NRC-07-0012, Proposed License Amendment to Revise the Minimum Emergency Diesel Generator Voltage in Technical Specification 3.8.1 Surveillance Requirements
| ML070860204 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/19/2007 |
| From: | Cobb D DTE Energy |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| NRC-07-0012 | |
| Download: ML070860204 (32) | |
Text
t . 1, Donald K. Cobb Assistant Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy, Newport, MI 48166 Tel: 734.586.5201 Fax: 734.586.4172 DTE Energy-10 CFR 50.90 March 19, 2007 NRC-07-0012 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Proposed License Amendment to Revise the Minimum Emergency Diesel Generator Voltage in Technical Specification 3.8.1 Surveillance Requirements Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License, Appendix A, Technical Specifications (TS) to revise Surveillance Requirements (SRs) 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14 and 3.8.1.17 in TS 3.8.1, "AC Sources - Operating." Specifically, this proposed amendment would change the minimum Emergency Diesel Generator (EDG) output voltage acceptance criterion from 3740 to 3873 volts.
This proposed license amendment is being submitted per the guidance in NRC Administrative Letter 98-10 as a correction to a Technical Specification that was found to be non-conservative.
Attachment 1 provides an evaluation of the proposed license amendment, including an analysis of significant hazards consideration using the standards of 10 CFR 50.92.
Detroit Edison has concluded that the change proposed in this submittal does not result in a significant hazards consideration. Attachment 2 provides marked up pages of the existing TS to show the proposed change. Attachment 3 provides a clean version of the affected TS pages with the proposed change incorporated. Attachment 4 provides a copy of marked up TS Bases pages affected by this change. Attachment 4 is provided for information only.
Detroit Edison has reviewed the proposed change against the criteria of 10 CFR 51.22 and has concluded that it meets the criteria provided in 10 CFR 51.22(c)(9) for
USNRC NRC-07-0012 Page 2 a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.
Detroit Edison requests NRC approval of this proposed license amendment as soon as practical, with an implementation period of within 30 days following NRC approval. Pursuant to the guidance in Administrative Letter 98-10, administrative controls will remain in place to ensure adequate margins of safety are preserved until this proposed TS change has been approved and implemented.
The following commitment is being made in this document:
Pending NRC approval and the implementation of the proposed license amendment in letter NRC-07-0012, Detroit Edison will maintain administrative controls to ensure that EDG minimum output voltage acceptance criterion for Division I EDGs is equal or greater than 3873 volts.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Michigan State Official.
Should you have any questions or require additional information, please contact Mr.
Ronald W. Gaston of my staff at (734) 586-5197.
Sincerely, cc: NRC Project.Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission
i!
USNRC NRC-07-0012 Page 3 I, DONALD K. COBB, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
DONALD K. COBB Assistant Vice President - Nuclear Generation On this l/ 4-4 day of A ,2007 before me personally appeared Donald K. Cobb, being first duly sworn and says that he executed the foregoing as his free act and deed.
totary Public MAUM ARMI*'fA -- -
MOTARY PUBLIC MONROEbO, Wi -
W C~OMMISSION EXPIRES.Oct 11, 2007
ATTACHMENT 1 TO NRC-07-0012 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE THE MINIMUM VOLTAGE FOR EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING IN TS 3.8.1 EVALUATION OF THE PROPOSED LICENSE AMENDMENT to NRC 07-0012 Page 1 Evaluation of the Proposed License Amendment
Subject:
Revision of the Minimum Voltage for Emergency Diesel Generator Surveillance Testing in Technical Specification 3.8.1 TABLE OF CONTENTS Subject Page 1.0 Description 2 2.0 Proposed Change 2 3.0 Background 3 3.1 Emergency Diesel Generators 3 3.2 Loss of Power Instrumentation 5 3.3 License Amendment No. 4 5 3.4 NRC Administrative Letter 98-10 6 4.0 Technical Analysis 7 5.0 Regulatory Safety Analysis 8 5.1 No Significant Hazards Consideration 8 5.2 Applicable Regulatory Requirements 9 6.0 Environmental Considerations 9 7.0 References 10 to NRC 07-0012 Page 2 1.0 Description Detroit Edison is requesting NRC approval of this proposed revision to the Fermi 2 Technical Specification (TS) Number 3.8.1, "AC Sources - Operating." The proposed amendment would change the minimum voltage acceptance criterion for Emergency Diesel Generator (EDG)
Surveillance Testing in Surveillance Requirements (SRs) 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14 and 3.8.1.17 from 3740 to 3873 volts.
2.0 Proposed Change The current Fermi 2 TS Number 3.8.1, "AC Sources - Operating," includes the following SRs:
SR 3.8.1.2, "Verify each EDG starts and achieves steady state voltage > 3740 V and <4580 V and frequency > 58.8 Hz and < 61.2 Hz."
SR 3.8.1.7, "Verify each EDG starts from standby condition and achieves:
- a. In < 10 seconds, voltage > 3740 V and frequency > 58.8 Hz; and
- b. Steady state voltage > 3740 V and <4580 V and frequency > 58.8 Hz and
< 61.2 Hz."
SR 3.8.1.10, "Verify on simulated loss of offsite power signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in < 10 seconds,
- 2. energizes auto-connected shutdown loads through load sequencer,
- 3. maintains steady state voltage > 3740 V and < 4580 V,
- 4. maintains steady state frequency > 58.8 Hz and < 61.2 Hz, and
- 5. supplies permanently connected and auto-connected shutdown loads for > 5 minutes."
SR 3.8.1.11, "Verify on an actual or simulated Emergency Core Cooling System (ECCS) initiation signal each EDG auto-starts and:
- a. In < 10 seconds after auto-start and during tests, achieves voltage >_3740 V and frequency > 58.8 Hz; to NRC 07-0012 Page 3
- b. Achieves steady state voltage > 3740 V and < 4580 V, and frequency >
58.8 Hz and < 61.2 Hz; and
- c. Operates for > 5 minutes."
SR 3.8.1.14, "Verify each EDG starts and achieves:
- a. In < 10 seconds, voltage > 3740 V and frequency > 58.8 Hz; and
- b. Steady state voltage >_ 3740 V and < 4580 V and frequency >_58.8 Hz and
< 61.2 Hz."
SR 3.8.1.17, "Verify, on simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in < 10 seconds,
- 2. energizes auto-connected emergency loads through load sequencer,
- 3. achieves steady state voltage > 3740 V and < 4580 V,
- 4. achieves steady state frequency > 58.8 Hz and < 61.2 Hz, and
- 5. supplies permanently connected and auto-connected emergency loads for > 5 minutes."
The proposed revision would change all occurrences of the EDG minimum voltage requirement in SRs 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14 and 3.8.1.17 from 3740 to 3873 volts.
3.0 Background 3.1 Emergency Diesel Generators The onsite standby power source at Fermi 2 consists of four EDGs separated into two independent divisions; Division I includes EDG 11 and EDG 12, and Division II includes EDG 13 and EDG 14. Either divisional pair of diesel generator units is capable of supplying loads needed to safely shutdown the reactor and maintain it in a safe shutdown condition after a Design Basis Accident (DBA).
to NRC 07-0012 Page 4 All EDGs start automatically on a Loss of Coolant Accident (LOCA) signal or on an Emergency Safety Feature (ESF) bus degraded voltage or undervoltage signal. After an EDG has started, it automatically ties to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with a LOCA signal. The EDGs also start and operate in the standby mode without tying to the ESF bus on a LOCA signal alone.
Following the trip of offsite power, load shed relays strip nonpermanent loads from the ESF bus.
When the EDG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the EDG In the event of a loss of normal power, the ESF electrical loads are automatically connected to the EDGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a DBA such as a LOCA.
Certain required plant loads are returned to service in a predetermined sequence in order to prevent overloading of the EDGs in the process. Within about a minute after the EDG breaker closure, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service (i.e., available to start according to designed start signals).
Each EDG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. Each EDG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions, such as EDG in standby with the engine hot and EDG in standby with the engine at ambient condition. Additional EDG capabilities must be demonstrated to meet required surveillances, e.g., capability of the EDG to revert to standby status upon restoration of offsite power.
The EDGs are designed to permit inspection and testing of all important areas and features, especially those that have a standby function. Periodic component tests are supplemented by extensive functional tests during system outages and refueling outages (under simulated accident conditions). The SRs for demonstrating EDG operability are based on the recommendations of Regulatory Guide 1.9 (Reference 1) as addressed in the Fermi 2 UJFSAR.
Where the SRs require a minimum EDG voltage, an output voltage of 3740 volts is specified.
This voltage equates to about 90% of the nominal 4160 volt output voltage of the EDG. The 90% value was established based on ANSI Standard C84.1 and allows for voltage to the terminals of motors and other equipment not to drop below minimum operating voltage which is usually specified as 90% of nameplate voltage rating.
The 3740 volt minimum EDG output voltage requirement has been in the Fermi 2 TS since the original licensing of the plant.
to NRC 07-0012 Page 5 3.2 Loss of Power Instrumentation TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," requires LOP instrumentation for each function in Table 3.3.8.1-1 to be operable. Item 2 in the Table specifies the number of required channels per bus, the surveillance requirements and allowable values for the 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) function. Sub-item (2.a.) of this function, "Bus Undervoltage," includes allowable values under footnote (c). This footnote specifies a minimum voltage of 3873 V for Division I and 3628 V for Division II.
Each 4.16 kV emergency bus has its own independent LOP instrumentation and associated trip logic. The voltage for each bus is monitored at two levels, which can be considered as two different undervoltage Functions: Loss of Voltage and 4.16 kV Emergency Bus Undervoltage Degraded Voltage. Instrumentation for the loss of voltage function monitors the Class 1E emergency bus for a level of voltage that is insufficient to operate the required ESF equipment protecting the ESF equipment from damage caused from a loss of the preferred off-site power source. Instrumentation for the degraded voltage function monitors the Class 1E bus for a level of voltage from the preferred off-site power source that may be insufficient to operate the required ESF equipment, but is not low enough to cause the loss of voltage function to operate, thereby ensuring adequate voltage for ESF operation and protecting the ESF equipment from damage caused by low voltage operation. Both loss of voltage and degraded voltage functions within a bus cause identical actions; Class lE bus isolation, load shedding to prevent overloading of the associated EDQý transfers, and automatic starting of the associated EDG and load sequencer.
Both LOP Functions are automatically bypassed whenever the associated EDG is supplying its respective ESF bus. This ensures that the voltage dips encountered during load sequencing on the EDG will not interact with the load shedding feature.
3.3 License Amendment No. 4 In the original Fermi 2 TS, the minimum allowable value for the 4.16 kV Emergency Bus Undervoltage, Degraded Voltage function was specified as 3628 V for both Division I and II. In May 1986, it was determined that the 3628 V TS value for the 4.16 kV emergency bus, Division I, was not adequate to ensure sufficient voltage is available to operate the required ESF equipment under accident conditions.
On July 2, 1986, Detroit Edison submitted a License Amendment request (Reference 2) to the NRC proposing to revise the value for Division I of the 4.16 kV Emergency bus degraded voltage condition from 3628 to 3873 volts. The request stated that the non-conservative degraded voltage value was identified during an update of the degraded grid relay setpoint design calculations. It further stated that the Division I value should be changed to correspond to the minimum degraded grid voltage necessary to protect Class 1E equipment.
to NRC 07-0012 Page 6 Reference 2 stated that only Division I Class 1E buses are impacted by the change. The Division I design incorporates a Load Tap Changing (LTC) transformer located between the offsite power supply and the Class 1E 4.16 kV buses. In contrast, the Division II design provides a fixed -
ratio transformer between its offsite power supply and the Class 1E 4.16 kV buses. In Division II, voltage regulators, rather than an LTC transformer, are provided between the 4.16 kV buses and lower voltage bus loads. This reduces the voltage changes on Division II ESF buses under degraded voltage conditions. Based on that, the Division II degraded voltage setting (a minimum of 3628 volts) is adequate to ensure sufficient voltage is available to operate the required Division II ESF equipment.
The License Amendment Request did not include changes to the EDG minimum voltage surveillance requirements.
On August 22, 1986, the NRC approved License Amendment No. 4 (Reference 3) to the Fermi 2 TS. The Amendment, in part, revised the Division 14.16 kV Emergency Bus Undervoltage (Degraded Voltage) minimum setting from 3628 to 3873 volts.
3.4 NRC Administrative Letter 98-10 On August 25, 2006, a corrective action document was initiated to document an NRC-identified concern of a potential non-conservative TS requirement. The document stated that the TS value for EDG minimum voltage is lower than the TS value for Division I degraded grid voltage.
Accordingly, a tracking LCO was entered to ensure that a minimum acceptance criteria for future Division I EDG testing would include a minimum required voltage of 3873 volts.
In addition to implementing administrative controls, a design calculation update was initiated to determine the minimum required EDG voltage which will ensure that sufficient EDG voltage is available to operate the required ESF equipment under accident conditions.
As discussed above, following a trip of offsite power, load shed relays strip nonpermanent loads from the ESF bus. When the EDG is tied to the ESF bus, essential loads are then sequentially connected to its respective ESF bus by the automatic sequencer. Therefore, based on these design features, EDG loading is not necessarily equivalent to the same loading on the ESF bus when supplied by offsite power. Additionally, voltage loss over the cables connecting the EDGs with the Emergency buses had to be considered in the required EDG minimum voltage calculations.
On February 13, 2007, updated design calculations for the EDG loading were issued. The calculations document that, at a minimum EDG output voltage of 3873 volts for Division I and a minimum of 3628 volts for Division II, sufficient terminal voltage is available to required ESF equipment to operate under worst case accident conditions.
to NRC 07-0012 Page 7 4.0 Technical Analysis The Fermi 2 Class 1E Alternating Current (AC) Electrical Power Distribution System sources consist of the offsite power sources and the onsite 4.16 kV standby power source (EDGs 11, 12, 13, and 14). The design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the ESF systems. The Class 1E distribution system is divided into redundant load groups (Division I and Division II), so loss of any one group does not prevent the minimum safety functions from being performed. Each load group is connected to an offsite power supply and two EDGs.
All EDGs start automatically on a loss of coolant accident (LOCA) signal (i.e., low reactor water level signal or high drywell pressure signal) or on an ESF bus degraded voltage or undervoltage signal. Following the trip of offsite power, load shed relays strip nonpermanent loads from the ESF bus. When the EDG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the EDG.
TS 3.8.1, "AC Sources - Operating," includes several SRs for demonstrating EDG operability and ability to provide sufficient voltage for safe reactor shutdown and to mitigate the consequences of accidents. The current requirement for minimum EDG output voltage was established since the original licensing of the plant at 3740 volts. This value was established based on guidance contained in ANSI Standard C84.1 and is equal to about 90% of the nominal EDG output voltage (4160 volts).
Based on a recent evaluation of EDG loading and considering the current TS allowable value for emergency bus degraded voltage conditions in Division I, it has been determined that the current EDG minimum output voltage requirement in TS 3.8.1 SRs is not conservative. This condition has been dispositioned in accordance with NRC Administrative Letter 98-10 (Reference 4).
Administrative controls were initiated at the time of discovery to ensure that minimum acceptance criteria for future Division I EDG testing would include a minimum required voltage of 3873 volts. Furthermore, a review of Division I EDG testing records over the past three years indicates no output voltage below 4000 volts; therefore, it appears that the non-conservative TS value has not resulted in a challenge to plant safety and the capability of Division I EDGs to safely support reactor shutdown and the mitigation of accident consequences. Recent EDG SR records also indicate that the 3873 volts output voltage is achieved well within the 10 seconds interval required by the SRs. The evaluation determined that at a minimum EDG output voltage of 3873 volts for Division I and a minimum of 3628 volts for Division II, sufficient terminal voltage is available to required ESF equipment to operate under worst accident conditions.
This License Amendment request proposes to revise the minimum EDG output voltage acceptance criterion in TS 3.8.1 surveillances from 3740 to 3873 volts. This change is being conservatively proposed for both Divisions of the onsite standby EDGs for consistency between divisions so as not to challenge the human performance of plant personnel if different acceptance criteria for similar equipment were used.
to NRC 07-0012 Page 8 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. The proposed change of the minimum Emergency Diesel Generator (EDG) output voltage acceptance criterion in Technical Specification (TS) 3.8.1 Surveillance Requirements (SRs) does not involve a significant hazards consideration for the following reasons:
- 1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The increase in the minimum EDG output voltage acceptance criterion value in TS 3.8.1 surveillance requirements does not adversely affect any of the parameters in the accident analyses. The change increases the minimum allowed EDG output voltage acceptance criterion to ensure that sufficient voltage is available to operate the required Emergency Safety Feature (ESF) equipment under accident conditions. The increase in the minimum allowed EDG output voltage in the TS surveillance requirements ensures that adequate voltage is available to support the assumptions made in the Design Bases Accident (DBA) analyses. DBA analyses assume that onsite standby emergency power will provide an adequate power source to operate safe shutdown equipment and to mitigate consequences of design bases accidents. This conservative change of the acceptance criterion enhances the testing requirements of the onsite emergency diesel generators and ensures the reliability of this power source. Changing the acceptance criterion does not affect the probability of evaluated accidents and it provides better assurance of EDG reliability in.
mitigating consequences of accidents. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The change in the value of the minimum EDG output voltage acceptance criterion supports the assumptions in the accident analyses that sufficient voltage will be available to operate ESF equipment on the Class 1E buses when these buses are powered from the onsite emergency diesel generators. The maximum EDG output voltage of 4580 volts is not affected by this change. The change in the minimum EDG output voltage from 3740 to 3873 volts ensures the reliability of the onsite emergency power source. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
to NRC 07-0012 Page 9
- 3. The proposed change does not involve a significant reduction in the margin of safety.
This proposed license amendment involves a change in the minimum EDG output voltage acceptance criterion in TS 3.8.1 surveillance requirements. The surveillance frequency and the different test requirements are unchanged. The change provides a better assurance that the onsite power source is able to satisfy the design requirements assumed in the accident analyses to safely shutdown the reactor and mitigate the consequences of design bases accidents. Therefore, the proposed change will not involve a significant reduction in a margin of safety.
Based on the above, Detroit Edison has determined that the proposed license amendment does not involve a significant hazards consideration.
5.2 Applicable Regulatory Requirements General Design Criterion No. 18 (Reference 5), "Inspection and Testing of Electrical Power Systems," states, in part: "Electrical power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features..."
Regulatory Guide 1.9, Revision I (Reference 1) "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants," Section B, "Discussion," states, in part, "A diesel generator unit selected for use in an onsite electric power system should have the capability to (1) start and accelerate a number of large motor loads in rapid succession and be able to sustain the loss of all or any part of such loads and maintain voltage and frequency within acceptable limits, and (2) supply power continuously to the equipment needed to maintain the plant in a safe condition if an extended loss of offsite power occurs."
This proposed TS change does not affect the Fermi 2 compliance with these regulatory requirements as discussed in the Fermi 2 Updated Final Safety Analysis Report (UFSAR).
6.0 Environmental Considerations Detroit Edison has reviewed the proposed change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor does it significantly change the types or significantly increase the amounts of effluents that may be released offsite. The proposed change does not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed change meets the criteria provided in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.
to NRC 07-0012 Page 10 7.0
References:
- 1) U. S. Nuclear Regulatory Commission Regulatory Guide 1.9, " Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, November 1978
- 2) Detroit Edison's Letter to NRC, "Request for Exigent Amendment to the Fermi 2 Technical Specifications Governing ECCS Actuation Instrumentation Setpoints (Degraded Grid Relay Setpoint)," VP-86-0076, dated July 2, 1986
- 3) NRC Letter to Detroit Edison, "Issuance of Amendment No. 4 to Facility Operating License No. NPF-43, Fermi-2," August 22, 1986
- 4) U. S. Nuclear Regulatory Commission Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," December 29, 1998
- 5) Title 10 - Code of Federal Regulations, "Energy," Part 50, "Domestic Licensing of Production and Utilization Facilities," Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 18, "Inspection and Testing of Electrical Power Systems"
ATTACHMENT 2 TO NRC-07-0012 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE THE MINIMUM VOLTAGE FOR EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING IN TS 3.8.1 MARKED-UP TS PAGE Affected Pages:
3.8-3 3.8-4 3.8-5 3.8-6 3.8-7 3.8-9
AC Sources- Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit.
SR 3;8;1;2 ------------------- NOTES---
- 1. All EDG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
- 2. A modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.
Verify each EG 4s ts and achieves steady 31 days state voltage V and s 4580 V and rt3740 frequency : 58.8 z and s 61.2 Hz.
SR 3.8.1.3 -------------------NOTES -------------------
- 1. EDG loadings may include gradual loading as recommended by the manufacturer.
- 2. Momentary transients below the load 111it do not invalidate this test.
- 3. This Surveillance shall be conducted on only one EDG at a time.
Verify each EDG is synchronized and loaded 31 days and operates for ý 60 minutes at a load 2 2500 kW.
(continued)
(
FERMI - UNIT 2 3.8-3 Amendment No. 134
AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR' 3.8.1.4 Verify each day tank contains m 210 gal of 31 days fuel oil.
SR 3.8.1.5 Check for and remove accumulated water from 31 days each day tank.
SR 3.8.1.6 Verify each fuel oil transfer system 31 days operates to automatically transfer fuel oil from storage tanks to the day tanks.
SR 3.8.1.7 ------------------- NOTE ...................
All EDG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
Verify each EDG starts from standby 184 days condition and achieves:
- a. In s 10 seconds, voltage ý 3740 V and frequency z 58.8 Hz: and
- b. Steady state voltage - 3740 V and
- 458O V and frequency : 58.8 Hz and 61.2 Hz.
SR 3.8.1.8 Verify each EDG rejects a load greater than 18 months or equal to its associated single largest post-accident load. and following load rejection, the frequency is s 66.75 Hz.
(continued)
(.
FERMI UNIT 2 3.8-4 Amendment No. 134
AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.9 Verify each EDG does not trip and voltage 18 months is maintained
- 5267 V during and following a load rejection of Ž 2850 kW.
SR 3.8.1.10 -------------------NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify on simulated loss of offsite power 18 months signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in
- 10 seconds,
- 2. energizes auto-connected shutdown loads through load sequencer,
- 3. maintains steady state voltage
_ 374 V and
- 4580 V,
- 4. maintains steady state frequency 58.8 Hz and
- 61.2 Hz, and
- 5. supplies permanently connected and auto-connected shutdown loads for
> 5 minutes.
(continued)
FERMI - UNIT 2 3.8-5 Amendment No. /O , 140
AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.11 ------------------- NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify on an actual or simulated Emergency 18 months Core Cooling System (ECCS) initiation signal each EDG afto-starts ahd:
- a. In s 10 seconds after auto-start and durina tests, achieves fequency voltage 58Hz; 7___ -3)(--3740_)V and frqec 58.8Hz
- b. Achieves steady state voltage - 3740 V and 5 4580 V. and frequency a 58.8 Hz and 5 61.2 Hz: and
- c. Operates for m 5 minutes.
SR 3.8.1.12, Verify each EDG's automatic trips are 18 months bypassed on an actual or simulated emergency start signal except:
- a. Engine overspeed:
- b. Generator differential current:
- c. Low lube oil pressure;
- d. Crankcase overpressure: and
- e. Failure to start.
(continued)
FERMI - UNIT 2 3.8-6 Amendment No. 134
AC Sources- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SURVEILLANCE SR 3.8.1.13 NOTE ---------------------
Momentary transients outside the load range do not invalidate this test.
Verify each EDG operates for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: 18 months
- a. For all but the final ý 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded
& 2500 kW and 5 2600 kW: and
- b. For the final ý 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test loaded 2 2800 kW and s 2900 kW.
4-SR 3.8.1.14 -------------------NOTES ..............
- 1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated z 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded z 2500 kW or until operating temperatures have stabilized.
Momentary transients below the load limit do not invalidate this test.
- 2. All EDG starts may be preceded by an engine prelube period.
Verify each EDG starts and achieves: 18 months
- a. in
- 10 seconds, voltage t 374/ V and
- b. Steady state voltage a 374V and s 4580 V and frequency ý 58.8 Hz and s 61.2 Hz.
(continued)
/.
FERMI - UNIT 2 3.8-7 Amendment No. 134
AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SURVE ILLANCE SR 3.8.1.17 - ----------------- -NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify, on simulated loss of offsite power 18 months signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses:
- b. Load shedding from emergency buses:
and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in 5 10 seconds,
- 2. energizes auto-connected emergency loads through load sequencer.
- 3. ac " ves steady state voltage 3 V and 5 4580 V.
- 4. achieves steady state frequency 58.8 Hz and.5 61.2 Hz, and
- 5. supplies permanently connected and auto-,connected emergency loads for ' 5 minutes.
SR 3.8.1.18 -------------------NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify, when started simultaneously each 10 years EDG achieves, in ý 10 seconds. frequency 58.8 Hz.
-FERMI - UNIT 2 3.8-9 Amendment No. 134
ATTACHMENT 3 TO NRC-07-0012 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE THE MINIMUM VOLTAGE FOR EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING IN TS 3.8.1 CLEAN TS PAGE New Pages:
3.8-3 3.8-4 3.8-5 3.8-6 3.8-7 3.8-9
AC Sources -- Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit..
SR 3.8.1.2 -------------------NOTES---------------
- 1. All EDG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
- 2. A modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR--as recommended by the manufacturer- - .
Verify each EDG starts and achieves steady 31 days state voltage > 3873 V and 9 4580 V and frequency Ž 58.8 Hz and
- 61.2 Hz.
SR 3.8.1.3 -................
NOTES---------------
- 1. EDG loadings may include gradual loading as recommended by the manufacturer.
- 2. Momentary transients below the load limit do not invalidate this test.
- 3. This Surveillance shall be conducted on only one EDG at a time.
Verify each EDG is synchronized and loaded 31 days and operates for > 60 minutes at .a load
> 2500 kW.
(continued)
FERMI - UNIT 2 3.8-3 Amendment No. 0A#
AC Sources -- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.4 Verify each day tank contains
- 210 gal of 31 days fuel oil.
SR 3.8.1.5 Check for and remove accumulated water from 31 days each day tank.
SR 3.8.1.6 Verify each fuel oil transfer system 31 days operates to automatically transfer fuel oil from storage tanks to the day tanks.
SR 3.8.1.7 ................... NOTE----------------
- . AllEDG starts-may be preceded by-an engine-prelube period and followed by a warmup period prior to loading.
Verify each EDG starts from standby 184 days condition and achieves:
- a. In
- 10 seconds, voltage > 3873 V and frequency ! 58.8 Hz: and
- b. Steady state voltage Ž 3873 V and
- 4580 V and frequency ; 58.8 Hz and
- 61.2 Hz.
SR 3.8.1.8 Verify each EDG rejects a load greater than 18 months or equal to its associated single largest post-accident load, and following load rejection, the frequency is < 66.75 Hz.
(continued)
FERMI - UNIT 2 3.8-4 Amendment No. /
AC Sources -- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.9 Verify each EDG does not trip and voltage 18 months is maintained 9 5267 V during and following a load rejection of ! 2850 kW.
SR 3.8.1.10 ------------------NOTE ---
All EDG starts may be preceded by an engine prelube period.
Verify on simulated loss of offsite power 18 months signal:
- a. De-energization of emergency buses; b_.._. Load shedding from emergency buses;.
and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in
- 10 seconds,
- 2. energizes auto-connected shutdown loads through load sequencer,
- 3. maintains steady state voltage 3873 V and
- 4580 V,
- 4. maintains steady state frequency 58.8 Hz and
- 61.2 Hz, and
- 5. supplies permanently connected and auto-connected shutdown loads for 2 5 minutes.
(continued)
FERMI - UNIT 2 3.8-5 Amendment No. /m4, i/'4#
AC Sources-'Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.11 ------------------ NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify on an actual or simulated Emergency 18 months Core Cooling System (ECCS) initiation signal each EDG auto-starts and:
- a. In
- 10 seconds after auto-start and during tests, achieves voltage
Ž 3873 V and frequency Ž 58.8 Hz;
- b. Achieves steady state voltage Ž 3873 V and
- 4580 V, and frequency Ž 58.8 Hz and 9 61.2 Hz; and
- c. Operates for Ž5 minutes.
SR 3.8.1.12 Verify each EDG's automatic trips are 18 months bypassed on an actual or simulated emergency start signal except:
- a. Engine overspeed;
- b. Generator differential current;
- c. Low lube oil pressure;
- d. Crankcase overpressure; and
- e. Failure to start.
(continued)
FERMI - UNIT 2 3.8-6 Amendment No. j#'
AC Sources -- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.13 ------------------NOTE----------------
Momentary transients outside the load range do not invalidate this test.
Verify each EDG operates for
- 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: 18 months
- a. For all but the final Ž 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2500 kW and
- 2600 kW; and
- b. For the final Ž 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test loaded ! 2800 kW and
- 2900 kW.
SR 3.8.1.14 ................. NOTES---------------
- 1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated
Ž 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded : 2500 kW or until operating temperatures have stabilized.
Momentary transients below the load limit do not invalidate this test.
- 2. All EDG starts may be preceded by an engine prelube period.
Verify each EDG starts and achieves: 18 months
- a. In
- 10 seconds, voltage Ž 3873 V and frequency
- 58.8 Hz; and
- b. Steady state voltage Ž 3873 V and
- 4580 V and frequency Ž 58.8 Hz and 61.2 Hz.
(continued)
FERMI - UNIT 2 3.8-7 Amendment No. W
AC Sources -- Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.81.17 ------------------NOTE-All EDG starts may be preceded by an engine prel ube period.
Verify, on simulated loss of offsite power 18 months signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. EDG auto-starts and:
- 1. energizes permanently connected loads in
- 10 seconds,
- 2. energizes auto-connected emergency loads through load sequencer,
- 3. achieves steady state voltage
> 3873 V and
- 4580 V,
- 4. achieves steady state frequency
> 58.8 Hz and
- 61.2 Hz, and
- 5. supplies permanently connected and auto-connected emergency loads for Ž 5 minutes.
SR 3.8.1.18 -------------------NOTE --------------------
All EDG starts may be preceded by an engine prelube period.
Verify, when started simultaneously each 10 years EDG achieves, in
- 10 seconds, frequency
Ž 58.8 Hz.
FERMI - UNIT 2 3.8-9 Amendment No
ATTACHMENT 4 TO NRC-07-0012 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE THE MINIMUM VOLTAGE FOR EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING IN TS 3.8.1 MARKED-UP TS BASES PAGES (For Information Only)
Affected pages:
B 3.8.1-8 B 3.8.1-9 B 3.8.1-20
AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)
Operating," must be immediately entered. This allows Condition E to provide requirements for the loss of the offsite circuit and one EDG without regard to whether a division is de-energized. LCO 3.8.7 provides the appropriate restrictions for a de-energized division.
According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition E for a period that should not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In Condition E, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition D (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration-to a single bus or switching failure.*The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.
F.1 and F.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, 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 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
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, 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 EDGs are based on 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 UFSAR.
Where the. SRs discussed herein specify voltage and frequency tolerances, the following summary is a plicable. The minimum steady state output voltage of ..........
-ncminl 4160 V output voltage. Thi saluc, which i:_*-
FERMI - UNIT 2 B 3.8.1-8 Revision 35
a AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)
I*s 1 is 4 ,s' -th.
t\ ,._.nas .f..000 .V, ........
,,,tor u*ilmprtn II J es*ie.* 4( J20 V !e'.e'e where miimum oper--ting vlt] i *'n iicil-ly cpife-0% of name plte-ratin The specified maximum steady state output voltage of 4580 V is equal to avAQI 4 ,Jw 4k,, the maximum operating voltage specified for 4000 V motors.
It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more
%b'vs8"I,4" than the maximum rated operating voltages. The specified
) minimum and maximum frequencies of the EDG are 58.8 Hz and d . --bI*%.* 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations found 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 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.
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 maintain the unit in a safe shutdown condition.
To minimize the mechanical stress and wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note I for SR 3.8.1.2 and the Note for SR 3.8.1.7) to indicate that all EDG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup prior to loading.
FERMI - UNIT 2 B 3.8.1--9 Revision 0
M AC Sources -Operating B 3.8.1
,BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.
- 2. UFSAR, Sections 8.2 and 8.3.
- 4. UFSAR, Chapter 6.
- 5. UFSAR, Chapter 15.
- 10. Regul-atory-Guide 1.-137..- -
ANLC'~ 1, 1982 9-* *eef*e 11.
- 12. UFSAR, Section 6.3.
- 13. ASME Boiler and Pressure Vessel Code, Section XI.
- 14. IEEE Standard 308.
FERMI - UNIT 2 B 3 .8.1 -20 Revision 0