NL-12-2142, License Amendment Request for Degraded Voltage Protection Modification Schedule

License Amendment Request for Degraded Voltage Protection Modification Schedule

ML12356A470
Person / Time
Site:	Farley
Issue date:	12/21/2012
From:	Ajluni M Southern Nuclear Operating Co, Southern Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-12-2142
Download: ML12356A470 (15)

Text

Mark J. Ajluni, P.E. Soutbem Nuclear Nuclear Lice nsing Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 SOUTHERN ' \

December 21, 2012 COMPANY Docket Nos.: 50-348 NL-12-2142 50-364 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Facility Operating License Amendment Request for Degraded Voltage Protection Modification Schedule Ladies and Gentlemen:

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) proposes to revise the Farley Nuclear Plant (FNP) Unit 1 and Unit 2 Facility Operating Licenses (FOL), NPF-2 and NPF-8.

On December 19, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued an NRC Component Design Bases Inspection (CDBI) Report to FNP (Reference 1 of Enclosure 1). The report included details of an Unresolved Item (URI 2011010-10, "Administrative Controls in lieu of Automatic Actions for Degraded Voltage Protection") regarding the licensee's use of administrative controls in lieu of automatic degraded voltage protection to assure adequate voltage to safety related equipment during design basis events. Based on this URI, a design modification will be implemented to remove dependence on manual operator action. The proposed FOL amendment would incorporate the Degraded Voltage Protection modification scheduled completion dates.

This FOl change is also a result of discussions between SNC and the NRC staff concerning the degraded voltage protection scheme at Plant Hatch and the use of administrative controls for degraded conditions, since FNP has a similar issue.

This FOl change documents SNC's commitment to redesign the current degraded voltage protection scheme to eliminate the use of administrative controls at FNP.

A discussion of the proposed FOl change, the basis for the change, and Significant Hazards Considerations are provided in Enclosure 1. Enclosures 2 and 3 provide the marked up FOl and clean typed pages of the FOl, respectively, for FNP. SNC has evaluated the proposed FOl change and has

u.s. Nuclear Regulatory Commission NL-12-2142 Page 2 determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92.

In accordance with 10 CFR 50.91, SNC is notifying the State of Alabama of this License Amendment Request by transmitting a copy of this letter and enclosures to the designated State Official.

SNC requests approval of the proposed license amendments by June 30, 2013.

The proposed changes will be implemented within 60 days of issuance of the amendment.

Mr. M. J. Ajluni states he is Nuclear Licensing Director of SNC, is authorized to execute this oath on behalf of SNC and , to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please contact Doug McKinney at (205) 992-5982.

Respectfully submitted, ~....

M. J. Ajluni Nuclear Licensing Director

\ Notary Public My commission expires: 11- z. -z 0 13 MJAlJMC

Enclosures:

1. Basis for Proposed Changes

2. FNP Facility Operating License Markup Pages

3. FNP Facility Operating License Clean Typed Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CFA04.054

U.S. Nuclear Regulatory Commission NL-1 3

Mr. V. M. McCree, Regional Administrator Ms. E. A. Brown, NRR Project Manager - Farley Mr. J. R. Sowa, Resident Inspector - Farley Mr. P.K. Niebaum, Senior Resident Inspector Farley

Joseph M. Farley Nuclear Plant, Units 1 and 2 Facility Operating License Amendment Request for Degraded Voltage Protection Modification Schedule Enclosure 1 Basis for Proposed Changes to Nl-12-2142 Basis for Proposed Changes

1. Summary Description This evaluation supports a to amend Facility Operating Licenses, NPF-2 and NPF-8, for Joseph M. Farley Nuclear Plant (FI\IP) Unit 1 and Unit 2, respectively.

The proposed License Amendment Request (LAR) would revise the FNP Facility Operating Licenses (FOL), Appendix C, to Southern Nuclear Operating Company (SNC) to fully implement and maintain in effect Degraded Voltage Protection modification schedule.

2. Detailed Description This LAR includes a proposed change to to implement a Degraded Voltage Protection modification. a Nuclear Regulatory Commission (NRC)

Component Design Basis Inspection (CDBI) report on December 1 2011 (Reference 1), FNP received an Unresolved Item regarding the use of administrative controls in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events.

SNC's project plan includes proposed modifications to Degraded Voltage (DVRs), possible replacement of the Loss of Offsite Power (LOSP) relays, and installation of new cabinets to house the relays. The modifications will ensure sufficient voltage is available to ensure safety-related loads will remain operable during a degraded voltage condition. A proposed schedule for implementation of the Degraded Voltage Protection modifications is provided in the Technical Evaluation SNC to NRC letter dated September 28, 2012 provided a modification schedule and stated a request change would be submitted by December 31,201 This change to FNP FOLs will ensure modifications are completed, as scheduled, in a timely and efficient manner.

3. Technical Evaluation Successful operation of the required functions of the Safety Features (ESF) is dependent upon the availability of adequate power sources for energizing the various components such as pump motors, motor operated valves, and associated control components. Offsite power is the preferred source of power for the 4160V emergency buses which power the required components. The Loss of Power (LOP) protection instrumentation monitors voltage on the F and G 4160V buses. Each electrical train has independent LOP instrumentation and relay actuation logic for detecting degraded grid or loss of voltage conditions, and initiating an LOP emergency diesel generator (EDG) start signal.

There are three LOP protection instrumentation actuation levels. An alarm sounds at a set point that is no less than 3850V, on detection of degraded voltage. At no than 3675V a LOP signal is generated for sustained degraded grid voltage. At no less than 3255V a LOP signal is generated for near instantaneous loss of voltage conditions.

Actuation of the degraded grid or of voltage will automatically disconnect the 4160V emergency from the offsite power source.

E1 -1 to NL-12-2142 Basis for Proposed Changes An administrative limit is established at a voltage level between the degraded grid voltage alarm allowable value and the automatic degraded grid voltage actuation upper allowable value. In the voltage range between the administrative limit and the degraded grid voltage actuation trip setpoint, a few ESF components may not have automatic protection from inadequate voltage. The manual actions provide the primary means of protecting these few ESF components from a sustained, slightly low voltage condition and all components from unnecessary automatic disconnection from the preferred offsite power source.

Based on an Unresolved Item from an NRC CDBI report, FNP's current Degraded Voltage Protection System requires upgrades because the system currently relies upon administrative controls to assure adequate voltage to safety-related equipment during design basis events. FNP automatic degraded voltage protection scheme employs automatic setpoints that are too low to assure operability of all safety-related electrical equipment in case of a sustained degraded grid voltage condition and instead relies on administrative controls to assure adequate voltage to safety-related equipment during an accident.

The electrical distribution system for each unit is capable of providing sufficient margin between the minimum expected bus voltage and the voltage level required by the loads, but will require a new DVR set point. The design of the existing DVRs does not allow resolution of this issue through set point adjustment.

The proposed modifications include replacement of DVRs, replacement of the LOSP relays, and installation of new cabinets to house the relays. This project will ensure sufficient voltage is available to ensure safety-related loads will remain operable during a degraded voltage condition.

Work scope and schedule are as follows:

2013 January Planning Starts 2013 July Design Starts 2015 January Complete Design and Begin Implementation Preparation 2015 January Submit Technical Specification Amendments 2016 January Issuance of Technical Specification -Amendments 2016 U2R24 U2 Spring Outage - Unit 2 Design Implementation Starts 2016 U1 R27 U1 Fall Outage - Unit 1 Design Implementation Starts 2017 U2R25 U2 Fall Outage - Unit 2 Completion 2018 U1 R28 U1 Spring Outage - Unit 1 Completion The implementation schedule above is slightly different from the schedule provided in the SNC letter to the NRC dated September 28,2012 due to further fine-tuning of the plan; however, the completion dates have not changed. This schedule allows time for detailed design completion and time to develop the engineering basis for the technical specification (TS) amendment request. This timeframe also accounts for coordination of outage activities. Two outages are necessary to complete the modifications on each unit based on FNP's philosophy that limits electrical modifications to one electrical train per outage. Non critical path work activities performed at power are not included in the above schedule.

The implementation schedule and proposed completion dates do not pose a threat to safety due to current administrative controls that will remain in place until the completion of the modifications and TS amendments occur.

E1 -2 to NL-12-2142 Basis for Proposed Changes This lAR includes the proposed change to FNP FOls, Appendix C. A marked up copy of FNP FOls reflecting the proposed changes are provided in Enclosure 2. A clean typed copy of FNP FOls with changes incorporated is provided in Enclosure 3.

4. Regulatory Evaluation 4.1 No Significant Hazards Consideration Determination Southern Nuclear Operating Company (SNC) is requesting an amendment to the Farley Nuclear Plant (FNP) Facility Operating Licenses (FOl), Appendix C, to include a Degraded Voltage Protection modification schedule. This modification is in response to an NRC Unresolved Item regarding the use of administrative controls in lieu of automatic degraded voltage protection to assure adequate voltage to safety related equipment during design basis events.

SNC has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change to the FNP FOl that incorporates the Degraded Voltage Protection modification implementation schedule is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested or inspected.

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

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

Response: No.

The proposed change to the FNP FOl that incorporates the Degraded Voltage Protection modification implementation schedule is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested or inspected.

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

E1 -3 to NL-12-2142 Basis for Proposed Changes

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

Response: No.

Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. The proposed change to the FNP FOL is administrative in nature.

Because there is no change to these established safety margins as a result of this change, the proposed change does not involve a significant reduction in a margin of safety.

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

Based on the above, SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Applicable Regulatory Requirements/Criteria This license amendment request is submitted to ensure compliance with applicable provisions of 10 CFR 50.55a(h)(2) and 10 CFR Part 50, Appendix A, General Design Criterion 17 - Electric Power Systems.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. Environmental Considerations SNC has evaluated the proposed amendment and determined that the amendment does not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in the individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to the 10 CFR 51.22(b), an environmental assessment of the proposed amendment is not required.

6. References

1. Letter from Rebecca Nease, U.S. Nuclear Regulatory Commission, to T.A. Lynch, SNC Farley Nuclear Plant, "Joseph M. Farley Nuclear Plant, NRC Component Design Bases E1-4 to NL-12-2142 Basis for Proposed Changes Inspection - Inspection Report 05000348/2011010 and 05000364/2011010," dated December 19, 2011.

2. Letter from M.J. Ajluni, SNC, to NRC, "Joseph M. Farley Nuclear Plant - Units 1 and 2 Administrative Controls in Lieu of Automatic Actions for Degraded Grid Protection Implementation Schedule," dated September 28, 2012.

E1 -5

Joseph M. Farley Nuclear Plant, Units 1 and 2 Facility Operating License Amendment Request for Degraded Voltage Protection Modification Schedule Enclosure 2 FNP Facility Operating License Markup Pages

APPENDIX C ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-2 Amendment Condition Completion Number Additional Condition Date 146 The schedule for performing new and revised Concurrent with Surveillance Requirements (SRs) shall be as the implementation of follows: the Improved Technical

1. For SRs that are new in this amendment Specifications.

the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

SNC shall implement the

3. For SRs that existed prior to this Degraded Voltage modifications to amendment that have modified eliminate the manual actions in acceptance criteria, the first performance lieu of automatic degraded voltage is due at the end of the first surveillance protection to assure adequate interval that began on the date the voltage to safety-related surveillance was last performed prior to equipment during design basis the implementation of this amendment.

events.

4. For SRs that existed prior to this amendment whose intervals of Unit 1 2018 Spring performance are being extended, the first Outage, U1 R28 extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

-2 Amendment No. +4e

APPENDIX C ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-8 Amendment Condition Completion Number Additional Condition Date 137 The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as implementation of follows: the Improved Technical

1. For SRs that are new in this amendment Specifications.

the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment. SNC shall implement the Degraded Voltage modifications to

3. For SRs that existed prior to this eliminate the manual actions in amendment that have modified lieu of automatic degraded voltage acceptance criteria, the first performance protection to assure adequate is due at the end of the first surveillance voltage to safety-related interval that began on the date the equipment during design basis surveillance was last performed prior to the implementation of this amendment. events.

4. For SRs that existed prior to this amendment whose intervals of performance are being extended, the first Unit 2 2017 Fall extended surveillance interval begins Outage, U2R25 upon completion of the last surveillance performed prior to implementation of this amendment.

Amendment No. +37

Joseph M. Farley Nuclear Plant, Units 1 and 2 Facility Operating License Amendment Request for Degraded Voltage Protection Modification Schedule Enclosure 3 FNP Facility Operating License Clean Typed Pages

APPENDIX C ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-2 Amendment Condition Completion I\lumber Additional Condition Date 146 The schedule for performing new and revised Concu rrent with Surveillance Requirements (SRs) shall be as the implementation of follows: the Improved Technical

1. For SRs that are new in this amendment the Specifications.

first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

3. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

4. For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

SNC shall implement the Degraded Voltage Unit 1 2018 Spring modifications to eliminate the manual actions in Outage, U1 R28 lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events.

-2 Amendment No.

APPENDIX C ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-8 Amendment Condition Completion Number Additional Condition Date 137 The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as implementation of follows: the Improved Technical

1. For SRs that are new in this amendment Specifications.

the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

2. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

3. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

4. For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

SNC shall implement the Degraded Voltage Unit 2 2017 Fall modifications to eliminate the manual actions in Outage, U2R25 lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events.

Amendment No.