolf Creek Request for additional information - Wolf Creek request to revise diesel generator completion time (EPID: L-2021-LLA-0173)," February 23, 2022. ADAMS Accession No. ML22055A114.

3. WCNOC letter ET 22-0005 from M. T. Boyce, WCNOC, to USNRC, "Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, "AC Sources -Operating"," April 13, 2022. ADAMS Accession No. ML22103A123.

Attachment II to ET 22-0012 Page 1 of 7

Revised WCGS Technical Specification 3.8.1 Pages (Markup) Attachment II to ET 22-0012 Page 2 of 7 AC Sources - Operating 3.8.1

ACTIONS (continued }

CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) Declare required feature(s) 24 hours from with no offsite power discovery of no available inoperable when offsite power to one its redundant required train concurrent feature(s) is inoperable. with inoperability of redundant required AND feature(s)

A.3 Restore offsite circuit to ::-,,____NOTE----- OPERABLE status. A Completion Time of 1 O days from discov e ry of failure to meet the LCO may be us ~d with the 7 day / Comple t~on Time of Requid Action B.4.2.2 for an

~'-6erable DG.

I 72 hours

AND 0

ftdays from discovery of failure to meet LCO

B. One DG inoperable. B.1 Perform SR 3.8.1.1 for the 1 hour offsite circuit(s).

Once per 8 hours thereafter

,..., 'I,. " ,.. 8.2 Verify the required Station 1 hour ,.. Blackout (SBO) DGs are AND available. Once per 8 hours .. thereafter AND j ( continued )

..I,._..... _J

Wolf Creek - Unit 1 3.8-2 Amendment No. ~,-4ea. Attachment II to ET 22-0012 AC Sources - Operating Page 3 of 7 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME w B. (continued) B. 2 NOTE In MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature.

Declare required feature(s) 4 hours from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable. redundant required feature(s)

AND Jti. 1 Determine OPERABLE 24 hours DG is not inoperable due to common cause failure. 0 OR

~.2 NOTE
~ Required Action of
'.2 is satisfied by the automatic start and sequence loading of the DG.

Perform SR 3.8.1.2 for 24 hours OPERABLE DG.

AND

(continued ) I

Wolf Creek - Unit 1 3.8-3 Amendment No.~. 163 Attachment II to ET 22-0012 Page 4 of? AC Sources - Operating 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued} ' NOTE----~ Require d Action B.4.2.1 anJ;I.-B-:"'6.2 are only app licable fo r 13lanned maintenance a nEI rnat be. used once per cycle per DG.,,,.

;EE]

Restore DG to 1~1:lfS-OPERABLE status.

-- / 0D AND GJ,,,,.

S- 'd ays from discovery of failure to meet LCO

1:t.'tl:1--\\/erifyihe-reqttired-Shatpe 0nee-per--42-fle1HS

-Statiefl-§eASets-are

.rutailabla.

AND-

&.43/4.2-R.-esrere-06--te*

0PERABtE-stattJS. AN 1-0-days-fr-em Gis~G~f.ajfuJ:e..to meet--bG-Q-

C.,-R=equired-Aetion-B-:4:2:'I-e:t --Rest-ere-BG-te- -flet:ffS*

*

• eiated-Gempletioo -eP&RA-Bk&stat-1:1&

-ime-Aet-met-,..

(continued}

~

Wolf Creek - Unit 1 3.8-4 Amendment No. 42J,'.!-eJ. Attachment II to ET 22-0012 Page 5 of 7

INSERT 3.8-4

CONDITION REQUIRED ACTION COMPLETION TIME

C. Required Action 8.2 and C.1 Restore DG to 72 hours from associated Completion Time OPERABLE status. Condition B entry not met. OR

C.2 Restore DG to ------NOTE----- OPERABLE status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry OR

C.3 Restore required SBO 72 hours from DGs to available status. Condition B entry

OR

C.4 Restore required SBO -------NOTE----- DGs to available status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry Attachment II to ET 22-0012 Page 6 of? AC Sources - Operating NO CHANGES THIS PAGE. INFORMATION ONLY. 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME

D. Two offsite circuits D.1 NOTE -- inoperable. In MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature.

Declare required feature(s) 12 hours from inoperable when its discovery of redundant required Condition D feature(s) is inoperable. concurrent with inoperability of redundant required features AND D.2 Restore one offsite circuit 24 hours to OPERABLE status.

E. One offsite circuit NOTE inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating," when Condition E is entered with no One DG inoperable. AC power source to any train.

E.1 Restore offsite circuit to 12 hours OPERABLE status. OR

E.2 Restore DG to 12 hours OPERABLE status.

F. Two DGs inoperable. F.1 Restore one DG to 2 hours OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.8-5 Amendment No. ~. 163 Attachment II to ET 22-0012 Page 7 of? AC Sources - Operating 3.8.1

ACTIONS (continued }

CONDITION REQUIRED ACTION COMPLETION TIME

G. One load shedder and G.1 Declare affected DG and Immediately emergency load sequencer offsite circuit inoperable. inoperable. AND

G.2 Restore load shedder and 12 hours emergency load sequencer to OPERABLE status.

H. Required Action and H.1 Be in MODE 3. 6 hours associated Completion Time of Condition A, C, AND D, E, F, or G not met. H.2 Be in MODE 5. 36 hours OR

Required Actions 8.1, &.2-;- -

-&.3;4, 8":-3-:2;-BA+,-a A1*

B~- and associated ~ Completion Time not met.

I. Three or more required AC 1.1 Enter LCO 3.0.3. Immediately sources inoperable.

Wolf Creek - Unit 1 3.8-6 Amendment No. ~. 1-tM-11 to ET 22-0012 Page 1 of 5

Revised WCGS Technical Specification Pages (4 pages) AC Sources - Operating 3.8.1

ACTIONS (continued ) CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) Declare required feature( s) 24 hours from with no offsite power discovery of no available inoperable when offsite power to one its redundant required train concurrent feature(s) is inoperable. with inoperability of redundant required AND feature(s)

A.3 Restore offsite circuit to 72 hours OPERABLE status. AND

17 days from discovery of failure to meet LCO

B. One DG inoperable. B.1 Perform SR 3.8.1.1 for the 1 hour offsite circuit(s). AND

Once per 8 hours thereafter AND

B.2 Verify the required Station 1 hour Blackout (SBO) DGs are available. AND

Once per 8 hours thereafter AND

(continued )

Wolf Creek - Unit 1 3.8-2 Amendment No. 12a, 16a, AC Sources - Operating 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued) B.3 NOTE-------------- In MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature.

Declare required feature(s) 4 hours from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable. redundant required feature(s)

AND

B.4.1 Determine OPERABLE 24 hours DG is not inoperable due to common cause failure.

OR

B.4.2 NOTE The Required Action of B.4.2 is satisfied by the automatic start and sequence loading of the DG.

Perform SR 3.8.1.2 for 24 hours OPERABLE DG.

AND

( continued )

• Wolf Creek - Unit 1 3.8-3 Amendment No. 123, 163, AC Sources - Operating 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued) B.5 Restore DG to 14 days OPERABLE status. AND

17 days from discovery of failure to meet LCO

C. Required Action B.2 and C.1 Restore DG to 72 hours from associated Completion OPERABLE status. Condition B entry Time not met. OR

C.2 Restore DG to NOTE-------- OPERABLE status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry OR

C.3 Restore required SBO 72 hours from DGs to available status. Condition B entry

OR

C.4 Restore required SBO ---- ----NOTE------ DGs to available status. Only allowed once within any given extended DG Completion Time.

24 hours from Condition C entry

(continued)

Wolf Creek - Unit 1 3.8-4 Amendment No. 123, 163, AC Sources - Operating 3.8.1

ACTIONS (continued )

CONDITION REQUIRED ACTION COMPLETION TIME

G. One load shedder and G.1 Declare affected DG and Immediately emergency load sequencer offsite circuit inoperable. inoperable. AND

G.2 Restore load shedder and 12 hours emergency load sequencer to OPERABLE status.

H. Required Action and H.1 Be in MODE 3. 6 hours associated Completion Time of Condition A, C, AND D, E, F, or G not met. H.2 Be in MODE 5. 36 hours OR

Required Actions 8.1, 8.3, 8.4.1, 8.4.2, and 8.5 and associated Completion Time not met.

I. Three or more required AC 1.1 Enter LCO 3.0.3. Immediately sources inoperable.

Wolf Creek - Unit 1 3.8-6 Amendment No. 123, 163, Attachment IV to ET 22-0012 Page 1 of 18

Revised WCGS Technical Specification 3.8.1 Bases Pages (Markup) (for information only) Attachment IV to ET 22-0012 Page 2 of 18 AC Sources - Operating B 3.8.1

BASES

BACKGROUND Power (LOP) Diesel Generator (DG) Start Instrumentation." After the DG (continued) has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SI signal. The DGs will also start and operate in the standby mode without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, a LSELS strips non essential loads from the ESF bus. When the DG is tied to the ESF bus, essential loads are then sequentially connected to its respective ESF bus by the load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application.

In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (OBA) such as a loss of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Within 1 minute after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service.

Ratings for Train A and Train B DGs satisfy the requirements of Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG is 6201 kW with 10% overload permissible for up to 2 hours in any 24 hour period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

APPLICABLE The initial conditions of OBA and transient analyses in the USAR, SAFETY ANALYSES Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume ESF systems are OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during Accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC power; and

Wolf Creek - Unit 1 B 3.8.1-2 Revision 88 Attachment IV to ET 22-0012 Page 3 of 18

INSERT B 3.8.1-2

The Station Blackout (S8O) DG System consists of three non-safety related DGs that are capable of supplying essential loads on ESF buses NB01 and NB02. The S8O DG System is made available to support extended Completion Times in the event of an inoperable DG. Only two SBO DGs are required to successfully start the minimum required safe shutdown loads. The S8O DGs are made available as a defense-in-depth supplemental source of AC power to mitigate a loss of offsite power event. The S8O DGs would remain disconnected from the Class 1 E AC Distribution System unless required during a loss of offsite power or during a functional load test. Attachment I to ET 22-0012 Page 4 of 18 AC Sources - Operating B 3.8.1

BASES

ACTIONS A.2 (continued)

b. A required feature on the other train is inoperable and not in the safeguards position.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1 E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1 E Distribution System. The 24 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1 E Distribution System.

The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DG is inoperable and that DG is subsequently returned OPERABLE, the LCO may already have been not met for u p t~4lettr-s. This could lead to a

~

Wolf Creek - Unit 1 B3.8.1-6 Revision 25 I Attachment IV to ET 22-0012 AC Sources - Operating Page 5 of 18 B 3.8.1

BASES

ACTIONS A.3 (continued)

total of 144 ROtlfS, since initial failure to meet the LCO, to restore the off~ circuit. At this time, a DG could again become inoperable and an additiomJ~-2--hetJfS allowed prior to complete restoration of the LCO. The

-& day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. Although highly unlikely, this could continue indefinitely if not limited. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. This limits the time the plant can alternate between Conditions A, B, and E (see Completion Time Example 1.3-3). The "AND" connector between the 72 hour and~ay Completion Times means that both Completion Times apply simultah'.~.!!~~md the more restrictive Completion Time must be met. ~

-Tra skiog}_h'@6-day Completion Time is a requirement for beginning the Completi~loc " that is in addition to the normal Completion Time requirements. With respec ~ day Completion Time, the "time zero" is specified as beginning at the time LCO 3.8.1 was initially not met, instead of at the time Condition A was entered. This results in the requirement, when in this Condition, to track the time elapsed from both the Condition A "time zero," and the "time zero" when LCO 3.8.1 was initially not met. Refer to Section 1.3, "Completion Times," for a more detailed discussion of the purpose of the "from discovery of failure to meet the LCO portion of the Completion Time.

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-Gem~etiefl...:r-ime-afle-a3/4lews-40-eays4r-em-EliSOOve,y-ef-f.atlt:1fe-t,e-meeHAe bGG-et:1r-iA§-tl:le-use~l=\\e ea~~eA-=r-ime-iA-Ret:1t1 *iree-AetieA-1:r.4:2:2:-

The 1 O day Completion Time specified in the Note establishes a limit or< the rilax imum time allowed for any combination of required AC pow er sources to be inoperable during any single contiguous occ ur.rence of failing to meet tR-El_ LCO. If Condition A is entered whilE;l, fo r instance, a DG is inoperable usingt~ day Completion Time of Re quired Action B.4.2.2 and that DG is subseque n tly restored OPER Q[ E, the LCO may already have been not met for up to 7 d ays. This co uld lead to a total of 10 days since initial failure to meet the L CG, te restore the offsite circuit. At this time, a DG could again become

• ope rat,le and an additional 72 hours allowed prior to complete restoration of the CO. Although highly unlikely, this could continue inq,efi itely if not limited. T he 10 day Completion Time provides a limit o n --tffne allowed in a specified con ditiQn after discovery of failure to me et the LCO. This limit is considered reas~b.Le for situations in which Go nditions A and B are entered concurrently. ThisliR'.l!!_s the time theylant can alternate between Conditions A, B, and D (see Com~ion

;r-m,e Example 1.3-3). ~

Wolf Creek - Unit 1 B 3.8.1-7 Revision 26 Attachment IV to ET 22-0012 Page 6 of 18 AC Sources - Operating B 3.8.1

BASES

ACTIONS -A"3:-{GemiAtteft-

rr--acl$i_ng the 10 day Completion Time is a requirement for beginning t e---- Complet!Ofl..J1me "clock " that is in addition to the normal Com

• n Time requirements.'Nith..@spect to the 1 O day Completion Ti -, the time zero" is specified as begtnflitl.g at the time LCO 3.8. 1 was initially not met, instead of at the time Conditior,;A. wa s entered. This results in the requirement, when in this Condi tion, o trask the time elapsed from both the Condition A "time zero," and the "time zero "\\llffle LCO 3.8.1 was initially not met. __Referto Section 1.3, "Completion Time," fQr a more detailed _d.iseus sion of the purpose of the "from discovery of fa ilUre-to meet jb.e--1::CO portion of the Completion Time."

B.1

To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

-- m

Required Action B.. :2 is intended to provide assurance that a loss ofoffsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical redundant required features. These redundant required features are those that are assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core Cooling System and Auxiliary Feedwater System. These redundant features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown. These features are powered from the redundant AC electrical power train. This includes motor driven auxiliary feedwater pumps. Single train systems, other than the turbine driven auxiliary feedwater pump, are not included in this Condition. A Note is added to this Required Action stating that in MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature. The reason for the Note is to confirm the OPERABILITY of the turbine driven auxiliary feedwater pump in this Condition, since the remaining OPERABLE motor driven auxiliary feedwater pump is not by itself capable of providing 100% of the auxiliary feedwater flow assumed in the safety analysis. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.

Wolf Creek-Unit 1 B 3.8.1-8 Revision 35 Attachment IV to ET 22-0012 Page 7 of 18

INSERT B 3.8.1-8

B.2

In order to extend the Completion Time for an inoperable DG from 72 hours to 14 days, the required SBO DGs must be verified available within 1 hour upon entry into TS 3.8.1, Condition B, and every 8 hours thereafter. SBO DG availability requires that:

a. A start/loaded test has been performed within 30 days of entry into the extended Completion Time. This portion of the Required Action evaluation is performed one time and is met with an administrative verification of this prior to a planned removal of a DG from service or after an emergent DG outage; and

b. Fuel oil tank level for each required SBO DG is verified locally to be ~ 24 hour supply (SBO Mission Time Minimum Fuel Satisfied Light); and

c. Supporting system parameters for starting and operating each required SBO DG are verified to be within required limits for functional availability (e.g., battery state of charge).

Only two SBO DGs are required to successfully start the minimum required safe shutdown loads. The SBO DG System is not used to extend the Completion Time for more than one inoperable DG at any one time. Attachment IV to ET 22-0012 Page 8 of 18 AC Sources - Operating B 3.8.1

BASES 0

ACTIONS -, B. 2 (continued)

The Completion Time for Required Action B.i is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists; and

b. A required feature on the other train (Train A or Train B) is inoperable and not in the safeguards position.

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1 E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completi_pn Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3. 1 and B. i~ ED

Required Action B ;a-:-1 provides an allowance to avoid unnecessary testing of OPERABLE DG. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on the other DG, it would be declared inoperable upon discovery and Condition F of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action 87"1 is satisfied. If the cause of the initial inoperable DG cannot be c pnnfmed not to exist on G3

Wolf Creek - Unit 1 B 3.8.1-9 Revision 42 Attachment IV to ET 22-0012 AC Sources - Operating Page 9 of 18

• B 3.8.1

BASES ACTIONS ----

8. 3':1 and 8. 3'.2 (continued)

the remaining DG, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG. Required Action B~.2 is modified by a Note stating that it is satisfied by the automatic start and sequence loading of the DG. The Note indicates that an additional start of the DG for test purposes only, is not required if the DG has automatically started and loaded following a loss of the offsite power source to its respective bus (Ref. 18). £D

In the event the inope~ e D G is restored to OPERABLE status prior to completing either B.r., or 8. 3".2, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour constraint imposed while in Condition B.

According to Generic Letter 84-*15 (Ref. 7), 24 hours is reasonable to confirm that the OPERABLE DG is not affected by the same problem as the inoperable DG. EJ ' B.-*4-:1-:-8:-4:2.1, a,,d B.4:2:2

'-1.(1 Condition B, the remaining OPERABLE DG and offsite circuits are /

aae~uate to supply electrical power to the onsite Class 1 E Distributi_9r<' Systef>Q_. With a DG inoperable, the inoperable DG must be restored to OPERA'B L E status within the applicable, specified Completio n T ime.

The Completion Time of 72 hours for Required Action B.( 1 applies when a DG is discoveres...or determined to be inoperable, su ch as due to a component or test fa11~e, and requires time to effect repairs, or it may apply when a DG is ren(j~red inoperable Eor t e performance of maintenance during applica~le MODES. T e 72-hour Completion Time takes into account the capacity. and caga ility of the remaining AC sources, reasonable time for re~irs,...and the low probability of a DBA during this period.

The second Completion Tim e for Required A ction B.4.1 also establishes a limit on the maximum time allowed for any co m bination of required AC power sources to bEY rioperable during any single contiguous occurrence of failing to ~eet tie LCO. If Condition B is entered w hile, for instance, an offsite circuit i *noperable, the LCO may already have b een not met for up to 72 hou~ If the offsite circuit is restored to OPERABL E status within the re~ired 72 hours, this could lead to a total of 144 hours, stnce initial failu,r,e to meet the LCO, to restore the compliance with the LCO'(i.e., i,sfore the DG). At this time, an offsite circuit could again become ,/'Inoperable and an additional 72 hours allowed prior to complete

Wolf Creek - Unit 1 B 3.8.1-10 Revision 39 Attachment IV to ET 22-0012 Page 10 of 18

INSERT B 3.8.1-10

In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 14 day Completion Time takes into account the capacity and capability of the remaining AC sources (including the required SBO DGs), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

When one DG is inoperable due to either preplanned maintenance (preventive or corrective) or unplanned corrective maintenance work, the Completion Time can be extended from 72 hours to 14 days if the required S80 DGs are verified available for backup operation in accordance with Required Action 8.2. The 14 day Completion Time for an inoperable DG will be used no more than once in an 18-month period on a per DG basis to perform DG planned maintenance.

The second Completion Time for Required Action 8.5 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 14 days. This could lead to a total of 17 days, since initial failure to meet the LCO, to restore the DGs. At this time, an offsite circuit could again become inoperable, the DGs restored OPERABLE, and an additional 72 hours (for a total of 20 days) allowed prior to complete restoration of the LCO. The 17 day Completion Time provides a limit on time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. This limits the time the plant can alternate between Conditions A, 8, and D (see Completion Time Example 1.3-3). The "AND" connector between the 14 day and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

Tracking the 17 day Completion Time is a requirement for beginning the Completion Time "clock" that is in addition to the normal Completion Time requirements. With respect to the 17 day Completion Time, the "time zero" is specified as beginning at the time LCO 3.8.1 was initially not met, instead of at the time Condition B was entered. This results in the requirement, when in this Condition, to track the time elapsed from both the Condition B "time zero," and the "time zero" when LCO 3.8.1 was initially not met. Refer to Section 1.3, "Completion Times," for a more detailed discussion of the purpose of the "from discovery of failure to meet the LCO portion of the Completion Time."

Administrative controls are required whenever Condition B is entered for a planned or unplanned DG outage that will extend beyond 72 hours. Administrative controls applied ensure or require that:

a. Weather conditions are conducive to an extended DG Completion Time.

b. The offsite power supply and switchyard condition are conducive to an extended DG Completion Time, which includes ensuring that switchyard access is restricted and no elective maintenance within the switchyard is performed that would challenge offsite power availability. Elective maintenance or testing that would challenge offsite power availability is that activity that could result in an electrical power distribution system (offsite circuit or transmission network) transient or make the offsite circuit(s) unavailable Attachment IV to ET 22-0012 Page 11 of 18

or inoperable (Reference 19). The operational risk assessment procedure provides a list of equipment that could challenge offsite power availability.

c. No equipment or systems assumed to be available for supporting the extended DG Completion Time are removed from service. The equipment or systems assumed to be available (including required support systems, i.e., associated room coolers, etc.) are as follows:

• Auxiliary Feedwater System (three trains)
• Component Cooling Water System (both trains and all four pumps)
• Essential Service Water System (both trains)
• Emergency Core Cooling System (two trains).

Attachment IV to ET 22-0012 Page 12 of 18 AC Sources - Operating B 3.8.1

BASES

ACTIONS -B-:4.1, 8.4.2.1. and B4.2-:-~rtt1flt:tedj*

e allowed in a specified condition after discovery of failure to meetz:h

0. This limit is considered reasonable for situations in which dTons A and B are entered concurrently. This limits the time th~ plant can ernate between Conditions A, B, and E (see Completion Time Exa le 1.3-3). The "AND" connector between the 72 hour and 6 day CompletiQn Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

Tracking the 6 day Completion Time is a requirement for eginning the Completion Time "clock" that is in addition to the normaj Completion Time requirements. Wit respect to the 6 day Completi~n { me, the "time z~ro" is specified as begi ning at the time LCO 3.8. 1 was nitially not met, instead of at the time s.._ondition B was entered. T 1s results in the requirement, when in tlii~ Condition, to track theAime elapsed from both the Condition B "time zero" and the 0 "time zero ?~hen LCO 3.8.1 was initially not met. Refer to S~tion 1.3, "Com p letion Times," for a more detailed discussion of the p~i'P,ose of the .ffom discovery of failure to meet the LCO portion of the Comple *on Time J' The Required Actions are modified ya Note that states that Required Actions B.4.2.1 and B.4.2.2 are on y applicable for voluntary planned maintenance and may be used o n ce per cycle per DG. Required Actions B.4.2.1 and B.4.2.2 only applie when a DG is declared or rendered inoperable for the performance of voluntary, planned maintenance activities. Required Action B.4.2.1 provides a~s;irance that the required Sharpe Station gensets a re available when a ~ is out of service for greater than 72 hours. the availability of the req~ired gensets are verified once per12 hours by lo"cally monitoring various gehset parameters.

The 7-day Comp !r ion Time of Required Action B.4.2.2 is a risk-informed allowed outage time (AOT) based on a plant-specific ris'k analysis. The Completion Time was established on the assumption that it would be used only for volu ntary planned maintenance, inspections and testing. Use of Required Actions B.4.2.1 and B.4.2.2 are limited to once within an operatin g cycle (18 months) for each DG. Administrative contro ls applied during use of Required Action B.4.2.2 for voluntary planned main tenance activities ensure or require that (Ref. 16):

a. Weather conditions are conducive to an extended DG Completio n Time. The extended DG Completion Time applies during the

/ period of September 7 through April 5. l

Wolf Creek - Unit 1 B 3.8. 1-11 Revision 36 Attachment IV to ET 22-0012 Page 13 of 18 AC Sources - Operating B 3.8.1

BASES

ACTIONS B:4.1, B.4.2.1, am.laaf34~ntimre~

The offsite power supply and switchyard condition are conduciveto an extended DG Completion Time, which includes ensuring that switchyard access is restricted and no elective maintenance wl.1t n the switchyard is performed that would challenge offsite power, availability. Elective maintenance or testing that would chEII ge off ite power availability is that activity that could result in a ele~!~cal power distribution system (offsite circuit or tran!j ission ne~1;\\k) transient or make the offsite circuit(s) unavailal:Sle or inopera-Qle (Reference 19). The operational risk asse sment procedur'e provides a list of equipment that could ch llenge offsite power avail bility. I

C. Prior to relyin'g on the required Sharpe Station gensets, the gensets are sta ed and proper operation ve lfied (i.e., the gensets reach rated speed and voltage). The Sha p) e Station is not required to be ope~ting the duration of the allowed outage time of the DG, however, a 'r(linimum of 8 gens e ts must be capable of providing power to a ~a~ bus (statio

• 1 blackout conditions) to power 1 ESF train. ~itR{n 8 months prior to utilization of Required Action B.4.2.2, a load caP{lbility tes't!verification will be performed on the Sharpe Station gensets. :f he load capability testing/verification will consis pf either 1) crediting a running of the gensets for load for commerci~easons for greater than 1 hour, or

2) tested by loading of the ge ns s for greater than 1 hour to a load equal to or greater tl;lan requ ed to supply safety related loads in the event of a station black ut.

d. No equipment or sys tems assumed to bf available for supporting the extended DG Completion Time are re{Tloved from service. The equipment or syJtems assumed to be avail~ble (including required support systems, i.e., associated room coole(s, etc.) are as follows:

• Au;5-U fu ry Feedwater System (three trains)
• domponent Cooling Water System (both trains 'a nd all four pumps)

Essential Service Water System (both trains)

• Emergency Core Cooling System {two trains).

If, while Required Action B.4.2.2 is being used, one (or more) of the above systems or components is determined or discovered to be inoperable, or if

Wolf Creek - Unit 1 B 3.8.1-12 Revision 75 I Attachment IV to ET 22-0012 AC Sources - Operating Page 14 of 18 B 3.8.1

BASES

ACTIONS B-:4:4,B-:4-:r:*-'1-,-a-rKIB-4~eCffltiAtteet

~n emergent condition affecting DG OPERABILITY is identified, re-entry int.,o Required Action B.2 and 8.3 would be required, as applicable. In addition, the effect on plant risk would be assessed and any additional or compensatory actions taken, in accordance with the plant's p~ogr.rti for impleme (ltation of 10 CFR 50.65(a)(4). The 7-day Completion *me would remain in effect for the DG if Required Action B.2 and. are satisfied.

The second Completion Time specified in Required AcJion B.4.2.2 establishes a limit on the maximum time allowed for any combination of required AC power s0urces to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable, the LCO may already have been not met for up to 72 hours. Lf the offsite circu it is restored to OPERABLE status within the required 72,ours, this codld lead to a total of 1 O days since initial failure to meet the LCO, to re6tore compliance with the LCO (i.e., restore the DG). At this time, an p ffsite circuit could again become inoperable and an additional 72 hou'! allowed prior to complete restoration of the LCO. The 1 O day ~~pletion Time provides a limit on time allowed in a specified c~n ition after discovery of failure to meet the LCO. Although highly unlikel, this could occur indefinitely if not limited. This limit is considered re~ nable for situations in which Conditions A and B are entered conc'P.'.'"ently. This limits the time the plant can alternate between Co,1tions A, B, and E (see Example 1.3-3).

Tracking the 10 d 9(completion Time is a requirement-!o~ beginning the Completion Timelclock" that is in addition to the norm~~ompletion Time requirements. With respect to the 1 O day Completion Timeil, the "time zero" is specified as beginning at the time LCO 3.8.1 was in1t~*a11y not met, instead of a t the time Condition B was entered. This results in he requirenfent, when in this Condition, to track the time elapsed fr ~oth the C o ndition B "time zero," and the time zero" when LCO 3.8.1 w s initially not met. Refer to Section 1.3, "Completion Times," for a mor de ailed discussion of the purpose of the "from discovery of failure to m~t the LCO portion of the Completion Time." ""

-lf..t:"'1&-availaaiHty--ef-the-FeE1*l:tiree-8flaFpe-Stat1er-i-§eAsets,eaAA0H:>e ver~fied, tt:ie DG-m1:1st-be~.e-st9r,ed~G-G,!2e.RAS.bE-stattis-Wit~~~AOOr.s.,

T-t'le-?~e\\:lf-G<:>mt>letieA-l-tme-i3e§-ifls-1:113eA-eAtfy-iflte-GeAeiti0rrG. Hewever~e-tetat-time-te-r-es-ter-e-afFioof)er.aete-9G-GaARe~x~e1-7-eays

~HA&GempletteA-+ime=ef-R-eEJtJir~~etioo~+

Wolf Creek - Unit 1 B 3.8.1-13 Revision 4 7 I Attachment IV to ET 22-0012 Page 15 of 18

INSERT B 3.8.1-13

C.1, C.2. C.3 and C.4

If the required S80 DGs are or becomes unavailable with an inoperable DG, then action is required to restore the DG to OPERABLE status or restore the required S80 DGs to available status. Required Action C.1 requires restoring the DG to OPERABLE status within 72 hours from declaring the DG inoperable and Condition B entry. Required Action C.3 requires restoring the required S80 DG(s) to available status within 72 hours from declaring the DG inoperable and Condition B entry.

Required Action C.2 requires restoring the DG to OPERABLE status within 24 hours from Condition C entry. Required Action C.4 requires restoring the required S80 DGs to available status within 24 hours from Condition C entry. The Completion Times for Required Actions C.2 and C.4 are modified by a Note indicating that the 24 hours from Condition C entry is only allowed once within any given extended DG Completion Time. Utilization of Required Actions C.2 and C.4 are typically applicable 72 hours after entry into Condition B (i.e., when the extended 14 day Completion Time is utilized). The total time to restore an inoperable DG cannot exceed 14 days (per the Completion Time of Required Action B.5).

The Completion Time of 72 hours is consistent with Regulatory Guide 1.93 (Ref. 6). The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and low probability of a OBA occurring during this period. Attachment IV to ET 22-0012 Page 16 of 18 AC Sources - Operating B 3.8.1

BASES

ACTIONS -fr1 (contimredt

-=fhe eompfetior I ftme o~!"S°is'consistentwittrRegutatory~tride
+,a9&{R-ef~---A&-?-r-Mettr-C-empletioo--:i=tme-takes-imo-aeeottnt-the
-Ga-J30Bity and oaf3aaHity af the reA'tatRm~~&se1::1r~es,---a-r~bfe--tifne40r
~aifS,aAe-l0W13r-eeaa-iHty~-a-BBA--eeet:K-rtA~ - dtfftA~+si3Cf 8Ga

D.1 and D.2

Required Action D.1, which applies when two offsitc circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required features. These redundant required features arc those that are assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core Cooling System and Auxiliary Feedwater System. These redundant features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps and the turbine driven auxiliary feedwater pump which must be available for mitigation of a feedwater line break. Single train features, other than the turbine driven auxiliary feedwater pump, are not included in this Condition. The Completion Time for this failure of redundant required features is reduced to 12 hours from that allowed for one train without offsite power (Required Action A.2}. The rationale for the reduction to 12 hours is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours is appropriate. A Note is added to this Required Action stating that in MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature. The reason for the Note is to confirm the OPERABILITY of the turbine driven auxiliary feedwater pump in this Condition, since the remaining OPERABLE motor driven auxiliary feedwater pump is not by itself capable of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

The Completion Time for Required Action D.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable; and

b. A required feature is inoperable and not in the safeguards position.

Wolf Creek - Unit 1 B 3.8.1-14 Revision 47 Attachment IV to ET 22-0012 AC Sources - Operating Page 17 of 18 B 3.8.1

BASES

ACTIONS E...1 (continued)

According to Reference 6, with both DGs inoperable, operation may continue for a period that should not exceed 2 hours.

G.1 and G.2

Required Action G.1 provides assurance that the appropriate Action is entered for the affected DG and offsite circuit if its associated LSELS becomes inoperable. An LS ELS failure results in the inability of the EDG to start upon a loss of ESF bus voltage or degraded voltage condition. Additionally, LSELS trips the ESF bus normal and alternate feeder supplies and trips non-essential loads. A sequencer failure results in the inability to start all or part of the safety loads powered from the associated ESF bus and thus when an LSELS is inoperable it is appropriate to immediately enter the Conditions for an inoperable DG and offsite circuit. Because an inoperable LS ELS affects all or part of the safety loads, an immediate Completion Time is appropriate.

The LSELS is an essential support system to both the offsite circuit and the DG associated with a given ESF bus. Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus. Therefore, loss of an ESF bus sequencer affects every major ESF system in the division. The 12 hour Completion Time of Required Action G.2 provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

H.1 and H.2

If the inoperable AC electric power sources or the load shedder and emergency load sequencer cannot be restored to OPERABLE status B.3, B.4.1, B.4.2, and B.5 within the required Completion Time, or Required Actions B.1, B:2-;-8:3".1";" 13:-3.2, B.4.1 o f-8.:4~cannot be met within the required Completion Times, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Wolf Creek - Unit 1 B 3.8.1-17 Revision 26 Attachment IV to ET 22-0012 Page 18 of 18 AC Sources - Operating B 3.8.1

BASES

REFERENCES 11. ANSI C84.1-1982 (continued)

12. IEEE Standard 308-1978.

13. Configuration Change Package (CCP) 08052, Revision 1, April 23, 1999.

14. Amendment No. 161, April 21, 2005.

,/~

15. Nt d ouse. / ~

16. Amendment No. 163~fil-26~00.

17. Amendment No. 154, August 4, 2004.

18. Amendment No. 8, May 29, 1987.

19. Condition Report 15727.

Wolf Creek - Unit 1 B 3.8.1-34 Revision 7 4 I}}