ML13232A143

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Issuance of Amendment Nos. 160 and 160, Revise Technical Specification 3.8.1, AC Sources - Operating, for Extension of Two 14-Day Completion Times for Offsite Circuits
ML13232A143
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 09/18/2013
From: Balwant Singal
Plant Licensing Branch IV
To: Flores R
Luminant Generation Co
Singal B
References
TAC MF0405, TAC MF0406
Download: ML13232A143 (24)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 18, 2013 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: REVISION TO TECHNICAL SPECIFICATION 3.8.1, "AC SOURCES - OPERATING," FOR TWO 14-DAY COMPLETION TIMES FOR OFFSITE CIRCUITS (TAC NOS. MF0405 AND MF0406)

Dear Mr. Flores:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 160 to Facility Operating License No. NPF-87 and Amendment No. 160 to Facility Operating License No. NPF-89 for Comanche Peak Nuclear Power Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 19, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13023A237), as supplemented by letter dated May 16, 2013 (ADAMS Accession No. ML13149A257).

The amendments revise TS 3.8.1, "AC [Alternating Current] Sources - Operating," to extend the Completion Time (CT) for Required Action A.3, "Restore required offsite circuit to OPERABLE status," on a one-time basis from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The CT extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days will be used twice while completing the plant modification to install alternate startup transformer XST1A and will expire on March 31, 2014.

R. Flores - 2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

~'"'"\~\~~

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 160 to NPF-87
2. Amendment No. 160 to NPF-89
3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT. UNIT NO.1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 160 License No. NPF-87

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Luminant Generation Company LLC dated December 19, 2012, as supplemented by letter dated May 16,2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-87 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 160 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Luminant Generation Company LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan as indicated in the attachment to this license amendment.

3. The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-87 and Technical Specifications Date of Issuance: September 18, 2013

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NO.2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 160 License No. NPF-89

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Luminant Generation Company LLC dated December 19, 2012, as supplemented by letter dated May 16,2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regUlations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-89 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 160 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Luminant Generation Company LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-89 and Technical Specifications Date of Issuance: September 18, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 160 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 160 TO FACILITY OPERATING LICENSE NO. NPF-89 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of the Facility Operating License Nos. NPF-87 and NPF-89, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. NPF-87 REMOVE INSERT 3 3 Facility Operating License No. NPF-89 REMOVE INSERT 3 3 Technical Specifications REMOVE INSERT 3.8-2 3.8-2

- 3 (3) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission=s regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Luminant Generation Company LLC is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal through Cycle 13 and 3612 megawatts thermal starting with Cycle 14 in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 160 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Luminant Generation Company LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Unit 1 Amendment No. 160

- 3 (3) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Luminant Generation Company LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission=s regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Luminant Generation Company LLC is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal through Cycle 11 and 3612 megawatts thermal starting with Cycle 12 in accordance with the conditions specified herein.

(2) Technical SpeCifications and Environmental Protection Plan The Technical SpeCifications contained in Appendix A as revised through Amendment No. 160 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Luminant Generation Company LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions DELETED Unit 2 Amendment No. 160

AC Sources -- Operating 3.8.1 ACTIONS

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit A.1 Perform SR 3.8.1.1 for required 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.

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 A.2 -------------------NOTE-------------------

In MODES 1, 2 and 3, the TDAFW pump is considered a required redundant feature.

Declare required feature(s) with no 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery offsite power available inoperable of no offsite power to when its redundant required one train concurrent feature(s) is inoperable. with inoperability of redundant required feature(s)

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

OR 14 days for two one time outages on XST1 to complete a plant modification to be completed by March 31, 2014.

COMANCHE PEAK - UNITS 1 AND 2 3.8-2 Amendment No. 160, 162, 160

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 160 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 160 TO FACILITY OPERATING LICENSE NO. NPF-89 LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION

By application dated December 19, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13023A237), as supplemented by letter dated May 16, 2013 (ADAMS Accession No. ML13149A257), Luminant Generation Company LLC (the licensee) requested changes to the Technical Specifications (TSs) for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2. The amendments modify TS 3.8.1, "AC [Alternating Current] Sources - Operating," to extend the Completion Time (CT) for Required Action A.3, "Restore required offsite circuit to OPERABLE status," on a one-time basis from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The CT extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days will be used twice while completing the plant modification to install alternate startup transformer (ST) XST1A and will expire on March 31, 2014. After completion of this modification, if ST XST1 should require maintenance or if failure occurs, the alternate ST XST1A can be aligned to the Class 1E buses well within the current CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The request for extension of the allowable CT for the inoperable offsite circuit associated with ST XST1 is based on the following three elements: 1) a traditional (deterministic, defense-in depth) engineering analysis, 2) avoidance of risk-significant plant configurations using mitigation measures, and 3) implementation of a Configuration Risk Management Program (CRMP) during the two, one-time, 14-day extended CTs.

The supplemental letter dated May 16, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 4, 2013 (78 FR 14131).

Enclosure 3

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2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 17 (General Design Criteria (GDC 17>>, "Electric power systems," requires, in part, that An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety ....

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

GDC 18, "Inspection and testing of electric power systems," requires, in part, that Electric power systems important to safety shall be deSigned to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components.

GDC 5, "Sharing of structures, systems, and components," requires that Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

- 3 Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The regulatory requirements related to the content of the TSs are contained 10 CFR 50.36, "Technical specifications." The regulation in 10 CFR 50.36 requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The regulation requires, in part, that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings and control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls. The proposed change to the CPNPP, Units 1 and 2, relates to the LCO category.

The regulations in 10 CFR 50.63, "Loss of all altemating current power," paragraph (a),

requires, in part, requires that each light-water cooled nuclear power plant licensed to operate "must be able to withstand for a specified duration and recover from a station blackout."

The regulations in 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," paragraph (a)(4), requires, in part, that before performing preventative maintenance activities, "the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities."

Regulatory Guide (RG) 1.93, "Availability of Electric Power Sources," December 1974 (ADAMS Accession No. ML003740292), provides guidance with respect to operating restrictions or CT if the number of available AC sources is less than that required by the TS LCO. In particular, this guide recommends a maximum CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable onsite or offsite AC source.

RG 1.155, "Station Blackout," August 1988 (ADAMS Accession No. ML003740034), provides guidance for complying with the 10 CFR 50.63 that requires nuclear power plants to be capable of coping with a station blackout (SBO) event for a specified duration.

RG 1.177, Revision 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," May 2011 (ADAMS Accession No. ML100910008), describes an acceptable risk-informed approach for assessing proposed changes to TS Allowed Outage Time, or termed as CT.

NUREG-0800, Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," February 2012 (ADAMS Accession No. ML113640138), provides guidance to the NRC staff in reviewing license amendment requests (LARs) for licensees proposing a one-time or permanent TS change to extend an emergency diesel generator (EDG) allowed outage time (AOT) beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

3.0 TECHNICAL EVALUATION

3.1 Description of CPNPP, Units 1 and 2, Offsite and Onsite AC Power System The CPNPP, Units 1 and 2, offsite power system is comprised of 138 kiloVolt (kV) and 345 kV systems. The 138 kV switch yard is physically and electrically independent of the 345 kV switchyard. The offsite power is the preferred source of power to the Class 1E buses.

-4 Two physically independent and redundant sources of offsite power circuits are available on an immediate basis for the safe shutdown of either unit. The normal offsite source for 6.9 kV Class 1E buses of Unit 1 is the 345 kV offsite supply from the 345 kV switchyard via ST XST2 (or spare XST2A if XST2 is unavailable). The normal offsite source for 6.9 kV Class 1E buses of Unit 2 is the 138 kV offsite supply from the 138 kV switchyard via ST XST1. The alternate offsite source to 6.9 kV Class 1E buses of Unit 1 is from ST XST1, and to 6.9 kV Class 1E buses of Unit 2 is from ST XST2 (or XST2A if XST2 is unavailable).

The offsite power sources supply power to the Class 1E buses during plant startup, normal operation, emergency shutdown, and upon a unit trip, thus eliminating the need for automatic transfer of safety-related loads in the event of a unit trip.

Each ST has the capacity to supply the required Class 1E loads of both units during all modes of plant operation. In the event that normal ST (e.g., XST1) becomes unavailable to the Class 1E buses, the power is immediately available from the alternate transformer (e.g., XST2) by an automatic transfer scheme. Each transformer is capable of supplying the required safe shutdown loads of both units.

Two independent and redundant 6.9 kV Class 1E buses are provided for each unit, each capable of supplying the required safety-related load$ to safely shut down the unit following a design-basis accident. Loss of both offsite power sources to any 6.9 kV Class 1E bus results in the diesel generator providing power to the associated Class 1E bus. The redundant safety related loads are divided between two trains of Class 1E buses so that loss of either train does not impact the minimum required safe shutdown equipment. Physical separation and electrical isolation are maintained between the two trains of Class 1E buses.

3.2 Proposed Plant Modifications and TS Changes If one required offsite circuit is inoperable, current TS 3.8.1 Required Action A.3 CT requires that the required offsite circuit be restored to operable status within:

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 14 days for a one-time outage on XST2 to complete a plant modification to be completed by March 1, 2011.

Revised TS 3.8.1 Required Action A.3 CT would state that the required offsite circuit be restored 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 14 days for two one-time outages on XST1 to complete a plant modification to be completed by March 31,2014.

- 5 In letter dated December 19, 2012, the licensee stated that currently, if ST XST1 required replacement, it would take about 18 to 21 days to replace XST1 with spare ST XST2A (with a dual voltage 345 kVand 138 kV primary winding). The duration is dependent on the mobilization/availability of heavy haulers, extent of transformer damage, and the availability of needed equipment and personnel to perform the work. Each ST provides one of the two required offsite AC sources for each unit. As required by current TS 3.8.1, an outage of XST1 (one required offsite circuit inoperable) for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires that both units be shut down to Mode 5.

The proposed one-time extended CT would allow the time needed for the installation/connection of new spare/alternate ST XST1A, and completion of the related modifications. After completion of this modification, if ST XST1 should require future maintenance or repair if a failure occurs, the spare/alternate XST1A can be quickly aligned to the plant distribution system, thus restoring the inoperable circuit associated with XST1 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (TS allowed CT), avoiding a shutdown of both units.

In letter dated December 19, 2012, the licensee stated that the proposed modification is, in general, similar to one previously approved by the NRC, on October 29, 2010 (ADAMS Accession No. ML102810130), that extended, on a one-time basis, the allowable CT for Required Action A.3 for the 345 kV inoperable offsite circuit, from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days, to facilitate installation of spare ST XST2A.

The proposed change would revise the TS 3.8.1, "AC Sources - Operating," Completion Time of Required Action A.3 to allow, on a one-time basis, two 14-day outages to complete a plant modification on ST XST1. The modifications are scheduled and must be completed by March 31,2014.

The licensee will perform modification work in three stages:

1. One 14-day CT (first requested CT) to complete the 138 kV modification work;
2. Perform the preparation, installation, and testing of the new spare/alternate transformer XST1A (existing 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed CT may be used for this work);

and,

3. Another 14-day CT (second requested CT) to complete the 6.9 kV modification work.

During the first requested 14-day CT, the 138 kV tower work will comprise of changes to the dead-end structure, installation of new air switches, insulators, lightning arresters, coupling capacitors, voltage transformers, carrier line equipment, and related wiring, connection, and testing. Subsequently, a 72-hour TS CT may be entered (which does not require TS change) during which Transformer XST1A will be moved to its permanent pad and connection will be made to the 138 kV bus. XST1A will be energized unloaded and related testing will be performed. Thereafter, the second requested 14-day CT will be used to install and terminate the 6.9 kV cables associated with XST1 and XST1A through transfer panels. After completion of these activities, XST1 will be restored and the offsite circuit will be restored to Operable. In

- 6 letter dated December 19, 2012, the licensee provided detailed description of each individual activity and the estimated time to complete each individual activity.

3.3 Supplemental Power Source The licensee has proposed a supplemental AC power source and various other compensatory measures, as defense-in-depth measures to meet the intent of BTP 8-8, to provide additional/maintain the safety margin against any extended loss-of-offsite power (LOOP) event coincident with unavailability of both EDGs in a Single unit.

The supplemental power source will consist of three (3) Alternate Power Diesel Generators (APDGs) per unit. The three APDGs, each rated at 1140 kiloWatts (kW), will operate in parallel as a set providing a combined output of approximately 3420 kW (4275 kiloVolt Amps (kVA)).

For each unit, the APDGs rated at 480 Volts (V) will provide power through a 480 V/6900-V transformer which may be loaded to 3450 kVA. The transformer can be connected to either of the 6.9 kV Class 1E bus through a manual transfer switch in each unit. The licensee stated that this supplemental power source is the same which was utilized while implementing the modifications previously approved by NRC by letter dated October 29, 2010.

During the proposed extended CTs, the APDGs would be available to provide an additional measure of defense-in-depth, beyond that required by the plant design and 10 CFR 50.63, in the unlikely event of a LOOP with concurrent unavailability of both EDGs on either unit. The APDGs would provide the ability to achieve and maintain cold shutdown for an extended LOOP event coincident with unavailability of both EDGs in a single unit.

The APDG sets are currently located in the station yard and are designed to be manually connected/provide feed to a 6.9 kV bus, if required within approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The APDGs will be manually connected to a 6.9 kV Class 1E bus only if that unit has no other source of power. The required loads on the APDGs can be connected manually.

As stated in the LAR, plant procedure SOP-614A1B, "Alternative Power Generator Operations,"

directs the operator to monitor the APDG set parameters (e.g., lube oil, engine coolant, fuel levels, transformer temperature, and liquid levels, etc.) on a shift basis to ensure the APDG set is ready to start. Once per month, the APDG sets are started, synchronized together, and operated in an unloaded condition to verify their availability. The APDGs have the capability to supply the necessary safety equipment in addition to being able to start the largest load. Within 2 weeks before entering a 14-day CT, the APDGs (one set per unit) will be tested to ensure the availability of the APDGs.

By letter dated May 16, 2013, the licensee provided the following supplemental information regarding APDGs:

  • A layout and the electrical connection details showing the connection of the APDGs to the plant 6.9 kV safety switchgear.
  • APDG fuel will be replenished every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, per the plant procedure SOP-614 AlB, "Alternate Power Generator Operation." If power remains

-7 available in the fuel island, the electric transfer pump can fill the 2,000-galion refueling truck from the fuel island storage tank which is normally filled with 5,000-8,000 gallons. If power is not available in the fuel island, a gasoline powered pump rated at approximately 200 gallons per minute (gpm) can be used to fill the refueling truck from one of the four the EDG fuel oil storage tanks, each typically filled to greater than 86,000 gallons. This will administratively be done by the Control Room. If the gas powered pump becomes unavailable, the APDG refueling truck can be filled by use of one of the two air-pressure powered pumps rated at 100 gpm.

  • A Nuclear Equipment Operator will be assigned to ensure proper operation of the APDGs, during the proposed two 14-day CTs.
  • The maximum loading to APDG will be 3416 kVA, which will remain within the connected transformer rating of 3450 kVA. The common loads will be fed by the operable EDG and APDG will not be required to power the common loads.
  • Each APDG generator set contains a multifunction protection and control device with the capability to equally share real kW and reactive kVA load with other generators.
  • The APDG sets are designed with built-in leak detection and spill containment.

The APDG fuel tank fill point is external, which prevents diesel fuel from refueling activities from potentially coming in contact with a running diesel generator (DG) and hot DG components.

In the LAR, the licensee provided regulatory commitment to perform thermographic survey to verify no abnormalities exist in two fixed sources in the safeguards room. By letter dated May 16, 2013, the licensee clarified that the two fixed sources are motor control center (1EB1-1) and a 6.9 kV to 480 V transformer (T1 EB3). Because only XST2 will be in-service during the extended CTs, a fire in either of these two sources could result in loss of power to the in-service ST XST2, thus warranting additional preventative measures. Therefore, the licensee committed to perform thermographic surveys on these devices 14 days prior to start of the CTs.

The NRC staff reviewed the information provided by the licensee and concludes that the design of APDGs meets the intent of BTP 8-8 for supplemental power source.

3.4 Compensatory and Mitigation Measures By letter dated December 19,2013, the licensee provided several regulatory commitments described in Section 4.0, "Regulatory Commitments," to meet the guidance provided in BTP 8-8 to assure safe shutdown during inoperability of one offsite circuit associated with modifications related to XST1 and XST1A. The commitments are associated with the 138 kV and 6.9 kV switch yard work and are outlined in the Attachment to this safety evaluation.

- 8 The NRC staff has reviewed the commitments made by the licensee and concludes that the commitments meet the intent of BTP 8-8 to provide defense-in-depth during the two 14-day CTs.

In letter dated December 19, 2013, the licensee also stated that CPNPP has a CRMP which has the characteristics of the Model Configuration Risk Management Program described in the RG 1.177. To avoid or reduce the potential for risk-significant configurations from either emergent or planned work, CPNPP has put in place a set of administrative guidelines that provide additional operational configuration limitations. These guidelines control configuration risk by assessing the risk impact of equipment out-of-service during all modes of operation to assure that the plant is always being operated within the acceptable risk guidelines.

3.5 Summary The licensee is providing supplemental power source (APDGs), as a defense-in-depth, during the period of two, one-time, 14-day CTs due to the modification work associated with transformer XST1 and installation of a spare transformer XT1A consistent with the BTP 8-8 guidance. The staff reviewed the proposed APDGs information with respect to size, installation, auxiliaries, and connection to the existing electrical system. The APDGs have the capacity and capability to provide power for one train of shutdown equipment needed for safe shutdown and long-term cooling to respond to extended LOOP if loss of XST2 occurs and both EDGs of a unit fail to start and load as designed. The licensee also provided various regulatory commitments as a measure of defense-in-depth concept of BTP 8-8. The licensee has a CRMP which follows the key components of CRMP described in the RG 1.177. The NRC staff concludes that the proposed LAR meets the intent of the BTP 8-8, and the traditional engineering guidance provided in RG 1.177.

The NRC staff also reviewed whether the proposed TS changes will have any impact on the licensee's compliance with GDC 5, GDC 17, GDC 18,10 CFR 50.36, 10 CFR 50.65, and 10 CFR 50.63. The staff concluded that there is no adverse impact on continued compliance with these regulatory requirements. The licensee is also consistent with the guidance provided by RGs 1.93 and 1.155.

Based on the above, the NRC staff concludes that the proposed change to TS 3.8.1 Required Action A.3 CT to allow two, one-time, 14-day CTs to complete a plant modification on ST XST1, to be completed by March 31 , 2014, is acceptable. The staff also concludes that the proposed change will not impact the licensee's compliance with the 10 CFR 50.36,10 CFR 50.63, 10 CFR 50.65, and GDCs 5, 17, and 18. Installation of the alternate ST will result in improved plant design and improve the long-term reliability of the 138 kV offsite circuit ST.

4.0 REGULATORY COMMITMENTS The licensee made several regulatory commitments described in Attachment to this safety evaluation to comply with the guidance provided in BTP 8-8 to assure safe shutdown during inoperability of one offsite circuit associated with modifications related to XST1 and XST1A.

The NRC staff concluded that the regulatory commitments meet the intent of BTP 8-8 to provide defense-in-depth during the two 14-day CTs.

- 9

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on March 4, 2013 (78 FR 14131). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Swagata Som, NRRlDE/EEEB Date: September 18, 2013

Attachment:

Regulatory Commitments

REGULATORY COMMITMENTS i Commitment I Commitment Description Due DatelEvent

~umber

  • The Following Commitments Are Associated With The 138kV Work 4441997 louring a 14-day CT, the APDG provided for each Unit will During the be verified available to provide power to equipment for long 14-day CT for L t e r m cooling once per shift. the 138kV work.

14456419 louring a 14-day CT, if an APDG becomes unavailable, both During the units shall enter Condition C of TS 3.8.1 and start shutting .14-day CT for down within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. (This 24-hour period will only be ithe 138kV work.

,allowed once within a 14-day CT).

4442002 ,Prior to initiation of a one time, 14-day CT extension, PM Prior to the start

[preventive maintenance] task for breakers 1EA 1-1, 1EA2-1 , .of the 14-day CT i 2EA1-1 and 2EA2-2 will be verified as current. iforthe 138kV~'

  • work.

4442007 Testing of EDGs, APDGs, and TDAFWPs [turbine-driven Within two auxiliary feedwater pumps] will occur within the two (2) weeks prior to weeks prior to the start of the XST1 CT i the start of the

  • 14-day CT for the 138kV work 4442008 The EDGs, APDGs, TDAFWPs, XST2, CCWPs [component During the cooling water pumps], and SSWPs [station service water 14-day CT for pumps] will have ALL testing and maintenance activities the 138kV work.

suspended for the duration of a one-time, 14-day CT for XST1. Additionally, signs will be placed on the doorways to the equipment, or in the case of XST2 around the equipment, noting the restriction of testing and maintenance i

during this XST1 CT.

I 4442010 A roving hourly fire watch will be in effect during the 14-day During the XST1 CT along the path of the XST2 power and control 14-day CT for cabling. This is an additional measure to monitor the area the 138kV work.

for fires that could damage and disable the XST2 i transformer cabling.

4442011 ILocal weather conditions and forecasts will be monitored by During the i Operations twice per shift to assess potential impacts on 14-day CT for l - -_ _ _ _--+_pl_a_nt_c_o_ndltlons. ---+-'1 th_e_13_8kV work.

  • 4442013 A time in which severe weather is not expected will be During ~

,selected for implementation of the XST1 CT. Based on 14-daY,~:for_L I ihistorical information; this time frame is September 1 the 138kV work.

  • through March 31. This planned timing will reduce high I' wind/tornados and weather challenges to the plant during the XST1 CT.

~-----~----

Attachment

-2 Commitment Commitment Description Due Date/Event Number 4442016 The seismic walkdown will be completed prior to the XST1 Within two CT to identify any issues that could impact the EDGs and weeks prior to TDAFWPs during a seismic event. These impacts include the start of the mounting or interactions issues including loose parts and 14-day CT for missing hardware. This walkdown is for assurance that the 138kV work

,these components will meet their seismic design criteria in ,

the event of a seismic incident.

4442028 Access to both switchyards and relay houses will be I,prior to the start controlled and posted, and all maintenance will be  ! of the 14-day CT i suspended for the duration of the CT on XST1. ifor the 138 kV work 4442046 CPNPP's Operations Department will contact the During the Transmission Operator (Transmission Grid Controller) once 14-day CT for per day during a 14-day Completion Time to ensure no the 138kV work.

problems exist in the transmission lines feeding CPNPP or their associated switchyards that would cause post trip switchyard voltages to exceed the voltage required by STA-

  • 629.

4442047 Just-in-time training for affected work groups will be ~i~r to the start

.completed prior to the start of a XST1 outage. of the 14-day CT I

for the 138kV work 4442049 All hot work actIVIties along the routing associated With DUring a 14-day power and control cabling for XST2, the in-service ST, will CT for the 138kV be suspended during the XST1 CT. This is to reduce the work.

likelihood of fires that could damage and thus disable the XST2 transformer cabling.

4456879 In the two weeks prior to the start of the CT, a Within two thermographic survey will be conducted on the two fixed weeks prior to sources in the safeguards switchgear room to verify no  ! the start of the abnormalities exist. This is to reduce the likelihood of a fire i 14-day CT for

. *I ignition.

_ _ _ _ _ _ __ the 138kV work 1

45700~. Both Unit 1 an.d 2 Transient Combustible safe zones that During a 14-day are associated with the cable routing for the XST2 CT for the 138kV transformer will have additional restrictions relating to work.

  • i combustible storage during the extended CT durations.

i Implementing this mitigation measure will reduce the likelihood of fires related to the XST2 transformer.

- 3 i Commitment Number Commitment Description I.

I Due Da"te/Event

--~------I The Following Commitments Are Associated With The 6.9kV Work 1---4-4-5~7-00-4~---'-During a 14-day CT, the APDG provided for each Unit will IDuring the be verified available to provide power to equipment for long i 14-day CT for term cooling once per shift. the 6.9kV work.

4457005 During a 14-day CT, if an APDG becomes unavailable, both During the Units shall enter Condition C of TS 3.8.1 and start shutting *14-day CT for down within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. (This 24-hour period will only be Ithe 6.9kV work.

allowed once within a 14-day CT). 1 _ _ _ _ -1 4457007 Prior to initiation of the one time, two CT extensions, P~r to the start task for breakers 1EA 1-1, 1EA2-1, 2EA 1-1 and 2EA2-2 will 'of the 14-day CT be verified as current. for the 6.9kV work.

4457008 Testing of EDGs, APDGs, and TDAFWPs will occur within Within two the two (2) weeks prior to the start of the XST1 CT. weeks prior to

,the start of the I14-day CT for

- - _.._ - - _ .__..__.._ - + the

--6.9kV

--- work

--\

- - - - r - - - . - - . - -..- - .

4457016 The EDGs, APDGs, TDAFWPs, XST2, CCWPs, and During the SSWPs will have ALL testing and maintenance activities 14-day CT for suspended for the duration of a one-time, 14-day CT for the 6.9kV work.

XST1. Additionally, signs will be placed on the doorways to the equipment, or in the case of XST2 around the

equipment, noting the restriction of testing and maintenance i ~.

during this XST1 CT.

r457030 A roving hourly fire watch will be in effect during the 14-day During the XST1 CT along the path of the XST2 power and control 14-day CT for cabling. This is an additional measure to monitor the area .the 6.9kV work. ,

I for fires that could damage and disable the XST2 I 'transformer cabling.

4457033 Local weather conditions and forecasts will be monitored by During the

.I Operations twice per shift to assess potential impacts on *' 14-day CT for plant conditions. 'the 6.9kV work.

4457041 A time in which severe weather is not expected will be During the selected for implementation of the XST1 CT. Based on 14-day CT for ihistorical information; this time frame is September 1 the 6.9kV work.

through March 31. This planned timing will reduce high wind/tornados and weather challenges to the plant during the XST1 CT.

- 4

.. -~

Commitment I Commitment Description Due Date/Event:

Number  !

4457044 The seismic walkdown will be completed prior to the XST1 Within two CT to identify any issues that could impact the EDGs and weeks prior to TDAFWPs during a seismic event. These impacts include the start of the mounting or interactions issues including loose parts and 14-day CT for missing hardware. This walkdown is for assurance that the 6.9kV work these components will meet their seismic design criteria in the event of a seismic incident.

4457119 Access to both switchyards and relay houses will be Prior to the start

  • controlled and posted, and all maintenance will be of the 14-day CT Isuspended for the duration of the CT on XST1. ifor the 6.9kV
  • work

~--

CPNPP's Operations Department will contact the During the Transmission Operator (Transmission Grid Controller) once 14-day CT for per day during a 14-day Completion Time to ensure no the 6.9kV work.

problems exist in the transmission lines feeding CPNPP or their associated switchyards that would cause post trip

  • switchyard voltages to exceed the voltage required by STA-629.

I44s-7-1-22--+-J-ust-in-time training for affected work groups will be Prior to the start I completed prior to the start ofaXST1 outage. of the 14-day CT ifor the 6.9kV I work .

I 4457123 All hot work activities along the routing associated with power and control cabling for XST2, the in-service ST, will During a 14-day CT for the 6.9kV

  • be suspended during the XST1 CT. This is to reduce the work.

I likelihood of fires that could damage and thus disable the XST2 transformer cabling.  !

4457124 In the two weeks prior to the start of the CT, a Within two thermographic survey will be conducted on the two fixed weeks prior to sources in the safeguards switchgear room to verify no the start of the

  • abnormalities exist. This is to reduce the likelihood of a fire 14-day CT for

!ignition. the 6.9kV work 4457125 Both Unit 1 and 2 Transient Combustible safe zones that During a 14-day are associated with the cable routing for the XST2 CT for the 6.9kV transformer will have additional restrictions relating to work.

I *combustible storage during the extended CT durations.

Implementing this mitigation measure will reduce the

likelihood of fires related to the XST2 transformer.

R. Flores - 2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA!

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 160 to NPF-87
2. Amendment No. 160 to NPF-89
3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDssStsb Resource LPLIV Reading RidsNrrLAJBurkhardt Resource RidsAcrsAcnw_MailCTR Resource RidsNrrPMComanchePeak Resource RidsNrrDeEeeb Resource RidsRgn4MailCenter Resource RidsNrrDorlDpr Resource SSom, NRRlDE/EEEB RidsNrrDorlLpl4 Resource GWaig, NRRlDSS/STSB ADAMS Accession No. ML13232A143 "'SE memo dated Au ust 14, 2013 OFFICE NRRlDORLlLPL4/PM NRRlDORLlLPL4/LA NRRlDSS/STSB/BC NRRlDE/EEEB/BC*

NAME BSingal JBurkhardt RElliott RMathew (A)

DATE 8/23/13 8/21/13 8/27/13 8/14/13 OFFICE OGC - NLO NRRlDORLlLPL4/BC NRRlDORLlLPL4/PM Ghosh MMarkley (FLyon for) BSingal OFFICIAL AGENCY RECORD

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