Text

License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements
	ML24080A455
Person / Time
Site:	Vogtle
Issue date:	03/20/2024
From:	Coleman J; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	NL-22-0267
	Download: ML24080A455 (1)
	v • d • e

3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 March 20, 2024 NL-22-0267 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Units 1&2 Docket Nos. 50-424 & 50-425

Subject:

License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources - Operating, Surveillance Requirements Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests a license amendment to the Technical Specifications (TS) for Vogtle Electric Generating Plant (VEGP) Unit 1 renewed facility operating license NPF-68 and Unit 2 renewed facility operating license NPF-81. The proposed amendment revises emergency diesel generator (EDG or DG) frequency and voltage acceptance criteria for TS 3.8.1, AC Sources - Operating, Surveillance Requirements. These changes reflect incorporation of Technical Specification Task Force (TSTF) traveler TSTF-163, Revision 2, "Minimum vs. Steady State Voltage and Frequency" (ML040500733), as well as changes to the steady state DG operating voltage and frequency ranges consistent with WCAP-17308-NP-A, Treatment of Diesel Generator (DG) Technical Specification Frequency and Voltage Tolerances, (ML17215A232) methodology.

The license amendment request is required to correct a non-conservative TS. This change is necessary based on the discovery that some safety related pumps could not be demonstrated to perform as specified in the design basis over the full range of DG voltages and frequencies allowed by the Technical Specifications without more detailed analysis. Conservative plant operations are currently administratively controlled in accordance with NEI 15-03, Revision 0, Licensee Actions to Address Nonconservative Technical Specifications (ML15147A655).

This LAR is required to resolve a non-conservative TS and is not a voluntary request.

Therefore, this request is not subject to 'forward fit' considerations as described in the letter from S. Burns (NRC) to E. Ginsberg (NEI), dated July 14, 2010 (ML101960180).

The Enclosure provides the description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. provides the clean typed proposed TS changes. Attachment 3 provides the existing TS Bases pages marked up to show proposed changes consistent with the TS changes (for information only).

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.

U. S. Nuclear Regulatory Commission NL-22-0267 Page 2 Approval of the proposed amendment is requested within one year of acceptance. Once approved, the amendment shall be implemented within 90 days.

SNC has concluded that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, Issuance of amendment.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this license amendment request by transmitting a copy of this letter, with attachments and enclosures, to the designated State Official.

If you have any questions, please contact Ryan Joyce at 205.992.6468.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of March 2024.

Respectfully submitted, Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company

Enclosure:

Description and Assessment of the Proposed Changes cc:

Regional Administrator, Region ll NRR Project Manager - Vogtle 1 & 2 Senior Resident Inspector - Vogtle 1 & 2 State of Georgia Environmental Protection Division RType: CVC7000

E-1 ENCLOSURE Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 1 and 2 License Amendment Request: Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources - Operating, Surveillance Requirements Description and Assessment of the Proposed Changes

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Technical Specification Page Markups

2. Technical Specification Clean Pages

3. Bases Page Markups (for information only)

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-2

1.

SUMMARY

DESCRIPTION Southern Nuclear Operating Company (SNC) requests an amendment to the Technical Specifications (TS) for Vogtle Electric Generating Plant (VEGP) Units 1 and 2 to revise emergency diesel generator (EDG or DG) frequency and voltage ranges for TS 3.8.1, AC Sources - Operating, Surveillance Requirements (SR). These changes reflect incorporation of Technical Specification Task Force (TSTF) traveler TSTF-163, Revision 2, "Minimum vs. Steady State Voltage and Frequency" (ML040500733)(Reference 1), as well as changes to the steady state DG operating voltage and frequency ranges consistent with WCAP-17308-NP-A, Treatment of Diesel Generator (DG) Technical Specification Frequency and Voltage Tolerances, (ML17215A232) (Reference 2) methodology.

The license amendment request is required to correct a non-conservative TS. These proposed TS changes establish DG surveillance testing limits to support the required performance ranges for the safety related equipment. This change is necessary based on the discovery that some safety related pumps could not be demonstrated to perform as specified in the design basis over the full range of DG voltages and frequencies allowed by the Technical Specifications without more detailed analysis. Conservative plant operations are currently administratively controlled in accordance with NEI 15-03, Revision 0, Licensee Actions to Address Nonconservative Technical Specifications (ML15147A655) (Reference 3).

2.

DETAILED DESCRIPTION 2.1 System Design and Operation The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs A and B are dedicated to ESF buses A and B, respectively. A DG starts automatically on a safety injection (SI) signal or on an ESF bus degraded voltage or undervoltage signal.

After the DG 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, in response to the undervoltage signal, a sequencer strips nonpermanent loads from the ESF bus. When the DG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application.

Each diesel generator is rated at 7000 kW for continuous operation and 7700 kW for a short-term (2-hour) period every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The voltage and frequency recovery characteristics meet or exceed the requirements of Regulatory Guide 1.9.

2.2 Current Technical Specifications Requirements Pertinent portions of the current Surveillance Requirements of TS 3.8.1 are shown:

SR 3.8.1.2 Verify each DG starts from standby conditions and achieves steady state voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz.

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-3 SR 3.8.1.7 Verify each DG starts from standby condition and achieves in 11.4 seconds, voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz SR 3.8.1.10 Verify on an actual or simulated loss of offsite power signal:

c.

DG auto-starts from standby condition and:

3.

... steady state voltage 3750 V and 4330 V,

4.

... steady state frequency 58.8 Hz and 61.2 Hz SR 3.8.1.11 Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and:

a.

In 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and 4330 V;

b.

In 11.4 seconds after auto-start and during tests, achieves frequency 58.8 Hz and 61.2 Hz; SR 3.8.1.14

... in 11.4 seconds, voltage 4025 V, and 4330 V and frequency 58.8 Hz and 61.2 Hz SR 3.8.1.18

3.

... steady state voltage: 3750 V and 4330 V,

4.

... steady state frequency: 58.8 Hz and 61.2 Hz SR 3.8.1.20 Verify when started simultaneously from standby condition, each DG achieves in 11.4 seconds, voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz 2.3 Reason for the Proposed Change TSTF-163 provided a generic change as now reflected in NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 5.0 [ML21259A155] to modify the fast-start (i.e., in [10] seconds) to require achieving only a minimum voltage and frequency and subsequently to establish a steady state voltage and frequency range.

Currently, the VEGP TS for these fast start Surveillances require achieving steady state voltage and frequency range within 11.4 seconds. As stated in TSTF-163:

The intent of the [10] second start tests is to confirm the ability of the DG to reach the minimum conditions to accept load. This is consistent with the revised minimum volt/Hz. A new range of acceptable voltage and frequency are provided which are applicable only to steady state operation.

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-4 Additionally, this change is necessary based on the discovery that some safety related pumps could not be demonstrated to perform as specified in the design basis over the full range of DG voltages and frequencies allowed by the Technical Specifications without more detailed analysis. Subsequent SNC evaluations utilizing the methodologies approved in WCAP-17308 determined that more conservative operating ranges for DG voltage and frequency TS Surveillance Requirements are appropriate to assure design basis assumptions for equipment performance.

This LAR is required to resolve a non-conservative TS and is not a voluntary request. As such, it is not subject to 'forward fit' considerations. Therefore, this request is not subject to 'forward fit' considerations as described in the letter from S. Burns (NRC) to E. Ginsberg (NEI), dated July 14, 2010 (ML101960180).

2.4 Description of the Proposed Change Revised voltage and frequency values are highlighted as BOLD; other formatting changes from TSTF-163 are not highlighted:

SR 3.8.1.2 Revise from

... voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz to

... 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz SR 3.8.1.7 Revise from

... in 11.4 seconds, voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz to:

a. In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady State voltage 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz SR 3.8.1.10 Revise subsection c from

3.... steady state voltage 3750 V and 4330 V,

4.... steady state frequency 58.8 Hz and 61.2 Hz to

3.... steady state voltage 4040 V and 4330 V,

4.... steady state frequency 59.6 Hz and 60.4 Hz SR 3.8.1.11 Revise from

a. In 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and 4330 V;

b. In 11.4 seconds after auto-start and during tests, achieves frequency 58.8 Hz and 61.2 Hz; to

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-5

a. In 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and frequency 58.8 Hz;

b. Achieves steady state voltage 4040 V and 4330 V and frequency 59.6 Hz and 60.4 Hz; SR 3.8.1.14 Revise from

... in 11.4 seconds, voltage 4025 V, and 4330 V and frequency 58.8 Hz and 61.2 Hz to

a. In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady State voltage 4040 V and 4330 V and frequency 59.6 Hz and 60.4 Hz SR 3.8.1.18 Revise from

3.... steady state voltage: 3750 V and 4330 V,

4.... steady state frequency: 58.8 Hz and 61.2 Hz to

3.... steady state voltage: 4040 V and 4330 V,

4.... steady state frequency: 59.6 Hz and 60.4 Hz SR 3.8.1.20 Revise from

... in 11.4 seconds, voltage 4025 V and 4330 V, and frequency 58.8 Hz and 61.2 Hz to

a. In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady state voltage 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz

3.

TECHNICAL EVALUATION The TSTF-163 related changes to VEGP Units 1 and 2 TS SRs 3.8.1.7, 3.8.1.11, 3.8.1.14, and 3.8.1.20 to only require achieving a minimum voltage and frequency within 11.4 seconds. This confirms the ability of the DG to reach the conditions necessary to accept load. The minimum values for voltage and frequency are unchanged and remain acceptable since these SRs do not require the DG to be loaded at 11.4 seconds. The TSTF-163 related change continues to require achieving steady state voltage and frequency with those ranges at revised values consistent with the changes described below to meet the methodology prescribed in WCAP-17308-NP-A. Therefore, any subsequent loading of the DG (e.g., to meet SR 3.8.1.3) would only be performed after reaching the proposed steady state ranges appropriate to support the performance of required loads. As such, this change does not have any impact on the safety related loads. The proposed change does not involve any departures (other than VEGP-specific values) from TSTF-163.

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-6 The performance of the required equipment is dependent on the DG voltage and frequency. The current analyses generally assume that the steady-state DG voltage is 4160 V and the steady-state DG frequency is 60 Hz. However, equipment powered from the DGs are allowed voltage and frequency variations up to the limits specified in the TS SRs. The current VEGP Units 1 and 2 TS 3.8.1 allows steady state voltage range of 4025 V to 4330 V and steady state frequency range of 58.8 Hz to 61.2 Hz. These allowed steady-state ranges represent tolerances for voltage of +4/-3.2% around a nominal 4160 V and for frequency of +/-2% around a nominal 60 Hz. The proposed revised DG voltage and frequency ranges have been analyzed assuming steady state voltage range of 4040 V to 4330 V and frequency range of 60 Hz +/-0.4 Hz for frequency.

The proposed tolerances are conservative with respect to the current TS SR ranges for DG voltage and frequency. Since the DGs were designed to operate within these current tolerances, limiting the tolerances to a tighter band is considered acceptable for DG operation. The DG frequency range was reduced to minimize the impact of frequency variation on the operation of connected loads. The DG voltage regulator is capable of maintaining steady state voltage within the proposed tolerance and the DG governor is capable of maintaining DG speed within the narrower tolerance as demonstrated by design analyses and supported by manufacturer design tolerances. Furthermore, review of surveillance test data over the past three years provides assurance that the revised voltage and frequency limits will be achievable.

Topical Report WCAP-17308-NP-A is approved for determining the impact of DG steady state frequency and voltage variations on the performance of pumps, valves, and fans/blowers, chillers, coolers, and miscellaneous electrical loads and mechanical equipment, particularly with regards to the Emergency Core Cooling System (ECCS).

Voltage and frequency operating range requirements allow for variations in motor speeds, which consequently allow for variations in equipment performance. SNC analyzed the allowable steady state variations in voltage and frequency proposed in the TS SRs (as listed in Section 2.4 of this LAR) following the methods provided by WCAP-17308 utilizing VEGP-specific inputs to demonstrate the capability of equipment to meet intended safety performance. The SRs being revised are consistent with those addressed by WCAP-17308.

The evaluation calculates the surveillance uncertainty which is a combination of the operational uncertainty (i.e., manufacturer voltage regulator and speed governor design control uncertainties) and the indication uncertainties (i.e., metering/indication circuit uncertainties). The surveillance uncertainty provides a tighter band around nominal than the 10% and 2% previously specified in the TS. The selected TS ranges are slightly larger than the surveillance uncertainties to allow some design margin for the future. These tighter values (which bound those uncertainties) are then evaluated against the design basis accident analyses to show that, within those tolerances, the new DG voltage and frequency are sufficient to support the required plant equipment operation. Therefore, as long as the voltage and frequency are within the new ranges specified in the TS, the design analyses are supported. Previous analyses did not explicitly account for surveillance uncertainty; as such, there is no change to the assumed uncertainty.

ECCS And Containment Spray Pump Evaluation The analysis evaluated the performance of the VEGP ECCS and containment spray pumps to generate revised minimum and maximum test curves that account for the effects of steady state DG voltage and frequency variations, as well as evaluating flow and

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-7 pressure measurement uncertainties. Adjustments are applied to the existing pump curves of record using the VEGP-specific DG and instrument uncertainties. In systems with variable resistance, throttle valve settings are checked or reset to within prescribed limits to meet the required minimum design basis accident flow rates, that pumps do not exceed runout flow, and that flow balance tolerances between branch lines are met.

The results will be used to adjust the Inservice Testing (IST) surveillance test acceptance criteria, as applicable, to ensure that design basis safety analysis limits of equipment loaded on the DG will be met at the extremes of steady state DG voltage and frequency variations and due to flow and pressure measurement uncertainties. These adjustments will be implemented upon approval of this requested amendment.

Miscellaneous Equipment powered from the DGs This analysis also evaluates other pumps, fans, motor operated valves, chillers, air conditioning units and coolers, miscellaneous electrical loads, and miscellaneous mechanical equipment that are powered from the DG for the effects of the over and under frequency and voltage allowed by the TS for line break hazards in accordance with the methodology prescribed in WCAP-17308-NP-A utilizing VEGP-specific inputs, including:

Component Cooling Water (CCW) Pumps New analyses for CCW pump performance, with allowances for IST limits and EDG frequency and voltage uncertainty and impacts on heat exchanger performance, show that the design basis requirements for the system can be met at the revised voltage and frequency ranges.

Nuclear Safety Cooling Water (NSCW) Pumps New analyses for NSCW pump performance, with allowances for IST limits and EDG frequency and voltage uncertainty, show that the design basis requirements for the system can be met at the revised voltage and frequency ranges.

Essential Chilled Water (ECW) Pumps The ECW pump nominal pump performance is significantly greater than the requirements. Even after allowing for degradation to the current IST limits, there is more than adequate margin to account for EDG frequency and voltage variation.

Therefore, the ECW pumps operating at the revised voltage and frequency ranges are acceptable.

Nuclear Safety Cooling Water (NSCW) Transfer Pumps The NSCW transfer pumps were analyzed for minimum and maximum flow with the tower basins empty and full. The calculation used nominal pump performance curves. Minimum and maximum pump performance curves were developed that bound IST limits, test uncertainty, and EDG uncertainty. These curves were plotted against system resistance curves to determine new minimum and maximum flow rates. The minimum flow exceeds the evaporation rate and is acceptable. The maximum flow rate was shown to be acceptable for both NPSH and pump horsepower.

Boric Acid Transfer (BAT) Pumps The BAT pumps are required to supply 30 gpm to the suction of the charging pumps through at least one flow path. The existing hydraulic analysis did not

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-8 adequately account for the overpressure or the maximum possible level in the volume control tank (VCT), which is directly connected to the charging pump suction. After adjusting the system resistance for this additional discharge pressure and reducing the pump performance for both IST degradation limits and EDG uncertainty, the analysis shows that the BAT pumps provide at least 30 gpm to the charging pump suction.

Spent Fuel Pit Pumps The Spent Fuel Pit pump sizing calculation indicates that only approximately 55 feet of head are required at the design flow of 2,300 gpm. The pumps were sized with 125 ft of head at 2,300 gpm, and therefore have significant margin for degradation and EDG uncertainty.

Diesel Fuel Oil Transfer Pumps The Fuel Oil Transfer Pumps are used to provide makeup to the day tanks. They were designed to provide 25 gpm compared to a maximum EDG consumption rate of 8.51 gpm, and therefore have significant margin for degradation and EDG uncertainty.

Motor Operated Valve (MOV) performance Four effects on MOV motor speeds uncertainties were evaluated when the DG is operating at highest or lowest allowable voltage and frequency limits: (1) the increased inertia of the motor due to increased DG frequency; (2) the potential effect of higher pump motor frequency on the differential pressure across the MOVs; (3) the impact of decreased voltage below nominal on the motor operator capability; and (4) the potential for increased stroke time.

In addition to the normal limits, the potential for the opening force to be limited by the effects of pressure locking and thermal binding (PL/TB) were evaluated to include the effects of DG voltage and frequency on those limits. This evaluation concluded that the existing PL/TB evaluation does not require any additional limits be place on the opening (pullout) force from the valve.

Analyses results show that MOV performance is not adversely affected by the proposed DG voltage and frequency ranges.

Ventilation fans credited in the dose analyses For each fan, the motor speed decrease based on the minimum DG frequency and voltage is determined. The analysis evaluates the fan capability at the reduced motor speed and then determines if the fans could still deliver the required air flow, and considers the worst case reduction in differential temperature across chillers, air conditioning units and coolers due to decreased operating speeds caused by DG voltage and frequency variations. The change in temperature across chillers, air conditioning units and coolers is also evaluated. Analysis results show any temperature change can be considered a negligible effect to the system.

Similarly, the fan speed increase based on the maximum DG frequency and voltage is determined. The analysis concluded that the small change in fan speed will have a negligible impact on room static pressures. An increase in voltage and frequency to the Engineered Safety Feature (ESF) HVAC components will result in slightly greater speeds, thus increasing the overall heat loads. However, because

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-9 some of these components are fans, chillers, air conditioner units (ACUs) and coolers, the increase in speeds will result to an improved performance from the components. The other non-motor driven components such as battery chargers, transformers and heaters, will dissipate more heat, but will have that heat removed by the fans, chillers, ACUs and coolers mentioned above. As a result, the additional heat being added will essentially be removed by the increased performance from the HVAC components. Additionally, these negligible changes are within the design margin of the ESF HVAC components.

DG fuel consumption and loading calculations The increase in DG loading due to DG voltage and frequency variation is used as input into the existing diesel fuel consumption and storage tank capacity calculation to verify that the increase in fuel oil consumption remains bounded. If variations in both voltage and frequency occur simultaneously, the effects were superimposed.

The maximum impact on DG loading is observed when both the voltage and frequency are at the upper TS limits of 4330 V and 60.4 Hz, where the steady state loading on the DG does not exceed the continuous rating of the DG. DG 1A, is selected for study since it has the heaviest steady-state load at the end of automatic sequencing. The diesel load will increase by 3.2% when both the voltage and frequency to be at their upper limits of 4330V and 60.4Hz. The new steady-state loading shows that Plant Vogtle Unit 1 & Unit 2 DGs continuous rating of 7000kW and 8750kVA is not exceeded due to the voltage and frequency variations.

Due to substantial margin available above the 68,000 gal required in each DG fuel oil storage tank by TS 3.8.3, Diesel Fuel Oil, Lube Oil, Starting Air, and Ventilation, Surveillance Requirement (SR) 3.8.3.1 for a 7-day fuel oil supply for one DG, this TS value is not affected by the small increased DG loading. Similarly, the

> 52,000 gal fuel oil supply required for entering TS 3.8.3 Action A continues to support the current licensing basis. The SR 3.8.1.4 requirement that each DG day tank contains 650 gal of fuel oil also continues to support the necessary volume to meet the current licensing basis requirement to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%.

Other loads such as battery chargers, inverters and similar type loads power demand are based on downstream conditions and are not impacted by upstream voltage and frequency variations. The battery chargers are maintained within their rated range even at a conservative +/- 10% voltage range to account for voltage loss in the circuit, therefore there will be no impact on the battery chargers ability to function as designed.

HVAC heaters Calculations have determined the HVAC heaters are capable of performing their required design function at the derated voltages that bound the proposed minimum steady state DG voltage.

Pressurizer Heaters Since the heaters are controlled to reduce power and then turn off when the pressurizer is hot enough over voltage is not a concern and requires no additional analysis. At the lower steady state DG voltage limit, the actual wattage for each group actual wattage is well above the TS 3.4.9, Pressurizer, requirement of

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-10 150 kW. Therefore, the DG voltage variance would not have an adverse effect on the Pressurizer Heater requirements. Additionally, DG frequency variances do not impact heater performance.

Miscellaneous 120 V AC Loads The adequacy of safety related devices energized from the 120 V distribution panels to perform their intended safety related function at degraded voltage is calculated based on voltages lower than the DG minimum steady state voltage.

The maximum steady state DG output voltage is bounded by the maximum 120 V buses rating. The effect of DG frequency variances is negligible on the 120 V loads as the loads do not include major rotating equipment (i.e., MOVs, large pumps, or large fans) that are subject to adverse performance based on frequency variances.

Miscellaneous DC Loads The battery chargers allowable input voltage and frequency range is much greater than the allowable DG output range. The battery chargers are maintained within their rated range, therefore there will be no impact on the battery chargers ability to function as designed. Consistent output voltage will be provided to supported DC loads. There are no adverse performance due to DG voltage or frequency variances for DC loads.

Assessment of Relief Valve and Pressure Switches This evaluation assessed the effect of increased DG frequency and voltage on pumps potentially receiving power from the DGs to assure that pressure relief valve or pressure switch actuation would not impact the ability of the plant to safely shutdown. The evaluation indicated that DG frequency and voltage uncertainty impacts on pump performance would not result in inadvertent pressure switch actuations that could impact the ability of the plant to safely shut down. There may be alarm actuations in certain alignments on low pressure in Auxiliary Feedwater, but flow delivery would still be met.

The analysis demonstrates that the components connected to the DGs have sufficient margin to allow for the voltage and frequency variations proposed in the TS. Therefore, the proposed changes in the TS SR voltage and frequency tolerances will ensure that the safety related equipment can meet the required performance.

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, paragraph (c) Technical specifications, requires including items in the following categories:

(1) Safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation; and (3) Surveillance requirements. The (1) safety limits, limiting safety system settings, and limiting control settings and (2) limiting conditions for operation, are not affected by this proposed amendment. In addition, the proposed changes to the plant specific Technical Specifications surveillance requirements, as justified by this license amendment request, continue to meet the scope required by 10 CFR 50.36(c)(3).

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-11 10 CFR Part 50 Appendix A, General Design Criterion (GDC) 17, ensures an onsite electric power system is provided to permit functioning of structures, systems, and components important to safety. As required by GDC 17, the design of the on-site emergency AC power system provides independence and redundancy to ensure an available source of power to the engineered safety features systems. The proposed TS Surveillance changes help to ensure the DGs and the on-site emergency AC power system remain capable of performing their functions.

10 CFR 50, Appendix A, GDC 18 requires electric power systems important to safety to be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. GDC 18 requires the systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems, as a whole and under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power between the nuclear power unit, the offsite power system, and the onsite power system. Provisions are made for periodic testing of the important components of the emergency power system. Further provision is made for periodic testing of the DGs to assure their capability to start and to accept loads within design limits. TS SR testing of the DGs and the emergency power system ensures they can perform as required during design basis events.

Regulatory Guide 1.9, Selection, Design, and Qualification of Emergency Diesel Generator Units Used as Standby (onsite) Onsite Electric Power Systems at Nuclear Power Plants provides guidance in the selection, design, and qualification of safety related diesel generator units, such that they be selected with sufficient capacity, be qualified and be maintained for reliability equal to or above the levels selected for a limiting event. VEGP Units 1 and 2 conforms with Regulatory Guide 1.9 guidance as discussed in Final Safety Analysis Report Section 1.9.9.2. The proposed changes do not adversely impact the level of conformance with Regulatory Guide 1.9.

4.2 Precedent Approved license amendment requests associated with revising DG Surveillances to adopt TSTF-163 include:

Pacific Gas and Electric Company submittal on March 28, 2011 (ML110880202) for Diablo Canyon, which was NRC approved on March 29, 2012 (ML120790338).

Approved license amendment requests associated with revising DG voltage and/or frequency in accordance with the NRC approved methodology in WCAP-17308-NP-A, recently included:

DTE Electric Company submitted on December 16, 2022 (ML22350A504) For Fermi 2, which was approved on December 8, 2023 (ML23310A149).

Exelon Generation submitted on December 15, 2021 (ML21349B378) for Limerick Units 1 and 2, which was approved on January 3, 2023 (ML22272A037).

Duke Energy submittal on August 19, 2020 (ML20233A258) for Catawba and McGuire, which was NRC approved on June 23, 2021 (ML21131A026).

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-12 Exelon Generation submittal on June 26, 2020 (ML20178A467) for Braidwood and Byron, which was NRC approved April 2, 2021 (ML21060B281).

Exelon Generation submittal on December 11, 2019 (ML19346E536) for Calvert Cliffs, which was NRC approved November 9, 2020 (ML20273A088).

4.3 No Significant Hazards Consideration Determination Analysis Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) for Vogtle Electric Generating Plant (VEGP) Units 1 and 2 to revise emergency diesel generator (EDG [or DG]) frequency and voltage ranges for TS 3.8.1, AC Sources - Operating, Surveillance Requirements. These changes reflect incorporation of Technical Specification Task Force (TSTF) traveler TSTF 163, Revision 2, "Minimum vs. Steady State Voltage and Frequency" (ML040500733), as well as changes to the steady state DG operating voltage and frequency ranges consistent with WCAP-17308-NP-A (ML17215A232) methodology. An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92(c), Issuance of amendment, as discussed below.

4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response

No.

The voltage and frequency ranges specified for DG operation are not associated with any accident initiator. The proposed changes do not affect the safety limits or limiting safety system settings as required by the plant specific Technical Specifications (TS). The proposed changes do not adversely affect the operation of any structures, systems, or components (SSCs) associated with an accident initiator or initiating sequence of events. The proposed changes continue to maintain the initial conditions and operating limits assumed during normal operation, assumed by the accident analysis, and assumed in anticipated operational occurrences. Therefore, the proposed changes do not result in any increase in probability of an analyzed accident occurring.

Verifying the ability of the DGs to maintain adequate voltage and frequency to support the proper operation of electrical and mechanical systems credited with accident mitigation does not increase the consequences of an accident. The proposed changes do not involve a change to any mitigation sequence or the predicted radiological releases due to postulated accident conditions. Thus, the consequences of the accidents previously evaluated are not adversely affected.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No.

The proposed changes would apply more restrictive steady state DG voltage and frequency operational acceptance criteria consistent with the DG design function to support the assumed loads, and retain the currently required minimum values for

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-13 voltage and frequency for DG loading at 11.4 seconds. The proposed changes have been found to continue to provide the required functional capability of the safety systems for previously evaluated accidents and anticipated operational occurrences. The proposed revisions do not change the function of the related systems, and thus, the changes do not introduce a new failure mode, malfunction or sequence of events that could adversely affect safety or safety-related equipment.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response

No.

The proposed changes continue to provide the required functional capability of the safety systems for previously evaluated accidents and anticipated operational occurrences. The proposed changes do not change the function of the related systems nor significantly affect the margins provided by the systems. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the requested changes.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.

ENVIRONMENTAL CONSIDERATION The proposed changes to the Technical Specifications (TS) are described in Section 2 of this Enclosure, which require a license amendment. SNC has evaluated this license amendment request against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21.

The requested amendment would change a surveillance requirement; however, meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that the amendment would not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be

Enclosure to NL-22-0267 Description and Assessment of the Proposed Changes E-14 released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.

REFERENCES (1)

Technical Specification Task Force (TSTF) traveler TSTF-163, Revision 2, "Minimum vs. Steady State Voltage and Frequency" (ML040500733)

(2)

WCAP-17308-NP-A, Treatment of Diesel Generator (DG) Technical Specification Frequency and Voltage Tolerances (ML17215A232)

(3)

NEI 15-03, Revision 0, Licensee Actions to Address Nonconservative Technical Specifications (ML15147A655)

(4)

Pacific Gas and Electric Company submittal on March 28, 2011 (ML110880202) for Diablo Canyon and NRC approval on March 29, 2012 (ML120790338)

(5)

DTE Electric Company submitted on December 16, 2022 (ML22350A504) For Fermi 2, which was approved on December 8, 2023 (ML23310A149).

(6)

Exelon Generation submitted on December 15, 2021 (ML21349B378) for Limerick Units 1 and 2, and NRC approval on January 3, 2023 (ML22272A037).

(7)

Duke Energy submittal on August 19, 2020 (ML20233A258) for Catawba and McGuire and NRC approval on June 23, 2021 (ML21131A026)

(8)

Exelon Generation submittal on June 26, 2020 (ML20178A467) for Braidwood and Byron and NRC approval April 2, 2021 (ML21060B281)

(9)

Exelon Generation submittal on December 11, 2019 (ML19346E536) for Calvert Cliffs and NRC approval November 9, 2020 (ML20273A088) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-1 Vogtle Electric Generating Plant Units 1&2 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources -

Operating, Surveillance Requirements Technical Specification Marked Up Proposed Changes

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-7 Amendment No. ___202 (Unit 1)

Amendment No. ___185 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I.

Required Action and associated Completion Time of Condition H not met.

I.1 Be in MODE 3.

AND I.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each required offsite circuit.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.2

NOTES--------------------------

1.

Performance of SR 3.8.1.7 satisfies this SR.

2.

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3.

A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

Verify each DG starts from standby conditions and achieves steady state voltage 4025 4040 V and 4330 V, and frequency 58.8 59.6 Hz and 61.2 60.4 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-2

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-9 Amendment No. ___158 (Unit 1)

Amendment No. ___140 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7

NOTE----------------------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and achieves:

a.

iIn 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady state voltage 4025 4040 V and 4330 V, and frequency 58.859.6 Hz and 61.260.4 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.8

NOTE-----------------------------

Credit may be taken for unplanned events that satisfy this SR.

Verify each DG rejects a load its associated single largest post accident load, and:

a.

Following load rejection, the frequency is 64.5 Hz;

b.

Within 3 seconds following load rejection, the voltage is 3750 V and 4330 V or 4550 V when performing the test synchronized with offsite power; and

c.

Within 3 seconds following load rejection, the frequency is 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-3

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-11 Amendment No. ___217 (Unit 1)

Amendment No. ___200 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10

NOTES--------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power signal:

a.

De-energization of emergency buses;

b.

Load shedding from emergency buses;

c.

DG auto-starts from standby condition and:

1.

energizes permanently connected loads in 11.5 seconds,

2.

energizes auto-connected shutdown loads through automatic load sequencer,

3.

maintains steady state voltage 3750 4040 V and 4330 V,

4.

maintains steady state frequency 58.859.6 Hz and 61.260.4 Hz, and

5.

supplies permanently connected and auto-connected shutdown loads for 5 minutes.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-4

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-12 Amendment No. ___217 (Unit 1)

Amendment No. ___200 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11

NOTES--------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and:

a.

In 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and 4330 V frequency 58.8 Hz;

b.

In 11.4 seconds after auto-start and during tests, aAchieves steady state voltage 4040 V and 4330 V and frequency 58.859.6 Hz and 61.260.4 Hz;

c.

Operates for 5 minutes;

d.

Permanently connected loads remain energized from the offsite power system; and

e.

Emergency loads are energized or auto-connected through the automatic load sequencer from the offsite power system.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-5

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-14 Amendment No. ___217 (Unit 1)

Amendment No. ___200 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14

NOTES--------------------------

1.

This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 6500 kW and 7000 kW.

Momentary transients outside of load range do not invalidate this test.

2.

All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves:

a.

, iIn 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady State voltage 4025 4040 V, and 4330 V and frequency 58.859.6 Hz and 61.260.4 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-6

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-17 Amendment No. ___217 (Unit 1)

Amendment No. ___200 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.18

NOTES---------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal:

a.

De-energization of emergency buses;

b.

Load shedding from emergency buses; and

c.

DG auto-starts from standby condition and:

1.

energizes permanently connected loads in 11.5 seconds,

2.

energizes auto-connected emergency loads through load sequencer,

3.

achieves steady state voltage:

3750 4040 V and 4330 V,

4.

achieves steady state frequency:

58.859.6 Hz and 61.260.4 Hz, and

5.

supplies permanently connected and auto-connected emergency loads for 5 minutes.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-7

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-18 Amendment No.___158 (Unit 1)

Amendment No. ___140 (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 Verify fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.20

NOTE--------------------------

All DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby condition, each DG achieves:

a.

, iIn 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady state voltage 4025 4040 V and 4330 V, and frequency 58.859.6 Hz and 61.260.4 Hz.

In accordance with the Surveillance Frequency Control Program to NL-22-0267 Technical Specification Marked Up Proposed Changes A1-8 to NL-22-0267 Technical Specification Clean Pages A2-1 Vogtle Electric Generating Plant Units 1&2 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources -

Operating, Surveillance Requirements Technical Specification Clean Pages

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-7 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I.

Required Action and associated Completion Time of Condition H not met.

I.1 Be in MODE 3.

AND I.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each required offsite circuit.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.2

NOTES--------------------------

1.

Performance of SR 3.8.1.7 satisfies this SR.

2.

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3.

A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

Verify each DG starts from standby conditions and achieves steady state voltage 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-2

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-9 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7

NOTE----------------------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and achieves:

a.

In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady state voltage 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.8

NOTE-----------------------------

Credit may be taken for unplanned events that satisfy this SR.

Verify each DG rejects a load its associated single largest post accident load, and:

a.

Following load rejection, the frequency is 64.5 Hz;

b.

Within 3 seconds following load rejection, the voltage is 3750 V and 4330 V or 4550 V when performing the test synchronized with offsite power; and

c.

Within 3 seconds following load rejection, the frequency is 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-3

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-11 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10

NOTES--------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power signal:

a.

De-energization of emergency buses;

b.

Load shedding from emergency buses;

c.

DG auto-starts from standby condition and:

1.

energizes permanently connected loads in 11.5 seconds,

2.

energizes auto-connected shutdown loads through automatic load sequencer,

3.

maintains steady state voltage 4040 V and 4330 V,

4.

maintains steady state frequency 59.6 Hz and 60.4 Hz, and

5.

supplies permanently connected and auto-connected shutdown loads for 5 minutes.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-4

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-12 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11

NOTES--------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and:

a.

In 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and frequency 58.8 Hz;

b.

Achieves steady state voltage 4040 V and 4330 V and frequency 59.6 Hz and 60.4 Hz;

c.

Operates for 5 minutes;

d.

Permanently connected loads remain energized from the offsite power system; and

e.

Emergency loads are energized or auto-connected through the automatic load sequencer from the offsite power system.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-5

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-14 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14

NOTES--------------------------

1.

This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 6500 kW and 7000 kW.

Momentary transients outside of load range do not invalidate this test.

2.

All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves:

a.

In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady State voltage 4040 V, and 4330 V and frequency 59.6 Hz and 60.4 Hz.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-6

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-15 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.15

NOTE-----------------------------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG:

a.

Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;

b.

Transfers loads to offsite power source; and

c.

Returns to ready-to-load operation.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.16

NOTE-----------------------------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

a.

Returning DG to ready-to-load operation; and

b.

Automatically energizing the emergency load from offsite power.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-7

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-16 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.17

NOTE-----------------------------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load block is within 10% of design interval for each load sequencer.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-8

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-17 Amendment No. ___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.18

NOTES---------------------------

1.

All DG starts may be preceded by an engine prelube period.

2.

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal:

a.

De-energization of emergency buses;

b.

Load shedding from emergency buses; and

c.

DG auto-starts from standby condition and:

1.

energizes permanently connected loads in 11.5 seconds,

2.

energizes auto-connected emergency loads through load sequencer,

3.

achieves steady state voltage:

4040 V and 4330 V,

4.

achieves steady state frequency:

59.6 Hz and 60.4 Hz, and

5.

supplies permanently connected and auto-connected emergency loads for 5 minutes.

In accordance with the Surveillance Frequency Control Program (continued) to NL-22-0267 Technical Specification Clean Pages A2-9

AC Sources - Operating 3.8.1 Vogtle Units 1 and 2 3.8.1-18 Amendment No.___ (Unit 1)

Amendment No. ___ (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 Verify fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.20

NOTE--------------------------

All DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby condition, each DG achieves:

a.

In 11.4 seconds, voltage 4025 V and frequency 58.8 Hz, and

b.

Steady state voltage 4040 V and 4330 V, and frequency 59.6 Hz and 60.4 Hz.

In accordance with the Surveillance Frequency Control Program to NL-22-0267 Technical Specification Clean Pages A2-10 to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

A3-1 Vogtle Electric Generating Plant Units 1&2 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources -

Operating, Surveillance Requirements Technical Specification Bases Marked up Proposed Changes (For Information Only)

AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-16 REVISION __77 BASES SURVEILLANCE The AC sources are designed to permit inspection and testing REQUIREMENTS of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 8). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of 3750 V is 90% of the nominal 4160 V output voltage.

This value, which is specified in ANSI C84.1 (Ref. 11), allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating. The specified maximum steady state output voltage of 4330 V will limit the 480 V bus voltage to within the maximum operating voltage specified for 460 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 460 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to 2% of the 60 Hz nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source, and that appropriate independence of offsite circuits is maintained. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.1.2 and SR 3.8.1.7 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition. to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

A3-2

AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-17 REVISION __77 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued)

REQUIREMENTS To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading.

For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.

In order to reduce stress and wear on diesel engines, the manufacturer recommends a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading.

These start procedures are the intent of Note 3.

SR 3.8.1.7 requires that the DG starts from standby conditions and achieves required voltage and frequency within 11.4 seconds. The 11.4 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter 15 (Ref. 5). SR 3.8.1.7 is consistent with the guidance for this SR contained in Section 2.2.3, "Fast Start Test," of Regulatory Guide 1.9 (Ref. 3), which requires verification that the DG "reaches required voltage and frequency within acceptable limits and time as defined in the plant technical specifications."

The 11.4 second start requirement is not applicable to SR 3.8.1.2 (see Note 3) when a modified start procedure as described above is used.

If a modified start is not used, the 11.4 second start requirement of SR 3.8.1.7 applies.

The criteria that in 11.4 seconds the DG achieves 4025 V and 58.8 Hz when the DG is started from a standby condition are starting and accelerating design criteria for the DG that are specified to confirm the capability of the DG to recover from a loading transient.

The ~10% for voltage and the ~2% for frequency are consistent with the guidance provided in Paragraph 1.4 of Regulatory Guide 1.9 (Ref. 3).

to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

A3-3

AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-18 REVISION __77 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued)

REQUIREMENTS SR 3.8.1.2 and SR 3.8.1.7 also demonstrate that the DG can achieve steady state voltage and frequency within the specified band around the nominal values of 4160 V and 60 Hz. The band placed around these nominal values is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following:

Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

Since SR 3.8.1.7 requires a 11.4 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2.

In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Any change in the scope or frequency of SR 3.8.1.2 or SR 3.8.1.7 requires reevaluation of STI Evaluation number 417332, in accordance with the Surveillance Frequency Control Program.

SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing with the offsite electrical system and accepting loads greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is an operational limitation to ensure circulating currents are minimized.

The load band is provided to avoid routine overloading of the DG. to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-24 REVISION __83 BASES SURVEILLANCE SR 3.8.1.10 (continued)

REQUIREMENTS The DG autostart time of 11.4 seconds is derived from requirements of the accident analysis to respond to a design basis large break LOCA. An additional tenth of a second is allowed for energizing permanently connected loads, thus the 11.5 second requirement in this surveillance. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.

The requirement to verify the connection and power supply of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.

For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

SR 3.8.1.10 also demonstrates that the DG can achieve steady state voltage and frequency within the specified band around the nominal values of 4160 V and 60 Hz. The band placed around these nominal values is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following:

Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-26 REVISION __83 BASES SURVEILLANCE SR 3.8.1.11 REQUIREMENTS (continued)

This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (11.4 seconds) from the design basis actuation signal (LOCA signal) and operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.11.d and SR 3.8.1.11.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.

The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The criteria that in 11.4 seconds the DG achieves 3750 V and 58.8 Hz when the DG is started from a standby condition are starting and accelerating design criteria for the DG that are specified to confirm the capability of the DG to recover from a loading transient.

The ~10% for voltage and the ~2% for frequency are consistent with the guidance provided in Paragraph 1.4 of Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.11 also demonstrates that the DG can achieve steady state voltage and frequency within the specified band around the nominal values of 4160 V and 60 Hz. The band placed around these nominal values is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following: to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-27 REVISION __83 BASES SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1, or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, or other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the surveillance are performed in MODE 1, or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

Examples of unplanned events may include:

1.

Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-31 REVISION __83 BASES SURVEILLANCE SR 3.8.1.14 REQUIREMENTS (continued)

This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 11.4 seconds. The 11.4 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.

The criteria that in 11.4 seconds the DG achieves 4025 V and 58.8 Hz when the DG is started from a standby condition are starting and accelerating design criteria for the DG that are specified to confirm the capability of the DG to recover from a loading transient.

The ~10% for voltage and the ~2% for frequency are consistent with the guidance provided in Paragraph 1.4 of Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.14 also demonstrates that the DG can achieve steady state voltage and frequency within the specified band. The band is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following:

Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by two Notes.

Note 1 ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients do not invalidate this test. The lower limit of the load band ensures the DG is sufficiently hot and the upper limit of the load band is to avoid an overload condition during routine testing. The upper and lower limits provide a reasonable band to operate the DG in for the specified run time. The Note recognizes that there are external grid conditions that can cause a shift in load sharing with the DG and allows the operator time to recognize and adjust load back into the band without invalidating the performance of to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-36 REVISION __83 BASES SURVEILLANCE SR 3.8.1.18 (continued)

REQUIREMENTS This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.10, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

SR 3.8.1.18 also demonstrates that the DG can achieve steady state voltage and frequency within the specified band around the nominal values of 4160 V and 60 Hz. The band placed around these nominal values is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following:

Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, or other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

A3-9

AC Sources Operating B 3.8.1 (continued)

Vogtle Units 1 and 2 B 3.8.1-38 REVISION __83 BASES SURVEILLANCE SR 3.8.1.20 REQUIREMENTS (continued)

This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

The criteria that in 11.4 seconds the DG achieves 4025 V and 58.8 Hz when the DG is started from a standby condition are starting and accelerating design criteria for the DG that are specified to confirm the capability of the DG to recover from a loading transient.

The ~10% for voltage and the ~2% for frequency are consistent with the guidance provided in Paragraph 1.4 of Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.20 also demonstrates that the DG can achieve steady state voltage and frequency within the specified band around the nominal values of 4160 V and 60 Hz. The band placed around these nominal values is based on the capability of the voltage regulator and governor. WCAP-17308-NP-A (Ref. 16) contains the methodology for evaluating the impact of variations in voltage and frequency, due to the voltage regulator and governor, on the following:

Pump flow and developed head to meet design basis requirements, DG loading calculations, DG fuel consumption calculations, Motor Operated Valve (MOV) performance, and Ventilation fans credited in the dose analyses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

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AC Sources Operating B 3.8.1 Vogtle Units 1 and 2 B 3.8.1-39 REVISION __83 BASES REFERENCES 1.

10 CFR 50, Appendix A, GDC 17.

2.

FSAR, Chapter 8.

3.

Regulatory Guide 1.9, Rev. 3, July 1993.

4.

FSAR, Chapter 6.

5.

FSAR, Chapter 15.

6.

Regulatory Guide 1.93, Rev. 0, December 1974.

7.

Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.

8.

10 CFR 50, Appendix A, GDC 18.

9.

Regulatory Guide 1.108, Rev. 1, August 1977.

10.

Regulatory Guide 1.137, Rev. 1, October 1979.

11.

IEEE Standard 308-1978.

12.

Generic Letter 91-04, "Changes in Technical Specification Intervals to Accommodate a 24-Month Fuel Cycle," April 2, 1991.

13.

STI Evaluation 417332.

14.

WCAP-16294-NP-A, Rev. 1, Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs, June 2010 15.

Vogtle Electric Generating Plant, Units 1 and 2 - Issuance of Amendments Regarding Implementation of Topical Report Nuclear Energy Institute NEI 06-09, Risk-Informed Technical Specifications Initiative 4B, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0-A (CAC Nos.

ME9555 and ME9556).

16.

WCAP-17308-NP-A, "Treatment of Diesel Generator (DG)

Technical Specification Frequency and Voltage Tolerances." to NL-22-0267 Technical Specification Bases Marked up Proposed Changes (For Information Only)

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v t e Letter Sequence Request
EPID:L-2024-LLA-0031, TSTF-163 (Approved, Closed)
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MONTHYEAR2024-06-05 [Table View]

NL-22-0267, License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements

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NL-22-0267, License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements

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