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               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
ACTION f      LCO 3.0.4.b is not applicable to DGs.
ACTION f      LCO 3.0.4.b is not applicable to DGs.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION a        A. One [required] offsite                  A.1      Perform SR 3.8.1.1 for                  1 hour ACTION c                                                                                                                                      4 circuit inoperable.                            [required] OPERABLE                                                            5 for reasons other offsite circuit.                        AND than Condition C Once per 8 hours thereafter AND DOC L20                                                    A.2      Declare required feature(s)              24 hours from with no offsite power                    discovery of no offsite available inoperable when                power to one train                        5 its redundant required                  concurrent with 6.9 kV Shutdown feature(s) is inoperable.                inoperability of Board 1A-A or 1B-B redundant required feature(s)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION a        A. One [required] offsite                  A.1      Perform SR 3.8.1.1 for                  1 hour ACTION c                                                                                                                                      4 circuit inoperable.                            [required] OPERABLE                                                            5 for reasons other offsite circuit.                        AND than Condition C Once per 8 hours thereafter AND DOC L20                                                    A.2      Declare required feature(s)              24 hours from with no offsite power                    discovery of no offsite available inoperable when                power to one train                        5 its redundant required                  concurrent with 6.9 kV Shutdown feature(s) is inoperable.                inoperability of Board 1A-A or 1B-B redundant required feature(s)
AND SEQUOYAH UNIT 1                                                                                                    Amendment XXX Westinghouse STS                                            3.8.1-1                                                Rev. 4.0            1 Enclosure 2, Volume 13, Rev. 0, Page 47 of 638
AND SEQUOYAH UNIT 1                                                                                                    Amendment XXX Westinghouse STS                                            3.8.1-1                                                Rev. 4.0            1 Enclosure 2, Volume 13, Rev. 0, Page 47 of 638
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deleted if the unit design is                  to OPERABLE status.
deleted if the unit design is                  to OPERABLE status.
such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.
such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.
                  --------------------------------------
F. [ One [required]
F. [ One [required]
[automatic load sequencer] inoperable.
[automatic load sequencer] inoperable.
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DOC A05                            1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
DOC A05                            1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
4.8.1.1.2.a.4                      [ 2. A modified DG start involving idling and gradual                                              4 Note
4.8.1.1.2.a.4                      [ 2. A modified DG start involving idling and gradual                                              4 Note
* 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. ]                                                      4
* 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. ]                                                      4 4.8.1.1.2.a.4                      Verify each DG starts from standby conditions and                      [ 31 days achieves steady state voltage  [3740] V and                                                        6 7260
                                  ---------------------------------------------------------------------
4.8.1.1.2.a.4                      Verify each DG starts from standby conditions and                      [ 31 days achieves steady state voltage  [3740] V and                                                        6 7260
[4580] V, and frequency  [58.8] Hz and                    6800    OR                      4
[4580] V, and frequency  [58.8] Hz and                    6800    OR                      4
[61.2] Hz.
[61.2] Hz.
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* 3. This Surveillance shall be conducted on only one DG at a time.
* 3. This Surveillance shall be conducted on only one DG at a time.
DOC M02                        4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
DOC M02                        4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
                                ---------------------------------------------------------------------
4.8.1.1.2.a.5                  Verify each DG is synchronized and loaded and                          [ 31 days operates for  60 minutes at a load  [4500] kW and                                                    6
4.8.1.1.2.a.5                  Verify each DG is synchronized and loaded and                          [ 31 days operates for  60 minutes at a load  [4500] kW and                                                    6
[5000] kW.                                      3960                OR                      4 4400 In accordance with the Surveillance Frequency Control Program ]            6 engine-mounted day 3.8.1.1.b.2      SR 3.8.1.4    Verify each day tank [and engine mounted tank]                        [ 31 days              1 4  6 4.8.1.1.2.a.1                  contains  [220] gal of fuel oil.
[5000] kW.                                      3960                OR                      4 4400 In accordance with the Surveillance Frequency Control Program ]            6 engine-mounted day 3.8.1.1.b.2      SR 3.8.1.4    Verify each day tank [and engine mounted tank]                        [ 31 days              1 4  6 4.8.1.1.2.a.1                  contains  [220] gal of fuel oil.
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4.8.1.1.2.a.4  SR 3.8.1.7          ------------------------------NOTE-------------------------------
4.8.1.1.2.a.4  SR 3.8.1.7          ------------------------------NOTE-------------------------------
DOC A05                            All DG starts may be preceded by an engine prelube period.
DOC A05                            All DG starts may be preceded by an engine prelube period.
                                    ---------------------------------------------------------------------
Verify each DG starts from standby condition and                      [ 184 days achieves:                                                                                              6 6800 OR
Verify each DG starts from standby condition and                      [ 184 days achieves:                                                                                              6 6800 OR
: a. In  [10] seconds, voltage  [3740] V and frequency  58.8] Hz and                                        In accordance              4 6800                  7260 with the
: a. In  [10] seconds, voltage  [3740] V and frequency  58.8] Hz and                                        In accordance              4 6800                  7260 with the
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4.8.1.1.1.b  SR 3.8.1.8              ------------------------------NOTE-------------------------------
4.8.1.1.1.b  SR 3.8.1.8              ------------------------------NOTE-------------------------------
[ This Surveillance shall not normally be performed                                            4 DOC L06                              in MODE 1 or 2. 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.
[ This Surveillance shall not normally be performed                                            4 DOC L06                              in MODE 1 or 2. 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.
INSERT 6
INSERT 6 the 4.8.1.1.1.b                          Verify [automatic [and] manual] transfer of AC power                  [ [18] months      6 Note ##
                                      ---------------------------------------------------------------------
the 4.8.1.1.1.b                          Verify [automatic [and] manual] transfer of AC power                  [ [18] months      6 Note ##
sources from the normal offsite circuit to each                                                1 alternate [required] offsite circuit.                                  OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply                              In accordance with the Surveillance Frequency Control Program ] ]              6  4 SEQUOYAH UNIT 1                                                                                            Amendment XXX Westinghouse STS                                              3.8.1-8                                      Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 59 of 638
sources from the normal offsite circuit to each                                                1 alternate [required] offsite circuit.                                  OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply                              In accordance with the Surveillance Frequency Control Program ] ]              6  4 SEQUOYAH UNIT 1                                                                                            Amendment XXX Westinghouse STS                                              3.8.1-8                                      Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 59 of 638


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Enclosure 2, Volume 13, Rev. 0, Page 61 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 61 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1  SR 3.8.1.9      ------------------------------NOTES-----------------------------                                      5 DOC M04                        [1. This Surveillance shall not normally be                                                    4 performed in MODE 1 or 2. 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.
SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1  SR 3.8.1.9      ------------------------------NOTES-----------------------------                                      5 DOC M04                        [1. This Surveillance shall not normally be                                                    4 performed in MODE 1 or 2. 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.
DOC M04                        2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor  [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                            4
DOC M04                        2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor  [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                            4 4.8.1.1.2.g.1                  Verify each DG rejects a load greater than or equal                    [ [18] months to its associated single largest post-accident load,                                                  6 and:                                                                  OR DOC L15                        a. Following load rejection, the frequency is                      In accordance
                                ---------------------------------------------------------------------
4.8.1.1.2.g.1                  Verify each DG rejects a load greater than or equal                    [ [18] months to its associated single largest post-accident load,                                                  6 and:                                                                  OR DOC L15                        a. Following load rejection, the frequency is                      In accordance
[63] Hz,                                                      with the                4 66.5                                                              Surveillance 4.8.1.1.2.g.1                  b. Within [3] seconds following load rejection, the                Frequency voltage is  [3740] V and  [4580] V, and                      Control Program ]      4    6 6800                7260 4.8.1.1.2.g.1                  c. Within [3] seconds following load rejection, the frequency is  [58.8] Hz and  [61.2] Hz.                                              4 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                3.8.1-9                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 61 of 638
[63] Hz,                                                      with the                4 66.5                                                              Surveillance 4.8.1.1.2.g.1                  b. Within [3] seconds following load rejection, the                Frequency voltage is  [3740] V and  [4580] V, and                      Control Program ]      4    6 6800                7260 4.8.1.1.2.g.1                  c. Within [3] seconds following load rejection, the frequency is  [58.8] Hz and  [61.2] Hz.                                              4 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                3.8.1-9                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 61 of 638


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SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2  SR 3.8.1.10          ------------------------------NOTES-----------------------------                                      5 DOC M04                              [ 1. This Surveillance shall not normally be                                                  4 performed in MODE 1 or 2. 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.
SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2  SR 3.8.1.10          ------------------------------NOTES-----------------------------                                      5 DOC M04                              [ 1. This Surveillance shall not normally be                                                  4 performed in MODE 1 or 2. 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.
DOC M04                            2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
DOC M04                            2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                                4
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                                4 4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is                            [ [18] months maintained  [5000] V during and following a load                                                    6 rejection of  [4500] kW and  [5000] kW.                              OR                      4 3960                  4400 In accordance with the Surveillance Frequency Control Program ]          6 SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                    3.8.1-10                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 62 of 638
                                    ---------------------------------------------------------------------
4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is                            [ [18] months maintained  [5000] V during and following a load                                                    6 rejection of  [4500] kW and  [5000] kW.                              OR                      4 3960                  4400 In accordance with the Surveillance Frequency Control Program ]          6 SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                    3.8.1-10                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 62 of 638


Enclosure 2, Volume 13, Rev. 0, Page 63 of 638 CTS                                                                                                        AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 63 of 638 CTS                                                                                                        AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
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For DGs 1A-A and 1B-B, this 5
For DGs 1A-A and 1B-B, this 5
DOC L11                            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.
DOC L11                            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                    [ [18] months signal:                                                                                                6 shutdown boards                  OR 4.8.1.1.2.d.4.a)                  a. De-energization of emergency buses,                                                          1 shutdown boards                  In accordance 4.8.1.1.2.d.4.a)                  b. Load shedding from emergency buses,                                  with the Surveillance 4.8.1.1.2.d.4.b)                  c. DG auto-starts from standby condition and:                          Frequency Control Program ]        6
Verify on an actual or simulated loss of offsite power                    [ [18] months signal:                                                                                                6 shutdown boards                  OR 4.8.1.1.2.d.4.a)                  a. De-energization of emergency buses,                                                          1 shutdown boards                  In accordance 4.8.1.1.2.d.4.a)                  b. Load shedding from emergency buses,                                  with the Surveillance 4.8.1.1.2.d.4.b)                  c. DG auto-starts from standby condition and:                          Frequency Control Program ]        6
: 1.      Energizes permanently connected loads 4
: 1.      Energizes permanently connected loads 4
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DOC A05                              [ 1. All DG starts may be preceded by prelube                                                  4 period.
DOC A05                              [ 1. All DG starts may be preceded by prelube                                                  4 period.
For DGs 1A-A and 1B-B, this DOC L11                              2. This Surveillance shall not normally be                                                  5 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.
For DGs 1A-A and 1B-B, this DOC L11                              2. This Surveillance shall not normally be                                                  5 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.
                                    ---------------------------------------------------------------------
4.8.1.1.2.d.5                        Verify on an actual or simulated Engineered Safety                    [ [18] months Feature (ESF) actuation signal each DG auto-starts                                                6 from standby condition and:                                            OR
4.8.1.1.2.d.5                        Verify on an actual or simulated Engineered Safety                    [ [18] months Feature (ESF) actuation signal each DG auto-starts                                                6 from standby condition and:                                            OR
: a. In  [10] seconds after auto-start and during                    In accordance tests, achieves voltage  [3740] V and                          with the frequency  [58.8] Hz,                  6800                    Surveillance 4
: a. In  [10] seconds after auto-start and during                    In accordance tests, achieves voltage  [3740] V and                          with the frequency  [58.8] Hz,                  6800                    Surveillance 4
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Enclosure 2, Volume 13, Rev. 0, Page 65 of 638 CTS                                                                                                          AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 65 of 638 CTS                                                                                                          AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c)  SR 3.8.1.13          ------------------------------NOTE-------------------------------
SURVEILLANCE                                                  FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c)  SR 3.8.1.13          ------------------------------NOTE-------------------------------
DOC L11                                  [ This Surveillance shall not normally be performed                                            4  5 in MODE 1 or 2. 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. ]                                                          4
DOC L11                                  [ This Surveillance shall not normally be performed                                            4  5 in MODE 1 or 2. 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. ]                                                          4 4.8.1.1.2.d.6.c)                        Verify each DG's noncritical automatic trips are                      [ [18] months              6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an                        OR                            4 actual or simulated ESF actuation signal].
                                        ---------------------------------------------------------------------
4.8.1.1.2.d.6.c)                        Verify each DG's noncritical automatic trips are                      [ [18] months              6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an                        OR                            4 actual or simulated ESF actuation signal].
                                                                                 , or both                      In accordance with the Surveillance Frequency Control Program ]            6 SEQUOYAH UNIT 1                                                                                          Amendment XXX Westinghouse STS                                      3.8.1-13                                          Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 65 of 638
                                                                                 , or both                      In accordance with the Surveillance Frequency Control Program ]            6 SEQUOYAH UNIT 1                                                                                          Amendment XXX Westinghouse STS                                      3.8.1-13                                          Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 65 of 638


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DOC M04                        3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
DOC M04                        3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.
                                ---------------------------------------------------------------------
4.8.1.1.2.g.3                  Verify each DG operates for  24 hours:                                [ [18] months 6
4.8.1.1.2.g.3                  Verify each DG operates for  24 hours:                                [ [18] months 6
: a. For  [2] hours loaded  [5250] kW and                          OR
: a. For  [2] hours loaded  [5250] kW and                          OR
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DOC A05                          1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  [2] hours loaded  [4500] kW and  [5000] kW.                                        3960                                    4 4400          and  2140 kvar and  2370 kvar DOC L09                                Momentary transients outside of load range do not invalidate this test.
DOC A05                          1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  [2] hours loaded  [4500] kW and  [5000] kW.                                        3960                                    4 4400          and  2140 kvar and  2370 kvar DOC L09                                Momentary transients outside of load range do not invalidate this test.
DOC A05                          2. All DG starts may be preceded by an engine prelube period.
DOC A05                          2. All DG starts may be preceded by an engine prelube period.
                                  ---------------------------------------------------------------------
Verify each DG starts and achieves:                                        [ [18] months 6800 6
Verify each DG starts and achieves:                                        [ [18] months 6800 6
DOC L19                          a. In  [10] seconds, voltage  [3740] V and                            OR frequency  [58.8] Hz and                                                                    4 6800                  7260 In accordance 4.8.1.1.2.g.4                    b. Steady state voltage  [3740] V, and  [4580] V                      with the and frequency  [58.8] Hz and  [61.2] Hz.                          Surveillance Frequency Control Program ]          6 4.8.1.1.2.d                              For DGs 1A-A and 1B-B, this 4.8.1.1.2.d.9    SR 3.8.1.16    ------------------------------NOTE-------------------------------
DOC L19                          a. In  [10] seconds, voltage  [3740] V and                            OR frequency  [58.8] Hz and                                                                    4 6800                  7260 In accordance 4.8.1.1.2.g.4                    b. Steady state voltage  [3740] V, and  [4580] V                      with the and frequency  [58.8] Hz and  [61.2] Hz.                          Surveillance Frequency Control Program ]          6 4.8.1.1.2.d                              For DGs 1A-A and 1B-B, this 4.8.1.1.2.d.9    SR 3.8.1.16    ------------------------------NOTE-------------------------------
DOC L11                          This Surveillance shall not normally be performed in                                                  5 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.
DOC L11                          This Surveillance shall not normally be performed in                                                  5 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:                                                            [ [18] months 6
Verify each DG:                                                            [ [18] months 6
4.8.1.1.2.d.9.a                  a. Synchronizes with offsite power source while                        OR loaded with emergency loads upon a simulated restoration of offsite power,                                        In accordance with the 4.8.1.1.2.d.9.b                  b. Transfers loads to offsite power source, and                        Surveillance Frequency 4.8.1.1.2.d.9.c                  c. Returns to ready-to-load operation.                                  Control Program ]        6 SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                  3.8.1-15                                              Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 67 of 638
4.8.1.1.2.d.9.a                  a. Synchronizes with offsite power source while                        OR loaded with emergency loads upon a simulated restoration of offsite power,                                        In accordance with the 4.8.1.1.2.d.9.b                  b. Transfers loads to offsite power source, and                        Surveillance Frequency 4.8.1.1.2.d.9.c                  c. Returns to ready-to-load operation.                                  Control Program ]        6 SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                  3.8.1-15                                              Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 67 of 638
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[ 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.
[ 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.
Credit may be taken for unplanned events that satisfy this SR.
                                        ---------------------------------------------------------------------
7 Verify, with a DG operating in test mode and                          [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:                          OR
7 Verify, with a DG operating in test mode and                          [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:                          OR
: a. Returning DG to ready-to-load operation and                        In accordance with the
: a. Returning DG to ready-to-load operation and                        In accordance with the
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in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4
in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4
taken for unplanned events that satisfy this SR. ]
taken for unplanned events that satisfy this SR. ]
                                        ---------------------------------------------------------------------
setpoint for                              load Verify interval between each sequenced load block                      [ [18] months is within +/- [10% of design interval] for each                timer 3        6 5% of design    emergency [and shutdown] load sequencer.                              OR In accordance with the Surveillance Frequency 6
setpoint for                              load Verify interval between each sequenced load block                      [ [18] months is within +/- [10% of design interval] for each                timer 3        6 5% of design    emergency [and shutdown] load sequencer.                              OR In accordance with the Surveillance Frequency 6
Control Program ]
Control Program ]
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SURVEILLANCE                                                    FREQUENCY 4.8.1.1.2.d 4.8.1.1.2.d.6    SR 3.8.1.19      ------------------------------NOTES-----------------------------                                  7 DOC A05 18  1. All DG starts may be preceded by an engine prelube period.
SURVEILLANCE                                                    FREQUENCY 4.8.1.1.2.d 4.8.1.1.2.d.6    SR 3.8.1.19      ------------------------------NOTES-----------------------------                                  7 DOC A05 18  1. All DG starts may be preceded by an engine prelube period.
For DGs 1A-A and 1B-B, this DOC L11                            2. This Surveillance shall not normally be                                                    5 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.
For DGs 1A-A and 1B-B, this DOC L11                            2. This Surveillance shall not normally be                                                    5 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.
                                    ---------------------------------------------------------------------
4.8.1.1.2.d.6                      Verify on an actual or simulated loss of offsite power                  [ [18] months signal in conjunction with an actual or simulated                                                  6 ESF actuation signal:                                                  OR 4.8.1.1.2.d.6.a                                                              shutdown boards
4.8.1.1.2.d.6                      Verify on an actual or simulated loss of offsite power                  [ [18] months signal in conjunction with an actual or simulated                                                  6 ESF actuation signal:                                                  OR 4.8.1.1.2.d.6.a                                                              shutdown boards
: a. De-energization of emergency buses,                              In accordance          1 4.8.1.1.2.d.6.a                                                              shutdown boards                with the
: a. De-energization of emergency buses,                              In accordance          1 4.8.1.1.2.d.6.a                                                              shutdown boards                with the
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Enclosure 2, Volume 13, Rev. 0, Page 70 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 70 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY 4.8.1.1.2.e  SR 3.8.1.20      ------------------------------NOTE-------------------------------                              7 DOC A05                    19  All DG starts may be preceded by an engine prelube period.
SURVEILLANCE                                                  FREQUENCY 4.8.1.1.2.e  SR 3.8.1.20      ------------------------------NOTE-------------------------------                              7 DOC A05                    19  All DG starts may be preceded by an engine prelube period.
                                ---------------------------------------------------------------------
4.8.1.1.2.e                    Verify when started simultaneously from standby                        [ 10 years condition, each DG achieves: ,                                                                  6 OR
4.8.1.1.2.e                    Verify when started simultaneously from standby                        [ 10 years condition, each DG achieves: ,                                                                  6 OR
: a. In  [10] seconds, voltage  [3740] V and                                                    4 frequency  [58.8] Hz and .                  6800              In accordance with the
: a. In  [10] seconds, voltage  [3740] V and                                                    4 frequency  [58.8] Hz and .                  6800              In accordance with the
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               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
ACTION f      LCO 3.0.4.b is not applicable to DGs.
ACTION f      LCO 3.0.4.b is not applicable to DGs.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION a        A. One [required] offsite                A.1        Perform SR 3.8.1.1 for                  1 hour ACTION c                                                                                                                                      4 circuit inoperable.                            [required] OPERABLE                                                            5 for reasons other offsite circuit.                        AND than Condition C Once per 8 hours thereafter AND DOC L20                                                  A.2        Declare required feature(s)              24 hours from with no offsite power                    discovery of no offsite available inoperable when                power to one train                        5 its redundant required                  concurrent with 6.9 kV Shutdown feature(s) is inoperable.                inoperability of Board 2A-A or 2B-B redundant required feature(s)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION a        A. One [required] offsite                A.1        Perform SR 3.8.1.1 for                  1 hour ACTION c                                                                                                                                      4 circuit inoperable.                            [required] OPERABLE                                                            5 for reasons other offsite circuit.                        AND than Condition C Once per 8 hours thereafter AND DOC L20                                                  A.2        Declare required feature(s)              24 hours from with no offsite power                    discovery of no offsite available inoperable when                power to one train                        5 its redundant required                  concurrent with 6.9 kV Shutdown feature(s) is inoperable.                inoperability of Board 2A-A or 2B-B redundant required feature(s)
AND SEQUOYAH UNIT 2                                                                                                    Amendment XXX Westinghouse STS                                            3.8.1-1                                                Rev. 4.0            1 Enclosure 2, Volume 13, Rev. 0, Page 71 of 638
AND SEQUOYAH UNIT 2                                                                                                    Amendment XXX Westinghouse STS                                            3.8.1-1                                                Rev. 4.0            1 Enclosure 2, Volume 13, Rev. 0, Page 71 of 638
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deleted if the unit design is                  to OPERABLE status.
deleted if the unit design is                  to OPERABLE status.
such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.
such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.
                  --------------------------------------
F. [ One [required]
F. [ One [required]
[automatic load sequencer] inoperable.
[automatic load sequencer] inoperable.
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DOC A05                            1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
DOC A05                            1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
4.8.1.1.2.a.4                      [ 2. A modified DG start involving idling and gradual                                              4 Note
4.8.1.1.2.a.4                      [ 2. A modified DG start involving idling and gradual                                              4 Note
* 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. ]                                                      4
* 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. ]                                                      4 4.8.1.1.2.a.4                      Verify each DG starts from standby conditions and                      [ 31 days achieves steady state voltage  [3740] V and                                                        6 7260
                                  ---------------------------------------------------------------------
4.8.1.1.2.a.4                      Verify each DG starts from standby conditions and                      [ 31 days achieves steady state voltage  [3740] V and                                                        6 7260
[4580] V, and frequency  [58.8] Hz and                    6800    OR                      4
[4580] V, and frequency  [58.8] Hz and                    6800    OR                      4
[61.2] Hz.
[61.2] Hz.
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* 3. This Surveillance shall be conducted on only one DG at a time.
* 3. This Surveillance shall be conducted on only one DG at a time.
DOC M02                        4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
DOC M02                        4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
                                ---------------------------------------------------------------------
4.8.1.1.2.a.5                  Verify each DG is synchronized and loaded and                          [ 31 days operates for  60 minutes at a load  [4500] kW and                                                    6
4.8.1.1.2.a.5                  Verify each DG is synchronized and loaded and                          [ 31 days operates for  60 minutes at a load  [4500] kW and                                                    6
[5000] kW.                                      3960                OR                      4 4400 In accordance with the Surveillance Frequency Control Program ]            6 engine-mounted day 3.8.1.1.b.2      SR 3.8.1.4    Verify each day tank [and engine mounted tank]                        [ 31 days              1 4  6 4.8.1.1.2.a.1                  contains  [220] gal of fuel oil.
[5000] kW.                                      3960                OR                      4 4400 In accordance with the Surveillance Frequency Control Program ]            6 engine-mounted day 3.8.1.1.b.2      SR 3.8.1.4    Verify each day tank [and engine mounted tank]                        [ 31 days              1 4  6 4.8.1.1.2.a.1                  contains  [220] gal of fuel oil.
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4.8.1.1.2.a.4  SR 3.8.1.7          ------------------------------NOTE-------------------------------
4.8.1.1.2.a.4  SR 3.8.1.7          ------------------------------NOTE-------------------------------
DOC A05                              All DG starts may be preceded by an engine prelube period.
DOC A05                              All DG starts may be preceded by an engine prelube period.
                                    ---------------------------------------------------------------------
Verify each DG starts from standby condition and                      [ 184 days achieves:                                                                                              6 6800 OR
Verify each DG starts from standby condition and                      [ 184 days achieves:                                                                                              6 6800 OR
: a. In  [10] seconds, voltage  [3740] V and frequency  58.8] Hz and                                        In accordance              4 6800                  7260 with the
: a. In  [10] seconds, voltage  [3740] V and frequency  58.8] Hz and                                        In accordance              4 6800                  7260 with the
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4.8.1.1.1.b  SR 3.8.1.8              ------------------------------NOTE-------------------------------
4.8.1.1.1.b  SR 3.8.1.8              ------------------------------NOTE-------------------------------
[ This Surveillance shall not normally be performed                                            4 DOC L06                              in MODE 1 or 2. 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.
[ This Surveillance shall not normally be performed                                            4 DOC L06                              in MODE 1 or 2. 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.
INSERT 6
INSERT 6 the 4.8.1.1.1.b                          Verify [automatic [and] manual] transfer of AC power                  [ [18] months      6 Note ##
                                      ---------------------------------------------------------------------
the 4.8.1.1.1.b                          Verify [automatic [and] manual] transfer of AC power                  [ [18] months      6 Note ##
sources from the normal offsite circuit to each                                                  1 alternate [required] offsite circuit.                                  OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply                              In accordance with the Surveillance Frequency Control Program ] ]                6  4 SEQUOYAH UNIT 2                                                                                            Amendment XXX Westinghouse STS                                              3.8.1-8                                      Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 83 of 638
sources from the normal offsite circuit to each                                                  1 alternate [required] offsite circuit.                                  OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply                              In accordance with the Surveillance Frequency Control Program ] ]                6  4 SEQUOYAH UNIT 2                                                                                            Amendment XXX Westinghouse STS                                              3.8.1-8                                      Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 83 of 638


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Enclosure 2, Volume 13, Rev. 0, Page 85 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 85 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1  SR 3.8.1.9      ------------------------------NOTES-----------------------------                                      5 DOC M04                        [1. This Surveillance shall not normally be                                                    4 performed in MODE 1 or 2. 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.
SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1  SR 3.8.1.9      ------------------------------NOTES-----------------------------                                      5 DOC M04                        [1. This Surveillance shall not normally be                                                    4 performed in MODE 1 or 2. 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.
DOC M04                        2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor  [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                            4
DOC M04                        2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor  [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                            4 4.8.1.1.2.g.1                  Verify each DG rejects a load greater than or equal                    [ [18] months to its associated single largest post-accident load,                                                  6 and:                                                                  OR DOC L15                        a. Following load rejection, the frequency is                      In accordance
                                ---------------------------------------------------------------------
4.8.1.1.2.g.1                  Verify each DG rejects a load greater than or equal                    [ [18] months to its associated single largest post-accident load,                                                  6 and:                                                                  OR DOC L15                        a. Following load rejection, the frequency is                      In accordance
[63] Hz,                                                      with the                4 66.5 Surveillance 4.8.1.1.2.g.1                  b. Within [3] seconds following load rejection, the                Frequency voltage is  [3740] V and  [4580] V, and                      Control Program ]      4    6 6800                7260 4.8.1.1.2.g.1                  c. Within [3] seconds following load rejection, the 4
[63] Hz,                                                      with the                4 66.5 Surveillance 4.8.1.1.2.g.1                  b. Within [3] seconds following load rejection, the                Frequency voltage is  [3740] V and  [4580] V, and                      Control Program ]      4    6 6800                7260 4.8.1.1.2.g.1                  c. Within [3] seconds following load rejection, the 4
frequency is  [58.8] Hz and  [61.2] Hz.
frequency is  [58.8] Hz and  [61.2] Hz.
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SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2  SR 3.8.1.10          ------------------------------NOTES-----------------------------                                      5 DOC M04                              [ 1. This Surveillance shall not normally be                                                  4 performed in MODE 1 or 2. 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.
SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2  SR 3.8.1.10          ------------------------------NOTES-----------------------------                                      5 DOC M04                              [ 1. This Surveillance shall not normally be                                                  4 performed in MODE 1 or 2. 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.
DOC M04                            2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
DOC M04                            2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                                4
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]                                                                                4 4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is                            [ [18] months maintained  [5000] V during and following a load                                                    6 rejection of  [4500] kW and  [5000] kW.                              OR                      4 3960                  4400 In accordance with the Surveillance Frequency Control Program ]          6 SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                    3.8.1-10                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 86 of 638
                                    ---------------------------------------------------------------------
4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is                            [ [18] months maintained  [5000] V during and following a load                                                    6 rejection of  [4500] kW and  [5000] kW.                              OR                      4 3960                  4400 In accordance with the Surveillance Frequency Control Program ]          6 SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                    3.8.1-10                                            Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 86 of 638


Enclosure 2, Volume 13, Rev. 0, Page 87 of 638 CTS                                                                                                        AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 87 of 638 CTS                                                                                                        AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
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For DGs 2A-A and 2B-B, this 5
For DGs 2A-A and 2B-B, this 5
DOC L11                            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.
DOC L11                            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                      [ [18] months signal:                                                                                                6 shutdown boards                  OR 4.8.1.1.2.d.4.a)                  a. De-energization of emergency buses,                                                          1 shutdown boards                  In accordance 4.8.1.1.2.d.4.a)                  b. Load shedding from emergency buses,                                  with the Surveillance 4.8.1.1.2.d.4.b)                  c. DG auto-starts from standby condition and:                            Frequency Control Program ]        6
Verify on an actual or simulated loss of offsite power                      [ [18] months signal:                                                                                                6 shutdown boards                  OR 4.8.1.1.2.d.4.a)                  a. De-energization of emergency buses,                                                          1 shutdown boards                  In accordance 4.8.1.1.2.d.4.a)                  b. Load shedding from emergency buses,                                  with the Surveillance 4.8.1.1.2.d.4.b)                  c. DG auto-starts from standby condition and:                            Frequency Control Program ]        6
: 1.      Energizes permanently connected loads 4
: 1.      Energizes permanently connected loads 4
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DOC A05                              [ 1. All DG starts may be preceded by prelube                                                  4 period.
DOC A05                              [ 1. All DG starts may be preceded by prelube                                                  4 period.
For DGs 2A-A and 2B-B, this DOC L11                              2. This Surveillance shall not normally be                                                  5 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.
For DGs 2A-A and 2B-B, this DOC L11                              2. This Surveillance shall not normally be                                                  5 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.
                                    ---------------------------------------------------------------------
4.8.1.1.2.d.5                        Verify on an actual or simulated Engineered Safety                    [ [18] months Feature (ESF) actuation signal each DG auto-starts                                                6 from standby condition and:                                            OR
4.8.1.1.2.d.5                        Verify on an actual or simulated Engineered Safety                    [ [18] months Feature (ESF) actuation signal each DG auto-starts                                                6 from standby condition and:                                            OR
: a. In  [10] seconds after auto-start and during                    In accordance tests, achieves voltage  [3740] V and                          with the frequency  [58.8] Hz,                  6800                    Surveillance 4
: a. In  [10] seconds after auto-start and during                    In accordance tests, achieves voltage  [3740] V and                          with the frequency  [58.8] Hz,                  6800                    Surveillance 4
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Enclosure 2, Volume 13, Rev. 0, Page 89 of 638 CTS                                                                                                          AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 89 of 638 CTS                                                                                                          AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c)  SR 3.8.1.13          ------------------------------NOTE-------------------------------
SURVEILLANCE                                                  FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c)  SR 3.8.1.13          ------------------------------NOTE-------------------------------
DOC L11                                  [ This Surveillance shall not normally be performed                                            4  5 in MODE 1 or 2. 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. ]                                                          4
DOC L11                                  [ This Surveillance shall not normally be performed                                            4  5 in MODE 1 or 2. 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. ]                                                          4 4.8.1.1.2.d.6.c)                        Verify each DG's noncritical automatic trips are                      [ [18] months              6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an                        OR                            4 actual or simulated ESF actuation signal].
                                        ---------------------------------------------------------------------
4.8.1.1.2.d.6.c)                        Verify each DG's noncritical automatic trips are                      [ [18] months              6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an                        OR                            4 actual or simulated ESF actuation signal].
                                                                                 , or both                      In accordance with the Surveillance Frequency Control Program ]            6 SEQUOYAH UNIT 2                                                                                          Amendment XXX Westinghouse STS                                      3.8.1-13                                          Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 89 of 638
                                                                                 , or both                      In accordance with the Surveillance Frequency Control Program ]            6 SEQUOYAH UNIT 2                                                                                          Amendment XXX Westinghouse STS                                      3.8.1-13                                          Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 89 of 638


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DOC M04                        3. If performed with DG synchronized with offsite 0.89 power,    it shall be performed at a power factor
DOC M04                        3. If performed with DG synchronized with offsite 0.89 power,    it shall be performed at a power factor
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.
[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.
                                ---------------------------------------------------------------------
4.8.1.1.2.g.3                  Verify each DG operates for  24 hours:                                [ [18] months 6
4.8.1.1.2.g.3                  Verify each DG operates for  24 hours:                                [ [18] months 6
: a. For  [2] hours loaded  [5250] kW and                          OR
: a. For  [2] hours loaded  [5250] kW and                          OR
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DOC A05                          1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  [2] hours loaded  [4500] kW and  [5000] kW.                                        3960                                        4 4400          and  2140 kvar and  2370 kvar DOC L09                                Momentary transients outside of load range do not invalidate this test.
DOC A05                          1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated  [2] hours loaded  [4500] kW and  [5000] kW.                                        3960                                        4 4400          and  2140 kvar and  2370 kvar DOC L09                                Momentary transients outside of load range do not invalidate this test.
DOC A04                          2. All DG starts may be preceded by an engine prelube period.
DOC A04                          2. All DG starts may be preceded by an engine prelube period.
                                  ---------------------------------------------------------------------
Verify each DG starts and achieves:                                        [ [18] months 6800 6
Verify each DG starts and achieves:                                        [ [18] months 6800 6
DOC L19                          a. In  [10] seconds, voltage  [3740] V and                            OR frequency  [58.8] Hz and                                                                    4 6800                  7260 In accordance 4.8.1.1.2.g.4                    b. Steady state voltage  [3740] V, and  [4580] V                      with the and frequency  [58.8] Hz and  [61.2] Hz.                          Surveillance Frequency Control Program ]          6 For DGs 2A-A and 2B-B, this 4.8.1.1.2.d 4.8.1.1.2.d.9    SR 3.8.1.16    ------------------------------NOTE-------------------------------
DOC L19                          a. In  [10] seconds, voltage  [3740] V and                            OR frequency  [58.8] Hz and                                                                    4 6800                  7260 In accordance 4.8.1.1.2.g.4                    b. Steady state voltage  [3740] V, and  [4580] V                      with the and frequency  [58.8] Hz and  [61.2] Hz.                          Surveillance Frequency Control Program ]          6 For DGs 2A-A and 2B-B, this 4.8.1.1.2.d 4.8.1.1.2.d.9    SR 3.8.1.16    ------------------------------NOTE-------------------------------
DOC L11                          This Surveillance shall not normally be performed in                                                    5 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.
DOC L11                          This Surveillance shall not normally be performed in                                                    5 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:                                                            [ [18] months 6
Verify each DG:                                                            [ [18] months 6
4.8.1.1.2.d.9.a                  a. Synchronizes with offsite power source while                        OR loaded with emergency loads upon a simulated restoration of offsite power,                                        In accordance with the 4.8.1.1.2.d.9.b                  b. Transfers loads to offsite power source, and                        Surveillance Frequency 4.8.1.1.2.d.9.c                  c. Returns to ready-to-load operation.                                  Control Program ]        6 SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                  3.8.1-15                                              Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 91 of 638
4.8.1.1.2.d.9.a                  a. Synchronizes with offsite power source while                        OR loaded with emergency loads upon a simulated restoration of offsite power,                                        In accordance with the 4.8.1.1.2.d.9.b                  b. Transfers loads to offsite power source, and                        Surveillance Frequency 4.8.1.1.2.d.9.c                  c. Returns to ready-to-load operation.                                  Control Program ]        6 SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                  3.8.1-15                                              Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 91 of 638
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[ 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.
[ 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.
Credit may be taken for unplanned events that satisfy this SR.
                                        ---------------------------------------------------------------------
7 Verify, with a DG operating in test mode and                          [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:                          OR
7 Verify, with a DG operating in test mode and                          [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:                          OR
: a. Returning DG to ready-to-load operation and                        In accordance with the
: a. Returning DG to ready-to-load operation and                        In accordance with the
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in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4
in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4
taken for unplanned events that satisfy this SR. ]
taken for unplanned events that satisfy this SR. ]
                                        ---------------------------------------------------------------------
setpoint for                              load Verify interval between each sequenced load block                      [ [18] months is within +/- [10% of design interval] for each                timer 3        6 5% of design    emergency [and shutdown] load sequencer.                              OR In accordance with the Surveillance Frequency 6
setpoint for                              load Verify interval between each sequenced load block                      [ [18] months is within +/- [10% of design interval] for each                timer 3        6 5% of design    emergency [and shutdown] load sequencer.                              OR In accordance with the Surveillance Frequency 6
Control Program ]
Control Program ]
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For DGs 2A-A and 2B-B, this 5
For DGs 2A-A and 2B-B, this 5
DOC L11                            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.
DOC L11                            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.
                                    ---------------------------------------------------------------------
4.8.1.1.2.d.6                      Verify on an actual or simulated loss of offsite power                  [ [18] months signal in conjunction with an actual or simulated                                                  6 ESF actuation signal:                                                  OR 4.8.1.1.2.d.6.a                                                              shutdown boards
4.8.1.1.2.d.6                      Verify on an actual or simulated loss of offsite power                  [ [18] months signal in conjunction with an actual or simulated                                                  6 ESF actuation signal:                                                  OR 4.8.1.1.2.d.6.a                                                              shutdown boards
: a. De-energization of emergency buses,                              In accordance          1 4.8.1.1.2.d.6.a                                                              shutdown boards                with the
: a. De-energization of emergency buses,                              In accordance          1 4.8.1.1.2.d.6.a                                                              shutdown boards                with the
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Enclosure 2, Volume 13, Rev. 0, Page 94 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 94 of 638 CTS                                                                                                AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY 4.8.1.1.2.e  SR 3.8.1.20      ------------------------------NOTE-------------------------------                              7 DOC A05                    19  All DG starts may be preceded by an engine prelube period.
SURVEILLANCE                                                  FREQUENCY 4.8.1.1.2.e  SR 3.8.1.20      ------------------------------NOTE-------------------------------                              7 DOC A05                    19  All DG starts may be preceded by an engine prelube period.
                                ---------------------------------------------------------------------
4.8.1.1.2.e                    Verify when started simultaneously from standby                        [ 10 years condition, each DG achieves: ,                                                                  6 OR
4.8.1.1.2.e                    Verify when started simultaneously from standby                        [ 10 years condition, each DG achieves: ,                                                                  6 OR
: a. In  [10] seconds, voltage  [3740] V and                                                    4 frequency  [58.8] Hz and .                  6800              In accordance with the
: a. In  [10] seconds, voltage  [3740] V and                                                    4 frequency  [58.8] Hz and .                  6800              In accordance with the
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A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining                            5 than Condition C  required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.                                  5 E
A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining                            5 than Condition C  required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.                                  5 E
                           -----------------------------------REVIEWERS NOTE-----------------------------------              6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
                           -----------------------------------REVIEWERS NOTE-----------------------------------              6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
                          --------------------------------------------------------------------------------------------------
SEQUOYAH UNIT 1                                                                                              Revision XXX Westinghouse STS                                      B 3.8.1-4                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 107 of 638
SEQUOYAH UNIT 1                                                                                              Revision XXX Westinghouse STS                                      B 3.8.1-4                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 107 of 638


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B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG,                            5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.
B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG,                            5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.
                       -----------------------------------REVIEWERS NOTE-----------------------------------                6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
                       -----------------------------------REVIEWERS NOTE-----------------------------------                6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
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B.2 (s)
B.2 (s)
Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a                              5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.                                                              5 SEQUOYAH UNIT 1                                                            (s)                              Revision XXX Westinghouse STS                                  B 3.8.1-6                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 109 of 638
Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a                              5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.                                                              5 SEQUOYAH UNIT 1                                                            (s)                              Revision XXX Westinghouse STS                                  B 3.8.1-6                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 109 of 638
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.
SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.
The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The DG autostart time of [10] seconds is derived from requirements of the                          2 accident analysis to respond to a design basis large break LOCA. 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 DG autostart time of [10] seconds is derived from requirements of the                          2 accident analysis to respond to a design basis large break LOCA. 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.
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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 for DGs 1A-A and 1B-B Surveillance in MODE 1 or 2 is further amplified to allow portions of the      5 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, and 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.
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 for DGs 1A-A and 1B-B Surveillance in MODE 1 or 2 is further amplified to allow portions of the      5 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, and 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 the assessment. ]            2 Credit may be taken for unplanned events that satisfy this SR.
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 the assessment. ]            2 Credit may be taken for unplanned events that satisfy this SR.
SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic      5
SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic      5 trips are all automatic trips except:                  , or both
                        ,
trips are all automatic trips except:                  , or both
: a. Engine overspeed; and
: a. Engine overspeed; and
: b. Generator differential current;
: b. Generator differential current;
                                                                  .
[ c. Low lube oil pressure;                                                    2
[ c. Low lube oil pressure;                                                    2
: d. High crankcase pressure; and
: d. High crankcase pressure; and
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  [2] hours of which is                      2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  [2] hours of which is                      2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
The load band is provided to avoid routine overloading of the DG.
The load band is provided to avoid routine overloading of the DG.
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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18 5
18 5
SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
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A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining                            5 than Condition C  required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.                                  5 E
A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining                            5 than Condition C  required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.                                  5 E
                           -----------------------------------REVIEWERS NOTE-----------------------------------              6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
                           -----------------------------------REVIEWERS NOTE-----------------------------------              6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
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SEQUOYAH UNIT 2                                                                                              Revision XXX Westinghouse STS                                      B 3.8.1-4                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 157 of 638
SEQUOYAH UNIT 2                                                                                              Revision XXX Westinghouse STS                                      B 3.8.1-4                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 157 of 638


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B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG,                            5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.
B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG,                            5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.
                       -----------------------------------REVIEWERS NOTE-----------------------------------                  6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
                       -----------------------------------REVIEWERS NOTE-----------------------------------                  6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.
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B.2 Required Action B.2 is intended to provide assurance that a loss of offsite (s) power, during the period that a DG is inoperable, does not result in a                              5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.                                                              5 SEQUOYAH UNIT 2                                                            (s)                            Revision XXX Westinghouse STS                                  B 3.8.1-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 159 of 638
B.2 Required Action B.2 is intended to provide assurance that a loss of offsite (s) power, during the period that a DG is inoperable, does not result in a                              5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.                                                              5 SEQUOYAH UNIT 2                                                            (s)                            Revision XXX Westinghouse STS                                  B 3.8.1-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 159 of 638


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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.
SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.
The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
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SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The DG autostart time of [10] seconds is derived from requirements of the                          2 accident analysis to respond to a design basis large break LOCA. 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 DG autostart time of [10] seconds is derived from requirements of the                          2 accident analysis to respond to a design basis large break LOCA. 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.
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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      5 for DGs 2A-A and 2B-B 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, and 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.
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      5 for DGs 2A-A and 2B-B 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, and 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 the assessment. ]            2 Credit may be taken for unplanned events that satisfy this SR.
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 the assessment. ]            2 Credit may be taken for unplanned events that satisfy this SR.
SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic      5
SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic      5 trips are all automatic trips except:                  , or both
                        ,
trips are all automatic trips except:                  , or both
: a. Engine overspeed; and
: a. Engine overspeed; and
: b. Generator differential current;
: b. Generator differential current;
                                                                  .
[ c. Low lube oil pressure;                                                    2
[ c. Low lube oil pressure;                                                    2
: d. High crankcase pressure; and
: d. High crankcase pressure; and
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: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
                      --------------------------------------------------------------------------------------------------
SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  [2] hours of which is                      2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours,  [2] hours of which is                      2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
The load band is provided to avoid routine overloading of the DG.
The load band is provided to avoid routine overloading of the DG.
Line 2,106: Line 2,043:
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
: c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.
                      --------------------------------------------------------------------------------------------------
18 5
18 5
SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
Line 2,266: Line 2,202:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M03        LCO 3.0.3 is not applicable.
DOC M03        LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One required offsite                  -------------------NOTE--------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One required offsite                  -------------------NOTE--------------------
DOC A02              circuit inoperable.                  Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized                6.9 kV Shutdown Board 1
DOC A02              circuit inoperable.                  Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized                6.9 kV Shutdown Board 1
as a result of Condition A.
as a result of Condition A.
                                                          ------------------------------------------------
DOC L01                                                    A.1        Declare affected required                Immediately feature(s) with no offsite power available inoperable.
DOC L01                                                    A.1        Declare affected required                Immediately feature(s) with no offsite power available inoperable.
OR SEQUOYAH UNIT 1                                                                                                      Amendment XXX Westinghouse STS                                          3.8.2-1                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 215 of 638
OR SEQUOYAH UNIT 1                                                                                                      Amendment XXX Westinghouse STS                                          3.8.2-1                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 215 of 638
Line 2,288: Line 2,222:
3.8.1.2.b.4, 4.8.1.2                        The following SRs are not required to be performed:
3.8.1.2.b.4, 4.8.1.2                        The following SRs are not required to be performed:
SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and                        and                                  1
SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and                        and                                  1
[SR 3.8.1.18].                              17                                                3
[SR 3.8.1.18].                              17                                                3 For AC sources required to be OPERABLE, the SRs                        In accordance of Specification 3.8.1, "AC Sources - Operating,"                      with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17,                          SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable.                                                      1 18                      19 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                3.8.2-3                                            Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 217 of 638
                              ---------------------------------------------------------------------
For AC sources required to be OPERABLE, the SRs                        In accordance of Specification 3.8.1, "AC Sources - Operating,"                      with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17,                          SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable.                                                      1 18                      19 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                3.8.2-3                                            Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 217 of 638


Enclosure 2, Volume 13, Rev. 0, Page 218 of 638 CTS                                                                                                            AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2          AC Sources - Shutdown 3.8.1.2        LCO 3.8.2                    The following AC electrical power sources shall be OPERABLE:
Enclosure 2, Volume 13, Rev. 0, Page 218 of 638 CTS                                                                                                            AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2          AC Sources - Shutdown 3.8.1.2        LCO 3.8.2                    The following AC electrical power sources shall be OPERABLE:
Line 2,298: Line 2,230:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M03        LCO 3.0.3 is not applicable.
DOC M03        LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One required offsite                  -------------------NOTE--------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One required offsite                  -------------------NOTE--------------------
DOC A02              circuit inoperable.                  Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized                6.9 kV Shutdown Board 1
DOC A02              circuit inoperable.                  Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized                6.9 kV Shutdown Board 1
as a result of Condition A.
as a result of Condition A.
                                                          ------------------------------------------------
DOC L01                                                    A.1        Declare affected required                Immediately feature(s) with no offsite power available inoperable.
DOC L01                                                    A.1        Declare affected required                Immediately feature(s) with no offsite power available inoperable.
OR SEQUOYAH UNIT 2                                                                                                      Amendment XXX Westinghouse STS                                          3.8.2-1                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 218 of 638
OR SEQUOYAH UNIT 2                                                                                                      Amendment XXX Westinghouse STS                                          3.8.2-1                                                    Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 218 of 638
Line 2,320: Line 2,250:
3.8.1.2.b.4, 4.8.1.2                        The following SRs are not required to be performed:
3.8.1.2.b.4, 4.8.1.2                        The following SRs are not required to be performed:
SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and                        and                                  1
SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and                        and                                  1
[SR 3.8.1.18].                              17                                                3
[SR 3.8.1.18].                              17                                                3 For AC sources required to be OPERABLE, the SRs                        In accordance of Specification 3.8.1, "AC Sources - Operating,"                      with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17,                          SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable.                                                      1 18                      19 SEQUOYAH UNIT 2                                                                                    Amendment XXX Westinghouse STS                                3.8.2-3                                            Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 220 of 638
                              ---------------------------------------------------------------------
For AC sources required to be OPERABLE, the SRs                        In accordance of Specification 3.8.1, "AC Sources - Operating,"                      with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17,                          SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable.                                                      1 18                      19 SEQUOYAH UNIT 2                                                                                    Amendment XXX Westinghouse STS                                3.8.2-3                                            Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 220 of 638


Enclosure 2, Volume 13, Rev. 0, Page 221 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN
Enclosure 2, Volume 13, Rev. 0, Page 221 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN
Line 2,643: Line 2,571:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC L01 Separate Condition entry is allowed for each DG.
DOC L01 Separate Condition entry is allowed for each DG.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME DOC L01        A. One or more DGs with                  A.1        Restore fuel oil level to                48 hours fuel level less than a                          within limits.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME DOC L01        A. One or more DGs with                  A.1        Restore fuel oil level to                48 hours fuel level less than a                          within limits.
[7] day supply and                                                                                                          1 greater than a [6] day supply in storage tank.
[7] day supply and                                                                                                          1 greater than a [6] day supply in storage tank.
Line 2,682: Line 2,609:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC L01 Separate Condition entry is allowed for each DG.
DOC L01 Separate Condition entry is allowed for each DG.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME DOC L01        A. One or more DGs with                  A.1        Restore fuel oil level to                48 hours fuel level less than a                          within limits.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME DOC L01        A. One or more DGs with                  A.1        Restore fuel oil level to                48 hours fuel level less than a                          within limits.
[7] day supply and                                                                                                          1 greater than a [6] day supply in storage tank.
[7] day supply and                                                                                                          1 greater than a [6] day supply in storage tank.
Line 3,180: Line 3,106:
INSERT 2 3
INSERT 2 3
DOC M02                              2. This Surveillance shall not normally be on in-service        performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed                                                  7 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.
DOC M02                              2. This Surveillance shall not normally be on in-service        performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed                                                  7 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 battery capacity is adequate to supply, and                            [ [18] months maintain in OPERABLE status, the required                                                              1 emergency loads for the design duty cycle when                                OR subjected to a battery service test.
Verify battery capacity is adequate to supply, and                            [ [18] months maintain in OPERABLE status, the required                                                              1 emergency loads for the design duty cycle when                                OR subjected to a battery service test.
actual or simulated                            6 In accordance with the Surveillance Frequency Control Program ]
actual or simulated                            6 In accordance with the Surveillance Frequency Control Program ]
Line 3,217: Line 3,142:
INSERT 2 3
INSERT 2 3
DOC M02                              2. This Surveillance shall not normally be on in-service        performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed                                                  7 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.
DOC M02                              2. This Surveillance shall not normally be on in-service        performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed                                                  7 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 battery capacity is adequate to supply, and                            [ [18] months maintain in OPERABLE status, the required                                                              1 emergency loads for the design duty cycle when                                OR subjected to a battery service test.
Verify battery capacity is adequate to supply, and                            [ [18] months maintain in OPERABLE status, the required                                                              1 emergency loads for the design duty cycle when                                OR subjected to a battery service test.
actual or simulated                            6 In accordance with the Surveillance Frequency Control Program ]
actual or simulated                            6 In accordance with the Surveillance Frequency Control Program ]
Line 3,299: Line 3,223:
                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                  4 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                  4 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
SEQUOYAH UNIT 1                                                                                            Revision XXX Westinghouse STS                                  B 3.8.4-4                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 325 of 638
SEQUOYAH UNIT 1                                                                                            Revision XXX Westinghouse STS                                  B 3.8.4-4                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 325 of 638


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Enclosure 2, Volume 13, Rev. 0, Page 327 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 327 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)
Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied                                4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour Completion Time must be adopted.
Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied                                4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour Completion Time must be adopted.
                        --------------------------------------------------------------------------------------------------
vital 1
vital 1
7 days    Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of                                2 restoring battery terminal voltage to greater than or equal to the minimum 1
7 days    Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of                                2 restoring battery terminal voltage to greater than or equal to the minimum 1
Line 3,324: Line 3,246:
: 2. Condition B is included if Required Action B.1 (one [or two]
: 2. Condition B is included if Required Action B.1 (one [or two]
batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is                                    6 used. If not, Condition B is deleted and only Condition C is used.
batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is                                    6 used. If not, Condition B is deleted and only Condition C is used.
                        --------------------------------------------------------------------------------------------------
Condition B represents one subsystem with one [or two] batter[y][ies]
Condition B represents one subsystem with one [or two] batter[y][ies]
inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 1                                                                                                Revision XXX Westinghouse STS                                    B 3.8.4-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 327 of 638
inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 1                                                                                                Revision XXX Westinghouse STS                                    B 3.8.4-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 327 of 638
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                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                  4 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                  4 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
SEQUOYAH UNIT 2                                                                                            Revision XXX Westinghouse STS                                  B 3.8.4-4                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 340 of 638
SEQUOYAH UNIT 2                                                                                            Revision XXX Westinghouse STS                                  B 3.8.4-4                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 340 of 638


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Enclosure 2, Volume 13, Rev. 0, Page 342 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)
Enclosure 2, Volume 13, Rev. 0, Page 342 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)
Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied                                4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour Completion Time must be adopted.
Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied                                4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour Completion Time must be adopted.
                        --------------------------------------------------------------------------------------------------
vital 1
vital 1
7 days    Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of                                2 restoring battery terminal voltage to greater than or equal to the minimum 1
7 days    Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of                                2 restoring battery terminal voltage to greater than or equal to the minimum 1
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: 2. Condition B is included if Required Action B.1 (one [or two]
: 2. Condition B is included if Required Action B.1 (one [or two]
batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is                                    6 used. If not, Condition B is deleted and only Condition C is used.
batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is                                    6 used. If not, Condition B is deleted and only Condition C is used.
                        --------------------------------------------------------------------------------------------------
Condition B represents one subsystem with one [or two] batter[y][ies]
Condition B represents one subsystem with one [or two] batter[y][ies]
inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 2                                                                                                Revision XXX Westinghouse STS                                    B 3.8.4-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 342 of 638
inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 2                                                                                                Revision XXX Westinghouse STS                                    B 3.8.4-6                                                    Rev. 4.0      1 Enclosure 2, Volume 13, Rev. 0, Page 342 of 638
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Add ACTIONS Note                                                      M01 With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours.                                                                                  See ITS 3.8.10 Add proposed ACTION A                                                            L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and                            See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability                  3.8.10 with an overall battery voltage of greater than or equal to 125 volts.
Add ACTIONS Note                                                      M01 With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours.                                                                                  See ITS 3.8.10 Add proposed ACTION A                                                            L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and                            See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability                  3.8.10 with an overall battery voltage of greater than or equal to 125 volts.
SR 3.8.5.1    4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.
SR 3.8.5.1    4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.
_______________
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                      LA01 January 24, 1985 SEQUOYAH - UNIT 1                                    3/4 8-14                                      Amendment No. 37 Page 2 of 4 Enclosure 2, Volume 13, Rev. 0, Page 355 of 638
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                      LA01 January 24, 1985 SEQUOYAH - UNIT 1                                    3/4 8-14                                      Amendment No. 37 Page 2 of 4 Enclosure 2, Volume 13, Rev. 0, Page 355 of 638


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This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.
Action A the bracketed optional wording in Condition B are also                                        1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.
Action A the bracketed optional wording in Condition B are also                                        1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.
                                          --------------------------------------------------------------------------------------------------
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                            4 ACTIONS
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                            4 ACTIONS
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M01    LCO 3.0.3 is not applicable.
DOC M01    LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME
CONDITION                                REQUIRED ACTION                            COMPLETION TIME
[A. One [or two] battery                  A.1        Restore battery terminal                2 hours charger[s on one                                voltage to greater than or subsystem] inoperable.                          equal to the minimum established float voltage.
[A. One [or two] battery                  A.1        Restore battery terminal                2 hours charger[s on one                                voltage to greater than or subsystem] inoperable.                          equal to the minimum established float voltage.
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7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:
7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:
SR 3.8.4.2 and SR 3.8.4.3.
SR 3.8.4.2 and SR 3.8.4.3.
                              ---------------------------------------------------------------------
For DC sources required to be OPERABLE, the                            In accordance following SRs are applicable:                                          with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                    3.8.5-3                                            Rev. 4.0    3 Enclosure 2, Volume 13, Rev. 0, Page 367 of 638
For DC sources required to be OPERABLE, the                            In accordance following SRs are applicable:                                          with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 1                                                                                    Amendment XXX Westinghouse STS                                    3.8.5-3                                            Rev. 4.0    3 Enclosure 2, Volume 13, Rev. 0, Page 367 of 638


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This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.
Action A the bracketed optional wording in Condition B are also                                        1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.
Action A the bracketed optional wording in Condition B are also                                        1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.
                                          --------------------------------------------------------------------------------------------------
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                            4 ACTIONS
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                            4 ACTIONS
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M01    LCO 3.0.3 is not applicable.
DOC M01    LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME
CONDITION                                REQUIRED ACTION                            COMPLETION TIME
[A. One [or two] battery                  A.1        Restore battery terminal                2 hours charger[s on one                                voltage to greater than or subsystem] inoperable.                          equal to the minimum established float voltage.
[A. One [or two] battery                  A.1        Restore battery terminal                2 hours charger[s on one                                voltage to greater than or subsystem] inoperable.                          equal to the minimum established float voltage.
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7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:
7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:
SR 3.8.4.2 and SR 3.8.4.3.
SR 3.8.4.2 and SR 3.8.4.3.
                              ---------------------------------------------------------------------
For DC sources required to be OPERABLE, the                            In accordance following SRs are applicable:                                          with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 2                                                                                    Amendment XXX Westinghouse STS                                    3.8.5-3                                            Rev. 4.0    3 Enclosure 2, Volume 13, Rev. 0, Page 372 of 638
For DC sources required to be OPERABLE, the                            In accordance following SRs are applicable:                                          with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 2                                                                                    Amendment XXX Westinghouse STS                                    3.8.5-3                                            Rev. 4.0    3 Enclosure 2, Volume 13, Rev. 0, Page 372 of 638


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                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in                                  5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.
ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in                                  5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.
                      --------------------------------------------------------------------------------------------------
Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1                                    4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 1                                                                                            Revision XXX Westinghouse STS                                  B 3.8.5-3                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 378 of 638
Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1                                    4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 1                                                                                            Revision XXX Westinghouse STS                                  B 3.8.5-3                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 378 of 638


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                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                            5 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                            5 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.
A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.
If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during                          4 the recovery period following a battery discharge event that the DC system is designed for.
If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during                          4 the recovery period following a battery discharge event that the DC system is designed for.
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                         -----------------------------------REVIEWERS NOTE-----------------------------------
                         -----------------------------------REVIEWERS NOTE-----------------------------------
Any licensee wishing to adopt a Completion Time greater than 72 hours for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in                                5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour Completion Time must be adopted.
Any licensee wishing to adopt a Completion Time greater than 72 hours for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in                                5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour Completion Time must be adopted.
                        --------------------------------------------------------------------------------------------------
Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a                                          4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.
Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a                                          4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.
A.1, A.2 and A.3  B.1, B.2.1, B.2.2, and B.2.3 INSERT 3    [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC                              2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.
A.1, A.2 and A.3  B.1, B.2.1, B.2.2, and B.2.3 INSERT 3    [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC                              2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.
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                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in                                  5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.
ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in                                  5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.
                      --------------------------------------------------------------------------------------------------
Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1                                    4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 2                                                                                            Revision XXX Westinghouse STS                                  B 3.8.5-3                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 387 of 638
Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1                                    4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 2                                                                                            Revision XXX Westinghouse STS                                  B 3.8.5-3                                                  Rev. 4.0        1 Enclosure 2, Volume 13, Rev. 0, Page 387 of 638


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                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                            5 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                            5 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.
A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.
If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during                          4 the recovery period following a battery discharge event that the DC system is designed for.
If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during                          4 the recovery period following a battery discharge event that the DC system is designed for.
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                         -----------------------------------REVIEWERS NOTE-----------------------------------
                         -----------------------------------REVIEWERS NOTE-----------------------------------
Any licensee wishing to adopt a Completion Time greater than 72 hours for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in                                5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour Completion Time must be adopted.
Any licensee wishing to adopt a Completion Time greater than 72 hours for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in                                5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour Completion Time must be adopted.
                        --------------------------------------------------------------------------------------------------
Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a                                          4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.
Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a                                          4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.
A.1, A.2 and A.3  B.1, B.2.1, B.2.2, and B.2.3 INSERT 3    [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC                              2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.
A.1, A.2 and A.3  B.1, B.2.1, B.2.2, and B.2.3 INSERT 3    [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC                              2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.
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Enclosure 2, Volume 13, Rev. 0, Page 407 of 638 ITS A01 ITS 3.8.6 TABLE 4.8.2 BATTERY SURVEILLANCE REQUIREMENTS L01 (1)                                          (2)
Enclosure 2, Volume 13, Rev. 0, Page 407 of 638 ITS A01 ITS 3.8.6 TABLE 4.8.2 BATTERY SURVEILLANCE REQUIREMENTS L01 (1)                                          (2)
CATEGORY A                                    CATEGORY B                                          L05 Limits for each              Limits for each                          (3)
CATEGORY A                                    CATEGORY B                                          L05 Limits for each              Limits for each                          (3)
Parameter                                                                      Allowable value for designated pilot cell        connected cell                                                        L06 each connected cell LA03 SR 3.8.6.3                        >Minimum level              >Minimum level              Above top of plates, and Electrolyte Level indication mark,            indication mark, and        not overflowing and  1/4 above              1/4 above maximum          greater than or equal to the          L08 maximum level                level indication mark      minimum established design limits indication mark L07
Parameter                                                                      Allowable value for designated pilot cell        connected cell                                                        L06 each connected cell LA03 SR 3.8.6.3                        >Minimum level              >Minimum level              Above top of plates, and Electrolyte Level indication mark,            indication mark, and        not overflowing and  1/4 above              1/4 above maximum          greater than or equal to the          L08 maximum level                level indication mark      minimum established design limits indication mark L07 SR 3.8.6.2,                        2.13 volts                  2.13 volts (c)          > 2.07 volts                          See ITS SR 3.8.6.5  Float Voltage                                                                                                          5.5.15 Not more than .020 2.07 below the average of all 1.195                    connected cells SR 3.8.6.1 L09 (a)            (b)                Average of all connected    Average of all connected Specific Gravity        1.200 cells > 1.205              cells > 1.195(b)
 
SR 3.8.6.2,                        2.13 volts                  2.13 volts (c)          > 2.07 volts                          See ITS SR 3.8.6.5  Float Voltage                                                                                                          5.5.15 Not more than .020 2.07 below the average of all 1.195                    connected cells SR 3.8.6.1 L09 (a)            (b)                Average of all connected    Average of all connected Specific Gravity        1.200 cells > 1.205              cells > 1.195(b)
(a)    Corrected for electrolyte temperature and level.
(a)    Corrected for electrolyte temperature and level.
SR 3.8.6.1  (b)    Or battery charging current is less than 2 amps.
SR 3.8.6.1  (b)    Or battery charging current is less than 2 amps.
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Add proposed ACTIONS Note                                          A03 With less than the above complement of D.C. equipment and board OPERABLE, establish                                                See ITS CONTAINMENT INTEGRITY within 8 hours.                                                                                              3.8.5 and 3.8.10 Add proposed ACTIONS A, B, C, D, E, and F                                          L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and                                    See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability                          3.8.10 with an overall battery voltage of greater than or equal to 125 volts.
Add proposed ACTIONS Note                                          A03 With less than the above complement of D.C. equipment and board OPERABLE, establish                                                See ITS CONTAINMENT INTEGRITY within 8 hours.                                                                                              3.8.5 and 3.8.10 Add proposed ACTIONS A, B, C, D, E, and F                                          L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and                                    See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability                          3.8.10 with an overall battery voltage of greater than or equal to 125 volts.
SR 3.8.6.1,  4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers sha11 be demonstrated SR 3.8.6.2, SR 3.8.6.3, OPERABLE per Surveillance Requirement 4.8.2.3.2.
SR 3.8.6.1,  4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers sha11 be demonstrated SR 3.8.6.2, SR 3.8.6.3, OPERABLE per Surveillance Requirement 4.8.2.3.2.
SR 3.8.6.4, SR 3.8.6.5 SR 3.8.6.6
SR 3.8.6.4, SR 3.8.6.5 SR 3.8.6.6 See ITS
_______________
See ITS
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                                  3.8.5 January 24, 1985 SEQUOYAH - UNIT 1                                      3/4 8-14                                          Amendment No. 37 Page 11 of 24 Enclosure 2, Volume 13, Rev. 0, Page 408 of 638
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                                  3.8.5 January 24, 1985 SEQUOYAH - UNIT 1                                      3/4 8-14                                          Amendment No. 37 Page 11 of 24 Enclosure 2, Volume 13, Rev. 0, Page 408 of 638


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                   ------------------------------------------------------------NOTE-----------------------------------------------------------
                   ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC A03          Separate Condition entry is allowed for each battery.
DOC A03          Separate Condition entry is allowed for each battery.
                  -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                  REQUIRED ACTION                          COMPLETION TIME more DOC L01            A. One [or two] batter[y][ies            A.1          Perform SR 3.8.4.1.                    2 hours                            2  3 on one subsystem] with one or more battery cells            AND float voltage < [2.07] V.                                                                                                      2 A.2          Perform SR 3.8.6.1.                    2 hours AND A.3          Restore affected cell                  24 hours voltage  [2.07] V.
CONDITION                                  REQUIRED ACTION                          COMPLETION TIME more DOC L01            A. One [or two] batter[y][ies            A.1          Perform SR 3.8.4.1.                    2 hours                            2  3 on one subsystem] with one or more battery cells            AND float voltage < [2.07] V.                                                                                                      2 A.2          Perform SR 3.8.6.1.                    2 hours AND A.3          Restore affected cell                  24 hours voltage  [2.07] V.
more Vital DOC L01            B. One [or two] batter[y][ies            B.1          Perform SR 3.8.4.1.                    2 hours on one subsystem] with float current > [2] amps.            AND                                                                                      2  3 Vital B.2          Restore battery float current          [12] hours
more Vital DOC L01            B. One [or two] batter[y][ies            B.1          Perform SR 3.8.4.1.                    2 hours on one subsystem] with float current > [2] amps.            AND                                                                                      2  3 Vital B.2          Restore battery float current          [12] hours
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Required Action C.2              Required Actions C.1 and C.2 are shall be completed if            only applicable if electrolyte level electrolyte level was            was below the top of plates.
Required Action C.2              Required Actions C.1 and C.2 are shall be completed if            only applicable if electrolyte level electrolyte level was            was below the top of plates.
below the top of plates.        ------------------------------------------------
below the top of plates.        ------------------------------------------------
                  --------------------------------
more              C.1        Restore electrolyte level to          8 hours One [or two] batter[y][ies                  above top of plates.                                            2  3 on one subsystem] with one or more cells                AND electrolyte level less than minimum                    C.2        Verify no evidence of                12 hours established design                          leakage.
more              C.1        Restore electrolyte level to          8 hours One [or two] batter[y][ies                  above top of plates.                                            2  3 on one subsystem] with one or more cells                AND electrolyte level less than minimum                    C.2        Verify no evidence of                12 hours established design                          leakage.
limits.
limits.
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INSERT 2                                                                                                                            4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                    FREQUENCY 4.8.1.1.3.a.1,    SR 3.8.6.1            -------------------------------NOTE------------------------------
INSERT 2                                                                                                                            4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                    FREQUENCY 4.8.1.1.3.a.1,    SR 3.8.6.1            -------------------------------NOTE------------------------------
4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.
4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.
                                          ---------------------------------------------------------------------
vital Verify each battery float current is  [2] amps.                        [ 7 days                1  2 and each DG battery float current is  1 amp                                    3 OR In accordance              5 with the Surveillance Frequency Control Program ]
vital Verify each battery float current is  [2] amps.                        [ 7 days                1  2 and each DG battery float current is  1 amp                                    3 OR In accordance              5 with the Surveillance Frequency Control Program ]
SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                          3.8.6-3                                          Rev. 4.0          1 Enclosure 2, Volume 13, Rev. 0, Page 440 of 638
SEQUOYAH UNIT 1                                                                                        Amendment XXX Westinghouse STS                                          3.8.6-3                                          Rev. 4.0          1 Enclosure 2, Volume 13, Rev. 0, Page 440 of 638
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DOC M04                              This Surveillance shall not be performed in                          on in-service MODE 1, 2, 3, or 4. However, portions of the                          Vital batteries Surveillance may be performed to reestablish                                                        6 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
DOC M04                              This Surveillance shall not be performed in                          on in-service MODE 1, 2, 3, or 4. However, portions of the                          Vital batteries Surveillance may be performed to reestablish                                                        6 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.
Credit may be taken for unplanned events that satisfy this SR.
                                      ---------------------------------------------------------------------
82 vital 4.8.2.3.2.e                          Verify battery capacity is  [80%] of the                            [ 60 months                  1  2 4.8.2.3.2.f                          manufacturer's rating when subjected to a performance discharge test or a modified                              OR performance discharge test.
82 vital 4.8.2.3.2.e                          Verify battery capacity is  [80%] of the                            [ 60 months                  1  2 4.8.2.3.2.f                          manufacturer's rating when subjected to a performance discharge test or a modified                              OR performance discharge test.
In accordance                5 with the Surveillance Frequency Control Program ]
In accordance                5 with the Surveillance Frequency Control Program ]
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INSERT 3 DOC M02 SR 3.8.6.7    -------------------------------NOTE------------------------------
INSERT 3 DOC M02 SR 3.8.6.7    -------------------------------NOTE------------------------------
Credit may be taken for unplanned events that satisfy this SR.
Credit may be taken for unplanned events that satisfy this SR.
                    ---------------------------------------------------------------------
Verify DG battery capacity is  80% of the                            In accordance manufacturer's rating when subjected to a                            with the performance discharge test or a modified                            Surveillance performance discharge test.                                          Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%
Verify DG battery capacity is  80% of the                            In accordance manufacturer's rating when subjected to a                            with the performance discharge test or a modified                            Surveillance performance discharge test.                                          Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%
of the expected life with capacity
of the expected life with capacity
Line 4,335: Line 4,231:
                   ------------------------------------------------------------NOTE-----------------------------------------------------------
                   ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC A03          Separate Condition entry is allowed for each battery.
DOC A03          Separate Condition entry is allowed for each battery.
                  -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                  REQUIRED ACTION                          COMPLETION TIME more DOC L01            A. One [or two] batter[y][ies            A.1          Perform SR 3.8.4.1.                    2 hours                            2  3 on one subsystem] with one or more battery cells            AND float voltage < [2.07] V.                                                                                                      2 A.2          Perform SR 3.8.6.1.                    2 hours AND A.3          Restore affected cell                  24 hours voltage  [2.07] V.
CONDITION                                  REQUIRED ACTION                          COMPLETION TIME more DOC L01            A. One [or two] batter[y][ies            A.1          Perform SR 3.8.4.1.                    2 hours                            2  3 on one subsystem] with one or more battery cells            AND float voltage < [2.07] V.                                                                                                      2 A.2          Perform SR 3.8.6.1.                    2 hours AND A.3          Restore affected cell                  24 hours voltage  [2.07] V.
more Vital DOC L01            B. One [or two] batter[y][ies            B.1          Perform SR 3.8.4.1.                    2 hours on one subsystem] with float current > [2] amps.            AND                                                                                      2  3 Vital B.2          Restore battery float current          [12] hours
more Vital DOC L01            B. One [or two] batter[y][ies            B.1          Perform SR 3.8.4.1.                    2 hours on one subsystem] with float current > [2] amps.            AND                                                                                      2  3 Vital B.2          Restore battery float current          [12] hours
Line 4,350: Line 4,245:
Required Action C.2              Required Actions C.1 and C.2 are shall be completed if            only applicable if electrolyte level electrolyte level was            was below the top of plates.
Required Action C.2              Required Actions C.1 and C.2 are shall be completed if            only applicable if electrolyte level electrolyte level was            was below the top of plates.
below the top of plates.        ------------------------------------------------
below the top of plates.        ------------------------------------------------
                  --------------------------------
more              C.1        Restore electrolyte level to          8 hours One [or two] batter[y][ies                  above top of plates.                                            2  3 on one subsystem] with one or more cells                AND electrolyte level less than minimum                    C.2        Verify no evidence of                12 hours established design                          leakage.
more              C.1        Restore electrolyte level to          8 hours One [or two] batter[y][ies                  above top of plates.                                            2  3 on one subsystem] with one or more cells                AND electrolyte level less than minimum                    C.2        Verify no evidence of                12 hours established design                          leakage.
limits.
limits.
Line 4,367: Line 4,261:
INSERT 2                                                                                                                            4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                    FREQUENCY 4.8.1.1.3.a.1,    SR 3.8.6.1            -------------------------------NOTE------------------------------
INSERT 2                                                                                                                            4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                    FREQUENCY 4.8.1.1.3.a.1,    SR 3.8.6.1            -------------------------------NOTE------------------------------
4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.
4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.
                                          ---------------------------------------------------------------------
vital Verify each battery float current is  [2] amps.                        [ 7 days                1  2 and each DG battery float current is  1 amp                                    3 OR In accordance              5 with the Surveillance Frequency Control Program ]
vital Verify each battery float current is  [2] amps.                        [ 7 days                1  2 and each DG battery float current is  1 amp                                    3 OR In accordance              5 with the Surveillance Frequency Control Program ]
SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                          3.8.6-3                                          Rev. 4.0          1 Enclosure 2, Volume 13, Rev. 0, Page 448 of 638
SEQUOYAH UNIT 2                                                                                        Amendment XXX Westinghouse STS                                          3.8.6-3                                          Rev. 4.0          1 Enclosure 2, Volume 13, Rev. 0, Page 448 of 638
Line 4,391: Line 4,284:
DOC M04                              This Surveillance shall not be performed in                          on in-service MODE 1, 2, 3, or 4. However, portions of the                          Vital batteries Surveillance may be performed to reestablish                                                        6 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
DOC M04                              This Surveillance shall not be performed in                          on in-service MODE 1, 2, 3, or 4. However, portions of the                          Vital batteries Surveillance may be performed to reestablish                                                        6 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.
Credit may be taken for unplanned events that satisfy this SR.
                                      ---------------------------------------------------------------------
82 vital 4.8.2.3.2.e                          Verify battery capacity is  [80%] of the                            [ 60 months                  1  2 4.8.2.3.2.f                          manufacturer's rating when subjected to a performance discharge test or a modified                              OR performance discharge test.
82 vital 4.8.2.3.2.e                          Verify battery capacity is  [80%] of the                            [ 60 months                  1  2 4.8.2.3.2.f                          manufacturer's rating when subjected to a performance discharge test or a modified                              OR performance discharge test.
In accordance                5 with the Surveillance Frequency Control Program ]
In accordance                5 with the Surveillance Frequency Control Program ]
Line 4,401: Line 4,293:
INSERT 3 DOC M02 SR 3.8.6.7    -------------------------------NOTE------------------------------
INSERT 3 DOC M02 SR 3.8.6.7    -------------------------------NOTE------------------------------
Credit may be taken for unplanned events that satisfy this SR.
Credit may be taken for unplanned events that satisfy this SR.
                    ---------------------------------------------------------------------
Verify DG battery capacity is  80% of the                            In accordance manufacturer's rating when subjected to a                            with the performance discharge test or a modified                            Surveillance performance discharge test.                                          Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%
Verify DG battery capacity is  80% of the                            In accordance manufacturer's rating when subjected to a                            with the performance discharge test or a modified                            Surveillance performance discharge test.                                          Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%
of the expected life with capacity
of the expected life with capacity
Line 4,442: Line 4,333:
                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                    6 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                    6 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant                                      2 risk.
A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant                                      2 risk.
If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this                              2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.
If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this                              2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.
Line 4,563: Line 4,453:
                       -----------------------------------REVIEWERS NOTE-----------------------------------
                       -----------------------------------REVIEWERS NOTE-----------------------------------
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                    6 current portion of the battery charge profile following the service test (SR 3.8.4.3).
A plant that cannot meet the 12 hour Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours plus the time experienced to accomplish the exponential charging                                    6 current portion of the battery charge profile following the service test (SR 3.8.4.3).
                      --------------------------------------------------------------------------------------------------
A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant                                      2 risk.
A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant                                      2 risk.
If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this                              2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.
If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this                              2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.
Line 4,747: Line 4,636:
[Class 1E constant voltage source transformers] [inverter using                              2 internal AC source], and
[Class 1E constant voltage source transformers] [inverter using                              2 internal AC source], and
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ]
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ]
                                      --------------------------------------------------------------------------------------------------
connected to their DC source Applicability  APPLICABILITY:          MODES 1, 2, 3, and 4.
connected to their DC source Applicability  APPLICABILITY:          MODES 1, 2, 3, and 4.
ACTIONS CONDITION                              REQUIRED ACTION                            COMPLETION TIME ACTION b      A. One [required] inverter            A.1        --------------NOTE--------------                                            2 inoperable.                                Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.
ACTIONS CONDITION                              REQUIRED ACTION                            COMPLETION TIME ACTION b      A. One [required] inverter            A.1        --------------NOTE--------------                                            2 inoperable.                                Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.
                                                                -------------------------------------
Restore inverter to                        24 hours OPERABLE status.
Restore inverter to                        24 hours OPERABLE status.
ACTION b      B. Required Action and                B.1        Be in MODE 3.                              6 hours associated Completion Time not met.                    AND SEQUOYAH UNIT 1                                                                                            Amendment XXX Westinghouse STS                                      3.8.7-1                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 494 of 638
ACTION b      B. Required Action and                B.1        Be in MODE 3.                              6 hours associated Completion Time not met.                    AND SEQUOYAH UNIT 1                                                                                            Amendment XXX Westinghouse STS                                      3.8.7-1                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 494 of 638
Line 4,768: Line 4,655:
[Class 1E constant voltage source transformers] [inverter using                              2 internal AC source], and
[Class 1E constant voltage source transformers] [inverter using                              2 internal AC source], and
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ]
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ]
                                      --------------------------------------------------------------------------------------------------
connected to their DC source Applicability  APPLICABILITY:          MODES 1, 2, 3, and 4.
connected to their DC source Applicability  APPLICABILITY:          MODES 1, 2, 3, and 4.
ACTIONS CONDITION                              REQUIRED ACTION                            COMPLETION TIME ACTION b      A. One [required] inverter            A.1        --------------NOTE--------------                                            2 inoperable.                                Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.
ACTIONS CONDITION                              REQUIRED ACTION                            COMPLETION TIME ACTION b      A. One [required] inverter            A.1        --------------NOTE--------------                                            2 inoperable.                                Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.
                                                                -------------------------------------
Restore inverter to                        24 hours OPERABLE status.
Restore inverter to                        24 hours OPERABLE status.
ACTION b      B. Required Action and                B.1        Be in MODE 3.                              6 hours associated Completion Time not met.                    AND SEQUOYAH UNIT 2                                                                                            Amendment XXX Westinghouse STS                                      3.8.7-1                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 496 of 638
ACTION b      B. Required Action and                B.1        Be in MODE 3.                              6 hours associated Completion Time not met.                    AND SEQUOYAH UNIT 2                                                                                            Amendment XXX Westinghouse STS                                      3.8.7-1                                                  Rev. 4.0    1 Enclosure 2, Volume 13, Rev. 0, Page 496 of 638
Line 4,962: Line 4,847:
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"
2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.
2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.
                                          --------------------------------------------------------------------------------------------------
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                                  1 ACTIONS
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                                  1 ACTIONS
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M01      LCO 3.0.3 is not applicable.
DOC M01      LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                              COMPLETION TIME DOC M03        A. One [or more] [required]              A.1        Declare affected required                  Immediately                          3 inverter[s] inoperable.                        feature(s) inoperable.
CONDITION                                REQUIRED ACTION                              COMPLETION TIME DOC M03        A. One [or more] [required]              A.1        Declare affected required                  Immediately                          3 inverter[s] inoperable.                        feature(s) inoperable.
1 OR DOC L02                                                  A.2.1      Suspend movement of                        Immediately
1 OR DOC L02                                                  A.2.1      Suspend movement of                        Immediately
Line 4,984: Line 4,867:
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"
This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"
2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.
2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.
                                          --------------------------------------------------------------------------------------------------
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                                  1 ACTIONS
Applicability APPLICABILITY:                MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies.                                                  1 ACTIONS
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M01      LCO 3.0.3 is not applicable.
DOC M01      LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                              COMPLETION TIME DOC M03        A. One [or more] [required]              A.1        Declare affected required                  Immediately                          3 inverter[s] inoperable.                        feature(s) inoperable.
CONDITION                                REQUIRED ACTION                              COMPLETION TIME DOC M03        A. One [or more] [required]              A.1        Declare affected required                  Immediately                          3 inverter[s] inoperable.                        feature(s) inoperable.
1 OR DOC L02                                                  A.2.1      Suspend movement of                        Immediately
1 OR DOC L02                                                  A.2.1      Suspend movement of                        Immediately
Line 5,186: Line 5,067:
: b. With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours; See ITS restore the inoperable inverter to OPERABLE status within 24 hours or be in at least HOT STANDBY                              3.8.7 within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: b. With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours; See ITS restore the inoperable inverter to OPERABLE status within 24 hours or be in at least HOT STANDBY                              3.8.7 within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
Add proposed ACTION G        M02 SURVEILLANCE REQUIREMENTS See ITS SR 3.8.9.1    4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie                              3.8.7 breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses.                        In accordance with the Surveillance Frequency Control Program LA03
Add proposed ACTION G        M02 SURVEILLANCE REQUIREMENTS See ITS SR 3.8.9.1    4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie                              3.8.7 breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses.                        In accordance with the Surveillance Frequency Control Program LA03
_________________
* Two inverters may be disconnected from their D.C. source for up to 24 hours for the purpose of performing an equalizing charge on their associated battery bank provided (1) the vital instrument                            LA02 power board is OPERABLE and energized, and (2) the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to                              See ITS 3.8.7 their respective D.C. source.
* Two inverters may be disconnected from their D.C. source for up to 24 hours for the purpose of performing an equalizing charge on their associated battery bank provided (1) the vital instrument                            LA02 power board is OPERABLE and energized, and (2) the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to                              See ITS 3.8.7 their respective D.C. source.
               # D.C. Channel V may be substituted for any one channel of channels I-IV.                                                        LA04
               # D.C. Channel V may be substituted for any one channel of channels I-IV.                                                        LA04
Line 5,343: Line 5,223:
Applicability 3.8.1.1 APPLICABILITY:          MODES 1, 2, 3, and 4.
Applicability 3.8.1.1 APPLICABILITY:          MODES 1, 2, 3, and 4.
3.8.2.1 3.8.2.3 ACTIONS CONDITION                      REQUIRED ACTION                              COMPLETION TIME Unit 1 3.8.2.1 A. One or more AC                  A.1    --------------NOTE--------------                                              2 ACTION a.          electrical power                      Enter applicable Conditions DOC A03            distribution subsystems              and Required Actions of inoperable.                          LCO 3.8.4, "DC Sources -                  vital Operating," for DC trains                                                      1 made inoperable by inoperable power distribution subsystems.
3.8.2.1 3.8.2.3 ACTIONS CONDITION                      REQUIRED ACTION                              COMPLETION TIME Unit 1 3.8.2.1 A. One or more AC                  A.1    --------------NOTE--------------                                              2 ACTION a.          electrical power                      Enter applicable Conditions DOC A03            distribution subsystems              and Required Actions of inoperable.                          LCO 3.8.4, "DC Sources -                  vital Operating," for DC trains                                                      1 made inoperable by inoperable power distribution subsystems.
                                                          -------------------------------------
Unit 1 3.8.2.1                                                  Restore AC electrical power                8 hours                              2 ACTION a.                                                distribution subsystem(s) to OPERABLE status.
Unit 1 3.8.2.1                                                  Restore AC electrical power                8 hours                              2 ACTION a.                                                distribution subsystem(s) to OPERABLE status.
8 3.8.2.1        B. One or more AC vital            B.1    Restore AC vital bus                      2 hours                              1 ACTION a.          buses inoperable.                    subsystem(s) to subsystems          OPERABLE status.
8 3.8.2.1        B. One or more AC vital            B.1    Restore AC vital bus                      2 hours                              1 ACTION a.          buses inoperable.                    subsystem(s) to subsystems          OPERABLE status.
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Applicability APPLICABILITY:          MODES 1, 2, 3, and 4.
Applicability APPLICABILITY:          MODES 1, 2, 3, and 4.
3.8.1.1 3.8.2.1 3.8.2.3 ACTIONS CONDITION                      REQUIRED ACTION                              COMPLETION TIME Unit 2 3.8.2.1 A. One or more AC                  A.1    --------------NOTE--------------                                              2 ACTION a.          electrical power                      Enter applicable Conditions DOC A03            distribution subsystems              and Required Actions of inoperable.                          LCO 3.8.4, "DC Sources -                  vital Operating," for DC trains                                                    1 made inoperable by inoperable power distribution subsystems.
3.8.1.1 3.8.2.1 3.8.2.3 ACTIONS CONDITION                      REQUIRED ACTION                              COMPLETION TIME Unit 2 3.8.2.1 A. One or more AC                  A.1    --------------NOTE--------------                                              2 ACTION a.          electrical power                      Enter applicable Conditions DOC A03            distribution subsystems              and Required Actions of inoperable.                          LCO 3.8.4, "DC Sources -                  vital Operating," for DC trains                                                    1 made inoperable by inoperable power distribution subsystems.
                                                          -------------------------------------
Unit 2 3.8.2.1                                                  Restore AC electrical power                8 hours                              2 ACTION a.                                                distribution subsystem(s) to OPERABLE status.
Unit 2 3.8.2.1                                                  Restore AC electrical power                8 hours                              2 ACTION a.                                                distribution subsystem(s) to OPERABLE status.
8 3.8.2.1        B. One or more AC vital            B.1    Restore AC vital bus                      2 hours                            1 ACTION a.          buses inoperable.                    subsystem(s) to subsystems          OPERABLE status.
8 3.8.2.1        B. One or more AC vital            B.1    Restore AC vital bus                      2 hours                            1 ACTION a.          buses inoperable.                    subsystem(s) to subsystems          OPERABLE status.
Line 5,686: Line 5,564:
During movement of irradiated fuel assemblies                              M02 ACTIONS      ACTION:
During movement of irradiated fuel assemblies                              M02 ACTIONS      ACTION:
ACTION A      With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours.
ACTION A      With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours.
Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4                          L01 Add Required Action A.1                                                    M01 SURVEILLANCE REQUIREMENTS In accordance with the Surveillance Frequency Control Program  LA02 SR 3.8.10.1  4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability with an overall battery voltage of greater than or equal to 125 volts.                                                            LA01 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated                                See ITS OPERABLE per Surveillance Requirement 4.8.2.3.2.                                                                                  3.8.5
Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4                          L01 Add Required Action A.1                                                    M01 SURVEILLANCE REQUIREMENTS In accordance with the Surveillance Frequency Control Program  LA02 SR 3.8.10.1  4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability with an overall battery voltage of greater than or equal to 125 volts.                                                            LA01 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated                                See ITS OPERABLE per Surveillance Requirement 4.8.2.3.2.                                                                                  3.8.5 See ITS
_______________
See ITS
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                              3.8.5 January 24, 1985 SEQUOYAH - UNIT 1                                  3/4 8-14                                            Amendment No. 37 Page 3 of 14 Enclosure 2, Volume 13, Rev. 0, Page 600 of 638
* D.C. Battery Bank V may be substituted for any other Battery Bank.                                                              3.8.5 January 24, 1985 SEQUOYAH - UNIT 1                                  3/4 8-14                                            Amendment No. 37 Page 3 of 14 Enclosure 2, Volume 13, Rev. 0, Page 600 of 638


Line 5,789: Line 5,665:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M02      LCO 3.0.3 is not applicable.
DOC M02      LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One or more required                  A.1        Declare associated                      Immediately 3.8.2.2 3.8.2.4        vital AC, DC, or AC vital bus                        supported required DOC M01                electrical power                              feature(s) inoperable.                                                        1 distribution subsystems inoperable.                        OR DOC L01                                                  A.2.1      Suspend movement of                      Immediately
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One or more required                  A.1        Declare associated                      Immediately 3.8.2.2 3.8.2.4        vital AC, DC, or AC vital bus                        supported required DOC M01                electrical power                              feature(s) inoperable.                                                        1 distribution subsystems inoperable.                        OR DOC L01                                                  A.2.1      Suspend movement of                      Immediately
[recently] irradiated fuel                                                    2 assemblies.
[recently] irradiated fuel                                                    2 assemblies.
Line 5,812: Line 5,687:
               ------------------------------------------------------------NOTE-----------------------------------------------------------
               ------------------------------------------------------------NOTE-----------------------------------------------------------
DOC M02      LCO 3.0.3 is not applicable.
DOC M02      LCO 3.0.3 is not applicable.
              -------------------------------------------------------------------------------------------------------------------------------
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One or more required                  A.1        Declare associated                      Immediately 3.8.2.2 3.8.2.4        vital AC, DC, or AC vital bus                        supported required DOC M01                electrical power                              feature(s) inoperable.                                                        1 distribution subsystems inoperable.                        OR DOC L01                                                  A.2.1      Suspend movement of                      Immediately
CONDITION                                REQUIRED ACTION                            COMPLETION TIME ACTION          A. One or more required                  A.1        Declare associated                      Immediately 3.8.2.2 3.8.2.4        vital AC, DC, or AC vital bus                        supported required DOC M01                electrical power                              feature(s) inoperable.                                                        1 distribution subsystems inoperable.                        OR DOC L01                                                  A.2.1      Suspend movement of                      Immediately
[recently] irradiated fuel                                                    2 assemblies.
[recently] irradiated fuel                                                    2 assemblies.

Revision as of 00:57, 6 February 2020

Enclosure 2 - Volume 13 - Improved Technical Specifications Conversion, ITS Section 3.8, Electrical Power Systems
ML13330A927
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Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/22/2013
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References
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Download: ML13330A927 (638)


Text

Enclosure 2, Volume 13, Rev. 0, Page 1 of 638 ENCLOSURE 2 VOLUME 13 SEQUOYAH NUCLEAR PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Enclosure 2, Volume 13, Rev. 0, Page 1 of 638

Enclosure 2, Volume 13, Rev. 0, Page 2 of 638 LIST OF ATTACHMENTS

1. ITS 3.8.1 - AC Sources - Operating
2. ITS 3.8.2 - AC Sources - Shutdown
3. ITS 3.8.3 - Diesel Fuel Oil, Lube Oil, and Starting Air
4. ITS 3.8.4 - DC Sources - Operating
5. ITS 3.8.5 - DC Sources - Shutdown
6. ITS 3.8.6 - Battery Parameters
7. ITS 3.8.7 - Inverters - Operating
8. ITS 3.8.8 - Inverters - Shutdown
9. ITS 3.8.9 - Distribution Systems - Operating
10. ITS 3.8.10 - Distribution Systems - Shutdown Enclosure 2, Volume 13, Rev. 0, Page 2 of 638

, Volume 13, Rev. 0, Page 3 of 638 ATTACHMENT 1 ITS 3.8.1, AC SOURCES - OPERATING , Volume 13, Rev. 0, Page 3 of 638

Enclosure 2, Volume 13, Rev. 0, Page 4 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Enclosure 2, Volume 13, Rev. 0, Page 4 of 638

Enclosure 2, Volume 13, Rev. 0, Page 5 of 638 ITS A01 ITS 3.8.1 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.1 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

qualified LA01 LCO 3.8.1.a a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and A02 LCO 3.8.1.b b. Four separate and independent diesel generator sets each with:

LA01

1. Two diesels driving a common generator SR 3.8.1.4 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of See ITS 62,000 gallons of fuel, 3.8.3 SR 3.8.1.6 4. A separate fuel transfer pump, and
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. See ITS 3.8.4 and battery bank and associated charger. 3.8.9 Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Add proposed Condition A L01

a. With one offsite A.C. circuit of the above required A.C. electrical power source inoperable, ACTION A demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> L01 thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in ACTION K at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the L02 following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed Condition B L01 b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at ACTION B least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement L01 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION K SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS C and D L01

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common L02 cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.

SR 3.8.1.3

  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis Note 3 L03 for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in A02 effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-1 Amendment No. 100, 132, 137, 205, 241, 332 Page 1 of 17 Enclosure 2, Volume 13, Rev. 0, Page 5 of 638

Enclosure 2, Volume 13, Rev. 0, Page 6 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS Add proposed ACTION F Note A03 ACTION (Continued)

Add proposed Condition F L01 ACTION F

c. With one offsite circuit and one diesel generator set of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources ACTION A, by performing Surveillance Requirements 4.8.1.1.1.a within one hour and at least once per 24 L04 ACTION B 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; restore at ACTION F least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least ACTION K HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With two of the above required offsite A.C. circuits inoperable, demonstrate the ACTION E OPERABILITY of 4 diesel generator sets by performing Surveillance Requirement L05 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the diesel generator sets are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in ACTION K at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> M01 ACTION J
e. With either diesel generator sets 1A-A and/or 2A-A inoperable simultaneous with 1B-B and/or 2B-B, demonstrate the OPERABILITY of two offsite A.C. circuits by performing L01 ACTION B Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least 1) 1A-A and 2A-A or 2) 1B-B and 2B-B to OPERABLE status ACTION J within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION K SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS G, H, and I L01 ACTIONS Note f. LCO 3.0.4.b is not applicable to diesel generators.

Add proposed ACTIONS L and M A04 SURVEILLANCE REQUIREMENTS SR 3.8.1.1 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and LA01 the onsite Class 1E distribution system shall be:

SR 3.8.1.1 a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments and indicated power availability. In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.8 b. Demonstrated OPERABLE at least once per 18 months# by manually and automatically transferring the power supply to each 6.9 kV Unit Board## from the normal supply to the alternate supply.

SR 3.8.1.8 Note 1

  1. For the 1A, 1B, 1C and 1D 6.9 kV Unit Boards, this Surveillance shall not be performed in MODES 1 and 2. Add proposed SR 3.8.1.8 Note 1, second and third sentences. L06 SR 3.8.1.8 ## Transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and alternate Note 2 power supplies.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-2 Amendment No. 100, 137, 184, 205, 228, 255, 301, 332 Page 2 of 17 Enclosure 2, Volume 13, Rev. 0, Page 6 of 638

Enclosure 2, Volume 13, Rev. 0, Page 7 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.2 Each diesel generator set shall be demonstrated OPERABLE:

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.2, SR 3.8.1.3, a. At least once per 31 days on a staggered test basis by:

SR 3.8.1.4, SR 3.8.1.6, and SR 3.8.1.7 L07 SR 3.8.1.4 1. Verifying the fuel level in the engine-mounted day tanks.

2. Verifying the fuel level in the 7 day tank. See ITS 3.8.3 SR 3.8.1.6 3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine mounted fuel tanks Add proposed Note 1 to SR 3.8.1.2 and Note to SR 3.8.1.7. A05 SR 3.8.1.2 and SR 3.8.1.7 4. *Verifying the diesel starts from ambient condition and achieves in less than or equal SR 3.8.1.7 to 10 seconds voltage and frequency of 6800 volts and 58.8 Hz and achieves a steady state voltage and frequency of 6800 volts and 7260 volts and 58.8 Hz SR 3.8.1.2 and and 61.2 Hz. The diesel generator shall be started for this test by using one of the SR 3.8.1.7 following signals with startup on each signal verified at least once per 124 days:

a) Manual.

L08 b) Simulated loss of offsite power by itself.

L09 c) An ESF actuation test signal by itself.

Add proposed SR 3.8.1.3 Note 2 Add proposed SR 3.8.1.3 Note 4 M02 SR 3.8.1.3 5. *Verifying the generator is synchronized, loaded between 3960 kw and 4400 kw in less than or equal to 60 seconds, and operates for greater than or equal to 60 minutes, and as recommended by the manufacturer A06

6. Verifying the diesel generator is aligned to provide standby power to the associated LA03 shutdown boards.

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.5 b. At least once per 31 days and after each operation of the diesel where the period of L10 operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the engine-mounted fuel tanks.

c. At a frequency in accordance with the Diesel Fuel Oil Testing Program, verify fuel oil See ITS 3.8.3 properties of new and stored fuel oil are tested in accordance with, and maintained within the limits specified in the Diesel Fuel Oil Testing Program.

A06 SR 3.8.1.3,

  • The diesel generator start (10 sec) and load (60 sec) from standby conditions shall be performed at SR 3.8.1.7 least once per 184 days in these surveillance tests. All other diesel generator engine starts and loading for the purpose of this surveillance testing may be preceded by an engine idle start, followed SR 3.8.1.2 by gradual acceleration to synchronous speed (approximately 900 rpm), synchronization, and gradual Note 2 and SR 3.8.1.3 loading. In this latter case, 10 second requirements do not apply. In accordance with the Surveillance Note 1 LA02 Frequency Control Program LA04 as recommended by the manufacturer A06 October 2, 2000 SEQUOYAH - UNIT 1 3/4 8-3 Amendment No. 52, 64, 99, 109, 137, 173, 195, 226, 234, 261 Page 3 of 17 Enclosure 2, Volume 13, Rev. 0, Page 7 of 638

Enclosure 2, Volume 13, Rev. 0, Page 8 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.11, d. At least once per 18 months during shutdown by:

SR 3.8.1.12, SR 3.8.1.13, L11 SR 3.8.1.16, 1. This surveillance is deleted.

SR 3.8.1.17 and SR 3.8.1.18

2. This surveillance has been relocated to SR 4.8.1.1.2.g.1.
3. This surveillance has been relocated to SR 4.8.1.1.2.g.2. Add proposed SR 3.8.1.11 Note 1 A05 Add proposed SR 3.8.1.11 Note 2 L11
4. Simulating a loss of offsite power by itself, and:

or an actual signal L12 a) Verifying de-energization of the shutdown boards and load shedding from the shutdown boards.

SR 3.8.1.11 b) Verifying the diesel starts on the auto-start signal, energizes the shutdown boards with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequencers and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady state voltage and frequency of the shutdown boards shall be maintained at 6800 volts and 7260 volts and A05 58.8 Hz and 61.2 Hz during this test. Add proposed SR 3.8.1.12 Note 1 Add proposed SR 3.8.1.12 Note 2 L11 actual or simulated

5. Verifying that on a ESF actuation test signal (without loss of offsite power) the diesel L12 generator starts on the auto-start signal and operates on standby for greater than or SR 3.8.1.12 equal to 5 minutes. The generator voltage and frequency shall be 6800 volts and A07 58.8 Hz within 10 seconds after the auto-start signal. After energization, the steady M03 state generator voltage and frequency shall be maintained at 6800 volts and 7260 Add proposed SR 3.8.1.12.d and e A05 volts and 58.8 Hz and 61.2 Hz during this test.

Add proposed SR 3.8.1.18 Note 1 Add proposed SR 3.8.1.18 Note 2

6. Simulating a loss of offsite power in conjunction with an ESF actuation test signal, L11 and actual or simulated or an actual signal L12 a) Verifying de-energization of the shutdown boards and load shedding from the shutdown boards.

SR 3.8.1.18 b) Verifying the diesel starts on the auto-start signal, energizes the shutdown boards with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loads through the load sequencers and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady state voltage and frequency of the shutdown boards shall be maintained at 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.

Add proposed SR 3.8.1.13 Note L11 non-critical c) Verifying that all automatic diesel generator trips, except engine overspeed SR 3.8.1.13 LA05 and generator differential, are automatically bypassed upon loss of voltage on the shutdown board and/or safety injection actuation signal.

actual or simulated L12

7. This surveillance has been relocated to SR 4.8.1.1.2.g.3 and SR 4.8.1.1.2.g.4.

July 22, 1998 SEQUOYAH - UNIT 1 3/4 8-4 Amendment Nos. 49, 64, 99, 114, 137, 154, 170, 234 Page 4 of 17 Enclosure 2, Volume 13, Rev. 0, Page 8 of 638

Enclosure 2, Volume 13, Rev. 0, Page 9 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

8. Verifying that the auto-connected loads to each diesel generator do not exceed the L13 continuous rating of 4400 kW.

Add proposed SR 3.8.1.16 Note L11

9. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with SR 3.8.1.16 its emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and c) Be restored to its shutdown status.

SR 3.8.1.17 10. Verifying that the automatic load sequence timers are OPERABLE with the setpoint for each sequence timer within + 5 percent of its design setpoint.#

Add proposed SR 3.8.1.19 Note A05

11. This surveillance is deleted. In accordance with the Surveillance Frequency Control Program LA02
e. At least once per 10 years or after any modifications which could affect diesel generator SR 3.8.1.19 L14 interdependence by starting the diesel generators simultaneously and verifying that each diesel generator achieves in less than or equal to 10 seconds, 6800 volts and 58.8 Hz.
f. At least once per 10 years by:
1. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning See ITS the tank. 3.8.3 In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.9, g. At least once per 18 months by: Add proposed SR 3.8.1.9 Notes 1 and 2 M04 SR 3.8.1.10 its associated single largest post-accident load SR 3.8.1.9 1. Verifying the generator capability to reject a load of greater than or equal to 600 kw LA06 while maintaining voltage at within +/- 10 percent of the initial pretest voltage and 6800 V and frequency at 60 + 1.2 Hz. At no time shall the transient voltage exceed 8276V. 7260 V M05 Add proposed recovery time and maximum frequency.

SR 3.8.1.10 2. Verifying the generator capability to reject a load of 4400 kw without tripping. The 3960 L15 generator voltage shall not exceed 8880V during and following the load rejection. and L16 Add proposed SR 3.8.1.10 Notes 1 and 2 M04 SR 3.8.1.17 Note #May be performed in Modes 1, 2, 3 & 4 if the associated equipment is out of service for maintenance or testing. to re-establish OPERABILITY provided an assessment determines the safety of the plant is M06 maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

October 2, 2000 SEQUOYAH - UNIT 1 3/4 8-5 Amendment No. 52, 64, 99, 109, 114, 137, 170,173, 195, 213, 234, 242, 261 Page 5 of 17 Enclosure 2, Volume 13, Rev. 0, Page 9 of 638

Enclosure 2, Volume 13, Rev. 0, Page 10 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS Add proposed SR 3.8.1.14 Note 1 L09 Add proposed SR 3.8.1.14 Notes 2 and 3 M04 SURVEILLANCE REQUIREMENTS (Continued)

For L17

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> SR 3.8.1.14 to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage L17 and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. Add proposed SR 3.8.1.15 Note 1, Part 2 Add proposed SR 3.8.1.15 Note 2 L09 SR 3.8.1.15

4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> A05 Note, Part 1 loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and L18 operates for greater than or equal to 5 minutes. After energization, the steady state SR 3.8.1.15 voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. achieves voltage 6800 V and frequency 58.8 Hz L19 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for each diesel generator shall be demonstrated OPERABLE:
a. At least once per 7 days by verifying:
1. That the parameters in Table 4.8-1a meet the Category A limits.
2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge.
b. At least once per 92 days by: See ITS 3.8.6
1. Verifying that the parameters in Table 4.8-1a meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to 6

terminal connection resistance of these items is less than 150 x 10- ohms, and

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.
c. At least once per 18 months by verifying that:
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.

6

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

4.8.1.1.4 This surveillance has been deleted.

December 16, 1998 SEQUOYAH - UNIT 1 3/4 8-6 Amendment Nos. 52, 137, 173, 213, 234, 241 Page 6 of 17 Enclosure 2, Volume 13, Rev. 0, Page 10 of 638

Enclosure 2, Volume 13, Rev. 0, Page 11 of 638 ITS A01 ITS 3.8.1 3/4 LIMITING CONDITIONS FOR OPEATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met and as provided in LCO 3.0.7.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

See ITS 3.0 Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Required 3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely Actions A.2, because its emergency power source is inoperable, or solely because its normal power source is B.2, E.1, and associated inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its Completion applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power Times source is OPERABLE; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-1 Amendment No. 202, 301, 312 Page 7 of 17 Enclosure 2, Volume 13, Rev. 0, Page 11 of 638

Enclosure 2, Volume 13, Rev. 0, Page 12 of 638 ITS A01 ITS 3.8.1 APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2 3.0.5 (Continued) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Action B.2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Required Action E.1 conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in: L20

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Declare required features inoperable.
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This Specification is not applicable in MODES 5 or 6. A08 3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.7 When one or more required snubbers are unable to perform their associated support function(s),

any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

See ITS 3.0 SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. 78, 162, 202, 208, 274, 280, 293, 312 Page 8 of 17 Enclosure 2, Volume 13, Rev. 0, Page 12 of 638

Enclosure 2, Volume 13, Rev. 0, Page 13 of 638 ITS A01 ITS 3.8.1 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.1 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

qualified LA01 LCO 3.8.1.a a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and A02 LCO 3.8.1.b b. Four separate and independent diesel generator sets each with:

LA01

1. Two diesels driving a common generator SR 3.8.1.4 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of 62,000 gallons of See ITS fuel, 3.8.3 SR 3.8.1.6 4. A separate fuel transfer pump, and
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS 3.8.4 and associated charger. 3.8.9 Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Add proposed Condition A L01

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, ACTION A demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> L01 thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in ACTION K at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the L02 following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed Condition B L01 b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining ACTION B A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement L01 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION K SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS C and D L01

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common L02 cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.

SR 3.8.1.3

  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis Note 3 L03 for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV A02 Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, 231, 325 Page 9 of 16 Enclosure 2, Volume 13, Rev. 0, Page 13 of 638

Enclosure 2, Volume 13, Rev. 0, Page 14 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS ACTION (Continued) Add proposed ACTION F Note A03 Add proposed Condition F L01 ACTION F

c. With one offsite circuit and one diesel generator set of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by ACTION A, performing Surveillance Requirements 4.8.1.1.1.a within one hour and at least once per 8 24 L04 ACTION B hours thereafter, and Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; restore at least ACTION F one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT ACTION K STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With two of the above required offsite A.C. circuits inoperable, demonstrate the ACTION E OPERABILITY of 4 diesel generator sets by performing Surveillance Requirement L05 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the diesel generator sets are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in ACTION K at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> M01 ACTION J
e. With either diesel generator sets 1A-A and/or 2 A-A inoperable simultaneous with 1B-B and/or 2B-B, demonstrate the OPERABILITY of two offsite A.C. circuits by performing L01 ACTION B Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least 1) 1A-A and 2A-A or 2) 1B-B and 2B-B to OPERABLE status ACTION J within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION K SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS G, H, and I L01 ACTIONS Note f. LCO 3.0.4.b is not applicable to diesel generators.

Add proposed ACTIONS L and M A04 SURVEILLANCE REQUIREMENTS SR 3.8.1.1 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and LA01 the onsite Class 1E distribution system shall be:

SR 3.8.1.1 a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments and indicated power availability. In accordance with the Surveillance LA02 Frequency Control Program SR 3.8.1.8 b. Demonstrated OPERABLE at least once per 18 months# by manually and automatically transferring the power supply to each 6.9 kV Unit Board ## from the normal supply to the alternate supply.

SR 3.8.1.8 # For the 2A, 2B, 2C and 2D 6.9 kV Unit Boards this Surveillance shall not be performed in Note 1 MODES 1 and 2. Add proposed SR 3.8.1.8 Note 1, second and third sentences. L06 SR 3.8.1.8 ## Transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and Note 2 alternate power supplies.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-2 Amendment No. 89, 123, 176, 195, 219, 246, 290, 325 Page 10 of 17 Enclosure 2, Volume 13, Rev. 0, Page 14 of 638

Enclosure 2, Volume 13, Rev. 0, Page 15 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.2 Each diesel generator set shall be demonstrated OPERABLE:

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.2, SR 3.8.1.3,

a. At least once per 31 days on a staggered test basis by:

SR 3.8.1.4, SR 3.8.1.6, and SR 3.8.1.7 L07 SR 3.8.1.4 1. Verifying the fuel level in the engine-mounted day tanks.

See ITS

2. Verifying the fuel level in the 7 day tank.

3.8.3 SR 3.8.1.6 3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine mounted fuel tanks Add proposed Note 1 to SR 3.8.1.2 and Note to SR 3.8.1.7. A05 SR 3.8.1.2 and SR 3.8.1.7 4. *Verifying the diesel starts from ambient condition and achieves in less than or equal SR 3.8.1.7 to 10 seconds generator voltage and frequency of 6800 volts and 58.8 Hz and SR 3.8.1.2 and achieves a steady state voltage and frequency of 6800 volts and 7260 volts and SR 3.8.1.7 58.8 Hz and 61.2 Hz. The diesel generator shall be started for this test by using one of the following signals with startup on each signal verified at least once per 124 days:

a) Manual.

L08 b) Simulated loss of offsite power by itself.

L09 c) An ESF actuation test signal by itself.

Add proposed SR 3.8.1.3 Note 2 Add proposed SR 3.8.1.3 Note 4 M02 SR 3.8.1.3 5. *Verifying the generator is synchronized, loaded between 3960 kw and 4400 kw in less than or equal to 60 seconds, and operates for greater than or equal to 60 minutes, and A06 as recommended by the manufacturer

6. Verifying the diesel generator is aligned to provide standby power to the associated LA03 shutdown boards.

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.5

b. At least once per 31 days and after each operation of the diesel where the period of operation L10 was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the engine-mounted fuel tanks.
c. At a frequency in accordance with the Diesel Fuel Oil Testing Program, verify fuel oil See ITS properties of new and stored fuel oil are tested in accordance with, and maintained within 3.8.3 the limits specified in the Diesel Fuel Oil Testing Program.

A06 SR 3.8.1.3,

  • The diesel generator start (10 sec) and load (60 sec) from standby conditions shall be performed at SR3.8.1.7 least once per 184 days in these surveillance tests. All other diesel generator engine starts and loading for the purpose of this surveillance testing may be preceded by an engine idle start, followed SR 3.8.1.2 by gradual acceleration to synchronous speed (approximately 900 rpm), synchronization, and gradual Note 2 and SR 3.8.1.3 loading. In this latter case, 10 second requirements do not apply. In accordance with the Surveillance LA02 Note 1 Frequency Control Program LA04 as recommended by the manufacturer A06 October 2, 2000 SEQUOYAH - UNIT 2 3/4 8-3 Amendment No. 44, 56, 88, 99, 123, 164, 186, 217, 224, 252 Page 11 of 17 Enclosure 2, Volume 13, Rev. 0, Page 15 of 638

Enclosure 2, Volume 13, Rev. 0, Page 16 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.11, d. At least once per 18 months during shutdown by:

SR 3.8.1.12, SR 3.8.1.13, L11 SR 3.8.1.16, 1. This surveillance is deleted.

SR 3.8.1.17 and SR 3.8.1.18

2. This surveillance has been relocated to SR 4.8.1.1.2.g.1.
3. This surveillance has been relocated to SR 4.8.1.1.2.g.2. Add proposed SR 3.8.1.11 Note 1 A05 Add proposed SR 3.8.1.11 Note 2 L11
4. Simulating a loss of offsite power by itself, and:

or an actual signal L12 a) Verifying de-energization of the shutdown boards and load shedding from the shutdown boards.

SR 3.8.1.11 b) Verifying the diesel starts on the auto-start signal, energizes the shutdown boards with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequencers and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady state voltage and frequency of the shutdown boards shall be maintained at 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during A05 this test. Add proposed SR 3.8.1.12 Note 1 Add proposed SR 3.8.1.12 Note 2 L11 actual or simulated L12

5. Verifying that on a ESF actuation test signal, without loss of offsite power, the diesel A07 generator starts on the auto-start signal and operates on standby for greater than or equal SR 3.8.1.12 to 5 minutes. The generator voltage and frequency shall be 6800 volts and 58.8 Hz M03 within 10 seconds after the auto-start signal. After energization, the steady state generator voltage and frequency shall be maintained at 6800 volts and 7260 volts and 58.8 Hz A05 and 61.2 Hz during this test. Add proposed SR 3.8.1.12.d and e Add proposed SR 3.8.1.18 Note 1 Add proposed SR 3.8.1.18 Note 2
6. Simulating a loss of offsite power in conjunction with an ESF actuation test signal, and L11 actual or simulated or an actual signal L12 a) Verifying de-energization of the shutdown boards and load shedding from the shutdown boards.

b) Verifying the diesel starts on the auto-start signal, energizes the shutdown boards SR 3.8.1.18 with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loads through the load sequencers and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads.

After energization, the steady state voltage and frequency of the shutdown boards shall be maintained at 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. Add proposed SR 3.8.1.13 Note L11 non-critical c) Verifying that all automatic diesel generator trips, except engine overspeed and LA05 generator differential, are automatically bypassed upon loss of voltage on the SR 3.8.1.13 shutdown board and/or safety injection actuation signal.

actual or simulated L12

7. This surveillance has been relocated to SR 4.8.1.1.2.g.3 and SR 4.8.1.1.2.g.4.

July 22, 1998 SEQUOYAH - UNIT 2 3/4 8-4 Amendment Nos. 41, 56, 88 123, 144, 160, 224 Page 12 of 17 Enclosure 2, Volume 13, Rev. 0, Page 16 of 638

Enclosure 2, Volume 13, Rev. 0, Page 17 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

8. Verifying that the auto-connected loads to each diesel generator do not exceed the L13 continuous rating of 4400 kw.

Add proposed SR 3.8.1.16 Note L11

9. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its SR 3.8.1.16 emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and c) Be restored to its shutdown status.

SR 3.8.1.17 10. Verifying that the automatic load sequence timers are OPERABLE with the setpoint for each sequence timer within + 5 percent of its design setpoint.#

Add proposed SR 3.8.1.19 Note. A05

11. This surveillance is deleted.

In accordance with the Surveillance Frequency Control Program LA02

e. At least once per 10 years or after any modifications which could affect diesel generator L14 SR 3.8.1.19 interdependence by starting the diesel generators simultaneously and verifying that each diesel generator achieves in less than or equal to 10 seconds, 6800 volts and 58.8 Hz.
f. At least once per 10 years by:
1. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the See ITS 3.8.3 tank.

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.1.9, g. At least once per 18 months by: Add proposed SR 3.8.1.9 Notes 1 and 2. M04 SR 3.8.1.10 its associated single largest post-accident load SR 3.8.1.9 1. Verifying the generator capability to reject a load of greater than or equal to 600 kw while LA06 maintaining voltage at within +/- 10 percent of the initial pretest voltage and frequency at 60

+ 1.2 Hz. At no time shall the transient voltage exceed 8276V. 6800 V and 7260 V M05 Add proposed recovery time and maximum frequency.

SR 3.8.1.10 2. Verifying the generator capability to reject a load of 4400 kw without tripping. The L15 3960 and generator voltage shall not exceed 8880V during and following the load rejection.

L16 Add proposed SR 3.8.1.10 Notes 1 and 2. M04 SR 3.8.1.17 Note # May be performed in Modes 1, 2, 3 & 4 if the associated equipment is out of service for maintenance or testing. to reestablish OPERABILITY provided an assessment determines the safety of the plant is M06 maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

October 2, 2000 SEQUOYAH - UNIT 2 3/4 8-5 Amendment No. 41, 56, 88, 123, 160, 164, 186, 203, 224, 232, 252 Page 13 of 17 Enclosure 2, Volume 13, Rev. 0, Page 17 of 638

Enclosure 2, Volume 13, Rev. 0, Page 18 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS Add proposed SR 3.8.1.14 Note 1 L09 Add proposed SR 3.8.1.14 Notes 2 and 3 SURVEILLANCE REQUIREMENTS (Continued) M04 For L17

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 SR 3.8.1.14 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and L17 frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. Add proposed SR 3.8.1.15 Note 1, Part 2 Add proposed SR 3.8.1.15 Note 2 L09 SR 3.8.1.15 4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Note, Part 1 A05 loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates L18 for greater than or equal to 5 minutes. After energization, the steady state voltage and SR 3.8.1.15 frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. achieves voltage 6800 V and frequency 58.8 Hz L19 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for each diesel generator shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying:
1. That the parameters in Table 4.8-1a meet the Category A limits.
2. That the total battery terminal voltage is greater than or equal to 124 volts on float charge.
b. At least once per 92 days by:

See ITS

1. Verifying that the parameters in Table 4.8-1a meet the Category B limits, 3.8.6
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to

-6 terminal connection resistance of these items is less than 150 x 10 ohms, and

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.
c. At least once per 18 months by verifying that:
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.
3. The resistance of each cell to terminal connection is less than or equal to 150 x

-6 10 ohms.

July 22, 1998 SEQUOYAH - UNIT 2 3/4 8-6 Amendment Nos. 8, 56, 164, 203, 224 Page 14 of 17 Enclosure 2, Volume 13, Rev. 0, Page 18 of 638

Enclosure 2, Volume 13, Rev. 0, Page 19 of 638 ITS ITS 3.8.1 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.4 This surveillance has been deleted.

December 16, 1998 SEQUOYAH - UNIT 2 3/4 8-7 Amendment No. 44, 231 Page 15 of 17 Enclosure 2, Volume 13, Rev. 0, Page 19 of 638

Enclosure 2, Volume 13, Rev. 0, Page 20 of 638 ITS A01 ITS 3.8.1 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met and as provided in LCO 3.0.7.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

See ITS Where corrective measures are completed that permit operation under the ACTION requirements, the 3.0 ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Required 3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely Actions A.2, B.2, E.1, and because its emergency power source is inoperable, or solely because its normal power source is associated inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its Completion Times applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-1 Amendment No. 192, 290, 301 Page 16 of 17 Enclosure 2, Volume 13, Rev. 0, Page 20 of 638

Enclosure 2, Volume 13, Rev. 0, Page 21 of 638 ITS A01 ITS 3.8.1 APPLICABILITY LIMITING CONDITION FOR OPERATION 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2 3.0.5 (Continued) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Action B.2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Required Action E.1 conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in: L20

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Declare required features inoperable.
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This Specification is not applicable in MODES 5 or 6. A08 3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.7 When one or more required snubbers are unable to perform their associated support function(s),

any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

See ITS SURVEILLANCE REQUIREMENTS 3.0 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-2 Amendment No. 69, 152, 192, 198, 263, 271, 283, 301 Page 17 of 17 Enclosure 2, Volume 13, Rev. 0, Page 21 of 638

Enclosure 2, Volume 13, Rev. 0, Page 22 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.1.a Note @ has an expiration date of November 30, 2013. As it is anticipated that the SQN ITS Conversion License Amendment Request will not be approved by the NRC before this date, Note @ has been deleted. As such, these changes are administrative.

A03 CTS 3.8.1.1 ACTION c applies when one offsite circuit and one diesel generator (DG) are inoperable. In this condition, one or more required electrical boards may be de-energized. CTS 3.8.2.1 provides an ACTION for a de-energized required electrical board. ITS 3.8.1 ACTION F Note in the Required Actions column states, "Enter applicable Conditions and Required Action of LCO 3.8.9, "Distribution System - Operating," when Condition F is entered with no AC power source to any train." This changes the CTS by specifically requiring the compensatory actions for Distribution System - Operating to be taken, if a distribution train is made inoperable by inoperable AC Sources.

This change is acceptable because no changes are made to CTS requirements.

CTS 3.0.1 requires the associated ACTION requirements to be met when an LCO is not met. With the addition of ITS LCO 3.0.6, an exception to ITS LCO 3.0.2 (CTS 3.0.1) was created, whereby ACTION requirements associated with an unmet LCO are not required to be met. Therefore, in the event AC Sources are inoperable such that a distribution subsystem is de-energized, ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in the event of an entire train without power, specific direction to take appropriate ACTIONS for the Distribution System is added (ITS 3.8.1, Note to ACTION F) for the condition of no power for a train. This format and construction implements the existing treatment of this condition within the framework of the ITS methods. This change is designated as administrative because it does not result in a technical change to the CTS.

A04 CTS 3.8.1.1 does not contain an ACTION for multiple offsite circuits and DGs inoperable. Having multiple offsite circuits and DGs inoperable requires entering CTS LCO 3.0.3. ITS 3.8.1 ACTION L requires entering LCO 3.0.3 immediately, if two offsite circuits are inoperable concurrent with one or more inoperable Train A or Train B DG(s). ITS 3.8.1 ACTION M requires entering LCO 3.0.3 immediately, if one offsite circuit is inoperable concurrent with one or more inoperable Train A and Train DGs. This changes the CTS by adding specific ACTIONS requiring entry into LCO 3.0.3.

Sequoyah Unit 1 and Unit 2 Page 1 of 24 Enclosure 2, Volume 13, Rev. 0, Page 22 of 638

Enclosure 2, Volume 13, Rev. 0, Page 23 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The change is acceptable because the CTS ACTIONS for multiple offsite circuits and DGs inoperable are the same as the ITS ACTIONS. The change is necessary due to the format of the ITS. This change is designated as administrative, because it does not result in a technical change to the CTS.

A05 CTS 4.8.1.1.2.a.4, CTS 4.8.1.1.2.d.4, CTS 4.8.1.1.2.d.5, CTS 4.8.1.1.2.d.6, CTS 4.8.1.1.2.e, and CTS 4.8.1.1.2.g.4 require the DGs to be started. ITS SR 3.8.1.2, SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 also require the DGs to be started. However, each of the ITS Surveillances include a Note concerning a prelube. ITS SR 3.8.1.2 Note 1 states that all DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. The Note to SR 3.8.1.7 and SR 3.8.1.19, Note 1 to SR 3.8.1.11, SR 3.8.1.12, and SR 3.8.1.18, and Note 2 to SR 3.8.1.15 state that all DG starts may be preceded by an engine prelube period. This changes the CTS by adding the Notes to the applicable Surveillance Requirements.

A Note has been added to various Surveillances that allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the DGs during testing. The addition of the Note is considered administrative, since the DGs at SQN run in a continuous prelube mode of operation. In addition, the Note to ITS SR 3.8.1.2 allows a warmup period prior to loading. The addition of this part of the Note is considered administrative, because the DGs are not immediately loaded upon startup, but are allowed to warmup for a short time after startup while the operations staff performs post startup DG checks. This change is designated as administrative, because it does not result in a technical change to the CTS.

A06 CTS 4.8.1.1.2.a.4 requires, in part, a manual start of each DG from ambient conditions and verification that the DG achieves a steady state voltage and frequency of 6800 V and 7260 V and 58.8 Hz and 61.2 Hz.

CTS 4.8.1.1.2.a.5 requires that the DG is synchronized, loaded between 3960 kW and 4400 kW in less than or equal to 60 seconds, and operates for at least 60 minutes. These Surveillances are modified by Note

  • that states the DG start may be preceded by an engine idle start and followed by gradual acceleration to synchronous speed, synchronization, and gradual loading. ITS SR 3.8.1.2 and SR 3.8.1.3 require similar DG tests. The ITS SR 3.8.1.2 is modified by Note 2 that states a modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. ITS SR 3.8.1.3 is modified by Note 1 that states DG loadings may include gradual loadings as recommended by the manufacturer. This changes the CTS by specifying the DG gradual acceleration to synchronous speed and DG gradual loading be performed "as recommended by the manufacturer."

The purpose of CTS 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 is to ensure each DG can be started and loaded from standby conditions. This change adds a specific requirement that DG gradual acceleration to synchronous speed may be used as recommended by the manufacturer. This change is consistent with current practice and is not precluded by CTS. Additionally, this change replaces the Sequoyah Unit 1 and Unit 2 Page 2 of 24 Enclosure 2, Volume 13, Rev. 0, Page 23 of 638

Enclosure 2, Volume 13, Rev. 0, Page 24 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING specific CTS DG loading requirement with a statement that DG loadings may include gradual loading as recommended by the manufacturer. This change is consistent with the recommendations of Generic Letter (GL) 93-05, "Line- Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." GL 93-05, Section 10.1, states that DGs "should be loaded in accordance with vendor recommendations for all test purposes other than the refueling outage LOOP tests." The change is acceptable, because it will ensure the DGs will continue to be operated consistent with manufacturer recommendations. This change is designated as administrative, because it does not result in a technical change to the CTS.

A07 CTS 4.8.1.1.2.d.5 requires verification that on an ESF actuation test signal (without loss of offsite power), each DG starts and operates for at least 5 minutes. ITS SR 3.8.1.12 requires a similar test, but does not specify that the DG auto-start on an ESF actuation test signal is "without loss of offsite power."

This changes the CTS by not specifying the DG auto-start on an ESF actuation test signal is without a loss of offsite power signal.

The purpose of CTS 4.8.1.1.2.d.5 is to demonstrate that each DG automatically starts on an ESF actuation test signal. The requirements of this Surveillance are retained in the ITS as SR 3.8.1.12. The purpose of CTS 4.8.1.1.2.d.6.b) is to verify that each DG starts on a loss of offsite power concurrent with an ESF actuation test signal. The requirements of this Surveillance are retained in the ITS as SR 3.8.1.18. This change is acceptable, because it is understood that the CTS 4.8.1.1.2.d.5 required DG start on an ESF actuation test signal is without a loss of offsite power signal. Therefore, it is unnecessary to provide this information in ITS SR 3.8.1.12. This change is designated as administrative, because it does not result in a technical change to the CTS.

A08 CTS 3.0.5 states that it is not applicable in MODE 5 or 6. CTS 3.0.5 has been incorporated into the ACTIONS of ITS 3.8.1. This changes the CTS by incorporating the allowances of CTS 3.0.5 in ITS 3.8.1.

This change is acceptable because ITS 3.8.1 is only applicable in MODES 1, 2, 3, and 4. Therefore, the statement in CTS 3.0.5, that states that the Specification is not applicable in MODE 5 or 6, is no longer necessary and is deleted. This change is designated as administrative, because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.1 ACTION d specifies the compensatory actions for two inoperable offsite circuits. The action requires restoration of at least one of the offsite sources within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and if it is not restored within the allowed time, the unit is required to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.8.1 ACTION E requires restoration of at least one offsite circuit to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, otherwise ITS 3.8.1 ACTION K requires the unit to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This changes the CTS by adding the requirement to be in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Sequoyah Unit 1 and Unit 2 Page 3 of 24 Enclosure 2, Volume 13, Rev. 0, Page 24 of 638

Enclosure 2, Volume 13, Rev. 0, Page 25 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of CTS 3.8.1.1 ACTION d is to provide the appropriate compensatory actions for two inoperable offsite circuits. However, the current action does not place the unit outside the MODE of Applicability of the Specification, if the Required Action and Completion Time are not met. Other CTS 3.8.1.1 ACTIONS require the unit to be placed outside the MODE of Applicability of the Specification (i.e., MODE 5). The action to exit the MODE of Applicability of the Specification is also appropriate for two inoperable offsite circuits. This change is designated as more restrictive, because additional requirements are being imposed that limit unit operation in the event of two inoperable offsite circuits.

M02 CTS 4.8.1.1.2.a.5 requires each DG to be synchronized, loaded, and operated for at least 60 minutes. ITS SR 3.8.1.3 requires the same test, however an additional Note has been added that places a restriction on the test. ITS SR 3.8.1.3 Note 4 modifies the CTS requirements by stating that the SR shall be preceded by and immediately follow, without a shut down of the DG, a successful performance of ITS SR 3.8.1.2 or ITS SR 3.8.1.7. This changes the CTS by adding a restriction when performing this test.

The purpose of CTS 4.8.1.1.2.a.5 is to ensure the DG can supply the emergency loads. This change is acceptable because DG loading during performance of CTS 4.8.1.1.2.a.5 is usually conducted without shut down after a successful start during performance of CTS 4.8.1.1.2.a.4. This change is designated as more restrictive, because an explicit restriction is added to the DG load test.

M03 CTS 4.8.1.1.2.d.5 requires each DG to auto-start on an ESF actuation test signal and operate for greater than or equal to 5 minutes. The generator voltage and frequency shall be 6800 V and frequency 58.8 Hz within 10 seconds. After energization the steady state voltage and frequency of the shutdown boards shall be 6800 V and 7260 V and 58.8 Hz and 61.2 Hz. ITS SR 3.8.1.12 requires the verification that each DG auto-start from standby condition and; a) in 10 seconds the DG achieves voltage 6800 V and frequency 58.8 Hz; b) achieves steady state voltage 6800 V and 7260 V and frequency 58.8 Hz and 61.2 Hz; c) operates for 5 minutes; d) permanently connected loads remain energized from the offsite power system; and e) emergency loads are energized from the offsite power system. This changes the CTS by adding additional performance requirements for the ESF actuation test.

The purpose of the CTS 4.8.1.1.2.d.5 is to test the performance of each DG on an ESF actuation test signal. The proposed change adds explicit requirements to verify the permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power. The change is acceptable, because verifying the connection of the permanent loads and emergency loads will confirm the DG loading logic. This change is designated as more restrictive, because additional acceptance criteria have been added to the CTS.

M04 CTS 4.8.1.1.2.g.1 requires the testing of each DG with a load rejection greater than or equal to 600 kW. CTS 4.8.1.1.2.g.2 requires the testing of each DG with a load rejection of 4400 kW. CTS 4.8.1.1.2.g.3 requires verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under specific loaded conditions. These Sequoyah Unit 1 and Unit 2 Page 4 of 24 Enclosure 2, Volume 13, Rev. 0, Page 25 of 638

Enclosure 2, Volume 13, Rev. 0, Page 26 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Surveillances do not specify that the testing be performed under certain unit conditions, nor that a DG shall be tested at a specific power factor. ITS SR 3.8.1.9 requires the verification that each DG can reject a load equal to or greater than its associated single largest post-accident load. ITS SR 3.8.1.10 requires the verification that each DG can reject a load of 3960 kW and 4400 kW. ITS SR 3.8.1.14 requires verifying each DG operates for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 4620 kW and 4840 kW and for the remaining hours of the test loaded 3960 kW and 4400 kW. Two Notes modify these SRs.

Note 1 states that for the associated unit's DGs, the Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Finally, credit may be taken for unplanned events that satisfy this SR. Note 2 states that if the Surveillance is performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. This changes the CTS requirement by specifying conditions for when the associated unit DGs are normally tested and by specifying a power factor of 0.89, if the testing is conducted by synchronizing with the offsite sources. Other changes to CTS 4.8.1.1.2.g.1 (ITS SR 3.8.1.9) are discussed in DOCs M05, LA06, and L15, while other changes to CTS 4.8.1.1.2.g.2 (ITS SR 3.8.1.1.10) are discussed in DOC L16.

The addition of Note 1 is acceptable, because performance of the Surveillance for the associated unit's DGs could cause perturbations to the electrical distribution systems. Restricting normal performance of the Surveillance on the associated unit's DGs during MODES 1 and 2 minimizes challenges to continued steady state operation and, as a result, the unit's safety systems. However, if an assessment of the risks indicates plant safety is maintained or enhanced, the Surveillance can be performed to reestablish OPERABILITY. The addition of Note 2 is acceptable, because the testing should be conducted as close as possible to the conditions that would be experienced by a DG following an accident. Loading the DG solely with the inductive characteristics of a large motor will create a power factor less than unity. The design of the DG is set for full power operation with a power factor of 0.8. Therefore, testing of the DG for a loss of the single largest load and at full load is acceptable with a power factor 0.89. This change is designated as more restrictive, because the testing required by the CTS does not currently contain these limitations.

M05 CTS 4.8.1.1.2.g.1 requires verification of the generator capability to reject a load greater than or equal to the specified value while maintaining voltage within

+/- 10 percent of the initial pretest voltage and frequency at 60 +/- 1.2 Hz.

Additionally, CTS 4.8.1.1.2.g.1 requires that at no time shall the transient voltage exceed 8276 V. ITS SR 3.8.1.9 requires verification that following load rejection, frequency is 66.5 Hz, and within 3 seconds following load rejection voltage is 6800 V and 7260 V and frequency is 58.8 Hz and 61.2 Hz. This changes the CTS in that the steady state voltage range has been reduced from "within +/-

10 percent of the initial pretest voltage" to " 6800 V and 7260 V." The deletion of the maximum voltage limit for the first 3 seconds following load rejection and Sequoyah Unit 1 and Unit 2 Page 5 of 24 Enclosure 2, Volume 13, Rev. 0, Page 26 of 638

Enclosure 2, Volume 13, Rev. 0, Page 27 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING adoption of a higher frequency excursion limit for the first 3 seconds following load rejection are described in DOC L15.

The purpose of the CTS 4.8.1.1.2.g.1 is to demonstrate the DG load response characteristics and capability to reject the largest single load without exceeding the appropriate limitations for voltage and frequency while maintaining margin to the overspeed trip. This change imposes a reduced steady state voltage range after the first 3 seconds following load rejection. The more restrictive steady state voltage limit provides assurance that the ESF pumps have the appropriate level of voltage available, so that they are assured of achieving adequate fluid flow to meet their safety and accident mitigation functions. This change is designated as more restrictive, because the proposed voltage range limit has been reduced.

M06 CTS 4.8.1.1.2.d.10 requires verification that the automatic load sequence timers are OPERABLE at least once per 18 months during shutdown. This Surveillance is modified by Note # that allows the test to be performed in MODES 1, 2, 3, and 4 if the associated equipment is out of service for maintenance or testing.

ITS SR 3.8.1.17 requires a similar test that is modified by a Note stating the Surveillance shall not normally be performed for the associated unit's DGs in MODE 1, 2, 3, or 4. The Note also states that the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. It further states that credit may be taken for unplanned events that satisfy this SR. This changes the CTS by only allowing relaxation of the performance restriction to reestablish OPERABILITY provided the associated assessment is performed or provided that an unplanned event satisfies the requirements of the Surveillance.

The purpose of CTS 4.8.1.1.2.d.10 is to confirm the OPERABILITY of the automatic load sequence timers. The purpose of Note # is to limit performance of the Surveillance during MODES 1, 2, 3, and 4 when perturbations to the electrical distribution system may occur that could challenge safety systems.

This change is acceptable, because the revised Note will continue to limit performance of the Surveillance while operating in MODES 1, 2, 3, and 4.

Additionally, the Surveillance will only be performed in MODES 1, 2, 3 and 4 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced, or credit for satisfying the Surveillance is being taken for an unplanned event. Lastly, the proposed Surveillance Note still restricts planned performance of the Surveillances to MODES other than MODE 1, 2, 3, or 4. This change is designated as more restrictive, because the plant conditions that the Surveillance may be performed in have been reduced.

RELOCATED SPECIFICATIONS None Sequoyah Unit 1 and Unit 2 Page 6 of 24 Enclosure 2, Volume 13, Rev. 0, Page 27 of 638

Enclosure 2, Volume 13, Rev. 0, Page 28 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.a requires two "physically independent" circuits between the offsite network and the onsite Class 1E AC Electrical Distribution System to be OPERABLE. CTS 3.8.1.1.b requires four "separate and independent" DG sets to be OPERABLE, each with "two diesels driving a common generator." CTS 4.8.1.1.1 requires the determination of OPERABILITY for each "independent" circuit between the offsite transmission network and the onsite Class 1E AC Electrical Distribution System. ITS LCO 3.8.1 requires two qualified circuits between the offsite network and the onsite Class 1E AC Electrical Distribution System, four DGs capable of supplying the onsite Class 1E AC Electrical Distribution System. ITS SR 3.8.1.1 requires verification of the correct breaker alignment for each offsite circuit. This changes the CTS by moving the details that the offsite circuits are "independent" or "physically independent," that the DGs are "separate and independent," and that each DG includes "two diesels driving a common generator" from the CTS to the Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE offsite sources and DGs. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.1.1.1.a requires verification of the correct breaker alignment between the offsite transmission network and the onsite Class 1E AC Electrical Distribution System at least once per 7 days. ITS SR 3.8.1.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.1.b requires demonstration of manual and automatic transfer from the normal power supply to the alternate power supply to each 6.9 kV Unit Board once per 18 months. ITS SR 3.8.1.8 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.a.1 requires verification of the fuel level in the engine-mounted fuel tanks at least once per 31 days ON A STAGGERED BASIS. ITS SR 3.8.1.4 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.a.3 requires verification that the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted fuel tanks at least once per 31 days ON A STAGGERED BASIS. ITS SR 3.8.1.6 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.a.4 requires verification that each DG can be started from ambient conditions and achieves voltage and frequency within specified values at least every 31 days ON A Sequoyah Unit 1 and Unit 2 Page 7 of 24 Enclosure 2, Volume 13, Rev. 0, Page 28 of 638

Enclosure 2, Volume 13, Rev. 0, Page 29 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING STAGGERED BASIS. Furthermore, the DG starts are required to be verified to occur within 10 seconds at least once per 184 days. ITS SR 3.8.1.2 and SR 3.8.1.7 require similar Surveillances with each SR specifying a periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.a.5 requires verification that each DG synchronizes and loads between 3960 kW and 4400 kW and operates for 60 minutes at least every 31 days ON A STAGGERED BASIS. ITS SR 3.8.1.3 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.b requires checking for and removing accumulated water from each DG engine-mounted fuel tank at least once per 31 days. ITS SR 3.8.1.5 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.d.4 requires verification of DG start on a loss of offsite power at least once per 18 months. ITS SR 3.8.1.11 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.d.5 requires verification of DG start on a safety injection signal at least once per 18 months.

ITS SR 3.8.1.12 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.d.6 requires verification of DG start on a loss of offsite power coincident with a safety injection signal at least once per 18 months. ITS SR 3.8.1.18 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.d.6.c) requires verification that DG noncritical automatic trips are bypassed on loss of voltage signal and a safety injection signal at least once per 18 months. ITS SR 3.8.1.13 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.d.9 requires verification of each DG's capability to synchronize with offsite power while loaded with its emergency loads upon a simulated restoration of offsite power, transfer its loads to the offsite power source, and restoration to its shutdown status at least once per 18 months. ITS SR 3.8.1.16 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.d.10 requires verification that each automatic load sequence timer setpoint is within 5 percent of its design setpoint at least once per 18 months.

ITS SR 3.8.1.17 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.e requires verification that the DGs achieve the specified voltage and frequency within 10 seconds when started simultaneously at least once per 10 years. ITS SR 3.8.1.19 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.g.1 requires verification of each DG's capability to reject a load of at least 600 kW and maintain voltage and frequency within specified values at least once per 18 months. ITS SR 3.8.1.9 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." CTS 4.8.1.1.2.g.2 requires verification of each DG's capability to reject a load of 4400 kW without tripping and without exceeding 8880 V at least once per 18 months. ITS SR 3.8.1.10 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.g.3 requires verification that each DG operates for at least 24 Sequoyah Unit 1 and Unit 2 Page 8 of 24 Enclosure 2, Volume 13, Rev. 0, Page 29 of 638

Enclosure 2, Volume 13, Rev. 0, Page 30 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING hours at the specified loads at least once per 18 months. ITS SR 3.8.1.14 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."

CTS 4.8.1.1.2.g.4 requires verification that within 5 minutes of shutting down each DG after it has operated for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the specified load that the DG starts within 10 seconds after receipt of a start signal and achieves voltage and frequency within specified values at a Frequency of at least once per 18 months. ITS SR 3.8.1.15 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for the SRs and the Bases to the Surveillance Frequency Control Program. (The change of the requirement to perform Surveillances ON A STAGGERED TEST BASIS is discussed in DOC L07).

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.a.6 requires the verification that each DG is aligned to provide standby power to the associated shutdown boards. ITS 3.8.1 does not contain this requirement. This changes the CTS by moving the detail that each DG is aligned to provide standby power to the associated shutdown boards from the CTS to the ITS Bases.

The removal of these details that are related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE DGs.

An OPERABLE DG must be capable of providing power to the associated shutdown boards as indicated in the Bases. This change is acceptable, because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

Sequoyah Unit 1 and Unit 2 Page 9 of 24 Enclosure 2, Volume 13, Rev. 0, Page 30 of 638

Enclosure 2, Volume 13, Rev. 0, Page 31 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.a.4 requires verification that each DG can be started from ambient conditions and achieve voltage and frequency within specified values. CTS 4.8.1.1.2.a.4 footnote

  • states, in part, that DG engine start and loading for the purpose of this Surveillance may be preceded by an engine idle start, followed by gradual acceleration to synchronous speed (approximately 900 rpm). ITS SR 3.8.1.2 requires a similar DG test, and is modified by a Note (Note 2) that states, in part, a modified DG start involving idling and gradual acceleration to synchronous speed may be used for the Surveillance. This changes the CTS by moving the detail that synchronous speed is approximately 900 rpm to the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the Note that a modified DG start involving gradual acceleration to synchronous speed may be used. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.d.6.c) requires verification that each DG's automatic trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the shutdown board and/or safety injection actuation signal. ITS SR 3.8.1.13 requires a similar verification, but instead of specifying the DG automatic trips that are not bypassed, the Surveillance refers to the trips that are bypassed as "noncritical." This changes the CTS by moving the detail of the specific DG trips that are not bypassed to the SQN UFSAR.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement to verify that the noncritical DG trips are bypassed on a loss of voltage signal concurrent with a safety injection signal. This change is acceptable because the UFSAR contains a complete listing of the DG electrical and mechanical trips and indicates the trips that are required whenever the DGs are required and the trips that are only required during the exercise mode of operation. In addition, SQN procedures periodically verify the capability of the DG trip relays and associated instrumentation to actuate a DG trip. The removed requirements will be adequately controlled in the UFSAR as any changes to the UFSAR are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

Sequoyah Unit 1 and Unit 2 Page 10 of 24 Enclosure 2, Volume 13, Rev. 0, Page 31 of 638

Enclosure 2, Volume 13, Rev. 0, Page 32 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING LA06 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.g.1 requires verification of each DG's capability to reject a load of greater than or equal to 600 kW while maintaining voltage and frequency within specified ranges. ITS SR 3.8.1.9 requires a similar verification, but does not specify the value of the single largest post-accident load to reject.

This changes the CTS by moving the detail of the single largest load to the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement to verify that each DG is capable of maintaining voltage and frequency within specified ranges upon reject of the single largest post-accident load. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 CTS 3.8.1.1 ACTION a provides actions for one inoperable offsite circuit and allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable offsite circuit to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION b provides actions for one or both DGs in a train inoperable and allows 7 days to restore the inoperable DG(s) to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION c provides actions for one inoperable offsite circuit and one inoperable DG and allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore at least one of the inoperable AC sources to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION d provides actions for two inoperable offsite circuits and allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore at least one of the inoperable offsite circuits to OPERABLE status before requiring the unit to be shut down. CTS 3.8.1.1 ACTION e provides actions for one or two inoperable DGs in both trains and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the inoperable DG(s) in one train to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION f states LCO 3.0.4.b is not applicable to DGs. The ITS ACTIONS are modified by a Note stating LCO 3.0.4.b is not applicable to DGs. ITS 3.8.1 ACTION A provides actions for one inoperable offsite circuit for reasons other than Condition C, and allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable offsite power source to OPERABLE status. ITS 3.8.1 ACTION B provides actions for one inoperable associated unit's DG or both DGs in one train inoperable, and allows 7 days to restore the inoperable DG(s) to OPERABLE status. ITS 3.8.1 ACTION C provides actions for one offsite circuit inoperable solely due to an inoperable offsite power source to an opposite unit's 6.9 kV Shutdown Board, and requires declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the offsite circuit cannot be Sequoyah Unit 1 and Unit 2 Page 11 of 24 Enclosure 2, Volume 13, Rev. 0, Page 32 of 638

Enclosure 2, Volume 13, Rev. 0, Page 33 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING restored to an OPERABLE status. ITS 3.8.1 ACTION D requires declaration that the affected required feature(s) with no OPERABLE DG are inoperable when its redundant required feature is inoperable in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the DG cannot be restored to an OPERABLE status. ITS 3.8.1 ACTION E requires declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Otherwise, one offsite circuit is required to be restored to an OPERABLE status in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.1 ACTION F provides actions for one associated unit's offsite circuit inoperable concurrent with one associated unit's DG inoperable, and allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore one of the inoperable AC sources to OPERABLE status. ITS ACTION G requires declaring the required feature(s) on the opposite unit's 6.9 kV Shutdown Board with no offsite power available inoperable in 7 days. ITS ACTION H requires declaring the required feature(s) on the opposite unit's 6.9 kV Shutdown Board with no DG available inoperable in 7 days. ITS ACTION I provides actions for one offsite circuit inoperable solely due to an inoperable offsite power source to an opposite unit's 6.9 kV Shutdown Board concurrent with one opposite unit's DG inoperable, and allows 7 days to restore one of the inoperable AC sources to OPERABLE status. In addition, a Note modifying ITS ACTION I requires entry into the applicable Conditions and Required Actions of LCO 3.8.9 with no AC power source to an opposite unit's 6.9 kV Shutdown Board. ITS 3.8.1 ACTION J provides actions for one or more Train A and one or more Train B DGs inoperable and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore one Train of DGs to OPERABLE status. ITS 3.8.1 ACTION K requires the unit to be shut down and cooled down if a Required Action and associated Completion Time of Condition A, B, E, F, I, or J is not met. These changes to the CTS provide separate ACTIONS to declare the required features powered from the opposite unit's Class 1E AC Electrical Power Distribution System inoperable as the remedial measures for the inoperable AC sources.

The purpose of the CTS 3.8.1.1 ACTIONS is to limit the time the unit can remain operating with different combinations of inoperable offsite circuits and DGs. The onsite Class 1E AC Electrical Distribution System supplies electrical power to two power trains shared between the two units. The core cooling and containment cooling system loads (e.g., Safety Injection (SI) pumps, Auxiliary Feedwater (AFW) pumps, Residual Heat Removal (RHR) pumps, Centrifugal Charging pumps, Containment Spray pumps, and Air Return System (ARS) fans) are unitized to the respective unit's 6.9 kV Shutdown Boards. However, some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVs), and Control Room HVAC (CRACS)) are shared between the units. The AC sources for the shared loads are distributed across both unit's shutdown boards.

Therefore, two qualified offsite circuits and four DGs capable of supplying the onsite Class 1E AC Electrical Distribution System are required to be OPERABLE.

However, the impacts of an inoperable offsite power source or DG on an opposite unit's 6.9 kV Shutdown Board differ from the impacts of an inoperable offsite power source or DG on an associated unit's 6.9 kV Shutdown Board, due to the loads powered from the respective board.

Sequoyah Unit 1 and Unit 2 Page 12 of 24 Enclosure 2, Volume 13, Rev. 0, Page 33 of 638

Enclosure 2, Volume 13, Rev. 0, Page 34 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING For example, with SQN Unit 1 in MODES 1, 2, 3, and 4, 6.9 kV Shutdown Boards 1A-A and 1B-B, and the associated offsite power sources and DGs are required to be OPERABLE to provide electrical power to the ESF systems powered from those boards. Additionally, 6.9 kV Shutdown Boards 2A-A and 2B-B and associated offsite power sources and DGs are required to be OPERABLE to provide electrical power to any required shared components required for Unit 1. If it is necessary to de-energize 6.9 kV Shutdown Board 2A-A or 2B-B, the redundant shared systems can be aligned prior to de-energizing the shutdown board to ensure no loss of safety function will occur. Upon removing the shutdown board from service, the applicable Conditions and Required Actions for the affected shared system LCOs will be entered and tracked and either the offsite power source or the DG is required to be restored to an OPERABLE status in 7 days.

In the event of an unplanned loss of an offsite power source to an opposite unit's 6.9 kV Shutdown Board, the proposed actions require declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the offsite power source cannot be restored to an OPERABLE status. Similarly, in the event of an unplanned loss of a DG to an opposite unit 6.9 kV Shutdown Board, the proposed actions require declaration that the affected required feature(s) with no OPERABLE DG are inoperable when its redundant required feature is inoperable in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the DG cannot be restored to an OPERABLE status. In both cases, the ACTIONS require performance of SR 3.8.1.1 for the required OPERABLE offsite circuit(s) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. These changes are acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation, while providing time to repair inoperable features. If the necessary repairs cannot be made within the established Completion Time, the associated required features are declared inoperable and the applicable Conditions and Required Actions for the affected shared system LCOs are entered and tracked. This change is acceptable because the provided ACTIONS effect restoration of the opposite unit's AC sources commensurate with the importance of maintaining these AC sources capable of supporting the associated unit's required feature(s). This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 ACTION b requires with DG set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B inoperable, determination that OPERABLE DGs are not inoperable due to common cause failure or through performance of CTS 4.8.1.1.2.a.4. This ACTION is modified by Note #, requiring completion of the required action once the ACTION is entered. ITS 3.8.1 Sequoyah Unit 1 and Unit 2 Page 13 of 24 Enclosure 2, Volume 13, Rev. 0, Page 34 of 638

Enclosure 2, Volume 13, Rev. 0, Page 35 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ACTION B requires with an associated unit's DG inoperable (or with both DGs in a train inoperable), determination that OPERABLE DGs are not inoperable due to common cause failure or through performance of SR 3.8.1.2. However, ITS does not specify completion of the ACTIONS if the Condition is exited. This changes the CTS by removing a requirement to complete the ACTIONS once the ACTION is entered.

The purpose of CTS 3.8.1.1 ACTION b is to provide compensatory measures to be taken in response to inoperable DG set(s), including demonstration that the OPERABLE DGs are not inoperable. The Note requiring completion of the actions to verify the remaining DGs are OPERABLE once the ACTION is entered was added to the CTS with License Amendments 205 (Unit 1) and 195 (Unit 2),

dated June 29, 1995 (ADAMS Accession No. ML013320017). TVA license amendment request TS 94-19, submitted on April 6, 1995, stated that the addition of this Note was being made to align with the requirements contained in NUREG-1431, LCO 3.8.1. On April 7, 1995, NUREG-1431, Rev. 1 was issued.

The Note modifying LCO 3.8.1 ACTION B that required completion of Required Actions B.3.1 and B.3.2 (demonstration of DG OPERABILITY) was removed from NUREG-1431 in Revision 1. The requirement to complete the actions to demonstrate the OPERABLE DGs are not inoperable is an exception to ITS LCO 3.0.2 (CTS LCO 3.0.2). Completing the ACTIONS to verify the OPERABILITY of the remaining OPERABLE DGs is not required to restore compliance with the LCO. This change is acceptable because completion of the ACTIONS to evaluate the possibility of a DG common cause failure will be tracked as an item in the corrective action program. This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 ACTION b provides actions for one or both DGs in a train inoperable. ACTION b is modified by Note

  • stating that no more than one DG may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing. ITS SR 3.8.1.3 verifies each DG can be started, synchronized, loaded, and operated for at least 60 minutes. SR 3.8.1.3 is modified by Note 3 stating the Surveillance shall be conducted on only one DG at a time. This changes the CTS by deleting the restriction for not making more than one DG simultaneously inoperable on a pre-planned basis, with the exception of the performance of SR 3.8.1.3.

The purpose of CTS 3.8.1.1 ACTION b is to provide required actions for one or both DGs in a train inoperable. The purpose of Note

  • is to ensure pre-planned activities that may result in an inoperable DG (i.e., maintenance, modifications, or surveillance testing) are not performed on both DGs in a train at the same time.

The proposed required actions do not include the restriction for limiting pre-planned activities to one DG at a time. The control of pre-planned maintenance, modifications, or surveillance testing is an issue for procedures and scheduling.

This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 3 - Relaxation of Completion Time) CTS 3.8.1.1 ACTION b requires, in part, with one or both DG(s) in a train inoperable to demonstrate the Sequoyah Unit 1 and Unit 2 Page 14 of 24 Enclosure 2, Volume 13, Rev. 0, Page 35 of 638

Enclosure 2, Volume 13, Rev. 0, Page 36 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING OPERABILITY of the remaining DGs by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. CTS 3.8.1.1 ACTION c requires, in part, with one offsite circuit and one DG inoperable to demonstrate the OPERABILITY of the remaining DGs by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.1 ACTION B requires with one or both DG(s) in a train inoperable to perform SR 3.8.1.2 for OPERABLE DGs within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This changes the CTS by extending the time allowed to demonstrate the OPERABILITY of the OPERABLE DGs with one offsite circuit and one DG inoperable from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The purpose of the CTS 3.8.1.1 ACTIONS b and c is to ensure that the OPERABLE DGs are not inoperable as a result of a similar, yet undetected, failure (i.e., due to a common mode failure). CTS 3.0.1 states that upon failure to meet an LCO, the associated ACTION requirements shall be met. In the instance of one offsite circuit and one DG inoperable, the condition of one inoperable DG also exists. Therefore, in addition to meeting the requirements of CTS 3.8.1.1 ACTION c, the requirements of CTS 3.8.1.1 ACTION b are required to be met. However, this results in conflicting time requirements for performing CTS 4.8.1.1.2.a.4 on the OPERABLE DGs. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time for performing DG common mode failure checks is consistent with the guidance provided in Generic Letter 84-15. This change is acceptable, since the vast majority of DG start tests demonstrate that the DG is OPERABLE. This change is designated as less restrictive, because additional time is allowed to demonstrate the OPERABILITY of the OPERABLE DGs for the condition of one offsite circuit and one DG inoperable under the ITS than under the CTS.

L05 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 ACTION d states, in part, with two offsite circuits inoperable demonstrate the OPERABILITY of the DGs by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the DGs are already operating. CTS 4.8.1.1.2.a.4 requires verification that each DG starts and achieves voltage and frequency within established ranges within 10 seconds. ITS 3.8.1 ACTION E does not contain this requirement. This changes the CTS by deleting the requirement to test each DG when two offsite circuits are inoperable.

The purpose of the CTS 4.8.1.1.2.a.4 requirement in CTS 3.8.1.1 ACTION c is to ensure that the DGs are OPERABLE in the case of a loss of offsite power. Since the DGs are tested on monthly basis, there is no reason to suspect that they would not perform their intended safety function. Furthermore, the inoperability of two offsite circuits does not affect the OPERABILITY of the DGs, since the DGs are independent of the offsite circuits. Therefore, there is no need to subject the DGs to additional testing. This change is designated as less restrictive because the CTS requirement to perform testing on the DGs when both offsite circuits are inoperable is not being retained in the ITS.

L06 (Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.1.1.1.b requires the demonstration of a manual and automatic transfer of the power supply to each 6.9 kV Unit Board from the normal to alternate once per 18 months. Note # specifies that the Surveillance shall not be performed on the associated unit's 6.9 kV Unit Boards in MODES 1 and 2.

This test has been incorporated in ITS SR 3.8.1.8. ITS SR 3.8.1.8 includes a Sequoyah Unit 1 and Unit 2 Page 15 of 24 Enclosure 2, Volume 13, Rev. 0, Page 36 of 638

Enclosure 2, Volume 13, Rev. 0, Page 37 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Note that states the Surveillance shall not normally be performed in MODES 1 and 2. The Note also states that the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. This changes the CTS by allowing the test to be performed in MODES 1 and 2 as long as the associated assessment is performed.

The purpose of CTS 4.8.1.1.1.b is to confirm OPERABILITY of the offsite circuits.

This change is acceptable because performance of the Surveillance will continue to be limited to conditions where an assessment has determined that plant safety will either be maintained or enhanced. Control of the plant conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do not dictate plant conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed at plant conditions other than shutdown.

L07 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.1.1.2.a requires, in part, performance of the following Surveillances for each DG to be demonstrated OPERABLE at a Frequency of at least once per 31 days on a STAGGERED TEST BASIS: 1. Verification of the fuel level in the engine-mounted fuel tanks;

3. Verification of the fuel transfer pump capability to transfer fuel from the storage system to the engine-mounted fuel tanks; 4. Verification that each DG starts from ambient conditions and achieves voltage and frequency within the specified values; and 5. Verification that each DG synchronizes and loads the specified amount of kilowatts and operates for at least 60 minutes. ITS SR 3.8.1.2, SR 3.8.1.3, SR 3.8.1.4, and SR 3.8.1.6 require similar verifications of each DG at a Frequency of "in accordance with the Surveillance Frequency Control Program." The discussion of moving the Surveillance Frequency to the Surveillance Frequency Control Program as discussed in DOC LA02. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.8.1.1.2.a is to ensure each DG is OPERABLE and available to mitigate design basis accidents and transients and maintain the unit in a safe shutdown condition. CTS 1.35, STAGGERED TEST BASIS definition, defines a testing schedule for n systems, subsystems, or trains by dividing the specified test interval into n equal subintervals, with the testing of one system, subsystem, or train occurring at the beginning of each subinterval. In other words, a Surveillance Requirement to verify the OPERABILITY of each train in a two train system at a Frequency of 31 days on a STAGGERED TEST BASIS would result in each train being verified OPERABLE every 31 days, with one train being verified in alternating 15.5 day subintervals. Removal of the STAGGERED TEST BASIS scheduling requirement does not change the requirement to verify the OPERABLILITY of each train every 31 days, but rather removes the requirement to schedule testing every 15.5 days. The new Surveillance Frequency will not change the testing Frequency of each train. The intent of the current staggered testing requirement is to evenly distribute testing of each DG across the system. However, as each DG is independent, no increase in Sequoyah Unit 1 and Unit 2 Page 16 of 24 Enclosure 2, Volume 13, Rev. 0, Page 37 of 638

Enclosure 2, Volume 13, Rev. 0, Page 38 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING reliability or safety is achieved by evenly staggering the testing subintervals. This change is acceptable, because removal of the staggered testing requirement will increase operational and scheduling flexibility without decreasing safety or system reliability. This change is designated as less restrictive, because the intervals between performances of the Surveillances for the DGs can be larger or smaller under the ITS than under the CTS.

L08 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.a.4 requires verification that each DG starts and achieves voltage and frequency within the specified limits. Additionally, the Surveillance requires the DG to be started for the test by using one of the following signals with startup on each signal verified at least once per 124 days: manual, simulated loss of offsite power by itself, and an ESF actuation test signal by itself. ITS SR 3.8.1.2 requires a similar test, but does not include the requirement to vary the start signal between manual, loss of offsite power, and ESF actuation. This changes the CTS by deleting the requirement to use different start signals in the performance of the DG start Surveillance.

The purpose of CTS 4.8.1.1.2.a.4 is to verify the capability of each DG to start and achieve voltage and frequency with the specified limits. This change is acceptable because the deleted requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between the origin of the start signal. Therefore, the results of the test are unaffected by the type of signal used to initiate the test. Each DG will continue to be tested in a manner to ensure the safety analyses assumption will be met. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L09 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.a.5 requires verification that each DG can be started and is operated within a specified loading range for at least 60 minutes.

CTS 4.8.1.1.2.g.3 requires verification that each DG can be started and is operated within specified loading ranges over a duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

CTS 4.8.1.1.2.g.4 requires verification that each DG can be started within 10 seconds following loading within a specified range for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS SR 3.8.1.3, SR 3.8.1.14 and SR 3.8.1.15 require similar tests. ITS SR 3.8.1.3 is modified by a Note stating that momentary transients outside the load range do not invalidate the test. ITS SR 3.8.1.14 is modified by a Note stating that momentary transients outside the load and power factor ranges do not invalidate the test. ITS SR 3.8.1.15 is modified by a Note stating that the restart is to follow operation for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a specified loading, and that momentary transients outside the load range do not invalidate the test. This changes the CTS by adding explicit Surveillance Notes to allow momentary transients outside the load range and/or power factor range that do not invalidate the test.

The purpose of CTS 4.8.1.1.2.a.5 and 4.8.1.1.2.g.3 is to verify the capability of each DG to operate at a loading that approximates the loading that would occur during accident conditions while avoiding routine overloading. The purpose of CTS 4.8.1.1.2.g.4 is to verify the capability of each DG to restart following operation where the DG has achieved hot conditions. This change is acceptable because it has been determined that the relaxed Surveillance Requirement Sequoyah Unit 1 and Unit 2 Page 17 of 24 Enclosure 2, Volume 13, Rev. 0, Page 38 of 638

Enclosure 2, Volume 13, Rev. 0, Page 39 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The Notes modifying these Surveillances acknowledge that during performance of these Surveillances changes in bus loads may occur that result in DG operation outside of the specified loading and/or power factor ranges. These momentary transients are not cause for invalidating the Surveillances, as successful performance of the Surveillances is not dependent on maintaining DG operation within the loading and power factor ranges for the entire specified duration to demonstrate DG OPERABILITY. This change is acceptable since each DG will continue to be tested as close as practicable to design conditions. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L10 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.1.1.2.b requires the removal of accumulated water from the engine-mounted fuel tanks at least once per 31 days and "after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." ITS SR 3.8.1.5 requires the same Surveillance to be performed at a Frequency of "in accordance with the Surveillance Frequency Control Program." The discussion of moving the Surveillance Frequency to the Surveillance Frequency Control Program as discussed in DOC LA02. This changes the CTS by deleting the conditional requirement to test for accumulated water after each operation of the DG for greater than or equal to one hour.

The purpose of CTS 4.8.1.1.2.b is to provide a degree of assurance that the engine-mounted fuel tanks are free of accumulated water each time the associated DG is operated for an hour or more. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Water condensation within the engine-mounted fuel tanks is a time dependent process, not a process dependent on the transfer of fuel oil during DG operation. Since it is the expectation that the DG will not be operated except for the nominal monthly OPERABILITY tests (based on experience), and that the fuel oil storage tanks are also periodically checked for water, no increased Frequency is necessary.

This change is designated as less restrictive because the explicit requirement to remove accumulated water in the engine-mounted fuel tanks after a DG run of greater than or equal to one hour has been deleted.

L11 (Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.1.1.2.d contains requirements to perform various tests "during shutdown." These tests have been incorporated into ITS SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.16, and SR 3.8.1.18. ITS SR 3.8.1.11, SR 3.8.1.16, and SR 3.8.1.18 include a Note stating the Surveillance shall not normally be performed for the associated unit's DGs in MODE 1, 2, 3, or 4. ITS SR 3.8.1.12 and SR 3.8.1.13 include a Note stating the Surveillance shall not normally be performed for the associated unit's DGs in MODE 1 or 2. The Notes also state that portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. It further states that credit may be taken for unplanned events that satisfy this SR. This changes the CTS by deleting the requirement to perform the Surveillances during shutdown and replacing the shutdown Sequoyah Unit 1 and Unit 2 Page 18 of 24 Enclosure 2, Volume 13, Rev. 0, Page 39 of 638

Enclosure 2, Volume 13, Rev. 0, Page 40 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING requirement with a Note stating when the Surveillances are not normally performed, but allowing the test to be performed in these MODES as long as the associated assessment is performed or provided that an unplanned event satisfies the requirements of the Surveillance.

The purpose of CTS 4.8.1.1.2.d is to confirm the OPERABILITY of each DG.

This change is acceptable, because the Surveillances, as modified by the revised Note, have been evaluated to ensure they provide an acceptable level of equipment reliability. The proposed Surveillances do not include the restriction on unit conditions at all times. It allows the unit to perform the Surveillances to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced and it allows the unit to credit an unplanned event for satisfying the Surveillances, provided the necessary data is obtained.

Furthermore, the proposed Surveillance Note still restricts planned performance of the Surveillances to MODES other than MODE 1 or 2, or MODE 1, 2, 3, or 4, as applicable. The control of the unit conditions appropriate to perform the tests is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. This change is designated as less restrictive, because the Surveillances may be performed during plant conditions other than shutdown.

L12 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.d.4 requires verification of DG performance following a "simulated" loss of offsite power. CTS 4.8.1.1.2.d.5 requires verification of DG performance following an ESF actuation "test" signal. CTS 4.8.1.1.2.d.6 requires verification of DG performance following a "simulated" loss of offsite power in conjunction with an ESF actuation "test" signal. CTS 4.8.1.1.2.d.6.c) requires verification that all automatic DG trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the shutdown board and/or safety injection actuation signal. ITS SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.18 specify that the signal may be from either an "actual or simulated."

This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.8.1.1.2.d.4, CTS 4.8.1.1.2.d.5, CTS 4.8.1.1.2.d.6, and CTS 4.8.1.1.2.d.6.c) is to ensure that the AC Sources operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual,"

"simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 19 of 24 Enclosure 2, Volume 13, Rev. 0, Page 40 of 638

Enclosure 2, Volume 13, Rev. 0, Page 41 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L13 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.d.8 requires verification that the auto-connected loads to each DG do not exceed 4400 kW.

ITS 3.8.1 does not require the verification of this loading limit to ensure OPERABILITY of the DGs. This changes the CTS by deleting the Surveillance Requirement.

This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Each DG will continue to be tested in a manner to ensure the safety analyses assumption will be met. Changes to the auto-connected loads will be controlled and evaluated by the design change control process to ensure the DG is not overloaded. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L14 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.e requires verification that the DGs achieve the specified voltage and frequency within 10 seconds when started simultaneously at least once per 10 years or after any modifications which could affect DG interdependence. ITS 3.8.1 does not include the requirement to test simultaneous start of the DGs after any modifications which could affect DG interdependence. This changes the CTS by deleting the requirement to simultaneously start the DGs after any modifications which could affect DG interdependence.

This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analyses. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. Following repair, maintenance, modification, or replacement of a component that may affect OPERABILITY, post maintenance testing is required to demonstrate OPERABILITY of the system or component. This is described in the Bases of ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements of the DGs are described in the Bases for Specification 3.8.1. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria.

Compliance with 10 CFR 50 is required under the units operating license. As a result, post maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L15 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.g.1 requires verification of the generator capability to reject a load greater than or equal to the specified value while maintaining voltage within

+/- 10 percent of the initial pretest voltage and frequency at 60 +/- 1.2 Hz.

Additionally, CTS 4.8.1.1.2.g.1 requires that at no time shall the transient voltage exceed 8276 V. ITS SR 3.8.1.9 requires verification that following load rejection, frequency is 66.5 Hz, and within 3 seconds following load rejection voltage is Sequoyah Unit 1 and Unit 2 Page 20 of 24 Enclosure 2, Volume 13, Rev. 0, Page 41 of 638

Enclosure 2, Volume 13, Rev. 0, Page 42 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING 6800 V and 7260 V and frequency is 58.8 Hz and 61.2 Hz. This changes the CTS in that the maximum voltage limit for the first 3 seconds following load rejection is deleted and a higher frequency limit for the first 3 seconds following load rejection is added. Reduction of the steady state voltage range more than 3 seconds after the load rejection is described in DOC M05.

The purpose of CTS 4.8.1.1.2.g.1 is to ensure the proper operation of the DG governor and load control circuits. These changes are acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. These changes to the CTS allow the transient frequency and voltage to exceed the current limit for the first 3 seconds following load rejection, but provide a time limit for the stabilization of voltage and frequency. Consistent with Regulatory Guide 1.9, the load rejection test is acceptable if the diesel speed does not exceed 75% of the difference between nominal speed and the overspeed trip setpoint, or 15% above nominal speed, whichever is lower. This corresponds to 66.5 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint. The time to reach steady state voltage is also consistent with the recommendation of Regulatory Guide 1.9 for response during load sequence intervals. The 3 seconds specified is equal to approximately 60% of the 5 second load sequence interval associated with sequencing of the largest load.

This change is acceptable since it is consistent with the recommendations of Regulatory Guide 1.9. This change is designated as less restrictive, because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L16 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.g.2 requires verification that the DG does not trip and generator voltage does not exceed 8880 V during and after a load rejection of 4400 kW.

ITS SR 3.8.1.10 requires verification that the DG does not trip and voltage is maintained 8880 V during and following a load rejection of 3960 kW and 4400 kW. This changes the CTS by allowing the DGs to be tested at a lower load during the Surveillance.

The purpose of CTS 4.8.1.1.2.g.2 is to ensure the proper operation of the DG following a full load rejection test. This change allows the DGs to be tested at a lower load during the Surveillance. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The proposed minimum value is consistent with Regulatory Guide 1.9, Regulatory Position C.2.2.8, which recommends a load range of 90% to 100% for the full load rejection test. The proposed values are 90% to 100% of the continuous load rating and therefore are consistent with the recommendations of Regulatory Guide 1.9. The values will preclude routine overloading of the DG and the lower value will still ensure the DG is at operating temperatures and that the maximum loads assumed in the safety analyses can be supported. This change is designated as less restrictive, because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 21 of 24 Enclosure 2, Volume 13, Rev. 0, Page 42 of 638

Enclosure 2, Volume 13, Rev. 0, Page 43 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L17 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.g.3 requires verification that each DG can operate for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with loading at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating during the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, and at a load equivalent of the continuous duty rating during the remaining hours of the test. The CTS further requires that voltage and frequency be 6800 volts and 58.8 Hz within 10 seconds after the start signal, and steady state voltage and frequency shall be maintained 6800 V and 7260 V and 58.8 Hz and 61.2 Hz during this test. ITS SR 3.8.1.14 requires a similar test, however it specifies the initial loading at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, followed by loading at the continuous duty rating for the remaining hours of the test. This changes the CTS by providing a less specific duration for the initial loading of the DG at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating and removes the voltage and frequency limits from the Surveillance.

The purpose of CTS 4.8.1.1.2.g.3 is to verify the capability of each DG to start and run continuously at full load for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Operation of the DG loaded at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating for greater than or equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will continue to avoid DG overloading that could lead to more frequent teardown inspections of the DG. DG operation with voltage and frequency within the specified limits will continue to be verified during performance of ITS SR 3.8.1.2, SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.15, SR 3.8.1.18 and SR 3.8.1.19. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.

The Surveillance will continue to verify that the DG is capable of running continuously at full load for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating, consistent with Regulatory Guide 1.108, Regulatory Position C.2.a.(3). This change is designated as less restrictive, because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L18 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.g.4 requires verification that each DG can be started within 10 seconds following loading within a specified range and continue to operate for at least 5 minutes. ITS SR 3.8.1.15 requires a similar test, but does not require the DG continue to operate for at least 5 minutes following the hot restart. This changes the CTS by removing the requirement that the DG operate for at least 5 minutes following a hot restart test.

The purpose of CTS 4.8.1.1.2.g.4 is to verify the capability of each DG to restart following operation where the DG has achieved hot conditions. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The Surveillance will continue to verify that the DG is capable of restarting and achieving voltage and frequency within acceptable limits and time, consistent with Regulatory Guide 1.108, Regulatory Position C.2.a.(5). This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 22 of 24 Enclosure 2, Volume 13, Rev. 0, Page 43 of 638

Enclosure 2, Volume 13, Rev. 0, Page 44 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L19 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.g.4 requires demonstration of a DG hot restart and verification following energization that steady state voltage and frequency are maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. ITS SR 3.8.1.15 requires demonstration of a DG hot restart and requires verification that within 10 seconds, voltage 6800 V and frequency 58.8 Hz, and steady state voltage 6800 V and 7260 V and frequency 58.8 Hz and 61.2 Hz.

This changes the CTS by specifying a minimum voltage and frequency limit to be achieved within 10 seconds instead of a voltage and frequency range.

The purpose of CTS 4.8.1.1.2.g.4 is to test the ability of each DG to restart on an accident signal under hot conditions and achieve the appropriate voltage and frequency. This changes the CTS by specifying a minimum voltage and frequency limit to be achieved within 10 seconds instead of a voltage and frequency range. This effectively allows the upper voltage and frequency limits to be exceeded during DG acceleration and stabilization. As stated above, the proposed Surveillance will require the establishment of the minimum frequency (58.8 Hz) and voltage (6800 V) within the given time frame. The accident analyses require that the DGs be capable of being loaded within 10 seconds.

This can be accomplished at 58.8 Hz and 6800 V. While the upper level requirement regarding the frequency and voltage acceptance criterion is being eliminated, the requirement to establish a steady state voltage and frequency has been retained. Verification that the minimum voltage and frequency limits are met within the proper time is sufficient to ensure the DG can perform its design function. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L20 (Category 3 - Relaxation of Completion Time) CTS 3.0.5 allows a system, subsystem, train, component, or device to be considered OPERABLE with an inoperable emergency or normal power source provided its corresponding normal or emergency power source is OPERABLE and its redundant system(s),

subsystem(s), train(s), component(s), and device(s) are OPERABLE. CTS 3.0.5 requires a unit shut down to start within two hours with these requirements not met. CTS 3.0.5 also provides an explicit time period to be in HOT STANDBY (MODE 3), HOT SHUTDOWN (MODE 4), and COLD SHUTDOWN (MODE 5).

ITS 3.8.1 ACTION A (one associated unit offsite source inoperable) requires the declaration of required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action A.2 is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION B (one associated unit DG or both DGs in a train inoperable) requires the declaration of required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable. The Completion Time allowed by the Required Action B.2 is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION E (two offsite circuits inoperable) requires the declaration of required feature(s) inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action E.1 is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of Condition E concurrent with inoperability of redundant required features. This changes the CTS by allowing more time to restore inoperable equipment and Sequoyah Unit 1 and Unit 2 Page 23 of 24 Enclosure 2, Volume 13, Rev. 0, Page 44 of 638

Enclosure 2, Volume 13, Rev. 0, Page 45 of 638 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING replaces the explicit times to be in MODE 3, MODE 4, and MODE 5 with a requirement to declare the affected features inoperable (and thus to take the ACTIONS required by the individual system LCO, including possible shut down of the unit).

This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This change allows more time to restore inoperable equipment when required AC Sources are inoperable concurrent with inoperabilities of redundant required features and deletes the explicit times to be in MODE 3, MODE 4, and MODE 5.

By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specifications ACTIONS of the affected supported equipment, unit operation is maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC Sources support the OPERABILITY of the affected equipment, it is appropriate that the proper action, in this condition, would be to declare that affected supported equipment inoperable. CTS 3.0.5 is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is sometimes provided, in other CTS sections. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time when one associated unit offsite circuit is inoperable is acceptable because: a) the redundant counterpart to the inoperable required feature is still OPERABLE although single failure protection may have been lost; b) the capacity and capability of the remaining AC Sources is still available; c) a reasonable time for repairs is provided for restoration before the unit is subjected to transients associated with shut down; and d) the low probability of a DBA occurring during this period. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time when two offsite circuits are inoperable is acceptable because Regulatory Guide 1.93 allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two offsite circuits inoperable. When a concurrent redundant required function is inoperable, a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time with one associated unit DG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shut down.

Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC Sources, reasonable time for repairs, and low probability of a DBA occurring during this period. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status and the change deletes the explicit times to reach MODE 3, MODE 4, and MODE 5.

Sequoyah Unit 1 and Unit 2 Page 24 of 24 Enclosure 2, Volume 13, Rev. 0, Page 45 of 638

Enclosure 2, Volume 13, Rev. 0, Page 46 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 46 of 638

Enclosure 2, Volume 13, Rev. 0, Page 47 of 638 CTS AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8.1.1 LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

3.8.1.1.a a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System, 1 2 Four

and 3.8.1.1.b b. Two diesel generators (DGs) capable of supplying the onsite 1 Class 1E power distribution subsystem(s), and 2 1 AC Electrical .

[ c. Automatic load sequencers for Train A and Train B. ] 3 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS


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

ACTION f LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ACTION c 4 circuit inoperable. [required] OPERABLE 5 for reasons other offsite circuit. AND than Condition C Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND DOC L20 A.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to one train 5 its redundant required concurrent with 6.9 kV Shutdown feature(s) is inoperable. inoperability of Board 1A-A or 1B-B redundant required feature(s)

AND SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 47 of 638

Enclosure 2, Volume 13, Rev. 0, Page 48 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A.3 Restore [required] offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 4 circuit to OPERABLE status.

ACTIONS B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> b, c, and e 4 inoperable. 1A-A

[required] offsite circuit(s).

AND INSERT 1 Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 5 AND DOC L20 B.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the inoperable discovery of DG inoperable when its Condition B required redundant concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND 4

ACTION b B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due 1 are to common cause failure.

OR ACTION b B.3.2 Perform SR 3.8.1.2 for [24] hours 4 ACTION c OPERABLE DG(s). 1 AND (s) 7 days ACTION b B.4 Restore [required] DG to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 4 1 OPERABLE status.

5 INSERT 2 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 48 of 638

Enclosure 2, Volume 13, Rev. 0, Page 49 of 638 5

INSERT 1 DOC L01 OR DG 1B-B inoperable.

OR DGs 1A-A and 2A-A inoperable.

OR DGs 1B-B and 2B-B inoperable.

5 INSERT 2 DOC L01 C. One offsite circuit C.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable solely due to OPERABLE offsite circuit.

an offsite power source AND to 6.9 kV Shutdown Board 2A-A or 2B-B Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. AND thereafter C.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to 6.9 kV its redundant required Shutdown Board feature(s) is inoperable. 2A-A or 2B-B concurrent with inoperability of redundant required feature(s)

AND C.3 Declare associated 7 days required feature(s) inoperable.

Insert Page 3.8.1-2a Enclosure 2, Volume 13, Rev. 0, Page 49 of 638

Enclosure 2, Volume 13, Rev. 0, Page 50 of 638 5

INSERT 2 (Continued)

D. DG 2A-A or 2B-B D.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. OPERABLE offsite circuit(s). AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND D.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the inoperable discovery of DG inoperable when its Condition D redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND D.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DGs are not inoperable due to common cause failure.

OR D.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DGs.

AND D.4 Declare associated 7 days required feature(s) inoperable.

Insert Page 3.8.1-2b Enclosure 2, Volume 13, Rev. 0, Page 50 of 638

Enclosure 2, Volume 13, Rev. 0, Page 51 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION d C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from 5 DOC L20 E circuits inoperable. E inoperable when its discovery of redundant required Condition C E feature(s) is inoperable. concurrent with inoperability of redundant required features AND 5 4 ACTION d C.2 Restore one [required] 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> E

offsite circuit to OPERABLE status.

ACTION c D. One [required] offsite --------------------NOTE-------------------

DOC A03 F circuit inoperable. Enter applicable Conditions and for reasons other Required Actions of LCO 3.8.9, AND than Condition C "Distribution Systems - Operating," F 5 when Condition D is entered with no One [required] DG AC power source to any train. 6.9 kV Shutdown Board 1A-A or 1B-B ACTION c inoperable. ------------------------------------------------

1A-A or 1B-B 4

D.1 Restore [required] offsite 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F

circuit to OPERABLE ACTION c status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 5 4 F

OPERABLE status.

INSERT 3 One or more Train A (s) train of s ACTION e E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 5 J inoperable. J to OPERABLE status.

5 INSERT 4 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 51 of 638

Enclosure 2, Volume 13, Rev. 0, Page 52 of 638 5

INSERT 3 DOC L01 G. One offsite circuit G.1 Declare required feature(s) 7 days inoperable solely due to on associated Unit 2 6.9 kV an offsite power source Shutdown Board to 6.9 kV Shutdown inoperable.

Board 2A-A or 2B-B inoperable.

AND DG 1A-A or 1B-B inoperable.

DOC L01 H. One offsite circuit H.1 Declare required feature(s) 7 days inoperable for reasons on associated Unit 2 6.9 kV other than Condition C. Shutdown Board inoperable.

AND DG 2A-A or 2B-B inoperable.

Insert Page 3.8.1-3a Enclosure 2, Volume 13, Rev. 0, Page 52 of 638

Enclosure 2, Volume 13, Rev. 0, Page 53 of 638 5

INSERT 3 (continued)

DOC L01 I. One offsite circuit --------------------NOTE-------------------

inoperable solely due to Enter applicable Conditions and an offsite power source Required Actions of LCO 3.8.9, to 6.9 kV Shutdown "Distribution Systems - Operating,"

Board 2A-A or 2B-B when Condition I is entered with no inoperable. AC power source to 6.9 kV Shutdown Board 2A-A or 2B-B.

AND ------------------------------------------------

DG 2A-A or 2B-B I.1 Restore offsite circuit to 7 days inoperable. OPERABLE status.

OR I.2 Restore DG to OPERABLE status. 7 days 5

INSERT 4 ACTION e AND One or more Train B DG(s) inoperable.

Insert Page 3.8.1-3b Enclosure 2, Volume 13, Rev. 0, Page 53 of 638

Enclosure 2, Volume 13, Rev. 0, Page 54 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME


REVIEWERS NOTE----- F.1 Restore [required] [12] hours ] 3 This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status.

such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.

F. [ One [required]

[automatic load sequencer] inoperable.

ACTIONS G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> a, b, c, d, e K associated Completion K Time of Condition A, B, AND 3 5 C, D, E, or [F] not met.

F, I, J G.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> K

INSERT 5 H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately 5 AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1 4.8.1.1.1.a SR 3.8.1.1 Verify correct breaker alignment and indicated [ 7 days power availability for each [required] offsite circuit. 4 6 OR In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 54 of 638

Enclosure 2, Volume 13, Rev. 0, Page 55 of 638 5

INSERT 5 DOC A04 L. Two offsite circuits L.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

DOC A04 M. One offsite circuit M.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

Insert Page 3.8.1-4 Enclosure 2, Volume 13, Rev. 0, Page 55 of 638

Enclosure 2, Volume 13, Rev. 0, Page 56 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.a.4 SR 3.8.1.2 ------------------------------NOTES-----------------------------

DOC A05 1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

4.8.1.1.2.a.4 [ 2. A modified DG start involving idling and gradual 4 Note

  • 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. ] 4 4.8.1.1.2.a.4 Verify each DG starts from standby conditions and [ 31 days achieves steady state voltage [3740] V and 6 7260

[4580] V, and frequency [58.8] Hz and 6800 OR 4

[61.2] Hz.

In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 56 of 638

Enclosure 2, Volume 13, Rev. 0, Page 57 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.a.5 SR 3.8.1.3 ------------------------------NOTES-----------------------------

4.8.1.1.2.a.5 1. DG loadings may include gradual loading as Note

  • recommended by the manufacturer.

DOC L09 2. Momentary transients outside the load range do not invalidate this test.

ACTION b, Note

  • 3. This Surveillance shall be conducted on only one DG at a time.

DOC M02 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

4.8.1.1.2.a.5 Verify each DG is synchronized and loaded and [ 31 days operates for 60 minutes at a load [4500] kW and 6

[5000] kW. 3960 OR 4 4400 In accordance with the Surveillance Frequency Control Program ] 6 engine-mounted day 3.8.1.1.b.2 SR 3.8.1.4 Verify each day tank [and engine mounted tank] [ 31 days 1 4 6 4.8.1.1.2.a.1 contains [220] gal of fuel oil.

250 OR In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 57 of 638

Enclosure 2, Volume 13, Rev. 0, Page 58 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.b SR 3.8.1.5 Check for and remove accumulated water from each [ [31] days day tank [and engine mounted tank]. 1 4 6 engine-mounted day OR In accordance with the Surveillance Frequency Control Program ] 6 the 3.8.1.1.b.4, 4.8.1.1.2.a.3 SR 3.8.1.6 Verify the fuel oil transfer system operates to [ [92] days

[automatically] transfer fuel oil from storage tank[s] 6 to the day tank [and engine mounted tank]. OR s 4 1 system engine-mounted day In accordance with the Surveillance Frequency 6

Control Program ]

4.8.1.1.2.a.4 SR 3.8.1.7 ------------------------------NOTE-------------------------------

DOC A05 All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and [ 184 days achieves: 6 6800 OR

a. In [10] seconds, voltage [3740] V and frequency 58.8] Hz and In accordance 4 6800 7260 with the
b. Steady state voltage [3740] V and [4580] V, Surveillance and frequency [58.8] Hz and [61.2] Hz. Frequency 6

Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 58 of 638

Enclosure 2, Volume 13, Rev. 0, Page 59 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

1. For the 1A, 1B, 1C, and 1D Unit Boards, this 5

4.8.1.1.1.b SR 3.8.1.8 ------------------------------NOTE-------------------------------

[ This Surveillance shall not normally be performed 4 DOC L06 in MODE 1 or 2. 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.

INSERT 6 the 4.8.1.1.1.b Verify [automatic [and] manual] transfer of AC power [ [18] months 6 Note ##

sources from the normal offsite circuit to each 1 alternate [required] offsite circuit. OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply In accordance with the Surveillance Frequency Control Program ] ] 6 4 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 59 of 638

Enclosure 2, Volume 13, Rev. 0, Page 60 of 638 1

INSERT 6

2. Transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and alternate power supplies.

Insert Page 3.8.1-8 Enclosure 2, Volume 13, Rev. 0, Page 60 of 638

Enclosure 2, Volume 13, Rev. 0, Page 61 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1 SR 3.8.1.9 ------------------------------NOTES----------------------------- 5 DOC M04 [1. This Surveillance shall not normally be 4 performed in MODE 1 or 2. 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.

DOC M04 2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 4 4.8.1.1.2.g.1 Verify each DG rejects a load greater than or equal [ [18] months to its associated single largest post-accident load, 6 and: OR DOC L15 a. Following load rejection, the frequency is In accordance

[63] Hz, with the 4 66.5 Surveillance 4.8.1.1.2.g.1 b. Within [3] seconds following load rejection, the Frequency voltage is [3740] V and [4580] V, and Control Program ] 4 6 6800 7260 4.8.1.1.2.g.1 c. Within [3] seconds following load rejection, the frequency is [58.8] Hz and [61.2] Hz. 4 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 61 of 638

Enclosure 2, Volume 13, Rev. 0, Page 62 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2 SR 3.8.1.10 ------------------------------NOTES----------------------------- 5 DOC M04 [ 1. This Surveillance shall not normally be 4 performed in MODE 1 or 2. 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.

DOC M04 2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 4 4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is [ [18] months maintained [5000] V during and following a load 6 rejection of [4500] kW and [5000] kW. OR 4 3960 4400 In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 62 of 638

Enclosure 2, Volume 13, Rev. 0, Page 63 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d, 4.8.1.1.2.d.4 SR 3.8.1.11 ------------------------------NOTES-----------------------------

DOC A05 1. All DG starts may be preceded by an engine prelube period.

For DGs 1A-A and 1B-B, this 5

DOC L11 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 [ [18] months signal: 6 shutdown boards OR 4.8.1.1.2.d.4.a) a. De-energization of emergency buses, 1 shutdown boards In accordance 4.8.1.1.2.d.4.a) b. Load shedding from emergency buses, with the Surveillance 4.8.1.1.2.d.4.b) c. DG auto-starts from standby condition and: Frequency Control Program ] 6

1. Energizes permanently connected loads 4

in [10] seconds,

2. Energizes auto-connected shutdown loads through [automatic load sequencer], 3 load sequence timers
3. Maintains steady state voltage

[3740] V and [4580] V, 6800 7260

4. Maintains steady state frequency

[58.8] Hz and [61.2] Hz, and 4

5. Supplies permanently connected [and auto-connected] shutdown loads for 5 minutes.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-11 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 63 of 638

Enclosure 2, Volume 13, Rev. 0, Page 64 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d, 4.8.1.1.2.d.5 SR 3.8.1.12 ------------------------------NOTES-----------------------------

DOC A05 [ 1. All DG starts may be preceded by prelube 4 period.

For DGs 1A-A and 1B-B, this DOC L11 2. This Surveillance shall not normally be 5 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.

4.8.1.1.2.d.5 Verify on an actual or simulated Engineered Safety [ [18] months Feature (ESF) actuation signal each DG auto-starts 6 from standby condition and: OR

a. In [10] seconds after auto-start and during In accordance tests, achieves voltage [3740] V and with the frequency [58.8] Hz, 6800 Surveillance 4

Frequency 7260 b. Achieves steady state voltage [3740] V and Control Program ] 6

[4580] V and frequency [58.8] Hz and

[61.2] Hz,

c. Operates for 5 minutes, DOC M03 d. Permanently connected loads remain energized from the offsite power system, and DOC M03 e. Emergency loads are energized [or auto- 3 connected through the automatic load sequencer] from the offsite power system.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-12 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 64 of 638

Enclosure 2, Volume 13, Rev. 0, Page 65 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 1A-A and 1B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c) SR 3.8.1.13 ------------------------------NOTE-------------------------------

DOC L11 [ This Surveillance shall not normally be performed 4 5 in MODE 1 or 2. 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. ] 4 4.8.1.1.2.d.6.c) Verify each DG's noncritical automatic trips are [ [18] months 6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an OR 4 actual or simulated ESF actuation signal].

, or both In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-13 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 65 of 638

Enclosure 2, Volume 13, Rev. 0, Page 66 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.g 4.8.1.1.2.g.3 SR 3.8.1.14 ------------------------------NOTES-----------------------------

DOC L09 1. Momentary transients outside the load and power factor ranges do not invalidate this test.

For DGs 1A-A and 1B-B, this 5

DOC M04 2. This Surveillance shall not normally be performed in MODE 1 or 2. 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.

DOC M04 3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

4.8.1.1.2.g.3 Verify each DG 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 6

a. For [2] hours loaded [5250] kW and OR

[5500] kW and 4620 4840 2380 kvar and 2600 kvar, and In accordance

b. For the remaining hours of the test loaded with the 4 1

[4500] kW and [5000] kW. Surveillance 3960 4400 Frequency and 2140 kvar and 2370 kvar Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-14 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 66 of 638

Enclosure 2, Volume 13, Rev. 0, Page 67 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.g 4.8.1.1.2.g.4 SR 3.8.1.15 ------------------------------NOTES-----------------------------

DOC A05 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated [2] hours loaded [4500] kW and [5000] kW. 3960 4 4400 and 2140 kvar and 2370 kvar DOC L09 Momentary transients outside of load range do not invalidate this test.

DOC A05 2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves: [ [18] months 6800 6

DOC L19 a. In [10] seconds, voltage [3740] V and OR frequency [58.8] Hz and 4 6800 7260 In accordance 4.8.1.1.2.g.4 b. Steady state voltage [3740] V, and [4580] V with the and frequency [58.8] Hz and [61.2] Hz. Surveillance Frequency Control Program ] 6 4.8.1.1.2.d For DGs 1A-A and 1B-B, this 4.8.1.1.2.d.9 SR 3.8.1.16 ------------------------------NOTE-------------------------------

DOC L11 This Surveillance shall not normally be performed in 5 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: [ [18] months 6

4.8.1.1.2.d.9.a a. Synchronizes with offsite power source while OR loaded with emergency loads upon a simulated restoration of offsite power, In accordance with the 4.8.1.1.2.d.9.b b. Transfers loads to offsite power source, and Surveillance Frequency 4.8.1.1.2.d.9.c c. Returns to ready-to-load operation. Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-15 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 67 of 638

Enclosure 2, Volume 13, Rev. 0, Page 68 of 638 CTS AC Sources - Operating 3.8.1 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, 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.

7 Verify, with a DG operating in test mode and [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by: OR

a. Returning DG to ready-to-load operation and In accordance with the
b. [Automatically energizing the emergency load Surveillance from offsite power]. Frequency Control Program ]

For DGs 1A-A and 1B-B, this 4.8.1.1.2.d 4.8.1.1.2.d.10 SR 3.8.1.18 ------------------------------NOTE------------------------------- 7 4.8.1.1.2.d.10 17

[ This Surveillance shall not normally be performed 4 5 Note #

in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4

taken for unplanned events that satisfy this SR. ]

setpoint for load Verify interval between each sequenced load block [ [18] months is within +/- [10% of design interval] for each timer 3 6 5% of design emergency [and shutdown] load sequencer. OR In accordance with the Surveillance Frequency 6

Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-16 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 68 of 638

Enclosure 2, Volume 13, Rev. 0, Page 69 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d 4.8.1.1.2.d.6 SR 3.8.1.19 ------------------------------NOTES----------------------------- 7 DOC A05 18 1. All DG starts may be preceded by an engine prelube period.

For DGs 1A-A and 1B-B, this DOC L11 2. This Surveillance shall not normally be 5 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.

4.8.1.1.2.d.6 Verify on an actual or simulated loss of offsite power [ [18] months signal in conjunction with an actual or simulated 6 ESF actuation signal: OR 4.8.1.1.2.d.6.a shutdown boards

a. De-energization of emergency buses, In accordance 1 4.8.1.1.2.d.6.a shutdown boards with the
b. Load shedding from emergency buses, and Surveillance 4.8.1.1.2.d.6.b Frequency
c. DG auto-starts from standby condition and: Control Program ] 6
1. Energizes permanently connected loads in

[10] seconds, 4

2. Energizes auto-connected emergency 3

loads through load sequencer, load sequence timers

3. Achieves steady state voltage [3740] V and [4580] V, 6800 7260 4
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.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-17 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 69 of 638

Enclosure 2, Volume 13, Rev. 0, Page 70 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.e SR 3.8.1.20 ------------------------------NOTE------------------------------- 7 DOC A05 19 All DG starts may be preceded by an engine prelube period.

4.8.1.1.2.e Verify when started simultaneously from standby [ 10 years condition, each DG achieves: , 6 OR

a. In [10] seconds, voltage [3740] V and 4 frequency [58.8] Hz and . 6800 In accordance with the
b. Steady state voltage [3744] V and [4576] V, Surveillance 8 and frequency [58.8] Hz and [61.2] Hz. Frequency Control Program ] 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.1-18 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 70 of 638

Enclosure 2, Volume 13, Rev. 0, Page 71 of 638 CTS AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8.1.1 LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

3.8.1.1.a a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System, 1 2 Four

and 3.8.1.1.b b. Two diesel generators (DGs) capable of supplying the onsite 1 Class 1E power distribution subsystem(s), and 2 1 AC Electrical .

3

[ c. Automatic load sequencers for Train A and Train B. ]

DOC L01 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS


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

ACTION f LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ACTION c 4 circuit inoperable. [required] OPERABLE 5 for reasons other offsite circuit. AND than Condition C Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND DOC L20 A.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to one train 5 its redundant required concurrent with 6.9 kV Shutdown feature(s) is inoperable. inoperability of Board 2A-A or 2B-B redundant required feature(s)

AND SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 71 of 638

Enclosure 2, Volume 13, Rev. 0, Page 72 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 4

ACTION a A.3 Restore [required] offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuit to OPERABLE status.

ACTIONS B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> b, c, and e 4 inoperable. 2A-A

[required] offsite circuit(s).

AND INSERT 1 Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 5 AND DOC L20 B.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the inoperable discovery of DG inoperable when its Condition B required redundant concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND 4

ACTION b B.3.1 Determine OPERABLE [24] hours are DG(s) is not inoperable due 1 to common cause failure.

OR ACTION b B.3.2 Perform SR 3.8.1.2 for [24] hours 4 ACTION c OPERABLE DG(s). 1 AND (s) 7 days 4 1 ACTION b B.4 Restore [required] DG to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

5 INSERT 2 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 72 of 638

Enclosure 2, Volume 13, Rev. 0, Page 73 of 638 5

INSERT 1 DOC L01 OR DG 2B-B inoperable.

OR DGs 1A-A and 2A-A inoperable.

OR DGs 1B-B and 2B-B inoperable.

5 INSERT 2 DOC L01 C. One offsite circuit C.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable solely due to OPERABLE offsite circuit.

an offsite power source AND to 6.9 kV Shutdown Board 1A-A or 1B-B Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. AND thereafter C.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to 6.9 kV its redundant required Shutdown Board feature(s) is inoperable. 1A-A or 1B-B concurrent with inoperability of redundant required feature(s)

AND C.3 Declare associated 7 days required feature(s) inoperable.

Insert Page 3.8.1-2a Enclosure 2, Volume 13, Rev. 0, Page 73 of 638

Enclosure 2, Volume 13, Rev. 0, Page 74 of 638 5

INSERT 2 (Continued)

D. DG 1A-A or 1B-B D.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. OPERABLE offsite circuit(s). AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND D.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the inoperable discovery of DG inoperable when its Condition D redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND D.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DGs are not inoperable due to common cause failure.

OR D.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DGs.

AND D.4 Declare associated 7 days required feature(s) inoperable.

Insert Page 3.8.1-2b Enclosure 2, Volume 13, Rev. 0, Page 74 of 638

Enclosure 2, Volume 13, Rev. 0, Page 75 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION d C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from 5 DOC L20 E circuits inoperable. E inoperable when its discovery of redundant required Condition C E feature(s) is inoperable. concurrent with inoperability of redundant required features AND 5 4 ACTION d C.2 Restore one [required] 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> E

offsite circuit to OPERABLE status.

ACTION c D. One [required] offsite --------------------NOTE-------------------

DOC A03 F circuit inoperable. Enter applicable Conditions and for reasons other Required Actions of LCO 3.8.9, AND than Condition C "Distribution Systems - Operating," F 5 when Condition D is entered with no One [required] DG AC power source to any train. 6.9 kV Shutdown Board 2A-A or 2B-B inoperable. ------------------------------------------------

2A-A or 2B-B 4

ACTION c D.1 Restore [required] offsite 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F

circuit to OPERABLE status.

OR ACTION c D.2 Restore [required] DG to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 5 4 F

OPERABLE status.

INSERT 3 One or more Train A (s) train of s 5

ACTION e E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> J inoperable. J to OPERABLE status.

5 INSERT 4 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 75 of 638

Enclosure 2, Volume 13, Rev. 0, Page 76 of 638 5

INSERT 3 DOC L01 G. One offsite circuit G.1 Declare required feature(s) 7 days inoperable solely due to on associated Unit 1 6.9 kV an offsite power source Shutdown Board to 6.9 kV Shutdown inoperable.

Board 1A-A or 1B-B inoperable.

AND DG 2A-A or 2B-B inoperable.

DOC L01 H. One offsite circuit H.1 Declare required feature(s) 7 days inoperable for reasons on associated Unit 1 6.9 kV other than Condition C. Shutdown Board inoperable.

AND DG 1A-A or 1B-B inoperable.

Insert Page 3.8.1-3a Enclosure 2, Volume 13, Rev. 0, Page 76 of 638

Enclosure 2, Volume 13, Rev. 0, Page 77 of 638 5

INSERT 3 (continued)

DOC L01 I. One offsite circuit --------------------NOTE-------------------

inoperable solely due to Enter applicable Conditions and an offsite power source Required Actions of LCO 3.8.9, to 6.9 kV Shutdown "Distribution Systems - Operating,"

Board 1A-A or 1B-B when Condition I is entered with no inoperable. AC power source to 6.9 kV Shutdown Board 1A-A or 1B-B.

AND ------------------------------------------------

DG 1A-A or 1B-B I.1 Restore offsite circuit to 7 days inoperable. OPERABLE status.

OR I.2 Restore DG to OPERABLE status. 7 days 5

INSERT 4 ACTION e AND One or more Train B DG(s) inoperable.

Insert Page 3.8.1-3b Enclosure 2, Volume 13, Rev. 0, Page 77 of 638

Enclosure 2, Volume 13, Rev. 0, Page 78 of 638 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME


REVIEWERS NOTE----- F.1 Restore [required] [12] hours ] 3 This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status.

such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.

F. [ One [required]

[automatic load sequencer] inoperable.

ACTIONS G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> a, b, c, d, e K associated Completion K Time of Condition A, B, AND 3 5 C, D, E, or [F] not met.

F, I, J G.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> K

INSERT 5 H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately 5 AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1 4.8.1.1.1.a SR 3.8.1.1 Verify correct breaker alignment and indicated [ 7 days power availability for each [required] offsite circuit. 4 6 OR In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 78 of 638

Enclosure 2, Volume 13, Rev. 0, Page 79 of 638 5

INSERT 5 DOC A04 L. Two offsite circuits L.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

DOC A04 M. One offsite circuit M.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

Insert Page 3.8.1-4 Enclosure 2, Volume 13, Rev. 0, Page 79 of 638

Enclosure 2, Volume 13, Rev. 0, Page 80 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.a.4 SR 3.8.1.2 ------------------------------NOTES-----------------------------

DOC A05 1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

4.8.1.1.2.a.4 [ 2. A modified DG start involving idling and gradual 4 Note

  • 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. ] 4 4.8.1.1.2.a.4 Verify each DG starts from standby conditions and [ 31 days achieves steady state voltage [3740] V and 6 7260

[4580] V, and frequency [58.8] Hz and 6800 OR 4

[61.2] Hz.

In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 80 of 638

Enclosure 2, Volume 13, Rev. 0, Page 81 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.a.5 SR 3.8.1.3 ------------------------------NOTES-----------------------------

4.8.1.1.2.a.5 1. DG loadings may include gradual loading as Note

  • recommended by the manufacturer.

DOC L09 2. Momentary transients outside the load range do not invalidate this test.

ACTION b, Note

  • 3. This Surveillance shall be conducted on only one DG at a time.

DOC M02 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

4.8.1.1.2.a.5 Verify each DG is synchronized and loaded and [ 31 days operates for 60 minutes at a load [4500] kW and 6

[5000] kW. 3960 OR 4 4400 In accordance with the Surveillance Frequency Control Program ] 6 engine-mounted day 3.8.1.1.b.2 SR 3.8.1.4 Verify each day tank [and engine mounted tank] [ 31 days 1 4 6 4.8.1.1.2.a.1 contains [220] gal of fuel oil.

250 OR In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 81 of 638

Enclosure 2, Volume 13, Rev. 0, Page 82 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.b SR 3.8.1.5 Check for and remove accumulated water from each [ [31] days day tank [and engine mounted tank]. 1 4 6 engine-mounted day OR In accordance with the Surveillance Frequency Control Program ] 6 the 3.8.1.1.b.4, 4.8.1.1.2.a.3 SR 3.8.1.6 Verify the fuel oil transfer system operates to [ [92] days

[automatically] transfer fuel oil from storage tank[s] 6 to the day tank [and engine mounted tank]. OR s 4 1 system engine-mounted day In accordance with the Surveillance Frequency 6

Control Program ]

4.8.1.1.2.a.4 SR 3.8.1.7 ------------------------------NOTE-------------------------------

DOC A05 All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and [ 184 days achieves: 6 6800 OR

a. In [10] seconds, voltage [3740] V and frequency 58.8] Hz and In accordance 4 6800 7260 with the
b. Steady state voltage [3740] V and [4580] V, Surveillance and frequency [58.8] Hz and [61.2] Hz. Frequency 6

Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 82 of 638

Enclosure 2, Volume 13, Rev. 0, Page 83 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

1. For the 2A, 2B, 2C, and 2D Unit Boards, this 5

4.8.1.1.1.b SR 3.8.1.8 ------------------------------NOTE-------------------------------

[ This Surveillance shall not normally be performed 4 DOC L06 in MODE 1 or 2. 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.

INSERT 6 the 4.8.1.1.1.b Verify [automatic [and] manual] transfer of AC power [ [18] months 6 Note ##

sources from the normal offsite circuit to each 1 alternate [required] offsite circuit. OR supply to each 6.9 kV Unit Board from the normal supply to the alternate supply In accordance with the Surveillance Frequency Control Program ] ] 6 4 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 83 of 638

Enclosure 2, Volume 13, Rev. 0, Page 84 of 638 1

INSERT 6

2. Transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and alternate power supplies.

Insert Page 3.8.1-8 Enclosure 2, Volume 13, Rev. 0, Page 84 of 638

Enclosure 2, Volume 13, Rev. 0, Page 85 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.1 SR 3.8.1.9 ------------------------------NOTES----------------------------- 5 DOC M04 [1. This Surveillance shall not normally be 4 performed in MODE 1 or 2. 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.

DOC M04 2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 4 4.8.1.1.2.g.1 Verify each DG rejects a load greater than or equal [ [18] months to its associated single largest post-accident load, 6 and: OR DOC L15 a. Following load rejection, the frequency is In accordance

[63] Hz, with the 4 66.5 Surveillance 4.8.1.1.2.g.1 b. Within [3] seconds following load rejection, the Frequency voltage is [3740] V and [4580] V, and Control Program ] 4 6 6800 7260 4.8.1.1.2.g.1 c. Within [3] seconds following load rejection, the 4

frequency is [58.8] Hz and [61.2] Hz.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 85 of 638

Enclosure 2, Volume 13, Rev. 0, Page 86 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.g, 4.8.1.1.2.g.2 SR 3.8.1.10 ------------------------------NOTES----------------------------- 5 DOC M04 [ 1. This Surveillance shall not normally be 4 performed in MODE 1 or 2. 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.

DOC M04 2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 4 4.8.1.1.2.g.2 8880 Verify each DG does not trip and voltage is [ [18] months maintained [5000] V during and following a load 6 rejection of [4500] kW and [5000] kW. OR 4 3960 4400 In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 86 of 638

Enclosure 2, Volume 13, Rev. 0, Page 87 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d, 4.8.1.1.2.d.4 SR 3.8.1.11 ------------------------------NOTES-----------------------------

DOC A05 1. All DG starts may be preceded by an engine prelube period.

For DGs 2A-A and 2B-B, this 5

DOC L11 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 [ [18] months signal: 6 shutdown boards OR 4.8.1.1.2.d.4.a) a. De-energization of emergency buses, 1 shutdown boards In accordance 4.8.1.1.2.d.4.a) b. Load shedding from emergency buses, with the Surveillance 4.8.1.1.2.d.4.b) c. DG auto-starts from standby condition and: Frequency Control Program ] 6

1. Energizes permanently connected loads 4

in [10] seconds,

2. Energizes auto-connected shutdown loads through [automatic load sequencer], 3 load sequence timers
3. Maintains steady state voltage

[3740] V and [4580] V, 6800 7260

4. Maintains steady state frequency

[58.8] Hz and [61.2] Hz, and 4

5. Supplies permanently connected [and auto-connected] shutdown loads for 5 minutes.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-11 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 87 of 638

Enclosure 2, Volume 13, Rev. 0, Page 88 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d, 4.8.1.1.2.d.5 SR 3.8.1.12 ------------------------------NOTES-----------------------------

DOC A05 [ 1. All DG starts may be preceded by prelube 4 period.

For DGs 2A-A and 2B-B, this DOC L11 2. This Surveillance shall not normally be 5 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.

4.8.1.1.2.d.5 Verify on an actual or simulated Engineered Safety [ [18] months Feature (ESF) actuation signal each DG auto-starts 6 from standby condition and: OR

a. In [10] seconds after auto-start and during In accordance tests, achieves voltage [3740] V and with the frequency [58.8] Hz, 6800 Surveillance 4

Frequency 7260 b. Achieves steady state voltage [3740] V and Control Program ] 6

[4580] V and frequency [58.8] Hz and

[61.2] Hz,

c. Operates for 5 minutes, DOC M03 d. Permanently connected loads remain energized from the offsite power system, and DOC M03 e. Emergency loads are energized [or auto- 3 connected through the automatic load sequencer] from the offsite power system.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-12 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 88 of 638

Enclosure 2, Volume 13, Rev. 0, Page 89 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For DGs 2A-A and 2B-B, this 4.8.1.1.2.d, 4.8.1.1.2.d.6.c) SR 3.8.1.13 ------------------------------NOTE-------------------------------

DOC L11 [ This Surveillance shall not normally be performed 4 5 in MODE 1 or 2. 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. ] 4 4.8.1.1.2.d.6.c) Verify each DG's noncritical automatic trips are [ [18] months 6 bypassed on [actual or simulated loss of voltage shutdown board, signal on the emergency bus concurrent with an OR 4 actual or simulated ESF actuation signal].

, or both In accordance with the Surveillance Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-13 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 89 of 638

Enclosure 2, Volume 13, Rev. 0, Page 90 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.g 4.8.1.1.2.g.3 SR 3.8.1.14 ------------------------------NOTES-----------------------------

DOC L09 1. Momentary transients outside the load and power factor ranges do not invalidate this test.

For DGs 2A-A and 2B-B, this 5

DOC M04 2. This Surveillance shall not normally be performed in MODE 1 or 2. 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.

DOC M04 3. If performed with DG synchronized with offsite 0.89 power, it shall be performed at a power factor

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

4.8.1.1.2.g.3 Verify each DG 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 6

a. For [2] hours loaded [5250] kW and OR

[5500] kW and 4620 4840 2380 kvar and 2600 kvar, and In accordance

b. For the remaining hours of the test loaded with the 4 1

[4500] kW and [5000] kW. Surveillance 3960 4400 Frequency and 2140 kvar and 2370 kvar Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-14 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 90 of 638

Enclosure 2, Volume 13, Rev. 0, Page 91 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.g 4.8.1.1.2.g.4 SR 3.8.1.15 ------------------------------NOTES-----------------------------

DOC A05 1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated [2] hours loaded [4500] kW and [5000] kW. 3960 4 4400 and 2140 kvar and 2370 kvar DOC L09 Momentary transients outside of load range do not invalidate this test.

DOC A04 2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves: [ [18] months 6800 6

DOC L19 a. In [10] seconds, voltage [3740] V and OR frequency [58.8] Hz and 4 6800 7260 In accordance 4.8.1.1.2.g.4 b. Steady state voltage [3740] V, and [4580] V with the and frequency [58.8] Hz and [61.2] Hz. Surveillance Frequency Control Program ] 6 For DGs 2A-A and 2B-B, this 4.8.1.1.2.d 4.8.1.1.2.d.9 SR 3.8.1.16 ------------------------------NOTE-------------------------------

DOC L11 This Surveillance shall not normally be performed in 5 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: [ [18] months 6

4.8.1.1.2.d.9.a a. Synchronizes with offsite power source while OR loaded with emergency loads upon a simulated restoration of offsite power, In accordance with the 4.8.1.1.2.d.9.b b. Transfers loads to offsite power source, and Surveillance Frequency 4.8.1.1.2.d.9.c c. Returns to ready-to-load operation. Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-15 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 91 of 638

Enclosure 2, Volume 13, Rev. 0, Page 92 of 638 CTS AC Sources - Operating 3.8.1 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, 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.

7 Verify, with a DG operating in test mode and [ [18] months connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by: OR

a. Returning DG to ready-to-load operation and In accordance with the
b. [Automatically energizing the emergency load Surveillance from offsite power]. Frequency Control Program ]

For DGs 2A-A and 2B-B, this 4.8.1.1.2.d 4.8.1.1.2.d.10 SR 3.8.1.18 ------------------------------NOTE------------------------------- 7 4.8.1.1.2.d.10 17

[ This Surveillance shall not normally be performed 4 5 Note #

in MODE 1, 2, 3, or 4. However, this Surveillance DOC M06 may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 4

taken for unplanned events that satisfy this SR. ]

setpoint for load Verify interval between each sequenced load block [ [18] months is within +/- [10% of design interval] for each timer 3 6 5% of design emergency [and shutdown] load sequencer. OR In accordance with the Surveillance Frequency 6

Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-16 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 92 of 638

Enclosure 2, Volume 13, Rev. 0, Page 93 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.d 4.8.1.1.2.d.6 SR 3.8.1.19 ------------------------------NOTES----------------------------- 7 DOC A05 18 1. All DG starts may be preceded by an engine prelube period.

For DGs 2A-A and 2B-B, this 5

DOC L11 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.

4.8.1.1.2.d.6 Verify on an actual or simulated loss of offsite power [ [18] months signal in conjunction with an actual or simulated 6 ESF actuation signal: OR 4.8.1.1.2.d.6.a shutdown boards

a. De-energization of emergency buses, In accordance 1 4.8.1.1.2.d.6.a shutdown boards with the
b. Load shedding from emergency buses, and Surveillance 4.8.1.1.2.d.6.b Frequency
c. DG auto-starts from standby condition and: Control Program ] 6
1. Energizes permanently connected loads in

[10] seconds, 4

2. Energizes auto-connected emergency 3

loads through load sequencer, load sequence timers

3. Achieves steady state voltage [3740] V and [4580] V, 6800 7260 4
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.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-17 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 93 of 638

Enclosure 2, Volume 13, Rev. 0, Page 94 of 638 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.2.e SR 3.8.1.20 ------------------------------NOTE------------------------------- 7 DOC A05 19 All DG starts may be preceded by an engine prelube period.

4.8.1.1.2.e Verify when started simultaneously from standby [ 10 years condition, each DG achieves: , 6 OR

a. In [10] seconds, voltage [3740] V and 4 frequency [58.8] Hz and . 6800 In accordance with the
b. Steady state voltage [3744] V and [4576] V, Surveillance 8 and frequency [58.8] Hz and [61.2] Hz. Frequency Control Program ] 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.1-18 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 94 of 638

Enclosure 2, Volume 13, Rev. 0, Page 95 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.
3. ISTS LCO 3.8.1.c and ISTS 3.8.1 ACTION F have been deleted since SQN Units 1 and 2 do not use load sequencers. Each load or load block is sequenced with the use of its associated time delay relay. Each major ESF component has individual time delay relays that operate individual components, not all ESF components.

Thus, if a single time delay relay fails, only the individual component and the DG could be affected. Subsequent Conditions and Required Actions have been renumbered, as applicable. ISTS SR 3.8.1.11 (ITS SR 3.8.1.11), ISTS SR 3.8.1.12 (ITS SR 3.8.1.12), ISTS SR 3.8.1.18 (ITS SR 3.8.1.17), and ISTS SR 3.8.1.19 (ITS SR 3.8.1.18) have been revised to reflect the use of time delay relays.

4. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
5. Changes were made to ISTS LCO 3.8.1 to ensure the appropriate AC power sources are OPERABLE during unit operation in MODES 1, 2, 3 and 4 to satisfy the design requirements. This modification was necessary due to shared systems between Units 1 and 2. This is an exception that is intended to allow taking the ACTIONS associated with inoperable shared equipment in lieu of requiring the opposite unit AC sources to be restored to OPERABLE status within a specified Completion Time.

This exception is acceptable since, with the opposite unit equipment inoperable and the associated ACTIONS entered, the opposite unit AC Sources provide no additional assurance of meeting the safety criteria of the given units AC power sources.

SR Notes associated with ISTS SR 3.8.1.8 (ITS SR 3.8.1.8), ISTS SR 3.8.1.9 (ITS SR 3.8.1.9), ISTS SR 3.8.1.10 (ITS SR 3.8.1.10), ISTS SR 3.8.1.11 (ITS SR 3.8.1.11), ISTS SR 3.8.1.12 (ITS SR 3.8.1.12), ISTS SR 3.8.1.13 (ITS SR 3.8.1.13), ISTS SR 3.8.1.14 (ITS SR 3.8.1.14), ISTS SR 3.8.1.16 (ITS SR 3.8.1.16), ISTS SR 3.8.1.18 (ITS SR 3.8.1.17), and ISTS SR 3.8.1.19 (ITS SR 3.8.1.18) have been revised to allow performance of the affected SR on opposite unit shutdown board or DGs when the given unit is in a restricted MODE.

6. ISTS SR 3.8.1.1 (ITS SR 3.8.1.1), ISTS SR 3.8.1.2 (ITS SR 3.8.1.2),

ISTS SR 3.8.1.3 (ITS SR 3.8.1.3), ISTS SR 3.8.1.4 (ITS SR 3.8.1.4),

ISTS SR 3.8.1.5 (ITS SR 3.8.1.5), ISTS SR 3.8.1.6 (ITS SR 3.8.1.6),

ISTS SR 3.8.1.7 (ITS SR 3.8.1.7), ISTS SR 3.8.1.8 (ITS SR 3.8.1.8),

ISTS SR 3.8.1.9 (ITS SR 3.8.1.9), ISTS SR 3.8.1.10 (ITS SR 3.8.1.10),

ISTS SR 3.8.1.11 (ITS SR 3.8.1.11), ISTS SR 3.8.1.12 (ITS SR 3.8.1.12),

ISTS SR 3.8.1.13 (ITS SR 3.8.1.13), ISTS SR 3.8.1.14 (ITS SR 3.8.1.14),

ISTS SR 3.8.1.15 (ITS SR 3.8.1.15), ISTS SR 3.8.1.16 (ITS SR 3.8.1.16),

ISTS SR 3.8.1.18 (ITS SR 3.8.1.17), ISTS SR 3.8.1.19 (ITS SR 3.8.1.18), and ISTS SR 3.8.1.20 (ITS SR 3.8.1.19) provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Sequoyah Unit 1 and Unit 2 Page 1 of 2 Enclosure 2, Volume 13, Rev. 0, Page 95 of 638

Enclosure 2, Volume 13, Rev. 0, Page 96 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING Surveillance Frequencies for these SRs under the Surveillance Frequency Control Program.

7. ISTS SR 3.8.1.17 is not included in the SQN ITS since this feature was not included in the SQN design. This SR demonstrates that with a DG operating in the test mode and connected to its bus, an ESF actuation signal overrides the test mode and returns the DG to ready-to-load operation. At SQN, with a DG connected to its shutdown board, if an ESF actuation signal were received, the DG would stay connected to its shutdown board. Therefore, this SR is not applicable. Subsequent Surveillances have been renumbered, as applicable.
8. The steady state limit does not apply to the simultaneous start of all DGs (ISTS SR 3.8.1.19), since it is a test of starting independence, not operating independence.

This is consistent with the current licensing basis.

Sequoyah Unit 1 and Unit 2 Page 2 of 2 Enclosure 2, Volume 13, Rev. 0, Page 96 of 638

Enclosure 2, Volume 13, Rev. 0, Page 97 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 97 of 638

Enclosure 2, Volume 13, Rev. 0, Page 98 of 638 AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and 1 alternate(s)), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

INSERT 1 The onsite Class 1E AC Distribution System is divided into redundant 1 load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

INSERT 2 Offsite power is supplied to the unit switchyard(s) from the transmission 1 network by [two] transmission lines. From the switchyard(s), two electrically and physically separated circuits provide AC power, through

[step down station auxiliary transformers], to the 4.16 kV ESF buses. A detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the FSAR, Chapter [8] (Ref. 2). 1 2 6.9 kV Shutdown Boards U An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus(es). 1 INSERT 3 Certain required unit loads are returned to service in a predetermined 1 sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution System. Within [1] minute after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service via the load sequencer.

6.9 kV Shutdown Board The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs [11] and [12] are dedicated to ESF buses [11]

1 INSERT 4 and [12], respectively. A DG starts automatically on a safety injection (SI)

, or low steam line pressure signal (i.e., low pressurizer pressure or high containment pressure ,

signals) or on an [ESF bus degraded voltage or undervoltage signal] 2 INSERT 5 (refer to LCO 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start 6.9 kV Shutdown Board Instrumentation"). After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus INSERT 5 undervoltage or degraded voltage, independent of or coincident with an 1 SI signal. The DGs will also start and operate in the standby mode 6.9 kV Shutdown Board without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, [a sequencer/an undervoltage signal] strips nonpermanent 2 a loss-of-voltage signal SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 98 of 638

Enclosure 2, Volume 13, Rev. 0, Page 99 of 638 B 3.8.1 1

INSERT 1 The onsite Class 1E AC Electrical Power Distribution System is divided into two redundant and independent load groups with two 6.9 kV Shutdown Boards in each load group. Each 6.9 kV Shutdown Board has a connection to a preferred offsite power source and a DG. The 6.9 kV Shutdown Boards in a load group (i.e., 1A-A and 2A-A, or 1B-B and 2B-B) are normally powered by the same offsite power circuit. Each 6.9 kV Shutdown Board can also be powered by a dedicated DG. Two DGs associated with one load group can provide all safety related functions to mitigate a loss of coolant accident (LOCA) in one unit and safely shut down the other unit. The Train A and Train B ESF systems each provide for the minimum safety functions necessary to shut down the plant and maintain it in a safe shutdown condition.

The Unit 1 core cooling systems and containment systems (e.g., Safety Injection (SI), Auxiliary Feedwater (AFW), Residual Heat Removal (RHR), Centrifugal Charging pump, Containment Spray, and Air Return System (ARS) fan) are unitized (not shared with Unit 2) and are powered from 6.9 kV Shutdown Boards 1A-A and 1B-B. However, some safety-related systems (e.g.,

Essential Raw Cooling Water (ERCW), Component Cooling Water (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVS), and Control Room Air-Conditioning (CRACS)) are shared with Unit 2. The AC sources for these loads are distributed across all four 6.9 kV Shutdown Boards. Therefore, two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System and a separate and independent DG for each 6.9 kV Shutdown Board ensure the availability of power to each of these systems.

Insert Page B 3.8.1-1a Enclosure 2, Volume 13, Rev. 0, Page 99 of 638

Enclosure 2, Volume 13, Rev. 0, Page 100 of 638 B 3.8.1 1

INSERT 2 The offsite power distribution system consists of two 161 kV buses supplied by eight 161 kV feeders and two 500 kV buses supplied by five 500 kV feeders. The output of the Unit 1 main generator is fed to the 500 kV buses and the output of the Unit 2 main generator is fed to the 161 kV buses. The output of each unit's main generator is also capable of supplying power to an offsite circuit (via the Unit Station Service Transformers (USSTs)) with a Generator Circuit Breaker (GCB) providing isolation between the main generator and the main bank transformers.

When the main generator is not operating, the main bank transformers function as step down transformers and supply electrical power from the grid to the USSTs.

Offsite power can also be supplied by the Common Station Service Transformers (CSSTs) via the 6.9 kV Start Buses and 6.9 kV Unit Boards. Offsite power will normally be supplied from the USSTs to the 6.9 kV Shutdown Boards via the 6.9 kV Unit Boards, and will automatically transfer at least one power supply to an alternate power supply (CSST A or CSST C) on a trip of the Power Circuit Breakers (PCBs). CSST C is the alternate power source for 6.9 kV Shutdown Boards 1A-A and 2A-A, and CSST A is the alternate power source for 6.9 kV Shutdown Boards 1B-B and 2B-B. (CSST B is a spare transformer with two sets of secondary windings that can be used to supply a total of two Start Buses for CSST A and/or CSST C, with each Start Bus on a separate CSST B secondary winding.) Therefore, two electrically and physically separated circuits provide AC power through a combination of the USSTs and/or CSSTs to the 6.9 kV Shutdown Boards. Each offsite circuit is capable of providing power to one train of ESF loads.

1 INSERT 3 (beginning at the switchyard) to one load group of Class 1E 6.9 kV Shutdown Boards (ending at the supply side of the normal or alternate supply circuit breaker) 1 INSERT 4 DGs 1A-A, 1B-B, 2A-A, and 2B-B are separate and independent and are dedicated to 6.9 kV Shutdown Boards 1A-A, 1B-B, 2A-A, and 2B-B, respectively. Each diesel generator set consists of two diesel engines in tandem driving a common generator with a normal synchronous speed of approximately 900 rpm.

1 INSERT 5 a 6.9 kV Shutdown Board degraded voltage or loss-of-voltage signal Insert Page B 3.8.1-1b Enclosure 2, Volume 13, Rev. 0, Page 100 of 638

Enclosure 2, Volume 13, Rev. 0, Page 101 of 638 AC Sources - Operating B 3.8.1 BASES BACKGROUND (continued) 6.9 kV Shutdown Board 6.9 kV Shutdown Board loads from the ESF bus. When the DG is tied to the ESF bus, loads are 1 sequence timers then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and 3 individual starting signals to motor breakers to prevent overloading the DG by automatic load application.

6.9 kV Shutdown Boards In the event of a loss of preferred power, the ESF electrical loads are 1 automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis 1

Accident (DBA) such as a loss of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Within 2 1 INSERT 6 [1] minute after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service. 1 INSERT 7 automatic and permanently connected Ratings for Train A and Train B DGs satisfy the requirements of 1 4400 Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG is [7000] kW with [10]% overload permissible for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 2 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The ESF loads that are powered from the 4.16 kV ESF 1 buses are listed in Reference 2. 6.9 kV Shutdown Boards U

1 APPLICABLE The initial conditions of DBA and transient analyses in the FSAR, SAFETY Chapter [6] (Ref. 4) and Chapter [15] (Ref. 5), assume ESF systems are 2 ANALYSES OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS);

and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon 4 meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during Accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC power and
b. A worst case single failure.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 101 of 638

Enclosure 2, Volume 13, Rev. 0, Page 102 of 638 B 3.8.1 2

INSERT 6 the required time interval (UFSAR Table 8.3.1-2) 1 INSERT 7 the 1A-A, 1B-B, 2A-A and 2B-B Insert Page B 3.8.1-2 Enclosure 2, Volume 13, Rev. 0, Page 102 of 638

Enclosure 2, Volume 13, Rev. 0, Page 103 of 638 AC Sources - Operating B 3.8.1 BASES LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Electrical Power System and separate and independent 1 6.9kV Shutdown Board DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit.

[ In addition, one required automatic load sequencer per train must be 2 OPERABLE. ]

qualified physically independent, Each offsite circuit must be capable of maintaining rated frequency and 1 voltage, and accepting required loads during an accident, while 1

connected to the ESF buses.

6.9kV Shutdown Boards INSERT 8 [ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied 1 from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. Offsite circuit #2 consists of the Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201, powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

6.9kV Shutdown Board Each DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus 1 undervoltage. This will be accomplished within [10] seconds. Each DG 2 must also be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power 6.9kV Shutdown Board can be restored to the ESF buses. These capabilities are required to be 1 met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby with the engine at ambient conditions.

Additional DG capabilities must be demonstrated to meet required 5 Surveillance, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, [including tripping of nonessential loads,] is a 2 required function for DG OPERABILITY.

The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For the DGs, separation and independence are complete.

For the offsite AC sources, separation and independence are to the 1 extent practical. A circuit may be connected to more than one ESF bus, with fast transfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is not connected to an ESF bus is required to have OPERABLE fast transfer interlock mechanisms to at least two ESF buses to support OPERABILITY of that circuit.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 103 of 638

Enclosure 2, Volume 13, Rev. 0, Page 104 of 638 B 3.8.1 1

INSERT 8 The minimum required switchyard voltages are determined by evaluation of plant accident loading and the associated voltage drops between the transmission network and these loads.

These minimum voltage values are provided to TVAs Transmission Operations for use in system studies to support operation of the transmission network in a manner that will maintain the necessary voltages. Transmission Operations is required to notify SQN Operations if it is determined that the transmission network may not be able to support accident loading or shutdown operations as required by 10 CFR 50, Appendix A, GDC-17. Any offsite power circuits supplied by the transmission network that are not able to support accident loading or shutdown operations are inoperable.

The USSTs utilize auto load tap changers to provide the required voltage response for accident loading. The load tap changer associated with a USST is required to be functional and in "automatic" for the USST to supply power to a 6.9 kV Unit Board.

Each required offsite circuit is that combination of power sources described below that are either connected to the Class 1E AC Electrical Power Distribution System, or is available to be connected to the Class 1E AC Electrical Power Distribution System through automatic transfer at the 6.9 kV Unit Boards.

The following offsite power configurations meet the requirements of the LCO:

1. Two offsite circuits consisting of a AND b (no board transfers required; a loss of either circuit will not prevent the minimum safety functions from being performed):
a. From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C), and CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
b. From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B), and CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

Insert Page B 3.8.1-3a Enclosure 2, Volume 13, Rev. 0, Page 104 of 638

Enclosure 2, Volume 13, Rev. 0, Page 105 of 638 B 3.8.1 INSERT 8 (Continued)

2. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.2)(b), or a.2) to b.1)(a) on a loss of USSTs 1A and 1B, OR relies on automatic transfer from alignment a.3) to b.2)(a), or a.4) to b.1)(b) on a loss of USSTs 2A and 2B):
a. Normal power source alignments
1) From the 500 kV switchyard through USST 1A to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B);
2) From the 500 kV switchyard through USST 1B to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C);
3) From the 161 kV switchyard through USST 2A to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B); AND
4) From the 161 kV switchyard through USST 2B to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C).
b. Alternate power source alignments
1) From the 161 kV transmission network, through:

(a) CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND (b) CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); OR

2) From the 161 kV transmission network, through:

(a) CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B); AND (b) CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

3. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.1) and b.2) on a loss of the Unit 2 USSTs; a loss of alignment a.2) or a.3) will not prevent the minimum safety functions from being performed):
a. Normal power source alignments
1) From the 161 kV switchyard through USST 2A to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B), and USST 2B to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C);
2) From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND Insert Page B 3.8.1-3b Enclosure 2, Volume 13, Rev. 0, Page 105 of 638

Enclosure 2, Volume 13, Rev. 0, Page 106 of 638 B 3.8.1 INSERT 8 (Continued)

3) From the 161 kV transmission network, through CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).
b. Alternate power source alignments
1) From the 161 kV transmission network, through CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
2) From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B).
4. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.1) and b.2) on a loss of the Unit 1 USSTs; a loss of alignment a.2) or a.3) will not prevent the minimum safety functions from being performed):
a. Normal power source alignments
1) From the 500 kV switchyard through USST 1A to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B), and USST 1B to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C);
2) From the 161 kV transmission network, through CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
3) From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B).
b. Alternate power source alignments
1) From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND
2) From the 161 kV transmission network, through CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

Other offsite power configurations are possible using different combinations of available USSTs and CSSTs, as long as the alignments are consistent with the analyzed configurations, and the alignments comply with the requirements of GDC 17.

Insert Page B 3.8.1-3c Enclosure 2, Volume 13, Rev. 0, Page 106 of 638

Enclosure 2, Volume 13, Rev. 0, Page 107 of 638 AC Sources - Operating B 3.8.1 BASES APPLICABILITY The AC sources [and sequencers] are required to be OPERABLE in 2 MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining 5 than Condition C required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered. 5 E


REVIEWERS NOTE----------------------------------- 6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 107 of 638

Enclosure 2, Volume 13, Rev. 0, Page 108 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.2 a Unit 1 6.9 kV Shutdown Board Required Action A.2, which only applies if the train cannot be powered 5 from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

These features are powered from the redundant AC electrical power train.

This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

6.9 kV Shutdown Board 1A-A or 1B-B

a. The train has no offsite power supplying it loads and 5
b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit 5 inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

a Unit 1 6.9 kV Shutdown Board Discovering no offsite power to one train of the onsite Class 1E Electrical 5 Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution 1 System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 108 of 638

Enclosure 2, Volume 13, Rev. 0, Page 109 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. 1 AC Electrical Power The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG, 5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.


REVIEWERS NOTE----------------------------------- 6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

B.2 (s)

Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a 5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG. 5 SEQUOYAH UNIT 1 (s) Revision XXX Westinghouse STS B 3.8.1-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 109 of 638

Enclosure 2, Volume 13, Rev. 0, Page 110 of 638 B 3.8.1 5

INSERT 9 DG 1A-A, DG 1B-B, DGs 1A-A and 2A-A, or DGs 1B-B and 2B-B Insert Page B 3.8.1-6 Enclosure 2, Volume 13, Rev. 0, Page 110 of 638

Enclosure 2, Volume 13, Rev. 0, Page 111 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists and 5
b. A required feature on the other train (Train A or Train B) is inoperable.

or more DGs in a train If at any time during the existence of this Condition (one DG inoperable) a 5 required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

or more DGs in a train Discovering one required DG inoperable coincident with one or more 5 inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is Acceptable because it minimizes risk while 4 allowing time for restoration before subjecting the unit to transients associated with shutdown.

s AC Electrical Power In this Condition, the remaining OPERABLE DG and offsite circuits are 1 adequate to supply electrical power to the onsite Class 1E Distribution 5 System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the J INSERT 10 failure is repaired, the common cause failure no longer exists, and 5 Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 111 of 638

Enclosure 2, Volume 13, Rev. 0, Page 112 of 638 B 3.8.1 5

INSERT 10 if one or more DG(s) in Train A and Train B are inoperable Insert Page B 3.8.1-7 Enclosure 2, Volume 13, Rev. 0, Page 112 of 638

Enclosure 2, Volume 13, Rev. 0, Page 113 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

(s) 5 In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will 2 continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to 2 confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(s) AC Electrical Power 5

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution 7 day System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

INSERT 11 5 C.1 and C.2 E 5 E E Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 113 of 638

Enclosure 2, Volume 13, Rev. 0, Page 114 of 638 B 3.8.1 5

INSERT 11 C.1, C.2, and C.3 Condition C is entered for an offsite circuit inoperable solely due to an inoperable power source to 6.9 kV Shutdown Board 2A-A or 2B-B. Required Action C.1 verifies the OPERABILITY of the remaining offsite circuit within an hour of the inoperability and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Since the Required Action only specifies "perform," a failure of the SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

The Completion Time for Required Action C.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. 6.9 kV Shutdown Board 2A-A or 2B-B has no offsite power; and
b. A required feature on the other train is inoperable.

If at any time during the existence of Condition C a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

A Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptable, because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The remaining OPERABLE offsite circuit and DGs are adequate to support these functions. The Completion Time takes into account the component OPERABILITY of the remaining redundant feature(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition C for a period of 7 days. With one offsite circuit inoperable, the reliability of the functions is degraded. The potential for the loss of offsite power to the redundant feature(s) is increased, with the attendant potential for a challenge to their safety functions.

The required offsite circuit must be returned to OPERABLE status within 7 days, or the support function for the associated required feature is considered inoperable. At that time, the required feature must be declared inoperable and the appropriate Conditions must be entered. The 7 days Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required feature(s), a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

Insert Page B 3.8.1-8a Enclosure 2, Volume 13, Rev. 0, Page 114 of 638

Enclosure 2, Volume 13, Rev. 0, Page 115 of 638 B 3.8.1 5

INSERT 11 (Continued)

D.1, D.2, D.3 and D.4 To ensure a highly reliable power source remains with an inoperable DG to a Unit 2 6.9 kV Shutdown Board, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. Required Action D.1 verifies the OPERABILITY of the required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must be entered.

Required Action D.2 is intended to provide assurance that a loss of offsite power, during the period that an LCO 3.8.1.d DG is inoperable, does not result in a complete loss of the safety functions.

The Completion Time for Required Action D.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG to 6.9 kV Shutdown Board 2A-A or 2B-B exists; and
b. A redundant feature in the same system is inoperable.

If at any time during the existence of Condition D (one DG to 6.9 kV Shutdown Board 2A-A or 2B-B) a redundant feature in the same system subsequently becomes inoperable, this Completion Time begins to be tracked. The four hour Completion Time is acceptable, because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to support the functions. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the component OPERABILITY of the remaining redundant feature(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

D.3.1 and D.3.2 Required Action D.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG(s), SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on another DG, the other DG would be declared inoperable, and upon discovery, Condition J of LCO 3.8.1 would be entered, if one or more DG(s) in Train A and Train B are inoperable. Otherwise, if the inoperability exists on the other DG in the same train, the other DG would be declared inoperable upon discovery, Condition B would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action D.3.1 is satisfied.

If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DGs, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

Insert Page B 3.8.1-8b Enclosure 2, Volume 13, Rev. 0, Page 115 of 638

Enclosure 2, Volume 13, Rev. 0, Page 116 of 638 B 3.8.1 5

INSERT 11 (Continued)

Operation may continue in Condition D for a period of 7 days. With one Unit 2 DG inoperable, the reliability of the respective function is degraded. The potential for the loss of a DG to the redundant feature(s) is increased, with the attendant potential for a challenge to respective safety function.

The required DG must be returned to OPERABLE status within 7 days, or the support function for the associated required feature is considered inoperable. At that time, the required feature must be declared inoperable and the appropriate Conditions must be entered. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required feature(s), a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

Insert Page B 3.8.1-8c Enclosure 2, Volume 13, Rev. 0, Page 116 of 638

Enclosure 2, Volume 13, Rev. 0, Page 117 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

E The Completion Time for Required Action C.1 is intended to allow the 5 operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and
b. A required feature is inoperable.

E 5

If at any time during the existence of Condition C (two offsite circuits inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

E According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This level of 5 degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable.

However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and
b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC 5 sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 117 of 638

Enclosure 2, Volume 13, Rev. 0, Page 118 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If two offsite sources are restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, power operation continues in accordance with Condition A.

or Condition C, as applicable 5 F F 5

D.1 and D.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-F energization. Therefore, the Required Actions of Condition D are modified by a Note to indicate that when Condition D is entered with no 6.9 kV Shutdown AC source to any train, the Conditions and Required Actions for F 5 Board 1A-A or 1B-B LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition D to provide requirements for the loss of F

to 6.9 kV Shutdown one offsite circuit and one DG, without regard to whether a train is de-Board 1A-A or 1B-B energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D 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 />.

F F 5 In Condition D, 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 E

higher than that in Condition C (loss of both required offsite circuits). This 5 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, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

INSERT 12 J

E.1 one or more Train A DG(s) and one or more Train B DG(s) insufficient 5 With Train A and Train B DGs inoperable, there are no remaining standby available to power AC sources. Thus, with an assumed loss of offsite electrical power, an entire load group insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 118 of 638

Enclosure 2, Volume 13, Rev. 0, Page 119 of 638 B 3.8.1 5

INSERT 12 G.1 and H.1 In Conditions G and H, individual redundancy is lost in the offsite electrical power system for one unit and the onsite AC electrical power system for the other unit. Since Conditions B and C are entered concurrent with entry into Condition G, and Conditions A and D are entered concurrent with entry into Condition H, the Required Actions of Conditions B and C (or Conditions A and D) provide the appropriate compensatory measures to ensure the onsite and offsite power sources are either restored to an OPERABLE status, or the associated required features are declared inoperable, thereby requiring entry into the appropriate Conditions associated with the associated feature's LCO. The Completion Times of Required Actions G.1 and H.1 are consistent with the Completion Times of Required Actions C.3 and D.4. If, while in Condition G or H, a redundant required feature is determined to be inoperable, the required feature(s) would be declared inoperable at the Completion Times specified in Conditions A, B, C, or D, as applicable.

I.1 and I.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition I are modified by a Note to indicate that when Condition I is entered with no AC source to 6.9 kV Shutdown Board 2A-A or 2B-B, the Conditions and Required Actions for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition I to provide requirements for the loss of one offsite power source and one DG, without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized 6.9 kV Shutdown Board.

In Condition I, individual redundancy is lost in the offsite electrical power system and the onsite AC electrical power system. Concurrent with entry into Condition I, entry into Condition C (inoperable offsite power source) and Condition D (inoperable DG) are required. The Required Actions of Conditions C and D ensure the remaining offsite circuit and DGs are OPERABLE and that required features with no offsite or onsite power sources are declared inoperable when its redundant required feature is inoperable within the Completion Times of Required Actions C.2 and D.2.

Insert Page B 3.8.1-10 Enclosure 2, Volume 13, Rev. 0, Page 119 of 638

Enclosure 2, Volume 13, Rev. 0, Page 120 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

In this Condition, According to Reference 6, with both DGs inoperable, operation may 5 continue for a period that should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

, consistent with the guidance provided in Reference 6 5

[ F.1 5 The sequencer(s) is an essential support system to [both the offsite circuit and the DG associated with a given ESF bus]. [Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

Therefore, loss of an [ESF bus sequencer] affects every major ESF system in the [division]. The [12] hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event and thereby causes its failure. Also implicit in the Note, is that the Condition is not applicable to any train that does not have a sequencer. ]

K K G.1 and G.2 5 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-11 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 120 of 638

Enclosure 2, Volume 13, Rev. 0, Page 121 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

L.1 and M.1 H.1 5 s L and M Condition H corresponds to a level of degradation in which all redundancy cannot be assured in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS 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 and Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as 1 addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output 6900 2 voltage of [3740] V is 90% of the nominal 4160 V output voltage. This 6210 10 value, which is specified in ANSI C84.1 (Ref. 11), allows for voltage drop 1 6600 to the terminals of 4000 V motors whose minimum operating voltage is 1 specified as 90% or 3600 V. It also allows for voltage drops to motors 1 5940 and other equipment down through the 120 V level where minimum 7260 operating voltage is also usually specified as 90% of name plate rating.

The specified maximum steady state output voltage of [4756] V is equal 2 6600 to the maximum operating voltage specified for 4000 V motors. It 1 6600 ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating 1 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 7 day Frequency is 7 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-12 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 121 of 638

Enclosure 2, Volume 13, Rev. 0, Page 122 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 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 1 for SR 3.8.1.2 and Note for SR 3.8.1.7) 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.

the

[ In order to reduce stress and wear on diesel engines, some s

manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are 2 gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only applicable when such modified start procedures are recommended by the manufacturer. ]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-13 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 122 of 638

Enclosure 2, Volume 13, Rev. 0, Page 123 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.7 requires that the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter [15] (Ref. 5). 2 The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described above is used. If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies.

Since SR 3.8.1.7 requires a 10 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.

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 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while 7 minimizing degradation resulting from testing.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-14 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 123 of 638

Enclosure 2, Volume 13, Rev. 0, Page 124 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) has an allowable Although no power factor requirements are established by this SR, the rating DG is normally operated at a power factor between [0.8 lagging] and 1

[1.0]. The [0.8] value is the design rating of the machine, while the [1.0] is 2 an operational limitation [to ensure circulating currents are minimized].

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

[ The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3).

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients, because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 engine-mounted day This SR provides verification that the level of fuel oil in the day tank [and 5 2

engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of DG operation at full load plus 10%.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-15 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 124 of 638

Enclosure 2, Volume 13, Rev. 0, Page 125 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility 7

operators would be aware of any large uses of fuel oil during this period.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the engine-mounted day fuel oil day [and engine mounted] tanks eliminates the necessary 5 2 environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. [ The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 10). This SR is for preventative maintenance. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-16 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 125 of 638

Enclosure 2, Volume 13, Rev. 0, Page 126 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

SR 3.8.1.6 the storage system to the This Surveillance demonstrates that each required fuel oil transfer pump engine-mounted day operates and transfers fuel oil from its associated storage tank to its 1 associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 11); however, the design of fuel transfer systems is such that pumps operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [and engine 7 mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.1.7 See SR 3.8.1.2.

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Enclosure 2, Volume 13, Rev. 0, Page 127 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 2

[ SR 3.8.1.8 1

INSERT 13 Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

[ The [18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, 7 the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

two s 1 This SR is modified by a Note. The reason for the Note is that, during 5 for the 1A, 1B, 1C, and 1D Unit Boards operation with the reactor critical, performance of this SR 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.] 2 Credit may be taken for unplanned events that satisfy this SR.

INSERT 14 5 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-18 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 127 of 638

Enclosure 2, Volume 13, Rev. 0, Page 128 of 638 B 3.8.1 1

INSERT 13 Transfer of the power supply to each 6.9 kV Unit Board from the normal supply to the alternate supply demonstrates the OPERABILITY of the alternate supply to power the shutdown loads.

This SR is modified by two Notes.

1 INSERT 14 Note 2 specifies that transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and alternate power supplies. When both load groups are being supplied power by the USSTs, only the 6.9 kV Unit Boards associated with one load group are required to have normal and alternate power supplies. Therefore, only one CSST is required to be OPERABLE and available as an alternate power supply. Manual transfers between the normal supply and the alternate supply are also required to meet the SR. However, delayed access to an offsite circuit is not credited in the accident analysis.

Insert Page B 3.8.1-18 Enclosure 2, Volume 13, Rev. 0, Page 128 of 638

Enclosure 2, Volume 13, Rev. 0, Page 129 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load 1 without exceeding predetermined voltage and frequency and while (600kw) maintaining a specified margin to the overspeed trip. [For this unit, the 2

single load for each DG and its horsepower rating is as follows:] This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus, or
b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

Consistent with Regulatory Guide 1.9 3 As required by IEEE-308 (Ref. 12), the load rejection test is acceptable if 1 the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. [ The

[18 month] Frequency is consistent with the recommendation of 7

Regulatory Guide 1.108 (Ref. 9).

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

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-19 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 129 of 638

Enclosure 2, Volume 13, Rev. 0, Page 130 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE----------------------------------- 6 Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

for DGs 1A-A and 1B-B This SR is modified by two Notes. The reason for Note 1 is that during 5 operation with the reactor critical, performance of this SR 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with 0.89 offsite power, testing should be performed at a power factor of [0.9]. 2 This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a 0.89 power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor 0.89 to [0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close 0.89 as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be 0.89 2

such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

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Enclosure 2, Volume 13, Rev. 0, Page 131 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

[ The [18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 9) and is intended to be consistent with expected fuel cycle lengths. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-21 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 131 of 638

Enclosure 2, Volume 13, Rev. 0, Page 132 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

for DGs 1A-A and 1B-B This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could 5 cause perturbation 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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. Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This 2 power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, 0.89 however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is 0.89 high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high.

0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be 0.89 2 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-22 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 132 of 638

Enclosure 2, Volume 13, Rev. 0, Page 133 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE----------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG autostart time of [10] seconds is derived from requirements of the 2 accident analysis to respond to a design basis large break LOCA. 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 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-23 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 133 of 638

Enclosure 2, Volume 13, Rev. 0, Page 134 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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.

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is 7 intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge for DGs 1A-A and 1B-B safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the 5 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, and 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 the assessment.

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

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-24 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 134 of 638

Enclosure 2, Volume 13, Rev. 0, Page 135 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.8.1.12 2 This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time

([10] seconds) from the design basis actuation signal (LOCA signal) and 2 operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.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 Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] 7 Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-25 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 135 of 638

Enclosure 2, Volume 13, Rev. 0, Page 136 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

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 for DGs 1A-A and 1B-B Surveillance in MODE 1 or 2 is further amplified to allow portions of the 5 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, and 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 the assessment. ] 2 Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic 5 trips are all automatic trips except: , or both

a. Engine overspeed; and
b. Generator differential current;

[ c. Low lube oil pressure; 2

d. High crankcase pressure; and
e. Start failure relay.]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-26 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 136 of 638

Enclosure 2, Volume 13, Rev. 0, Page 137 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The noncritical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

[ The [18 month] Frequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when 7 performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service. This for DGs 1A-A restriction from normally performing the Surveillance in MODE 1 or 2 is 5 and 1B-B further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-27 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 137 of 638

Enclosure 2, Volume 13, Rev. 0, Page 138 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, [2] hours of which is 2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

[ The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is 7

intended to be consistent with expected fuel cycle lengths.

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

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-28 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 138 of 638

Enclosure 2, Volume 13, Rev. 0, Page 139 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during for DGs 1A-A operation with the reactor critical, performance of this Surveillance could 5 and 1B-B 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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. Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This 2 power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, 0.89 however, Note 3 allows the Surveillance to be conducted as a power factor other than [0.9]. These conditions occur when grid voltage is 0.89 high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high.

0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on 2 the emergency busses. In other circumstances, the grid voltage may be 0.89 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained close as practicable to [0.9]

without exceeding the DG excitation limits.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-29 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 139 of 638

Enclosure 2, Volume 13, Rev. 0, Page 140 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.15 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

[10] seconds. The [10] second time is derived from the requirements of 2 the accident analysis to respond to a design basis large break LOCA.

[ The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5). 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load 2 conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-30 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 140 of 638

Enclosure 2, Volume 13, Rev. 0, Page 141 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset.

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

for DGs 1A-A This restriction from normally performing the Surveillance in MODE 1 or 2 5 and 1B-B is further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-31 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 141 of 638

Enclosure 2, Volume 13, Rev. 0, Page 142 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.8.1.17 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads 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 [18 month] Frequency is consistent with the recommendations of 5 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note. The reason for the Note is that performing 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 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 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-32 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 142 of 638

Enclosure 2, Volume 13, Rev. 0, Page 143 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and 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 5

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

17 5

SR 3.8.1.18 Under accident [and loss of offsite power] conditions loads are load sequence sequentially connected to the bus by the [automatic load sequencer]. The 2 timers sequencing logic controls the permissive and starting signals to motor 5

breakers to prevent overloading of the DGs due to high motor starting 2

currents. The [10]% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses. 1 6.9 kV Shutdown Boards

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is 7 intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-33 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 143 of 638

Enclosure 2, Volume 13, Rev. 0, Page 144 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

for DGs 1A-A This restriction from normally performing the Surveillance in MODE 1 or 2 5 and 1B-B is further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

18 5

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-34 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 144 of 638

Enclosure 2, Volume 13, Rev. 0, Page 145 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, 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.

[ The Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of [18 months]. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 for DGs 1A-A performing the Surveillance in MODE 1 or 2 is further amplified to allow 5 and 1B-B 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, and 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 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-35 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 145 of 638

Enclosure 2, Volume 13, Rev. 0, Page 146 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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 the assessment. Credit may be taken for unplanned events that satisfy this SR.

19 5

SR 3.8.1.20 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 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9). 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

1 2

2. FSAR, Chapter [8].

U 0

3. Regulatory Guide 1.9, Rev. 3. 1 1 2
4. FSAR, Chapter [6].

U

5. FSAR, Chapter [15]. 1 2 U

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-36 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 146 of 638

Enclosure 2, Volume 13, Rev. 0, Page 147 of 638 AC Sources - Operating B 3.8.1 BASES REFERENCES (continued)

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.

1

10. Regulatory Guide 1.137, Rev. [ ], [date].

10 11. ASME Code for Operation and Maintenance of Nuclear Power 1 Plants. ANSI C84.1, Voltage Ratings for Electric Power Systems and Equipment (60 Hz)

12. IEEE Standard 308-1978. 1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.1-37 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 147 of 638

Enclosure 2, Volume 13, Rev. 0, Page 148 of 638 AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and 1 alternate(s)), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

1 INSERT 1 The onsite Class 1E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

INSERT 2 Offsite power is supplied to the unit switchyard(s) from the transmission 1 network by [two] transmission lines. From the switchyard(s), two electrically and physically separated circuits provide AC power, through

[step down station auxiliary transformers], to the 4.16 kV ESF buses. A detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the FSAR, Chapter [8] (Ref. 2). 1 2 6.9 kV Shutdown Boards U An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus(es). 1 INSERT 3 Certain required unit loads are returned to service in a predetermined 1 sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution System. Within [1] minute after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service via the load sequencer.

6.9 kV Shutdown Board The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs [11] and [12] are dedicated to ESF buses [11]

1 INSERT 4 and [12], respectively. A DG starts automatically on a safety injection (SI)

, or low steam line pressure signal (i.e., low pressurizer pressure or high containment pressure ,

signals) or on an [ESF bus degraded voltage or undervoltage signal] 2 INSERT 5 (refer to LCO 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start 6.9 kV Shutdown Board Instrumentation"). After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus INSERT 5 undervoltage or degraded voltage, independent of or coincident with an 1 SI signal. The DGs will also start and operate in the standby mode 6.9 kV Shutdown Board without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, [a sequencer/an undervoltage signal] strips nonpermanent 2 a loss-of-voltage signal SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 148 of 638

Enclosure 2, Volume 13, Rev. 0, Page 149 of 638 B 3.8.1 1

INSERT 1 The onsite Class 1E AC Electrical Power Distribution System is divided into two redundant and independent load groups with two 6.9 kV Shutdown Boards in each load group. Each 6.9 kV Shutdown Board has a connection to a preferred offsite power source and a DG. The 6.9 kV Shutdown Boards in a load group (i.e., 1A-A and 2A-A, or 1B-B and 2B-B) are normally powered by the same offsite power circuit. Each 6.9 kV Shutdown Board can also be powered by a dedicated DG. Two DGs associated with one load group can provide all safety related functions to mitigate a loss of coolant accident (LOCA) in one unit and safely shut down the other unit. The Train A and Train B ESF systems each provide for the minimum safety functions necessary to shut down the plant and maintain it in a safe shutdown condition.

The Unit 2 core cooling systems and containment systems (e.g., Safety Injection (SI), Auxiliary Feedwater (AFW), Residual Heat Removal (RHR), Centrifugal Charging pump, Containment Spray, and Air Return System (ARS) fan) are unitized (not shared with Unit 1) and are powered from 6.9 kV Shutdown Boards 2A-A and 2B-B. However, some safety-related systems (e.g.,

Essential Raw Cooling Water (ERCW), Component Cooling Water (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVS), and Control Room Air-Conditioning (CRACS)) are shared with Unit 1. The AC sources for these loads are distributed across all four 6.9 kV Shutdown Boards. Therefore, two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System and a separate and independent DG for each 6.9 kV Shutdown Board ensure the availability of power to each of these systems.

Insert Page B 3.8.1-1a Enclosure 2, Volume 13, Rev. 0, Page 149 of 638

Enclosure 2, Volume 13, Rev. 0, Page 150 of 638 B 3.8.1 1

INSERT 2 The offsite power distribution system consists of two 161 kV buses supplied by eight 161 kV feeders and two 500 kV buses supplied by five 500 kV feeders. The output of the Unit 1 main generator is fed to the 500 kV buses and the output of the Unit 2 main generator is fed to the 161 kV buses. The output of each unit's main generator is also capable of supplying power to an offsite circuit (via the Unit Station Service Transformers (USSTs)) with a Generator Circuit Breaker (GCB) providing isolation between the main generator and the main bank transformers.

When the main generator is not operating, the main bank transformers function as step down transformers and supply electrical power from the grid to the USSTs.

Offsite power can also be supplied by the Common Station Service Transformers (CSSTs) via the 6.9 kV Start Buses and 6.9 kV Unit Boards. Offsite power will normally be supplied from the USSTs to the 6.9 kV Shutdown Boards via the 6.9 kV Unit Boards, and will automatically transfer at least one power supply to an alternate power supply (CSST A or CSST C) on a trip of the Power Circuit Breakers (PCBs). CSST C is the alternate power source for 6.9 kV Shutdown Boards 1A-A and 2A-A, and CSST A is the alternate power source for 6.9 kV Shutdown Boards 1B-B and 2B-B. (CSST B is a spare transformer with two sets of secondary windings that can be used to supply a total of two Start Buses for CSST A and/or CSST C, with each Start Bus on a separate CSST B secondary winding.) Therefore, two electrically and physically separated circuits provide AC power through a combination of the USSTs and/or CSSTs to the 6.9 kV Shutdown Boards. Each offsite circuit is capable of providing power to one train of ESF loads.

1 INSERT 3 (beginning at the switchyard) to one load group of Class 1E 6.9 kV Shutdown Boards (ending at the supply side of the normal or alternate supply circuit breaker) 1 INSERT 4 DGs 1A-A, 1B-B, 2A-A, and 2B-B are separate and independent and are dedicated to 6.9 kV Shutdown Boards 1A-A, 1B-B, 2A-A, and 2B-B, respectively. Each diesel generator set consists of two diesel engines in tandem driving a common generator with a normal synchronous speed of approximately 900 rpm.

1 INSERT 5 a 6.9 kV Shutdown Board degraded voltage or loss-of-voltage signal Insert Page B 3.8.1-1b Enclosure 2, Volume 13, Rev. 0, Page 150 of 638

Enclosure 2, Volume 13, Rev. 0, Page 151 of 638 AC Sources - Operating B 3.8.1 BASES BACKGROUND (continued) 6.9 kV Shutdown Board 6.9 kV Shutdown Board loads from the ESF bus. When the DG is tied to the ESF bus, loads are 1 sequence timers then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and 3 individual starting signals to motor breakers to prevent overloading the DG by automatic load application.

6.9 kV Shutdown Boards In the event of a loss of preferred power, the ESF electrical loads are 1 automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss of coolant accident (LOCA). 1 Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Within 2 1 INSERT 6 [1] minute after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service. 1 INSERT 7 automatic and permanently connected Ratings for Train A and Train B DGs satisfy the requirements of 1 4400 Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG is [7000] kW with [10]% overload permissible for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 2 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The ESF loads that are powered from the 4.16 kV ESF 1 buses are listed in Reference 2. 6.9 kV Shutdown Boards U 1 APPLICABLE The initial conditions of DBA and transient analyses in the FSAR, SAFETY Chapter [6] (Ref. 4) and Chapter [15] (Ref. 5), assume ESF systems are 2 ANALYSES OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS);

and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon 4 meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during Accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC power and
b. A worst case single failure.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 151 of 638

Enclosure 2, Volume 13, Rev. 0, Page 152 of 638 B 3.8.1 2

INSERT 6 the required time interval (UFSAR Table 8.3.1-2) 1 INSERT 7 the 1A-A, 1B-B, 2A-A and 2B-B Insert Page B 3.8.1-2 Enclosure 2, Volume 13, Rev. 0, Page 152 of 638

Enclosure 2, Volume 13, Rev. 0, Page 153 of 638 AC Sources - Operating B 3.8.1 BASES LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Electrical Power System and separate and independent 1 6.9kV Shutdown Board DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit.

[ In addition, one required automatic load sequencer per train must be 2 OPERABLE. ]

qualified physically independent, Each offsite circuit must be capable of maintaining rated frequency and 1 voltage, and accepting required loads during an accident, while 1

connected to the ESF buses.

6.9kV Shutdown Boards INSERT 8 [ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied 1 from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. Offsite circuit #2 consists of the Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201, powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

6.9kV Shutdown Board Each DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus 1 undervoltage. This will be accomplished within [10] seconds. Each DG 2 must also be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power 6.9kV Shutdown Board can be restored to the ESF buses. These capabilities are required to be 1 met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby with the engine at ambient conditions.

Additional DG capabilities must be demonstrated to meet required 5 Surveillance, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, [including tripping of nonessential loads,] is a 2 required function for DG OPERABILITY.

The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For the DGs, separation and independence are complete.

For the offsite AC sources, separation and independence are to the 1 extent practical. A circuit may be connected to more than one ESF bus, with fast transfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is not connected to an ESF bus is required to have OPERABLE fast transfer interlock mechanisms to at least two ESF buses to support OPERABILITY of that circuit.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 153 of 638

Enclosure 2, Volume 13, Rev. 0, Page 154 of 638 B 3.8.1 1

INSERT 8 The minimum required switchyard voltages are determined by evaluation of plant accident loading and the associated voltage drops between the transmission network and these loads.

These minimum voltage values are provided to TVAs Transmission Operations for use in system studies to support operation of the transmission network in a manner that will maintain the necessary voltages. Transmission Operations is required to notify SQN Operations if it is determined that the transmission network may not be able to support accident loading or shutdown operations as required by 10 CFR 50, Appendix A, GDC-17. Any offsite power circuits supplied by the transmission network that are not able to support accident loading or shutdown operations are inoperable.

The USSTs utilize auto load tap changers to provide the required voltage response for accident loading. The load tap changer associated with a USST is required to be functional and in "automatic" for the USST to supply power to a 6.9 kV Unit Board.

Each required offsite circuit is that combination of power sources described below that are either connected to the Class 1E AC Electrical Power Distribution System, or is available to be connected to the Class 1E AC Electrical Power Distribution System through automatic transfer at the 6.9 kV Unit Boards.

The following offsite power configurations meet the requirements of the LCO:

1. Two offsite circuits consisting of a AND b (no board transfers required; a loss of either circuit will not prevent the minimum safety functions from being performed):
a. From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C), and CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
b. From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B), and CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

Insert Page B 3.8.1-3a Enclosure 2, Volume 13, Rev. 0, Page 154 of 638

Enclosure 2, Volume 13, Rev. 0, Page 155 of 638 B 3.8.1 INSERT 8 (Continued)

2. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.2)(b), or a.2) to b.1)(a) on a loss of USSTs 1A and 1B, OR relies on automatic transfer from alignment a.3) to b.2)(a), or a.4) to b.1)(b) on a loss of USSTs 2A and 2B):
a. Normal power source alignments
1) From the 500 kV switchyard through USST 1A to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B);
2) From the 500 kV switchyard through USST 1B to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C);
3) From the 161 kV switchyard through USST 2A to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B); AND
4) From the 161 kV switchyard through USST 2B to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C).
b. Alternate power source alignments
1) From the 161 kV transmission network, through:

(a) CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND (b) CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); OR

2) From the 161 kV transmission network, through:

(a) CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B); AND (b) CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

3. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.1) and b.2) on a loss of the Unit 2 USSTs; a loss of alignment a.2) or a.3) will not prevent the minimum safety functions from being performed):
a. Normal power source alignments
1) From the 161 kV switchyard through USST 2A to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B), and USST 2B to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C);
2) From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND Insert Page B 3.8.1-3b Enclosure 2, Volume 13, Rev. 0, Page 155 of 638

Enclosure 2, Volume 13, Rev. 0, Page 156 of 638 B 3.8.1 INSERT 8 (Continued)

3) From the 161 kV transmission network, through CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).
b. Alternate power source alignments
1) From the 161 kV transmission network, through CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
2) From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B).
4. Two offsite circuits consisting of a AND b (relies on automatic transfer from alignment a.1) to b.1) and b.2) on a loss of the Unit 1 USSTs; a loss of alignment a.2) or a.3) will not prevent the minimum safety functions from being performed):
a. Normal power source alignments
1) From the 500 kV switchyard through USST 1A to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B), and USST 1B to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C);
2) From the 161 kV transmission network, through CSST A (winding Y) to Start Bus 2A to 6.9 kV Shutdown Board 2B-B (through 6.9 kV Unit Board 2C); AND
3) From the 161 kV transmission network, through CSST C (winding X) to Start Bus 2B to 6.9 kV Shutdown Board 2A-A (through 6.9 kV Unit Board 2B).
b. Alternate power source alignments
1) From the 161 kV transmission network, through CSST A (winding X) to Start Bus 1A to 6.9 kV Shutdown Board 1B-B (through 6.9 kV Unit Board 1C); AND
2) From the 161 kV transmission network, through CSST C (winding Y) to Start Bus 1B to 6.9 kV Shutdown Board 1A-A (through 6.9 kV Unit Board 1B).

Other offsite power configurations are possible using different combinations of available USSTs and CSSTs, as long as the alignments are consistent with the analyzed configurations, and the alignments comply with the requirements of GDC 17.

Insert Page B 3.8.1-3c Enclosure 2, Volume 13, Rev. 0, Page 156 of 638

Enclosure 2, Volume 13, Rev. 0, Page 157 of 638 AC Sources - Operating B 3.8.1 BASES APPLICABILITY The AC sources [and sequencers] are required to be OPERABLE in 2 MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 To ensure a highly reliable power source remains with one offsite circuit for reasons other inoperable, it is necessary to verify the OPERABILITY of the remaining 5 than Condition C required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered. 5 E


REVIEWERS NOTE----------------------------------- 6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 157 of 638

Enclosure 2, Volume 13, Rev. 0, Page 158 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.2 a Unit 2 6.9 kV Shutdown Board Required Action A.2, which only applies if the train cannot be powered 5 from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

These features are powered from the redundant AC electrical power train.

This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

6.9 kV Shutdown Board 2A-A or 2B-B 5

a. The train has no offsite power supplying it loads and
b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit 5 inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

a Unit 2 6.9 kV Shutdown Board Discovering no offsite power to one train of the onsite Class 1E Electrical 5 Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution 1 System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 158 of 638

Enclosure 2, Volume 13, Rev. 0, Page 159 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. 1 AC Electrical Power The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.1 INSERT 9 To ensure a highly reliable power source remains with an inoperable DG, 5 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.


REVIEWERS NOTE----------------------------------- 6 The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite (s) power, during the period that a DG is inoperable, does not result in a 5 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG. 5 SEQUOYAH UNIT 2 (s) Revision XXX Westinghouse STS B 3.8.1-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 159 of 638

Enclosure 2, Volume 13, Rev. 0, Page 160 of 638 B 3.8.1 5

INSERT 9 DG 1A-A, DG 1B-B, DGs 1A-A and 2A-A, or DGs 1B-B and 2B-B Insert Page B 3.8.1-6 Enclosure 2, Volume 13, Rev. 0, Page 160 of 638

Enclosure 2, Volume 13, Rev. 0, Page 161 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists and 5
b. A required feature on the other train (Train A or Train B) is inoperable.

or more DGs in a train 5

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

or more DGs in a train Discovering one required DG inoperable coincident with one or more 5 inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is Acceptable because it minimizes risk while 4 allowing time for restoration before subjecting the unit to transients associated with shutdown.

s AC Electrical Power In this Condition, the remaining OPERABLE DG and offsite circuits are 1 adequate to supply electrical power to the onsite Class 1E Distribution 5 System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the J INSERT 10 failure is repaired, the common cause failure no longer exists, and 5 Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 161 of 638

Enclosure 2, Volume 13, Rev. 0, Page 162 of 638 B 3.8.1 5

INSERT 10 if one or more DG(s) in Train A and Train B are inoperable Insert Page B 3.8.1-7 Enclosure 2, Volume 13, Rev. 0, Page 162 of 638

Enclosure 2, Volume 13, Rev. 0, Page 163 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

(s) 5 In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will 2 continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to 2 confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(s) AC Electrical Power 5

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution 7 day System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

INSERT 11 5 C.1 and C.2 E 5 E E Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 163 of 638

Enclosure 2, Volume 13, Rev. 0, Page 164 of 638 B 3.8.1 5

INSERT 11 C.1, C.2, and C.3 Condition C is entered for an offsite circuit inoperable solely due to an inoperable power source to 6.9 kV Shutdown Board 1A-A or 1B-B. Required Action C.1 verifies the OPERABILITY of the remaining offsite circuit within an hour of the inoperability and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Since the Required Action only specifies "perform," a failure of the SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

The Completion Time for Required Action C.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. 6.9 kV Shutdown Board 1A-A or 1B-B has no offsite power; and
b. A required feature on the other train is inoperable.

If at any time during the existence of Condition C a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

A Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptable, because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The remaining OPERABLE offsite circuit and DGs are adequate to support these functions. The Completion Time takes into account the component OPERABILITY of the remaining redundant feature(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition C for a period of 7 days. With one offsite circuit inoperable, the reliability of the functions is degraded. The potential for the loss of offsite power to the redundant feature(s) is increased, with the attendant potential for a challenge to their safety functions.

The required offsite circuit must be returned to OPERABLE status within 7 days, or the support function for the associated required feature is considered inoperable. At that time, the required feature must be declared inoperable and the appropriate Conditions must be entered. The 7 days Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required feature(s), a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

Insert Page B 3.8.1-8a Enclosure 2, Volume 13, Rev. 0, Page 164 of 638

Enclosure 2, Volume 13, Rev. 0, Page 165 of 638 B 3.8.1 5

INSERT 11 (Continued)

D.1, D.2, D.3, and D.4 To ensure a highly reliable power source remains with an inoperable DG to a Unit 1 6.9 kV Shutdown Board, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. Required Action D.1 verifies the OPERABILITY of the required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must be entered.

Required Action D.2 is intended to provide assurance that a loss of offsite power, during the period that an LCO 3.8.1.d DG is inoperable, does not result in a complete loss of the safety functions.

The Completion Time for Required Action D.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG to 6.9 kV Shutdown Board 1A-A or 1B-B exists; and
b. A redundant feature in the same system is inoperable.

If at any time during the existence of Condition D (one DG to 6.9 kV Shutdown Board 1A-A or 1B-B) a redundant feature in the same system subsequently becomes inoperable, this Completion Time begins to be tracked. The four hour Completion Time is acceptable, because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to support the functions. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the component OPERABILITY of the remaining redundant feature(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

D.3.1 and D.3.2 Required Action D.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG(s), SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on another DG, the other DG would be declared inoperable, and upon discovery, Condition J of LCO 3.8.1 would be entered, if one or more DG(s) in Train A and Train B are inoperable. Otherwise, if the inoperability exists on the other DG in the same train, the other DG would be declared inoperable upon discovery, Condition B would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action D.3.1 is satisfied.

If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DGs, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

Insert Page B 3.8.1-8b Enclosure 2, Volume 13, Rev. 0, Page 165 of 638

Enclosure 2, Volume 13, Rev. 0, Page 166 of 638 B 3.8.1 5

INSERT 11 (Continued)

Operation may continue in Condition D for a period of 7 days. With one Unit 2 DG inoperable, the reliability of the respective function is degraded. The potential for the loss of a DG to the redundant feature(s) is increased, with the attendant potential for a challenge to respective safety function.

The required DG must be returned to OPERABLE status within 7 days, or the support function for the associated required feature is considered inoperable. At that time, the required feature must be declared inoperable and the appropriate Conditions must be entered. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required feature(s), a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

Insert Page B 3.8.1-8c Enclosure 2, Volume 13, Rev. 0, Page 166 of 638

Enclosure 2, Volume 13, Rev. 0, Page 167 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

E The Completion Time for Required Action C.1 is intended to allow the 5 operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and
b. A required feature is inoperable.

E 5

If at any time during the existence of Condition C (two offsite circuits inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

E According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This level of 5 degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable.

However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and
b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC 5 sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 167 of 638

Enclosure 2, Volume 13, Rev. 0, Page 168 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If two offsite sources are restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, power operation continues in accordance with Condition A.

or Condition C, as applicable 5 F F 5

D.1 and D.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-F energization. Therefore, the Required Actions of Condition D are modified by a Note to indicate that when Condition D is entered with no 5

6.9 kV Shutdown AC source to any train, the Conditions and Required Actions for F Board 2A-A or 2B-B LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition D to provide requirements for the loss of F

to 6.9 kV Shutdown one offsite circuit and one DG, without regard to whether a train is de-Board 2A-A or 2B-B energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D 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 />.

F F 5 In Condition D, 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 E

higher than that in Condition C (loss of both required offsite circuits). This 5 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, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

INSERT 12 J

E.1 one or more Train A DG(s) and one or more Train B DG(s) insufficient 5

With Train A and Train B DGs inoperable, there are no remaining standby available to power AC sources. Thus, with an assumed loss of offsite electrical power, an entire load group insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 168 of 638

Enclosure 2, Volume 13, Rev. 0, Page 169 of 638 B 3.8.1 5

INSERT 12 G.1 and H.1 In Conditions G and H, individual redundancy is lost in the offsite electrical power system for one unit and the onsite AC electrical power system for the other unit. Since Conditions B and C are entered concurrent with entry into Condition G, and Conditions A and D are entered concurrent with entry into Condition H, the Required Actions of Conditions B and C (or Conditions A and D) provide the appropriate compensatory measures to ensure the onsite and offsite power sources are either restored to an OPERABLE status, or the associated required features are declared inoperable, thereby requiring entry into the appropriate Conditions associated with the associated feature's LCO. The Completion Times of Required Actions G.1 and H.1 are consistent with the Completion Times of Required Actions C.3 and D.4. If, while in Condition G or H, a redundant required feature is determined to be inoperable, the required feature(s) would be declared inoperable at the Completion Times specified in Conditions A, B, C, or D, as applicable.

I.1 and I.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition I are modified by a Note to indicate that when Condition I is entered with no AC source to 6.9 kV Shutdown Board 1A-A or 1B-B, the Conditions and Required Actions for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition I to provide requirements for the loss of one offsite power source and one DG, without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized 6.9 kV Shutdown Board.

In Condition I, individual redundancy is lost in the offsite electrical power system and the onsite AC electrical power system. Concurrent with entry into Condition I, entry into Condition C (inoperable offsite power source) and Condition D (inoperable DG) are required. The Required Actions of Conditions C and D ensure the remaining offsite circuit and DGs are OPERABLE and that required features with no offsite or onsite power sources are declared inoperable when its redundant required feature is inoperable within the Completion Times of Required Actions C.2 and D.2.

Insert Page B 3.8.1-10 Enclosure 2, Volume 13, Rev. 0, Page 169 of 638

Enclosure 2, Volume 13, Rev. 0, Page 170 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

In this Condition, According to Reference 6, with both DGs inoperable, operation may 5 continue for a period that should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

, consistent with the guidance provided in Reference 6 5

[ F.1 5 The sequencer(s) is an essential support system to [both the offsite circuit and the DG associated with a given ESF bus]. [Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

Therefore, loss of an [ESF bus sequencer] affects every major ESF system in the [division]. The [12] hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event and thereby causes its failure. Also implicit in the Note, is that the Condition is not applicable to any train that does not have a sequencer. ]

K K G.1 and G.2 5 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-11 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 170 of 638

Enclosure 2, Volume 13, Rev. 0, Page 171 of 638 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

L.1 and M.1 H.1 5 s L and M Condition H corresponds to a level of degradation in which all redundancy cannot be assured in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS 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 and Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as 1 addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output 6900 2 voltage of [3740] V is 90% of the nominal 4160 V output voltage. This 6210 10 value, which is specified in ANSI C84.1 (Ref. 11), allows for voltage drop 1 6600 to the terminals of 4000 V motors whose minimum operating voltage is 1 specified as 90% or 3600 V. It also allows for voltage drops to motors 1 5940 and other equipment down through the 120 V level where minimum 7260 operating voltage is also usually specified as 90% of name plate rating.

The specified maximum steady state output voltage of [4756] V is equal 2 6600 to the maximum operating voltage specified for 4000 V motors. It 1 6600 ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating 1 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 7 day Frequency is 7 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-12 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 171 of 638

Enclosure 2, Volume 13, Rev. 0, Page 172 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 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 1 for SR 3.8.1.2 and Note for SR 3.8.1.7) 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.

the

[ In order to reduce stress and wear on diesel engines, some s

manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are 2 gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only applicable when such modified start procedures are recommended by the manufacturer. ]

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-13 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 172 of 638

Enclosure 2, Volume 13, Rev. 0, Page 173 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.7 requires that the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter [15] (Ref. 5). 2 The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described above is used. If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies.

Since SR 3.8.1.7 requires a 10 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.

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 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while 7 minimizing degradation resulting from testing.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-14 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 173 of 638

Enclosure 2, Volume 13, Rev. 0, Page 174 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) has an allowable Although no power factor requirements are established by this SR, the 1

rating 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 2 an operational limitation [to ensure circulating currents are minimized].

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

[ The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3).

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients, because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 engine-mounted day This SR provides verification that the level of fuel oil in the day tank [and 5 2

engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of DG operation at full load plus 10%.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-15 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 174 of 638

Enclosure 2, Volume 13, Rev. 0, Page 175 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility 7

operators would be aware of any large uses of fuel oil during this period.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the engine-mounted day fuel oil day [and engine mounted] tanks eliminates the necessary 5 2 environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. [ The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 10). This SR is for preventative maintenance. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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Enclosure 2, Volume 13, Rev. 0, Page 176 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

SR 3.8.1.6 the storage system to the This Surveillance demonstrates that each required fuel oil transfer pump engine-mounted day operates and transfers fuel oil from its associated storage tank to its 1 associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 11); however, the design of fuel transfer systems is such that pumps operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [and engine 7 mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.1.7 See SR 3.8.1.2.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-17 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 176 of 638

Enclosure 2, Volume 13, Rev. 0, Page 177 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 2

[ SR 3.8.1.8 1

INSERT 13 Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

[ The [18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, 7 the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

two s 1 for the 2A, 2B, 2C, This SR is modified by a Note. The reason for the Note is that, during 5 and 2D Unit Boards operation with the reactor critical, performance of this SR 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.] 2 Credit may be taken for unplanned events that satisfy this SR.

INSERT 14 5 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-18 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 177 of 638

Enclosure 2, Volume 13, Rev. 0, Page 178 of 638 B 3.8.1 1

INSERT 13 Transfer of the power supply to each 6.9 kV Unit Board from the normal supply to the alternate supply demonstrates the OPERABILITY of the alternate supply to power the shutdown loads.

This SR is modified by two Notes.

1 INSERT 14 Note 2 specifies that transfer capability is only required to be met for 6.9 kV Unit Boards that require normal and alternate power supplies. When both load groups are being supplied power by the USSTs, only the 6.9 kV Unit Boards associated with one load group are required to have normal and alternate power supplies. Therefore, only one CSST is required to be OPERABLE and available as an alternate power supply. Manual transfers between the normal supply and the alternate supply are also required to meet the SR. However, delayed access to an offsite circuit is not credited in the accident analysis.

Insert Page B 3.8.1-18 Enclosure 2, Volume 13, Rev. 0, Page 178 of 638

Enclosure 2, Volume 13, Rev. 0, Page 179 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load 1 without exceeding predetermined voltage and frequency and while (600kw) maintaining a specified margin to the overspeed trip. [For this unit, the 2

single load for each DG and its horsepower rating is as follows:] This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus, or
b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

Consistent with Regulatory Guide 1.9 3 As required by IEEE-308 (Ref. 12), the load rejection test is acceptable if 1 the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. [ The

[18 month] Frequency is consistent with the recommendation of 7

Regulatory Guide 1.108 (Ref. 9).

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

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Enclosure 2, Volume 13, Rev. 0, Page 180 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE----------------------------------- 6 Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

for DGs 2A-A and 2B-B This SR is modified by two Notes. The reason for Note 1 is that during 5 operation with the reactor critical, performance of this SR 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with 0.89 offsite power, testing should be performed at a power factor of [0.9]. 2 This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain 0.89 conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage 0.89 is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high.

0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be 0.89 2 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-20 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 180 of 638

Enclosure 2, Volume 13, Rev. 0, Page 181 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

[ The [18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 9) and is intended to be consistent with expected fuel cycle lengths. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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Enclosure 2, Volume 13, Rev. 0, Page 182 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

for DGs 2A-A and 2B-B This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could 5 cause perturbation 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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. Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This 2 power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, 0.89 however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is 0.89 high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high.

0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be 0.89 2 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-22 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 182 of 638

Enclosure 2, Volume 13, Rev. 0, Page 183 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE----------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG autostart time of [10] seconds is derived from requirements of the 2 accident analysis to respond to a design basis large break LOCA. 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 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-23 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 183 of 638

Enclosure 2, Volume 13, Rev. 0, Page 184 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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.

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is 7 intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge for DGs 2A-A and 2B-B safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the 5 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, and 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 the assessment.

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

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Enclosure 2, Volume 13, Rev. 0, Page 185 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.8.1.12 2 This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time

([10] seconds) from the design basis actuation signal (LOCA signal) and 2 operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.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 Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] 7 Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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Enclosure 2, Volume 13, Rev. 0, Page 186 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

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 5 for DGs 2A-A and 2B-B 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, and 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 the assessment. ] 2 Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic 5 trips are all automatic trips except: , or both

a. Engine overspeed; and
b. Generator differential current;

[ c. Low lube oil pressure; 2

d. High crankcase pressure; and
e. Start failure relay.]

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Enclosure 2, Volume 13, Rev. 0, Page 187 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The noncritical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

[ The [18 month] Frequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when 7 performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service. This for DGs 2A-A restriction from normally performing the Surveillance in MODE 1 or 2 is 5 and 2B-B further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

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Enclosure 2, Volume 13, Rev. 0, Page 188 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, [2] hours of which is 2 at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

[ The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is 7

intended to be consistent with expected fuel cycle lengths.

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

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Enclosure 2, Volume 13, Rev. 0, Page 189 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during for DGs 2A-A operation with the reactor critical, performance of this Surveillance could 5 and 2B-B 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 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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. Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This 2 power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, 0.89 however, Note 3 allows the Surveillance to be conducted as a power factor other than [0.9]. These conditions occur when grid voltage is 0.89 high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high.

0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on 2 the emergency busses. In other circumstances, the grid voltage may be 0.89 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such 0.89 cases, the power factor shall be maintained close as practicable to [0.9]

without exceeding the DG excitation limits.

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Enclosure 2, Volume 13, Rev. 0, Page 190 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.15 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

[10] seconds. The [10] second time is derived from the requirements of 2 the accident analysis to respond to a design basis large break LOCA.

[ The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5). 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load 2 conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-30 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 190 of 638

Enclosure 2, Volume 13, Rev. 0, Page 191 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset.

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

for DGs 2A-A This restriction from normally performing the Surveillance in MODE 1 or 2 5 and 2B-B is further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-31 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 191 of 638

Enclosure 2, Volume 13, Rev. 0, Page 192 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.8.1.17 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads 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 [18 month] Frequency is consistent with the recommendations of 5 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note. The reason for the Note is that performing 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 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 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-32 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 192 of 638

Enclosure 2, Volume 13, Rev. 0, Page 193 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and 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 5

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

17 5

SR 3.8.1.18 Under accident [and loss of offsite power] conditions loads are load sequence sequentially connected to the bus by the [automatic load sequencer]. The 2 timers sequencing logic controls the permissive and starting signals to motor 5

breakers to prevent overloading of the DGs due to high motor starting 2

currents. The [10]% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses. 1 6.9 kV Shutdown Boards

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is 7 intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-33 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 193 of 638

Enclosure 2, Volume 13, Rev. 0, Page 194 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

for DGs 2A-A This restriction from normally performing the Surveillance in MODE 1 or 2 5 and 2B-B is further amplified to allow 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, and 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 Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 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 the Surveillance is 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.


REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 6
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

18 5

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-34 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 194 of 638

Enclosure 2, Volume 13, Rev. 0, Page 195 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, 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.

[ The Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of [18 months]. 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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 for DGs 2A-A performing the Surveillance in MODE 1 or 2 is further amplified to allow 5 and 2B-B 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, and 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 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-35 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 195 of 638

Enclosure 2, Volume 13, Rev. 0, Page 196 of 638 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 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 the assessment. Credit may be taken for unplanned events that satisfy this SR.

19 5

SR 3.8.1.20 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 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9). 7 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

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.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

1 2

2. FSAR, Chapter [8].

U 0

3. Regulatory Guide 1.9, Rev. 3. 1 1 2
4. FSAR, Chapter [6].

U

5. FSAR, Chapter [15]. 1 2 U

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-36 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 196 of 638

Enclosure 2, Volume 13, Rev. 0, Page 197 of 638 AC Sources - Operating B 3.8.1 BASES REFERENCES (continued)

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.

1

10. Regulatory Guide 1.137, Rev. [ ], [date].

10 11. ASME Code for Operation and Maintenance of Nuclear Power 1 Plants. ANSI C84.1, Voltage Ratings for Electric Power Systems and Equipment (60 Hz)

12. IEEE Standard 308-1978. 1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.1-37 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 197 of 638

Enclosure 2, Volume 13, Rev. 0, Page 198 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Discussions regarding load sequencers have been deleted, because SQN does not use load sequencers. Each load is sequenced with the use of its associated time delay relay.
4. Editorial/grammatical error corrected.
5. Changes have been made to be consistent with changes made to the Specifications.
6. The Reviewer's Note has been deleted, because it is not meant to be retained in the plant specific ITS submittal.
7. ISTS SR 3.8.1.1 through SR 3.8.1.19 Bases provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.8.1.1 through SR 3.8.1.19 under the Surveillance Frequency Control Program.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 198 of 638

Enclosure 2, Volume 13, Rev. 0, Page 199 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 199 of 638

Enclosure 2, Volume 13, Rev. 0, Page 200 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L01 SQN is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below are the descriptions of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 3.8.1.1 ACTION a provides actions for one inoperable offsite circuit and allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable offsite circuit to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION b provides actions for one or both DGs in a train inoperable and allows 7 days to restore the inoperable DG(s) to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION c provides actions for one inoperable offsite circuit and one inoperable DG and allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore at least one of the inoperable AC sources to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION d provides actions for two inoperable offsite circuits and allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore at least one of the inoperable offsite circuits to OPERABLE status before requiring the unit to be shut down. CTS 3.8.1.1 ACTION e provides actions for one or two inoperable DGs in both trains and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the inoperable DG(s) in one train to OPERABLE status before requiring the unit to be shut down and cooled down. CTS 3.8.1.1 ACTION f states LCO 3.0.4.b is not applicable to DGs. The ITS ACTIONS are modified by a Note stating LCO 3.0.4.b is not applicable to DGs. ITS 3.8.1 ACTION A provides actions for one inoperable offsite circuit for reasons other than Condition C, and allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable offsite power source to OPERABLE status. ITS 3.8.1 ACTION B provides actions for one inoperable associated unit's DG or both DGs in one train inoperable, and allows 7 days to restore the inoperable DG(s) to OPERABLE status. ITS 3.8.1 ACTION C provides actions for one offsite circuit inoperable solely due to an inoperable offsite power source to an opposite unit's 6.9 kV Shutdown Board, and requires declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the offsite circuit cannot be restored to an OPERABLE status. ITS 3.8.1 ACTION D requires declaration that the affected required feature(s) with no OPERABLE DG are inoperable when its redundant required feature is inoperable in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the DG cannot be restored to an OPERABLE status. ITS 3.8.1 ACTION E requires declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Otherwise, one offsite circuit is required to be restored to an OPERABLE status in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.1 ACTION F provides actions for one associated unit's offsite circuit inoperable concurrent with one associated unit's DG inoperable, and allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore one of the inoperable AC sources to OPERABLE status. ITS ACTION G requires declaring the required feature(s) on the opposite unit's 6.9 kV Shutdown Board with no offsite power available inoperable in 7 days. ITS ACTION H requires declaring the required feature(s) on the opposite unit's 6.9 kV Shutdown Board with no DG available inoperable in 7 days. ITS ACTION I provides actions for one offsite circuit inoperable solely due to an inoperable offsite power source to an opposite unit's 6.9 kV Shutdown Board concurrent with one opposite unit's DG inoperable, and allows 7 days Sequoyah Unit 1 and 2 Page 1 of 4 Enclosure 2, Volume 13, Rev. 0, Page 200 of 638

Enclosure 2, Volume 13, Rev. 0, Page 201 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING to restore one of the inoperable AC sources to OPERABLE status. In addition, a Note modifying ITS ACTION I requires entry into the applicable Conditions and Required Actions of LCO 3.8.9 with no AC power source to an opposite unit's 6.9 kV Shutdown Board. ITS 3.8.1 ACTION J provides actions for one or more Train A and one or more Train B DGs inoperable and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore one Train of DGs to OPERABLE status. ITS 3.8.1 ACTION K requires the unit to be shut down and cooled down if a Required Action and associated Completion Time of Condition A, B, E, F, I, or J is not met. These changes to the CTS provide separate ACTIONS to declare the required features powered from the opposite unit's Class 1E AC Electrical Power Distribution System inoperable as the remedial measures for the inoperable AC sources.

The purpose of the CTS 3.8.1.1 ACTIONS is to limit the time the unit can remain operating with different combinations of inoperable offsite circuits and DGs. The onsite Class 1E AC Electrical Distribution System supplies electrical power to two power trains shared between the two units. The core cooling and containment cooling system loads (e.g., Safety Injection (SI) pumps, Auxiliary Feedwater (AFW) pumps, Residual Heat Removal (RHR) pumps, Centrifugal Charging pumps, Containment Spray pumps, and Air Return System (ARS) fans) are unitized to the respective unit's 6.9 kV Shutdown Boards. However, some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVs), and Control Room HVAC (CRACS)) are shared between the units. The AC sources for the shared loads are distributed across both unit's shutdown boards. Therefore, two qualified offsite circuits and four DGs capable of supplying the onsite Class 1E AC Electrical Distribution System are required to be OPERABLE. However, the impacts of an inoperable offsite power source or DG on an opposite unit's 6.9 kV Shutdown Board differ from the impacts of an inoperable offsite power source or DG on an associated unit's 6.9 kV Shutdown Board, due to the loads powered from the respective board.

For example, with SQN Unit 1 in MODES 1, 2, 3, and 4, 6.9 kV Shutdown Boards 1A-A and 1B-B, and the associated offsite power sources and DGs are required to be OPERABLE to provide electrical power to the ESF systems powered from those boards.

Additionally, 6.9 kV Shutdown Boards 2A-A and 2B-B and associated offsite power sources and DGs are required to be OPERABLE to provide electrical power to any required shared components required for Unit 1. If it is necessary to de-energize 6.9 kV Shutdown Board 2A-A or 2B-B, the redundant shared systems can be aligned prior to de-energizing the shutdown board to ensure no loss of safety function will occur. Upon removing the shutdown board from service, the applicable Conditions and Required Actions for the affected shared system LCOs will be entered and tracked and either the offsite power source or the DG is required to be restored to an OPERABLE status in 7 days.

In the event of an unplanned loss of an offsite power source to an opposite unit's 6.9 kV Shutdown Board, the proposed actions require declaration that the affected required feature(s) with no offsite power available are inoperable when its redundant required feature is inoperable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the affected required feature(s) are declared inoperable in 7 days, if the offsite power source cannot be restored to an OPERABLE status. Similarly, in the event of an unplanned loss of a DG to an opposite unit 6.9 kV Shutdown Board, the proposed actions require declaration that the affected required feature(s) with no OPERABLE DG are inoperable when its redundant required feature is inoperable in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, the affected required feature(s) are declared Sequoyah Unit 1 and 2 Page 2 of 4 Enclosure 2, Volume 13, Rev. 0, Page 201 of 638

Enclosure 2, Volume 13, Rev. 0, Page 202 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING inoperable in 7 days, if the DG cannot be restored to an OPERABLE status. In both cases, the ACTIONS require performance of SR 3.8.1.1 for the required OPERABLE offsite circuit(s) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. These changes are acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation, while providing time to repair inoperable features. If the necessary repairs cannot be made within the established Completion Time, the associated required features are declared inoperable and the applicable Conditions and Required Actions for the affected shared system LCOs are entered and tracked. This change is acceptable because the provided ACTIONS effect restoration of the opposite unit's AC sources commensurate with the importance of maintaining these AC sources capable of supporting the associated unit's required feature(s). This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Tennessee Valley Authority (TVA) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No.

The proposed change relaxes the Required Actions for the opposite unit's offsite AC power sources and DGs. The opposite unit's offsite AC power sources and DGs are required to be OPERABLE to support the associated unit's required features. This change will not affect the probability of an accident, since the offsite AC circuits and DGs are not initiators of any accident sequence analyzed in the Updated Final Safety Analysis Report (UFSAR). Rather, offsite AC power sources and DGs support equipment used to mitigate accidents. The consequences of an analyzed accident will not be significantly increased since the minimum requirements for AC power sources will be maintained to ensure the availability of the required power to mitigate accidents assumed in the UFSAR. Operation in accordance with the proposed TS will ensure that sufficient onsite and offsite AC power sources are OPERABLE as required to support the unit's required features. Therefore, the mitigating functions supported by the onsite and offsite AC power sources will continue to provide the protection assumed by the accident analysis. The integrity of fission product barriers, plant configuration, and operating procedures as described in the UFSAR will not be affected by the proposed changes. Thus, the consequences of previously analyzed accidents will not increase by implementing these changes. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Sequoyah Unit 1 and 2 Page 3 of 4 Enclosure 2, Volume 13, Rev. 0, Page 202 of 638

Enclosure 2, Volume 13, Rev. 0, Page 203 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change relaxes the Required Actions for the opposite unit's offsite AC power sources and DGs. The opposite unit's offsite AC power sources and DGs are required to be OPERABLE to support the associated unit's required features. This change will not physically alter the plant (no new or different type of equipment will be installed). The proposed changes will maintain the minimum requirements for AC power sources to ensure the availability of the equipment required to mitigate accidents assumed in the UFSAR. Therefore, operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in the margin of safety?

Response: No.

The proposed change relaxes the Required Actions for the opposite unit's offsite AC power sources and DGs. The opposite unit's offsite AC power sources and DGs are required to be OPERABLE to support the associated unit's required features. The margin of safety is not affected by this change because the minimum requirements for AC power sources will be maintained to ensure the availability of the required power to shutdown the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Therefore, the proposed changes do not involve a significant reduction in a margin of safety Sequoyah Unit 1 and 2 Page 4 of 4 Enclosure 2, Volume 13, Rev. 0, Page 203 of 638

, Volume 13, Rev. 0, Page 204 of 638 ATTACHMENT 2 ITS 3.8.2, AC SOURCES - SHUTDOWN , Volume 13, Rev. 0, Page 204 of 638

, Volume 13, Rev. 0, Page 205 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 205 of 638

Enclosure 2, Volume 13, Rev. 0, Page 206 of 638 ITS ITS 3.8.2 A01 ELECTRICAL POWER SYSTEMS AC SOURCES - A01 SHUTD0WN LIMITING CONDITION FOR OPERATION LCO 3.8.2 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

qualified LCO 3.8.2.a a. One circuit between the offsite transmission network and the onsite Class 1E distribution M01 system, and Two LA01 LCO 3.8.2.b b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

M02

1. Two diesels driving a common generator, LA01 SR 3.8.2.1 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 SR 3.8.2.1 4. A fuel transfer pump, and
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS 3.8.5 and associated charger. 3.8.10 During movement of irradiated fuel Applicability APPLICABILITY: MODES 5 and 6.

Add proposed ACTIONS Note M03 ACTION: Add proposed ACTION A Note A02 Add proposed Required Action A.1 and Completion Time L01 With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all ACTIONS operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions L02 A and B that could result in loss of required shutdown margin or boron concentration.

Add proposed Required Actions A.2.3 and B.3 and associated Completion Times M04 SURVEILLANCE REQUIREMENTS SR 3.8.2.1 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the L03 performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement SR 3.8.2.1 4.8.1.1.2.a.5), and 4.8.1.1.3.

Note See ITS 3.8.5 Add proposed SR 3.8.2.1 exceptions L04 May 22, 2003 SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. 241, 285 Page 1 of 2 Enclosure 2, Volume 13, Rev. 0, Page 206 of 638

Enclosure 2, Volume 13, Rev. 0, Page 207 of 638 ITS ITS 3.8.2 A01 ELECTRICAL POWER SYSTEMS AC SOURCES - A01 SHUTDOWN LIMITING CONDITION FOR OPERATION LCO 3.8.2 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

qualified LCO 3.8.2.a a. One circuit between the offsite transmission network and the onsite Class 1E distribution M01 system, and Two LA01 LCO 3.8.2.b b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

M02

l. Two diesels driving a common generator, LA01 SR 3.8.2.1 2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank,
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, See ITS 3.8.3 SR 3.8.2.1 4. A fuel transfer pump, and
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS 3.8.5 and associated charger.

3.8.10 During movement of irradiated fuel Applicability APPLICABILITY: MODES 5 and 6.

Add proposed ACTIONS Note M03 A02 ACTION: Add proposed ACTION A Note Add proposed Required Action A.1 and Completion Time L01 With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all ACTIONS operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions L02 A and B that could result in loss of required shutdown margin or boron concentration.

Add proposed Required Actions A.2.3 and B.3 and associated Completion Times M04 SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the SR 3.8.2.1 L03 performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement SR 3.8.2.1 4.8.1.1.2.a.5), and 4.8.1.1.3.

Note See ITS 3.8.5 Add proposed SR 3.8.2.1 exceptions L04 May 22, 2003 SEQUOYAH - UNIT 2 3/4 8-9 Amendment No. 231, 274 Page 2 of 2 Enclosure 2, Volume 13, Rev. 0, Page 207 of 638

Enclosure 2, Volume 13, Rev. 0, Page 208 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.2 does not address the situation when an ESF train is de-energized as a result of the loss of an AC Source. ITS 3.8.2 Required Action A.1 Note requires entry into the applicable Conditions and Required Actions of LCO 3.8.10 when one required train is de-energized as a result of an inoperable offsite circuit. This changes the CTS by directing entry into LCO 3.8.10.

AC Sources are considered a support system to the AC distribution System (ITS 3.8.10). If AC Sources are inoperable such that a distribution subsystem is made inoperable, then ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the AC Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in the event, specific direction to take appropriate ACTIONS for the Distribution System is added (proposed Note to ITS 3.8.2 ACTION A). This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2.a requires one circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown," to be OPERABLE. This changes the CTS by being specific that the circuit be qualified and as to what the required circuit must be capable of powering.

The purpose of CTS 3.8.1.2.a is to ensure the offsite circuit is OPERABLE in order to supply the equipment supported by the onsite Class 1E distribution system. The existing requirement of CTS LCO 3.8.1.2.a for one offsite circuit to be OPERABLE during shutdown conditions is not specific that the circuit be qualified and as to what that circuit must be powering. The requirement in ITS LCO 3.8.2.a specifies that the circuit must be qualified and available to supply power to all equipment required to be OPERABLE in the current plant conditions.

This change is acceptable since the added restrictions conservatively assure the needed offsite circuit is qualified (as described in the Bases) and powering all AC loads required to be OPERABLE. This change is designated as more restrictive because more explicit offsite circuit requirements have been added.

Sequoyah Unit 1 and Unit 2 Page 1 of 6 Enclosure 2, Volume 13, Rev. 0, Page 208 of 638

Enclosure 2, Volume 13, Rev. 0, Page 209 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN M02 CTS 3.8.1.2.b requires two DGs to be OPERABLE. ITS LCO 3.8.2.b requires two DGs capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. This changes the CTS by being specific as to what the required DGs must be capable of powering.

The purpose of CTS 3.8.1.2.b is to ensure the required DGs are OPERABLE.

This change provides an explicit requirement as to what the required DGs must be capable of powering. Similar to the added restrictions for an OPERABLE offsite circuit (refer to DOC M01 above), the DGs required OPERABLE during shutdown conditions by CTS 3.8.1.2.b is not specific as to what the DGs must be powering. The requirements in ITS LCO 3.8.2.b will ensure the OPERABLE DGs are associated with one or more systems, subsystems, or components required to be OPERABLE. This added restriction enforces a level of Technical Specification control which currently is enforced only by administrative procedures. This change is designated as more restrictive because more explicit DG requirements have been added.

M03 CTS 3.8.1.2 is applicable during MODES 5 and 6. ITS 3.8.2 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies. In addition, a Note has been added to the ACTIONS of ITS 3.8.2 that states LCO 3.0.3 is not applicable. This changes the CTS by requiring the AC Sources to be OPERABLE under more conditions than is currently required.

The purpose of CTS 3.8.1.2 is to ensure that sufficient AC Sources are available to mitigate the consequences of an analyzed event during shutdown modes.

This change provides an explicit requirement that the AC Sources must be OPERABLE during the movement of irradiated fuel assemblies. The movement of irradiated fuel assemblies may occur during MODE 5 or 6, however the operations could also occur while the unit is operating if moving fuel only in the spent fuel pool. CTS 3.8.1.1 (ITS 3.8.1) and CTS 3.8.1.2 do not provide the appropriate compensatory actions under this condition. The activity should be suspended immediately when the AC Sources are not available consistent with the immediate actions for CORE ALTERATIONS in the CTS 3.8.1.2 Action; that is the actions in LCO 3.0.3 will not place the unit in a safe condition. This change is acceptable because the proposed Applicability is consistent with the Applicability in the AC Distribution System - Shutdown Specification (CTS 3.8.2.2 and ITS 3.8.10). AC Sources provides the power for the AC Distribution System. This change is designated as more restrictive because the Applicability of the Specification has been expanded.

M04 The CTS 3.8.1.2 ACTION requires the suspension of CORE ALTERATIONS and positive reactivity changes when a required AC Source is inoperable. It does not include an action to restore the inoperable AC Source. ITS 3.8.2 Required Actions A.2.3 and B.3 require the immediate initiation of action to restore the required AC Sources to OPERABLE status. This changes the CTS by adding explicit requirements to restore the inoperable AC Sources to OPERABLE status.

The purpose of ITS 3.8.1.2 Required Actions A.2.3 and B.3 is to place the unit within the requirements of the LCO. When a required offsite circuit or one or more required DG(s) is inoperable, the actions imposed by the CTS 3.8.1.2 Sequoyah Unit 1 and Unit 2 Page 2 of 6 Enclosure 2, Volume 13, Rev. 0, Page 209 of 638

Enclosure 2, Volume 13, Rev. 0, Page 210 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ACTION do not necessarily place the unit in a MODE or other specified condition in which CTS LCO 3.8.1.2 is not applicable. Therefore, proposed ITS 3.8.2 Required Actions A.2.3 and B.3 are being added. These Required Actions implement a requirement to immediately initiate action to restore the required AC Sources to an OPERABLE status. These additional restrictions are consistent with implicit assumptions and will ensure action is immediately taken to restore compliance with the LCO requirements. This change is designated as more restrictive because the Required Actions do not exist in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.2.b requires two DG sets "1A-A and 2A-A or 1B-B and 2B-B" to be OPERABLE each with "two diesels driving a common generator."

ITS LCO 3.8.2.b requires two DGs capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

This changes the CTS by moving the details of the specific DGs that provide power to a train, and that each DG includes "two diesels driving a common generator" from the CTS to the Bases. The discussion of specifying what the DGs must be capable of powering is provided in DOC M02.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE offsite sources and DGs. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION requires the suspension of certain activities when the required AC Source is inoperable.

ITS 3.8.2 provides an alternate Required Action (ITS 3.8.2 Required Action A.1) that allows the declaration of affected required feature(s) with no offsite power available inoperable instead of requiring the specified activities to be suspended.

This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending the specified activities.

Sequoyah Unit 1 and Unit 2 Page 3 of 6 Enclosure 2, Volume 13, Rev. 0, Page 210 of 638

Enclosure 2, Volume 13, Rev. 0, Page 211 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN The purpose of CTS 3.8.1.2 is to ensure the appropriate offsite circuit is OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a loss of offsite power occurring during the repair period. This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending specified activities (i.e., movement of irradiated fuel assemblies).

Since the ITS 3.8.2 circuit OPERABILITY requirements are proposed to require supplying power to all required electrical power distribution subsystems, if one or more subsystems are not powered by an offsite circuit, that circuit is inoperable.

Conservative actions can be assured if all required equipment with offsite power is declared inoperable and the associated ACTIONS of the individual equipment taken (ITS 3.8.2 Required Action A.1). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION specifies the compensatory action for an inoperable required AC Source. One of the compensatory actions is the suspension of CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 does not require suspension of CORE ALTERATIONS.

This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when a required AC source is inoperable.

The purpose of the CTS 3.8.1.2 ACTION to suspend CORE ALTERATIONS is to minimize the possibility of an event that may need the AC source to mitigate the consequences of the event. CORE ALTERATION is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed - it only applies in MODE 6. There is only one accident considered during MODE 6 that involves a CORE ALTERATION: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.2 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.2 Required Action A.2.1 (for an inoperable required offsite circuit) and Required Action B.1 (for one or more inoperable required DG(s)). Therefore, since the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of a AC source is covered by the ITS Required Actions, deletion of the term "CORE ALTERATIONS" is acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 4 of 6 Enclosure 2, Volume 13, Rev. 0, Page 211 of 638

Enclosure 2, Volume 13, Rev. 0, Page 212 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 4.8.1.1.2.a.5. ITS SR 3.8.2.1 has included a similar allowance in the Note to SR 3.8.2.1. However, additional ITS SRs are exempt from being required to be performed. ITS SR 3.8.2.1 states the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, and SR 3.8.1.13 through SR 3.8.1.17. This changes the CTS by not requiring the performance of CTS 4.8.1.1.2.g.1 (ITS SR 3.8.1.9), CTS 4.8.1.1.2.g.2 (ITS SR 3.8.1.10), CTS 4.8.1.1.2.d.4 (ITS SR 3.8.1.11), CTS 4.8.1.1.2.d.6.c) (ITS SR 3.8.1.13), CTS 4.8.1.1.2.g.3 (ITS SR 3.8.1.14), CTS 4.8.1.1.2.g.4 (ITS SR 3.8.1.15), CTS 4.8.1.1.2.d.9 (ITS SR 3.8.1.16) and CTS 4.8.1.1.2.d.10 (ITS SR 3.8.1.17).

The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability.

Currently CTS 4.8.1.1.2.a.5) is not required to be performed (however it must be met). CTS 4.8.1.1.2.g.1 (ITS SR 3.8.1.9) is the DG single largest load reject test, CTS 4.8.1.1.2.g.2 (ITS SR 3.8.1.10) is the DG full load reject test, CTS 4.8.1.1.2.d.4 (ITS SR 3.8.1.11) is the DG start on a loss of offsite power test, CTS 4.8.1.1.2.d.6.c) (ITS SR 3.8.1.13) demonstrates the DG noncritical protective functions are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal, CTS 4.8.1.1.2.g.3 (ITS SR 3.8.1.14) is the DG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run test, CTS 4.8.1.1.2.g.4 (ITS SR 3.8.1.15) is the DG hot restart test, CTS 4.8.1.1.2.d.9 (ITS SR 3.8.1.16) ensures manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored, and CTS 4.8.1.1.2.d.10 (ITS SR 3.8.1.17) is a test of the individual load sequence timers.

These tests normally require the DG to be paralleled with offsite power. This condition (one of two required DGs and the only required offsite source connected) presents a significant risk of a single fault resulting in station blackout. The NRC has previously recognized this in the exception stated in CTS 4.8.1.2. In an effort to consistently address this concern and to avoid potential conflicting Technical Specifications, the Surveillances that would require a DG to be connected to the offsite source or would require disconnection of the required offsite circuit and de-energization of required buses are excepted from performance requirements. The exception does not remove the requirement for the DGs to be capable of performing the particular function. The exception only removes the requirement to demonstrate the capability while that source of power is being relied on to meet the supporting LCO. This change is acceptable since it is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when a DG and the offsite circuit are required to be OPERABLE. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L04 (Category 5 - Deletion of Surveillance Requirements) CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance Sequoyah Unit 1 and Unit 2 Page 5 of 6 Enclosure 2, Volume 13, Rev. 0, Page 212 of 638

Enclosure 2, Volume 13, Rev. 0, Page 213 of 638 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirements 4.8.1.1.2.a.5). ITS SR 3.8.2.1 has included a similar allowance in the Note to SR 3.8.2.1. However, the ITS is exempting SRs from being required to be met, not just exempting them from being performed. ITS SR 3.8.2.1 states the following SRs are not required to be met: SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.18, and SR 3.8.1.19. This changes the CTS by not requiring CTS 4.8.1.1.2.d.5 (ITS SR 3.8.1.12), CTS 4.8.1.1.2.d.6 (ITS SR 3.8.1.18), and CTS 4.8.1.1.2.e (ITS SR 3.8.1.19) to be met. The addition of ITS SR 3.8.1.8 is discussed in ITS 3.8.1 DOC M03.

The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated OPERABLE. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function.

This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.d.5 (ITS SR 3.8.1.12), the ESF actuation signal DG start test, CTS 4.8.1.1.2.d.6 (ITS SR 3.8.1.18), ESF concurrent with loss of offsite power signal test, and CTS 4.8.1.1.2.e (ITS SR 3.8.1.19), the simultaneous DG start test. ITS SR 3.8.1.12 and ITS SR 3.8.1.18 are not required to be met since the ESF signal is not required to be OPERABLE in the MODES or other specified conditions listed in the Applicability of ITS 3.8.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODE 5 and 6. The DGs are required to support the equipment powered from the 6.9 kV shutdown boards. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DG to autostart on an ESF actuation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to start if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.11). Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change is designated as less restrictive because Surveillances that are required in CTS will not be required in the ITS.

Sequoyah Unit 1 and Unit 2 Page 6 of 6 Enclosure 2, Volume 13, Rev. 0, Page 213 of 638

Enclosure 2, Volume 13, Rev. 0, Page 214 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 214 of 638

Enclosure 2, Volume 13, Rev. 0, Page 215 of 638 CTS AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown 3.8.1.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

3.8.1.2.a a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) 1 required by LCO 3.8.10, "Distribution Systems - Shutdown" and 2 Two s s  ;

3.8.1.2.b b. One diesel generator (DG) capable of supplying one train of the 1 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

Applicability APPLICABILITY: MODES 5 and 6, DOC M03 During movement of [recently] irradiated fuel assemblies. 3 ACTIONS


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

DOC M03 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. One required offsite -------------------NOTE--------------------

DOC A02 circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized 6.9 kV Shutdown Board 1

as a result of Condition A.

DOC L01 A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.2-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 215 of 638

Enclosure 2, Volume 13, Rev. 0, Page 216 of 638 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A.2.1 Suspend movement of Immediately 3

[recently] irradiated fuel assemblies.

AND ACTION A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND DOC M04 A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

or more (s)

ACTION B. One required DG B.1 Suspend movement of Immediately 1 inoperable. [recently] irradiated fuel 3 assemblies.

AND ACTION B.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND DOC M04 B.3 Initiate action to restore Immediately required DG to OPERABLE 1 status. (s)

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.2-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 216 of 638

Enclosure 2, Volume 13, Rev. 0, Page 217 of 638 CTS AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.8.1.2.b.2, SR 3.8.2.1 ------------------------------NOTE------------------------------

3.8.1.2.b.4, 4.8.1.2 The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and and 1

[SR 3.8.1.18]. 17 3 For AC sources required to be OPERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources - Operating," with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable. 1 18 19 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.2-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 217 of 638

Enclosure 2, Volume 13, Rev. 0, Page 218 of 638 CTS AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown 3.8.1.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

3.8.1.2.a a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) 1 required by LCO 3.8.10, "Distribution Systems - Shutdown" and 2 Two s s  ;

3.8.1.2.b b. One diesel generator (DG) capable of supplying one train of the 1 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

Applicability APPLICABILITY: MODES 5 and 6, DOC M03 During movement of [recently] irradiated fuel assemblies. 3 ACTIONS


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

DOC M03 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. One required offsite -------------------NOTE--------------------

DOC A02 circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized 6.9 kV Shutdown Board 1

as a result of Condition A.

DOC L01 A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.2-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 218 of 638

Enclosure 2, Volume 13, Rev. 0, Page 219 of 638 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A.2.1 Suspend movement of Immediately 3

[recently] irradiated fuel assemblies.

AND ACTION A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND DOC M04 A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

or more (s)

ACTION B. One required DG B.1 Suspend movement of Immediately 1 inoperable. [recently] irradiated fuel 3 assemblies.

AND ACTION B.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND DOC M04 B.3 Initiate action to restore Immediately required DG to OPERABLE 1 status. (s)

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.2-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 219 of 638

Enclosure 2, Volume 13, Rev. 0, Page 220 of 638 CTS AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.8.1.2.b.2, SR 3.8.2.1 ------------------------------NOTE------------------------------

3.8.1.2.b.4, 4.8.1.2 The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and and 1

[SR 3.8.1.18]. 17 3 For AC sources required to be OPERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources - Operating," with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable. 1 18 19 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.2-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 220 of 638

Enclosure 2, Volume 13, Rev. 0, Page 221 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.
3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 221 of 638

Enclosure 2, Volume 13, Rev. 0, Page 222 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 222 of 638

Enclosure 2, Volume 13, Rev. 0, Page 223 of 638 AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of [recently] irradiated fuel assemblies ensures 2 ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling 2

accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single because failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained 1 within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of result occurrence being significantly reduced or eliminated, and in minimal limitations consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems. reflected in During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 223 of 638

Enclosure 2, Volume 13, Rev. 0, Page 224 of 638 AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and 1 administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.
b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.
d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Two Shutdown," ensures that all required loads are powered from offsite s

power. An OPERABLE DG, associated with a distribution system train 3 required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit s

and DG ensures the availability of sufficient AC sources to operate the 3 unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 2 recently irradiated fuel]).

The qualified offsite circuit must be capable of maintaining rated 6.9 kV shutdown frequency and voltage, and accepting required loads during an accident, boards while connected to the Engineered Safety Feature (ESF) bus(es).

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit. Bases for LCO 3.8.1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 224 of 638

Enclosure 2, Volume 13, Rev. 0, Page 225 of 638 AC Sources - Shutdown B 3.8.2 BASES LCO (continued)

INSERT 1 [ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. The second offsite circuit consists of the 1 Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

s The DG must be capable of starting, accelerating to rated speed and 3 their voltage, and connecting to its respective ESF bus on detection of bus 1 6.9 kV shutdown board undervoltage. This sequence must be accomplished within [10] seconds. 2 The DG must be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power 6.9 kV shutdown can be restored to the ESF buses. These capabilities are required to be 1 boards met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

[ In addition, proper sequencer operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts on the ability to start and 4 maintain energized loads required OPERABLE by LCO 3.8.10. ]

It is acceptable for trains to be cross tied during shutdown conditions, 1 allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide 2 assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available,
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 225 of 638

Enclosure 2, Volume 13, Rev. 0, Page 226 of 638 1

INSERT 1 Each required offsite circuit is that combination of power sources described in the Bases of LCO 3.8.1.

Insert Page B 3.8.2-3 Enclosure 2, Volume 13, Rev. 0, Page 226 of 638

Enclosure 2, Volume 13, Rev. 0, Page 227 of 638 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with offsite power available may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option one or more may involve undesired administrative efforts, the allowance for sufficiently s

conservative actions is made. With the required DG inoperable, the 3 minimum required diversity of AC power sources is not available. It is, therefore, required to suspend movement of [recently] irradiated fuel 2 assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 227 of 638

Enclosure 2, Volume 13, Rev. 0, Page 228 of 638 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are 6.9 kV shutdown modified by a Note to indicate that when Condition A is entered with no board AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must 1 be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.8 is not required to be met since only one offsite 18 circuit is required to be OPERABLE. SR 3.8.1.12 and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to 3

be OPERABLE. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being 19 synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DG(s) that is not required to be operable. 5 This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or 1 6.9 kV shutdown board SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 228 of 638

Enclosure 2, Volume 13, Rev. 0, Page 229 of 638 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued) disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the s

required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during 3 s

periods when the DG and offsite circuit is required to be OPERABLE.

Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES None.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.2-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 229 of 638

Enclosure 2, Volume 13, Rev. 0, Page 230 of 638 AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of [recently] irradiated fuel assemblies ensures 2 ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling 2

accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single because failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained 1 within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of result occurrence being significantly reduced or eliminated, and in minimal limitations consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems. reflected in During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 230 of 638

Enclosure 2, Volume 13, Rev. 0, Page 231 of 638 AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and 1 administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.
b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.
d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Two Shutdown," ensures that all required loads are powered from offsite s

power. An OPERABLE DG, associated with a distribution system train 3 required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit s

and DG ensures the availability of sufficient AC sources to operate the 3 unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 2 recently irradiated fuel]).

The qualified offsite circuit must be capable of maintaining rated 6.9 kV shutdown frequency and voltage, and accepting required loads during an accident, boards while connected to the Engineered Safety Feature (ESF) bus(es).

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit. Bases for LCO 3.8.1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 231 of 638

Enclosure 2, Volume 13, Rev. 0, Page 232 of 638 AC Sources - Shutdown B 3.8.2 BASES LCO (continued)

INSERT 1 [ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. The second offsite circuit consists of the 1 Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

s The DG must be capable of starting, accelerating to rated speed and 3 their voltage, and connecting to its respective ESF bus on detection of bus 1 6.9 kV shutdown board undervoltage. This sequence must be accomplished within [10] seconds. 2 The DG must be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power 6.9 kV shutdown can be restored to the ESF buses. These capabilities are required to be 1 boards met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

[ In addition, proper sequencer operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts on the ability to start and 4 maintain energized loads required OPERABLE by LCO 3.8.10. ]

It is acceptable for trains to be cross tied during shutdown conditions, 1 allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide 2 assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available,
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 232 of 638

Enclosure 2, Volume 13, Rev. 0, Page 233 of 638 1

INSERT 1 Each required offsite circuit is that combination of power sources described in the Bases of LCO 3.8.1.

Insert Page B 3.8.2-3 Enclosure 2, Volume 13, Rev. 0, Page 233 of 638

Enclosure 2, Volume 13, Rev. 0, Page 234 of 638 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with offsite power available may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option one or more may involve undesired administrative efforts, the allowance for sufficiently s

conservative actions is made. With the required DG inoperable, the 3 minimum required diversity of AC power sources is not available. It is, therefore, required to suspend movement of [recently] irradiated fuel 2 assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 234 of 638

Enclosure 2, Volume 13, Rev. 0, Page 235 of 638 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are 6.9 kV shutdown modified by a Note to indicate that when Condition A is entered with no board AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must 1 be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.8 is not required to be met since only one offsite 18 circuit is required to be OPERABLE. SR 3.8.1.12 and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to 3

be OPERABLE. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being 19 synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DG(s) that is not required to be operable. 5 This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or 1 6.9 kV shutdown board SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 235 of 638

Enclosure 2, Volume 13, Rev. 0, Page 236 of 638 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued) disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the s

required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during 3 s

periods when the DG and offsite circuit is required to be OPERABLE.

Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES None.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.2-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 236 of 638

Enclosure 2, Volume 13, Rev. 0, Page 237 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes have been made to be consistent with changes made to the Specifications.
4. Discussions regarding load sequencers have been deleted, because SQN does not use load sequencers. Each load is sequenced with the use of its associated time delay relay.
5. Editorial/grammatical error corrected.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 237 of 638

Enclosure 2, Volume 13, Rev. 0, Page 238 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 238 of 638

Enclosure 2, Volume 13, Rev. 0, Page 239 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 239 of 638

Enclosure 2, Volume 13, Rev. 0, Page 240 of 638 ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Enclosure 2, Volume 13, Rev. 0, Page 240 of 638

, Volume 13, Rev. 0, Page 241 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 241 of 638

Enclosure 2, Volume 13, Rev. 0, Page 242 of 638 ITS A01 ITS 3.8.3 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with: See ITS 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of LA01 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of SR 3.8.3.1 a 7 day supply 62,000 gallons of fuel, See ITS
4. A separate fuel transfer pump, and 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. See ITS 3.8.4 and battery bank and associated charger. 3.8.9 Applicability APPLICABILITY: MODES 1, 2, 3 and 4. When associated DG is required to be OPERABLE A02 Add proposed ACTIONS Note L01 ACTIONS ACTION: Add proposed ACTION A Add proposed ACTIONS B, C, D, E, and F M01
a. With one offsite A.C. circuit of the above required A.C. electrical power source inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are See ITS not inoperable due to common cause failure or performing Surveillance Requirement 3.8.1 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-1 Amendment No. 100, 132, 137, 205, 241, 332 Page 1 of 8 Enclosure 2, Volume 13, Rev. 0, Page 242 of 638

Enclosure 2, Volume 13, Rev. 0, Page 243 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

In accordance with the Surveillance LA02 4.8.1.1.2 Each diesel generator set shall be demonstrated OPERABLE: Frequency Control Program L02

a. At least once per 31 days on a staggered test basis by:

See ITS

1. Verifying the fuel level in the engine-mounted day tanks. 3.8.1 SR 3.8.3.1 2. Verifying the fuel level in the 7 day tank.

Add proposed SR 3.8.3.2 M01

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine mounted fuel tanks
4. *Verifying the diesel starts from ambient condition and achieves in less than or equal to 10 seconds voltage and frequency of 6800 volts and 58.8 Hz and achieves a steady state voltage and frequency of 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz. The diesel generator shall be started for this test by using one of the following signals with startup on each signal verified at least once per 124 days:

a) Manual.

b) Simulated loss of offsite power by itself.

See ITS 3.8.1 c) An ESF actuation test signal by itself.

5. *Verifying the generator is synchronized, loaded between 3960 kw and 4400 kw in less than or equal to 60 seconds, and operates for greater than or equal to 60 minutes, and
6. Verifying the diesel generator is aligned to provide standby power to the associated shutdown boards.
b. At least once per 31 days and after each operation of the diesel where the period of See ITS operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated 3.8.1 water from the engine-mounted fuel tanks.

Add proposed SR 3.8.3.5 M02 SR 3.8.3.3 c. At a frequency in accordance with the Diesel Fuel Oil Testing Program, verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits specified in the Diesel Fuel Oil Testing Program.

Add proposed SR 3.8.3.4 M01

  • The diesel generator start (10 sec) and load (60 sec) from standby conditions shall be performed at least once per 184 days in these surveillance tests. All other diesel generator engine starts and See ITS loading for the purpose of this surveillance testing may be preceded by an engine idle start, followed 3.8.1 by gradual acceleration to synchronous speed (approximately 900 rpm), synchronization, and gradual loading. In this latter case, 10 second requirements do not apply.

October 2, 2000 SEQUOYAH - UNIT 1 3/4 8-3 Amendment No. 52, 64, 99, 109, 137, 173, 195, 226, 234, 261 Page 2 1 of 8 Enclosure 2, Volume 13, Rev. 0, Page 243 of 638

Enclosure 2, Volume 13, Rev. 0, Page 244 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

8. Verifying that the auto-connected loads to each diesel generator do not exceed the continuous rating of 4400 kW.
9. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and See ITS 3.8.1 c) Be restored to its shutdown status.

10. Verifying that the automatic load sequence timers are OPERABLE with the setpoint for each sequence timer within + 5 percent of its design setpoint.#
11. This surveillance is deleted.
e. At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously and verifying that each diesel generator achieves in less than or equal to 10 seconds, 6800 volts and 58.8 Hz.
f. At least once per 10 years by:

LA03

1. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank.
g. At least once per 18 months by:
1. Verifying the generator capability to reject a load of greater than or equal to 600 kw while maintaining voltage at within +/- 10 percent of the initial pretest voltage and frequency at 60 + 1.2 Hz. At no time shall the transient voltage exceed 8276V.

See ITS

2. Verifying the generator capability to reject a load of 4400 kw without tripping. The 3.8.1 generator voltage shall not exceed 8880V during and following the load rejection.
  1. May be performed in Modes 1, 2, 3 & 4 if the associated equipment is out of service for maintenance or testing.

October 2, 2000 SEQUOYAH - UNIT 1 3/4 8-5 Amendment No. 52, 64, 99, 109, 114, 137, 170,173, 195, 213, 234, 242, 261 Page 3 of 8 Enclosure 2, Volume 13, Rev. 0, Page 244 of 638

Enclosure 2, Volume 13, Rev. 0, Page 245 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SHUTD0WN Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

See ITS 3.8.2

1. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, LA01 a 7 day supply SR 3.8.3.1 3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, See ITS
4. A fuel transfer pump, and 3.8.2
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.5 and 3.8.9 Applicability APPLICABILITY: MODES 5 and 6. When associated DG is required to be OPERABLE A02 ACTIONS ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions See ITS 3.8.2 that could result in loss of required shutdown margin or boron concentration.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 3.8.2 and 4.8.1.1.2.a.5), and 4.8.1.1.3. 3.8.5 May 22, 2003 SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. 241, 285 Page 4 9 of 8 x Page 8 of x Enclosure 2, Volume 13, Rev. 0, Page 245 of 638

Enclosure 2, Volume 13, Rev. 0, Page 246 of 638 ITS A01 ITS 3.8.3 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with: See ITS 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank SR 3.8.3.1 3. A separate fuel storage system containing a minimum volume of 62,000 gallons of fuel, a 7 day supply LA01
4. A separate fuel transfer pump, and See ITS 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.4 and 3.8.9 Applicability APPLICABILITY: MODES 1, 2, 3 and 4. When associated DG is required to be OPERABLE A02 Add proposed ACTIONS Note L01 ACTIONS ACTION: Add proposed ACTION A Add proposed ACTIONS B, C, D, E, and F M01
a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not See ITS inoperable due to common cause failure or performing Surveillance Requirement 3.8.1 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, 231, 325 Page 5 of 8 Enclosure 2, Volume 13, Rev. 0, Page 246 of 638

Enclosure 2, Volume 13, Rev. 0, Page 247 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

In accordance with the Surveillance LA02 4.8.1.1.2 Each diesel generator set shall be demonstrated OPERABLE: Frequency Control Program L02

a. At least once per 31 days on a staggered test basis by:

See ITS

1. Verifying the fuel level in the engine-mounted day tanks. 3.8.1 SR 3.8.3.1 2. Verifying the fuel level in the 7 day tank. Add proposed SR 3.8.3.2 M01
3. Verifying the fuel transfer pump starts and transfers fuel from the storage system to the engine mounted fuel tanks.
4. *Verifying the diesel starts from ambient condition and achieves in less than or equal to 10 seconds generator voltage and frequency of 6800 volts and 58.8 Hz and achieves a steady state voltage and frequency of 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz. The diesel generator shall be started for this test by using one of the following signals with startup on each signal verified at least once per 124 days:

a) Manual.

b) Simulated loss of offsite power by itself. See ITS 3.8.1 c) An ESF actuation test signal by itself.

5. *Verifying the generator is synchronized, loaded between 3960 kw and 4400 kw in less than or equal to 60 seconds, and operates for greater than or equal to 60 minutes, and
6. Verifying the diesel generator is aligned to provide standby power to the associated shutdown boards.
b. At least once per 31 days and after each operation of the diesel where the period of operation See ITS was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the 3.8.1 engine-mounted fuel tanks.

Add proposed SR 3.8.3.5 M02 SR 3.8.3.3 c. At a frequency in accordance with the Diesel Fuel Oil Testing Program, verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits specified in the Diesel Fuel Oil Testing Program.

Add proposed SR 3.8.3.4 M01

  • The diesel generator start (10 sec) and load (60 sec) from standby conditions shall be performed at least once per 184 days in these surveillance tests. All other diesel generator engine starts and loading See ITS for the purpose of this surveillance testing may be preceded by an engine idle start, followed by gradual 3.8.1 acceleration to synchronous speed (approximately 900 rpm), synchronization, and gradual loading. In this latter case, 10 second requirements do not apply.

October 2, 2000 SEQUOYAH - UNIT 2 3/4 8-3 Amendment No. 44, 56, 88, 99, 123, 164, 186, 217, 224, 252 Page 6 of 8 Enclosure 2, Volume 13, Rev. 0, Page 247 of 638

Enclosure 2, Volume 13, Rev. 0, Page 248 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

8. Verifying that the auto-connected loads to each diesel generator do not exceed the continuous rating of 4400 kw.
9. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and c) Be restored to its shutdown status. See ITS 3.8.1

10. Verifying that the automatic load sequence timers are OPERABLE with the setpoint for each sequence timer within + 5 percent of its design setpoint.#
11. This surveillance is deleted.
e. At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously and verifying that each diesel generator achieves in less than or equal to 10 seconds, 6800 volts and 58.8 Hz.
f. At least once per 10 years by:
1. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the LA03 tank.
g. At least once per 18 months by:
1. Verifying the generator capability to reject a load of greater than or equal to 600 kw while maintaining voltage at within +/- 10 percent of the initial pretest voltage and frequency at 60

+ 1.2 Hz. At no time shall the transient voltage exceed 8276V.

2. Verifying the generator capability to reject a load of 4400 kw without tripping. The generator voltage shall not exceed 8880V during and following the load rejection. See ITS 3.8.1
  1. May be performed in Modes 1, 2, 3 & 4 if the associated equipment is out of service for maintenance or testing.

October 2, 2000 SEQUOYAH - UNIT 2 3/4 8-5 Amendment No. 41, 56, 88, 123, 160, 164, 186, 203, 224, 232, 252 Page 7 of 8 Enclosure 2, Volume 13, Rev. 0, Page 248 of 638

Enclosure 2, Volume 13, Rev. 0, Page 249 of 638 ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SHUTDOWN Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

See ITS 3.8.2

l. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, a 7 day supply LA01 SR 3.8.3.1 3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel,
4. A fuel transfer pump, and See ITS
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and 3.8.2 associated charger.

Applicability APPLICABILITY: MODES 5 and 6. When associated DG is required to be OPERABLE A02 ACTIONS ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions See ITS 3.8.2 that could result in loss of required shutdown margin or boron concentration.

SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement See ITS 3.8.2 4.8.1.1.2.a.5), and 4.8.1.1.3.

May 22, 2003 SEQUOYAH - UNIT 2 3/4 8-9 Amendment No. 231, 274 Page 8 9 of 8 x

Page 8 of x Enclosure 2, Volume 13, Rev. 0, Page 249 of 638

Enclosure 2, Volume 13, Rev. 0, Page 250 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS LCOs 3.8.1.1 and 3.8.1.2 state the requirements for the AC Sources during operating and shutdown conditions, respectively. These requirements are used to form the LCO and Applicability for the ITS diesel fuel oil Specification. ITS LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," states that the stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required DG. The Applicability for this requirement is when the associated DG is required to be OPERABLE. This changes the CTS by combining the requirements for diesel fuel oil and diesel lube oil and starting air subsystem (See DOC M01 for discussion of diesel lube oil and starting air subsystem) into one Specification.

This change is acceptable because the current requirements are translated into ITS form with no technical changes. The additional requirements for DG lube oil and starting air subsystem are discussed in DOC M01. Diesel fuel oil, lube oil and starting air subsystem are a support system for each DG. The CTS and ITS maintain this relationship between the DGs and the Diesel Fuel Oil System, DG Lube oil System and Starting Air Subsystem. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 4.8.1.1.2.c requires, in part, to verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within limits specified in the Diesel Fuel Oil Testing program. The CTS does not provide any requirements for DG lube oil, stored diesel fuel oil total particulate level or starting air pressure. ITS LCO 3.8.3, in part, requires the stored diesel fuel oil, lube oil, and starting air to be within limits for each required DG with associated Required Actions and Completion times when outside these limits. The Applicability for these requirements is when the associated DG is required to be OPERABLE. ITS SR 3.8.3.2 requires verification that the lube oil inventory is a 7-day supply for each DG. ITS SR 3.8.3.3 requires verification that new and stored fuel oil properties are tested and maintained within limits, as specified in the Diesel Fuel Oil Testing Program. This includes stored fuel oil total particulate level and new fuel oil properties. ITS SR 3.8.3.4 requires verification that DG air start Tank A is 200 psig and Tank B pressure is 150 psig for each DG. ITS 3.8.3 ACTION B provides an ACTION if the limit of ITS SR 3.8.3.2 is not met. ITS 3.8.3 ACTION C specifies the compensatory actions for one or more DGs with stored fuel oil total Sequoyah Unit 1 and Unit 2 Page 1 of 6 Enclosure 2, Volume 13, Rev. 0, Page 250 of 638

Enclosure 2, Volume 13, Rev. 0, Page 251 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR particulates not within limits. ITS 3.8.3 ACTION D specifies the compensatory actions for one or more DGs with new fuel oil properties not within limits. ITS ACTION E provides an ACTION if the limit of ITS SR 3.8.3.4 is not met. Finally, ITS ACTION F provides an ACTION if the Required Action and associated Completion Time of ACTION A, B, C, D, or E, are not met or if the diesel fuel oil, lube oil, or starting air subsystems are not within limits for reasons other than Condition A, B, C, D, or E. This changes the CTS by adding limits for stored diesel fuel oil total particulates, lube oil inventory, and starting air, Surveillance Requirements to verify the limits are being maintained, and explicit ACTIONS for when the limits are not met.

The purpose of ITS 3.8.3 is to provide appropriate limits, ACTIONS, and Surveillances for diesel fuel oil, lube oil, and the air start subsystems because these subsystems support the operation of the standby AC power sources (DGs).

The purpose of ITS SR 3.8.3.2 is to provide the appropriate limits for stored lube oil volume. ITS 3.8.3 ACTIONS B provides an explicit Required Action and Completion Time for restoring stored lube oil volume to within limits. The purpose of ITS SR 3.8.3.3 is to provide the appropriate limits for stored and new fuel oil properties. ITS 3.8.3 ACTIONS C and D provide explicit Required Actions and Completion Times for restoring both total particulates and stored fuel oil properties (affected by the addition of new fuel oil whose properties are not within limits) to within limits. ITS 3.8.3 ACTION C is entered because of a failure to meet the acceptance criterion of total particulate concentration specified in ITS 5.5.11. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures, contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not necessarily result in a failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, re-sampling and re-analysis of the DG fuel oil.

ITS 3.8.3 ACTION D is entered because of failure to meet the requirements specified in ITS 5.5.11.b. With the new fuel oil properties defined in the Bases for ITS SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil did not cause the stored fuel oil to be outside of the required limits, or to restore the stored fuel oil properties to within limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the stored fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function. The purpose of ITS SR 3.8.3.4 is to provide the appropriate limits for the DG starting air subsystem. ITS 3.8.3 ACTIONS E provides explicit Required Action and Completion Time for restoring starting air pressures to within limits. ITS 3.8.3 ACTION F covers the condition when a Required Action and associated Completion Time of any of the above ACTIONS could not be met, or if one or more DGs with diesel fuel oil, lube oil, or starting air subsystem is not within limits for reasons other than Condition A, B, C, D, or E. The allowances are considered acceptable since only a short time is allowed to exist Sequoyah Unit 1 and Unit 2 Page 2 of 6 Enclosure 2, Volume 13, Rev. 0, Page 251 of 638

Enclosure 2, Volume 13, Rev. 0, Page 252 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR with DG parameters not within limits. These changes are designated as more restrictive because explicit requirements are included in the Technical Specifications for stored diesel fuel oil total particulates, new diesel fuel oil properties and lube oil inventory limits.

M02 The CTS does not provide any requirements for checking and removing accumulated water from each fuel oil storage tank (7-day tanks). ITS SR 3.8.3.5 requires checking for and removing accumulated water from each fuel oil storage tank (7-day tanks). This changes the CTS by adding a new Surveillance Requirement to check and remove accumulated water from each fuel oil storage tank (7-day tanks).

Microbiological fouling is a major cause of fuel oil degradation. Numerous bacteria can grow in fuel oil and cause fouling but all must have a water environment to survive. Removal of water from the fuel storage tanks (7-day tanks) eliminates the necessary environment for bacterial survival. Water may come from any of several sources, including condensation, ground water, rain water, and contaminated fuel oil, and from breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system.

This change is designated as more restrictive because explicit requirements are added to the Technical Specifications for checking for and removing accumulated water from each fuel oil storage 7-day tank.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b.3 and CTS 3.8.1.2.b.3 require a separate fuel storage system containing a minimum volume of 62,000 gallons of fuel. ITS SR 3.8.3.1 requires, in part, verifying that each fuel oil 7-day storage tank contains a 7-day supply of fuel oil when the associated diesel generator is required to be OPERABLE. This changes the CTS by moving the specific values for the fuel oil inventory to the Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 3.8.1.1.b.3 and CTS 3.8.1.2.b.3 is to ensure that the DGs have sufficient fuel oil to perform their safety function when the DGs are required to be OPERABLE. ITS SR 3.8.3.1 will continue to ensure that sufficient fuel is contained in the fuel oil storage tank for the DGs to perform their intended safety function when the DGs are required to be OPERABLE. In addition, this change is acceptable because these types of details will be adequately controlled in the Technical Specification Bases.

Changes to the Bases are controlled by the Technical Specification Control Sequoyah Unit 1 and Unit 2 Page 3 of 6 Enclosure 2, Volume 13, Rev. 0, Page 252 of 638

Enclosure 2, Volume 13, Rev. 0, Page 253 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as less restrictive removal of detail change because details are being moved from the Technical Specifications to the ITS Bases LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.1.1.2.a.2 requires that the diesel generator fuel level in the 7 day tank be verified at least once per 31 days on a staggered test basis ITS SR 3.8.3.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." Refer to DOC L02 for changes to the STAGGERED TEST BASIS frequency. This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequency is being removed from the Technical Specifications.

LA03 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, UFSAR, ODCM, NQAP, CLRT Program, IST Program, or ISI Program) CTS 4.8.1.1.2.f.1 requires draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank every 10 years. ITS 3.8.3 does not include these requirements for the fuel oil storage tanks. This changes the CTS by moving these fuel oil storage tank requirements from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The criteria and Frequencies established in the ITS 5.5.11, "Diesel Fuel Oil Testing Program," and ITS SR 3.8.3.3 will ensure the diesel fuel oil is at a quality that will ensure proper operation of the DG during a design basis accident. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because information is being removed from the Technical Specifications.

Sequoyah Unit 1 and Unit 2 Page 4 of 6 Enclosure 2, Volume 13, Rev. 0, Page 253 of 638

Enclosure 2, Volume 13, Rev. 0, Page 254 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 and CTS 3.8.1.2 do not provide explicit compensatory actions if the volume of fuel oil in a storage tank is less than the specified limit. Thus, if the minimum required volume is not met, the associated DG must be declared inoperable and the actions of CTS 3.8.1.1 or CTS 3.8.1.2 must be entered, as appropriate. ITS 3.8.3 ACTION A allows for not declaring the associated DG inoperable as long as the volume of stored fuel oil is greater than a six-day supply. ITS 3.8.3 Required Action A.1 allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the fuel oil volume to within limits. As stated in the ACTIONS Note, a separate entry into this new ACTION is allowed for each DG.

If this Required Action and associated Completion Time are not met or if the fuel oil storage tank volume is < a 6-day supply, the associated DG must be declared inoperable immediately, as required by ITS 3.8.3 ACTION F. This changes the CTS by allowing the DGs to not be declared inoperable with the fuel oil 7-day storage tank volume not within the specified Surveillance limit as long as the associated DG has enough fuel oil for 6 days of operation at rated load.

The purpose of ITS 3.8.3 ACTION A is to allow time to restore the stored diesel fuel oil volume to within the specified limit for a given DG. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to a degraded condition in order to minimize risk associated with continued operation while providing time to restore inventory. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The addition of ITS 3.8.3 ACTION A will allow each DG to not be declared inoperable with the associated stored diesel fuel oil volume not within the specified Surveillance limit as long as the DG has enough fuel oil for 6 days of operation at rated load. In this Condition, the 7-day fuel oil supply for the DG is not available. However, the Condition is restricted to fuel oil volume reductions that maintain at least a 6-day supply. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required fuel oil level, or feed and bleed operations, which may be necessary due to increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the associated DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. This change is designated as less restrictive since less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.1.1.2.a requires, in part, that each diesel generator set be demonstrated OPERABLE by verifying the fuel level in the 7 day tank at least once per 31 days on a STAGGERED TEST BASIS. ITS SR 3.8.3.1 requires this same verification every 31 days. This changes the CTS by deleting the requirement to perform the verification on a Sequoyah Unit 1 and Unit 2 Page 5 of 6 Enclosure 2, Volume 13, Rev. 0, Page 254 of 638

Enclosure 2, Volume 13, Rev. 0, Page 255 of 638 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR STAGGERED TEST BASIS. See DOC LA02 for the discussion on moving the 31 day Frequency for ITS SR 3.8.3.1 to the Surveillance Frequency Control Program.

The purpose of CTS 4.8.1.1.2.a is to ensure that adequate fuel oil is available for each diesel generator set. CTS 1.35 STAGGERED TEST BASIS definition, defines a testing schedule for n systems, subsystems, or trains by dividing the specified test interval into n equal subintervals, with the testing of one system, subsystem, or train occurring at the beginning of each subinterval. In other words, a Surveillance Requirement to verify the OPERABILITY of each diesel generator set at a Frequency of 31 days on a STAGGERED TEST BASIS would result in each of the four diesel generator sets being verified OPERABLE every 31 days, with one diesel generator set being verified in alternating 7.75 day subintervals. Removal of the STAGGERED TEST BASIS scheduling requirement does not change the requirement to verify the OPERABILITY of each diesel generator set every 31 days, but rather removes the requirement to schedule testing every 7.75 days. The new Surveillance Frequency will not change the testing Frequency of each diesel generator set. The intent of the CTS staggered testing requirement is to evenly distribute testing of each diesel generator set across the system. However, as each diesel generator set is independent, no increase in reliability or safety is achieved by evenly staggering the testing subintervals. This change is acceptable, because removal of the staggered testing requirement will increase operational and scheduling flexibility without decreasing safety or system reliability. This change is designated as less restrictive, because the intervals between performances of the Surveillances for diesel generator set can be larger or smaller under the ITS than under the CTS.

Sequoyah Unit 1 and Unit 2 Page 6 of 6 Enclosure 2, Volume 13, Rev. 0, Page 255 of 638

Enclosure 2, Volume 13, Rev. 0, Page 256 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 256 of 638

Enclosure 2, Volume 13, Rev. 0, Page 257 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.1.1 3.8.1.2 LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

Applicability APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS


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

DOC L01 Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One or more DGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel level less than a within limits.

[7] day supply and 1 greater than a [6] day supply in storage tank.

DOC M01 B. One or more DGs with B.1 Restore lube oil inventory to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory less within limits.

than a [7] day supply and greater than a 1

[6] day supply.

DOC M01 C. One or more DGs with C.1 Restore fuel oil total 7 days stored fuel oil total particulates to within limits.

particulates not within limit.

DOC M01 D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limits.

not within limits.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.3-1 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 257 of 638

Enclosure 2, Volume 13, Rev. 0, Page 258 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Tank A DOC M01 E. One or more DGs with E.1 Restore starting air receiver 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> starting air receiver pressure to [225] psig. 1 2

pressure < [225] psig 200 and [125] psig.

Tank B pressure 150 F. Required Action and F.1 Declare associated DG Immediately DOC M01 associated Completion inoperable.

Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 1

4.8.1.1.2.a.2 SR 3.8.3.1 Verify each fuel oil storage tank contains a [7] day [ 31 days 3.8.1.1.b.3 3.8.1.2.b.3 supply of fuel.

OR 3

In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.3-2 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 258 of 638

Enclosure 2, Volume 13, Rev. 0, Page 259 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M01 SR 3.8.3.2 Verify lubricating oil inventory is a [7] day supply. [ 31 days 1 OR 3

In accordance with the Surveillance Frequency Control Program ]

4.8.1.1.2.c SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program Tank A 2 DOC M01 SR 3.8.3.4 Verify each DG air start receiver pressure is [ 31 days

[225] psig. 1 2 200 and Tank B pressure is 150 psig OR In accordance 3 with the Surveillance Frequency Control Program ]

DOC M02 SR 3.8.3.5 Check for and remove accumulated water from each [ [31] days fuel oil storage tank.

2 (7-day tanks) OR 3

In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.3-3 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 259 of 638

Enclosure 2, Volume 13, Rev. 0, Page 260 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.1.1 3.8.1.2 LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

Applicability APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS


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

DOC L01 Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One or more DGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel level less than a within limits.

[7] day supply and 1 greater than a [6] day supply in storage tank.

DOC M01 B. One or more DGs with B.1 Restore lube oil inventory to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory less within limits.

than a [7] day supply and greater than a 1

[6] day supply.

DOC M01 C. One or more DGs with C.1 Restore fuel oil total 7 days stored fuel oil total particulates to within limits.

particulates not within limit.

DOC M01 D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limits.

not within limits.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.3-1 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 260 of 638

Enclosure 2, Volume 13, Rev. 0, Page 261 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Tank A DOC M01 E. One or more DGs with E.1 Restore starting air receiver 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> starting air receiver pressure to [225] psig. 1 2

pressure < [225] psig 200 and [125] psig.

Tank B pressure 150 F. Required Action and F.1 Declare associated DG Immediately DOC M01 associated Completion inoperable.

Time not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 1

4.8.1.1.2.a.2 SR 3.8.3.1 Verify each fuel oil storage tank contains a [7] day [ 31 days 3.8.1.1.b.3 3.8.1.2.b.3 supply of fuel.

OR 3

In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.3-2 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 261 of 638

Enclosure 2, Volume 13, Rev. 0, Page 262 of 638 CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M01 SR 3.8.3.2 Verify lubricating oil inventory is a [7] day supply. [ 31 days 1 OR 3

In accordance with the Surveillance Frequency Control Program ]

4.8.1.1.2.c SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program Tank A 2 DOC M01 SR 3.8.3.4 Verify each DG air start receiver pressure is [ 31 days

[225] psig. 1 2 200 and Tank B pressure is 150 psig OR In accordance 3 with the Surveillance Frequency Control Program ]

DOC M02 SR 3.8.3.5 Check for and remove accumulated water from each [ [31] days fuel oil storage tank.

2 (7-day tanks) OR 3

In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.3-3 Rev. 4.0 2 Enclosure 2, Volume 13, Rev. 0, Page 262 of 638

Enclosure 2, Volume 13, Rev. 0, Page 263 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. ISTS SR 3.8.3.1, ISTS SR 3.8.3.2, ISTS SR 3.8.3.4, and ISTS SR 3.8.3.5 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.3.1, ITS SR 3.8.3.2, ITS SR 3.8.3.4, and ITS SR 3.8.3.5 is "In accordance with the Surveillance Frequency Control Program."

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 263 of 638

Enclosure 2, Volume 13, Rev. 0, Page 264 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 264 of 638

Enclosure 2, Volume 13, Rev. 0, Page 265 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES 7-day storage tank, comprised of four inter-connected tanks, 1

BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel oil capacity sufficient to operate that diesel for a period of [7] days while 2 U

the DG is supplying maximum post loss of coolant accident load demand 1 2 3

discussed in the FSAR, Section [9.5.4.2] (Ref. 1) [and Regulatory INSERT 1 Guide 1.137 (Ref. 2)]. The maximum load demand is calculated using the 1 assumption that a minimum of any two DGs is available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

each diesel generator 7-day two engine-mounted day tanks the 7-day Fuel oil is transferred from storage tank to day tank by either of two transfer pumps associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any 1 pipe, valve or tank to result in the loss of more than one DG. All outside tanks, pumps, and piping are located underground. INSERT 2 For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of without supporting a minimum of [7] days of operation. [The onsite storage in requiring replenishment addition to the engine oil sump is sufficient to ensure [7] days of 2 continuous operation.] This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Each DG has an air start system with adequate capacity for five successive start attempts on the DG without recharging the air start tank receiver(s). 1 INSERT 3 1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 265 of 638

, Volume 13, Rev. 0, Page 266 of 638 3.8.3 1

INSERT 1 The maximum load demand assumed is the diesel generator operating at 110% rated load for the first two hours then operating at 100% rated load for the remaining 166 hours0.00192 days <br />0.0461 hours <br />2.744709e-4 weeks <br />6.3163e-5 months <br />.

1 INSERT 2 Each 7-day tank is embedded in the concrete substructure below its respective DG with the two 550-gallon engine-mounted "day" tanks located in the respective DG room.

1 INSERT 3 The Starting Air System for each diesel engine includes two tanks. The tanks are aligned in series to the starter motors. The upstream tank (Tank A) is maintained at 250-300 psig by the air compressor while the downstream tank (Tank B) is maintained at approximately 195 psig via a pressure control valve (PCV) between the two tanks.

Insert Page B 3.8.3-1 , Volume 13, Rev. 0, Page 266 of 638

Enclosure 2, Volume 13, Rev. 0, Page 267 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, 1 2

ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Stored diesel fuel oil is required to have sufficient supply for [7] days of 2 full load operation. It is also required to meet specific standards for quality. Additionally, sufficient lubricating oil supply must be available to ensure the capability to operate at full load for [7] days. This requirement, 2 in conjunction with an ability to obtain replacement supplies within

[7] days, supports the availability of DGs required to shut down the 2 reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG engine-mounted day tank day tank fuel requirements, as well as transfer capability from the storage 1 tank to the day tank, are addressed in LCO 3.8.1, "AC Sources -

Operating," and LCO 3.8.2, "AC Sources - Shutdown."

The starting air system is required to have a minimum capacity for five tank(s) successive DG start attempts without recharging the air start receivers. 1 APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 267 of 638

Enclosure 2, Volume 13, Rev. 0, Page 268 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

A.1 In this Condition, the [7] day fuel oil supply for a DG is not available.

However, the Condition is restricted to fuel oil level reductions that 2 53719 maintain at least a [6] day supply. The fuel oil level equivalent to a [6] day supply is [28,285] gallons. These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the fact that procedures will be initiated to obtain 2 replenishment, and the low probability of an event during this brief period.

B.1 In this Condition, the [7] day lube oil inventory i.e., sufficient lubricating oil to support [7] days of continuous DG operation at full load conditions is not available. However, the Condition is restricted to lube oil volume 2 120 reductions that maintain at least a [6] day supply. The lube oil inventory (per diesel equivalent to a [6] day supply is [425] gallons. This restriction allows engine) sufficient time to obtain the requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the low rate of usage, the 2 fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 3 This Condition is entered as a result of a failure to meet the acceptance 5

for the stored fuel criterion of SR 3.8.3.5. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 268 of 638

Enclosure 2, Volume 13, Rev. 0, Page 269 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling and re-analysis of the DG fuel oil.

D.1 3 With the new fuel oil properties defined in the Bases for SR 3.8.3.4 not 5 within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

E.1 Tank A 200 With starting air receiver pressure < [225] psig, sufficient capacity for five 1 2 Tank B successive DG start attempts does not exist. However, as long as the 150 receiver pressure is > [125] psig, there is adequate capacity for at least 1 2 one start attempt, and the DG can be considered OPERABLE while the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

F.1 With a Required Action and associated Completion Time not met, or one or more DG's fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through D, the E 5 associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 269 of 638

Enclosure 2, Volume 13, Rev. 0, Page 270 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil 62,000 in the storage tanks to support each DG's operation for [7] days at full 2 load. The fuel oil level equivalent to a [7] day supply is [33,000] gallons when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, the corresponding fuel consumption rate, the onsite fuel storage volume required for [7] days of operation can be determined. 2 SR 3.8.3.3 requires a new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumption calculations. The [7] day period is sufficient time to 2 place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

[ The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. 3 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to 142 support at least [7] days of full load operation for each DG. The lube oil 2 (per diesel inventory equivalent to a [7] day supply is [500] gallons and is based on engine) the DG manufacturer consumption values for the run time of the DG.

Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG, when the DG lube oil sump does not hold adequate inventory for [7] days of full load operation 2 without the level reaching the manufacturer recommended minimum level.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 270 of 638

Enclosure 2, Volume 13, Rev. 0, Page 271 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the unit 3

staff.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for 7-day contaminating the entire volume of fuel oil in the storage tanks. These 1 tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

1988

a. Sample the new fuel oil in accordance with ASTM D4057-[ ] 2 (Ref. 6),

1990

b. Verify in accordance with the tests specified in ASTM D975-[ ] 2 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 0.83 and 0.89 or an API gravity at 60°F of 27° and 39° when 1985 tested in accordance with ASTM D1298-[ ] (Ref. 6), a kinematic 2 viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a flash point of 125°F, and
c. Verify that the new fuel oil has a clear and bright appearance with 2004 proper color when tested in accordance with ASTM D4176-[ ] or a 2 water and sediment content within limits when tested in accordance with [ASTM D2709-[ ]] (Ref. 6). 2 D1796-1997 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 271 of 638

Enclosure 2, Volume 13, Rev. 0, Page 272 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the 1 7-day fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-[ ] (Ref. 7) are met for new fuel oil when tested in 1990 accordance with ASTM D975-[ ] (Ref. 6), except that the analysis for 1990 2

1987 sulfur may be performed in accordance with ASTM D1552-[ ],

ASTM D2622-[ ], or ASTM D4294-[ ] (Ref. 6). The 31 day period is 2 2002 acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

Particulate concentrations should be determined in accordance with D6217-11 ASTM D5452-[ ] (Ref. 6). This method involves a gravimetric 1 2 determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. [For those designs in which the total stored fuel oil volume is contained in two or more interconnected 2 tanks, each tank must be considered and tested separately.]

fuel oil (7-day tank) 1 storage The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. The system design requirements provide for a minimum of [five] engine start cycles without recharging. [A start cycle is defined by the DG vendor, but usually is measured in terms of time (seconds of cranking) or engine cranking 2 speed.] The pressure specified in this SR is intended to reflect the lowest value at which the [five] starts can be accomplished.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 272 of 638

Enclosure 2, Volume 13, Rev. 0, Page 273 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to 3 below normal air start pressure.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the (7-day tanks) fuel storage tanks eliminates the necessary environment for bacterial 1 survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, and contaminated fuel oil, and from breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance.

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the 3 Surveillance.

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

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 273 of 638

Enclosure 2, Volume 13, Rev. 0, Page 274 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Section [9.5.4.2]. 1 3

2. Regulatory Guide 1.137. , 1979. 1
3. ANSI N195, 1976.
4. FSAR, Chapter [6]. 1 2
5. FSAR, Chapter [15]. 1 1988 1990 1985 2004
6. ASTM Standards: D4057-[ ]; D975-[ ]; D1298-[ ]; D4176-[ ];

[D2709-[ ];] D1552-[ ]; D2622-[ ]; D4294-[ ]; D5452-[ ]. 1 D1796-1997 1990 1987 D6217-11

7. ASTM Standards, D975-[ ], Table 1. 2002 1990 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.3-9 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 274 of 638

Enclosure 2, Volume 13, Rev. 0, Page 275 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES 7-day storage tank, comprised of four inter-connected tanks, 1

BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel oil capacity sufficient to operate that diesel for a period of [7] days while 2 U

the DG is supplying maximum post loss of coolant accident load demand 1 2 3

discussed in the FSAR, Section [9.5.4.2] (Ref. 1) [and Regulatory INSERT 1 Guide 1.137 (Ref. 2)]. The maximum load demand is calculated using the 1 assumption that a minimum of any two DGs is available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

each diesel generator 7-day two engine-mounted day tanks the 7-day Fuel oil is transferred from storage tank to day tank by either of two transfer pumps associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any 1 pipe, valve or tank to result in the loss of more than one DG. All outside tanks, pumps, and piping are located underground. INSERT 2 For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of without supporting a minimum of [7] days of operation. [The onsite storage in requiring replenishment addition to the engine oil sump is sufficient to ensure [7] days of 2 continuous operation.] This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Each DG has an air start system with adequate capacity for five successive start attempts on the DG without recharging the air start tank receiver(s). 1 INSERT 3 1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 275 of 638

, Volume 13, Rev. 0, Page 276 of 638 3.8.3 1

INSERT 1 The maximum load demand assumed is the diesel generator operating at 110% rated load for the first two hours then operating at 100% rated load for the remaining 166 hours0.00192 days <br />0.0461 hours <br />2.744709e-4 weeks <br />6.3163e-5 months <br />.

1 INSERT 2 Each 7-day tank is embedded in the concrete substructure below its respective DG with the two 550-gallon engine-mounted "day" tanks located in the respective DG room.

1 INSERT 3 The Starting Air System for each diesel engine includes two tanks. The tanks are aligned in series to the starter motors. The upstream tank (Tank A) is maintained at 250-300 psig by the air compressor while the downstream tank (Tank B) is maintained at approximately 195 psig via a pressure control valve (PCV) between the two tanks.

Insert Page B 3.8.3-1 , Volume 13, Rev. 0, Page 276 of 638

Enclosure 2, Volume 13, Rev. 0, Page 277 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, 1 2

ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Stored diesel fuel oil is required to have sufficient supply for [7] days of 2 full load operation. It is also required to meet specific standards for quality. Additionally, sufficient lubricating oil supply must be available to ensure the capability to operate at full load for [7] days. This requirement, 2 in conjunction with an ability to obtain replacement supplies within

[7] days, supports the availability of DGs required to shut down the 2 reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG engine-mounted day tank day tank fuel requirements, as well as transfer capability from the storage 1 tank to the day tank, are addressed in LCO 3.8.1, "AC Sources -

Operating," and LCO 3.8.2, "AC Sources - Shutdown."

The starting air system is required to have a minimum capacity for five tank(s) successive DG start attempts without recharging the air start receivers. 1 APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 277 of 638

Enclosure 2, Volume 13, Rev. 0, Page 278 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

A.1 In this Condition, the [7] day fuel oil supply for a DG is not available.

However, the Condition is restricted to fuel oil level reductions that 2 53719 maintain at least a [6] day supply. The fuel oil level equivalent to a [6] day supply is [28,285] gallons. These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the fact that procedures will be initiated to obtain 2 replenishment, and the low probability of an event during this brief period.

B.1 In this Condition, the [7] day lube oil inventory i.e., sufficient lubricating oil to support [7] days of continuous DG operation at full load conditions is not available. However, the Condition is restricted to lube oil volume 2 120 reductions that maintain at least a [6] day supply. The lube oil inventory (per diesel equivalent to a [6] day supply is [425] gallons. This restriction allows engine) sufficient time to obtain the requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> [6] days), the low rate of usage, the 2 fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 3 This Condition is entered as a result of a failure to meet the acceptance 5

for the stored fuel criterion of SR 3.8.3.5. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 278 of 638

Enclosure 2, Volume 13, Rev. 0, Page 279 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling and re-analysis of the DG fuel oil.

D.1 3 With the new fuel oil properties defined in the Bases for SR 3.8.3.4 not 5 within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

E.1 Tank A 200 With starting air receiver pressure < [225] psig, sufficient capacity for five 1 2 Tank B successive DG start attempts does not exist. However, as long as the 150 receiver pressure is > [125] psig, there is adequate capacity for at least 1 2 one start attempt, and the DG can be considered OPERABLE while the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

F.1 With a Required Action and associated Completion Time not met, or one or more DG's fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through D, the E 5 associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 279 of 638

Enclosure 2, Volume 13, Rev. 0, Page 280 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil 62,000 in the storage tanks to support each DG's operation for [7] days at full 2 load. The fuel oil level equivalent to a [7] day supply is [33,000] gallons when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, the corresponding fuel consumption rate, the onsite fuel storage volume required for [7] days of operation can be determined. 2 SR 3.8.3.3 requires a new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumption calculations. The [7] day period is sufficient time to 2 place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

[ The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. 3 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to 142 support at least [7] days of full load operation for each DG. The lube oil 2 (per diesel inventory equivalent to a [7] day supply is [500] gallons and is based on engine) the DG manufacturer consumption values for the run time of the DG.

Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG, when the DG lube oil sump does not hold adequate inventory for [7] days of full load operation 2 without the level reaching the manufacturer recommended minimum level.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 280 of 638

Enclosure 2, Volume 13, Rev. 0, Page 281 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the unit 3

staff.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for 7-day contaminating the entire volume of fuel oil in the storage tanks. These 1 tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

1988

a. Sample the new fuel oil in accordance with ASTM D4057-[ ] 2 (Ref. 6),

1990

b. Verify in accordance with the tests specified in ASTM D975-[ ] 2 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 0.83 and 0.89 or an API gravity at 60°F of 27° and 39° when 1985 tested in accordance with ASTM D1298-[ ] (Ref. 6), a kinematic 2 viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a flash point of 125°F, and
c. Verify that the new fuel oil has a clear and bright appearance with 2004 proper color when tested in accordance with ASTM D4176-[ ] or a 2 water and sediment content within limits when tested in accordance with [ASTM D2709-[ ]] (Ref. 6). 2 D1796-1997 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 281 of 638

Enclosure 2, Volume 13, Rev. 0, Page 282 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the 1 7-day fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-[ ] (Ref. 7) are met for new fuel oil when tested in 1990 accordance with ASTM D975-[ ] (Ref. 6), except that the analysis for 1990 2

1987 sulfur may be performed in accordance with ASTM D1552-[ ],

ASTM D2622-[ ], or ASTM D4294-[ ] (Ref. 6). The 31 day period is 2 2002 acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

Particulate concentrations should be determined in accordance with D6217-11 ASTM D5452-[ ] (Ref. 6). This method involves a gravimetric 1 2 determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. [For those designs in which the total stored fuel oil volume is contained in two or more interconnected 2 tanks, each tank must be considered and tested separately.]

fuel oil (7-day tank) 1 storage The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. The system design requirements provide for a minimum of [five] engine start cycles without recharging. [A start cycle is defined by the DG vendor, but usually is measured in terms of time (seconds of cranking) or engine cranking 2 speed.] The pressure specified in this SR is intended to reflect the lowest value at which the [five] starts can be accomplished.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 282 of 638

Enclosure 2, Volume 13, Rev. 0, Page 283 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to 3 below normal air start pressure.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.3.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the (7-day tanks) fuel storage tanks eliminates the necessary environment for bacterial 1 survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, and contaminated fuel oil, and from breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance.

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the 3 Surveillance.

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

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 283 of 638

Enclosure 2, Volume 13, Rev. 0, Page 284 of 638 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Section [9.5.4.2]. 1 3

2. Regulatory Guide 1.137. , 1979. 1
3. ANSI N195, 1976.
4. FSAR, Chapter [6]. 1 2
5. FSAR, Chapter [15]. 1 1988 1990 1985 2004
6. ASTM Standards: D4057-[ ]; D975-[ ]; D1298-[ ]; D4176-[ ];

[D2709-[ ];] D1552-[ ]; D2622-[ ]; D4294-[ ]; D5452-[ ]. 1 D1796-1997 1990 1987 D6217-11

7. ASTM Standards, D975-[ ], Table 1. 2002 1990 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.3-9 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 284 of 638

Enclosure 2, Volume 13, Rev. 0, Page 285 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. ISTS SR 3.8.3.1, SR 3.8.3.2, 3.8.3.4 and 3.8.3.5 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

Therefore, the Frequency for ITS SR 3.8.3.1, SR 3.8.3.2, 3.8.3.4 and 3.8.3.5 is "In accordance with the Surveillance Frequency Control Program."

4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
5. Changes have been made to be consistent with changes made to the Specifications.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 285 of 638

Enclosure 2, Volume 13, Rev. 0, Page 286 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 286 of 638

Enclosure 2, Volume 13, Rev. 0, Page 287 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL AND STARTING AIR There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 287 of 638

, Volume 13, Rev. 0, Page 288 of 638 ATTACHMENT 4 ITS 3.8.4, DC SOURCES - OPERATING , Volume 13, Rev. 0, Page 288 of 638

, Volume 13, Rev. 0, Page 289 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 289 of 638

Enclosure 2, Volume 13, Rev. 0, Page 290 of 638 ITS A01 ITS 3.8.4 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.4 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.4 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and See ITS
b. Four separate and independent diesel generator sets each with: 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of See ITS 3.8.3 62,000 gallons of fuel, See ITS
4. A separate fuel transfer pump, and 3.8.1 LCO 3.8.4 5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

battery bank and associated charger. LA01 Applicability APPLICABILITY: MODES 1, 2, 3 and 4. See ITS

3.8.9 ACTION

Add proposed ACTION D A03

a. With one offsite A.C. circuit of the above required A.C. electrical power source inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE See ITS status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 3.8.1 SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-1 Amendment No. 100, 132, 137, 205, 241, 332 Page 1 of 9 Enclosure 2, Volume 13, Rev. 0, Page 290 of 638

Enclosure 2, Volume 13, Rev. 0, Page 291 of 638 ITS A01 ITS 3.8.4 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and See ITS 61.2 Hz during this test. 3.8.1

4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes. After energization, the steady state voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.

See ITS SR 3.8.4.1 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for 3.8.9 each diesel generator shall be demonstrated OPERABLE:

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.4.1 a. At least once per 7 days by verifying:

See ITS

1. That the parameters in Table 4.8-1a meet the Category A limits. 3.8.6 SR 3.8.4.1 2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge. the minimum established float voltage LA03
b. At least once per 92 days by:
1. Verifying that the parameters in Table 4.8-1a meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to terminal connection resistance of these items is less than 150 x 10-6 ohms, and
3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.
c. At least once per 18 months by verifying that: See ITS 3.8.6
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.

6

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

4.8.1.1.4 This surveillance has been deleted.

December 16, 1998 SEQUOYAH - UNIT 1 3/4 8-6 Amendment Nos. 52, 137, 173, 213, 234, 241 Page 2 of 9 Enclosure 2, Volume 13, Rev. 0, Page 291 of 638

Enclosure 2, Volume 13, Rev. 0, Page 292 of 638 ITS A01 ITS 3.8.4 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTI0N - OPERATING Add proposed LCO 3.8.4 A02 LIMITING CONDITION FOR OPERATION See ITS 3.8.9 LCO 3.8.4 3.8.2.3 The following D.C. vital battery channels shall be energized and OPERABLE:

CHANNEL I Consisting of 125 - volt D.C. board No. I, 125 - volt D.C.

battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

battery bank No. II*, and a full capacity charger.

LA01 CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D.C.

battery bank No. IV*, and a full capacity charger.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTIONS ACTION:

a. With one 125-volt D.C. board inoperable, restore the inoperable board to OPERABLE status See ITS 3.8.9 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed Action A L01 ACTION B

b. With one 125-volt D.C. battery bank and/or its charger inoperable, restore the inoperable battery bank and/or charger to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT ACTION C STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed. LA01 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-11 Amendment No. 37 Page 31 of 9 7

Enclosure 2, Volume 13, Rev. 0, Page 292 of 638

Enclosure 2, Volume 13, Rev. 0, Page 293 of 638 ITS A01 ITS 3.8.4 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated See ITS 3.8.9 power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts.

LA01 SR 3.8.4.1 SR 3.8.4.2 4.8.2.3.2* Each 125-volt battery bank and charger shall be demonstrated OPERABLE:

SR 3.8.4.3 In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.4.1 a. At least once per 7 days by:

See ITS

1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and 3.8.6 SR 3.8.4.1 2. Verifying total battery terminal voltage is greater than or equal to 129-volts on float charge. the minimum established float voltage LA04
b. At least once per 92 days and within 7 days after a battery discharge (battery terminal voltage below 110-volts), or battery overcharge (battery terminal voltage above 150-volts), by: See ITS 3.8.6
1. Verifying that the parameters in Table 4.8-2 meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the See ITS connection resistance of these items is less than 150 x 10-6 ohms, and 5.5.15
3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F. See ITS 3.8.6 SR 3.8.4.2 c. At least once per 18 months by verifying that: In accordance with the Surveillance Frequency Control Program LA02
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, See ITS
2. The cell-to-cell and terminal connections are clean, tight and coated with anti- 5.5.15 corrosion material,
3. The resistance of each cell-to-terminal connection is less than or equal to 150 x 10-6 ohms, and SR 3.8.4.2 4. The battery charger will supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

129 volts M01 greater than or equal to the LA05 minimum established float voltage

  • This surveillance includes Battery Bank V, but not charger V.

Add proposed 2nd option for SR 3.8.4.2 L02 LA01 October 4, 1995 SEQUOYAH - UNIT 1 3/4 8-12 Amendment No. 37, 213 Page 4 of 9 Enclosure 2, Volume 13, Rev. 0, Page 293 of 638

Enclosure 2, Volume 13, Rev. 0, Page 294 of 638 ITS A01 ITS 3.8.4 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.4.3 d. At least once per 18 months by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LA06 when the battery is subjected to a battery service test. the design duty cycle Add proposed SR 3.8.4.3 NOTE 2 M02

e. At least once per 60 months by verifying that the battery capacity is at least 82% of the SR 3.8.4.3 manufacturer's rating when subjected to a performance discharge test. Once per 60 month See ITS Note 1 interval, this performance discharge test may be performed in lieu of the battery service test. 3.8.6
f. Annual performance discharge tests of battery capacity shall be given to any battery that L03 shows signs of degradation or has reached 85% of the service life expected for the See ITS application. Degradation is indicated when the battery capacity drops more than 10% of 3.8.6 rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

In accordance with the Surveillance Frequency Control Program LA02 Add proposed SR 3.8.4.3 for DG batteries with a Frequency of 24 months M03 October 4, 1995 SEQUOYAH - UNIT 1 3/4 8-13 Amendment No. 29, 213 Page 5 of 9 Enclosure 2, Volume 13, Rev. 0, Page 294 of 638

Enclosure 2, Volume 13, Rev. 0, Page 295 of 638 ITS ITS 3.8.4 A01 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.4 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.4 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with: See ITS 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of 62,000 gallons of See ITS fuel, 3.8.3
4. A separate fuel transfer pump, and See ITS 3.8.1 LCO 3.8.4 5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and LA01 associated charger.

See ITS Applicability APPLICABILITY: MODES 1, 2, 3 and 4. 3.8.9 ACTION:

Add proposed ACTION D A03

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE See ITS status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 3.8.1 SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, 231, 325 Page 6 of 9 Enclosure 2, Volume 13, Rev. 0, Page 295 of 638

Enclosure 2, Volume 13, Rev. 0, Page 296 of 638 ITS ITS 3.8.4 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz See ITS during this test. 3.8.1

4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes. After energization, the steady state voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.

See ITS 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for 3.8.9 SR 3.8.4.1 each diesel generator shall be demonstrated OPERABLE:

In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.4.1 a. At least once per 7 days by verifying:

See ITS

1. That the parameters in Table 4.8-1a meet the Category A limits. 3.8.6 SR 3.8.4.1 2. That the total battery terminal voltage is greater than or equal to 124 volts on float charge.

the minimum established float voltage LA03

b. At least once per 92 days by:
1. Verifying that the parameters in Table 4.8-1a meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to terminal connection resistance of these items is less than 150 x 10-6 ohms, and
3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.

See ITS

c. At least once per 18 months by verifying that: 3.8.6
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.
3. The resistance of each cell to terminal connection is less than or equal to 150 x

-6 10 ohms.

July 22, 1998 SEQUOYAH - UNIT 2 3/4 8-6 Amendment No. 8, 56, 164, 203, 224 Page 7 of 9 Enclosure 2, Volume 13, Rev. 0, Page 296 of 638

Enclosure 2, Volume 13, Rev. 0, Page 297 of 638 ITS ITS 3.8.4 A01 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - OPERATING Add proposed LCO 3.8.4 A02 LIMITING CONDITION FOR OPERATION See ITS 3.8.9 LCO 3.8.4 3.8.2.3 The following D.C. vital battery channels shall be OPERABLE and energized:

CHANNEL I Consisting of 125 -volt D.C. board No. I, 125 - volt D.C. battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

battery bank No. II*, and a full capacity charger.

LA01 CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D. C.

battery bank No. IV*, and a full capacity charger.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one 125-volt D.C. board inoperable or not energized, restore the inoperable board to See ITS OPERABLE and energized status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the 3.8.9 next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed Action A L01

b. With one 125-volt D.C. battery bank and/or its charger inoperable or not energized, restore ACTION B the inoperable battery bank and/or charger to OPERABLE and energized status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN ACTION C within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated See ITS 3.8.9 power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts.

LA01 SR 3.8.4.1 4.8.2.3.2** Each 125-volt battery bank and charger shall be demonstrated OPERABLE:

SR 3.8.4.2 SR 3.8.4.3 In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.4.1 a. At least once per 7 days by:

See ITS

1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and 3.8.6
  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed.

LA01

    • This surveillance includes Battery Bank V, but not Charger V.

January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-12 Amendment No. 29 Page 8 of 9 Enclosure 2, Volume 13, Rev. 0, Page 297 of 638

Enclosure 2, Volume 13, Rev. 0, Page 298 of 638 ITS ITS 3.8.4 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS the minimum established float voltage LA04 SR SR 3.8.4.1 3.8.4.1 2. Verifying total battery terminal voltage is greater than or equal to 129-volts on float charge.

b. At least once per 92 days and within 7 days after a battery discharge (battery terminal voltage below 110-volts), or battery overcharge (battery terminal voltage above 150-volts), by: See ITS 3.8.6
1. Verifying that the parameters in Table 4.8-2 meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the connection See ITS

-6 resistance of these items is less than 150 x 10 ohms, and 5.5.15

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F. See ITS 3.8.6 SR 3.8.4.2 c. At least once per 18 months by verifying that: In accordance with the Surveillance Frequency Control Program LA02
1. The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, See ITS
2. The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion 5.5.15 material,

-6

3. The resistance of each cell-to-terminal connection is less than or equal to 150 x 10 ohms, and LA05 greater than or equal to the minimum established float voltage 129 volts M01 SR 3.8.4.2 4. The battery charger will supply at least 150 amperes at 125-volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Add proposed 2nd option for SR 3.8.4.2 L02 SR 3.8.4.3 d. At least once per 18 months by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when the battery is subjected to a battery service test. the design duty cycle LA06 In accordance with the Surveillance Frequency Control Program

e. At least once per 60 months by verifying that the battery capacity is at least 82% of the LA02 manufacturer's rating when subjected to a performance discharge test. Once per 60 month SR 3.8.4.3 Note 1 interval, this performance discharge test may be performed in lieu of the battery service test.

L03

f. Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85% of the service life expected for the application. See ITS Degradation is indicated when the battery capacity drops more than 10% of rated capacity from 3.8.6 its average on previous performance tests, or is below 90% of the manufacturer's rating.

Add proposed SR 3.8.4.3 NOTE 2 M02 Add proposed SR 3.8.4.3 for DG batteries with a Frequency of 24 months M03 In accordance with the Surveillance Frequency Control Program LA02 October 4, 1995 SEQUOYAH - UNIT 2 3/4 8-13 Amendment No. 18, 203 Page 9 of 9 Enclosure 2, Volume 13, Rev. 0, Page 298 of 638

Enclosure 2, Volume 13, Rev. 0, Page 299 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.1 requires, in part, a separate 125 volt DC battery bank and associated charger for each of the four diesel generator (DG) sets. CTS 3.8.2.3 requires, in part, a 125-volt DC battery bank and a full capacity charger for each of four DC vital battery channels. ITS LCO 3.8.4 requires two vital DC electrical power trains and four DG DC electrical power subsystems to be OPERABLE.

This changes the CTS by combining the requirements for the vital battery, vital battery charger, DG battery, and DG battery charger into one separate Specification.

The purpose, in part, of CTS 3.8.1.1 and CTS 3.8.2.3 is to define the limiting condition for operation for required direct current (DC) systems during plant operation. ITS LCO 3.8.4 retains the requirements of CTS 3.8.2.3 and the applicable part of CTS 3.8.1.1 associated with batteries and battery chargers.

This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.1.1.b.5 requires, in part, a separate 125 volt DC battery bank and associated charger for each DG as a condition for OPERABILITY. ITS LCO 3.8.4 requires four DG DC electrical power subsystems to be OPERABLE.

ITS 3.8.4 ACTION D has been added for one DG DC electrical power subsystem inoperable and requires the associated DG be declared inoperable immediately.

This changes the CTS by providing explicit direction to declare the associated DG inoperable when its supporting battery or battery charger is inoperable.

The purpose of CTS 3.8.1.1.b.5 is to specify the OPERABILITY association between each DG set and its supporting battery and battery charger. ITS 3.8.4 ACTION D preserves this intent by explicitly requiring each DG to be declared inoperable if its associated DC electrical subsystem is inoperable. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 4.8.2.3.2 c.4 requires the battery charger supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS SR 3.8.4.2 requires, in part, verification that each battery charger supplies greater than or equal to 150 amps at greater than or equal to the minimum established float voltage for greater than or equal to 4 Sequoyah Unit 1 and Unit 2 Page 1 of 7 Enclosure 2, Volume 13, Rev. 0, Page 299 of 638

Enclosure 2, Volume 13, Rev. 0, Page 300 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING hours. This changes the CTS testing requirement from 125 volts to the minimum establish float voltage of 129 volts.

The purpose of CTS 4.8.2.3.2.c.4, in part, is to verify the OPERABILITY of the Vital battery charger. ITS 3.8.4.2 requires in part, verifying each battery charger supplies greater than or equal to 150 amps at greater than or equal to the minimum established float voltage (129 volts) for greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This change is designated as more restrictive because the surveillance testing voltage for CTS has been changed from 125 volts to greater than or equal to 129 volts to reflect the minimum established float voltage.

M02 CTS 4.8.2.3.2.d requires a battery service test for the vital batteries. The Surveillance does not specify that the testing be performed under certain unit conditions. ITS SR 3.8.4.3 requires a similar verification of battery capacity but is modified by a Note. ITS SR 3.8.4.3, Note 2 states that for the battery service test the Surveillance shall not be performed on in-service vital batteries in MODE 1, 2, 3, or 4, however, credit may be taken for unplanned events that satisfy this SR. This changes the CTS requirement by specifying conditions for when the associated vital batteries are tested.

The purpose of CTS 4.8.2.3.2.d is to verify the OPERABILITY of the Vital DC Batteries. The addition of the Note limiting the conditions under which the Surveillance can be performed is acceptable, because performance of the Surveillance on in-service vital batteries could cause perturbations to the electrical distribution system. Restricting performance of the Surveillance to the spared vital battery during MODES 1, 2, 3, and 4 minimizes challenges to continued steady state operation and, as a result, the units safety systems. This change is designated as more restrictive because testing required by the CTS does not contain this limitation.

M03 CTS 4.8.1.1.3.a.2 provides testing requirements to verify OPERABILITY of DG batteries and chargers by verifying total battery terminal voltage is within limits.

ITS SR 3.8.4.1 provides a similar test. In addition, ITS SR 3.8.4.3 requires verification every 24 months that each DG battery can supply and maintain in OPERABLE status the required emergency loads and any connected non-safety loads for the design duty cycle when subjected to a battery service test. ITS SR 3.8.4.3 includes an allowance (Note 1) allowing performance of a modified performance discharge test (ITS SR 3.8.6.6) in lieu of the battery service test. In addition, Note 2 allows credit to be taken for unplanned events that satisfy the SR. This changes the CTS by adding a new Surveillance Requirement for verifying the OPERABILITY of the DG batteries. (See DOC LA02 for a discussion of moving the 24 month Frequency for this Surveillance Requirement to the Surveillance Frequency Control Program.)

The purpose of the additional Surveillance Requirement is to ensure the DG battery is capable of adequately supplying its associated loads during a design basis accident. This change is acceptable because the new SR provides additional assurance that the DG batteries remain OPERABLE to perform their safety function. This change is designated as more restrictive because more Surveillance Requirements will be required in ITS than are required in CTS.

Sequoyah Unit 1 and Unit 2 Page 2 of 7 Enclosure 2, Volume 13, Rev. 0, Page 300 of 638

Enclosure 2, Volume 13, Rev. 0, Page 301 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b.5 states, in part, that a separate 125 volt DC battery and associated charger, supporting each required diesel generator, shall be OPERABLE. CTS 3.8.2.3 states, in part, that the DC vital battery channels shall be energized and OPERABLE and lists the details of what constitutes a channel including a footnote (*) that allows Battery Bank V to be substituted for any other required Battery Bank. In addition, CTS 4.8.2.3.2 footnote (*) states, in part, that the surveillances are applicable to Battery Bank V, but not charger V.

ITS LCO 3.8.4 requires two Vital DC electrical power trains and four DG DC electrical power subsystems to be OPERABLE. This changes the CTS by moving the details of the components of the DC Sources (battery and charger) from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for the Vital 125 V DC channels and DG DC electrical subsystems. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.1.1.3.a.2 requires, in part, demonstrating each DG 125-volt battery bank and associated charger is OPERABLE by verifying that total battery terminal voltage is within limits at least once per 7 days. CTS 4.8.2.3.2.a.2 requires demonstrating each required DC Vital 125-volt battery bank and charger is OPERABLE by verifying total battery terminal voltage is within limits at least once per 7 days. CTS 4.8.2.3.2.c.4 requires demonstrating each DC Vital 125-volt required charger is OPERABLE by verifying that the battery charger will supply a prescribed current for a designated period at least once per 18 months.

CTS 4.8.2.3.2.d requires demonstrating each DC Vital 125-volt battery bank is OPERABLE by verifying adequate battery capacity by performance of a prescribed test at least once per 18 months. ITS SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 require similar Surveillances and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program. Additionally, ITS SR 3.8.4.3 has been added to perform a service test on each DG battery every 24 months. (See DOC M03 for the discussion on adding of this SR). The Sequoyah Unit 1 and Unit 2 Page 3 of 7 Enclosure 2, Volume 13, Rev. 0, Page 301 of 638

Enclosure 2, Volume 13, Rev. 0, Page 302 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING 24 month Frequency for this Surveillances has also been relocated to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.3.a.2 requires verifying DG total battery terminal voltage is greater than or equal to 124 volts on float charge. ITS SR 3.8.4.1 requires verification that the DG battery terminal voltage is greater than or equal to the minimum established float voltage. This changes the CTS by moving the specific values of the minimum established float voltage from the CTS to the ITS Bases.

The removal of these details that are related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for an OPERABLE DG battery. This change is acceptable, because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.a.2 requires verifying vital battery total battery terminal voltage to be greater than or equal to 129 volts on float charge. ITS SR 3.8.4.1 requires the verification that the vital battery terminal voltage is greater than or equal to the minimum established float voltage. This changes the CTS by moving the specific values of the minimum established float voltage from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Sequoyah Unit 1 and Unit 2 Page 4 of 7 Enclosure 2, Volume 13, Rev. 0, Page 302 of 638

Enclosure 2, Volume 13, Rev. 0, Page 303 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING protection of public health and safety. The ITS still retains the requirements that the vital battery terminal voltage be greater than or equal to the minimum established float voltage. This change is acceptable, because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.c.4 requires the vital battery chargers supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS SR 3.8.4.2 requires the verification the vital battery charger supplies greater than or equal to 150 amps at greater than or equal to the minimum established float voltage for greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This changes the CTS by moving the specific values of the minimum established float voltage from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements that the battery charger voltage be greater than or equal to the minimum established float voltage. This change is acceptable, because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA06 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.d requires, verifying the vital battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when the battery is subjected to a battery service test. ITS SR 3.8.4.3 requires, the verification that the vital battery capacity is adequate to supply and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. This changes the CTS by moving the specific value of the design duty cycle, from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements that the design duty cycle be maintained. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change Sequoyah Unit 1 and Unit 2 Page 5 of 7 Enclosure 2, Volume 13, Rev. 0, Page 303 of 638

Enclosure 2, Volume 13, Rev. 0, Page 304 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 ACTION b states, that with one 125-volt DC battery bank and/or charger inoperable, to restore the inoperable battery bank and/or charger to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or commence a unit shutdown. ITS 3.8.4 ACTION A has been added to provide Actions for the condition of one or more vital battery chargers inoperable. ITS 3.8.4 Required Action A.1 requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

ITS 3.8.4 Required Action A.2 requires the verification that the battery float current is 2 amps once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.4 Required Action A.3 requires the restoration of the battery chargers to OPERABLE status within 7 days. This changes the CTS by extending the time a required battery charger may be inoperable.

The purpose of CTS 3.8.2.3 is to ensure that the two trains of DC electrical power system (four vital DC channels) are capable of supplying the associated loads during a design bases accident. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with the safe operation under the specified Condition, considering the OPERABLE status of the redundant systems and features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The proposed ITS 3.8.4 ACTION A provides up to a 7 day restoration time for an inoperable vital battery charger.

However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The first priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (ITS 3.8.4 Required Action A.1). Presuming that the battery discharge (if occurring) can be terminated and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit. The second tiered action proposes 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 7 day restoration period, is an acceptable relaxation. Since the focus of this allowance is that the battery capacity be preserved and assured, the means of accomplishing this may be the spare battery charger employed within the initial 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or the degraded inservice charger that continues to float the battery. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 6 of 7 Enclosure 2, Volume 13, Rev. 0, Page 304 of 638

Enclosure 2, Volume 13, Rev. 0, Page 305 of 638 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING L02 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.c.4 requires, in part, the battery charger to supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS SR 3.8.4.2 includes a similar test.

In addition, the SR provides an alternative test method. This test method requires a verification that each vital battery charger can recharge the battery to the fully charge state within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. This changes the CTS by allowing an alternate test method that is not currently allowed.

The purpose of CTS 4.8.2.3.2.c.4 is to verify the required 125 V DC vital battery chargers can recharge their respective batteries following a loss of offsite power event. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify the equipment used to meet the LCO can perform its required functions. This alternate test provides an acceptable method for determining charger capability by actually recharging a discharge battery within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while supplying the required loads. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.d requires, in part, a verification of the station battery capacity when the battery is subjected to a service test. CTS 4.8.2.3.2.e allows substitution of a performance discharge test in lieu of the battery service test once per 60 month interval. ITS SR 3.8.4.3 is modified by Note 1 which allows the modified performance discharge test in SR 3.8.6.6 to be performed in lieu of the service test in SR 3.8.4.3. This changes the CTS by allowing a modified performance discharge test to be substituted for a service test for any performance of the Surveillance, instead of the current once per 60 months.

This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). As stated in the Bases for ITS SR 3.8.6.6, the battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test. This modified test has been shown to be as effective in determining battery capacity as the standard service test. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 7 of 7 Enclosure 2, Volume 13, Rev. 0, Page 305 of 638

Enclosure 2, Volume 13, Rev. 0, Page 306 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 306 of 638

Enclosure 2, Volume 13, Rev. 0, Page 307 of 638 CTS DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating Two Vital trains and four diesel generator (DG) DC electrical power 3.8.2.3 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be 1 OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME vital DOC L01 A. One [or two] battery A.1 Restore battery terminal [2 hours] 3 2

charger[s] on one voltage to greater than or 1

subsystem inoperable. equal to the minimum train established float voltage.

AND A.2 Verify battery float current Once per [12] hours 3

[2] amps.

AND vital 7 days 1 3 4 A.3 Restore battery charger[s] [72] hours to OPERABLE status.

[B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ] 5 on one subsystem] OPERABLE status.

inoperable.

B vital B vital 3.8.2.3 ACTION b C. One DC electrical power C.1 Restore DC electrical [2] hours 5 3 1

train subsystem inoperable power subsystem to for reasons other than OPERABLE status. train Condition A [or B]. 3 3.8.2.3 C C ACTION b D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion 5 Time not met. AND 2 of Condition A or B C D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SEQUOYAH UNIT 1 INSERT 1 Amendment XXX 2 Westinghouse STS 3.8.4-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 307 of 638

Enclosure 2, Volume 13, Rev. 0, Page 308 of 638 CTS 3.8.4 2 INSERT 1 DOC A03 D. One or more DG DC D.1 Declare associated DG(s) Immediately electrical power inoperable.

subsystem(s) inoperable.

Insert Page 3.8.4-1 Enclosure 2, Volume 13, Rev. 0, Page 308 of 638

Enclosure 2, Volume 13, Rev. 0, Page 309 of 638 CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.3.a.2, 4.8.2.3.2.a.2 SR 3.8.4.1 Verify battery terminal voltage is greater than or [ 7 days equal to the minimum established float voltage.

OR In accordance 6 with the Surveillance Frequency Control Program ]

vital 150 4.8.2.3.2.c.4 SR 3.8.4.2 Verify each battery charger supplies [400] amps at [ [18] months 1 3 greater than or equal to the minimum established float voltage for [8] hours. OR 3 4

OR In accordance vital 36 with the 6 DOC L02 Verify each battery charger can recharge the battery Surveillance 1 to the fully charged state within [24] hours while Frequency 3 supplying the largest combined demands of the Control Program ]

various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.4-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 309 of 638

Enclosure 2, Volume 13, Rev. 0, Page 310 of 638 CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.2.3.2.d, 4.8.2.3.2.e, SR 3.8.4.3 ------------------------------NOTES-----------------------------

DOC M03 1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3. for the vital batteries 2

INSERT 2 3

DOC M02 2. This Surveillance shall not normally be on in-service performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed 7 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 battery capacity is adequate to supply, and [ [18] months maintain in OPERABLE status, the required 1 emergency loads for the design duty cycle when OR subjected to a battery service test.

actual or simulated 6 In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.4-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 310 of 638

Enclosure 2, Volume 13, Rev. 0, Page 311 of 638 CTS 3.8.4 7 INSERT 2 DOC M03 2. The modified performance discharge test in SR 3.8.6.7 may be performed in lieu of SR 3.8.4.3 for the DG batteries.

Insert Page 3.8.4-3 Enclosure 2, Volume 13, Rev. 0, Page 311 of 638

Enclosure 2, Volume 13, Rev. 0, Page 312 of 638 CTS DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating Two Vital trains and four diesel generator (DG) DC electrical power 3.8.2.3 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be 1 OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME vital DOC L01 A. One [or two] battery A.1 Restore battery terminal [2 hours] 3 2

charger[s] on one voltage to greater than or 1

subsystem inoperable. equal to the minimum train established float voltage.

AND A.2 Verify battery float current Once per [12] hours 3

[2] amps.

AND vital 7 days 1 3 4 A.3 Restore battery charger[s] [72] hours to OPERABLE status.

[B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ] 5 on one subsystem] OPERABLE status.

inoperable.

B vital B vital 3.8.2.3 ACTION b C. One DC electrical power C.1 Restore DC electrical [2] hours 5 3 1

train subsystem inoperable power subsystem to for reasons other than OPERABLE status. train Condition A [or B]. 3 3.8.2.3 C C ACTION b D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion 5 Time not met. AND 2 of Condition A or B C D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SEQUOYAH UNIT 2 INSERT 1 Amendment XXX 2 Westinghouse STS 3.8.4-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 312 of 638

Enclosure 2, Volume 13, Rev. 0, Page 313 of 638 CTS 3.8.4 2 INSERT 1 DOC A03 D. One or more DG DC D.1 Declare associated DG(s) Immediately electrical power inoperable.

subsystem(s) inoperable.

Insert Page 3.8.4-1 Enclosure 2, Volume 13, Rev. 0, Page 313 of 638

Enclosure 2, Volume 13, Rev. 0, Page 314 of 638 CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.3.a.2, 4.8.2.3.2.a.2 SR 3.8.4.1 Verify battery terminal voltage is greater than or [ 7 days equal to the minimum established float voltage.

OR In accordance 6 with the Surveillance Frequency Control Program ]

vital 150 4.8.2.3.2.c.4 SR 3.8.4.2 Verify each battery charger supplies [400] amps at [ [18] months 1 3 greater than or equal to the minimum established float voltage for [8] hours. OR 3 4

OR In accordance vital 36 with the 6 DOC L02 Verify each battery charger can recharge the battery Surveillance 1 to the fully charged state within [24] hours while Frequency 3 supplying the largest combined demands of the Control Program ]

various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.4-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 314 of 638

Enclosure 2, Volume 13, Rev. 0, Page 315 of 638 CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.2.3.2.d, 4.8.2.3.2.e, SR 3.8.4.3 ------------------------------NOTES-----------------------------

DOC M03 1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3. for the vital batteries 2

INSERT 2 3

DOC M02 2. This Surveillance shall not normally be on in-service performed in MODE 1, 2, 3, or 4. However, vital batteries portions of the Surveillance may be performed 7 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 battery capacity is adequate to supply, and [ [18] months maintain in OPERABLE status, the required 1 emergency loads for the design duty cycle when OR subjected to a battery service test.

actual or simulated 6 In accordance with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.4-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 315 of 638

Enclosure 2, Volume 13, Rev. 0, Page 316 of 638 CTS 3.8.4 7 INSERT 2 DOC M03 2. The modified performance discharge test in SR 3.8.6.7 may be performed in lieu of SR 3.8.4.3 for the DG batteries.

Insert Page 3.8.4-3 Enclosure 2, Volume 13, Rev. 0, Page 316 of 638

Enclosure 2, Volume 13, Rev. 0, Page 317 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. An LCO, ACTION, and Surveillance Requirements have been added to ITS 3.8.4 to reflect SQN current licensing basis whereby diesel generator (DG) OPERABILITY is dependent on the associated DG DC electrical power subsystem.
3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
4. ISTS Required Action A.3 states, to restore a battery charger to OPERABLE status within [72] hours. Reviewers Notes allow Licensees adopting a Completion Time for Required Action A.3 of 7 days provided a commitment is made that an alternate means to charge the batteries will be available that is capable of being supplied power from a source that is independent of the offsite power supply. SQN will commit that an alternate means will be available to charge the batteries, and that the supplied power source is independent from the offsite power supply.
5. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been arranged in sequence.

6. ISTS SR 3.8.4.1, ISTS SR 3.8.4.2, and ISTS SR 3.8.4.3 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 is "In accordance with the Surveillance Frequency Control Program."
7. No portion of the battery service test can be performed on in-service vital batteries in MODES 1, 2, 3, or 4 without making the battery inoperable. The battery service test is normally performed by removing a vital battery from service and placing the spare vital battery in-service. Furthermore, the battery service test is not performed in steps, where only part of the test can be performed. Therefore, this part of the Note has been deleted.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 317 of 638

Enclosure 2, Volume 13, Rev. 0, Page 318 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 318 of 638

Enclosure 2, Volume 13, Rev. 0, Page 319 of 638 DC Sources - Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating INSERT 1 BASES sub BACKGROUND The station DC electrical power system provides the AC emergency 1 125 V Vital power system with control power. It also provides both motive and control power to selected safety related equipment and preferred AC vital INSERT 2 bus power (via inverters). As required by 10 CFR 50, Appendix A, 1 GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3).

Vital sub 2 1 The [125/250] VDC electrical power system consists of two independent INSERT 3 and redundant safety related Class 1E DC electrical power subsystems trains 1

([Train A and Train B]). Each subsystem consists of [two] 125 VDC train batteries [(each battery [50]% capacity)], the associated battery charger(s) for each battery, and all the associated control equipment and interconnecting cabling.

INSERT 4 [ The 250 VDC source is obtained by use of the two 125 VDC batteries 2 connected in series. Additionally there is [one] spare battery charger per INSERT 5 subsystem, which provides backup service in the event that the preferred battery charger is out of service. If the spare battery charger is substituted for one of the preferred battery chargers, then the requirements of independence and redundancy between subsystems are maintained. ] trains Vital During normal operation, the [125/250] VDC load is powered from the 2 1 battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

Vital trains The [Train A and Train B] DC electrical power subsystems provide the 6.9 2 1 control power for its associated Class 1E AC power load group, [4.16] kV 2

Shutdown Boards switchgear, and [480] V load centers. The DC electrical power 1 trains subsystems also provide DC electrical power to the inverters, which in 1 turn power the AC vital buses.

The DC power distribution system is described in more detail in Bases for LCO 3.8.9, "Distribution System - Operating," and LCO 3.8.10, "Distribution Systems - Shutdown."

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 319 of 638

Enclosure 2, Volume 13, Rev. 0, Page 320 of 638 B 3.8.4 1

INSERT 1 The DC electrical power system consists of the 125 V Vital DC electrical power subsystem and the diesel generator (DG) DC electrical power subsystem.

1 INSERT 2 Control power and generator field flashing for each DG is provided by the DG DC electrical power subsystem.

1 INSERT 3 Train A is associated with channels I and III and Train B is associated with channels II and IV 2

INSERT 4 The 125 V Vital DC electrical power subsystem has manual access to a fifth vital battery system. The fifth 125 VDC Vital Battery System is intended to serve as a replacement for any one of the four 125 VDC vital batteries during testing, maintenance, and outages with no loss of system reliability under any mode of operation.

2 INSERT 5 for channels I and II and one spare charger for channels III and IV Insert Page B 3.8.4-1 Enclosure 2, Volume 13, Rev. 0, Page 320 of 638

Enclosure 2, Volume 13, Rev. 0, Page 321 of 638 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

Vital Each 125/250 VDC battery is separately housed in a ventilated room train apart from its charger and distribution centers. Each subsystem is 1 train located in an area separated physically and electrically from the other train train subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. [There is no sharing between 2

redundant Class 1E subsystems, such as batteries, battery chargers, or 1

distribution panels.] trains Vital Each battery has adequate storage capacity to meet the duty cycle(s) discussed in the FSAR, Chapter [8] (Ref 4). The battery is designed with 1 2 U

additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

125 V Vital 82 trains The batteries for Train A and Train B DC electrical power subsystems are 1 sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The minimum design voltage limit is [105/210 V]. 2 Vital The battery cells are of flooded lead acid construction with a nominal specific gravity of [1.215]. This specific gravity corresponds to an open 60 2 123.78 circuit battery voltage of approximately 120 V for a [58] cell battery (i.e.,

2.063 cell voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 3 maintain its capacity for [30] days without further charging per minimum manufacturer's instructions. Optimal long term performance however, is obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides 2 of 129 V DC adequate over-potential, which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total 1

float voltage output of [128.8] V for a [58] cell battery as discussed in the FSAR, Chapter [8] (Ref. 4).

Vital train Each Train A and Train B DC electrical power subsystem battery charger 1 has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger also has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within [24] hours while supplying normal 1 12 2 steady state loads discussed in the FSAR, Chapter [8] (Ref. 4). INSERT 6 Each vital The battery charger is normally in the float-charge mode. Float-charge is 1 the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 321 of 638

Enclosure 2, Volume 13, Rev. 0, Page 322 of 638 B 3.8.4 1

INSERT 6 (with accident loads being supplied) following a 30 minute AC power outage and in approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (with normal loads being supplied) following a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AC power outage.

Insert Page B 3.8.4-2 Enclosure 2, Volume 13, Rev. 0, Page 322 of 638

Enclosure 2, Volume 13, Rev. 0, Page 323 of 638 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued) each Vital battery When desired, the charger can be placed in the equalize mode. The 1 equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours INSERT 7 discharged from the battery and amp-hours returned to the battery. 1 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 1 2 SAFETY U analyses in the FSAR, Chapter [6] (Ref. 5) and Chapter [15] (Ref. 6),

ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC 1

electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power and
b. A worst-case single failure.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Vital trains train 2

LCO The DC electrical power subsystems, each subsystem consisting of [two] 1 batteries, battery charger [for each battery] and the corresponding control 1 2 equipment and interconnecting cabling supplying power to the associated bus within the subsystem are required to be OPERABLE to ensure the 1 train availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any DC electrical power subsystem does not 1 train prevent the minimum safety function from being performed (Ref. 4).

INSERT 8 1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 323 of 638

Enclosure 2, Volume 13, Rev. 0, Page 324 of 638 B 3.8.4 1

INSERT 7 Control power for the DGs is provided by the four DG battery systems, one per DG. Each system is comprised of one 125VDC battery, the associated charger for each battery, and all associated control equipment and interconnecting cabling.

1 INSERT 8 The DG DC electrical power subsystems, each subsystem consisting of one battery, one battery charger and the corresponding control equipment and interconnecting cabling supply power to the associated DG control circuit are required to be OPERABLE to ensure the availability of the required power to support the operability of the diesel generator.

Insert Page B 3.8.4-3 Enclosure 2, Volume 13, Rev. 0, Page 324 of 638

Enclosure 2, Volume 13, Rev. 0, Page 325 of 638 DC Sources - Operating B 3.8.4 BASES LCO (continued)

Vital train 1

An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es).

APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

ACTIONS A.1, A.2, and A.3 train vital Condition A represents one subsystem with one [or two] battery chargers 1 2 inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, 2 the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 4 current portion of the battery charge profile following the service test (SR 3.8.4.3).

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 325 of 638

Enclosure 2, Volume 13, Rev. 0, Page 326 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within [2] hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

2 If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it is now fully capable of supplying the maximum expected load requirement. The

[2] amp value is based on returning the battery to [95]% charge and assumes a [5]% design margin for the battery. If at the expiration of the initial [12] hour period the battery float current is not less than or equal to

[2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.


REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in 4 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," and RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis."

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 326 of 638

Enclosure 2, Volume 13, Rev. 0, Page 327 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied 4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

vital 1

7 days Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of 2 restoring battery terminal voltage to greater than or equal to the minimum 1

7 day established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a fifth 2 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1


REVIEWERS NOTES---------------------------------

1. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Times of Required Actions B.1 and C.1 are in brackets. Any licensee wishing to request a longer Completion Time will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in RG 1.177 and RG 1.174.
2. Condition B is included if Required Action B.1 (one [or two]

batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is 6 used. If not, Condition B is deleted and only Condition C is used.

Condition B represents one subsystem with one [or two] batter[y][ies]

inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 327 of 638

Enclosure 2, Volume 13, Rev. 0, Page 328 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) batter[y][ies] will not be able to be brought online. The [2] hour limit allows sufficient time to effect restoration of an inoperable battery given that the majority of the conditions that lead to battery inoperability (e.g., 6 loss of battery charger, battery cell voltage less than [2.07] V, etc.) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 together with additional specific Completion Times.

B 6

C.1 B vital DC train Condition C represents one subsystem with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for train vital complete loss of DC power to the affected subsystem. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is consistent with the allowed time for an inoperable DC distribution subsystem.

vital trains If one of the required DC electrical power subsystems is inoperable for reasons other than Condition A or B (e.g., inoperable battery charger and 6 vital associated inoperable battery), the remaining DC electrical power train subsystem has the capacity to support a safe shutdown and to mitigate 1 an accident condition. Since a subsequent worst- case single failure vital could, however, result in the loss of the minimum necessary DC electrical trains subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is based on vital Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess vital unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

train C

D.1 and D.2 6 train vital If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

INSERT 9 1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 328 of 638

Enclosure 2, Volume 13, Rev. 0, Page 329 of 638 B 3.8.4 1

INSERT 9 D.1 If the DG DC electrical power subsystem(s) is inoperable, the associated DG(s) may be incapable of performing their intended function and must be immediately declared inoperable.

This declaration also requires entry into applicable Conditions and Required Actions for inoperable DG(s), LCO 3.8.1, "AC Sources - Operating."

Insert Page B 3.8.4-7 Enclosure 2, Volume 13, Rev. 0, Page 329 of 638

Enclosure 2, Volume 13, Rev. 0, Page 330 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries 1 helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the train or battery in a fully charged state while supplying the continuous steady 1

state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by 129 the battery manufacturer ([2.20] Vpc times the number of connected cells 1 or [127.6] V for a 58 cell battery at the battery terminals). This voltage 2 for the Vital batteries and 124 V maintains the battery plates in a condition that supports maintaining the for the DG batteries grid life. [ The 7 day Frequency is consistent with manufacturer recommendations. 5 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.4.2 vital This SR verifies the design capacity of the battery chargers. According to 1 Regulatory Guide 1.32 (Ref. 8), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensures that these requirements can be satisfied.

150 This SR provides two options. One option requires that each battery 2

charger be capable of supplying [400] amps at the minimum established float voltage for [8] hours. The ampere requirements are based on the 1 2 (129 V DC) 4 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 330 of 638

Enclosure 2, Volume 13, Rev. 0, Page 331 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time 7 period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours.

vital The other option requires that each battery charger be capable of 1 recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps. 2

[ The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month]

5 intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for 1 Vital batteries) to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 331 of 638

Enclosure 2, Volume 13, Rev. 0, Page 332 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The Surveillance Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 8) and Regulatory Guide 1.129 (Ref. 9), which state that the battery service test should be 5 performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months].

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

three s 1 and 2 This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

3 on in-service vital batteries Therefore, prior to performing a battery service test, the in-The reason for Note 2 is that performing the Surveillance would perturb service vital battery to the electrical distribution system and challenge safety systems. This be tested is removed from service and the restriction from normally performing the Surveillance in MODE 1 or 2 is spare vital battery is further amplified to allow portions of the Surveillance to be performed for placed in-service.

the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY 6 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 the assessment. Credit may be taken for unplanned events that satisfy this SR.

1 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 332 of 638

Enclosure 2, Volume 13, Rev. 0, Page 333 of 638 DC Sources - Operating B 3.8.4 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

1971

3. IEEE-308-[1978]. 2 U
4. FSAR, Chapter [8].
5. FSAR, Chapter [6]. 1 2
6. FSAR, Chapter [15].
7. Regulatory Guide 1.93, December 1974.

1972

8. Regulatory Guide 1.32, February 1977. 1
9. Regulatory Guide 1.129, December 1974.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.4-11 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 333 of 638

Enclosure 2, Volume 13, Rev. 0, Page 334 of 638 DC Sources - Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating INSERT 1 BASES sub BACKGROUND The station DC electrical power system provides the AC emergency 1 125 V Vital power system with control power. It also provides both motive and control power to selected safety related equipment and preferred AC vital INSERT 2 bus power (via inverters). As required by 10 CFR 50, Appendix A, 1 GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3).

Vital sub 2 1 The [125/250] VDC electrical power system consists of two independent INSERT 3 and redundant safety related Class 1E DC electrical power subsystems trains 1

([Train A and Train B]). Each subsystem consists of [two] 125 VDC train batteries [(each battery [50]% capacity)], the associated battery charger(s) for each battery, and all the associated control equipment and interconnecting cabling.

INSERT 4 [ The 250 VDC source is obtained by use of the two 125 VDC batteries 2 connected in series. Additionally there is [one] spare battery charger per INSERT 5 subsystem, which provides backup service in the event that the preferred battery charger is out of service. If the spare battery charger is substituted for one of the preferred battery chargers, then the requirements of independence and redundancy between subsystems are maintained. ] trains Vital During normal operation, the [125/250] VDC load is powered from the 2 1 battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

Vital trains The [Train A and Train B] DC electrical power subsystems provide the 6.9 2 1 control power for its associated Class 1E AC power load group, [4.16] kV 2

Shutdown Boards switchgear, and [480] V load centers. The DC electrical power 1 trains subsystems also provide DC electrical power to the inverters, which in 1 turn power the AC vital buses.

The DC power distribution system is described in more detail in Bases for LCO 3.8.9, "Distribution System - Operating," and LCO 3.8.10, "Distribution Systems - Shutdown."

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 334 of 638

Enclosure 2, Volume 13, Rev. 0, Page 335 of 638 B 3.8.4 1

INSERT 1 The DC electrical power system consists of the 125 V Vital DC electrical power subsystem and the diesel generator (DG) DC electrical power subsystem.

1 INSERT 2 Control power and generator field flashing for each DG is provided by the DG DC electrical power subsystem.

1 INSERT 3 Train A is associated with channels I and III and Train B is associated with channels II and IV 2

INSERT 4 The 125 V Vital DC electrical power subsystem has manual access to a fifth vital battery system. The fifth 125 VDC Vital Battery System is intended to serve as a replacement for any one of the four 125 VDC vital batteries during testing, maintenance, and outages with no loss of system reliability under any mode of operation.

2 INSERT 5 for channels I and II and one spare charger for channels III and IV Insert Page B 3.8.4-1 Enclosure 2, Volume 13, Rev. 0, Page 335 of 638

Enclosure 2, Volume 13, Rev. 0, Page 336 of 638 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

Vital Each 125/250 VDC battery is separately housed in a ventilated room train apart from its charger and distribution centers. Each subsystem is 1 train located in an area separated physically and electrically from the other train train subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. [There is no sharing between 2

redundant Class 1E subsystems, such as batteries, battery chargers, or 1

distribution panels.] trains Vital Each battery has adequate storage capacity to meet the duty cycle(s) discussed in the FSAR, Chapter [8] (Ref 4). The battery is designed with 1 2 U

additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

125 V Vital 82 trains The batteries for Train A and Train B DC electrical power subsystems are 1 sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The minimum design voltage limit is [105/210 V]. 2 Vital The battery cells are of flooded lead acid construction with a nominal specific gravity of [1.215]. This specific gravity corresponds to an open 60 2 123.78 circuit battery voltage of approximately 120 V for a [58] cell battery (i.e.,

2.063 cell voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 3 maintain its capacity for [30] days without further charging per minimum manufacturer's instructions. Optimal long term performance however, is obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides 2 of 129 V DC adequate over-potential, which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total 1

float voltage output of [128.8] V for a [58] cell battery as discussed in the FSAR, Chapter [8] (Ref. 4).

Vital train Each Train A and Train B DC electrical power subsystem battery charger 1 has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger also has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within [24] hours while supplying normal 1 12 2 steady state loads discussed in the FSAR, Chapter [8] (Ref. 4). INSERT 6 Each vital The battery charger is normally in the float-charge mode. Float-charge is 1 the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 336 of 638

Enclosure 2, Volume 13, Rev. 0, Page 337 of 638 B 3.8.4 1

INSERT 6 (with accident loads being supplied) following a 30 minute AC power outage and in approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (with normal loads being supplied) following a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AC power outage.

Insert Page B 3.8.4-2 Enclosure 2, Volume 13, Rev. 0, Page 337 of 638

Enclosure 2, Volume 13, Rev. 0, Page 338 of 638 DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued) each Vital battery When desired, the charger can be placed in the equalize mode. The 1 equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours INSERT 7 discharged from the battery and amp-hours returned to the battery. 1 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 1 2 SAFETY U analyses in the FSAR, Chapter [6] (Ref. 5) and Chapter [15] (Ref. 6),

ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC 1

electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power and
b. A worst-case single failure.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Vital trains train 2

LCO The DC electrical power subsystems, each subsystem consisting of [two] 1 batteries, battery charger [for each battery] and the corresponding control 1 2 equipment and interconnecting cabling supplying power to the associated bus within the subsystem are required to be OPERABLE to ensure the 1 train availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any DC electrical power subsystem does not 1 train prevent the minimum safety function from being performed (Ref. 4).

INSERT 8 1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 338 of 638

Enclosure 2, Volume 13, Rev. 0, Page 339 of 638 B 3.8.4 1

INSERT 7 Control power for the DGs is provided by the four DG battery systems, one per DG. Each system is comprised of one 125VDC battery, the associated charger for each battery, and all associated control equipment and interconnecting cabling.

1 INSERT 8 The DG DC electrical power subsystems, each subsystem consisting of one battery, one battery charger and the corresponding control equipment and interconnecting cabling supply power to the associated DG control circuit are required to be OPERABLE to ensure the availability of the required power to support the operability of the diesel generator.

Insert Page B 3.8.4-3 Enclosure 2, Volume 13, Rev. 0, Page 339 of 638

Enclosure 2, Volume 13, Rev. 0, Page 340 of 638 DC Sources - Operating B 3.8.4 BASES LCO (continued)

Vital train 1

An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es).

APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

ACTIONS A.1, A.2, and A.3 train vital Condition A represents one subsystem with one [or two] battery chargers 1 2 inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, 2 the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 4 current portion of the battery charge profile following the service test (SR 3.8.4.3).

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 340 of 638

Enclosure 2, Volume 13, Rev. 0, Page 341 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within [2] hours, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

2 If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it is now fully capable of supplying the maximum expected load requirement. The

[2] amp value is based on returning the battery to [95]% charge and assumes a [5]% design margin for the battery. If at the expiration of the initial [12] hour period the battery float current is not less than or equal to

[2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.


REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in 4 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," and RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis."

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 341 of 638

Enclosure 2, Volume 13, Rev. 0, Page 342 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied 4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

vital 1

7 days Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of 2 restoring battery terminal voltage to greater than or equal to the minimum 1

7 day established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a fifth 2 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1


REVIEWERS NOTES---------------------------------

1. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Times of Required Actions B.1 and C.1 are in brackets. Any licensee wishing to request a longer Completion Time will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in RG 1.177 and RG 1.174.
2. Condition B is included if Required Action B.1 (one [or two]

batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is 6 used. If not, Condition B is deleted and only Condition C is used.

Condition B represents one subsystem with one [or two] batter[y][ies]

inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 342 of 638

Enclosure 2, Volume 13, Rev. 0, Page 343 of 638 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) batter[y][ies] will not be able to be brought online. The [2] hour limit allows sufficient time to effect restoration of an inoperable battery given that the majority of the conditions that lead to battery inoperability (e.g., 6 loss of battery charger, battery cell voltage less than [2.07] V, etc.) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 together with additional specific Completion Times.

B 6

C.1 B vital DC train Condition C represents one subsystem with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for train vital complete loss of DC power to the affected subsystem. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is consistent with the allowed time for an inoperable DC distribution subsystem.

vital trains If one of the required DC electrical power subsystems is inoperable for reasons other than Condition A or B (e.g., inoperable battery charger and 6 vital associated inoperable battery), the remaining DC electrical power train subsystem has the capacity to support a safe shutdown and to mitigate 1 an accident condition. Since a subsequent worst- case single failure vital could, however, result in the loss of the minimum necessary DC electrical trains subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is based on vital Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess vital unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

train C

D.1 and D.2 6 train vital If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

INSERT 9 1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 343 of 638

Enclosure 2, Volume 13, Rev. 0, Page 344 of 638 B 3.8.4 1

INSERT 9 D.1 If the DG DC electrical power subsystem(s) is inoperable, the associated DG(s) may be incapable of performing their intended function and must be immediately declared inoperable.

This declaration also requires entry into applicable Conditions and Required Actions for inoperable DG(s), LCO 3.8.1, "AC Sources - Operating."

Insert Page B 3.8.4-7 Enclosure 2, Volume 13, Rev. 0, Page 344 of 638

Enclosure 2, Volume 13, Rev. 0, Page 345 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries 1 helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the train or battery in a fully charged state while supplying the continuous steady 1

state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by 129 the battery manufacturer ([2.20] Vpc times the number of connected cells 1 or [127.6] V for a 58 cell battery at the battery terminals). This voltage 2 for the Vital batteries and 124 V maintains the battery plates in a condition that supports maintaining the for the DG batteries grid life. [ The 7 day Frequency is consistent with manufacturer recommendations. 5 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.4.2 vital This SR verifies the design capacity of the battery chargers. According to 1 Regulatory Guide 1.32 (Ref. 8), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensures that these requirements can be satisfied.

150 This SR provides two options. One option requires that each battery 2

charger be capable of supplying [400] amps at the minimum established float voltage for [8] hours. The ampere requirements are based on the 1 2 (129 V DC) 4 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 345 of 638

Enclosure 2, Volume 13, Rev. 0, Page 346 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time 7 period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours.

vital The other option requires that each battery charger be capable of 1 recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps. 2

[ The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month]

5 intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for 1 Vital batteries) to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 346 of 638

Enclosure 2, Volume 13, Rev. 0, Page 347 of 638 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The Surveillance Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 8) and Regulatory Guide 1.129 (Ref. 9), which state that the battery service test should be 5 performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months].

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

three s 1 and 2 This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

3 on in-service vital batteries Therefore, prior to performing a battery service test, the in-The reason for Note 2 is that performing the Surveillance would perturb service vital battery to the electrical distribution system and challenge safety systems. This be tested is removed from service and the restriction from normally performing the Surveillance in MODE 1 or 2 is spare vital battery is further amplified to allow portions of the Surveillance to be performed for placed in-service.

the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY 6 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 the assessment. Credit may be taken for unplanned events that satisfy this SR.

1 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 347 of 638

Enclosure 2, Volume 13, Rev. 0, Page 348 of 638 DC Sources - Operating B 3.8.4 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

1971

3. IEEE-308-[1978]. 2 U
4. FSAR, Chapter [8].
5. FSAR, Chapter [6]. 1 2
6. FSAR, Chapter [15].
7. Regulatory Guide 1.93, December 1974.

1972

8. Regulatory Guide 1.32, February 1977. 1
9. Regulatory Guide 1.129, December 1974.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.4-11 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 348 of 638

Enclosure 2, Volume 13, Rev. 0, Page 349 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.
4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
5. ISTS SR 3.8.4.1, ISTS SR 3.8.4.2, and ISTS SR 3.8.4.3 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 is "In accordance with the Surveillance Frequency Control Program."
6. Changes have been made to be consistent with changes made to the Specifications.
7. Removed information related to the basis for the time that a battery charger is required to be capable of supplying 150 amps at the minimum established float voltage, as the SQN current licensing basis does not include time for the charger temperature to stabilize.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 349 of 638

Enclosure 2, Volume 13, Rev. 0, Page 350 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 350 of 638

Enclosure 2, Volume 13, Rev. 0, Page 351 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 351 of 638

, Volume 13, Rev. 0, Page 352 of 638 ATTACHMENT 5 ITS 3.8.5, DC SOURCES - SHUTDOWN , Volume 13, Rev. 0, Page 352 of 638

, Volume 13, Rev. 0, Page 353 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 353 of 638

Enclosure 2, Volume 13, Rev. 0, Page 354 of 638 ITS A01 ITS 3.8.5 ELECTRICAL POWER SYSTEMS SHUTD0WN Add proposed LCO 3.8.5 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.5 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

See ITS 3.8.2

1. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 See ITS
4. A fuel transfer pump, and 3.8.2 LA01 LCO 3.8.5 5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger. See ITS 3.8.10 Applicability APPLICABILITY: MODES 5 and 6.

, During movement of irradiated fuel assemblies. M01 ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all See ITS 3.8.2 operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions that could result in loss of required shutdown margin or boron concentration.

Add proposed ACTION B A03 SURVEILLANCE REQUIREMENTS SR 3.8.5.2 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 3.8.2 4.8.1.1.2.a.5), and 4.8.1.1.3.

Add proposed SR 3.8.4.3 for DG batteries M02 May 22, 2003 SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. 241, 285 Page 1 of 4 Enclosure 2, Volume 13, Rev. 0, Page 354 of 638

Enclosure 2, Volume 13, Rev. 0, Page 355 of 638 ITS A01 ITS 3.8.5 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN Add proposed LCO 3.8.5 A02 LIMITING CONDITION FOR OPERATION See ITS 3.8.10 LCO 3.8.5 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be energized and 0PERABLE:

See ITS 2 - 125-volt D.C. boards either I and III or II and IV, and 3.8.10 LCO 3.8.5 2* - 125-volt battery banks and chargers, one associated with each operable D.C. board LA01 Applicability APPLICABILITY: MODES 5 and 6. , During movement of irradiated fuel assemblies. M01 ACTION:

Add ACTIONS Note M01 With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See ITS 3.8.10 Add proposed ACTION A L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability 3.8.10 with an overall battery voltage of greater than or equal to 125 volts.

SR 3.8.5.1 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.

  • D.C. Battery Bank V may be substituted for any other Battery Bank. LA01 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-14 Amendment No. 37 Page 2 of 4 Enclosure 2, Volume 13, Rev. 0, Page 355 of 638

Enclosure 2, Volume 13, Rev. 0, Page 356 of 638 ITS ITS 3.8.5 A01 ELECTRICAL POWER SYSTEMS SHUTDOWN Add proposed LCO 3.8.5 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.5 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:

See ITS 3.8.2

l. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 See ITS
4. A fuel transfer pump, and 3.8.2 LA01 LCO 3.8.5 5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger. See ITS 3.8.10 Applicability APPLICABILITY: MODES 5 and 6. ,During movement of irradiated fuel assemblies M01 ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions See ITS 3.8.2 that could result in loss of required shutdown margin or boron concentration.

Add proposed ACTION A03 SURVEILLANCE REQUIREMENTS SR 3.8.5.2 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 3.8.2 4.8.1.1.2.a.5), and 4.8.1.1.3.

Add proposed SR 3.8.4.3 for DG batteries M02 May 22, 2003 SEQUOYAH - UNIT 2 3/4 8-9 Amendment No. 231, 274 Page 3 of 4 Enclosure 2, Volume 13, Rev. 0, Page 356 of 638

Enclosure 2, Volume 13, Rev. 0, Page 357 of 638 ITS ITS 3.8.5 A01 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN Add proposed LCO 3.8.5 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.5 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be and OPERABLE and See ITS energized: 3.8.10 See ITS 2 - 125-volt D.C. boards either I and III or II and IV, and 3.8.10 LCO 3.8.5 2* - 125-volt battery banks and chargers, one associated with each operable D.C. board LA01 Applicability APPLICABILITY: MODES 5 and 6. ,During movement of irradiated fuel assemblies M01 ACTION: Add ACTIONS Note M01 With less than the above complement of D.C. equipment and board OPERABLE and energized, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See ITS 3.8.10 Add proposed ACTION A L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and See ITS energized at least once per 7 days by verifying correct breaker alignment and voltage on the board with 3.8.10 an overall battery voltage of greater than or equal to 125 volts.

SR 3.8.5.1 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.

  • D.C. Battery Bank V may be substituted for any other Battery Bank. LA01 January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-15 Amendment No. 29 Page 4 of 4 Enclosure 2, Volume 13, Rev. 0, Page 357 of 638

Enclosure 2, Volume 13, Rev. 0, Page 358 of 638 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.2 requires, in part, a separate 125-volt DC battery bank and associated charger for each required diesel generator (DG). CTS 3.8.2.4 requires, in part, two 125-volt DC battery banks and chargers, one associated with each OPERABLE DC board. ITS LCO 3.8.5 requires one vital DC electrical power train to be OPERABLE and the DG DC electrical power subsystems required to support one train of DGs to be OPERABLE. This changes the CTS by combining the requirements for the vital batteries, vital battery chargers, DG batteries, and DG battery chargers into one separate Specification.

The change is acceptable because no changes are made to CTS requirements.

The change in format from the CTS to the ITS maintains the technical requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.1.2.b.5 requires, in part, DG sets with a separate and independent 125-volt DC battery bank and associated charger for the DG to be OPERABLE.

ITS LCO 3.8.5 requires, in part, the required DG DC electrical power subsystems to be OPERABLE to support DG OPERABILITY. ITS 3.8.5 ACTION B requires for an inoperable DG DC electrical power subsystem to immediately declare the associated DG inoperable. This changes the CTS by specifying an Action to declare a DG inoperable if its associated DC subsystem is inoperable.

The purpose of CTS 3.8.1.2 is to specify the requirements for DG OPERABILITY.

ITS 3.8.5 ACTION B preserves the intent of CTS 3.8.1.2 by declaring the DG inoperable if its associated DC subsystem is inoperable. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2 and CTS 3.8.2.4 is applicable in MODES 5 and 6. ITS 3.8.5 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

Sequoyah Unit 1 and Unit 2 Page 1 of 4 Enclosure 2, Volume 13, Rev. 0, Page 358 of 638

Enclosure 2, Volume 13, Rev. 0, Page 359 of 638 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN This change is acceptable because the proposed requirements are necessary to ensure the DC electrical power sources are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies.

Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate DC electrical power source requirements are specified during fuel handling and ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supplies are not available (See DOC L01 for the changes to the Required Actions). This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.5 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only in MODES 5 and 6.

M02 The CTS 4.8.1.2 provides testing requirements to verify OPERABILITY of DG batteries and chargers in MODES 5 and 6 by verifying total battery terminal voltage is within limits. ITS SR 3.8.4.1 provides a similar test. In addition, ITS SR 3.8.4.3 requires verification that each DG battery can supply and maintain the required emergency loads and any connected non-safety loads for the design duty cycle when subjected to a battery service test. ITS SR 3.8.5.1 adds the requirement that these new surveillance requirements are also applicable in MODES 5 and 6 and during movement of irradiated fuel. This changes the CTS by requiring an additional battery Surveillance Requirement in MODES 5 and 6 and during movement of irradiated fuel.

The purpose of the additional Surveillance Requirement is to ensure each required DG battery is capable of adequately supplying its associated loads during postulated accidents. This change is acceptable because the new SR provides additional assurance that the DG batteries remain OPERABLE to perform their safety function. This change is designated as more restrictive because it adds an SR to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.4 states, in part, two 125-volt battery banks and Sequoyah Unit 1 and Unit 2 Page 2 of 4 Enclosure 2, Volume 13, Rev. 0, Page 359 of 638

Enclosure 2, Volume 13, Rev. 0, Page 360 of 638 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN chargers (one associated with each OPERABLE DC board) are required to support either channels I and III (Train A) or channels II and IV (Train B).

Footnote (*) allows battery bank V to be substituted for any other battery bank.

CTS 3.8.1.2 states, in part, a separate 125-volt DC battery bank and associated charger shall be OPERABLE for the required Diesel Generator sets 1A-A and 2A-A or 1B-B and 2B-B. ITS LCO 3.8.5 requires one vital DC electrical power train and the DG DC electrical power subsystems required to support one train of DGs to be OPERABLE. This changes the CTS by moving the details of the DG DC electrical power subsystems and vital DC electrical power subsystems from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the OPERABILITY requirements for electrical power trains. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) With less than the minimum complement of DC sources OPERABLE, CTS 3.8.2.4 ACTION requires the establishment of containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.5 ACTION A requires suspending movement of irradiated fuel assemblies, suspending operations involving a positive reactivity addition that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore required DC electrical power sources to operable status. This changes the CTS by replacing the existing Required Action to restore containment integrity with Actions that will prevent a fuel handling accident from occurring and Actions that will ensure the reactor remains subcritical.

The purpose of the CTS 3.8.2.4 Action is to isolate the containment to minimize any release from the plant if an event were to occur during shutdown conditions with no DC Sources OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The purposed Required Actions require the suspension of movement of irradiated fuel assemblies, suspension of operations involving positive reactivity additions that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore required DC electrical power source to OPERABLE status.

Suspending the movement of irradiated fuel assemblies will prevent a fuel handling accident from occurring and suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit will ensure the reactor remains subcritical. The actions to restore the required DC Sequoyah Unit 1 and Unit 2 Page 3 of 4 Enclosure 2, Volume 13, Rev. 0, Page 360 of 638

Enclosure 2, Volume 13, Rev. 0, Page 361 of 638 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN electrical power source to OPERABLE status will ensure the plant is placed in compliance with the LCO in an expeditious manner. The proposed actions will immediately minimize the potential for any accident releases outside of the containment and are considered acceptable in lieu of the current action to restore containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The actions may be considered somewhat more restrictive since immediate action is required, however, is classified as less restrictive since the current actions to restore containment integrity have been deleted. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 4 of 4 Enclosure 2, Volume 13, Rev. 0, Page 361 of 638

Enclosure 2, Volume 13, Rev. 0, Page 362 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 362 of 638

Enclosure 2, Volume 13, Rev. 0, Page 363 of 638 CTS DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown 3.8.1.2.b.5, LCO 3.8.5 [DC electrical power subsystem shall be OPERABLE to support the DC 1 3.8.2.4 electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."]

Vital INSERT 1 2 3

[One DC electrical power subsystem shall be OPERABLE.]


REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.

Action A the bracketed optional wording in Condition B are also 1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 4 ACTIONS


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

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

[A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charger[s on one voltage to greater than or subsystem] inoperable. equal to the minimum established float voltage.

AND AND 1 The redundant subsystem battery and A.2 Verify battery float current Once per [12] hours charger[s] OPERABLE. [2] amps.

AND SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.5-1 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 363 of 638

Enclosure 2, Volume 13, Rev. 0, Page 364 of 638 CTS 3.8.5 2

INSERT 1 3.8.1.2.b.5 train and the diesel generator (DG) DC electrical power subsystems required to support one train of DGs Insert Page 3.8.5-1 Enclosure 2, Volume 13, Rev. 0, Page 364 of 638

Enclosure 2, Volume 13, Rev. 0, Page 365 of 638 CTS DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore battery charger[s] [72] hours ] 1 to OPERABLE status.

DOC L01 A B. One [or more] required B.1 Declare affected required Immediately 1 4 5 vital DC electrical power feature(s) inoperable. 3 train subsystem[s] inoperable

[for reasons other than OR Condition A.

5 B.2.1 Suspend movement of Immediately OR A.1

[recently] irradiated fuel 4 1

assemblies.

Required Actions and associated Completion AND Time of Condition A not met]. B.2.2 Suspend operations Immediately 5 involving positive reactivity A.2 additions that could result in loss of required SDM or boron concentration.

AND B.2.3 Initiate action to restore Immediately 5 A.3 required DC electrical train power subsystems to 3 OPERABLE status.

INSERT 2 6 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.5-2 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 365 of 638

Enclosure 2, Volume 13, Rev. 0, Page 366 of 638 CTS 3.8.5 6

INSERT 2 DOC A03 B. One or more required B.1 Declare associated DG(s) Immediately DG DC electrical power inoperable.

subsystem(s) inoperable.

Insert Page 3.8.5-2 Enclosure 2, Volume 13, Rev. 0, Page 366 of 638

Enclosure 2, Volume 13, Rev. 0, Page 367 of 638 CTS DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.2, SR 3.8.5.1 -------------------------------NOTE------------------------------

7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.5-3 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 367 of 638

Enclosure 2, Volume 13, Rev. 0, Page 368 of 638 CTS DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown 3.8.1.2.b.5, LCO 3.8.5 [DC electrical power subsystem shall be OPERABLE to support the DC 1 3.8.2.4 electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."]

Vital INSERT 1 2 3

[One DC electrical power subsystem shall be OPERABLE.]


REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.

Action A the bracketed optional wording in Condition B are also 1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 4 ACTIONS


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

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

[A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charger[s on one voltage to greater than or subsystem] inoperable. equal to the minimum established float voltage.

AND AND 1 The redundant subsystem battery and A.2 Verify battery float current Once per [12] hours charger[s] OPERABLE. [2] amps.

AND SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.5-1 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 368 of 638

Enclosure 2, Volume 13, Rev. 0, Page 369 of 638 CTS 3.8.5 2

INSERT 1 3.8.1.2.b.5 train and the diesel generator (DG) DC electrical power subsystems required to support one train of DGs Insert Page 3.8.5-1 Enclosure 2, Volume 13, Rev. 0, Page 369 of 638

Enclosure 2, Volume 13, Rev. 0, Page 370 of 638 CTS DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore battery charger[s] [72] hours ] 1 to OPERABLE status.

DOC L01 A B. One [or more] required B.1 Declare affected required Immediately 1 4 5 vital DC electrical power feature(s) inoperable. 3 train subsystem[s] inoperable

[for reasons other than OR Condition A.

5 B.2.1 Suspend movement of Immediately OR A.1

[recently] irradiated fuel 4 1

assemblies.

Required Actions and associated Completion AND Time of Condition A not met]. B.2.2 Suspend operations Immediately 5 involving positive reactivity A.2 additions that could result in loss of required SDM or boron concentration.

AND B.2.3 Initiate action to restore Immediately 5 A.3 required DC electrical train power subsystems to 3 OPERABLE status.

INSERT 2 6 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.5-2 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 370 of 638

Enclosure 2, Volume 13, Rev. 0, Page 371 of 638 CTS 3.8.5 6

INSERT 2 DOC A03 B. One or more required B.1 Declare associated DG(s) Immediately DG DC electrical power inoperable.

subsystem(s) inoperable.

Insert Page 3.8.5-2 Enclosure 2, Volume 13, Rev. 0, Page 371 of 638

Enclosure 2, Volume 13, Rev. 0, Page 372 of 638 CTS DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.2, SR 3.8.5.1 -------------------------------NOTE------------------------------

7 4.8.2.4.2, DOC M02 The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.5-3 Rev. 4.0 3 Enclosure 2, Volume 13, Rev. 0, Page 372 of 638

Enclosure 2, Volume 13, Rev. 0, Page 373 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.5 and "Reviewers Note" have been deleted since the current licensing basis only requires one DC electrical power subsystem to be OPERABLE. ISTS 3.8.5 ACTION A has been deleted since only one required DC electrical power train is specified in the LCO. This allowance is only acceptable if the first option of the LCO is used. The subsequent Condition and Required Actions have been renumbered and modified, as applicable.
2. The second option of ISTS LCO 3.8.5 has been modified to specify one vital DC electrical power train and the diesel generator (DG) electrical power subsystems required to support one train of DGs is required to be OPERABLE. This change is consistent with the current licensing basis whereby each DG is supported by a separate DG DC electrical power subsystem instead of relying on the vital DC electrical power distribution subsystem.
3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
4. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
5. ISTS 3.8.5 Required Action B.1 provides an option to declare affected required feature(s) inoperable with one or more required DC electrical power subsystems inoperable. The ISTS Bases states this is acceptable because the remaining train with DC power available may be capable of supporting sufficient features to allow continued fuel movement. Thus this Required Action assumes two DC power sources are required by the LCO. This option has been deleted since only one train of vital DC electrical power is required to be OPERABLE by the LCO. Subsequent Required Actions have been renumbered and modified, as applicable.
6. ITS ACTION B has been added to ISTS 3.8.5 to ensure that a DG is declared inoperable if its associated DC electrical power subsystem is inoperable.
7. The allowance to not perform SR 3.8.4.2 and SR 3.8.4.3 has been deleted. The Sequoyah design includes a spare vital battery and charger per train. Therefore, the battery and charger SRs can be performed without making the train inoperable for the entire duration of the test.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 373 of 638

Enclosure 2, Volume 13, Rev. 0, Page 374 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 374 of 638

Enclosure 2, Volume 13, Rev. 0, Page 375 of 638 DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 2 U

ANALYSES assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [recently] irradiated fuel 2 assemblies ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling 2 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in MODES 2

[5 and 6] because the energy contained within the reactor pressure SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 375 of 638

Enclosure 2, Volume 13, Rev. 0, Page 376 of 638 DC Sources - Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYSES (continued) boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

One vital INSERT 1 LCO The DC electrical power subsystems, [each required ] [the required]

train

[subsystem consisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling 1 2 within the subsystem, [are] [is] required to be OPERABLE to support train

[required] [one] subsystem[s] of the distribution systems [required OPERABLE by LCO 3.8.10, "Distribution Systems - Shutdown."] This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents INSERT 2 [involving handling recently irradiated fuel]). 3 APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies, 2 provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core, SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 376 of 638

Enclosure 2, Volume 13, Rev. 0, Page 377 of 638 B 3.8.5 1

INSERT 1 train consists of two channels. Train A consists of channels I and III and Train B consists of channels II and IV.

3 INSERT 2 Control power for the DGs is provided by four DG DC electrical power subsystems, one per DG.

Each DG DC electrical power subsystem is comprised of one 125 VDC battery, an associated charger, and associated control equipment and interconnecting cabling. One DG DC electrical power subsystem is required to be OPERABLE for each required DG.

Insert Page B 3.8.5-2 Enclosure 2, Volume 13, Rev. 0, Page 377 of 638

Enclosure 2, Volume 13, Rev. 0, Page 378 of 638 DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY (continued)

b. Required features needed to mitigate a fuel handling accident

[involving handling recently irradiated fuel (i.e., fuel that has occupied 2 part of a critical reactor core within the previous [X] days)] are available,

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2, and A.3 4


REVIEWERS NOTE-----------------------------------

ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in 5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.

Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 378 of 638

Enclosure 2, Volume 13, Rev. 0, Page 379 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, 4

the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 5 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during 4 the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 379 of 638

Enclosure 2, Volume 13, Rev. 0, Page 380 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) been fully recharged. If at the expiration of the initial [12] hour period the battery float current is not less than or equal to [2] amps this indicates 4 there may be additional battery problems and the battery must be declared inoperable.


REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt a Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in 5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a 4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

A.1, A.2 and A.3 B.1, B.2.1, B.2.2, and B.2.3 INSERT 3 [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC 2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and 2 operations involving positive reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6).

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 380 of 638

Enclosure 2, Volume 13, Rev. 0, Page 381 of 638 B 3.8.5 2

INSERT 3 With the required train of DC electrical power sources inoperable, the minimum required DC electrical power source is not available.

Insert Page B 3.8.5-5 Enclosure 2, Volume 13, Rev. 0, Page 381 of 638

Enclosure 2, Volume 13, Rev. 0, Page 382 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power train subsystem[s] and to continue this action until restoration is accomplished 1 in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be INSERT 4 without sufficient power. 3 SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered 4 inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

U REFERENCES 1. FSAR, Chapter [6].

1 2

2. FSAR, Chapter [15].

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.5-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 382 of 638

Enclosure 2, Volume 13, Rev. 0, Page 383 of 638 B 3.8.5 3

INSERT 4 B.1 If one or more DG DC electrical power subsystems are inoperable, the associated DGs may be incapable of performing their intended function and must be immediately declared inoperable.

This declaration also requires entry into the applicable Conditions and Required Actions for inoperable DGs, LCO 3.8.2, "AC Sources - Shutdown".

Insert Page B 3.8.5-6 Enclosure 2, Volume 13, Rev. 0, Page 383 of 638

Enclosure 2, Volume 13, Rev. 0, Page 384 of 638 DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 2 U

ANALYSES assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [recently] irradiated fuel 2 assemblies ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling 2 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in MODES 2

[5 and 6] because the energy contained within the reactor pressure SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 384 of 638

Enclosure 2, Volume 13, Rev. 0, Page 385 of 638 DC Sources - Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYSES (continued) boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

One vital INSERT 1 LCO The DC electrical power subsystems, [each required ] [the required]

train

[subsystem consisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling 1 2 within the subsystem, [are] [is] required to be OPERABLE to support train

[required] [one] subsystem[s] of the distribution systems [required OPERABLE by LCO 3.8.10, "Distribution Systems - Shutdown."] This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents INSERT 2 [involving handling recently irradiated fuel]). 3 APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies, 2 provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core, SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 385 of 638

Enclosure 2, Volume 13, Rev. 0, Page 386 of 638 B 3.8.5 1

INSERT 1 train consists of two channels. Train A consists of channels I and III and Train B consists of channels II and IV.

3 INSERT 2 Control power for the DGs is provided by four DG DC electrical power subsystems, one per DG.

Each DG DC electrical power subsystem is comprised of one 125 VDC battery, an associated charger, and associated control equipment and interconnecting cabling. One DG DC electrical power subsystem is required to be OPERABLE for each required DG.

Insert Page B 3.8.5-2 Enclosure 2, Volume 13, Rev. 0, Page 386 of 638

Enclosure 2, Volume 13, Rev. 0, Page 387 of 638 DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY (continued)

b. Required features needed to mitigate a fuel handling accident

[involving handling recently irradiated fuel (i.e., fuel that has occupied 2 part of a critical reactor core within the previous [X] days)] are available,

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2, and A.3 4


REVIEWERS NOTE-----------------------------------

ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in 5 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.

Condition A represents one subsystem with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 4 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 387 of 638

Enclosure 2, Volume 13, Rev. 0, Page 388 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, 4

the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 5 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during 4 the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 388 of 638

Enclosure 2, Volume 13, Rev. 0, Page 389 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) been fully recharged. If at the expiration of the initial [12] hour period the battery float current is not less than or equal to [2] amps this indicates 4 there may be additional battery problems and the battery must be declared inoperable.


REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt a Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in 5 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a 4 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

A.1, A.2 and A.3 B.1, B.2.1, B.2.2, and B.2.3 INSERT 3 [If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC 2 power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and 2 operations involving positive reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6).

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 389 of 638

Enclosure 2, Volume 13, Rev. 0, Page 390 of 638 B 3.8.5 2

INSERT 3 With the required train of DC electrical power sources inoperable, the minimum required DC electrical power source is not available.

Insert Page B 3.8.5-5 Enclosure 2, Volume 13, Rev. 0, Page 390 of 638

Enclosure 2, Volume 13, Rev. 0, Page 391 of 638 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power train subsystem[s] and to continue this action until restoration is accomplished 1 in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be INSERT 4 without sufficient power. 3 SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered 4 inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

U REFERENCES 1. FSAR, Chapter [6].

1 2

2. FSAR, Chapter [15].

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.5-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 391 of 638

Enclosure 2, Volume 13, Rev. 0, Page 392 of 638 B 3.8.5 3

INSERT 4 B.1 If one or more DG DC electrical power subsystems are inoperable, the associated DGs may be incapable of performing their intended function and must be immediately declared inoperable.

This declaration also requires entry into the applicable Conditions and Required Actions for inoperable DGs, LCO 3.8.2, "AC Sources - Shutdown".

Insert Page B 3.8.5-6 Enclosure 2, Volume 13, Rev. 0, Page 392 of 638

Enclosure 2, Volume 13, Rev. 0, Page 393 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. The ISTS Bases have been revised to include discussions of the LCO and ACTION requirements for the diesel generator (DG) DC electrical power subsystems to be consistent with the changes made to the Specification.
4. Changes have been made to be consistent with changes made to the Specifications.
5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 393 of 638

Enclosure 2, Volume 13, Rev. 0, Page 394 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 394 of 638

Enclosure 2, Volume 13, Rev. 0, Page 395 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 395 of 638

, Volume 13, Rev. 0, Page 396 of 638 ATTACHMENT 6 ITS 3.8.6, BATTERY PARAMETERS , Volume 13, Rev. 0, Page 396 of 638

, Volume 13, Rev. 0, Page 397 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 397 of 638

Enclosure 2, Volume 13, Rev. 0, Page 398 of 638 ITS A01 ITS 3.8.6 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and See ITS
b. Four separate and independent diesel generator sets each with: 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of See ITS 3.8.3 62,000 gallons of fuel, See ITS
4. A separate fuel transfer pump, and 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. See ITS battery bank and associated charger. 3.8.4 and

3.8.9 APPLICABILITY

MODES 1, 2, 3 and 4.

When associated Vital DC and DG DC electrical power A02 subsystems are required to be OPERABLE.

Applicability ACTION:

Add proposed ACTIONS Note A03 ACTIONS a. With one offsite A.C. circuit of the above required A.C. electrical power source inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required See ITS 3.8.1 A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS A, B, C, D, E, and F. L01

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

See ITS 3.8.1

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-1 Amendment No. 100, 132, 137, 205, 241, 332 Page 1 of 24 Enclosure 2, Volume 13, Rev. 0, Page 398 of 638

Enclosure 2, Volume 13, Rev. 0, Page 399 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar. See ITS 3.8.1 The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.
4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and See ITS operates for greater than or equal to 5 minutes. After energization, the steady state 3.8.1 voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. See ITS 3.8.4 and 3.8.9 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for each diesel generator shall be demonstrated OPERABLE:

LA01 In accordance with the Surveillance Frequency Control Program

a. At least once per 7 days by verifying:

31 days for pilot cell float voltage L02 SR 3.8.6.1 1. That the parameters in Table 4.8-1a meet the Category A limits.

SR 3.8.6.2 See ITS

2. That the total battery terminal voltage is greater than or equal to 124-volts on float 3.8.4 and charge. 3.8.5 31 days for electrolyte level and temperature SR 3.8.6.3, M01 SR 3.8.6.4, b. At least once per 92 days by:

SR 3.8.6.5 In accordance with the Surveillance Frequency Control Program SR 3.8.6.3, 1. Verifying that the parameters in Table 4.8-1a meet the Category B limits, LA01 SR 3.8.6.5

2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to L03 terminal connection resistance of these items is less than 150 x 10-6 ohms, and each battery pilot cell temperature L04 SR 3.8.6.4 3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.

greater than or equal to minimum established design limits

c. At least once per 18 months by verifying that: LA02
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.

L03

2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.
3. The resistance of each cell to terminal connection is less than or equal to 150 x 10-6 ohms.

Add proposed SR 3.8.6.7 with a Frequency of 60 months M02 4.8.1.1.4 This surveillance has been deleted. In accordance with the Surveillance Frequency Control Program LA01 December 16, 1998 SEQUOYAH - UNIT 1 3/4 8-6 Amendment Nos. 52, 137, 173, 213, 234, 241 Page 2 of 24 Enclosure 2, Volume 13, Rev. 0, Page 399 of 638

Enclosure 2, Volume 13, Rev. 0, Page 400 of 638 ITS A01 ITS 3.8.6 TABLE 4.8-1 DIESEL GENERATOR RELIABILITY THIS PAGE INTENTIONALLY DELETED July 14, 1997 SEQUOYAH - UNIT 1 3/4 8-7 Amendment No. 52, 226 Page 3 of 24 Enclosure 2, Volume 13, Rev. 0, Page 400 of 638

Enclosure 2, Volume 13, Rev. 0, Page 401 of 638 ITS A01 ITS 3.8.6 TABLE 4.8.1a DIESEL GENERATOR BATTERY SURVEILLANCE REQUIREMENTS L01 (1) (2)

CATEGORY A CATEGORY B (3)

Parameter Allowable Limits for each Limits for each value for each designated pilot cell connected cell connected cell L05 SR 3.8.6.3 >Minimum level >Minimum level Above top of Electrolyte Level L06 indication mark, indication mark, and plates, and not and 1/4 above 1/4 above overflowing maximum level maximum level greater than or equal to the LA03 indication mark indication mark minimum established design limits L07 SR 3.8.6.2, SR 3.8.6.5 Float Voltage 2.13 volts 2.13 volts(C) > 2.07 volts See ITS 5.5.15 2.07 L08 Not more than

.020 below the average of all 1.190 connected cells SR 3.8.6.1 (a) (b) Average of all Average of all L09 Specific Gravity 1.195 connected cells connected cells

> 1.200 > 1.190(b)

(a) Corrected for electrolyte temperature and level. M03 1

SR 3.8.6.1 (b) Or battery charging current is less than 2 amps.

See ITS (c) Corrected for average electrolyte temperature. 5.5.15 (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all the Category B measurements are taken and found to be within their allowable values, and provided all parameter(s) are restored to within limits within the next 6 days.

(2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered L01 OPERABLE provided that they are within their allowable values and provided the parameter(s) are restored to within limits within 7 days.

(3) Any Category B parameter not within its allowable value indicates an inoperable battery.

March 25, 1982 SEQUOYAH - UNIT 1 3/4 8-7a Amendment No. 12 Page 4 of 24 Enclosure 2, Volume 13, Rev. 0, Page 401 of 638

Enclosure 2, Volume 13, Rev. 0, Page 402 of 638 ITS A01 ITS 3.8.6 ATTACHMENT TO TABLE 4.8-1 DIESEL GENERATOR REQUALIFICATION PROGRAM THIS PAGE INTENTIONALLY DELETED July 14, 1997 SEQUOYAH - UNIT 1 3/4 8-7b Amendment No. 52, 226 Page 5 of 24 Enclosure 2, Volume 13, Rev. 0, Page 402 of 638

Enclosure 2, Volume 13, Rev. 0, Page 403 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SHUTD0WN Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and See ITS 3.8.2
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:
1. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS 3.8.3
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, See ITS
4. A fuel transfer pump, and 3.8.2
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.5 and 3.8.10 Applicability APPLICABILITY: MODES 5 and 6.

When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE. A02 ACTION:

Add proposed ACTIONS Note A03 With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions See ITS 3.8.2 that could result in loss of required shutdown margin or boron concentration.

Add proposed ACTIONS A, B, C, D, E, and F L01 SURVEILLANCE REQUIREMENTS SR 3.8.6.1, See ITS SR 3.8.6.2, 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the 3.8.2 SR 3.8.6.3, performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement SR 3.8.6.4, 4.8.1.1.2.a.5), and 4.8.1.1.3.

SR 3.8.6.5 May 22, 2003 SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. 241, 285 Page 6 of 24 Enclosure 2, Volume 13, Rev. 0, Page 403 of 638

Enclosure 2, Volume 13, Rev. 0, Page 404 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTI0N - OPERATING Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.2.3 The following D.C. vital battery channels shall be energized and OPERABLE:

CHANNEL I Consisting of 125 - volt D.C. board No. I, 125 - volt D.C.

battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

See ITS battery bank No. II*, and a full capacity charger. 3.8.4 and 3.8.9 CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D.C.

battery bank No. IV*, and a full capacity charger.

A02 Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE.

ACTION: Add proposed ACTIONS Note A03

a. With one 125-volt D.C. board inoperable, restore the inoperable board to OPERABLE status See ITS within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 3.8.9 SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one 125-volt D.C. battery bank and/or its charger inoperable, restore the inoperable battery bank and/or charger to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT See ITS 3.8.4 STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS A, B, C, D, E and F. L01 See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed. 3.8.4 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-11 Amendment No. 37 Page 7 of 24 Enclosure 2, Volume 13, Rev. 0, Page 404 of 638

Enclosure 2, Volume 13, Rev. 0, Page 405 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS See ITS 3.8.9 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated See ITS power availability from the charger and battery, and voltage on the bus of greater than or equal to 3.8.4 125 volts.

L02 4.8.2.3.2* Each 125-volt battery bank and charger shall be demonstrated OPERABLE:

31 days for pilot cell float voltage

a. At least once per 7 days by: In accordance with the Surveillance Frequency Control Program LA01 SR 3.8.6.1, 1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and SR 3.8.6.2 See ITS 3.8.4
2. Verifying total battery terminal voltage is greater than or equal to 129-volts on float charge. In accordance with the Surveillance Frequency Control Program LA01 31 days for electrolyte level and temperature SR 3.8.6.3, b. At least once per 92 days and within 7 days after a battery discharge (battery terminal M01 SR 3.8.6.4, SR 3.8.6.5 voltage below 110-volts), or battery overcharge (battery terminal voltage above 150- L10 volts), by:

SR 3.8.6.3, 1. Verifying that the parameters in Table 4.8-2 meet the Category B limits, SR 3.8.6.5

2. Verifying there is no visible corrosion at either terminals or connectors, or the L03 connection resistance of these items is less than 150 x 10-6 ohms, and each battery pilot cell temperature L04 SR 3.8.6.4 3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.

greater than or equal to minimum established design limits LA02

c. At least once per 18 months by verifying that:
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, L03
2. The cell-to-cell and terminal connections are clean, tight and coated with anti-corrosion material,
3. The resistance of each cell-to-terminal connection is less than or equal to 150 x 10-6 ohms, and
4. The battery charger will supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. See ITS 3.8.4 See ITS
  • This surveillance includes Battery Bank V, but not charger V. 3.8.4 October 4, 1995 SEQUOYAH - UNIT 1 3/4 8-12 Amendment No. 37, 213 Page 8 of 24 Enclosure 2, Volume 13, Rev. 0, Page 405 of 638

Enclosure 2, Volume 13, Rev. 0, Page 406 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS Add proposed SR 3.8.6.6 Note M04 SURVEILLANCE REQUIREMENTS (Continued)

d. At least once per 18 months by verifying that the battery capacity is adequate to supply and See ITS 3.8.4 maintain in OPERABLE status all of the actual or simulated emergency loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when the battery is subjected to a battery service test. In accordance with the Surveillance Frequency Control Program LA01
e. At least once per 60 months by verifying that the battery capacity is at least 82% of the SR 3.8.6.6 or a modified manufacturer's rating when subjected to a performance discharge test. Once per 60 month performance See ITS discharge test interval, this performance discharge test may be performed in lieu of the battery service test. 3.8.4
f. Annual performance discharge tests of battery capacity shall be given to any battery that L11 SR 3.8.6.6 shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the LA04 manufacturer's rating.

Add proposed SR 3.8.6.6 third Frequency L12 October 4, 1995 SEQUOYAH - UNIT 1 3/4 8-13 Amendment No. 29, 213 Page 9 of 24 Enclosure 2, Volume 13, Rev. 0, Page 406 of 638

Enclosure 2, Volume 13, Rev. 0, Page 407 of 638 ITS A01 ITS 3.8.6 TABLE 4.8.2 BATTERY SURVEILLANCE REQUIREMENTS L01 (1) (2)

CATEGORY A CATEGORY B L05 Limits for each Limits for each (3)

Parameter Allowable value for designated pilot cell connected cell L06 each connected cell LA03 SR 3.8.6.3 >Minimum level >Minimum level Above top of plates, and Electrolyte Level indication mark, indication mark, and not overflowing and 1/4 above 1/4 above maximum greater than or equal to the L08 maximum level level indication mark minimum established design limits indication mark L07 SR 3.8.6.2, 2.13 volts 2.13 volts (c) > 2.07 volts See ITS SR 3.8.6.5 Float Voltage 5.5.15 Not more than .020 2.07 below the average of all 1.195 connected cells SR 3.8.6.1 L09 (a) (b) Average of all connected Average of all connected Specific Gravity 1.200 cells > 1.205 cells > 1.195(b)

(a) Corrected for electrolyte temperature and level.

SR 3.8.6.1 (b) Or battery charging current is less than 2 amps.

(c) Corrected for average electrolyte temperature. See ITS 5.5.15 (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all the Category B measurements are taken and found to be within their allowable values, and provided all parameter(s) are restored to within limits within the next 6 days.

L01 (2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that they are within their allowable values and provided the parameter(s) are restored to within limits within 7 days.

(3) Any Category B parameter not within its allowable value indicates an inoperable battery.

March 25, 1982 SEQUOYAH - UNIT 1 3/4 8-13a Amendment No. 12 Page 10 of 24 Enclosure 2, Volume 13, Rev. 0, Page 407 of 638

Enclosure 2, Volume 13, Rev. 0, Page 408 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be energized and 0PERABLE:

See ITS 2 - 125-volt D.C. boards either I and III or II and IV, and 3.8.5 and 3.8.10 2* - 125-volt battery banks and chargers, one associated with each operable D.C. board A02 Applicability APPLICABILITY: MODES 5 and 6.

When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE.

ACTION:

Add proposed ACTIONS Note A03 With less than the above complement of D.C. equipment and board OPERABLE, establish See ITS CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 3.8.5 and 3.8.10 Add proposed ACTIONS A, B, C, D, E, and F L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and See ITS energized at least once per 7 days by verifying correct breaker alignment and indicated power availability 3.8.10 with an overall battery voltage of greater than or equal to 125 volts.

SR 3.8.6.1, 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers sha11 be demonstrated SR 3.8.6.2, SR 3.8.6.3, OPERABLE per Surveillance Requirement 4.8.2.3.2.

SR 3.8.6.4, SR 3.8.6.5 SR 3.8.6.6 See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank. 3.8.5 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-14 Amendment No. 37 Page 11 of 24 Enclosure 2, Volume 13, Rev. 0, Page 408 of 638

Enclosure 2, Volume 13, Rev. 0, Page 409 of 638 ITS A01 ITS 3.8.6 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with: See ITS 3.8.1
1. Two diesels driving a common generator
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of 62,000 gallons of See ITS 3.8.3 fuel,
4. A separate fuel transfer pump, and See ITS 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.4 and When associated Vital DC or DG DC electrical 3.8.9 APPLICABILITY: MODES 1, 2, 3 and 4. power subsystems are required to be OPERABLE.

A02 Applicability ACTION:

Add proposed ACTIONS Note A03 ACTIONS a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required See ITS A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining 3.8.1 A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS A, B, C, D, E, and F. L01

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing. See ITS 3.8.1

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, 231, 325 Page 12 of 24 Enclosure 2, Volume 13, Rev. 0, Page 409 of 638

Enclosure 2, Volume 13, Rev. 0, Page 410 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar. See ITS 3.8.1 The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.
4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes. After energization, the steady state voltage and See ITS 3.8.1 frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test.

See ITS 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for 3.8.4 and 3.8.9 each diesel generator shall be demonstrated OPERABLE:

In accordance with the Surveillance Frequency Control Program LA01

a. At least once per 7 days by verifying:

31 days for pilot cell float voltage L02 SR 3.8.6.2 1. That the parameters in Table 4.8-1a meet the Category A limits.

See ITS

2. That the total battery terminal voltage is greater than or equal to 124 volts on float charge. 3.8.4 and 3.8.5 SR 3.8.6.3, 31 days for electrolyte level and temperature SR 3.8.6.4, b. At least once per 92 days by:

SR 3.8.6.5 In accordance with the Surveillance Frequency Control Program M01 SR 3.8.6.3, 1. Verifying that the parameters in Table 4.8-1a meet the Category B limits, LA01 SR 3.8.6.5

2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to L03 terminal connection resistance of these items is less than 150 x 10-6 ohms, and each battery pilot cell temperature L04 SR 3.8.6.4 3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.

greater than or equal to minimum established design limits LA02

c. At least once per 18 months by verifying that:
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.

L03

2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.
3. The resistance of each cell to terminal connection is less than or equal to 150 x 10-6 ohms.

Add proposed SR 3.8.6.7 with a Frequency of 60 months M02 In accordance with the Surveillance Frequency Control Program LA01 July 22, 1998 SEQUOYAH - UNIT 2 3/4 8-6 Amendment No. 8, 56, 164, 203, 224 Page 13 of 24 Enclosure 2, Volume 13, Rev. 0, Page 410 of 638

Enclosure 2, Volume 13, Rev. 0, Page 411 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.4 This surveillance has been deleted.

December 16, 1998 SEQUOYAH - UNIT 2 3/4 8-7 Amendment No. 44, 231 Page 14 of 24 Enclosure 2, Volume 13, Rev. 0, Page 411 of 638

Enclosure 2, Volume 13, Rev. 0, Page 412 of 638 ITS A01 ITS 3.8.6 TABLE 4.8-1 DIESEL GENERATOR RELIABILITY THIS PAGE INTENTIONALLY DELETED July 14, 1997 SEQUOYAH - UNIT 2 3/4 8-8 Amendment No. 44, 217 Page 15 of 24 Enclosure 2, Volume 13, Rev. 0, Page 412 of 638

Enclosure 2, Volume 13, Rev. 0, Page 413 of 638 ITS A01 ITS 3.8.6 TABLE 4.8-1a L01 DIESEL GENERATOR BATTERY SURVEILLANCE REQUIREMENTS L05 CATEROGY A(1) CATEGORY B(2)

L08 (3)

Parameter Limit for each designated Limits for each connected Allowable pilot cell cell value for each L01 connected cell INSERT 1 LA03 SR 3.8.6.3 Electrolyte >Minimum level indication >Minimum level indication Above top of Level mark, and 1/4 above mark, and 1/4 above plates, L06 maximum level indication maximum level indication and not mark mark overflowing See ITS 2.07 5.5.15 (c)

Float Voltage 2.13 volts 2.13 volts > 2.07 volts Not more than L07

.020 below the average of all 1.190 connected cells SR 3.8.6.1 Specific 1.195(b) Average of all Average of all L09 Gravity(a) connected cells connected cells

> 1.200 1.190(b)

(a) Corrected for electrolyte temperature and level. 1 M03 SR 3.8.6.1 (b) Or battery charging current is less than 2 amps.

(c) Corrected for average electrolyte temperature. See ITS 5.5.15 (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all the Category B measurements are taken and found to be within their allowable values, and provided all parameter(s) are restored to within limits within the next 6 days.

L01 (2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that they are within their allowable values and provided the parameter(s) are restored to within limits within 7 days.

(3) Any Category B parameter not within its allowable value indicates an inoperable battery.

SEQUOYAH - UNIT 2 3/4 8-8a Page 16 of 24 Enclosure 2, Volume 13, Rev. 0, Page 413 of 638

Enclosure 2, Volume 13, Rev. 0, Page 414 of 638 LA03 INSERT 1 greater than or equal to the minimum established design limits Insert Page 3/4 8-8a Page 17 of 24 Enclosure 2, Volume 13, Rev. 0, Page 414 of 638

Enclosure 2, Volume 13, Rev. 0, Page 415 of 638 ITS A01 ITS 3.8.6 ATTACHMENT TO TABLE 4.8-1 DIESEL GENERATOR REQUALIFICATION PROGRAM THIS PAGE INTENTIONALLY DELETED July 14, 1997 SEQUOYAH - UNIT 2 3/4 8-8b Amendment No. 44, 217 Page 18 of 24 Enclosure 2, Volume 13, Rev. 0, Page 415 of 638

Enclosure 2, Volume 13, Rev. 0, Page 416 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SHUTDOWN Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and See ITS 3.8.2
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with:
l. Two diesels driving a common generator,
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 See ITS
4. A fuel transfer pump, and 3.8.2
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.5 and Applicability APPLICABILITY: MODES 5 and 6.

When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE. A02 ACTIONS ACTION:

Add proposed ACTIONS Note A03 With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions See ITS that could result in loss of required shutdown margin or boron concentration. 3.8.2 Add proposed ACTIONS A, B, C, D, E, and F L01 SURVEILLANCE REQUIREMENTS SR 3.8.6.1, 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS SR 3.8.6.2, 3.8.2 SR 3.8.6.3, performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement SR 3.8.6.4, 4.8.1.1.2.a.5), and 4.8.1.1.3.

SR 3.8.6.5 May 22, 2003 SEQUOYAH - UNIT 2 3/4 8-9 Amendment No. 231, 274 Page 19 of 24 Enclosure 2, Volume 13, Rev. 0, Page 416 of 638

Enclosure 2, Volume 13, Rev. 0, Page 417 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - OPERATING Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.2.3 The following D.C. vital battery channels shall be OPERABLE and energized:

CHANNEL I Consisting of 125 -volt D.C. board No. I, 125 - volt D.C. battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

See ITS battery bank No. II*, and a full capacity charger. 3.8.4 and 3.8.9 CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D. C.

battery bank No. IV*, and a full capacity charger.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4. A02 When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE.

ACTION: Add proposed ACTIONS Note A03

a. With one 125-volt D.C. board inoperable or not energized, restore the inoperable board to OPERABLE and energized status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the See ITS 3.8.9 next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one 125-volt D.C. battery bank and/or its charger inoperable or not energized, restore the inoperable battery bank and/or charger to OPERABLE and energized status within See ITS 3.8.4 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTIONS A, B, C, D, E and F. L01 SURVEILLANCE REQUIREMENTS 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated See ITS 3.8.9 power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts. See ITS 3.8.4 4.8.2.3.2** Each 125-volt battery bank and charger shall be demonstrated OPERABLE:

L02 31 days for pilot cell float voltage

a. At least once per 7 days by:

In accordance with the Surveillance Frequency Control Program LA01 SR 3.8.6.2 1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and

  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed. See ITS 3.8.4
    • This surveillance includes Battery Bank V, but not Charger V.

January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-12 Amendment No. 29 Page 20 of 24 Enclosure 2, Volume 13, Rev. 0, Page 417 of 638

Enclosure 2, Volume 13, Rev. 0, Page 418 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS See ITS

2. Verifying total battery terminal voltage is greater than or equal to 129-volts on float charge. 3.8.4 SR 3.8.6.3, SR 3.8.6.4, b. At least once per 92 days and within 7 days after a battery discharge (battery terminal voltage SR 3.8.6.5 L10 below 110-volts), or battery overcharge (battery terminal voltage above 150-volts), by:

SR 3.8.6.3, 31 days for electrolyte level and temperature M01 SR 3.8.6.5 1. Verifying that the parameters in Table 4.8-2 meet the Category B limits, LA01 In accordance with the Surveillance Frequency Control Program

2. Verifying there is no visible corrosion at either terminals or connectors, or the connection L03 resistance of these items is less than 150 x 10-6 ohms, and each battery pilot cell temperature L04 SR 3.8.6.4 3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.

greater than or equal to minimum established design limits

c. At least once per 18 months by verifying that: LA02
1. The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, L03
2. The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material,
3. The resistance of each cell-to-terminal connection is less than or equal to 150 x 10-6 ohms, and
4. The battery charger will supply at least 150 amperes at 125-volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. See ITS 3.8.4
d. At least once per 18 months by verifying that the battery capacity is adequate to supply and See ITS maintain in OPERABLE status all of the actual or simulated emergency loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when 3.8.4 the battery is subjected to a battery service test.

In accordance with the Surveillance Frequency Control Program LA01 SR 3.8.6.6 e. At least once per 60 months by verifying that the battery capacity is at least 82% of the manufacturer's rating when subjected to a performance discharge test. Once per 60 month or a modified See ITS performance interval, this performance discharge test may be performed in lieu of the battery service test. 3.8.4 discharge test SR 3.8.6.6 f. Annual performance discharge tests of battery capacity shall be given to any battery that shows L11 signs of degradation or has reached 85% of the service life expected for the application.

Degradation is indicated when the battery capacity drops more than 10% of rated capacity from LA04 its average on previous performance tests, or is below 90% of the manufacturer's rating.

Add proposed SR 3.8.6.6 Note M04 Add proposed SR 3.8.6.6 third Frequency L12 October 4, 1995 SEQUOYAH - UNIT 2 3/4 8-13 Amendment No. 18, 203 Page 21 of 24 Enclosure 2, Volume 13, Rev. 0, Page 418 of 638

Enclosure 2, Volume 13, Rev. 0, Page 419 of 638 ITS A01 ITS 3.8.6 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS L05 L01 CATEROGY A(1) CATEGORY B(2)

L08 (3)

Parameter Limit for each designated Limits for each connected Allowable L01 pilot cell cell value for each connected cell INSERT 2 LA03 SR 3.8.6.3 Electrolyte >Minimum level indication >Minimum level indication Above top of Level mark, and 1/4 above mark, and 1/4 above plates, L06 maximum level indication maximum level indication and not mark mark overflowing See ITS 2.07 5.5.15 SR 3.8.6.2, SR 3.8.6.5 Float Voltage 2.13 volts 2.13 volts(c) > 2.07 volts L07 Not more than

.020 below the average of all 1.195 connected cells SR 3.8.6.1 L09 Specific 1.200(b) Average of all Average of all Gravity(a) connected cells connected cells

> 1.205 1.195(b)

(a) Corrected for electrolyte temperature and level.

SR 3.8.6.1 (b) Or battery charging current is less than 2 amps.

See ITS (c) Corrected for average electrolyte temperature. 5.5.15 (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all the Category B measurements are taken and found to be within their allowable values, and provided all parameter(s) are restored to within limits within the next 6 days.

(2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered L01 OPERABLE provided that they are within their allowable values and provided the parameter(s) are restored to within limits within 7 days.

(3) Any Category B parameter not within its allowable value indicates an inoperable battery.

SEQUOYAH - UNIT 2 3/4 8-14 Page 22 of 24 Enclosure 2, Volume 13, Rev. 0, Page 419 of 638

Enclosure 2, Volume 13, Rev. 0, Page 420 of 638 LA03 INSERT 2 greater than or equal to the minimum established design limits Insert Page 3/4 8-14 Page 23 of 24 Enclosure 2, Volume 13, Rev. 0, Page 420 of 638

Enclosure 2, Volume 13, Rev. 0, Page 421 of 638 ITS A01 ITS 3.8.6 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be and OPERABLE and energized:

See ITS 3.8.5 and 2 - 125-volt D.C. boards either I and III or II and IV, and 3.8.10 2* - 125-volt battery banks and chargers, one associated with each operable D.C. board A02 Applicability APPLICABILITY: MODES 5 and 6.

When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE.

ACTIONS ACTION: Add proposed ACTIONS Note A03 With less than the above complement of D.C. equipment and board OPERABLE and energized, establish See ITS CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 3.8.5 and 3.8.10 Add proposed ACTIONS A, B, C, D, E, and F L01 SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and See ITS energized at least once per 7 days by verifying correct breaker alignment and voltage on the board with 3.8.10 an overall battery voltage of greater than or equal to 125 volts.

SR 3.8.6.1, 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated SR 3.8.6.2, SR 3.8.6.3, OPERABLE per Surveillance Requirement 4.8.2.3.2.

SR 3.8.6.4, SR 3.8.6.5 SR 3.8.6.6 See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank. 3.8.5 January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-15 Amendment No. 29 Page 24 of 24 Enclosure 2, Volume 13, Rev. 0, Page 421 of 638

Enclosure 2, Volume 13, Rev. 0, Page 422 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.1 and CTS 3.8.2.3 are applicable during MODES 1, 2, 3, and 4.

CTS 3.8.1.2 and CTS 3.8.2.4 are applicable during MODES 5 and 6. ITS LCO 3.8.6 requires the battery parameters for the Vital DC and diesel generator (DG) batteries to be within limits when the associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE. This changes the CTS by combining the requirements for the Vital Battery and DG battery parameters into one Specification and replacing the actual MODES with the phrase "When associated Vital DC and DG DC electrical power subsystems are required to be OPERABLE."

The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. This change combines CTS 3.8.1.1, 3.8.1.2, 3.8.2.3, and 3.8.2.4 requirements for the DG and Vital battery parameters into one Specification. There are no technical changes as a result of this change since it converts the requirements into the format of the ITS. The proposed LCO states that the required battery's parameters shall be within limits. The proposed Applicability ensures the battery parameter requirements are met when the associated battery is required to be OPERABLE. Any technical changes to the battery parameters are discussed in a Discussion of Change specifically associated with that change. Any changes to the LCO and Applicability of the Vital or DG batteries are discussed in the Discussion of Changes for ITS 3.8.4 and 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.1.1 and 3.8.1.2 contain ACTIONS for various combinations of DG inoperability that would be entered if its support battery is inoperable. CTS 3.8.1.1 and 3.8.2.3 each contain a table that describes battery degradation levels where separate actions are taken for each battery depending on the level of degradation. CTS 3.8.2.4 requires two of four vital batteries to be OPERABLE and if one of the two required vital batteries is inoperable operations can continue as long as the required ACTION is completed. ITS 3.8.6 ACTIONS Note states that separate entry condition is allowed for each battery. This changes the CTS by explicitly stating the intent of CTS.

The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. As in CTS, exceeding the battery parameter limits in ITS 3.8.6 is indicative of a degradation of battery capacity but the battery may still be capable of performing its intended function (i.e., OPERABLE). Compliance with Sequoyah Unit 1 and Unit 2 Page 1 of 14 Enclosure 2, Volume 13, Rev. 0, Page 422 of 638

Enclosure 2, Volume 13, Rev. 0, Page 423 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS the Required Actions within the associated Completion Times provides assurance that there is still sufficient battery capacity to perform its intended function without considering the battery inoperable. As in CTS, if the battery parameter condition degrades such that the parameter is outside the Conditions allowed or the Required Actions are not accomplished within the associated Completion Time the battery is considered inoperable and the appropriate Condition(s) entered for the equipment the battery supports. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 4.8.1.1.3.b.1 and 4.8.2.3.2.b.1 require verification that the average electrolyte level of each battery connected cell is within limit every 92 days. ITS SR 3.8.6.3 requires verification of each battery connected cell electrolyte level is greater than or equal to minimum established design limits every 31 days. CTS 4.8.1.1.b.3 and 4.8.2.3.2.b.3 require verification that electrolyte temperature of 6 connected battery cells is within limit every 92 days. ITS SR 3.8.6.4 requires verification of each battery pilot cell temperature is greater than or equal to the minimum established design limits every 31 days. (See DOC L04 for a discussion on limiting verification of electrolyte temperature to the pilot cell.) This changes the CTS by increasing the Frequency of performance of the Surveillances from 92 days to 31 days.

The purpose of CTS 4.8.1.1.3.b.1, 4.8.1.1.3.b.3, 4.8.2.3.2.b.1, and 4.8.2.3.2.b.3 is to ensure the electrolyte level and temperature is within the specified limit to ensure the battery plates suffer no physical damage and maintain adequate electron transfer capability. The applicable IEEE 450-2002 standard recommends a Surveillance Frequency of 31 days. The change is acceptable since it will help ensure the battery plates will not suffer physical damage and maintain adequate electron transfer capability. This change is designated as more restrictive because the Surveillance Requirement Frequencies have been increased.

M02 CTS 4.8.1.1.3 specifies the Surveillances for the DG batteries while the unit is in MODE 1, 2, 3, or 4. CTS 4.8.1.2 refers to this Specification for DG battery surveillances while in MODE 5 or 6. ITS 3.8.6 adds a new Surveillance, ITS SR 3.8.6.7 requiring verification that the DG battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test or a modified performance discharge test at a Frequency of 60 months or at a conditional Frequency based on specific battery conditions. (Refer to DOC LA01 for the discussion on moving the 60 month Frequency to the Surveillance Frequency Control Program.) This changes the CTS by adding a Surveillance for DG battery capacity testing.

The purpose of SR 3.8.6.7 is to test the DG battery to detect any change in the capacity, and/or to determine the batterys as-found capacity and ability to satisfy the duty cycle. IEEE 450-2002 recommends replacing the battery if its capacity is below 80% of the manufacturers rating and if a battery cannot meet its duty cycle it is considered inoperable. This change is considered acceptable because Sequoyah Unit 1 and Unit 2 Page 2 of 14 Enclosure 2, Volume 13, Rev. 0, Page 423 of 638

Enclosure 2, Volume 13, Rev. 0, Page 424 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS the Surveillance is consistent with IEEE 450-2002 and is necessary to monitor the battery for degradation and/or battery OPERABILITY. This change is designated as more restrictive because Surveillance Requirements have been added to the CTS.

M03 CTS 4.8.1.1.3.a.1 requires verification that the DG battery parameters are within the Category A limits of Table 4.8-1a. CTS Table 4.8-1a includes Category A limit for specific gravity, modified by footnote (b), which provides an alternative method of verifying the DG battery state of charge by ensuring a battery charging current of less than 2 amps. ITS SR 3.8.6.1 requires verification that DG battery float current is less than or equal to 1 amp. This changes CTS by lowering the Surveillance acceptance criterion for verifying DG battery state of charge from less than 2 amps to less than or equal to 1 amp.

The purpose of CTS 4.8.1.1.3.a.1 and Table 4.8-1a, in part, is to verify the DG batteries state of charge. The DG batteries installed at SQN are C&D Technologies, Inc. Model KCR-7. As identified in the C&D Technologies, Inc.

letter to TVA, dated August 9, 2013, for the KCR-7 batteries, after a discharge, when the float current drops to less than or equal to 1 amp, the battery should be at least 98% recharged. Therefore, as recommended by the manufacturer, verification of state of charge for the DG batteries requires a lower current than is specified in CTS. This change is acceptable because the float current specified in CTS is not associated with an established percentage of state of charge for the DG batteries. Therefore, specifying a manufacturer's recommended float current to ensure the DG batteries are at least 98% recharged will ensure the DG batteries are in a fully charged state. This change is designated as more restrictive because the acceptance criteria for the DG batteries Surveillance in ITS will ensure a higher state of charge than required in CTS.

M04 CTS 4.8.2.3.2.e requires verifying that the vital battery capacity is at least 82% of the manufacturer's rating when subjected to a performance discharge test with no limitations on plant conditions under which this test can be performed. ITS 3.8.6.6 requires verifying each required vital battery capacity is 82% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test with a Note placing MODE limitations on when the test can be performed. ITS SR 3.8.6.6 Note states that this Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed on in-service vital batteries 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. This changes the CTS by adding restrictions, modified by some allowances, defining under what plant MODES the test can be performed.

The purpose of CTS 4.8.2.3.2.e is to verify the OPERABILITY of the vital DC batteries. The addition of the Note limiting the conditions in which the Surveillance can be performed is acceptable because performing the Surveillance on in-service vital batteries would perturb the electrical distribution system and challenge safety systems, although credit may be taken for unplanned events that satisfy this SR. This change is designated as more restrictive because restraints have been added limiting when a Surveillance Requirement can be performed.

Sequoyah Unit 1 and Unit 2 Page 3 of 14 Enclosure 2, Volume 13, Rev. 0, Page 424 of 638

Enclosure 2, Volume 13, Rev. 0, Page 425 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.1.1.3.a and 4.8.2.3.2.a require verifying pilot cell float voltage in Table 4.8-1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2) are within limits at least once per 31 days, as changed by DOC L02. CTS 4.8.1.1.b and 4.8.2.3.2.b require verifying electrolyte level in Table 4.8-1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2), and electrolyte temperature at least once per 31 days, as changed by DOC M01. CTS 4.8.2.3.2.e requires verification of battery capacity at least once per 60 months. ITS SR 3.8.6.7 is initially proposed to be added with a Frequency of 7 days as discussed in DOC M02. ITS SRs 3.8.6.1, 3.8.6.2, 3.8.6.3, 3.8.6.4, 3.8.6.5, and partially SRs 3.8.6.6 and 3.8.6.7 require a similar Surveillance and specify the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.3.b.3 and 4.8.2.3.2.b.3 require, in part, verifying the average electrolyte temperature of 6 connected cells above 60°F. ITS SR 3.8.6.4 requires, in part, verification that each required battery pilot cell temperature is greater than or equal to minimum established design limits. The pilot cell temperature for the minimum established design limits will be placed in the SQN UFSAR. This changes the CTS by moving the specified temperature value for this SR to the SQN UFSAR.

Sequoyah Unit 1 and Unit 2 Page 4 of 14 Enclosure 2, Volume 13, Rev. 0, Page 425 of 638

Enclosure 2, Volume 13, Rev. 0, Page 426 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The specific limiting value for the battery electrolyte temperature is relocated to a licensee controlled document. The removal of these details related to battery electrolyte temperature limits from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety.

Depending on the available excess capacity of the associated battery, the minimum temperature necessary to support operability of the battery can vary.

Relocating these values to the UFSAR is acceptable because these battery parameter values will continue to be controlled at their current level, changes will be evaluated in accordance with 10 CFR 50.59 and reported in accordance with 10 CFR 50.71, and actions to restore deficient values will be implemented in accordance with the TVA's corrective action program. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65. This relocation will continue to assure that the battery is maintained at current levels of performance, and that operators appropriately focus on monitoring the battery parameters for degradation. This change is designated as a less restrictive removal of detail change, because the Surveillance limits are being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.3.b.1 and 4.8.2.3.2.b.1, as modified by DOC M01, require verification that battery electrolyte level is greater than the minimum level indication mark, and less than or equal to 1/4 inch above maximum level indication mark at least once per 31 days for the DG and vital batteries. ITS SR 3.8.6.3 requires a similar Surveillance and specifies the acceptance criteria as "greater than or equal to the minimum established design limits." The minimum established design limits for battery electrolyte level will be placed in the SQN UFSAR. This changes the CTS by moving the specified limits for this SR to the SQN UFSAR.

The removal of these details related to Surveillance Requirement limits from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This Category B value of CTS Table 4.8.1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2) represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. Relocating these values to the UFSAR is acceptable because these battery parameter values will continue to be controlled at their current level, changes will be evaluated in accordance with 10 CFR 50.59 and reported in accordance with 10 CFR 50.71, and actions to restore deficient values will be implemented in accordance with the TVA's corrective action program.

Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65. This relocation will continue to assure that the battery is maintained at current levels of performance, and that operators appropriately focus on monitoring the battery parameters for degradation. This change is designated as a less restrictive removal of detail change, because the Surveillance limits are being removed from the Technical Specifications.

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.f requires the performance of a battery performance Sequoyah Unit 1 and Unit 2 Page 5 of 14 Enclosure 2, Volume 13, Rev. 0, Page 426 of 638

Enclosure 2, Volume 13, Rev. 0, Page 427 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS test. The Surveillance requires a more frequent performance if the battery shows signs of "degradation" or has reached 85% of the service life expected for the application. The CTS further states that degradation is indicated when the battery capacity drops more than 10% from its capacity on previous performance tests, or is below 90% of the manufacturers rating. ITS SR 3.8.6.6 requires verification of the battery capacity when subjected to a performance discharge test or a modified performance discharge test. The Surveillance is also required more frequently when the battery shows degradation or has reached 85% of the expected life, but the definition of what constitutes "degradation" is not included.

This changes the CTS by moving the detail on how degradation is determined from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.8.6.6 retains the requirement to verify the battery capacity when subjected to a performance discharge test or a modified performance discharge test. The Surveillance also requires more frequent performance when the battery shows degradation or has reached 85%

of the expected life. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1, 3.8.1.2, 3.8.2.3, and 3.8.2.4 provide ACTIONS and associated Completion Times for when a DG or Vital battery is inoperable due to battery parameters not within limits. In addition, CTS Table 4.8.1a and CTS Table 4.8.2 (CTS Table 4.8-2 for Unit 2) provide in the form of Notes (1), (2), and (3), ACTIONS and associated Completions Times when Category A or Category B parameter limits or allowable values are exceeded. In lieu of these current Actions under these conditions, ITS 3.8.6 ACTIONS provide compensatory Required Actions and associated Completion Times when battery parameters are not within limits. This changes the CTS by replacing the current ACTIONS with new compensatory ACTIONS for battery parameters not within limits.

The purpose of CTS 3.8.1.1, 3.8.1.2, 3.8.2.3, and 3.8.2.4 ACTIONS is to provide a finite period for continued operation when a DG or Vital battery is inoperable due to battery parameters not within limits. ITS 3.8.6 ACTIONS also allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to correct degraded conditions.

The Required Actions are consistent with safe operation under the specified Sequoyah Unit 1 and Unit 2 Page 6 of 14 Enclosure 2, Volume 13, Rev. 0, Page 427 of 638

Enclosure 2, Volume 13, Rev. 0, Page 428 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, time for repairs or replacement, and the low probability of a DBA occurring during the Completion Time. ACTIONS have been added to allow a short time period to restore parameters to within limits. ITS 3.8.6 ACTION A covers the condition of one or more batteries with one or more battery cells float voltage less than the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the performance of SR 3.8.6.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and restoration of the affected cell voltage to within limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.6 ACTION B covers the condition of one or more batteries with float current not within the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and restoration of the battery float current to within limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.6 ACTION C covers the condition of one or more batteries with one or more cells electrolyte level less than minimum established design limits, and requires the restoration of electrolyte level to above top of plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, verification that there is no evidence of leakage within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6 ACTION C NOTE requires Required Action C.2 to be completed if electrolyte level was below the top of plates. Because with electrolyte level below the top of the plates there is a potential for dryout and plate degradation, this Note requires verification of no evidence of leakage even if the level is increased above the top of the plates allowing the Condition to be exited. ITS 3.8.6 Required Action C.1 NOTE states that Required Actions C.1 and C.2 are only applicable if electrolyte level was below the top of the plates allowing 31 days to restore electrolyte level to greater than or equal to the minimum established design level. ITS 3.8.6 ACTION D covers the condition of one or more batteries with pilot cell electrolyte temperature less than the minimum established design limits, and requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.6 ACTION E covers the condition of one or more batteries in redundant subsystems with battery parameters not within limits, and requires restoration of the battery parameters for one battery to within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.8.6 ACTION F covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS cannot be met, if one or more batteries with one or more battery cells float voltage and float current are not within limits, if SR 3.8.6.6 is not met, or SR 3.8.6.7 is not met, and requires the immediate declaration that the associated battery is inoperable. The allowances are considered acceptable since only a short time is allowed to exist with battery parameters not within limits. In addition, when one or more batteries in redundant subsystems have battery parameters not within limit, only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is allowed to restore at least one subsystems batteries before declaring the battery(ies) inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7 - Relaxation Of Surveillance Frequency) CTS 4.8.1.1.3.a and 4.8.2.3.2.a require the verification that the pilot cell voltage is greater than or equal to the specified limit every 7 days. ITS SR 3.8.6.2 requires the verification of each pilot battery cell voltage every 31 days. This changes the CTS by extending the Surveillance interval for verification of pilot cell voltage from 7 days to 31 days.

Sequoyah Unit 1 and Unit 2 Page 7 of 14 Enclosure 2, Volume 13, Rev. 0, Page 428 of 638

Enclosure 2, Volume 13, Rev. 0, Page 429 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The purpose of CTS 4.8.1.1.3.a and 4.8.2.3.2.a is to verify that the pilot cell voltages are within limits. ITS 3.8.6.2 ensures the pilot cell float voltages are equal to or greater than the short term absolute minimum voltage. This change extends the Surveillance Frequency from 7 days to 31 days for verification of pilot cell voltage. This change is acceptable because the new Surveillance Frequency ensures an acceptable level of equipment reliability and is consistent with the Frequency recommended in IEEE-450-2002. This change is also acceptable since ITS 5.5.15, "Battery Monitoring and Maintenance Program," has been added which requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the ITS SR 3.8.6.2 limit of 2.07 V. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L03 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.3.b.2 and 4.8.2.3.2.b.2 require verification that there is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 10-6 ohms. CTS 4.8.1.1.3.c and 4.8.2.3.2.c, in part, require verification that the cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, the battery-to-battery and terminal connections are clean, tight and coated with anti-corrosion material, and the resistance of each cell-to-terminal connection is less than or equal to 150 x 10-6 ohms. ITS 3.8.6 does not include these requirements for battery inspections, the removal of visible corrosion, and the verification that the battery-to-battery and terminal connections are clean, tight, and coated with anti-corrosion material.

This changes the CTS by deleting the explicit battery requirements from the Technical Specifications.

The purpose of CTS 4.8.1.1.3.b.2, 4.8.1.1.3.c, 4.8.2.3.2.b.2, and CTS 4.8.2.3.2.c, and the Vital and DG batteries, is to ensure that the proper preventative maintenance type of battery activities are performed. In accordance with ITS SR 3.0.1, when any SR is not met, the LCO is not met. This is based on the premise that SRs represent the minimum acceptable requirements for OPERABILITY of the required equipment. However, the failure to meet these specific Surveillances does not necessarily mean that the equipment is not capable of performing its safety function. When the batteries are capable of meeting ITS SR 3.8.4.1, the battery terminal voltage verification and ITS SR 3.8.4.3, the battery capacity test, they are considered to be able to meet their safety function. The Surveillances that are proposed to be deleted are considered preventative maintenance type activities and are not considered the minimum acceptable requirements for OPERABILITY of the batteries. This change is acceptable because the SR requirements proposed in ITS 3.8.4 continue to ensure that the batteries are maintained consistent with the safety analyses and licensing basis. In addition, ITS 5.5.15, "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on the recommendations of IEEE 450-2002. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-2002, and as such, will be maintained in the plant procedures implementing ITS 5.5.15.

This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

Sequoyah Unit 1 and Unit 2 Page 8 of 14 Enclosure 2, Volume 13, Rev. 0, Page 429 of 638

Enclosure 2, Volume 13, Rev. 0, Page 430 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.3.b.3 and 4.8.2.3.2.b.3 require, in part, verifying the average electrolyte temperature of 6 connected cells is within limits. ITS SR 3.8.6.4 requires, in part, verification that each required battery pilot cell temperature is within limits. This changes the CTS by only requiring verifying the pilot cell temperature instead of the average of 6 connected cells.

The purpose of monitoring cell temperature is to monitor battery capability because as the temperature of the electrolyte increases, the internal resistance decreases and the electrochemical reaction rates increase conversely as temperature decreases. Because batteries have very large thermal inertia; the batteries are designed with significant margins (i.e., temperature, aging, and design); and there is monitoring and correction of low battery room temperatures, the pilot cell temperature is an accurate representation of the temperature of the battery bank and is adequate to ensure that the minimum electrolyte temperature is maintained. ITS 5.5.15, Battery Monitoring and Maintenance Program, requires a program that includes provisions for limits on average electrolyte temperature and battery room temperature is routinely monitored. Thus, this change is considered acceptable because electrolyte temperature limits are provided in the Battery Monitoring and Maintenance Program and the battery room temperature is routinely monitored. Therefore, the pilot cell temperature is considered a sufficiently accurate representation of the temperature of the battery bank. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.3.a.1 requires verifying the parameters in Table 4.8-1a meet Category A limits at least once per 7 days for the DG batteries. CTS 4.8.2.3.2.a.1 requires verifying the parameters in Table 4.8.2 meet Category A limits at least once per 7 days for the Vital Batteries. CTS Table 4.8-1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2)

Category A contains the parameter 'Electrolyte Level' with the limit for each designated pilot cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark." CTS 4.8.1.1.3.b.1 requires verifying the parameters in Table 4.8-1a meet Category B limits at least once per 92 days.

CTS 4.8.2.3.2.b.1 requires verifying the parameters in Table 4.8-2 meet Category B limits at least once per 92 days. CTS Table 4.8-1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2) Category B contains the parameter 'Electrolyte Level' with the limit for each connected cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark." In addition, the Category B electrolyte level Allowable Value for each connected cell (which includes the pilot cells) is above the top of plates, and not overflowing. ITS SR 3.8.6.3 requires verifying each Vital and DG battery connected cell electrolyte level is greater than or equal to minimum established design limits in accordance with the Surveillance Frequency Control Program. Changes for the Frequency for verification of each connected cells electrolyte level and relocating this Frequency to the Surveillance Frequency Control Program are discussed in other DOCs. This changes the CTS by deleting the requirement to verify the pilot cells electrolyte level is within limits at least once per 7 days.

Sequoyah Unit 1 and Unit 2 Page 9 of 14 Enclosure 2, Volume 13, Rev. 0, Page 430 of 638

Enclosure 2, Volume 13, Rev. 0, Page 431 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The purpose of CTS Category A limit on pilot cell electrolyte level and its related Frequency is to represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. The definition of Limiting Condition for Operation (LCO) presented in 10 CFR 50.36 states that LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." As such, the Category A value for cell electrolyte level does not reflect the 10 CFR 50.36 criteria for LCOs. ITS 5.5.15, Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2002 as endorsed by Regulatory Guide 1.129, Revision 2, with exceptions and other provisions.

IEEE 450-2002 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications.

These values and actions associated with restoration are being replaced by a licensee controlled program, required and described in TS Section 5.5, "Program," and titled the "Battery Monitoring and Maintenance Program." This provides adequate assurance that necessary battery parameter values will continue to be controlled and actions will be implemented if the battery parameter values are not met. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L06 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.3.b.1 requires verifying the parameters in Table 4.8.1a meet Category B limits at least once per 92 days for the DG batteries. CTS 4.8.2.3.2.b.1 requires verifying the parameters in Table 4.8.2 (CTS Table 4.8-2 for Unit 2) meet Category B limits at least once per 92 days for the vital batteries. CTS Table 4.8.1a and Table 4.8.2 (CTS Table 4.8-2 for Unit 2) Category B contains the parameter 'Electrolyte Level' with an allowable value for each connected cell of "Above top of plates, and not overflowing." In addition Note (3) states that with any Category B parameter not within its allowable value indicates an inoperable battery. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater or equal to minimum established design limits at a Frequency of every 31 days. (DOC M01 discusses changing the CTS Frequency of 92 days to the ISTS Frequency of 31 days. DOC LA01 discusses moving this Frequency to the Surveillance Frequency Control Program.) ITS 3.8.6 Required Action C.1 requires restoration of battery's electrolyte level to above the top of the plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or Condition F is entered with a Required Action to declare the associated battery inoperable immediately. This changes the CTS by relaxing the requirement of immediately declaring the battery inoperable, and allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the battery parameter to within limits before having to declare the battery inoperable.

The purpose of CTS Category B allowable value on each connected cell for electrolyte level and its related Frequency is to ensure that the plates suffer no physical damage and maintain adequate electron transfer capability to ensure the battery can perform its intended function and maintain a margin of safety.

Sequoyah Unit 1 and Unit 2 Page 10 of 14 Enclosure 2, Volume 13, Rev. 0, Page 431 of 638

Enclosure 2, Volume 13, Rev. 0, Page 432 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS Electrolyte level cannot decrease to below the top of the plates or be overflowing unless it has exceeded the limits prescribed in ITS SR 3.8.6.3. If battery electrolyte level is found outside the minimum established design limits ITS 3.8.6 Condition C is entered with Required Action C.1 requiring restoring electrolyte level to above the top of the plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or declaring the battery inoperable. With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. ITS 5.5.15, Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2002 as endorsed by Regulatory Guide 1.129, Revision 2, with exceptions and other provisions. IEEE 450-2002 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications. New Required Actions C.1 and C.2 restore the electrolyte level and ensure that the cause of the loss of electrolyte level is not due to a leak in the battery cell jar. These changes, with the additional requirements in the Battery Monitoring and Maintenance Program, are adequate to ensure that minimum electrolyte levels are maintained. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L07 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.3.b.1 and 4.8.2.3.2.b.1 require verification that each connected cell voltage is > 2.07 V at least every 92 days. ITS SR 3.8.6.5 requires the verification that each connected cell voltage is 2.07 V. This changes the CTS by reducing the acceptance criteria for each connected cell voltage limit from >

2.07 V to 2.07 V.

The purpose of CTS 4.8.1.1.3.b.1 and 4.8.2.3.2.b.1 is to verify each connected cell voltage > 2.07 V, thereby establishing a minimum value for battery OPERABILITY. The purpose of the ITS 3.8.6.5 requirement to verify each connected cell voltage is 2.07 V is also to establish a minimum value for battery OPERABILITY. Optimal long-term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 2.063 V per cell. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable.

Float voltages in this range or less, but greater than 2.07 V per cell, are addressed in the Battery Monitoring and Maintenance Program. Furthermore, the Battery Monitoring and Maintenance Program includes actions to restore battery cells with float voltage less than 2.13 V and actions to verify that the remaining cells are greater than or equal to 2.07 V when a cell or cells have been found to be less than 2.13 V. The 2.07 V per individual cell limit reflects the OPERABILITY limit for the batteries. With all battery cells at or above 2.07 V, there is adequate assurance that that the terminal voltage is at an acceptable threshold for establishing battery OPERABILITY. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 11 of 14 Enclosure 2, Volume 13, Rev. 0, Page 432 of 638

Enclosure 2, Volume 13, Rev. 0, Page 433 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L08 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.3.a.1 and 4.8.2.3.2.a.1 require verification that the pilot cell voltage is 2.13 V. ITS SR 3.8.6.2 requires the verification that each pilot cell voltage is 2.07 V. ITS 3.8.6 ACTION A addresses the condition in which one or more batteries with one or more battery cells float voltage less than 2.07 V. Once ACTION A has been entered, the battery cell is considered degraded and the Required Actions are to perform SR 3.8.4.1 and SR 3.8.6.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 is to ensure the cell voltages are greater than or equal to the short-term absolute minimum voltage. A cell voltage of 2.07 V or below under float conditions may indicate internal cell problems while prolonged operation of cells below 2.13 V has the potential to reduce the life expectancy of cells. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V. At this lower voltage the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.15, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L09 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.3.a.1 requires the verification that DG battery pilot cell specific gravity is within limit (Category A limits of Table 4.8.1a) and CTS 4.8.1.1.3.b.1 requires the verification that the DG battery connected cells specific gravity is within limits (Category B limits of Table 4.8.1a, as modified by footnote (a)). CTS 4.8.2.3.2.a.1 requires the verification that the pilot cell specific gravity is within limit (the Category A limits of Table 4.8.2 (CTS Table 4.8-2 for Unit 2), as modified by footnote (a)) and CTS 4.8.2.3.2.b.1 requires the verification that the connected cell specific gravity is within limit (the Category B limits of Table 4.8.2 (CTS Table 4.8-2 for Unit 2)).

As indicated in CTS Table 4.8.1a and CTS Table 4.8.2 (CTS Table 4.8-2 for Unit

2) (footnote (a)), the specific gravity limit must be corrected for electrolyte temperature and level. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting the Surveillances to verify battery cell specific gravity.

The purpose of CTS 4.8.1.1.3.a.1, 4.8.1.1.3.b.1, 4.8.2.3.2.a.1, and 4.8.2.3.2.b.1 is to ensure the state of charge of each DG and Vital battery cell. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its Sequoyah Unit 1 and Unit 2 Page 12 of 14 Enclosure 2, Volume 13, Rev. 0, Page 433 of 638

Enclosure 2, Volume 13, Rev. 0, Page 434 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS assumed safety function. While the specified Surveillances have been deleted, the alternative Surveillances of CTS Table 4.8.1a, footnote (b), to verify DG battery float current < 2 amps, and CTS Table 4.8.2 (CTS Table 4.8-2 for Unit 2),

footnote (b) to verify Vital battery float current is < 2 amps is retained in ITS as SR 3.8.6.1, with modifications to the acceptance criteria to reflect the information provided by the battery manufacturer. (See DOC M03 for the discussion on changing the DG battery float current acceptance criterion to 1 amp.) IEEE 450-2002 states that the most accurate indicator of return to full charge is a stabilized charging or float current. Specific gravity readings may not be accurate when the battery is on charge following a discharge. Therefore, ITS SR 3.8.6.1 gives a better indication of the overall battery condition. This change is designated as less restrictive because Surveillances which are required in CTS will not be required in ITS.

L10 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.3.2.b requires the performance of several Surveillances within 7 days after a battery discharge (battery terminal voltage below 110 volts), or battery overcharge (battery terminal voltage above 150 volts). ITS 3.8.6 does not require these Surveillances to be performed after a battery discharge or overcharge. (See DOC L03 for the discussion on deleting the battery inspection requirements from CTS. See DOC L09 for the discussion on replacing the requirement to verify the battery cell specific gravity within limits to a requirement to verify battery float current within limits.) This changes the CTS by not including a specific Surveillance Requirement to perform these tests after a discharge or overcharge.

The purpose of the CTS 4.8.2.3.2.b Frequency is to ensure the batteries remain OPERABLE after a severe battery discharge or overcharge. This change is acceptable because the proposed Surveillance Requirement Frequency continues to ensure an acceptable level of equipment reliability. ITS SR 3.8.6.1 requires verification that each Vital battery float current is 2 amps every 7 days.

The float current requirements are based on the float current indicative of a charged battery. Therefore, this Surveillance will detect a discharge condition of the battery. In addition, ITS 5.5.15, "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on the recommendations of IEEE 450-2002. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-2002, and as such, will be maintained in the plant procedures implementing ITS 5.5.15. This change is designated as less restrictive because Surveillances will be performed less frequently under ITS than under CTS.

L11 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.e requires the performance of a battery performance discharge test on the vital batteries. ITS SR 3.8.6.6 requires the performance of a performance discharge test or a modified performance discharge test. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test.

The purpose of CTS 4.8.2.3.2.e is to determine overall battery degradation due to age and usage. A performance test, as defined in IEEE 450-2002, is a constant-current or constant-power capacity test made on a battery after it has been in service, to detect any change in the capacity. A modified performance Sequoyah Unit 1 and Unit 2 Page 13 of 14 Enclosure 2, Volume 13, Rev. 0, Page 434 of 638

Enclosure 2, Volume 13, Rev. 0, Page 435 of 638 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS test, as defined in IEEE 450-2002, is a test, in the "as found" condition, of battery capacity and the ability of the battery to satisfy the duty cycle. Both tests, performance discharge test or modified performance discharge test, monitor the battery capacity. IEEE 450-2002, as endorsed by RG 1.129-2007, states that a modified performance test is a test of battery capacity using a constant current, modified by increasing the current to bound the currents in the duty cycle.

Deviations from the constant-current test, which increase the current, are acceptable. IEEE 450-2002 also states that a modified performance test can be used in lieu of a service test and/or a performance test at any time. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are acceptable for verification that the equipment used to meet the LCO can perform its required functions. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L12 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.3.2.f requires an increased Frequency (Annually) from that in CTS 4.8.2.3.2.e (60 months) for vital battery performance tests if the battery shows signs of degradation or has reached 85% of its expected service life. ITS SR 3.8.6.6 provides two Frequencies when a battery has reached 85% of its expected service life based on whether the battery's remaining capacity is less than 100% or not. If the battery's remaining capacity is less than 100% of the manufactures rating the required discharge test is performed every 12 months (annually). If the battery's remaining capacity is greater than or equal to 100% of the manufactures rating then the required discharge test is performed every 24 months. This changes the CTS by relaxing the Frequency of required discharge tests when the battery has reached 85% of its expected service life.

The purpose of CTS 4.8.2.3.2.f is to verify the battery capacity is acceptable on batteries that show signs of degradation or have reached 85% of the service life.

ITS 3.8.6.6 provides an alternative Frequency if the battery that has reached 85% of its service life but has not shown signs of degradation and has a capacity of greater than or equal to 100% of the manufactures rating. This relaxed frequency is acceptable because the battery has not shown signs of degradation, retains greater than or equal to the manufacturers rated capacity, and is being tested at a more frequent periodicity than a battery that has not reached 85% of the service life expected. Also, IEEE-450 states that if the battery has reached 85% of service life, delivers a capacity of 100% or greater of the manufacturers rated capacity, and has shown no signs of degradation, performance testing at two-year intervals is acceptable until the battery shows signs of degradation.

This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 14 of 14 Enclosure 2, Volume 13, Rev. 0, Page 435 of 638

Enclosure 2, Volume 13, Rev. 0, Page 436 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 436 of 638

Enclosure 2, Volume 13, Rev. 0, Page 437 of 638 CTS Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters Vital and diesel generator (DG) batteries 3.8.1.1, LCO 3.8.6 Battery parameters for Train A and Train B batteries electrical power 1 3.8.1.2, 3.8.2.3, subsystem shall be within limits.

3.8.2.4 Vital and DG DC Applicability APPLICABILITY: When associated DC electrical power subsystems are required to be 1 OPERABLE.

ACTIONS


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

DOC A03 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME more DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 3 on one subsystem] with one or more battery cells AND float voltage < [2.07] V. 2 A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> voltage [2.07] V.

more Vital DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem] with float current > [2] amps. AND 2 3 Vital B.2 Restore battery float current [12] hours

.1 to [2] amps.

INSERT 1 3 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.6-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 437 of 638

Enclosure 2, Volume 13, Rev. 0, Page 438 of 638 3.8.6 3

INSERT 1 DOC L01 OR OR One or more DG B.2.2 Restore DG battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> batteries with float current to 1 amp.

current > 1 amp.

Insert Page 3.8.6-1 Enclosure 2, Volume 13, Rev. 0, Page 438 of 638

Enclosure 2, Volume 13, Rev. 0, Page 439 of 638 CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 C. -----------NOTE------------- -------------------NOTE--------------------

Required Action C.2 Required Actions C.1 and C.2 are shall be completed if only applicable if electrolyte level electrolyte level was was below the top of plates.

below the top of plates. ------------------------------------------------

more C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> One [or two] batter[y][ies above top of plates. 2 3 on one subsystem] with one or more cells AND electrolyte level less than minimum C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> established design leakage.

limits.

AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

more DOC L01 D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 3 on one subsystem] with temperature to greater than pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

DOC L01 E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> trains redundant subsystems for batteries in one 1 with battery parameters subsystem to within limits.

train not within limits.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.6-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 439 of 638

Enclosure 2, Volume 13, Rev. 0, Page 440 of 638 CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR more Vital One [or two] batter[y][ies on one subsystem] with one or more battery cells 2 3 float voltage < [2.07] V and float current

> [2] amps.

INSERT 2 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.3.a.1, SR 3.8.6.1 -------------------------------NOTE------------------------------

4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

vital Verify each battery float current is [2] amps. [ 7 days 1 2 and each DG battery float current is 1 amp 3 OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.6-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 440 of 638

Enclosure 2, Volume 13, Rev. 0, Page 441 of 638 3.8.6 3

INSERT 2 DOC L01 OR One or more DG batteries with one or more battery cells float voltage < 2.07 V and float current > 1 amp.

OR SR 3.8.6.6 not met.

OR SR 3.8.6.7 not met.

Insert Page 3.8.6-3 Enclosure 2, Volume 13, Rev. 0, Page 441 of 638

Enclosure 2, Volume 13, Rev. 0, Page 442 of 638 CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.3.a.1, SR 3.8.6.2 Verify each battery pilot cell float voltage is [ 31 days 4.8.2.3.2.a.1

[2.07] V. 2 OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.1, SR 3.8.6.3 Verify each battery connected cell electrolyte level is [ 31 days 4.8.2.3.2.b.1 greater than or equal to minimum established design limits. OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.3, SR 3.8.6.4 Verify each battery pilot cell temperature is greater [ 31 days 4.8.2.3.2.b.3 than or equal to minimum established design limits.

OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.1, SR 3.8.6.5 Verify each battery connected cell float voltage is [ 92 days 4.8.2.3.2.b.1

[2.07] V. 2 OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.6-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 442 of 638

Enclosure 2, Volume 13, Rev. 0, Page 443 of 638 CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.6 -------------------------------NOTE------------------------------

DOC M04 This Surveillance shall not be performed in on in-service MODE 1, 2, 3, or 4. However, portions of the Vital batteries Surveillance may be performed to reestablish 6 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.

82 vital 4.8.2.3.2.e Verify battery capacity is [80%] of the [ 60 months 1 2 4.8.2.3.2.f manufacturer's rating when subjected to a performance discharge test or a modified OR performance discharge test.

In accordance 5 with the Surveillance Frequency Control Program ]

AND 12 months when battery shows degradation, or has reached 2

[85]% of the expected life with capacity < 100%

of manufacturer's rating AND DOC L09 24 months when battery has reached [85]% of 2 the expected life with capacity 100% of manufacturer's rating INSERT 3 3 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.6-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 443 of 638

Enclosure 2, Volume 13, Rev. 0, Page 444 of 638 3.8.6 3

INSERT 3 DOC M02 SR 3.8.6.7 -------------------------------NOTE------------------------------

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

Verify DG battery capacity is 80% of the In accordance manufacturer's rating when subjected to a with the performance discharge test or a modified Surveillance performance discharge test. Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturer's rating Insert Page 3.8.6-5 Enclosure 2, Volume 13, Rev. 0, Page 444 of 638

Enclosure 2, Volume 13, Rev. 0, Page 445 of 638 CTS Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters Vital and diesel generator (DG) batteries 3.8.1.1, LCO 3.8.6 Battery parameters for Train A and Train B batteries electrical power 1 3.8.1.2, 3.8.2.3, subsystem shall be within limits.

3.8.2.4 Vital and DG DC Applicability APPLICABILITY: When associated DC electrical power subsystems are required to be 1 OPERABLE.

ACTIONS


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

DOC A03 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME more DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 3 on one subsystem] with one or more battery cells AND float voltage < [2.07] V. 2 A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> voltage [2.07] V.

more Vital DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem] with float current > [2] amps. AND 2 3 Vital B.2 Restore battery float current [12] hours

.1 to [2] amps.

INSERT 1 3 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.6-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 445 of 638

Enclosure 2, Volume 13, Rev. 0, Page 446 of 638 3.8.6 3

INSERT 1 DOC L01 OR OR One or more DG B.2.2 Restore DG battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> batteries with float current to 1 amp.

current > 1 amp.

Insert Page 3.8.6-1 Enclosure 2, Volume 13, Rev. 0, Page 446 of 638

Enclosure 2, Volume 13, Rev. 0, Page 447 of 638 CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 C. -----------NOTE------------- -------------------NOTE--------------------

Required Action C.2 Required Actions C.1 and C.2 are shall be completed if only applicable if electrolyte level electrolyte level was was below the top of plates.

below the top of plates. ------------------------------------------------

more C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> One [or two] batter[y][ies above top of plates. 2 3 on one subsystem] with one or more cells AND electrolyte level less than minimum C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> established design leakage.

limits.

AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

more DOC L01 D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 3 on one subsystem] with temperature to greater than pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

DOC L01 E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> trains redundant subsystems for batteries in one 1 with battery parameters subsystem to within limits.

train not within limits.

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.6-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 447 of 638

Enclosure 2, Volume 13, Rev. 0, Page 448 of 638 CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR more Vital One [or two] batter[y][ies on one subsystem] with one or more battery cells 2 3 float voltage < [2.07] V and float current

> [2] amps.

INSERT 2 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.3.a.1, SR 3.8.6.1 -------------------------------NOTE------------------------------

4.8.2.3.2.a.1 Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

vital Verify each battery float current is [2] amps. [ 7 days 1 2 and each DG battery float current is 1 amp 3 OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.6-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 448 of 638

Enclosure 2, Volume 13, Rev. 0, Page 449 of 638 3.8.6 3

INSERT 2 DOC L01 OR One or more DG batteries with one or more battery cells float voltage < 2.07 V and float current > 1 amp.

OR SR 3.8.6.6 not met.

OR SR 3.8.6.7 not met.

Insert Page 3.8.6-3 Enclosure 2, Volume 13, Rev. 0, Page 449 of 638

Enclosure 2, Volume 13, Rev. 0, Page 450 of 638 CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.1.1.3.a.1, SR 3.8.6.2 Verify each battery pilot cell float voltage is [ 31 days 4.8.2.3.2.a.1

[2.07] V. 2 OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.1, SR 3.8.6.3 Verify each battery connected cell electrolyte level is [ 31 days 4.8.2.3.2.b.1 greater than or equal to minimum established design limits. OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.3, SR 3.8.6.4 Verify each battery pilot cell temperature is greater [ 31 days 4.8.2.3.2.b.3 than or equal to minimum established design limits.

OR In accordance 5 with the Surveillance Frequency Control Program ]

4.8.1.1.3.b.1, SR 3.8.6.5 Verify each battery connected cell float voltage is [ 92 days 4.8.2.3.2.b.1

[2.07] V. 2 OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.6-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 450 of 638

Enclosure 2, Volume 13, Rev. 0, Page 451 of 638 CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.6 -------------------------------NOTE------------------------------

DOC M04 This Surveillance shall not be performed in on in-service MODE 1, 2, 3, or 4. However, portions of the Vital batteries Surveillance may be performed to reestablish 6 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.

82 vital 4.8.2.3.2.e Verify battery capacity is [80%] of the [ 60 months 1 2 4.8.2.3.2.f manufacturer's rating when subjected to a performance discharge test or a modified OR performance discharge test.

In accordance 5 with the Surveillance Frequency Control Program ]

AND 12 months when battery shows degradation, or has reached 2

[85]% of the expected life with capacity < 100%

of manufacturer's rating AND DOC L09 24 months when battery has reached [85]% of 2 the expected life with capacity 100% of manufacturer's rating INSERT 3 3 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.6-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 451 of 638

Enclosure 2, Volume 13, Rev. 0, Page 452 of 638 3.8.6 3

INSERT 3 DOC M02 SR 3.8.6.7 -------------------------------NOTE------------------------------

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

Verify DG battery capacity is 80% of the In accordance manufacturer's rating when subjected to a with the performance discharge test or a modified Surveillance performance discharge test. Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturer's rating Insert Page 3.8.6-5 Enclosure 2, Volume 13, Rev. 0, Page 452 of 638

Enclosure 2, Volume 13, Rev. 0, Page 453 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6, BATTERY PARAMETERS

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes have been made to reflect the differences in the acceptance criteria between the Vital batteries and the diesel generator (DG) batteries.
4. ISTS SR 3.8.6.6 requires a battery performance discharge or modified performance discharge test to be performed and provides acceptance criteria. However, no ACTION is provided in the ISTS 3.8.6 ACTIONS for when this SR is not met.

Therefore, in the ISTS, LCO 3.0.3 would be entered. To preclude an LCO 3.0.3 entry, ISTS 3.8.6 Condition F has been modified to cover the case when SR 3.8.6.6 is not met. In addition, because proposed ITS SR 3.8.6.7 is similar to ITS SR 3.8.6.6 but for different batteries, Condition F has been modified to cover the case when SR 3.8.6.7 is not met. ACTION F will require the associated battery to be declared inoperable. This is also consistent with the current Technical Specification requirements.

5. ISTS SR 3.8.6.1, ISTS SR 3.8.6.2, ISTS SR 3.8.6.3, ISTS SR 3.8.6.4, ISTS SR 3.8.6.5, and ISTS SR 3.8.6.6 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.6.1, ITS SR 3.8.6.2, ITS SR 3.8.6.3, ITS SR 3.8.6.4, ITS SR 3.8.6.5, and ITS SR 3.8.6.6 is "In accordance with the Surveillance Frequency Control Program."
6. The Note modifying ISTS SR 3.8.6.6 has be changed to reflect that no portion of the Vital battery performance discharge or modified performance discharge test can be performed on an in-service battery in MODES 1, 2, 3, or 4 without making the battery inoperable. This test is normally performed by removing the battery from service and placing the spare vital battery in-service. Furthermore, the test is not performed in steps, where only part of the test can be performed.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 453 of 638

Enclosure 2, Volume 13, Rev. 0, Page 454 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 454 of 638

Enclosure 2, Volume 13, Rev. 0, Page 455 of 638 Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGROUND This LCO delineates the limits on battery float current as well as Vital and diesel electrolyte temperature, level, and float voltage for the DC power 1 generator (DG) subsystem batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." In addition to the limitations of this Specification, the [licensee controlled 2 Battery Monitoring and Maintenance Program program] also implements a program specified in Specification 5.5.17 for 3 monitoring various battery parameters. 15 Vital The battery cells are of flooded lead acid construction with a nominal 1 123.78 specific gravity of [1.215]. This specific gravity corresponds to an open 60 circuit battery voltage of approximately 120 V for [58] cell battery (i.e., cell 2 voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the 2.063 voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 4 maintain its capacity for [30] days without further charging per manufacturer's instructions. Optimal long term performance however, is 2.17 2 obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total float voltage output of [128.8] V for a [58] cell battery as discussed in the 1 FSAR, Chapter [8] (Ref. 2).

APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient 1 2 SAFETY analyses in the FSAR, Chapter [6] (Ref. 3) and Chapter [15] (Ref. 4),

ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the train design basis of the unit. This includes maintaining at least one subsystem of DC sources OPERABLE during accident conditions, in the 1 event of:

a. An assumed loss of all offsite AC power or all onsite AC power and
b. A worst-case single failure.

Battery parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 455 of 638

Enclosure 2, Volume 13, Rev. 0, Page 456 of 638 Battery Parameters B 3.8.6 BASES LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testing, and Battery Monitoring and monitoring performed in accordance with the [licensee controlled 2 3 Maintenance Program program] is conducted as specified in Specification 5.5.17.

15 APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical power subsystems. Therefore, battery parameter limits are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACTIONS A.1, A.2, and A.3 With one or more cells in one or more batteries in one subsystem 5

< [2.07] V, the battery cell is degraded. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the 2 required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries < [2.07] V, 2 and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is no assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

B.1 and B.2 or one or more DG batteries vital with float current > 1 amp One or more batteries in one subsystem with float current > [2] amps 1 5 2 indicates that a partial discharge of the battery capacity has occurred.

This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 456 of 638

Enclosure 2, Volume 13, Rev. 0, Page 457 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued) operating in the current limit mode. Condition A addresses charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within

[12] hours (Required Action B.2). The battery must therefore be declared 2 5 inoperable. .1 or B.2.2 If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than [2.07] V, the associated "OR" 2 statement in Condition F is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than [2.07] V there is good assurance that, within [12] hours, the 2 battery will be restored to its fully charged condition (Required Action B.2) 5 from any discharge that might have occurred due to a temporary loss of the battery charger. .1 or B.2.2


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 6 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant 2 risk.

If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this 2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 457 of 638

Enclosure 2, Volume 13, Rev. 0, Page 458 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1, C.2, and C.3 With one or more batteries in one subsystem with one or more cells 5 electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this potential (as well as provisions in Specification 5.5.17, Battery Monitoring 15 3 and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level is required to be restored to above the top of the plates. The Required Action C.2 requirement to verify that there is no leakage by visual inspection and the Specification 5.5.17.b item to initiate 15 3 action to equalize and test in accordance with manufacturer's recommendation are taken from IEEE Standard 450. They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batter[y][ies] may have to be declared inoperable and the affected 2 cell[s] replaced.

D.1 With one or more batteries in one subsystem with pilot cell temperature 5 less than the minimum established design limits, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 458 of 638

Enclosure 2, Volume 13, Rev. 0, Page 459 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

E.1 trains With one or more batteries in redundant subsystems with battery 1 parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsystem 1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. train F.1 With one or more batteries with any battery parameter outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is vital not assured and the corresponding battery must be declared inoperable.

Additionally, discovering one or more batteries in one subsystem with one 5 or more battery cells float voltage less than [2.07] V and float current 2 greater than [2] amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore 5 be declared inoperable immediately. INSERT 1 SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). [ The 7 day Frequency is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 459 of 638

Enclosure 2, Volume 13, Rev. 0, Page 460 of 638 5

INSERT 1 Similarly, discovering one or more DG batteries with one or more battery cells float voltage less than 2.07 V and float current greater than 1 amp indicates that the battery capacity may not be sufficient to perform the intended functions. The associated vital or DG battery must therefore be declared inoperable. In addition, if SR 3.8.6.6 or SR 3.8.6.7 are not met, the associated vital or DG battery is declared inoperable.

Insert Page B 3.8.6-5 Enclosure 2, Volume 13, Rev. 0, Page 460 of 638

Enclosure 2, Volume 13, Rev. 0, Page 461 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of [2] amps is 2 established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5 129 V for vital batteries and 124 V for DG batteries Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to [130.5] V at 1 2 the battery terminals, or [2.25] Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in this range or less, but greater than [2.07] Vpc, are addressed in 2 15 Specification 5.5.17. SRs 3.8.6.2 and 3.8.6.5 require verification that the 3 cell float voltages are equal to or greater than the short term absolute minimum voltage of [2.07] V. [ The Frequency for cell voltage verification 2 every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1).

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 461 of 638

Enclosure 2, Volume 13, Rev. 0, Page 462 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

[ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., [40]°F). Pilot cell 60 2

electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

INSERT 2 8 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 462 of 638

, Volume 13, Rev. 0, Page 463 of 638 8

INSERT 2 SR 3.8.6.5 See SR 3.8.6.2 Bases.

Insert Page B 3.8.6-7 , Volume 13, Rev. 0, Page 463 of 638

Enclosure 2, Volume 13, Rev. 0, Page 464 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.6 8 and SR 3.8.6.7 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.3.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

It may consist of just two rates; for instance the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this [80]% limit. INSERT 3 2 1

[ The Surveillance Frequency for this test is normally 60 months. 7 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 464 of 638

Enclosure 2, Volume 13, Rev. 0, Page 465 of 638 1

INSERT 3 The minimum battery capacity for the vital batteries has been raised from 80% to 82% to allow for possible discharge during the 5-minute delay associated with the Diesel Generator Start and Load Shed Timer.

Insert Page B 3.8.6-8 Enclosure 2, Volume 13, Rev. 0, Page 465 of 638

Enclosure 2, Volume 13, Rev. 0, Page 466 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 7

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is [10%] below the manufacturer's rating. 2 These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

3.8.6.6 This SR is modified by a Note. The reason for the Note is that performing 5 the Surveillance would perturb the electrical distribution system and

, 2, 3, or 4 challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the 5 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, and 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 the assessment.

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

INSERT 4 9 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 466 of 638

Enclosure 2, Volume 13, Rev. 0, Page 467 of 638 9

INSERT 4 SR 3.8.6.7 is modified by a Note stating that credit may be taken for unplanned events that satisfy this SR.

Insert Page B 3.8.6-9 Enclosure 2, Volume 13, Rev. 0, Page 467 of 638

Enclosure 2, Volume 13, Rev. 0, Page 468 of 638 Battery Parameters B 3.8.6 BASES

-2002 REFERENCES 1. IEEE-450.

U

2. FSAR, Chapter 8.

1

3. FSAR, Chapter [6].
4. FSAR, Chapter [15]. 2
5. IEEE-485-[1983], June 1983.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.6-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 468 of 638

Enclosure 2, Volume 13, Rev. 0, Page 469 of 638 Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGROUND This LCO delineates the limits on battery float current as well as Vital and diesel electrolyte temperature, level, and float voltage for the DC power 1 generator (DG) subsystem batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." In addition to the limitations of this Specification, the [licensee controlled 2 Battery Monitoring and Maintenance Program program] also implements a program specified in Specification 5.5.17 for 3 monitoring various battery parameters. 15 Vital The battery cells are of flooded lead acid construction with a nominal 1 123.78 specific gravity of [1.215]. This specific gravity corresponds to an open 60 circuit battery voltage of approximately 120 V for [58] cell battery (i.e., cell 2 voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the 2.063 voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 4 maintain its capacity for [30] days without further charging per manufacturer's instructions. Optimal long term performance however, is 2.17 2 obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total float voltage output of [128.8] V for a [58] cell battery as discussed in the 1 FSAR, Chapter [8] (Ref. 2).

APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient 1 2 SAFETY analyses in the FSAR, Chapter [6] (Ref. 3) and Chapter [15] (Ref. 4),

ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the train design basis of the unit. This includes maintaining at least one subsystem of DC sources OPERABLE during accident conditions, in the 1 event of:

a. An assumed loss of all offsite AC power or all onsite AC power and
b. A worst-case single failure.

Battery parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 469 of 638

Enclosure 2, Volume 13, Rev. 0, Page 470 of 638 Battery Parameters B 3.8.6 BASES LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testing, and Battery Monitoring and monitoring performed in accordance with the [licensee controlled 2 3 Maintenance Program program] is conducted as specified in Specification 5.5.17.

15 APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical power subsystems. Therefore, battery parameter limits are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACTIONS A.1, A.2, and A.3 With one or more cells in one or more batteries in one subsystem 5

< [2.07] V, the battery cell is degraded. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the 2 required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries < [2.07] V, 2 and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is no assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

B.1 and B.2 or one or more DG batteries vital with float current > 1 amp One or more batteries in one subsystem with float current > [2] amps 1 5 2 indicates that a partial discharge of the battery capacity has occurred.

This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 470 of 638

Enclosure 2, Volume 13, Rev. 0, Page 471 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued) operating in the current limit mode. Condition A addresses charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within

[12] hours (Required Action B.2). The battery must therefore be declared 2 5 inoperable. .1 or B.2.2 If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than [2.07] V, the associated "OR" 2 statement in Condition F is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than [2.07] V there is good assurance that, within [12] hours, the 2 battery will be restored to its fully charged condition (Required Action B.2) 5 from any discharge that might have occurred due to a temporary loss of the battery charger. .1 or B.2.2


REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 6 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant 2 risk.

If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this 2 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 471 of 638

Enclosure 2, Volume 13, Rev. 0, Page 472 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1, C.2, and C.3 With one or more batteries in one subsystem with one or more cells 5 electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this potential (as well as provisions in Specification 5.5.17, Battery Monitoring 15 3 and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level is required to be restored to above the top of the plates. The Required Action C.2 requirement to verify that there is no leakage by visual inspection and the Specification 5.5.17.b item to initiate 15 3 action to equalize and test in accordance with manufacturer's recommendation are taken from IEEE Standard 450. They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batter[y][ies] may have to be declared inoperable and the affected 2 cell[s] replaced.

D.1 With one or more batteries in one subsystem with pilot cell temperature 5 less than the minimum established design limits, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 472 of 638

Enclosure 2, Volume 13, Rev. 0, Page 473 of 638 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

E.1 trains With one or more batteries in redundant subsystems with battery 1 parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsystem 1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. train F.1 With one or more batteries with any battery parameter outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is vital not assured and the corresponding battery must be declared inoperable.

Additionally, discovering one or more batteries in one subsystem with one 5 or more battery cells float voltage less than [2.07] V and float current 2 greater than [2] amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore 5 be declared inoperable immediately. INSERT 1 SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). [ The 7 day Frequency is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 473 of 638

Enclosure 2, Volume 13, Rev. 0, Page 474 of 638 5

INSERT 1 Similarly, discovering one or more DG batteries with one or more battery cells float voltage less than 2.07 V and float current greater than 1 amp indicates that the battery capacity may not be sufficient to perform the intended functions. The associated vital or DG battery must therefore be declared inoperable. In addition, if SR 3.8.6.6 or SR 3.8.6.7 are not met, the associated vital or DG battery is declared inoperable.

Insert Page B 3.8.6-5 Enclosure 2, Volume 13, Rev. 0, Page 474 of 638

Enclosure 2, Volume 13, Rev. 0, Page 475 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of [2] amps is 2 established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5 129 V for vital batteries and 124 V for DG batteries Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to [130.5] V at 1 2 the battery terminals, or [2.25] Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in this range or less, but greater than [2.07] Vpc, are addressed in 2 15 Specification 5.5.17. SRs 3.8.6.2 and 3.8.6.5 require verification that the 3 cell float voltages are equal to or greater than the short term absolute minimum voltage of [2.07] V. [ The Frequency for cell voltage verification 2 every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1).

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 475 of 638

Enclosure 2, Volume 13, Rev. 0, Page 476 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

[ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., [40]°F). Pilot cell 60 2

electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).

OR 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

INSERT 2 8 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 476 of 638

, Volume 13, Rev. 0, Page 477 of 638 8

INSERT 2 SR 3.8.6.5 See SR 3.8.6.2 Bases.

Insert Page B 3.8.6-7 , Volume 13, Rev. 0, Page 477 of 638

Enclosure 2, Volume 13, Rev. 0, Page 478 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.6 8 and SR 3.8.6.7 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.3.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

It may consist of just two rates; for instance the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this [80]% limit. INSERT 3 2 1

[ The Surveillance Frequency for this test is normally 60 months. 7 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 478 of 638

Enclosure 2, Volume 13, Rev. 0, Page 479 of 638 1

INSERT 3 The minimum battery capacity for the vital batteries has been raised from 80% to 82% to allow for possible discharge during the 5-minute delay associated with the Diesel Generator Start and Load Shed Timer.

Insert Page B 3.8.6-8 Enclosure 2, Volume 13, Rev. 0, Page 479 of 638

Enclosure 2, Volume 13, Rev. 0, Page 480 of 638 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 7

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 6

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is [10%] below the manufacturer's rating. 2 These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

3.8.6.6 This SR is modified by a Note. The reason for the Note is that performing 5 the Surveillance would perturb the electrical distribution system and

, 2, 3, or 4 challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the 5 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, and 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 the assessment.

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

INSERT 4 9 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-9 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 480 of 638

Enclosure 2, Volume 13, Rev. 0, Page 481 of 638 9

INSERT 4 SR 3.8.6.7 is modified by a Note stating that credit may be taken for unplanned events that satisfy this SR.

Insert Page B 3.8.6-9 Enclosure 2, Volume 13, Rev. 0, Page 481 of 638

Enclosure 2, Volume 13, Rev. 0, Page 482 of 638 Battery Parameters B 3.8.6 BASES

-2002 REFERENCES 1. IEEE-450.

U

2. FSAR, Chapter 8.

1

3. FSAR, Chapter [6].
4. FSAR, Chapter [15]. 2
5. IEEE-485-[1983], June 1983.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.6-10 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 482 of 638

Enclosure 2, Volume 13, Rev. 0, Page 483 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6 BASES, BATTERY PARAMETERS

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes have been made to reflect changes made to other Specifications.
4. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.
5. Changes have been made to reflect changes made to the Specification.
6. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
7. ISTS SR 3.8.6.1, ISTS SR 3.8.6.2, ISTS SR 3.8.6.3, ISTS SR 3.8.6.4, ISTS SR 3.8.6.5, and ISTS 3.8.6.6 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.6.1, ITS SR 3.8.6.2, ITS SR 3.8.6.3, ITS SR 3.8.6.4, ITS SR 3.8.6.5, and ITS 3.8.6.6 is "In accordance with the Surveillance Frequency Control Program."
8. Editorial changes made for enhanced clarity or reflecting specification changes.
9. ITS SR 3.8.6.7 requires performance testing or modified performance testing of the DG batteries. Because this testing would not perturb the electrical distribution system as testing the vital batteries, the MODE restrictions are not applied, but the Note allowing unplanned events to be credited as satisfying this SR is included.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 483 of 638

Enclosure 2, Volume 13, Rev. 0, Page 484 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 484 of 638

Enclosure 2, Volume 13, Rev. 0, Page 485 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 485 of 638

, Volume 13, Rev. 0, Page 486 of 638 ATTACHMENT 7 ITS 3.8.7, INVERTERS - OPERATING , Volume 13, Rev. 0, Page 486 of 638

, Volume 13, Rev. 0, Page 487 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 487 of 638

Enclosure 2, Volume 13, Rev. 0, Page 488 of 638 ITS A01 ITS 3.8.7 ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING A01 LIMITING CONDITION FOR OPERATION inverters See ITS 3.8.2.1 The following A.C. electrical boards shall be OPERABLE and energized with tie breakers open 3.8.9 between redundant boards:

6900 Volt Shutdown Board 1A-A 6900 Volt Shutdown Board 1B-B 6900 Volt Shutdown Board 2A-A 6900 Volt Shutdown Board 2B-B 480 Volt Shutdown Board 1A1-A See ITS 480 Volt Shutdown Board 1A2-A 3.8.9 480 Volt Shutdown Board 1B1-B 480 Volt Shutdown Board 1B2-B 480 Volt Shutdown Board 2A1-A 480 Volt Shutdown Board 2A2-A See ITS 480 Volt Shutdown Board 2B1-B 3.8.9 480 Volt Shutdown Board 2B2-B 120 Volt A.C. Vital Instrument Power Board Channels 1-I and 2-I energized from inverters 1-I and 2-I connected to D.C. Channel I*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-II and 2-II energized from inverters 1-II and 2-II LCO 3.8.7 connected to D.C. Channel II*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-III and 2-III energized from inverters 1-III and 2- LA01 III connected to D.C. Channel III*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-IV and 2-IV energized from inverters 1-IV and 2-IV connected to D.C. Channel IV*#@.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With less than the above complement of A.C. boards OPERABLE and energized, See ITS restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY 3.8.9 REQUIRED ACTION A.1 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

NOTE

b. With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; ACTION A restore the inoperable inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY ACTION B within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS See ITS 3.8.9 SR 3.8.7.1 4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. inverter voltage, frequency, and

_________________ In accordance with the Surveillance Frequency Control Program M01

  • Two inverters may be disconnected from their D.C. source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the purpose of LCO 3.8.7 performing an equalizing charge on their associated battery bank provided (1) the vital instrument LA02 NOTE power board is OPERABLE and energized, and (2) the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to their respective D.C. source. M02 from inverter using internal AC source
  1. D.C. Channel V may be substituted for any one channel of channels I-IV. See ITS 3.8.9

@ The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

LA01 September 23, 1999 SEQUOYAH - UNIT 1 3/4 8-9 Amendment No. 37, 246 Page 1 of 2 Enclosure 2, Volume 13, Rev. 0, Page 488 of 638

Enclosure 2, Volume 13, Rev. 0, Page 489 of 638 ITS ITS 3.8.7 A01 ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION See ITS LCO 3.8.7 3.8.2.1 The following A.C. electrical boards and inverters shall be OPERABLE and energized with tie 3.8.9 breakers open between redundant boards:

6900 Volt Shutdown Board 1A-A 6900 Volt Shutdown Board 1B-B 6900 Volt Shutdown Board 2A-A 6900 Volt Shutdown Board 2B-B 480 Volt Shutdown Board 1A1-A See ITS 480 Volt Shutdown Board 1A2-A 3.8.9 480 Volt Shutdown Board 1B1-B 480 Volt Shutdown Board 1B2-B 480 Volt Shutdown Board 2A1-A 480 Volt Shutdown Board 2A2-A 480 Volt Shutdown Board 2B1-B See ITS 480 Volt Shutdown Board 2B2-B 3.8.9 120 Volt A.C. Vital Instrument Power Board Channels 1-I and 2-I energized from inverters 1-I and 2-I connected to D.C. Channel I*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-II and 2-II energized from inverter 1-II and 2-II connected to D.C. Channel II*#@.

LA01 120 Volt A.C. Vital Instrument Power Board Channels l-III and 2-III energized from inverter 1-III and 2-III connected to D.C. Channel III*#@.

120 Volt A.C. Vital Instrument Power Board Channels l-IV and 2-IV energized from inverter 1-IV and 2-IV connected to D.C. Channel IV*#@.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With less than the above complement of A.C. boards OPERABLE and energized, restore the See ITS inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the 3.8.9 REQUIRED next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

ACTION A.1 NOTE With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; ACTION A b.

restore the inoperable inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT ACTION B STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS See ITS 3.8.9 SR 3.8.7.1 4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. inverter voltage, frequency, and M01 In accordance with the Surveillance Frequency Control Program

  • Two inverters may be disconnected from their D.C. source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the purpose of LA02 LCO 3.8.7 performing an equalizing charge on their associated battery bank provided (1) the vital instrument NOTE power board is OPERABLE and energized, and (2) the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to M02 their respective D.C. sources. from inverter using internal AC source See ITS
  1. D.C. Channel V may be substituted for any one channel of channels I - IV.

3.8.9

@ The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

LA01 September 23, 1999 SEQUOYAH - UNIT 2 3/4 8-10 Amendment No. 29, 237 Page 2 of 2 Enclosure 2, Volume 13, Rev. 0, Page 489 of 638

Enclosure 2, Volume 13, Rev. 0, Page 490 of 638 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 4.8.2.1 requires, in part, the specified inverters to be determined OPERABLE by verifying correct breaker alignment. ITS SR 3.8.7.1 requires the verification of correct inverter voltage, frequency, and alignment to required AC vital buses. This changes the CTS by requiring the specific verification of the inverter voltage and frequency.

The purpose of this change is to ensure the instrumentation channels are provided with the proper voltage and frequency from the AC vital bus when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters.

Proper voltage and frequency is supplied to the instrumentation channels that provide inputs to the Reactor Trip System and Engineered Safety Features Actuation System. This change is designated as more restrictive because the ITS requires verification of the correct voltage and frequency, where the CTS does not provide explicit requirements for the inverter.

M02 CTS 3.8.2.1 Note

  • provides an allowance for two inverters to be disconnected from their DC source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for performing an equalizing charge on their associated battery bank, if certain provisions are maintained. One of the provisions is that the vital instrument power board is OPERABLE and energized.

ITS 3.8.7 Note provides a similar allowance, and specifies that the affected vital instrument power board is powered from the inverter connected to its internal AC source. This changes the CTS by specifying that the inverters that are disconnected from their DC source for the performance of an equalizing charge on the associated battery bank shall be energized from their respective internal AC source.

The purpose of CTS 3.8.2.1 is to ensure stable and reliable AC electrical power for the system instrumentation required for a safe reactor shut down. CTS 3.8.2.1 Note

  • provides an allowance to disconnect the inverters from their DC source to preclude damage to the inverters when the associated battery bank is undergoing an equalizing charge. Requiring the vital instrument board to be energized from its respective inverter powered from the internal AC source ensures the vital instrument board continues to be powered from a stable power source to minimize perturbations on the vital instrumentation board. This change Sequoyah Unit 1 and Unit 2 Page 1 of 3 Enclosure 2, Volume 13, Rev. 0, Page 490 of 638

Enclosure 2, Volume 13, Rev. 0, Page 491 of 638 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING is designated as more restrictive because ITS requires the vital instrumentation boards associated with a inverters disconnected from their DC source during an equalizing charge on the associated battery bank to be energized from a specific source of power.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.1 states, in part, inverters 1-I and 2-I connected to D.C. Channel I, inverters 1-II and 2-II connected to D.C. Channel II, inverters 1-III and 2-III connected to D.C. Channel III, and inverters 1-IV and 2-IV connected to D.C. Channel IV. CTS 3.8.2.1 Note @ states, in part, the spare inverter for a specified channel may be substituted for one of the two inverters of the same channel. ITS 3.8.7 does not contain this level of detail information. This changes the CTS by moving the level of detail of inverter designators and alignment to the DC channel and details that spare inverter may be substituted for one of the two inverters of the same channel to the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.2.1 requires, in part, verification of the correct breaker alignment for the inverters at least once per 7 days. ITS SR 3.8.7.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency for the SR to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain Sequoyah Unit 1 and Unit 2 Page 2 of 3 Enclosure 2, Volume 13, Rev. 0, Page 491 of 638

Enclosure 2, Volume 13, Rev. 0, Page 492 of 638 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

Sequoyah Unit 1 and Unit 2 Page 3 of 3 Enclosure 2, Volume 13, Rev. 0, Page 492 of 638

Enclosure 2, Volume 13, Rev. 0, Page 493 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 493 of 638

Enclosure 2, Volume 13, Rev. 0, Page 494 of 638 CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 3.8.2.1 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

T


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

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC bus for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform an equalizing charge on [its/their]

associated [common] battery, provided:

a. The associated AC vital bus(es) [is/are] energized from [its/their]

3.8.2.1 Note *

[Class 1E constant voltage source transformers] [inverter using 2 internal AC source], and

b. All other AC vital buses are energized from their associated OPERABLE inverters. ]

connected to their DC source Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION b A. One [required] inverter A.1 --------------NOTE-------------- 2 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.

Restore inverter to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.

ACTION b B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.7-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 494 of 638

Enclosure 2, Volume 13, Rev. 0, Page 495 of 638 CTS Inverters - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1 SR 3.8.7.1 Verify correct inverter voltage, [frequency], and [ 7 days 2 alignment to required AC vital buses.

OR In accordance 3 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.7-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 495 of 638

Enclosure 2, Volume 13, Rev. 0, Page 496 of 638 CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 3.8.2.1 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

T


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

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC bus for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform an equalizing charge on [its/their]

associated [common] battery, provided:

a. The associated AC vital bus(es) [is/are] energized from [its/their]

3.8.2.1 Note *

[Class 1E constant voltage source transformers] [inverter using 2 internal AC source], and

b. All other AC vital buses are energized from their associated OPERABLE inverters. ]

connected to their DC source Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION b A. One [required] inverter A.1 --------------NOTE-------------- 2 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.

Restore inverter to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.

ACTION b B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.7-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 496 of 638

Enclosure 2, Volume 13, Rev. 0, Page 497 of 638 CTS Inverters - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1 SR 3.8.7.1 Verify correct inverter voltage, [frequency], and [ 7 days 2 alignment to required AC vital buses.

OR In accordance 3 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.7-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 497 of 638

Enclosure 2, Volume 13, Rev. 0, Page 498 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. ISTS SR 3.8.7.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.7.1 is "In accordance with the Surveillance Frequency Control Program."

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 498 of 638

Enclosure 2, Volume 13, Rev. 0, Page 499 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 499 of 638

Enclosure 2, Volume 13, Rev. 0, Page 500 of 638 Inverters - Operating B 3.8.7 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters are the preferred source of power for the AC vital buses INSERT 1 because of the stability and reliability they achieve. The function of the 1 inverter is to provide AC electrical power to the vital buses. The inverters ies can be powered from an internal AC source/rectifier or from the station battery. The station battery provides an uninterruptible power source for 1 the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Feature Actuation System (ESFAS). Specific details on inverters and their operating characteristics are found in the U FSAR, Chapter [8] (Ref. 1). 1 2 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 2) and Chapter [15] (Ref. 3), 1 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the RPS and ESFAS instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required AC vital buses OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC electrical power or all onsite AC electrical power and
b. A worst case single failure.

Inverters are a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverters ensure the availability of AC electrical power for the systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.7-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 500 of 638

Enclosure 2, Volume 13, Rev. 0, Page 501 of 638 B 3.8.7 1

INSERT 1 There are two unit inverters and one spare inverter per channel, each capable of supplying its associated AC vital buses, making a total of twelve inverters. Inverters 1-I and 2-I are connected to DC Channel I, inverters 1-II and 2-II are connected to DC Channel II, inverters 1-III and 2-III are connected to DC Channel III, and inverters 1-IV and 2-IV are connected to DC Channel IV. The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

Insert Page B 3.8.7-1 Enclosure 2, Volume 13, Rev. 0, Page 501 of 638

Enclosure 2, Volume 13, Rev. 0, Page 502 of 638 Inverters - Operating B 3.8.7 BASES LCO (continued) eight inverters (two per channel)

Maintaining the required inverters OPERABLE ensures that the redundancy incorporated into the design of the RPS and ESFAS instrumentation and controls is maintained. The four inverters [(two per 1 2 train)] ensure an uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. 1 480 volt OPERABLE inverters require the associated vital bus to be powered by the inverter with output voltage and frequency within tolerances, and power input to the inverter from a [125 VDC] station battery.

Alternatively, power supply may be from an internal AC source via rectifier as long as the station battery is available as the uninterruptible power supply.

This LCO is modified by a Note that allows [one/two] inverters to be 2 n

disconnected from a [common] battery for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if the vital bus(es) is powered from a [Class 1E constant voltage transformer or inverter 1

the remaining using internal AC source] during the period and all other inverters are required 3 operable. This allows an equalizing charge to be placed on one battery.

If the inverters were not disconnected, the resulting voltage condition might damage the inverter[s]. These provisions minimize the loss of equipment that would occur in the event of a loss of offsite power. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period for the allowance minimizes the time during which a loss of offsite power could result in the loss of equipment energized from the affected AC vital bus while taking into consideration the time required to perform an equalizing charge on the battery bank.

The intent of this Note is to limit the number of inverters that may be disconnected. Only those inverters associated with the single battery remaining required undergoing an equalizing charge may be disconnected. All other 1 inverters must be aligned to their associated batteries, regardless of the number of inverters or unit design.

APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown."

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.7-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 502 of 638

Enclosure 2, Volume 13, Rev. 0, Page 503 of 638 Inverters - Operating B 3.8.7 BASES ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant 2

voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized 1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

8 Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. [ The 7 day Frequency takes into account the redundant capability of the inverters 4 and other indications available in the control room that alert the operator to inverter malfunctions.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.7-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 503 of 638

Enclosure 2, Volume 13, Rev. 0, Page 504 of 638 Inverters - Operating B 3.8.7 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 4 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance 5 Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [8].

1 2

2. FSAR, Chapter [6].
3. FSAR, Chapter [15].

SEQUOYAH UNIT 1 Revision XXX 1

Westinghouse STS B 3.8.7-4 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 504 of 638

Enclosure 2, Volume 13, Rev. 0, Page 505 of 638 Inverters - Operating B 3.8.7 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters are the preferred source of power for the AC vital buses INSERT 1 because of the stability and reliability they achieve. The function of the 1 inverter is to provide AC electrical power to the vital buses. The inverters ies can be powered from an internal AC source/rectifier or from the station battery. The station battery provides an uninterruptible power source for 1 the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Feature Actuation System (ESFAS). Specific details on inverters and their operating characteristics are found in the U FSAR, Chapter [8] (Ref. 1). 1 2 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 2) and Chapter [15] (Ref. 3), 1 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the RPS and ESFAS instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required AC vital buses OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC electrical power or all onsite AC electrical power and
b. A worst case single failure.

Inverters are a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverters ensure the availability of AC electrical power for the systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.7-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 505 of 638

Enclosure 2, Volume 13, Rev. 0, Page 506 of 638 B 3.8.7 1

INSERT 1 There are two unit inverters and one spare inverter per channel, each capable of supplying its associated AC vital buses, making a total of twelve inverters. Inverters 1-I and 2-I are connected to DC Channel I, inverters 1-II and 2-II are connected to DC Channel II, inverters 1-III and 2-III are connected to DC Channel III, and inverters 1-IV and 2-IV are connected to DC Channel IV. The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

Insert Page B 3.8.7-1 Enclosure 2, Volume 13, Rev. 0, Page 506 of 638

Enclosure 2, Volume 13, Rev. 0, Page 507 of 638 Inverters - Operating B 3.8.7 BASES LCO (continued) eight inverters (two per channel)

Maintaining the required inverters OPERABLE ensures that the redundancy incorporated into the design of the RPS and ESFAS instrumentation and controls is maintained. The four inverters [(two per 1 2 train)] ensure an uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. 1 480 volt OPERABLE inverters require the associated vital bus to be powered by the inverter with output voltage and frequency within tolerances, and power input to the inverter from a [125 VDC] station battery.

Alternatively, power supply may be from an internal AC source via rectifier as long as the station battery is available as the uninterruptible power supply.

This LCO is modified by a Note that allows [one/two] inverters to be 2 n

disconnected from a [common] battery for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if the vital bus(es) is powered from a [Class 1E constant voltage transformer or inverter 1

the remaining using internal AC source] during the period and all other inverters are required 3 operable. This allows an equalizing charge to be placed on one battery.

If the inverters were not disconnected, the resulting voltage condition might damage the inverter[s]. These provisions minimize the loss of equipment that would occur in the event of a loss of offsite power. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period for the allowance minimizes the time during which a loss of offsite power could result in the loss of equipment energized from the affected AC vital bus while taking into consideration the time required to perform an equalizing charge on the battery bank.

The intent of this Note is to limit the number of inverters that may be disconnected. Only those inverters associated with the single battery remaining required undergoing an equalizing charge may be disconnected. All other 1 inverters must be aligned to their associated batteries, regardless of the number of inverters or unit design.

APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown."

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.7-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 507 of 638

Enclosure 2, Volume 13, Rev. 0, Page 508 of 638 Inverters - Operating B 3.8.7 BASES ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant 2

voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized 1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

8 Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. [ The 7 day Frequency takes into account the redundant capability of the inverters 4 and other indications available in the control room that alert the operator to inverter malfunctions.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.7-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 508 of 638

Enclosure 2, Volume 13, Rev. 0, Page 509 of 638 Inverters - Operating B 3.8.7 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 4 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance 5 Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [8].

1 2

2. FSAR, Chapter [6].
3. FSAR, Chapter [15].

SEQUOYAH UNIT 2 Revision XXX 1

Westinghouse STS B 3.8.7-4 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 509 of 638

Enclosure 2, Volume 13, Rev. 0, Page 510 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, INVERTERS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Editorial/grammar changes to the Bases have been made to enhance clarity.
4. ISTS SR 3.8.7.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.7.1 is "In accordance with the Surveillance Frequency Control Program.
5. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 510 of 638

Enclosure 2, Volume 13, Rev. 0, Page 511 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 511 of 638

Enclosure 2, Volume 13, Rev. 0, Page 512 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, INVERTERS - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 512 of 638

, Volume 13, Rev. 0, Page 513 of 638 ATTACHMENT 8 ITS 3.8.8, INVERTERS - SHUTDOWN , Volume 13, Rev. 0, Page 513 of 638

, Volume 13, Rev. 0, Page 514 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 514 of 638

Enclosure 2, Volume 13, Rev. 0, Page 515 of 638 ITS A01 ITS 3.8.8 ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN to support one train of the 120 V AC vital board electrical power distribution subsystem(s) required by A02 LCO 3.8.10, "Distribution Systems - Shutdown."

LIMITING CONDITION FOR OPERATION LCO 3.8.8 3.8.2.2 As a minimum, the following A.C. electrical boards and inverters shall be OPERABLE and See ITS energized: 3.8.10 2 - 6900 volt shutdown boards, either 1A-A and 2A-A or 1B-B and 2B-B, See ITS 3.8.10 4 - 480 volt shutdown boards associated with the required OPERABLE 6900 volt shutdown boards, See ITS 3.8.10 LCO 3.8.8 2 - 120 volt A.C. vital instrument power boards either Channels I and III or Channels II and IV energized from their respective inverters# connected to their respective D.C. battery banks*,

LA03 and 480 volt shutdown boards.

LA02 Applicability APPLICABILITY: MODES 5 and 6. L01

, During movement of irradiated fuel assemblies. M01 ACTION:

Add ACTIONS Note With less than the above complement of A.C. boards and inverters OPERABLE and energized, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See ITS 3.8.10 Add proposed Required Actions A.1, A.2, and A.3 L02 SURVEILLANCE REQUIREMENTS See ITS 3.8.10 SR 3.8.8.1 4.8.2.2 The specified A.C. boards and inverters shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the bus.

inverter voltage, frequency, and M02 in accordance with the Surveillance Frequency Control Program LA01

  • Any one of the inverters may be connected to D.C. Battery Bank V.

LA02

  1. The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

September 23, 1999 SEQUOYAH - UNIT 1 3/4 8-10 Amendment No. 37, 246 Page 1 of 2 Enclosure 2, Volume 13, Rev. 0, Page 515 of 638

Enclosure 2, Volume 13, Rev. 0, Page 516 of 638 ITS ITS 3.8.8 A01 ECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN to support one train of the 120 V AC vital board electrical power distribution subsystem(s) required by A02 LIMITING CONDITION FOR OPERATION LCO 3.8.10, "Distribution Systems - Shutdown."

LCO 3.8.8 3.8.2.2 As a minimum, the following A.C. electrical boards and inverters shall be OPERABLE and energized: See ITS 3.8.10 2 - 6900 volt shutdown boards, either 1A-A and 2A-A or 1B-B and 2B-B, See ITS 3.8.10 4 - 480 volt shutdown boards associated with the required OPERABLE 6900 volt shutdown boards, See ITS LCO 3.8.8 2 - 120 volt A.C. vital instrument power boards either Channels I and III or Channels II and IV 3.8.10 energized from their respective inverters# connected to their respective D.C. battery banks,*

and 480 volt shut-down boards. LA03 LA02 Applicability L01 APPLICABILITY: MODES 5 and 6. , During movement of irradiated fuel assemblies. M01 ACTION:

Add ACTIONS Note With less than the above complement of A.C. boards and inverters OPERABLE and energized, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See ITS 3.8.10 Add proposed Required Actions A.1, A.2, and A.3 L02 SR 3.8.8.1 SURVEILLANCE REQUIREMENTS See ITS 3.8.10 4.8.2.2 The specified A.C. boards and inverters shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the bus.

inverter voltage, frequency, and M02 in accordance with the Surveillance Frequency Control Program LA01

  • Any one of the inverters may be connected to D.C. Battery Bank V.

LA02

  1. The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

September 23, 1999 SEQUOYAH - UNIT 2 3/4 8-11 Amendment No. 29, 237 Page 2 of 2 Enclosure 2, Volume 13, Rev. 0, Page 516 of 638

Enclosure 2, Volume 13, Rev. 0, Page 517 of 638 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.2.2 requires, in part, two OPERABLE 120 V AC vital instrument boards (either Channels I and III or Channels II and IV) energized from their respective inverters connected to their respective DC battery banks and 480 V shutdown boards. (See DOC L01 for the discussion related to deleting the requirement for the inverters to be connected to 480 V shutdown boards. See DOC LA03 for the discussion related to moving the requirement for the inverters to be connected to their respective DC battery bank.) ITS 3.8.8 requires two inverters to be OPERABLE to support one train of the 120 V AC vital electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems -

Shutdown." This changes the CTS by providing a specific LCO for inverters.

The purpose of CTS 3.8.2.2 is to ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

The change is acceptable because ITS 3.8.8 maintains this purpose for the part associated with the inverters. No changes are made to CTS inverter requirements. The change is in format from CTS to ITS and maintains the inverters technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.2.2 is applicable in MODES 5 and 6. ITS LCO 3.8.8 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

This change is acceptable because the proposed requirements are necessary to ensure the inverters are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies. Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate distribution system requirements are specified during fuel handling and ensure the appropriate ACTIONS are taken (i.e. stop fuel movement) when the minimum Sequoyah Unit 1 and Unit 2 Page 1 of 5 Enclosure 2, Volume 13, Rev. 0, Page 517 of 638

Enclosure 2, Volume 13, Rev. 0, Page 518 of 638 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN electrical supply is not available. (See DOC L02 for the changes to the Required Actions). This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.8 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only in MODES 5 and 6.

M02 CTS 4.8.2.2 requires, in part, verification that the specified inverters are OPERABLE every 7 days by verifying correct breaker alignment. ITS SR 3.8.8.1 requires the verification of correct inverter voltage, frequency, and alignments to required AC vital boards. This changes the CTS by requiring the specific verification of the inverter voltage and frequency every 7 days.

The purpose of CTS 4.8.2.2 is to ensure the instrumentation channels are provided with the proper voltage and frequency when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters by verifying proper voltage and frequency are supplied to the instrumentation channels that provide inputs to the Reactor Trip System and Engineered Safety Features Actuation System. This change is designated as more restrictive because the ITS requires verification of the correct inverter voltage and frequency, where the CTS does not provide explicit requirements for the inverter.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.2.2 requires, in part, the specified inverters shall be determined OPERABLE once per seven days by verifying correct breaker alignment. ITS SR 3.8.8.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Sequoyah Unit 1 and Unit 2 Page 2 of 5 Enclosure 2, Volume 13, Rev. 0, Page 518 of 638

Enclosure 2, Volume 13, Rev. 0, Page 519 of 638 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.2 footnote # states, the spare inverter for the specified channel may be substituted for one of the two inverters of the same channel and CTS 3.8.2.2 footnote

  • states, any one of the inverters may be connected to the D.C. Battery Bank V. ITS 3.8.8 requires, in part, the inverters to be OPERABLE to support the onsite class 1E AC vital board electrical power distribution subsystem(s) required by LCO 3.8.10. This changes the CTS by moving this level of detail information into the ITS Bases. Note that ITS 3.8.8 Bases refers to the Bases for LCO 3.8.7, "Inverters - Operating," where this level of detail is located.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.2 states, in part, two 120 volt A.C. vital instrument power boards either Channel I and III or Channels II and IV energized from their respective inverters connected to their respective D.C. battery banks. ITS 3.8.8, LCO states that two inverters shall be OPERABLE to support one train of the 120 V AC vital board electrical power distribution subsystem required by LCO 3.8.10, "Distribution Systems - Shutdown." This changes the CTS by moving this level of detail information into the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change Sequoyah Unit 1 and Unit 2 Page 3 of 5 Enclosure 2, Volume 13, Rev. 0, Page 519 of 638

Enclosure 2, Volume 13, Rev. 0, Page 520 of 638 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.2.2 requires, in part, two OPERABLE inverters that are connected to their respective DC battery banks and 480 volt shutdown boards in MODES 5 and 6. ITS 3.8.8 requires two OPERABLE inverters in MODES 5 and 6 and during the movement of irradiated fuel assemblies. (See DOC LA03 for the discussion related to moving the details regarding the inverters being connected to their respective DC battery banks.

See DOC M01 for the discussion related to changes in the Applicability.) This changes the CTS by deleting the requirement that the inverters be connected to the 480 volt shutdown boards.

The purpose of CTS 3.8.2.2 is to ensure the availability of vital AC electrical power for the instrumentation associated with systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. CTS 3.8.2.1 provides the requirements for the 120 V AC vital boards and associated inverters in MODES 1, 2, 3 and 4 and specifies that an OPERABLE inverter is connected to its respective DC channel. Furthermore, CTS 3.8.2.1 Note

  • specifies that two inverters may be disconnected from their DC source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the performance of an equalizing charge on the associated battery bank provided the instrument power board is OPERABLE and energized, and the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to their respective DC source. There are no special operations associated with MODES 5 and 6 that would require 480 V AC power to be connected to the required inverters to ensure their OPERABILITY. The requirements of ITS 3.8.5 will continue to require one train of vital DC electrical power to be OPERABLE to support the required subsystems of the distribution systems required to be OPERABLE by ITS 3.8.10, "Distribution Systems - Shutdown," in MODES 5 and 6 and during the movement of irradiated fuel assemblies. Therefore, the inverter required power source, as specified for operation in MODES 1, 2, 3 and 4, will be reflected as the required power source for inverter OPERABILITY in MODES 5 and 6 and during the movement of irradiated fuel assemblies. This change is designated as less restrictive because less stringent requirements are being applied in ITS than were applied in CTS.

L02 (Category 4 - Relaxation of Required Action) With less than the minimum required inverters OPERABLE, CTS 3.8.2.2 Action requires the establishment of containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.8 ACTION A requires suspending movement of irradiated fuel assemblies, suspending operations involving a positive reactivity addition that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore required inverters to OPERABLE status. This changes the CTS by replacing the existing Required Sequoyah Unit 1 and Unit 2 Page 4 of 5 Enclosure 2, Volume 13, Rev. 0, Page 520 of 638

Enclosure 2, Volume 13, Rev. 0, Page 521 of 638 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN Action to restore containment integrity with Actions that will minimize the probability of occurrence of postulated events.

The purpose of the CTS 3.8.2.2 Action is to isolate the containment to minimize any release from the plant if an event were to occur during shutdown conditions with no inverters OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The purposed Required Actions require the suspension of movement of irradiated fuel assemblies, suspension of operations involving a positive reactivity additions that could result in the loss of required SDM or boron concentration, and the initiation of actions to restore required inverter(s) to OPERABLE status. Suspending the movement of irradiated fuel assemblies will prevent a fuel handling accident from occurring and suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit will ensure the reactor remains subcritical. The actions to restore the required inverter(s) to OPERABLE status will ensure the plant is placed in compliance with the LCO in an expeditious manner. The proposed actions will immediately minimize the potential for any accident releases outside of the containment and are considered acceptable in lieu of the current action to restore containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The actions may be considered somewhat more restrictive since immediate action is required, however, is classified as less restrictive since the current action to restore containment integrity has been deleted. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 5 of 5 Enclosure 2, Volume 13, Rev. 0, Page 521 of 638

Enclosure 2, Volume 13, Rev. 0, Page 522 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 522 of 638

Enclosure 2, Volume 13, Rev. 0, Page 523 of 638 CTS Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown 3.8.2.2 LCO 3.8.8 [Inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."] 1 to support one train of the 120 V AC vital board Two electrical power distribution subsystem(s) required

[One] inverter[s] shall be OPERABLE.] by LCO 3.8.10, "Distribution Systems - Shutdown."


REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"

2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 1 ACTIONS


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

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME DOC M03 A. One [or more] [required] A.1 Declare affected required Immediately 3 inverter[s] inoperable. feature(s) inoperable.

1 OR DOC L02 A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 3 A.1 assemblies.

AND SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.8-1 Rev. 4.0 4 Enclosure 2, Volume 13, Rev. 0, Page 523 of 638

Enclosure 2, Volume 13, Rev. 0, Page 524 of 638 CTS Inverters - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3

DOC L02 A.2.2 Suspend operations Immediately A.2 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.3 Initiate action to restore Immediately 3 A.3 required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.2 SR 3.8.8.1 Verify correct inverter voltage, [frequency,] and [ 7 days 1 DOC M02 alignments to required AC vital buses. 2 boards OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.8-2 Rev. 4.0 4 Enclosure 2, Volume 13, Rev. 0, Page 524 of 638

Enclosure 2, Volume 13, Rev. 0, Page 525 of 638 CTS Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown 3.8.2.2 LCO 3.8.8 [Inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."] 1 to support one train of the 120 V AC vital board Two electrical power distribution subsystem(s) required

[One] inverter[s] shall be OPERABLE.] by LCO 3.8.10, "Distribution Systems - Shutdown."


REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"

2 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 1 ACTIONS


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

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME DOC M03 A. One [or more] [required] A.1 Declare affected required Immediately 3 inverter[s] inoperable. feature(s) inoperable.

1 OR DOC L02 A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 3 A.1 assemblies.

AND SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.8-1 Rev. 4.0 4 Enclosure 2, Volume 13, Rev. 0, Page 525 of 638

Enclosure 2, Volume 13, Rev. 0, Page 526 of 638 CTS Inverters - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3

DOC L02 A.2.2 Suspend operations Immediately A.2 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.3 Initiate action to restore Immediately 3 A.3 required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.2 SR 3.8.8.1 Verify correct inverter voltage, [frequency,] and [ 7 days 1 DOC M02 alignments to required AC vital buses. 2 boards OR In accordance 5 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.8-2 Rev. 4.0 4 Enclosure 2, Volume 13, Rev. 0, Page 526 of 638

Enclosure 2, Volume 13, Rev. 0, Page 527 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, INVERTERS - SHUTDOWN

1. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
3. ISTS 3.8.8 Required Action A.1 provides an option to declare affected required feature(s) inoperable with one or more required inverters inoperable. The ISTS Bases states this is acceptable because the remaining inverters may be capable of supporting sufficient features to allow continued fuel movement. This option has been deleted since only one train of inverters is required to be OPERABLE in MODES 5 and 6, and during the movement of irradiated fuel assemblies.

Subsequent Required Actions have been renumbered and modified, as applicable.

4. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
5. ISTS SR 3.8.8.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.8.1 is "In accordance with the Surveillance Frequency Control Program."

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 527 of 638

Enclosure 2, Volume 13, Rev. 0, Page 528 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 528 of 638

Enclosure 2, Volume 13, Rev. 0, Page 529 of 638 Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY U analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

board The OPERABILITY of the minimum inverters to each AC vital bus during 1 MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, the AC and DC inverters are only required to mitigate fuel handling accidents 2 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in 2 MODES [5 and 6] because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being SEQUOYAH UNIT 1 Amendment XXX 1

Westinghouse STS B 3.8.8-1 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 529 of 638

Enclosure 2, Volume 13, Rev. 0, Page 530 of 638 Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverter[s] ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence an or a postulated DBA. The battery powered inverter[s] provide[s] boards 480 volt shutdown boards uninterruptible supply of AC electrical power to the AC vital bus[es] even if the 4.16 kV safety buses are de-energized. OPERABILITY of the an 1 each required inverter[s] requires that the AC vital bus be powered by the inverter. This 2 1 vital board is ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling recently irradiated fuel]).

APPLICABILITY The inverter[s] required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available, SEQUOYAH UNIT 1 Amendment XXX 1

Westinghouse STS B 3.8.8-2 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 530 of 638

Enclosure 2, Volume 13, Rev. 0, Page 531 of 638 Inverters - Shutdown B 3.8.8 BASES APPLICABILITY (continued)

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2 and A.3 A.1, A.2.1, A.2.2, and A.2.3

[If two trains are required by LCO 3.8.10, "Distribution Systems -

Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of [recently] 2 irradiated fuel movement, and operations with a potential for positive reactivity additions.] By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required 1 features LCOs' Required Actions. In many instances, this option may INSERT 1 involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of

[recently] irradiated fuel assemblies, and operations involving positive 2 reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

SEQUOYAH UNIT 1 Amendment XXX 1

Westinghouse STS B 3.8.8-3 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 531 of 638

Enclosure 2, Volume 13, Rev. 0, Page 532 of 638 1

INSERT 1 With one or more required inverters inoperable, the minimum required vital AC electrical power source is not available.

Insert Page B 3.8.8-3 Enclosure 2, Volume 13, Rev. 0, Page 532 of 638

Enclosure 2, Volume 13, Rev. 0, Page 533 of 638 Inverters - Shutdown B 3.8.8 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverter[s] and to 2 continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with boards 1 all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation boards connected to the AC vital buses. [ The 7 day Frequency takes into 1 account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter 3 malfunctions.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

REFERENCES U

1. FSAR, Chapter [6].

1 2 U 2. FSAR, Chapter [15].

SEQUOYAH UNIT 1 Amendment XXX 1

Westinghouse STS B 3.8.8-4 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 533 of 638

Enclosure 2, Volume 13, Rev. 0, Page 534 of 638 Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY U analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

board The OPERABILITY of the minimum inverters to each AC vital bus during 1 MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, the AC and DC inverters are only required to mitigate fuel handling accidents 2 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in 2 MODES [5 and 6] because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being SEQUOYAH UNIT 2 Amendment XXX 1

Westinghouse STS B 3.8.8-1 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 534 of 638

Enclosure 2, Volume 13, Rev. 0, Page 535 of 638 Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverter[s] ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence an or a postulated DBA. The battery powered inverter[s] provide[s] boards 480 volt shutdown boards uninterruptible supply of AC electrical power to the AC vital bus[es] even if the 4.16 kV safety buses are de-energized. OPERABILITY of the an 1 each required inverter[s] requires that the AC vital bus be powered by the inverter. This 2 1 vital board is ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling recently irradiated fuel]).

APPLICABILITY The inverter[s] required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available, SEQUOYAH UNIT 2 Amendment XXX 1

Westinghouse STS B 3.8.8-2 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 535 of 638

Enclosure 2, Volume 13, Rev. 0, Page 536 of 638 Inverters - Shutdown B 3.8.8 BASES APPLICABILITY (continued)

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2 and A.3 A.1, A.2.1, A.2.2, and A.2.3

[If two trains are required by LCO 3.8.10, "Distribution Systems -

Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of [recently] 2 irradiated fuel movement, and operations with a potential for positive reactivity additions.] By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required 1 features LCOs' Required Actions. In many instances, this option may INSERT 1 involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of

[recently] irradiated fuel assemblies, and operations involving positive 2 reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

SEQUOYAH UNIT 2 Amendment XXX 1

Westinghouse STS B 3.8.8-3 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 536 of 638

Enclosure 2, Volume 13, Rev. 0, Page 537 of 638 1

INSERT 1 With one or more required inverters inoperable, the minimum required vital AC electrical power source is not available.

Insert Page B 3.8.8-3 Enclosure 2, Volume 13, Rev. 0, Page 537 of 638

Enclosure 2, Volume 13, Rev. 0, Page 538 of 638 Inverters - Shutdown B 3.8.8 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverter[s] and to 2 continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with boards 1 all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation boards connected to the AC vital buses. [ The 7 day Frequency takes into 1 account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter 3 malfunctions.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

REFERENCES U

1. FSAR, Chapter [6].

1 2 U 2. FSAR, Chapter [15].

SEQUOYAH UNIT 2 Amendment XXX 1

Westinghouse STS B 3.8.8-4 Rev. 4.0 Enclosure 2, Volume 13, Rev. 0, Page 538 of 638

Enclosure 2, Volume 13, Rev. 0, Page 539 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, INVERTERS - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. ISTS SR 3.8.8.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.8.1 is "In accordance with the Surveillance Frequency Control Program."
4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 539 of 638

Enclosure 2, Volume 13, Rev. 0, Page 540 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 540 of 638

Enclosure 2, Volume 13, Rev. 0, Page 541 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, INVERTERS - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 541 of 638

Enclosure 2, Volume 13, Rev. 0, Page 542 of 638 ATTACHMENT 9 ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Enclosure 2, Volume 13, Rev. 0, Page 542 of 638

, Volume 13, Rev. 0, Page 543 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 543 of 638

Enclosure 2, Volume 13, Rev. 0, Page 544 of 638 ITS A01 ITS 3.8.9 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.9 L01 LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

See ITS

a. Two physically independent circuits between the offsite transmission 3.8.1 network and the onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with:

LA01

1. Two diesels driving a common generator See ITS
2. Two engine-mounted fuel tanks containing a minimum volume of 3.8.1 250 gallons of fuel, per tank
3. A separate fuel storage system containing a minimum volume of See ITS 62,000 gallons of fuel, 3.8.3 See ITS
4. A separate fuel transfer pump, and 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C.

LA01 battery bank and associated charger.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4. See ITS

3.8.4 ACTION

Add proposed ACTION E A02

a. With one offsite A.C. circuit of the above required A.C. electrical power source inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. See ITS 3.8.1

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 1 3/4 8-1 Amendment No. 100, 132, 137, 205, 241, 332 Page 1 of 9 Enclosure 2, Volume 13, Rev. 0, Page 544 of 638

Enclosure 2, Volume 13, Rev. 0, Page 545 of 638 ITS A01 ITS 3.8.9 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage See ITS and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 3.8.1 61.2 Hz during this test.

4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes. After energization, the steady state voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. See ITS 3.8.4 and SR 3.8.9.1 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for 3.8.6 each diesel generator shall be demonstrated OPERABLE:
a. At least once per 7 days by verifying:

See ITS

1. That the parameters in Table 4.8-1a meet the Category A limits. 3.8.4 and 3.8.6
2. That the total battery terminal voltage is greater than or equal to 124-volts on float charge.
b. At least once per 92 days by:
1. Verifying that the parameters in Table 4.8-1a meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to 6

terminal connection resistance of these items is less than 150 x 10- ohms, and

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

See ITS

c. At least once per 18 months by verifying that: 3.8.6
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.

6

3. The resistance of each cell to terminal connection is less than or equal to 150 x 10-ohms. M01 Add proposed SR 3.8.9.1 with a Frequency of 7 days 4.8.1.1.4 This surveillance has been deleted.

In accordance with the Surveillance Frequency Control Program LA02 December 16, 1998 SEQUOYAH - UNIT 1 3/4 8-6 Amendment Nos. 52, 137, 173, 213, 234, 241 Page 2 of 9 Enclosure 2, Volume 13, Rev. 0, Page 545 of 638

Enclosure 2, Volume 13, Rev. 0, Page 546 of 638 ITS A01 ITS 3.8.9 ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.9 3.8.2.1 The following A.C. electrical boards shall be OPERABLE and energized with tie breakers open LA03 between redundant boards:

6900 Volt Shutdown Board 1A-A 6900 Volt Shutdown Board 1B-B 6900 Volt Shutdown Board 2A-A 6900 Volt Shutdown Board 2B-B 480 Volt Shutdown Board 1A1-A 480 Volt Shutdown Board 1A2-A LA01 480 Volt Shutdown Board 1B1-B 480 Volt Shutdown Board 1B2-B 480 Volt Shutdown Board 2A1-A 480 Volt Shutdown Board 2A2-A 480 Volt Shutdown Board 2B1-B 480 Volt Shutdown Board 2B2-B See ITS 120 Volt A.C. Vital Instrument Power Board Channels 1-I and 2-I energized from inverters 1-I and 2-I 3.8.7 connected to D.C. Channel I*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-II and 2-II energized from inverters 1-II and 2-II connected to D.C. Channel II*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-III and 2-III energized from inverters 1-III and 2-III connected to D.C. Channel III*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-IV and 2-IV energized from inverters 1-IV and 2-IV connected to D.C. Channel IV*#@.

Applicability APPLICABILITY: MODES 1, 2, 3 and 4. Add proposed Required Action A Note A03 ACTIONS ACTION:

Unit 1 L01 ACTION A a. With less than the above complement of A.C. boards OPERABLE and energized, ACTION B restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY ACTION F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTION D L01

b. With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; See ITS restore the inoperable inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 3.8.7 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTION G M02 SURVEILLANCE REQUIREMENTS See ITS SR 3.8.9.1 4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie 3.8.7 breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. In accordance with the Surveillance Frequency Control Program LA03

  • Two inverters may be disconnected from their D.C. source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the purpose of performing an equalizing charge on their associated battery bank provided (1) the vital instrument LA02 power board is OPERABLE and energized, and (2) the vital instrument power boards associated with the other battery banks are OPERABLE and energized from their respective inverters connected to See ITS 3.8.7 their respective D.C. source.
  1. D.C. Channel V may be substituted for any one channel of channels I-IV. LA04

@ The spare inverter for a specified channel may be substituted for one of the two inverters of the same See ITS channel. 3.8.7 September 23, 1999 SEQUOYAH - UNIT 1 3/4 8-9 Amendment No. 37, 246 Page 3 of 9 Enclosure 2, Volume 13, Rev. 0, Page 546 of 638

Enclosure 2, Volume 13, Rev. 0, Page 547 of 638 ITS A01 ITS 3.8.9 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTI0N - OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.9 3.8.2.3 The following D.C. vital battery channels shall be energized and OPERABLE:

LA01 CHANNEL I Consisting of 125 - volt D.C. board No. I, 125 - volt D.C.

battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

battery bank No. II*, and a full capacity charger.

CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D.C.

battery bank No. IV*, and a full capacity charger.

See ITS 3.8.4 Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTIONS ACTION:

ACTION C

a. With one 125-volt D.C. board inoperable, restore the inoperable board to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION F SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one 125-volt D.C. battery bank and/or its charger inoperable, restore the inoperable See ITS battery bank and/or charger to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT 3.8.4 STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed. 3.8.4 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-11 Amendment No. 37 Page 4 of 9 Enclosure 2, Volume 13, Rev. 0, Page 547 of 638

Enclosure 2, Volume 13, Rev. 0, Page 548 of 638 ITS A01 ITS 3.8.9 ELECTRICAL POWER SYSTEMS In accordance with the Surveillance Frequency Control Program LA02 SURVEILLANCE REQUIREMENTS LA03 SR 3.8.9.1 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open See ITS between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated 3.8.4 power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts. LA05 4.8.2.3.2* Each 125-volt battery bank and charger shall be demonstrated OPERABLE: See ITS 3.8.4 and 3.8.6

a. At least once per 7 days by:

See ITS

1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and 3.8.6
2. Verifying total battery terminal voltage is greater than or equal to 129-volts on float See ITS charge. 3.8.4
b. At least once per 92 days and within 7 days after a battery discharge (battery terminal voltage below 110-volts), or battery overcharge (battery terminal voltage above 150-volts), by:
1. Verifying that the parameters in Table 4.8-2 meet the Category B limits, See ITS 3.8.6
2. Verifying there is no visible corrosion at either terminals or connectors, or the

-6 connection resistance of these items is less than 150 x 10 ohms, and

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.
c. At least once per 18 months by verifying that:
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, See ITS
2. The cell-to-cell and terminal connections are clean, tight and coated with anti- 3.8.6 corrosion material,

-6

3. The resistance of each cell-to-terminal connection is less than or equal to 150 x 10 ohms, and See ITS
4. The battery charger will supply at least 150 amperes at 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 3.8.4 See ITS
  • This surveillance includes Battery Bank V, but not charger V. 3.8.4 October 4, 1995 SEQUOYAH - UNIT 1 3/4 8-12 Amendment No. 37, 213 Page 5 of 9 Enclosure 2, Volume 13, Rev. 0, Page 548 of 638

Enclosure 2, Volume 13, Rev. 0, Page 549 of 638 ITS ITS 3.8.9 A01 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION Add proposed LCO 3.8.9 L01 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

See ITS

a. Two physically independent circuits between the offsite transmission network and the 3.8.1 onsite Class 1E distribution system@, and
b. Four separate and independent diesel generator sets each with:

LA01

1. Two diesels driving a common generator See ITS
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel, 3.8.1 per tank
3. A separate fuel storage system containing a minimum volume of 62,000 gallons of See ITS fuel, 3.8.3
4. A separate fuel transfer pump, and See ITS 3.8.1
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger. LA01 See ITS Applicability APPLICABILITY: MODES 1, 2, 3 and 4. 3.8.4 ACTION:

Add proposed ACTION E A02

a. With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.# With diesel generator set(s) 1A-A and/or 2A-A or 1B-B and/or 2B-B of the above required A.C. electrical power sources inoperable,* demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and determining OPERABLE diesel generator sets are not inoperable due to common cause failure or performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; restore at least four diesel generator sets to OPERABLE See ITS 3.8.1 status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  1. Required actions, to verify OPERABLE diesel generator sets are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.4, shall be completed if this action is entered.
  • No more than one diesel generator may be made simultaneously inoperable on a pre-planned basis for maintenance, modifications, or surveillance testing.

@ Offsite circuits utilizing USST 2A and USST 2B as the normal power sources require CSST A and CSST C to be available as the alternate power sources via automatic transfer at the associated 6.9 kV Unit Boards. (CSST B can be substituted for CSST A or CSST C.) This Note remains in effect until November 30, 2013, or until the USST modifications are implemented on Units 1 and 2, whichever occurs first.

October 31, 2012 SEQUOYAH - UNIT 2 3/4 8-1 Amendment No. 89, 119, 123, 195, 231, 325 Page 6 of 9 Enclosure 2, Volume 13, Rev. 0, Page 549 of 638

Enclosure 2, Volume 13, Rev. 0, Page 550 of 638 ITS ITS 3.8.9 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of this test, the diesel generator shall be loaded between 4620 kw and 4840 kw and between 2380 kvar and 2600 kvar and during the remaining hours of this test, the diesel generator shall be loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar.

The generator voltage and frequency shall be 6800 volts and 58.8 Hz within 10 seconds after the start signal. After energization, the steady state generator voltage and See ITS frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz 3.8.1 during this test.

4. Within 5 minutes of shutting down the diesel generator after it has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded between 3960 kw and 4400 kw and between 2140 kvar and 2370 kvar, verify that the diesel generator starts within 10 seconds after receipt of the start signal and operates for greater than or equal to 5 minutes. After energization, the steady state voltage and frequency shall be maintained 6800 volts and 7260 volts and 58.8 Hz and 61.2 Hz during this test. See ITS 3.8.4 and SR 3.8.9.1 4.8.1.1.3 The 125-volt D.C. distribution panel, 125-volt D.C. battery bank and associated charger for 3.8.6 each diesel generator shall be demonstrated OPERABLE:
a. At least once per 7 days by verifying:

See ITS

1. That the parameters in Table 4.8-1a meet the Category A limits. 3.8.4 and 3.8.6
2. That the total battery terminal voltage is greater than or equal to 124 volts on float charge.
b. At least once per 92 days by:
1. Verifying that the parameters in Table 4.8-1a meet the Category B limits,
2. Verifying there is no visible corrosion at either terminals or connectors, or the cell to

-6 terminal connection resistance of these items is less than 150 x 10 ohms, and

3. Verifying that the average electrolyte temperature of 6 connected cells is above 60°F.
c. At least once per 18 months by verifying that: See ITS 3.8.6
1. The cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration.
2. The battery to battery and terminal connections are clean, tight and coated with anti-corrosion material.
3. The resistance of each cell to terminal connection is less than or equal to 150 x

-6 10 ohms. M01 Add proposed SR 3.8.9.1 with a Frequency of 7 days In accordance with the Surveillance Frequency Control Program LA02 July 22, 1998 SEQUOYAH - UNIT 2 3/4 8-6 Amendment No. 8, 56, 164, 203, 224 Page 7 of 9 Enclosure 2, Volume 13, Rev. 0, Page 550 of 638

Enclosure 2, Volume 13, Rev. 0, Page 551 of 638 ITS ITS 3.8.9 A01 ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.9 3.8.2.1 The following A.C. electrical boards and inverters shall be OPERABLE and energized with tie LA03 breakers open between redundant boards:

6900 Volt Shutdown Board 1A-A 6900 Volt Shutdown Board 1B-B 6900 Volt Shutdown Board 2A-A 6900 Volt Shutdown Board 2B-B 480 Volt Shutdown Board 1A1-A 480 Volt Shutdown Board 1A2-A 480 Volt Shutdown Board 1B1-B LA01 480 Volt Shutdown Board 1B2-B 480 Volt Shutdown Board 2A1-A 480 Volt Shutdown Board 2A2-A 480 Volt Shutdown Board 2B1-B 480 Volt Shutdown Board 2B2-B See ITS 120 Volt A.C. Vital Instrument Power Board Channels 1-I and 2-I 3.8.7 energized from inverters 1-I and 2-I connected to D.C. Channel I*#@.

120 Volt A.C. Vital Instrument Power Board Channels 1-II and 2-II energized from inverter 1-II and 2-II connected to D.C. Channel II*#@.

120 Volt A.C. Vital Instrument Power Board Channels l-III and 2-III energized from inverter 1-III and 2-III connected to D.C. Channel III*#@.

120 Volt A.C. Vital Instrument Power Board Channels l-IV and 2-IV energized from inverter 1-IV and 2-IV connected to D.C. Channel IV*#@.

A03 Applicability APPLICABILITY: MODES 1, 2, 3 and 4. Add proposed Required Action A Note ACTIONS ACTION: Unit 2 L01 ACTION A

a. With less than the above complement of A.C. boards OPERABLE and energized, restore the ACTION B inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the ACTION F next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTION D L01 With one inverter inoperable, energize the associated Vital Instrument Power Board within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />;

b. See ITS restore the inoperable inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT 3.8.7 STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Add proposed ACTION G M02 SURVEILLANCE REQUIREMENTS See ITS 3.8.7 SR 3.8.9.1 4.8.2.1 The specified A.C. boards and inverters shall be determined OPERABLE and energized with tie breakers open between redundant boards at least once per 7 days by verifying correct breaker alignment LA03 and indicated voltage on the busses. In accordance with the Surveillance Frequency Control Program

  • Two inverters may be disconnected from their D.C. source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the purpose of LA02 performing an equalizing charge on their associated battery bank provided (1) the vital instrument power board is OPERABLE and energized, and (2) the vital instrument power boards associated with See ITS 3.8.7 the other battery banks are OPERABLE and energized from their respective inverters connected to their respective D.C. sources.
  1. D.C. Channel V may be substituted for any one channel of channels I - IV. LA04

@ The spare inverter for a specified channel may be substituted for one of the two inverters of the same See ITS channel. 3.8.7 September 23, 1999 SEQUOYAH - UNIT 2 3/4 8-10 Amendment No. 29, 237 Page 8 of 9 Enclosure 2, Volume 13, Rev. 0, Page 551 of 638

Enclosure 2, Volume 13, Rev. 0, Page 552 of 638 ITS ITS 3.8.9 A01 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.9 3.8.2.3 The following D.C. vital battery channels shall be OPERABLE and energized:

LA01 CHANNEL I Consisting of 125 -volt D.C. board No. I, 125 - volt D.C. battery bank No. I* and a full capacity charger.

CHANNEL II Consisting of 125 - volt D.C. board No. II, 125 - volt D.C.

battery bank No. II*, and a full capacity charger.

CHANNEL III Consisting of 125 - volt D.C. board No. III, 125 - volt D.C.

battery bank No. III*, and a full capacity charger.

CHANNEL IV Consisting of 125 - volt D.C. board No. IV, 125 - volt D. C.

battery bank No. IV*, and a full capacity charger.

See ITS 3.8.4 Applicability APPLICABILITY: MODES 1, 2, 3 and 4.

ACTIONS ACTION:

a. With one 125-volt D.C. board inoperable or not energized, restore the inoperable board to ACTION C OPERABLE and energized status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the ACTION F next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one 125-volt D.C. battery bank and/or its charger inoperable or not energized, restore the inoperable battery bank and/or charger to OPERABLE and energized status within See ITS 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN 3.8.4 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS LA02 In accordance with the Surveillance Frequency Control Program SR 3.8.9.1 4.8.2.3.1 Each D.C. bus train shall be determined OPERABLE and energized with tie breakers open between redundant busses at least once per 7 days by verifying correct breaker alignment, indicated LA03 power availability from the charger and battery, and voltage on the bus of greater than or equal to 125 volts. See ITS 3.8.4 4.8.2.3.2** Each 125-volt battery bank and charger shall be demonstrated OPERABLE: LA05

a. At least once per 7 days by: See ITS 3.8.4 and 3.8.6
1. Verifying that the parameters in Table 4.8-2 meet the Category A limits, and
  • D.C. Battery Bank V may be substituted for any other Battery Bank as needed. See ITS
    • This surveillance includes Battery Bank V, but not Charger V. 3.8.4 January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-12 Amendment No. 29 Page 9 of 9 Enclosure 2, Volume 13, Rev. 0, Page 552 of 638

Enclosure 2, Volume 13, Rev. 0, Page 553 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS does not contain specific ACTIONS for the condition where a diesel generator (DG) DC distribution subsystem is inoperable. However, the CTS definition of OPERABLE-OPERABILITY, CTS 1.19, states, in part, that a system, subsystem, train, or component or device shall be OPERABLE or have OPERABILITY when all necessary auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s). ITS 3.8.9, ACTION E specifically states that when a DG DC distribution subsystem is inoperable to declare the associated DG inoperable immediately. This changes the CTS by specifically stating the CTS 1.19 requirement in ITS LCO 3.8.9.

The purpose of ITS 3.8.9 is to ensure the necessary AC, vital DC, DG DC, and AC vital electrical power distribution subsystems are available to provide emergency electrical power to ensure the fuel, Reactor Coolant System (RCS),

and containment design limits are not exceeded and to mitigate postulated events. The change is acceptable since it is consistent with the requirements in CTS 1.19 that all attendant equipment must be capable of performing its related support function to support a required feature. Although not explicitly stated in CTS, this action is always applied due to the application of CTS 1.19. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.2.1 ACTION a states, in part, that with less than the above complement of AC boards OPERABLE and energized, to restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the associated unit's AC electrical power distribution subsystem(s) to OPERABLE status. In addition, Required Action A.1 includes a Note that requires entry into applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating," for vital DC Sources made inoperable by inoperable power distribution subsystems. This changes the CTS by explicitly requiring the compensatory actions for DC Sources to be taken if made inoperable by inoperable power distribution subsystems. The discussion for limiting the Required Actions to the associated unit's AC boards is contained in DOC L01.

This change is acceptable because no changes are made to CTS requirements.

The change in format from the CTS to the ITS maintains the technical requirements. The addition of the Note only acts as a reminder to enter the appropriate actions if the emergency bus which supplies the Train A or Train B Sequoyah Unit 1 and Unit 2 Page 1 of 7 Enclosure 2, Volume 13, Rev. 0, Page 553 of 638

Enclosure 2, Volume 13, Rev. 0, Page 554 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING battery charger becomes de-energized. In the event an emergency board is inoperable such that a Train A or Train B battery charger were inoperable, ITS LCO 3.0.6 would allow taking only the Distribution System - Operating ACTIONS; taking exception to complying with the DC Sources - Operating ACTIONS. Since the Distribution System - Operating ACTIONS may not be sufficiently conservative in this event (i.e., a battery charger may be without power), specific direction to take appropriate ACTIONS for the DC Sources - Operating is added (ITS 3.8.9, Note to ACTION A) when there is no power to support the associated required battery charger. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 4.8.1.1.3 requires, in part, that the 125 volt DC distribution panel for each DG be demonstrated OPERABLE. ITS SR 3.8.9.1 requires, in part, verifying correct breaker alignments and voltage to the 125 volt DC distribution subsystem for each DG. This changes the CTS by requiring correct breaker alignment verification and correct voltage for the DG DC bus electrical power distribution subsystem.

The purpose of CTS 4.8.1.1.3 is to provide assurance that necessary power to required supported systems is available with sufficient capacity, capability, redundancy, and reliability to ensure the fuel, RCS, and containment design limits are not exceeded and postulated accidents are mitigated. This change is acceptable because it provides additional assurance that the panels associated with the DG DC bus electrical power distribution subsystem are OPERABLE.

This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS for verification of correct breaker alignment and voltage.

M02 CTS 3.8.2.1 ACTION a states that with less than the above complement of AC boards OPERABLE and energized, to restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. CTS 3.8.2.3 ACTION a states that with one 125 volt DC board inoperable, to restore the inoperable boards to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. However, there are no limitations to preclude a loss of function due to numerous concurrently inoperable AC and DC boards. ITS 3.8.9 ACTION G has been added, requiring entry into ITS 3.0.3 if the loss of two or more required electrical power distribution subsystems result in a loss of safety function. This changes CTS by adding an explicit Action to enter LCO 3.0.3 for a loss of two or more electrical power distribution subsystems that result in a loss of safety function.

The purpose of the CTS ACTIONS is to limit the time the unit can operate under these conditions. CTS 3.8.2.3 ACTION a specifies the compensatory actions for one inoperable DC board. With two inoperable DC boards, CTS 3.8.2.3 does not provide any actions and entry into LCO 3.0.3 would be required. CTS 3.8.2.1 ACTION a is applicable to all inoperable AC boards even if there is a loss of safety function. Certain combinations of inoperable AC and DC electrical power distribution subsystems result in a loss of safety function (e.g., an inoperable Train A AC electrical power distribution subsystem in combination with an Sequoyah Unit 1 and Unit 2 Page 2 of 7 Enclosure 2, Volume 13, Rev. 0, Page 554 of 638

Enclosure 2, Volume 13, Rev. 0, Page 555 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING inoperable Train B vital DC electrical power distribution subsystem). ITS 3.8.9 includes ACTION G, which requires immediate entry into LCO 3.0.3 if the loss of one or more required electrical power distribution subsystems boards results in a loss of safety function. ITS 3.8.9 Required Action G.1 preserves the intent of ITS LCO 3.0.3 and reflects an additional restriction on plant operation. This change is designated as more restrictive because an explicit action has been added which requires entry into LCO 3.0.3 with any combination of required AC and/or DC boards inoperable that results in a loss of safety function.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.3.b.5 requires, in part, a separate 125 volt DC distribution panel to be OPERABLE for each DG. CTS 3.8.2.1 requires, in part, the AC electrical boards to be OPERABLE and lists the specific AC shutdown boards and AC vital instrument power board channels, including the applicable nominal voltage. CTS 3.8.2.3 requires, in part, vital DC boards to be OPERABLE and lists the specific boards and includes the nominal voltage. ITS LCO 3.8.9 requires the applicable electrical power distribution subsystems to be OPERABLE. This changes the CTS by moving the specific names of the buses and the associated nominal bus voltages (i.e., 6900 V, 480 V, 125 V, and 120 V) from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required distribution subsystems to be OPERABLE. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases, requiring an evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.1.1.3 requires, in part, verification that the 125 volt DC distribution panel for each diesel generator is demonstrated OPERABLE.

CTS 4.8.2.1 requires, in part, the specified AC boards to be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. CTS 4.8.2.3.1 requires, in part, each DC bus train to be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment, indicated power availability from the charger and battery, and voltage on the bus. DOC M01 discusses addition of a surveillance requirement to verify correct alignments and voltage for the DG Sequoyah Unit 1 and Unit 2 Page 3 of 7 Enclosure 2, Volume 13, Rev. 0, Page 555 of 638

Enclosure 2, Volume 13, Rev. 0, Page 556 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING DC distribution subsystem with a frequency of 7 days. ITS SR 3.8.9.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.2.1 requires the AC electrical boards to be OPERABLE and energized "with tie breakers open between redundant boards."

CTS 4.8.2.1 also requires the AC boards to be determined OPERABLE and energized from AC sources "with tie breakers open between redundant busses" by verifying correct breaker alignment and indicated voltage on the buses.

CTS 4.8.2.3.1 requires, in part, the DC bus trains to be determined OPERABLE and energized "with tie breakers open between redundant buses". ITS LCO 3.8.9 requires the applicable electrical power distribution subsystems to be OPERABLE and ITS SR 3.8.9.1 requires the verification of correct breaker alignments and voltage to required AC, vital DC, DG DC, and AC vital electrical power distribution subsystems. This changes the CTS by moving the procedural detail that the boards must have their tie breakers open between redundant boards from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC, vital DC, DG DC, and AC vital electrical power distribution subsystems. In addition, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal Sequoyah Unit 1 and Unit 2 Page 4 of 7 Enclosure 2, Volume 13, Rev. 0, Page 556 of 638

Enclosure 2, Volume 13, Rev. 0, Page 557 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1 states, in part, that the specified A.C. boards shall be determined OPERABLE by verifying correct breaker alignment. CTS 3.8.2.1 includes Note # that allows D.C. Channel V to be substituted for any one channel of channels I-IV, thus verification of correct breaker alignment is required when Channel V is substituted. ITS SR 3.8.9.1 does not contain this design information. This changes the CTS by moving the details that DC channel V can be substituted for any one of channels I-IV from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required distribution subsystems to be OPERABLE. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases, requiring an evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.1 requires, in part, each DC bus to be determined OPERABLE by verifying voltage of greater than or equal to 125 volt DC on the bus. ITS SR 3.8.9.1 requires, in part, verification of correct breaker alignment and voltage to the DG DC electrical power distribution subsystems. This changes the CTS by removing the specified voltage limit from the surveillance and placing it in the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the correct voltage to each diesel generator 125 volt DC distribution panel and to each vital DC board. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 CTS 3.8.2.1 ACTION a requires that with less than the listed AC electrical boards OPERABLE and energized to restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS LCO 3.8.9 ACTION A requires that with one or more Sequoyah Unit 1 and Unit 2 Page 5 of 7 Enclosure 2, Volume 13, Rev. 0, Page 557 of 638

Enclosure 2, Volume 13, Rev. 0, Page 558 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING associated unit's AC electrical power distribution subsystems boards(s) inoperable to restore AC electrical power distribution subsystem(s) to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.9 ACTION D requires that when one or more opposite unit's AC boards are inoperable to declare the associated supported required feature(s) inoperable immediately. This changes the CTS by providing a separate ACTION to declare the required supported feature(s) inoperable and follow the applicable ACTIONS for the affected shared system LCOs when the opposite unit's required AC boards are inoperable.

The safety function of the Standby AC Power System is to supply power to support the functioning of components and systems required to assure that (1) fuel design limits and reactor coolant pressure boundary design conditions are not exceeded due to anticipated operational occurrences, and (2) the core is cooled and vital functions are maintained in the event of postulated accidents, subject to loss of the Preferred Power System and subject to any single failure in the Standby Power System. To accomplish its safety function, the onsite Class 1E AC distribution system supplies electrical power to two power trains for each unit. Each power train includes two Class 1E 6.9 kV shutdown boards powered from one of two separate and independent offsite power lines or a dedicated onsite DG. Two DGs in one train can provide the safety related functions to mitigate a loss-of-coolant accident (LOCA) in one unit and safely shut down the other unit. The core cooling and containment cooling system loads are unitized to the respective unit's 6.9 kV shutdown boards. Although the core cooling systems and containment systems credited in the mitigation of an anticipated operational occurrence (AOO) or postulated Design Basis Accident (DBA) are unitized (not shared with the opposite unit) and powered from the associated unit's shutdown boards, some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVS), and Control Room HVAC (CRACS)) are shared between the units. The AC sources for these loads are distributed across both unit's shutdown boards. Therefore, in addition to requiring the associated unit's boards to be OPERABLE; the opposite unit's boards supplying power to a required shared system component is also required to be OPERABLE. The purpose of CTS 3.8.2.1 ACTION a is to limit the time AC boards can be inoperable. The proposed change maintains the CTS ACTIONS and allowed outage time for the associated unit's AC boards, and proposes a new ACTION that changes the allowed outage time for the opposite unit's AC boards. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. These changes are acceptable because the Required Actions associated with the required features are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation, while providing time to repair the inoperable features. If the necessary repairs cannot be made within the established Completion Time, the applicable Conditions for the affected shared system LCOs establish the Required Actions to exit the MODE of Applicability for that inoperable required feature. This change is acceptable because the provided ACTIONS effect restoration of the opposite unit's AC boards Sequoyah Unit 1 and Unit 2 Page 6 of 7 Enclosure 2, Volume 13, Rev. 0, Page 558 of 638

Enclosure 2, Volume 13, Rev. 0, Page 559 of 638 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING commensurate with the importance of maintaining these AC boards capable of supporting the associated unit's required feature(s). This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 7 of 7 Enclosure 2, Volume 13, Rev. 0, Page 559 of 638

Enclosure 2, Volume 13, Rev. 0, Page 560 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 560 of 638

Enclosure 2, Volume 13, Rev. 0, Page 561 of 638 CTS Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating vital , and diesel generator (DG) DC 3.8.1.1 LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution 1 3.8.2.1 3.8.2.3 subsystems shall be OPERABLE.

Applicability 3.8.1.1 APPLICABILITY: MODES 1, 2, 3, and 4.

3.8.2.1 3.8.2.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Unit 1 3.8.2.1 A. One or more AC A.1 --------------NOTE-------------- 2 ACTION a. electrical power Enter applicable Conditions DOC A03 distribution subsystems and Required Actions of inoperable. LCO 3.8.4, "DC Sources - vital Operating," for DC trains 1 made inoperable by inoperable power distribution subsystems.

Unit 1 3.8.2.1 Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 2 ACTION a. distribution subsystem(s) to OPERABLE status.

8 3.8.2.1 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1 ACTION a. buses inoperable. subsystem(s) to subsystems OPERABLE status.

vital vital C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1

electrical power power distribution 3.8.2.3 ACTION a. distribution subsystems subsystem(s) to inoperable. OPERABLE status.

INSERT 1 2 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.9-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 561 of 638

Enclosure 2, Volume 13, Rev. 0, Page 562 of 638 3.8.9 2

INSERT 1 D. One or more Unit 2 AC D.1 Declare associated Immediately DOC L01 electrical power required feature(s) distribution subsystems inoperable.

inoperable.

DOC A02 E. One or more required E.1 Declare associated Immediately DG DC subsystems supported DG inoperable.

inoperable.

Insert Page 3.8.9-1 Enclosure 2, Volume 13, Rev. 0, Page 562 of 638

Enclosure 2, Volume 13, Rev. 0, Page 563 of 638 CTS Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F

3.8.2.1 D. Required Action and F D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION a. associated Completion 2 3.8.2.3 Time not met. AND ACTION a.

for Condition A, B, or C F D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G G DOC M02 E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately 2 power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1 SR 3.8.9.1 Verify correct breaker alignments and voltage to [ 7 days 4.8.2.3.1 DOC M01

[required] AC, DC, and AC vital bus electrical power 3 1 vital distribution subsystems. DG DC, OR In accordance 4 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.9-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 563 of 638

Enclosure 2, Volume 13, Rev. 0, Page 564 of 638 CTS Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating vital , and diesel generator (DG) DC 3.8.1.1 LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution 1 3.8.2.1 3.8.2.3 subsystems shall be OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

3.8.1.1 3.8.2.1 3.8.2.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Unit 2 3.8.2.1 A. One or more AC A.1 --------------NOTE-------------- 2 ACTION a. electrical power Enter applicable Conditions DOC A03 distribution subsystems and Required Actions of inoperable. LCO 3.8.4, "DC Sources - vital Operating," for DC trains 1 made inoperable by inoperable power distribution subsystems.

Unit 2 3.8.2.1 Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 2 ACTION a. distribution subsystem(s) to OPERABLE status.

8 3.8.2.1 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1 ACTION a. buses inoperable. subsystem(s) to subsystems OPERABLE status.

vital vital C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1

electrical power power distribution 3.8.2.3 ACTION a. distribution subsystems subsystem(s) to inoperable. OPERABLE status.

INSERT 1 2 SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.9-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 564 of 638

Enclosure 2, Volume 13, Rev. 0, Page 565 of 638 3.8.9 2

INSERT 1 D. One or more Unit 1 AC D.1 Declare associated Immediately DOC L01 electrical power required feature(s) distribution subsystems inoperable.

inoperable.

DOC A02 E. One or more required E.1 Declare associated Immediately DG DC subsystems supported DG inoperable.

inoperable.

Insert Page 3.8.9-1 Enclosure 2, Volume 13, Rev. 0, Page 565 of 638

Enclosure 2, Volume 13, Rev. 0, Page 566 of 638 CTS Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F

3.8.2.1 D. Required Action and F D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION a. associated Completion 2

3.8.2.3 Time not met. AND ACTION a.

for Condition A, B, or C F D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G G DOC M02 E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately 2 power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1 SR 3.8.9.1 Verify correct breaker alignments and voltage to [ 7 days 4.8.2.3.1 DOC M01

[required] AC, DC, and AC vital bus electrical power 3 1 vital distribution subsystems. DG DC, OR In accordance 4 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.9-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 566 of 638

Enclosure 2, Volume 13, Rev. 0, Page 567 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. Changes are made to the ISTS to reflect the interaction between an operating unit's electrical distribution subsystem and those credited features needing support from the opposite unit's associated electrical distribution subsystem.
3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
4. ISTS SR 3.8.9.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.9.1 is "In accordance with the Surveillance Frequency Control Program."

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 567 of 638

Enclosure 2, Volume 13, Rev. 0, Page 568 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 568 of 638

Enclosure 2, Volume 13, Rev. 0, Page 569 of 638 Distribution Systems - Operating B 3.8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES INSERT 1 1 vital BACKGROUND The onsite Class 1E AC, DC, and AC vital bus electrical power 1 distribution systems are divided by train into [two] redundant and vital 2

independent AC, DC, and AC vital bus electrical power distribution 1 1

subsystems. INSERT 2 two 1

6.9 kV Shutdown Boards The AC electrical power subsystem for each train consists of a primary boards Engineered Safety Feature (ESF) 4.16 kV bus and secondary [480 and 1 2 120] V buses, distribution panels, motor control centers and load centers. 1 train of 6.9 kV Shutdown Boards Each [4.16 kV ESF bus] has at least [one separate and independent 2 1 6.9 kV Shutdown Board offsite source of power] as well as a dedicated onsite diesel generator 2 for each 6.9 kV Shutdown Board (DG) source. Each [4.16 kV ESF bus] is normally connected to a 2 preferred offsite source. After a loss of the preferred offsite power source 1 to a 4.16 kV ESF bus, a transfer to the alternate offsite source is an is accomplished by utilizing a time delayed bus undervoltage relay. If all s 1

affected 6.9 kV offsite sources are unavailable, the onsite emergency DG supplies power y

Shutdown Boards to the 4.16 kV ESF bus. Control power for the 4.16 kV breakers is 1 supplied from the Class 1E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources - 6.9 kV Shutdown Board Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."

boards The secondary AC electrical power distribution subsystem for each train includes the safety related buses, load centers, motor control centers, 1 and distribution panels shown in Table B 3.8.9-1.

subsystems The 120 VAC vital buses are arranged in two load groups per train and are normally powered from the inverters. The alternate power supply for the vital buses are Class 1E constant voltage source transformers 1 powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage source transformer is powered from a Class 1E AC bus.

vital The DC electrical power distribution subsystem consists of [125] V 1 2 boards bus(es) and distribution panel(s). 1 INSERT 3 1 AC, vital The list of all required DC and vital AC distribution buses [and panels] is 1 2 4 presented in Table B 3.8.9-1. DG DC, subsystems SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 569 of 638

, Volume 13, Rev. 0, Page 570 of 638 3.8.9 1

INSERT 1 The two units share several structures and systems including the preferred and emergency (standby) electric power systems (UFSAR Chapter 8.0). The vital DC Power System is shared to the extent that a few loads (e.g., the vital inverters) in one nuclear unit are energized by the DC power channels assigned primarily to power loads of the other unit. In no case does the sharing inhibit the safe shutdown of one unit while the other unit is experiencing an accident. The Standby Power System serving each unit is divided into two redundant load groups (power trains). These power trains (Train A and Train B for each unit) supply power to safety-related equipment. Generally, the Engineered Safety Feature (ESF) loads assigned to a unit are supplied by the unit designated trains. For example, Safety Injection (SI) pump 1A-A (associated with Unit 1) is supplied by Shutdown Board 1A-A (also associated with Unit 1) while SI pump 2A-A (associated with Unit 2) is supplied by Shutdown Board 2A-A (also associated with Unit 2).

Separate and similar systems and equipment are provided for each unit when required. In certain instances, both units share systems or some components of a system. Shared systems are the exception to the unit/power system association. Because both units share the power system, one unit's power system(s) supports certain components required by the other unit (e.g., emergency gas treatment system). To show the unit, train, board, and panel association, Table B 3.8.9-1 lists these power system components by train and unit designation.

1 INSERT 2 In addition, each diesel generator (DG) has an associated DC electrical power distribution panel.

1 INSERT 3 The DG 125 Volt DC distribution subsystem includes a 125 V distribution panel for each DG. During normal operation, power is supplied to the distribution panel by a 480 VAC board through a battery charger. During emergency operation of the DG (loss of offsite power source), the distribution panel is supplied power from a 58 cell battery. This panel supplies power for DG control, protection, and the engine DC lube oil circulating pump.

Insert Page B 3.8.9-1 , Volume 13, Rev. 0, Page 570 of 638

Enclosure 2, Volume 13, Rev. 0, Page 571 of 638 Distribution Systems - Operating B 3.8.9 BASES APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1), and in the FSAR, 1 2 ANALYSES vital Chapter [15] (Ref. 2), assume ESF systems are OPERABLE. The AC, DG DC, 2

DC, and AC vital bus electrical power distribution systems are designed 1 4 to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

vital DG DC, The OPERABILITY of the AC, DC, and AC vital bus electrical power 1 4 distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.

This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical power 3 and  ;
b. A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO vital The required power distribution subsystems listed in Table B 3.8.9-1 DG DC, ensure the availability of AC, DC, and AC vital bus electrical power for the 1 4 systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a vital DG DC, postulated DBA. The AC, DC, and AC vital bus electrical power 1 4 distribution subsystems are required to be OPERABLE.

DG DC, vital Maintaining the Train A and Train B AC, DC, and AC vital bus electrical 1 4 power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

OPERABLE AC electrical power distribution subsystems require the boards vital associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages. OPERABLE DC boards 1 electrical power distribution subsystems require the associated buses and distribution panels to be energized to their proper voltage from either the AC associated battery or charger. OPERABLE vital bus electrical power boards distribution subsystems require the associated buses to be energized to their proper voltage from the associated [inverter via inverted DC voltage, or inverter using internal AC source, or Class 1E constant voltage 2 transformer]. 120 volt regulated SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 571 of 638

Enclosure 2, Volume 13, Rev. 0, Page 572 of 638 Distribution Systems - Operating B 3.8.9 BASES LCO (continued) vital DG DC, In addition, tie breakers between redundant safety related AC, DC, and 1 4 AC vital bus power distribution subsystems, if they exist, must be open.

This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV 1 buses from being powered from the same offsite circuit. 6.9 kV Shutdown Boards APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients 3 and  ;
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown."

ACTIONS A.1 Unit 1 boards With one or more Train A and B required AC buses, load centers, motor 4 1 control centers, or distribution panels (except AC vital buses), in one train boards inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum Unit 1 required ESF functions not being supported. Therefore, the required AC 4 boards buses, load centers, motor control centers, and distribution panels must 1 be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

of Unit 1 boards Condition A worst scenario is one train without AC power (i.e., no offsite 4 power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on Unit 1 minimizing the potential for loss of power to the remaining train by 4 SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 572 of 638

Enclosure 2, Volume 13, Rev. 0, Page 573 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit and 3
b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Required Action A.1 is modified by a Note that requires the applicable vital Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power 1 distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

B.1 subsystems subsystems 1

With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the subsystem minimum [required] ESF functions not being supported. Therefore, the 2 required AC vital bus must be restored to OPERABLE status within 1 subsystem 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated [inverter via inverted 1 8

DC, inverter using internal AC source, or Class 1E constant voltage 2 or transformer]. 120 volt regulated subsystems Condition B represents one or more AC vital buses without power; 1 potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, subsystems minimizing the potential for loss of power to the remaining vital buses and 1 restoring power to the affected vital bus. 1 subsystem SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 573 of 638

Enclosure 2, Volume 13, Rev. 0, Page 574 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) 8 This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for 1 the vast majority of components that are without adequate vital AC power.

Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if declared inoperable, is acceptable because of: 1 8

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue, 3
b. The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and 3
c. The potential for an event in conjunction with a single failure of a redundant component.

8 subsystem The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time takes into account the importance to safety 1

of restoring the AC vital bus to OPERABLE status, the redundant subsystems capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

C.1 subsystem vital With one or more DC buses or distribution panels inoperable, and a loss 4 vital of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is 1 vital reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF subsystem vital functions not being supported. Therefore, the [required] DC buses and 2 distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated battery or charger.

subsystem subsystem vital Condition C represents one or more DC buses or distribution panels 1 without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 574 of 638

Enclosure 2, Volume 13, Rev. 0, Page 575 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable 5 operations to continue, not 3
b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and 3
c. The potential for an event in conjunction with a single failure of a redundant component.

subsystems vital The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC buses is consistent with Regulatory 1 Guide 1.93 (Ref. 3).

INSERT 4 F F D.1 and D.2 4 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

G E.1 4 G

Condition E corresponds to a level of degradation in the electrical power 4 distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 575 of 638

Enclosure 2, Volume 13, Rev. 0, Page 576 of 638 3.8.9 1 4 INSERT 4 D.1 With one or more Unit 2 AC electrical power distribution subsystems (except AC vital) inoperable, the associated required feature(s) must be declared inoperable immediately and the appropriate Condition(s) entered. The Required Actions of these appropriate Conditions will determine the impact of the inoperable Unit 2 AC electrical power distribution subsystem.

E.1 With one or more required DG DC subsystems inoperable there is no longer assurance the supported DG is able to start and perform its necessary safety function. The DG must therefore be declared inoperable immediately and the appropriate Condition(s) entered.

Insert Page B 3.8.9-6 Enclosure 2, Volume 13, Rev. 0, Page 576 of 638

Enclosure 2, Volume 13, Rev. 0, Page 577 of 638 Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE SR 3.8.9.1 REQUIREMENTS DG DC, vital This Surveillance verifies that the [required] AC, DC, and AC vital bus 2 1 4 sub electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is board maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control boards functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to 6 subsystem malfunctions.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [6].

1 2 U

2. FSAR, Chapter [15].
3. Regulatory Guide 1.93, December 1974.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 577 of 638

Enclosure 2, Volume 13, Rev. 0, Page 578 of 638 Distribution Systems - Operating B 3.8.9 Safety Related Onsite Table B 3.8.9-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems INSERT 5 TYPE VOLTAGE TRAIN A* TRAIN B*

AC safety buses [4160 V] [ESF Bus] [NB01] [ESF Bus] [NB02]

[480 V] Load Centers Load Centers

[NG01, NG03] [NG02, NG04]

[480 V] Motor Control Motor Control Centers Centers

[NG01A, NG01I, [NG02A, NG02I, NG01B, NG03C, NG02B, NG04C, NG03I, NG03D] NG04I, NG04D]

[120 V] Distribution Panels Distribution Panels 1

[NP01, NP03] [NP02, NP04]

DC buses [125 V] Bus [NK01] Bus [NK02]

Bus [NK03] Bus [NK04]

Distribution Panels Distribution Panels

[NK41, NK43, NK51] [NK42, NK44, NK52]

AC vital buses [120 V] Bus [NN01] Bus [NN02]

Bus [NN03] Bus [NN04]

  • Each train of the AC and DC electrical power distribution systems is a subsystem.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.9-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 578 of 638

Enclosure 2, Volume 13, Rev. 0, Page 579 of 638 3.8.9 1

INSERT 5 TYPE VOLTAGE SR 3.8.9.1 TRAIN A* TRAIN B*

(nominal) Voltage Range Vital DC 129 V and battery 125 V Board I Board III Board II Board IV 140 V boards AC safety Unit 1 Unit 2 Unit 1 Unit 2 boards 6900 V 6560 V SD BD SD BD SD BD SD BD and 1A-A 2A-A 1B-B 2B-B 7260 V 480 V 440 V and SD BD SD BD SD BD SD BD 508 V 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B Rx MOV Bd Rx MOV Bd Rx MOV Bd Rx MOV Bd 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B C & A Vent Bd C & A Vent Bd C & A Vent Bd C & A Vent Bd 1A1-A 2A1-A 1B1-B 2B1-B Diesel Aux Bd Diesel Aux Bd Diesel Aux Bd Diesel Aux Bd 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B ERCW MCC ERCW MCC ERCW MCC ERCW MCC 1A-A 2A-A 1B-B 2B-B AC vital Unit 1 Unit 2 Unit 1 Unit 2 instrument power 120 V 120.6 V Board 1-I Board 2-I Board 1-II Board 2-II boards and 126.6 V Board 1-III Board 2-III Board 1-IV Board 2-IV DG DC 124 V and DG 1A-A DG 2A-A DG 1B-B DG 2B-B boards 125 V 135 V Dist. Pnl. Dist. Pnl. Dist. Pnl. Dist. Pnl.

Insert Page B 3.8.9-8 Enclosure 2, Volume 13, Rev. 0, Page 579 of 638

Enclosure 2, Volume 13, Rev. 0, Page 580 of 638 Distribution Systems - Operating B 3.8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES INSERT 1 1 vital BACKGROUND The onsite Class 1E AC, DC, and AC vital bus electrical power 1 distribution systems are divided by train into [two] redundant and vital 2

independent AC, DC, and AC vital bus electrical power distribution 1 1

subsystems. INSERT 2 two 1

6.9 kV Shutdown Boards The AC electrical power subsystem for each train consists of a primary boards Engineered Safety Feature (ESF) 4.16 kV bus and secondary [480 and 1 2 120] V buses, distribution panels, motor control centers and load centers. 1 train of 6.9 kV Shutdown Boards Each [4.16 kV ESF bus] has at least [one separate and independent 2 1 6.9 kV Shutdown Board offsite source of power] as well as a dedicated onsite diesel generator 2 for each 6.9 kV Shutdown Board (DG) source. Each [4.16 kV ESF bus] is normally connected to a 2 preferred offsite source. After a loss of the preferred offsite power source 1 to a 4.16 kV ESF bus, a transfer to the alternate offsite source is an is accomplished by utilizing a time delayed bus undervoltage relay. If all s 1

affected 6.9 kV offsite sources are unavailable, the onsite emergency DG supplies power y

Shutdown Boards to the 4.16 kV ESF bus. Control power for the 4.16 kV breakers is 1 supplied from the Class 1E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources - 6.9 kV Shutdown Board Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."

boards The secondary AC electrical power distribution subsystem for each train includes the safety related buses, load centers, motor control centers, 1 and distribution panels shown in Table B 3.8.9-1.

subsystems The 120 VAC vital buses are arranged in two load groups per train and are normally powered from the inverters. The alternate power supply for the vital buses are Class 1E constant voltage source transformers 1 powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage source transformer is powered from a Class 1E AC bus.

vital The DC electrical power distribution subsystem consists of [125] V 1 2 boards bus(es) and distribution panel(s). 1 INSERT 3 1 AC, vital The list of all required DC and vital AC distribution buses [and panels] is 1 2 4 presented in Table B 3.8.9-1. DG DC, subsystems SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 580 of 638

, Volume 13, Rev. 0, Page 581 of 638 3.8.9 1

INSERT 1 The two units share several structures and systems including the preferred and emergency (standby) electric power systems (UFSAR Chapter 8.0). The vital DC Power System is shared to the extent that a few loads (e.g., the vital inverters) in one nuclear unit are energized by the DC power channels assigned primarily to power loads of the other unit. In no case does the sharing inhibit the safe shutdown of one unit while the other unit is experiencing an accident. The Standby Power System serving each unit is divided into two redundant load groups (power trains). These power trains (Train A and Train B for each unit) supply power to safety-related equipment. Generally, the Engineered Safety Feature (ESF) loads assigned to a unit are supplied by the unit designated trains. For example, Safety Injection (SI) pump 1A-A (associated with Unit 1) is supplied by Shutdown Board 1A-A (also associated with Unit 1) while SI pump 2A-A (associated with Unit 2) is supplied by Shutdown Board 2A-A (also associated with Unit 2).

Separate and similar systems and equipment are provided for each unit when required. In certain instances, both units share systems or some components of a system. Shared systems are the exception to the unit/power system association. Because both units share the power system, one unit's power system(s) supports certain components required by the other unit (e.g., emergency gas treatment system). To show the unit, train, board, and panel association, Table B 3.8.9-1 lists these power system components by train and unit designation.

1 INSERT 2 In addition, each diesel generator (DG) has an associated DC electrical power distribution panel.

1 INSERT 3 The DG 125 Volt DC distribution subsystem includes a 125 V distribution panel for each DG. During normal operation, power is supplied to the distribution panel by a 480 VAC board through a battery charger. During emergency operation of the DG (loss of offsite power source), the distribution panel is supplied power from a 58 cell battery. This panel supplies power for DG control, protection, and the engine DC lube oil circulating pump.

Insert Page B 3.8.9-1 , Volume 13, Rev. 0, Page 581 of 638

Enclosure 2, Volume 13, Rev. 0, Page 582 of 638 Distribution Systems - Operating B 3.8.9 BASES APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1), and in the FSAR, 1 2 ANALYSES vital Chapter [15] (Ref. 2), assume ESF systems are OPERABLE. The AC, DG DC, 2 DC, and AC vital bus electrical power distribution systems are designed 1 4 to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

vital DG DC, The OPERABILITY of the AC, DC, and AC vital bus electrical power 1 4 distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.

This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical power 3 and  ;
b. A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

DG DC, LCO vital The required power distribution subsystems listed in Table B 3.8.9-1 ensure the availability of AC, DC, and AC vital bus electrical power for the 1 4 systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a vital DG DC, postulated DBA. The AC, DC, and AC vital bus electrical power 1 4 distribution subsystems are required to be OPERABLE.

DG DC, vital Maintaining the Train A and Train B AC, DC, and AC vital bus electrical 1 4 power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

OPERABLE AC electrical power distribution subsystems require the boards vital associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages. OPERABLE DC boards 1 electrical power distribution subsystems require the associated buses and distribution panels to be energized to their proper voltage from either the AC associated battery or charger. OPERABLE vital bus electrical power boards distribution subsystems require the associated buses to be energized to their proper voltage from the associated [inverter via inverted DC voltage, or inverter using internal AC source, or Class 1E constant voltage 2 transformer]. 120 volt regulated SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 582 of 638

Enclosure 2, Volume 13, Rev. 0, Page 583 of 638 Distribution Systems - Operating B 3.8.9 BASES LCO (continued) vital DG DC, In addition, tie breakers between redundant safety related AC, DC, and 1 4 AC vital bus power distribution subsystems, if they exist, must be open.

This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV 1 buses from being powered from the same offsite circuit. 6.9 kV Shutdown Boards APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients 3 and  ;
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown."

ACTIONS A.1 Unit 2 boards With one or more Train A and B required AC buses, load centers, motor 4 1 control centers, or distribution panels (except AC vital buses), in one train boards inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum Unit 2 required ESF functions not being supported. Therefore, the required AC 4 boards buses, load centers, motor control centers, and distribution panels must 1 be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

of Unit 2 boards Condition A worst scenario is one train without AC power (i.e., no offsite 4 power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on Unit 2 minimizing the potential for loss of power to the remaining train by 4 SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 583 of 638

Enclosure 2, Volume 13, Rev. 0, Page 584 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit and 3
b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Required Action A.1 is modified by a Note that requires the applicable vital Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power 1 distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

B.1 subsystems subsystems 1

With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the subsystem minimum [required] ESF functions not being supported. Therefore, the 2 required AC vital bus must be restored to OPERABLE status within 1 subsystem 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated [inverter via inverted 1 8

DC, inverter using internal AC source, or Class 1E constant voltage 2 or transformer]. 120 volt regulated subsystems Condition B represents one or more AC vital buses without power; 1 potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, subsystems minimizing the potential for loss of power to the remaining vital buses and 1 restoring power to the affected vital bus. 1 subsystem SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 584 of 638

Enclosure 2, Volume 13, Rev. 0, Page 585 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) 8 This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for 1 the vast majority of components that are without adequate vital AC power.

Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if declared inoperable, is acceptable because of: 1 8

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue, 3
b. The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and 3
c. The potential for an event in conjunction with a single failure of a redundant component.

8 subsystem The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time takes into account the importance to safety 1

of restoring the AC vital bus to OPERABLE status, the redundant subsystems capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

C.1 subsystem vital With one or more DC buses or distribution panels inoperable, and a loss 4 vital of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is 1 vital reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF subsystem vital functions not being supported. Therefore, the [required] DC buses and 2 distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated battery or charger.

subsystem subsystem vital Condition C represents one or more DC buses or distribution panels 1 without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-5 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 585 of 638

Enclosure 2, Volume 13, Rev. 0, Page 586 of 638 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable 5 operations to continue, not 3
b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and 3
c. The potential for an event in conjunction with a single failure of a redundant component.

subsystems vital The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC buses is consistent with Regulatory 1 Guide 1.93 (Ref. 3).

INSERT 4 F F D.1 and D.2 4 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required 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 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

G E.1 4 G

Condition E corresponds to a level of degradation in the electrical power 4 distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-6 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 586 of 638

Enclosure 2, Volume 13, Rev. 0, Page 587 of 638 3.8.9 1 4 INSERT 4 D.1 With one or more Unit 1 AC electrical power distribution subsystems (except AC vital) inoperable, the associated required feature(s) must be declared inoperable immediately and the appropriate Condition(s) entered. The Required Actions of these appropriate Conditions will determine the impact of the inoperable Unit 1 AC electrical power distribution subsystem.

E.1 With one or more required DG DC subsystems inoperable there is no longer assurance the supported DG is able to start and perform its necessary safety function. The DG must therefore be declared inoperable immediately and the appropriate Condition(s) entered.

Insert Page B 3.8.9-6 Enclosure 2, Volume 13, Rev. 0, Page 587 of 638

Enclosure 2, Volume 13, Rev. 0, Page 588 of 638 Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE SR 3.8.9.1 REQUIREMENTS DG DC, vital This Surveillance verifies that the [required] AC, DC, and AC vital bus 2 1 4 sub electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is board maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control boards functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to 6 subsystem malfunctions.

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


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [6].

1 2 U

2. FSAR, Chapter [15].
3. Regulatory Guide 1.93, December 1974.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-7 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 588 of 638

Enclosure 2, Volume 13, Rev. 0, Page 589 of 638 Distribution Systems - Operating B 3.8.9 Safety Related Onsite Table B 3.8.9-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems INSERT 5 TYPE VOLTAGE TRAIN A* TRAIN B*

AC safety buses [4160 V] [ESF Bus] [NB01] [ESF Bus] [NB02]

[480 V] Load Centers Load Centers

[NG01, NG03] [NG02, NG04]

[480 V] Motor Control Motor Control Centers Centers

[NG01A, NG01I, [NG02A, NG02I, NG01B, NG03C, NG02B, NG04C, NG03I, NG03D] NG04I, NG04D]

[120 V] Distribution Panels Distribution Panels 1

[NP01, NP03] [NP02, NP04]

DC buses [125 V] Bus [NK01] Bus [NK02]

Bus [NK03] Bus [NK04]

Distribution Panels Distribution Panels

[NK41, NK43, NK51] [NK42, NK44, NK52]

AC vital buses [120 V] Bus [NN01] Bus [NN02]

Bus [NN03] Bus [NN04]

  • Each train of the AC and DC electrical power distribution systems is a subsystem.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.9-8 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 589 of 638

Enclosure 2, Volume 13, Rev. 0, Page 590 of 638 3.8.9 1

INSERT 5 TYPE VOLTAGE SR 3.8.9.1 TRAIN A* TRAIN B*

(nominal) Voltage Range Vital DC 129 V and battery 125 V Board I Board III Board II Board IV 140 V boards AC safety Unit 1 Unit 2 Unit 1 Unit 2 boards 6900 V 6560 V SD BD SD BD SD BD SD BD and 1A-A 2A-A 1B-B 2B-B 7260 V 480 V 440 V and SD BD SD BD SD BD SD BD 508 V 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B Rx MOV Bd Rx MOV Bd Rx MOV Bd Rx MOV Bd 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B C & A Vent Bd C & A Vent Bd C & A Vent Bd C & A Vent Bd 1A1-A 2A1-A 1B1-B 2B1-B Diesel Aux Bd Diesel Aux Bd Diesel Aux Bd Diesel Aux Bd 1A1-A 2A1-A 1B1-B 2B1-B 1A2-A 2A2-A 1B2-B 2B2-B ERCW MCC ERCW MCC ERCW MCC ERCW MCC 1A-A 2A-A 1B-B 2B-B AC vital Unit 1 Unit 2 Unit 1 Unit 2 instrument power 120 V 120.6 V Board 1-I Board 2-I Board 1-II Board 2-II boards and 126.6 V Board 1-III Board 2-III Board 1-IV Board 2-IV DG DC 124 V and DG 1A-A DG 2A-A DG 1B-B DG 2B-B boards 125 V 135 V Dist. Pnl. Dist. Pnl. Dist. Pnl. Dist. Pnl.

Insert Page B 3.8.9-8 Enclosure 2, Volume 13, Rev. 0, Page 590 of 638

Enclosure 2, Volume 13, Rev. 0, Page 591 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.
4. Changes are made to be consistent with changes made to the Specification.
5. Editorial changes made for enhanced clarity.
6. ISTS SR 3.8.9.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.9.1 is "In accordance with the Surveillance Frequency Control Program."
7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 591 of 638

Enclosure 2, Volume 13, Rev. 0, Page 592 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 592 of 638

Enclosure 2, Volume 13, Rev. 0, Page 593 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L01 SQN is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below are the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 3.8.2.1 ACTION a requires that with less than the listed AC electrical boards OPERABLE and energized to restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS LCO 3.8.9 ACTION A requires that with one or more associated unit's AC electrical power distribution subsystems boards(s) inoperable to restore AC electrical power distribution subsystem(s) to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.9 ACTION D requires that when one or more opposite unit's AC boards are inoperable to declare the associated supported required feature(s) inoperable immediately. This changes the CTS by providing a separate ACTION to declare the required supported feature(s) inoperable and follow the applicable ACTIONS for the affected shared system LCOs when the opposite unit's required AC boards are inoperable.

The safety function of the Standby AC Power System is to supply power to support the functioning of components and systems required to assure that (1) fuel design limits and reactor coolant pressure boundary design conditions are not exceeded due to anticipated operational occurrences, and (2) the core is cooled and vital functions are maintained in the event of postulated accidents, subject to loss of the Preferred Power System and subject to any single failure in the Standby Power System. To accomplish its safety function, the onsite Class 1E AC distribution system supplies electrical power to two power trains for each unit. Each power train includes two Class 1E 6.9 kV shutdown boards powered from one of two separate and independent offsite power lines or a dedicated onsite DG. Two DGs in one train can provide the safety related functions to mitigate a loss-of-coolant accident (LOCA) in one unit and safely shut down the other unit. The core cooling and containment cooling system loads are unitized to the respective unit's 6.9 kV shutdown boards. Although the core cooling systems and containment systems credited in the mitigation of an anticipated operational occurrence (AOO) or postulated Design Basis Accident (DBA) are unitized (not shared with the opposite unit) and powered from the associated unit's shutdown boards, some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS),

Control Room Emergency Ventilation (CREVS), and Control Room HVAC (CRACS)) are shared between the units. The AC sources for these loads are distributed across both unit's shutdown boards. Therefore, in addition to requiring the associated unit's boards to be OPERABLE; the opposite unit's boards supplying power to a required shared system component is also required to be OPERABLE. The purpose of CTS 3.8.2.1 ACTION a is to limit the time AC boards can be inoperable. The proposed change maintains the CTS ACTIONS and allowed outage time for the associated unit's AC boards, and proposes a new ACTION that changes the allowed outage time for the opposite unit's AC boards. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA Sequoyah Unit 1 and 2 Page 1 of 3 Enclosure 2, Volume 13, Rev. 0, Page 593 of 638

Enclosure 2, Volume 13, Rev. 0, Page 594 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING occurring during the repair period. These changes are acceptable because the Required Actions associated with the required features are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation, while providing time to repair the inoperable features. If the necessary repairs cannot be made within the established Completion Time, the applicable Conditions for the affected shared system LCOs establish the Required Actions to exit the MODE of Applicability for that inoperable required feature. This change is acceptable because the provided ACTIONS effect restoration of the opposite unit's AC boards commensurate with the importance of maintaining these AC boards capable of supporting the associated unit's required feature(s). This change is designated as less restrictive, because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Tennessee Valley Authority (TVA) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No.

The proposed change relaxes the Required Actions for the opposite unit's distribution system. This change will not affect the probability of an accident, since the distribution system are not initiators of any accident sequence analyzed in the Updated Final Safety Analysis Report (UFSAR). Rather, the opposite unit's distribution system support equipment used to mitigate accidents. The consequences of an analyzed accident will not be significantly increased since the minimum requirements for distribution systems will be maintained to ensure the availability of the required power to mitigate accidents assumed in the UFSAR. Operation in accordance with the proposed TS will ensure that sufficient onsite electrical distribution systems are OPERABLE as required to support the unit's required features. Therefore, the mitigating functions supported by the onsite electrical distribution systems will continue to provide the protection assumed by the accident analysis. The integrity of fission product barriers, plant configuration, and operating procedures as described in the UFSAR will not be affected by the proposed changes. Thus, the consequences of previously analyzed accidents will not increase by implementing these changes. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change relaxes the Required Actions for the opposite unit's onsite electrical distribution systems. This change will not physically alter the plant (no new or different type of equipment will be installed). The proposed changes will maintain the minimum requirements for onsite electrical distribution systems to ensure the availability of the equipment required to mitigate accidents assumed in the UFSAR. Therefore, Sequoyah Unit 1 and 2 Page 2 of 3 Enclosure 2, Volume 13, Rev. 0, Page 594 of 638

Enclosure 2, Volume 13, Rev. 0, Page 595 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in the margin of safety?

Response: No.

The proposed change relaxes the Required Actions for the opposite unit's onsite electrical distribution system. The margin of safety is not affected by this change because the minimum requirements for onsite electrical distribution systems will be maintained to ensure the availability of the required power to shutdown the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Therefore, the proposed changes do not involve a significant reduction in a margin of safety Sequoyah Unit 1 and 2 Page 3 of 3 Enclosure 2, Volume 13, Rev. 0, Page 595 of 638

Enclosure 2, Volume 13, Rev. 0, Page 596 of 638 ATTACHMENT 10 ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN Enclosure 2, Volume 13, Rev. 0, Page 596 of 638

, Volume 13, Rev. 0, Page 597 of 638 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 597 of 638

Enclosure 2, Volume 13, Rev. 0, Page 598 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS SHUTD0WN The necessary portion of the diesel generator (DG) DC distribution subsystem M01 LIMITING CONDITION FOR OPERATION to support equipment required to be OPERABLE. M01 LCO 3.8.10 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution See ITS system, and 3.8.2
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with: LA01
1. Two diesels driving a common generator, See ITS
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel 3.8.2 per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 See ITS
4. A fuel transfer pump, and 3.8.2
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS 3.8.5 associated charger.

Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all See ITS operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions 3.8.2 that could result in loss of required shutdown margin or boron concentration.

Add proposed ACTION B A02 SURVEILLANCE REQUIREMENTS SR 3.8.10.1 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 3.8.2 4.8.1.1.2.a.5), and 4.8.1.1.3.

Add proposed SR 3.8.10.1 for DG DC distribution panels M03 May 22, 2003 SEQUOYAH - UNIT 1 3/4 8-8 Amendment No. 241, 285 Page 1 of 14 Enclosure 2, Volume 13, Rev. 0, Page 598 of 638

Enclosure 2, Volume 13, Rev. 0, Page 599 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN The necessary portion of M01 LIMITING CONDITION FOR OPERATION See ITS 3.8.8 LCO 3.8.10 3.8.2.2 As a minimum, the following A.C. electrical boards and inverters shall be OPERABLE and energized: to support equipment required to be OPERABLE. M01 2 - 6900 volt shutdown boards, either 1A-A and 2A-A or 1B-B and 2B-B, 4 - 480 volt shutdown boards associated with the required OPERABLE 6900 volt shutdown LA01 boards, 2 - 120 volt A.C. vital instrument power boards either Channels I and III or Channels II and IV energized from their respective inverters# connected to their respective D.C. battery banks*,

and 480 volt shutdown boards. See ITS 3.8.8 Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTION:

Add proposed ACTIONS Note M02 ACTION A With less than the above complement of A.C. boards and inverters OPERABLE and energized, establish See ITS CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 3.8.8 Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4 L01 Add Required Action A.1 M01 SURVEILLANCE REQUIREMENTS See ITS 3.8.8 SR 3.8.10.1 4.8.2.2 The specified A.C. boards and inverters shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the bus.

In accordance with the Surveillance Frequency Control Program LA02

  • Any one of the inverters may be connected to D.C. Battery Bank V.

See ITS 3.8.8

  1. The spare inverter for a specified channel may be substituted for one of the two inverters of the same channel.

September 23, 1999 SEQUOYAH - UNIT 1 3/4 8-10 Amendment No. 37, 246 Page 2 of 14 Enclosure 2, Volume 13, Rev. 0, Page 599 of 638

Enclosure 2, Volume 13, Rev. 0, Page 600 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS D.C. DISTRIBUTION - SHUTDOWN M01 The necessary portions of the LIMITING CONDITION FOR OPERATION See ITS 3.8.5 LCO 3.8.10 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be energized and M01 0PERABLE: to support equipment required to be OPERABLE.

2 - 125-volt D.C. boards either I and III or II and IV, and LA01 2* - 125-volt battery banks and chargers, one associated with each See ITS operable D.C. board 3.8.5 Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTIONS ACTION:

ACTION A With less than the above complement of D.C. equipment and board OPERABLE, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4 L01 Add Required Action A.1 M01 SURVEILLANCE REQUIREMENTS In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.10.1 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability with an overall battery voltage of greater than or equal to 125 volts. LA01 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated See ITS OPERABLE per Surveillance Requirement 4.8.2.3.2. 3.8.5 See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank. 3.8.5 January 24, 1985 SEQUOYAH - UNIT 1 3/4 8-14 Amendment No. 37 Page 3 of 14 Enclosure 2, Volume 13, Rev. 0, Page 600 of 638

Enclosure 2, Volume 13, Rev. 0, Page 601 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS 3/4.8.3 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION This specification is deleted.

(Pages 3/4 8-15 through 3/4 8-16 are deleted)

February 22, 2000 SEQUOYAH - UNIT 1 3/4 8-15 Amendment No. 42, 110, 203, 250 Page 4 of 14 Enclosure 2, Volume 13, Rev. 0, Page 601 of 638

Enclosure 2, Volume 13, Rev. 0, Page 602 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION LIMITING CONDITION FOR OPERATION This specification is deleted.

(Page 3/4 8-17 is deleted)

February 22, 2000 SEQUOYAH - UNIT 1 3/4 8-17 Amendment Nos. 33, 80, 128, 203, 250 Page 5 of 14 Enclosure 2, Volume 13, Rev. 0, Page 602 of 638

Enclosure 2, Volume 13, Rev. 0, Page 603 of 638 ITS A01 ITS 3.8.10 Pages 3/4 8/18 through 3/4 8-19 intentionally deleted June 13, 1995 SEQUOYAH - UNIT 1 3/4 8-18 Amendment No. 203 Page 6 of 14 Enclosure 2, Volume 13, Rev. 0, Page 603 of 638

Enclosure 2, Volume 13, Rev. 0, Page 604 of 638 ITS A01 ITS 3.8.10 ELECTRICAL POWER SYSTEMS ISOLATION DEVICES LIMITING CONDITION FOR OPERATION This specification is deleted.

(Page 3/4 8-20 is deleted)

February 22, 2000 SEQUOYAH - UNIT 1 3/4 8-20 Amendment Nos. 61, 80, 250 Page 7 of 14 Enclosure 2, Volume 13, Rev. 0, Page 604 of 638

Enclosure 2, Volume 13, Rev. 0, Page 605 of 638 ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS SHUTDOWN The necessary portion of the diesel M01 generator (DG) DC distribution subsystem LIMITING CONDITION FOR OPERATION to support equipment required to be OPERABLE. M01 LCO 3.8.10 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution See ITS system, and 3.8.2
b. Diesel generator sets 1A-A and 2A-A or 1B-B and 2B-B each with: LA01
1. Two diesels driving a common generator, See ITS 3.8.2
2. Two engine-mounted fuel tanks containing a minimum volume of 250 gallons of fuel per tank, See ITS
3. A fuel storage system containing a minimum volume of 62,000 gallons of fuel, 3.8.3 See ITS
4. A fuel transfer pump, and 3.8.2
5. A separate 125-volt D.C. distribution panel, 125-volt D.C. battery bank and See ITS associated charger. 3.8.5 Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all See ITS operations involving CORE ALTERATIONS and suspend operations involving positive reactivity additions 3.8.2 that could result in loss of required shutdown margin or boron concentration.

Add proposed ACTION B A02 SR 3.8.10.1 SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the See ITS performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (except for requirement 3.8.2 4.8.1.1.2.a.5), and 4.8.1.1.3.

Add proposed SR 3.8.10.1 for DG DC distribution panels M03 May 22, 2003 SEQUOYAH - UNIT 2 3/4 8-9 Amendment No. 231, 274 Page 8 of 14 Enclosure 2, Volume 13, Rev. 0, Page 605 of 638

Enclosure 2, Volume 13, Rev. 0, Page 606 of 638 ITS ITS 3.8.10 A01 ECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN The necessary portion of M01 LIMITING CONDITION FOR OPERATION See ITS 3.8.8 LCO 3.8.10 3.8.2.2 As a minimum, the following A.C. electrical boards and inverters shall be OPERABLE and energized: to support equipment required to be OPERABLE. M01 2 - 6900 volt shutdown boards, either 1A-A and 2A-A or 1B-B and 2B-B, 4 - 480 volt shutdown boards associated with the required OPERABLE 6900 volt shutdown boards, LA01 2 - 120 volt A.C. vital instrument power boards either Channels I and III or Channels II and IV energized from their respective inverters# connected to their respective D.C. battery banks,*

and 480 volt shut-down boards. See ITS 3.8.8 Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTION:

Add proposed ACTIONS Note M02 ACTION A With less than the above complement of A.C. boards and inverters OPERABLE and energized, establish See ITS CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 3.8.8 Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4 L01 Add Required Action A.1 M01 SURVEILLANCE REQUIREMENTS See ITS 3.8.8 SR 3.8.10.1 4.8.2.2 The specified A.C. boards and inverters shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the bus.

In accordance with the Surveillance LA02 Frequency Control Program

  • Any one of the inverters may be connected to D.C. Battery Bank V.

See ITS

  1. The spare inverter for a specified channel may be substituted for one of the two inverters of the same 3.8.8 channel.

September 23, 1999 SEQUOYAH - UNIT 2 3/4 8-11 Amendment No. 29, 237 Page 9 of 14 Enclosure 2, Volume 13, Rev. 0, Page 606 of 638

Enclosure 2, Volume 13, Rev. 0, Page 607 of 638 ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS M01 D.C. DISTRIBUTION - SHUTDOWN The necessary portions of the See ITS LIMITING CONDITION FOR OPERATION 3.8.5 LCO 3.8.10 3.8.2.4 As a minimum, the following D.C. electrical equipment and boards shall be and OPERABLE and M01 energized: to support equipment required to be OPERABLE.

LA01 2 - 125-volt D.C. boards either I and III or II and IV, and See ITS 3.8.5 2* - 125-volt battery banks and chargers, one associated with each operable D.C. board Applicability APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies M02 ACTION:

ACTION A With less than the above complement of D.C. equipment and board OPERABLE and energized, establish CONTAINMENT INTEGRITY within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Add Required Action A.2.1, A.2.2, A.2.3, and A.2.4 L01 Add Required Action A.1 M01 SURVEILLANCE REQUIREMENTS In accordance with the Surveillance Frequency Control Program LA02 SR 3.8.10.1 4.8.2.4.1 The above required 125-volt D.C. vital battery boards shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and voltage on the board with an overall battery voltage of greater than or equal to 125 volts. LA01 4.8.2.4.2 The above required 125-volt D.C. vital battery banks and chargers shall be demonstrated See ITS OPERABLE per Surveillance Requirement 4.8.2.3.2. 3.8.5 See ITS

  • D.C. Battery Bank V may be substituted for any other Battery Bank. 3.8.5 January 24, 1985 SEQUOYAH - UNIT 2 3/4 8-15 Amendment No. 29 Page 10 of 14 Enclosure 2, Volume 13, Rev. 0, Page 607 of 638

Enclosure 2, Volume 13, Rev. 0, Page 608 of 638 ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS 3/4.8.3 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION This specification is deleted.

(Pages 3/4 8-16 through 3/4 8-17 are deleted)

February 22, 2000 SEQUOYAH - UNIT 2 3/4 8-16 Amendment No. 34, 100, 193, 241 Page 11 of 14 Enclosure 2, Volume 13, Rev. 0, Page 608 of 638

Enclosure 2, Volume 13, Rev. 0, Page 609 of 638 ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION SURVEILLANCE REQUIREMENT (Continued)

This specification is deleted.

(Page 3/4 8-18 is deleted)

February 22, 2000 SEQUOYAH - UNIT 2 3/4 8-18 Amendment No. 25, 71, 115, 193, 241 Page 12 of 14 Enclosure 2, Volume 13, Rev. 0, Page 609 of 638

Enclosure 2, Volume 13, Rev. 0, Page 610 of 638 ITS ITS 3.8.10 A01 Pages 3/4 8-19 through 3/4 8-20 intentionally deleted June 13, 1995 SEQUOYAH - UNIT 2 3/4 8-19 Amendment No. 193 Page 13 of 14 Enclosure 2, Volume 13, Rev. 0, Page 610 of 638

Enclosure 2, Volume 13, Rev. 0, Page 611 of 638 ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS ISOLATION DEVICES LIMITING CONDITION FOR OPERATION This specification is deleted.

(Page 3/4 8-21 is deleted)

February 22, 2000 SEQUOYAH - UNIT 2 3/4 8-21 Amendment No. 53, 71, 241 Page 14 of 14 Enclosure 2, Volume 13, Rev. 0, Page 611 of 638

Enclosure 2, Volume 13, Rev. 0, Page 612 of 638 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.2.b.5 requires, in part, a separate and independent 125 volt DC distribution panel for diesel generator (DG) OPERABILITY. ITS 3.8.10 ACTION B requires for one or more inoperable DG DC electrical power distribution subsystems to immediately declare the associated DG inoperable. This changes the CTS by specifying an Action to declare a DG inoperable if its associated DC electrical power distribution subsystem is inoperable.

The purpose of CTS 3.8.1.2.b.5 is to specify the requirements for DG OPERABILITY. ITS 3.8.10 ACTION B preserves the intent of CTS 3.8.1.2.b.5 by declaring the DG inoperable if the associated DG DC distribution subsystem is inoperable. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2.b.5 requires, in part, a sparate 125 volt DC distribution panel for each DG set to be OPERABLE. CTS 3.8.2.2 states, in part, that as a minimum the following AC electrical boards shall be OPERABLE and energized, and then lists the applicable boards. CTS 3.8.2.4 requires, in part, that as a minimum the following 125 volt DC boards shall be energized and OPERABLE as listed.

ITS 3.8.10 states that the necessary portion of AC, vital DC, DG DC, and AC vital electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. In addition, an optional Required Action (ITS 3.8.10 Required Action A.1) has been added which allows the associated supported required feature(s) to be declared inoperable. This changes the CTS by requiring those necessary portions of electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, which could require more distribution boards or panels to be OPERABLE than is currently required. In addition, an action has been added to allow an option to the existing actions.

The purpose of CTS 3.8.1.2.b.5, CTS 3.8.2.2 and CTS 3.8.2.4 is to ensure that at least one train of AC, vital DC, DG DC, and 120 volt AC vital electrical power distribution systems are OPERABLE. This change adds a requirement that the applicable portions of AC, vital DC, DG DC, and 120 volt AC vital electrical power distribution subsystems must be OPERABLE when required to support equipment required to be OPERABLE by the Technical Specifications. This Sequoyah Unit 1 and Unit 2 Page 1 of 5 Enclosure 2, Volume 13, Rev. 0, Page 612 of 638

Enclosure 2, Volume 13, Rev. 0, Page 613 of 638 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN added restriction conservatively assures the needed electrical power distribution boards and panels are OPERABLE, even if this results in both trains of one or more of the electrical power distribution systems being required. Because the ITS 3.8.10 electrical power distribution subsystem OPERABILITY requirements require the necessary portions of the distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, if a portion of the electrical power distribution subsystem cannot supply any required equipment, that electrical power distribution subsystem is inoperable. In this event, it may not be necessary to suspend, irradiated fuel handling, and positive reactivity additions.

Conservative actions can be assured if all required equipment without the necessary power is declared inoperable, and the associated ACTIONS of the individual equipment is taken (ITS 3.8.10 Required Action A.1). Therefore, along with the conservative additional requirements placed on the electrical power distribution subsystems, Required Action A.1, which requires the associated supported equipment to be declared inoperable, is also added. These changes are acceptable since the additions represent restrictions consistent with implicit assumptions for operation in shutdown conditions (required equipment receiving the necessary required power), and these restrictions are not currently imposed by the Technical Specifications. This change is designated as more restrictive because it adds a new requirement to the CTS and more boards may be required to be OPERABLE in ITS than in the CTS.

M02 CTS 3.8.1.2, CTS 3.8.2.2 and CTS 3.8.2.4 are applicable in MODES 5 and 6.

ITS 3.8.10 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies and contains an ACTIONS Note stating that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of "During movement of irradiated fuel assemblies," and adds a Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

This change is acceptable because the proposed requirements are necessary to ensure the electrical power subsystems are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies.

Movement of fuel normally occurs during MODES 5 and 6; however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This addition to the applicability is needed to ensure the appropriate electrical distribution system requirements are specified during fuel handling and to ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supply is not available. In addition, this change adds a clarification Note stating that LCO 3.0.3 is not applicable because LCO 3.0.3 has no Required Actions that restore safety. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable because LCO 3.0.3 applicability is limited to MODES 1, 2, 3, and 4 only with a designated endpoint of MODE 5. In addition, if moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with ITS 3.8.10 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires equipment to be OPERABLE during movement of irradiated fuel Sequoyah Unit 1 and Unit 2 Page 2 of 5 Enclosure 2, Volume 13, Rev. 0, Page 613 of 638

Enclosure 2, Volume 13, Rev. 0, Page 614 of 638 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN assemblies both inside and outside of the containment, not only when in MODES 5 and 6.

M03 CTS 4.8.1.2 requires, in part, the performance of CTS 4.8.1.1.3, which includes a requirement that the 125 volt DC distribution panel for each DG be demonstrated OPERABLE. ITS SR 3.8.10.1 requires, in part, verification of the correct breaker alignments and voltage to the 125 volt DC distribution panel for each DG. This changes the CTS by adding a specific surveillance requiring verification of correct breaker alignment and correct voltage to the DG DC distribution subsystem.

The purpose of CTS 4.8.1.2 is to provide assurance that necessary power to required supported systems is available with sufficient capacity, capability, redundancy, and reliability to ensure the fuel, Reactor Coolant System, and containment design limits are not exceeded and postulated accidents are mitigated. This change is acceptable because it provides additional assurance that the distribution panels associated with the DG DC electrical power distribution subsystem are OPERABLE. This change is designated as more restrictive because it add a Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.2 requires AC electrical power sources to be OPERABLE, listing the sources and subsystems. CTS LCO 3.8.2.2 requires AC electrical boards to be OPERABLE, listing the boards. CTS LCO 3.8.2.4 requires DC electrical equipment and boards to be energized and OPERABLE and CTS 4.8.2.4.1 requires the overall battery voltage to be greater than or equal to 125 volts. ITS LCO 3.8.10 requires necessary portions of the AC, vital DC, DG DC, and AC vital electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE. ITS SR 3.8.10.1 requires the verification of correct breaker alignment and voltage to each required AC, vital DC, and vital AC electrical power distribution subsystem. The details of the boards are contained in the ITS Bases. This changes the CTS by moving description of the boards and panels (including the nominal voltages and any specified limits) from the CTS to the ITS Bases.

The removal of these details relating to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Sequoyah Unit 1 and Unit 2 Page 3 of 5 Enclosure 2, Volume 13, Rev. 0, Page 614 of 638

Enclosure 2, Volume 13, Rev. 0, Page 615 of 638 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.8.2.2 requires, in part, that the specified AC boards be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated voltage on the buses. CTS 4.8.2.4.1 requires, in part, that each required DC battery board be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability with an overall battery voltage of greater than or equal to 125 volts. ITS SR 3.8.10.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) With less than the minimum complement of AC boards OPERABLE and energized, CTS 3.8.2.2 requires the establishment of containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. With less than the minimum complement of DC boards OPERABLE and energized, CTS 3.8.2.4 also requires the establishment of containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

ITS 3.8.10 ACTION A requires, in part, suspending movement of irradiated fuel assemblies, suspension of operations involving positive reactivity additions that could result in the loss of required SDM or boron concentration, the initiation of actions to restore required AC, vital DC, and AC vital board electrical power distribution subsystems to OPERABLE status, and the declaration of the associated required residual heat removal subsystems(s) inoperable and not in Sequoyah Unit 1 and Unit 2 Page 4 of 5 Enclosure 2, Volume 13, Rev. 0, Page 615 of 638

Enclosure 2, Volume 13, Rev. 0, Page 616 of 638 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN operation. This changes the CTS by replacing the existing Required Action to restore containment integrity.

The purpose of the CTS 3.8.2.2 Action and CTS 3.8.2.4 Action is to isolate the containment to minimize any release from the plant if an event were to occur during shutdown conditions. This change is acceptable because the Required Actions establish remedial measures taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The proposed Required Actions require the suspension of movement of irradiated fuel assemblies, the suspension of operations involving positive reactivity additions that could result in the loss of required SDM or boron concentration, the initiation of actions to restore required AC, vital DC, and AC vital electrical power distribution subsystems to OPERABLE status, and the declaration of the associated required residual heat removal subsystems(s) inoperable and not in operation. Suspending the movement of irradiated fuel assemblies will prevent a fuel handling accident from occurring. Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. The actions to restore required AC, vital DC, and AC vital electrical power distribution subsystems to OPERABLE status will place the plant in compliance with the LCO. Declaration of the associated required decay heat removal subsystems(s) inoperable and not in operation will require the plant to enter the applicable LCOs to apply additional Required Actions. The proposed actions will immediately minimize the potential for any accident releases outside of containment and are considered acceptable instead of the current action to restore containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The actions may be considered somewhat more restrictive since immediate action is required, however, is classified as less restrictive since the current actions to restore containment integrity have been deleted. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Sequoyah Unit 1 and Unit 2 Page 5 of 5 Enclosure 2, Volume 13, Rev. 0, Page 616 of 638

Enclosure 2, Volume 13, Rev. 0, Page 617 of 638 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 617 of 638

Enclosure 2, Volume 13, Rev. 0, Page 618 of 638 CTS Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown vital , and diesel generator (DG) DC 1

3.8.1.2, 3.8.2.2, LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power 3.8.2.4 distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

Applicability 3.8.1.2, 3.8.2.2, APPLICABILITY: MODES 5 and 6, 3.8.2.4 DOC M02 During movement of [recently] irradiated fuel assemblies. 2 ACTIONS


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

DOC M02 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. One or more required A.1 Declare associated Immediately 3.8.2.2 3.8.2.4 vital AC, DC, or AC vital bus supported required DOC M01 electrical power feature(s) inoperable. 1 distribution subsystems inoperable. OR DOC L01 A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 2 assemblies.

AND DOC L01 A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.10-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 618 of 638

Enclosure 2, Volume 13, Rev. 0, Page 619 of 638 CTS Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A.2.3 Initiate actions to restore Immediately vital required AC, DC, and AC 1 vital bus electrical power 1

distribution subsystems to OPERABLE status.

AND DOC L01 A.2.4 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation. 1 INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.2, SR 3.8.10.1 Verify correct breaker alignments and voltage to [ 7 days 4.8.2.2, 4.8.2.4.1 required AC, DC, and AC vital bus electrical power vital distribution subsystems. OR 1

, and DG DC In accordance 3 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.8.10-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 619 of 638

Enclosure 2, Volume 13, Rev. 0, Page 620 of 638 3.8.10 1

INSERT 1 B. One or more required B.1 Declare associated DG(s) Immediately DOC A02 DG DC electrical power inoperable.

distribution subsystems inoperable.

Insert Page 3.8.10-2 Enclosure 2, Volume 13, Rev. 0, Page 620 of 638

Enclosure 2, Volume 13, Rev. 0, Page 621 of 638 CTS Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown vital , and diesel generator (DG) DC 1

3.8.1.2, 3.8.2.2, LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power 3.8.2.4 distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

Applicability 3.8.1.2, 3.8.2.2, APPLICABILITY: MODES 5 and 6, 3.8.2.4 DOC M02 During movement of [recently] irradiated fuel assemblies. 2 ACTIONS


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

DOC M02 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. One or more required A.1 Declare associated Immediately 3.8.2.2 3.8.2.4 vital AC, DC, or AC vital bus supported required DOC M01 electrical power feature(s) inoperable. 1 distribution subsystems inoperable. OR DOC L01 A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 2 assemblies.

AND DOC L01 A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.10-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 621 of 638

Enclosure 2, Volume 13, Rev. 0, Page 622 of 638 CTS Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A.2.3 Initiate actions to restore Immediately vital required AC, DC, and AC 1 vital bus electrical power 1

distribution subsystems to OPERABLE status.

AND DOC L01 A.2.4 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation. 1 INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.2, SR 3.8.10.1 Verify correct breaker alignments and voltage to [ 7 days 4.8.2.2, 4.8.2.4.1 required AC, DC, and AC vital bus electrical power vital distribution subsystems. OR 1

, and DG DC In accordance 3 with the Surveillance Frequency Control Program ]

SEQUOYAH UNIT 2 Amendment XXX Westinghouse STS 3.8.10-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 622 of 638

Enclosure 2, Volume 13, Rev. 0, Page 623 of 638 3.8.10 1

INSERT 1 B. One or more required B.1 Declare associated DG(s) Immediately DOC A02 DG DC electrical power inoperable.

distribution subsystems inoperable.

Insert Page 3.8.10-2 Enclosure 2, Volume 13, Rev. 0, Page 623 of 638

Enclosure 2, Volume 13, Rev. 0, Page 624 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. ISTS SR 3.8.10.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.10.1 is "In accordance with the Surveillance Frequency Control Program."

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 624 of 638

Enclosure 2, Volume 13, Rev. 0, Page 625 of 638 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 13, Rev. 0, Page 625 of 638

Enclosure 2, Volume 13, Rev. 0, Page 626 of 638 Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown vital ,diesel generator (DG) DC, BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution 1 systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating." DG DC, APPLICABLE U The initial conditions of Design Basis Accident and transient analyses in 1 2 SAFETY the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), assume vital ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, 1 and AC vital bus electrical power distribution systems are designed to 1 provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

vital DG DC, The OPERABILITY of the AC, DC, and AC vital bus electrical power 1 distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

vital DG DC, The OPERABILITY of the minimum AC, DC, and AC vital bus electrical 1 power distribution subsystems during MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies ensures that: 2

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents 2 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.10-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 626 of 638

Enclosure 2, Volume 13, Rev. 0, Page 627 of 638 Distribution Systems - Shutdown B 3.8.10 BASES LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents [involving handling recently irradiated fuel]). 2 APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [recently] 2 irradiated fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available,
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

vital DG DC, The AC, DC, and AC vital bus electrical power distribution subsystems 1 requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.10-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 627 of 638

Enclosure 2, Volume 13, Rev. 0, Page 628 of 638 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

A.1, A.2.1, A.2.2, A.2.3, and A.2.4 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and operations 2 involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be 3 inoperable. In this case, Required Actions A.2.1 through A.2.4 do not 3 adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be 4 entered. Therefore, Required Action A.2.5 is provided to direct declaring 3 and not in operation RHR inoperable, which results in taking the appropriate RHR actions.

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.10-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 628 of 638

Enclosure 2, Volume 13, Rev. 0, Page 629 of 638 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in INSERT 1 order to minimize the time the unit safety systems may be without power. 1 SURVEILLANCE SR 3.8.10.1 REQUIREMENTS vital DG DC, boards This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution subsystems are functioning properly, with all the buses 1 energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses.

[ The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. 4 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [6].

1 2

2. FSAR, Chapter [15].

SEQUOYAH UNIT 1 Revision XXX Westinghouse STS B 3.8.10-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 629 of 638

Enclosure 2, Volume 13, Rev. 0, Page 630 of 638 3.8.10 1

INSERT 1 B.1 If one or more required DG DC electrical power distribution subsystems are inoperable, the associated DGs may be incapable of performing their intended function and must be immediately declared inoperable. This declaration also requires entry into the applicable Conditions and Required Actions for inoperable DGs, LCO 3.8.2, "AC Sources - Shutdown."

Insert Page B 3.8.10-4 Enclosure 2, Volume 13, Rev. 0, Page 630 of 638

Enclosure 2, Volume 13, Rev. 0, Page 631 of 638 Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown vital ,diesel generator (DG) DC, BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution 1 systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating." DG DC, APPLICABLE U The initial conditions of Design Basis Accident and transient analyses in 1 2 SAFETY the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), assume vital ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, 1 and AC vital bus electrical power distribution systems are designed to 1 provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

vital DG DC, The OPERABILITY of the AC, DC, and AC vital bus electrical power 1 distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

vital DG DC, The OPERABILITY of the minimum AC, DC, and AC vital bus electrical 1 power distribution subsystems during MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies ensures that: 2

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents 2 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.10-1 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 631 of 638

Enclosure 2, Volume 13, Rev. 0, Page 632 of 638 Distribution Systems - Shutdown B 3.8.10 BASES LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents [involving handling recently irradiated fuel]). 2 APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [recently] 2 irradiated fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 2 critical reactor core within the previous [X] days)] are available,
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

vital DG DC, The AC, DC, and AC vital bus electrical power distribution subsystems 1 requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.10-2 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 632 of 638

Enclosure 2, Volume 13, Rev. 0, Page 633 of 638 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

A.1, A.2.1, A.2.2, A.2.3, and A.2.4 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and operations 2 involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be 3 inoperable. In this case, Required Actions A.2.1 through A.2.4 do not 3 adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be 4 entered. Therefore, Required Action A.2.5 is provided to direct declaring 3 and not in operation RHR inoperable, which results in taking the appropriate RHR actions.

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.10-3 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 633 of 638

Enclosure 2, Volume 13, Rev. 0, Page 634 of 638 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in INSERT 1 order to minimize the time the unit safety systems may be without power. 1 SURVEILLANCE SR 3.8.10.1 REQUIREMENTS vital DG DC, boards This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution subsystems are functioning properly, with all the buses 1 energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses.

[ The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. 4 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.


REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.


]

U REFERENCES 1. FSAR, Chapter [6].

1 2

2. FSAR, Chapter [15].

SEQUOYAH UNIT 2 Revision XXX Westinghouse STS B 3.8.10-4 Rev. 4.0 1 Enclosure 2, Volume 13, Rev. 0, Page 634 of 638

Enclosure 2, Volume 13, Rev. 0, Page 635 of 638 3.8.10 1

INSERT 1 B.1 If one or more required DG DC electrical power distribution subsystems are inoperable, the associated DGs may be incapable of performing their intended function and must be immediately declared inoperable. This declaration also requires entry into the applicable Conditions and Required Actions for inoperable DGs, LCO 3.8.2, "AC Sources - Shutdown."

Insert Page B 3.8.10-4 Enclosure 2, Volume 13, Rev. 0, Page 635 of 638

Enclosure 2, Volume 13, Rev. 0, Page 636 of 638 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10 BASES, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes are made to the Bases to reflect the Specification.
4. ISTS SR 3.8.10.1 (ITS SR 3.8.10.1) provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program. Therefore, the Frequency for ITS SR 3.8.10.1 is "In accordance with the Surveillance Frequency Control Program."
5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 636 of 638

Enclosure 2, Volume 13, Rev. 0, Page 637 of 638 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 13, Rev. 0, Page 637 of 638

Enclosure 2, Volume 13, Rev. 0, Page 638 of 638 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 13, Rev. 0, Page 638 of 638