ML040430212

Response to Request for Additional Information Regarding License Amendment Request 03-01

ML040430212
Person / Time
Site:	Seabrook
Issue date:	02/09/2004
From:	Warner M Florida Power & Light Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NYN-04005, TAC MC0635
Download: ML040430212 (7)

Text

FPL Energy Seabrook Station FPL Energy P.O. Box 300 Seabrook, NH 03874 Seabrook Station (603) 773-7000 FEB 9 204 Docket No. 50-443 NYN-04005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Reference:

FPLE Seabrook Letter NYN-03069, Seabrook Station License Amendment Request 03-0l,"Changes to Electrical Power Systems - A.C. Sources Technical Specifications

- Inclusion of the Supplemental Emergency Power System," dated August 25, 2003.

Seabrook Station "Response to Request for Additional Information Regarding License Amendment Recquest 03-01" FPL Energy Seabrook, LLC (FPLE Seabrook) has enclosed herein its response to a request for additional information associated with License Amendment Request (LAR) 03-01. The additional information requested by the NRC is associated with FPLIE Seabrook's planned installation of a permanent non safety-related supplemental emergency power system (SEPS).

LAR 03-01 propose changes to the Seabrook Station Technical Specifications (TS) Allowed Outage Time (AOT) specified in TS 3/4.8.1.1. Specifically, FPLE Seabrook proposes to amend the AOT for TS 3/4.8.1.1 ACTIONs b., c. and f. from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a period of 14 days whenever the SEPS is available. In addition, a change is proposed to revise ACTION d. to allow extension of the current 2-hour time requirement to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for verification of redundant component Operability Should you have any questions concerning this response, please contact Mr. James M. Peschel, Regulatory Programs Manager, at (603) 773-7194.

Very truly yours, FPL ENERGY SEABROOK, LLC Mark E. Warner Site Vice President an FPL Group company

U. S. Nuclear Regulatory Commission NYN-04005/Page 2 Cc: H. J. Miller, NRC Region I Administrator V. Nerses, NRC Project Manager, Project Directorate 1-2 G. T. Dentel, NRC Senior Resident Inspector Mr. Bruce Cheney, Director New Hampshire Office of Emergency Management State Office Park South 107 Pleasant Street Concord, NH 03301 OATH AND AFFIRMATION I, Mark E. Warner, Site Vice President of FPL Energy Seabrook, LLC, hereby affirm that the information and statements contained within this response to the Request for Additional Information to License Amendment Request 03-01 are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Sworn and Subscribed before me this 7j day of e ru' ,2004 Mark E. Warner Site Vice President I N}tary Public

Enclosure to NYN-04005 Response to Request for Additional Information Seabrook Station, Unit No. I (TAC NO. MC0635)

NRC Request 1:

If a full-load reject test is performed at power, describe the typical and worst-case voltage transients on the 4160V safety busses as a result of the full-load rejection.

FPLE Seabrook Response to NRC Request 1:

Performance of a full load rejection test to demonstrate EDG Operability is governed by TS 4.8.1.1.2f. sub-step 3). This surveillance test, as with all surveillance tests performed under TS 4.8.1.1.2f., is normally performed during shutdown. However, TS 4.8.1.1.2.f. is conditioned by footnote ## which allows selected surveillance requirements or portions thereof to be performed during conditions or modes other than shutdown provided an evaluation supports safe conduct of that surveillance in a condition or mode that is consistent with safe operation. The footnote is reflective of NRC Generic Letter 91-04. Thus, FPLE Seabrook is required by license to perform such an evaluation prior to performance of a full load rejection test while at power.

Seabrook Station has experienced a EDG full-load rejection with the plant at 100% power. On July 26, 2002, DG-1B was paralleled to offsite power to conduct a maintenance retest. The maintenance retest was to determine satisfactory operation following the replacement of a defective output resistor associated with the voltage regulator. During the maintenance retest DG-IB was manually tripped from full load following recurrence of kVAR fluctuations. Bus voltage wvas 4160V+/- 420V during the occurrence. The voltage values were well within the TS 4.8.1.1.2f.3) acceptance criteria.

NRC Request 2:

Please provide a one-line diagram of the proposed plant configuration (i.e., with the supplemental emergency power system (SEPS) installed.

FPLE Seabrook Response to NRC Request 2:

See attached diagram.

I

NRC Request 3:

Describe the compensatory measures that will be implemented when the emergency diesel generator (EDG) is removed from service for maintenance utilizing the 14-day extended allowed outage time (AOT).

FPLE Seabrook Response to NRC Request 3:

LAR 03-01 describes the compensatory measures that will be implemented when the EDG is removed from service for maintenance utilizing the 14-day extended AOT. The compensatory measures are summarized as follows:

• SEPS will be verified "operationally ready" (available and properly aligned) prior to exceeding the standard 72-hour AOT and will continue to be surveilled/verified "operationally ready" at least once every 72-hours during the extended AOT, up to 14 days.

• Before voluntarily entering the LCO Action to perform extended EDG maintenance and during the outage, grid and environmental conditions will be evaluated to ensure that sufficient time is available for restoration, when needed. The intent will be to minimize the time vhen the EDG is out of service under conditions that could significantly threaten the offsite power sources.

• Operability of offsite power sources will be continually surveilled at a frequency of at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as required by TS 3.8.1.1 ACTION b.

• TS 3.8.1.1 ACTION Statement d., which is linked by ACTION b. (and c.), ensures that required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also verified OPERABLE within a 2-hour (proposed 4-hour) window whenever an EDG is inoperable.

• The risk impact of performing maintenance of up to 14 days would be managed through FPLE Seabrook's on-line maintenance program and procedures in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants."

• FPLE Seabrook implements a "Protected Train" concept to administratively control pre-planned maintenance to avert the potential of accidentally causing standby/required safety equipment to be inoperable/unavailable due to scheduling or personnel errors. The Protected Train concept ensures that prior to removing an EDG from service for performing preplanned maintenance, maintenance activities associated with required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are either not performed or limited in scope to assure rapid return to Operability status.

• Should emergent work associated with other SSCs occur during the extended EDG AOT, the work activity would be reviewed for risk impact either qualitatively or quantitatively via the Safety Monitor. If these emergent work activities increase risk, steps would be taken to restore any equipment that affects plant safety.

2

• To ensure that an unsafe transient condition on the emergency bus (i.e., load swing or voltage transient) does not occur, post-maintenance testing on the EDG is performed in progressive steps to verify that maintenance or repair was properly performed. This testing is designed to identify maintenance-induced problems while the EDG is separated from the electrical system, thus preventing system transients from occurring.

• On loss of offsite power, the SEPS gensets will auto-start and come up to rated speed and voltage and synchronize automatically. The emergency operating procedure (ECA 0.0, Loss of All AC Power) for loss of power will be entered directing the necessary operator actions to manually energize the proper emergency bus. The control room operator will load the emergency bus based on a predetermined loading schedule per ECA 0.0.

NRC Request 4:

If at any time during the extended EDG AOT the SEPS was to become inoperable, what course of action would be taken and how will the SEPS be returned to operable status (i.e., verified)?

FPLE Seabrook Response to NRC Request 4:

The proposed TS changes states: "(b) If at any time the SEPS availabilitycannot be met, either restore the SEPS to availablestatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (not to exceed 14 days from the time the diesel generatororiginally became inoperable), 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 SHUTDOJVN within thefollowing 30 houirs." (Refer to page 5)

Page 7 states: "The proposed iordingto ACTION b. and its associatedBases address the extension of the inoperableEDG 72-hourAOTto 14 days provided that the SEPS is available.

Other conditions / constraints are also imposed to ensure that f at anytime the SEPS becomes unavailableduring the extended 14-day AOT the SEPS must be restoredto availablestatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, otherwise the plant must be placed in Cold Shutdovn within the stated time constraints. In addition, ACTIONb. notes thatthe totalAOTof 14 daysfrom the time the EDG originallybecame inoperableis not to be exceeded. These additionalconstraintsare to ensure that the impact to overallplantrisk is managed and maintained within the assumptions used to derive andjustify extending the inoperable EDG A OT whenever the SEPS is available."

The LCO of Technical Requirement (TR) 31 states: "he Supplemental Emergency Power System (SEPS) shall be availablefor standby service." TR 31 ACTION a. states: " With the requirements of the LCO not satisfied, initiate corrective action to restore the SEPS to available statis in a timely fashion." SEPS operational availability is monitored/assured by ensuring that the surveillance requirements of Technical Requirement 31 are satisfied. TR3 1-4.1 is specifically for demonstrating SEPS availability. This is similar to how Operability is verified for TS required components when returned to service following maintenance. (Refer to LAR 03-01 Attachment 1) 3

TRAIN A Control Bldg. -V Waste Proc. Bldg TRAIN A I

TRAIN B I ASSOCIATED I I RAT-3A UAT-2A RAT-3B UAT-2B I

I A52 ) f A51 ) NC I A72 ) NO A71 ) NC 480 V BUS I 4160 V BUEiE5 I I l 4160 V BUS E6 I MCC-1 52 I NO i KGD) NO NO ) K3 I

NC.) <(9 I

I I NOTE I I NOTE 1 I

I I

6) DG-1A I 4) DG-11B I

I

- - - - - - - I _- - - _

I TransferlSelector Switch SEPS-CP-1 TRAIN B ASSOCIATED I

_ I

_ I

,I

• l , l Remote Mon. &

Ctrl. Pnl.

NOTE I \ NOTE I SEPS-CP-2 X ___________________ ___ .

• I TRAIN B ASSOCIATED <W NCI 4160 V BUS SEPS-SWG-1 I I I I NO ) NO ) ) NC 3750 KVA SEPS-X-1 I I 4 480 V SEPS-PP-1 L- - - -

I I

SEPS-DG-2A SEPS-DG-2B NC')

I Digital Master Control Panel SEPS-CP-4 1- -

II SEPS-CP-3

<3i I

I I

(E> I L- I SEPS SEPS S-PP-2 I

SEPS-MM-968 SEPS-MM-969 I FN- FN- I 216A 216B

,I Load Bank I NC) I DG Cooling Fan Motors I I- - - *

- - - 1 SEPS Aux. I NOTE 1: BUS E5 AND E6 UTILIZE A KIRK KEY INTERLOCK WHICH ALLOWS ONLY ONE BREAKER TO BE RACKED IN I Loads I AT ANY TIME. THE NON-SAFETY TRANSFER SWITCHES ARE INTERLOCKED WHICH ALLOWS ONLY ONE SWITCH I J TO BE CLOSED AT ANY ONE TIME. SEPS Simplified Electrical One Line Diagram