ML14328A323

Edwin I Hatch Nuclear Plant, Unit Nos. 1 and 2, Issuance of Amendments for Degraded Voltage Protection Modification Schedule

ML14328A323
Person / Time
Site:	Hatch
Issue date:	12/16/2014
From:	Martin R Plant Licensing Branch II
To:	Pierce C Southern Nuclear Operating Co
Martin R
References
TAC MF0412, TAC MF0413
Download: ML14328A323 (20)

Text

UNITED STATES .'

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 16, 2014 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

Post Office Box 1295, Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS FOR DEGRADED VOLTAGE PROTECTION MODIFICATION SCHEDULE (TAC NOS. MF0412 AND MF0413)

Dear Mr. Pierce:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 271 to Renewed Facility Operating License DPR-57 and Amendment No. 215 to Renewed Facility Operating License NPF-5 for the Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2, respectively.

The amendments revise the Renewed Operating Licenses in response to your application dated December 21, 2012, as supplemented June 21, 2013, to incorporate a degraded voltage protection modification schedule into the Hatch licenses.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included

'in the Commission's biweekly Federal Register notice.

Sincerely,

(;) tk:rfJ1~

V~obert Marti~: Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment No. 271 to DPR-57

2. Amendment No. 215 to NPF-5

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 271 Renewed License No. DPR-57

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

A.. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 21, 2012, as supplemented by letter dated June 21, 2013, complies with the standards and*

requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and reg.ulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, 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 set forth in 10 CFR Chapter I; D. The issuance of this 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

2. Accordingly, by Amendment No. 271 Renewed Facility Operating License No. DPR-57 is hereby amended to include Additional Condition 2.C(11) "Degraded Voltage Protection,"

as set forth in the Southern Nuclear Operating Company's application dated December 21,2012, as supplemented June 21,2013, and evaluated in the NRC staff's safety evaluation dated December 16, 2014.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

./fd;;:J -

/ '-; II i1.M-..-f/lf4..4--v Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-57 Date of Issuance: December 16, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 271 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-32,1 Replace the following page of the License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

• Remove Page Insert Page License License DPR 57, Page 8 DPR-57, Page 8

c. The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 24 months, plus the 6 months Allowed by SR 3.0.2, from the date of the most recent successful pressure measurement test.

(1 0) Degraded Voltage Protection SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events by completion of the Unit 1 2020 Spring Outage, U1 R29.

D. Southern Nuclear shall not market or broker power or energy from Edwin 1. Hatch Nuclear Plant, Unit 1. . * *

• 3. This renewed license is effective as of the date of issuance and shall expire at midnight, August 6, 2034.

• FOR THE U.S. NUCLEAR REGULATORY COMMISSION

~irector Office of Nuclear Reactor Regulation Attachments: .

Appendix A - Technical Specificatio-ns Appendix B - Environmental Protection Plan Date of Issuance: January 15, 2002 Renewed License No. DPR-57 AmendmentNo. 271

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 215 Renewed License No. NPF-5

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

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 21, 2012, as supplemented by letter dated June 21, 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 as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, 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 set forth in 10 CFR Chapter I; D. The issuance of this 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

2. Accordingly, by Amendment No. 215 Renewed Facility Operating License No. NPF-5 is hereby amended to include Additional Condition 2.C(3)(i) "Degraded Voltage Protection,"

as set forth in the Southern Nuclear Operating Company's application dated December 21, 2012, as supplemented June 21, 2013, and evaluated in the NRC staff's safety evaluation dated December 16, 2014.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing

. Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-5 Date of Issuance: December 16, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 215 RENEWED FACILITY OPERATING LICENSE NO. NPF-5 DOCKET NO. 50-366 Replace the following page of the License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Pages Insert Pages License License NPF-5, Page 6b NPF-5, Page 6b

- 6b-(h) TSTF-448. Control Room Habitability Upon implementation of the Amendments adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance with TS5.5.14.c.(i), the assessment of CFE habitability as required by Specification 5.5.14.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:

i) The first performance of SR 3.7.4.4, in accordance with Specification 5.5.14.c.(i), shall be within the next 18 months.

ii) The first performance of the periodic assessment of CFRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month Allowance of $R 3.0.2, ofthe next successful tracer gas test.

• iii) The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 24 months, plus the 6 months allowed by SR 3.0.2, from the date of the most recent successful pressure measurement test.

(i) Degraded Voltage Protection SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events by completion of the Unit 2 2019 Spring Outage, U2R25.

D. This renewed license is subject to the following antitrust conditions:

(1) As used herein:

(a) "Entity" means any financially responsible person, private or public corporation, municipality, county, cooperative, association, joint stock association or business trust, owning, operating or proposing to own or operate equipment or facilities within the state of Georgia (other than Chatham, Effingham, Fannin, Towns and Uniton Counties) for Renewed License No. NPF-5 Amendment No. 215

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON; D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 271 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 215 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

EDWIN I. HATCH NUCLEAR PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366 1.0. INTRODUCTION By license amendment request (LAR) dated December 21, 2012, as supplemented by letter dated, June 21, 2013 (Agencywide Documents Access and Management System (ADAMS),

Accession Nos. ML12356A472 and ML13172A405), Southern Nuclear Operating Company, Inc.

(SNC, the licensee), requested changes to incorporate a schedule for degraded grid modification schedule into the Hatch operating license.

The proposed change requests the addition of a condition to the license related to the completion date for SNC modifications to redesign the current degraded voltage scheme to eliminate the need for use of administrative controls .. The modifications will improve the voltage profile in the plant safety busses to ensure that safety-related loads will remain operable during a degraded voltage condition.

Specifically, the proposed License Amendment Request (LAR) would revise the Hatch Nuclear Plant (HNP) Facility Operating Licenses to require SNC to implement modifications that will eliminate the need for administrative controls instead of automatic protection requirements implemented in accordance with Title 10 Code of Federal Reguiations (1 0 CFR) 50.55a(h)(2).

The licensee has proposed the addition of a license condition in the LAR stating that SNC shall implement the degraded voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events. The project completion dates are 2019 spring outage for Unit 2 and 2020 spring outage for Unit 1.

Enclosure 3

2.0 BACKGROUND

As a result of a July 1976 event at Millstone, Unit 2, involving a degraded voltage condition, the U.S. Nuclear Regulatory Commission (NRC) staff in its further evaluation has identified that improper protection logic can cause adverse effects on Class 1E systems and equipment.

Since degradation of the offsite power system can initiate or cause the failure of redundant Class 1E safety-related electrical equipment, the NRC recommended that licensees install degraded voltage protection as described in NRC letter dated June 2, 1977, "Statement of Staff Positions Relative to Emergency Power Systems for Operating Reactors" (ADAMS Legacy No.

4007002656). The letter states that "the voltage monitors shall automatically initiate the disconnection of offsite power sources whenever the voltage setpoint and time delay limits have been exceeded." The letter further states that "the voltage monitors shall be designed to satisfy the requirements of Institute of Electrical and Electronics Engineers Std. 279-01971, "Criteria for Protection Systems for Nuclear Power Generating Stations." This automatic feature enables the availability of offsite power and onsite power which ensures that the plant electrical distribution*

system has sufficient capacity and capability to automatically start and operate all required safety loads.

However, in a Safety Evaluation (SE) for the HNP dated February 23, 1995 (ADAMS Legacy No. 7908230155), the NRC staff approved a deviation from the June 2, 1977, guidance on degraded voltage protection that was subsequently found not to be consistent with the guidance, as discussed below.

On May 25, 2011, a Component Design Bases Inspection Report (ADAMS Accession No. ML111450793) was issued by NRC Region 2 and concluded that the measures in effect at HNP to demonstrate compliance with the applicable provisions of 10 CFR 50.55a(h)(2) and 10 CFR Part 50, Appendix A, general design criteria (GDC)-17 were not acceptable. The NRC staff further concluded that:

I. The NRC was in error in accepting manual actions, II. The degraded voltage protection system configuration for the two Hatch units, approved in the 1995 Safety Evaluation Report (SER), was inadequate.

Ill. As the staff had previously approved manual actions in the SER dated February 23, 1995, requiring Hatch to conform to the provisions of GDC-17 and 10 CFR 50.55a(h)(2) constituted a change in staff position requiring a backfit as defined in 10 CFR 50.1 09(a)(1 ).

.SNC appealed this decision in a letter dated June 17, 2011 (ADAMS Accession No. ML111680360). This appeal was denied by the NRC in a letter dated September 29, 2011 (ADAMS Accession No. ML112730194). The NRC staff's final response to the backfit appeal stated the following:

"Further, the staff concludes that the NRC change in position, from that in the 1995 SER, regarding the acceptability of relying on manual operator action to demonstrate compliance with the applicable provisions of GDC-17 and 10 CFR 50.55a(h )(2),

constitutes backfitting as defined in 10 CFR 50.109(a)(1). The backfitting action is necessary for compliance with GDC-17 and 10 CFR 50.55a(h)(2) and is consistent with applicable guidance and practices in effect at the time that the NRC staff erroneously

approved the use of manual actions responding to degraded grid voltage condition in 1995.

Although SNC has been in compliance with its 1995 license amendment approving SNC's degraded voltage protection system configuration, SNC also has been in violation of GDC-17 and 10 CFR 50.55a(h)(2) due to the NRC's erroneous approval of the 1995 license amendment. The NRC is exercising enforcement discretion for SNC's failure to comply with GDC-17 and 10 CFR 50.55a(h)(2) because SNC's failure to comply resulted from the NRC incorrectly issuing the license amendment in 1995."

In a letter dated October 28, 2011 (ADAMS Accession No. ML11335A179), SNC once again appealed the staff findings. The second appeal was also denied by the NRC Executive Director of Operations (EDO) in a letter dated June 19, 2012 (ADAMS Accession No. ML12130A135).

The letter provided a summary of the Backfit Appeal Panel findings and stated that the staff, determined that the degraded voltage protection configuration for the two HNP units approved in the 1995 SER does not meet the NRC's regulatory requirements. The response concluded that although the NRC made an error in approving the use of manual actions through the 1995 SER addressing the HNP degraded voltage scenario, the agency considers the application of the backfit rule, and the compliance exception, appropriate in this situation.

• 3.0 ELECTRICAL ENGINEERING

3.1 REGULATORY EVALUATION

The NRC staff used the following regulatory requirements and guidance documents during its review of the LAR:

The Updated Final Safety Analyses Report (UFSAR) for Hatch, Unit 1 (HNP-1 ), Appendix F, Section F.2, contains an evaluation of the design bases of Unit 1 based on the understanding of the intent of the Atomic Energy Commission (AEC) General Design Criteria (GDC) for Nuclear Power Plant Construction, issued for comment in July 1967. Section F.3 of Appendix F also contains an evaluation of the design bases of HNP-1 based on the understanding of the intent of the GDC effective May 21, 1971, and subsequently amended July 7, 1971. The UFSAR states that the HNP-1 construction permit was received under GDC 1 thru 70 as discussed in Section F.2.

HNP-1 UFSAR Appendix F, Section F.2 discusses compliance with AEC GDC 39, "Emergency Power for Engineered Safety Features (ESF)" and states "Sufficient offsite and standby (redundant, independent, and testable) auxiliary sources of electrical power are provided to attain prompt shutdown and continued maintenance of the plant in a safe condition. The capacity of the offsite and onsite power sources are (sic) independently adequate to accomplish the required ESF functions, assuming a failure of a single active component in each power system."

• Section 8.3.1.2.1 of the UFSAR for H.NP-2, states that the offsite power system and the onsite power systems conform to Title 10 of the Code of Federal Regulations, Part 50 (1 0 CFR) GDC 17 and 18 .. Appendix F.3 of HNP-2 UFSAR provides details on compliance with GDC 17 which was developed from AEC GDC 3~ ..

GDC 17, "Electric Power Systems," of Appendix A, for Nuclear Power Plants," to 10 CFR Part 50, requires, in part, that an onsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The onsite electric power supplies and the onsite electric distribution system shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. In addition, this criterion requires provisions to minimize the probability of losing electric power from any of the remaining supplies as a result of the loss of power from the unit, the transmission network, or the on site electric power supplies.

GDC 18, "Inspection and Testing of Electric Power Systems," requires that electric power systems important to safety be designed to permit appropriate periodic inspection and testing to demonstrate operability and functional performance.

10 CFR 50.55a(h)(2) "Protection Systems," the NRC requires nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, to have protection systems that meet the requirements stated in either Institute of Electrical and Electronics Engineers (IEEE) Standard 279, "Criteria for Protection Systems for Nuclear Power Generating Stations," or IEEE Standard 603-1991, "Criteria for Safety Systems for Nuclear Power Generating Stations," and the correction sheet dated January 30, 1995.

NRC Regulatory Guide 1.32, "Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants" describes a method acceptable to the NRC staff for complying with the Commissions regulations with regard to design, operation, and testing of electric power systems in nuclear power plants.

3.2 TECHNICAL EVALUATION

Degraded voltage protection enhances the availability of adequate voltage to safety-related equipment during design basis events. SNC's project plan includes modifications for replacing Startup Auxiliary Transformers (SATs), Degraded Voltage Relays (DVRs), possible replacement of 4160V breakers/switchgears, and Technical Specification (TS) amendments for relay set points and elimination of the TS requirement for the degraded grid voltage alarm.

The NRC staff has reviewed the licensee's proposed schedule to improve the plant voltage profile during degraded grid voltage conditions and interim measures to support plant operations until the completion of the modifications and TS amendments, as described in Enclosure 1 of the proposed LAR.

As stated in the UFSAR, the Southern electric system transmission network supplies offsite alternating current (AC) electrical power for operating the essential buses as well as startup and shutdown of the HNP units. The network interconnections at HNP consist of four 500 kilo Volt (kV) transmission lines and four 230kV transmission lines. A 500/230kV autotransformer connects the 500kV switchyard to the 230kV switchyard. Three physically independent 230 kV circuits are provided from the switchyard to SATs 1C, 1D, 2C, and 2D. SATs 1C and 2C share one 230kV circuit and SATs 1D and 2D have independent circuits. The normal offsite system operating voltage range for HNP-1 and HNP-2 is 101.3% to 104.9% of 230 kV. The UFSAR

states that a minimum voltage level of 101.3% is required for the plant safety systems to perform their safety functions to mitigate the consequences of a loss-of-coolant accident.

The onsite standby AC power supply for HNP-1 and HNP-2 consists offive diesel generator (DGs) units, which supply standby power to 4160 Volt(V) essential buses. DGs 1A and 1C supply Unit 1 essential busses and DGs 2A and 2C supply Unit 2 essential busses. DG 1B is a shared between the two units. DGs 2A and 2C have a continuous rating of 2850 kilo-Watts (kW) while DGs 1A, 1B, and 1C have a 1000-hour rating of 2850 kW.

The licensee provided the following modification work scope and schedule for Units 1 and 2:

2012 May Planning Starts 2013 June Approve Project Plan 2014 June Issue Purchase Orders for New SATs 2015 December Complete Design 2015 December Submit Technical Specification Amendment Request 2016 January Receive New SATs 2016 September Issuance of Technical Speci'fication Amendments 2017 February 2R24 Outage Work-SAT(s), Cabling, Switchgear 2018 February 1 R28 Outage Work-SAT(s), Cabling, Switchgear 2019 February 2R25 Outage Work -SAT(s), Cabling, Switchgear 2020 February 1 R29 Outage Work -SAT(s), Cabling, Switchgear 2020 March Complete Project Implementation SNC has proposed the following statement to be added to the license of Hatch, Unit 1; (1 0) Degraded Voltage Protection SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events by completion of the Unit 1, 2020 Spring Outage U1 R29 SNC has proposed the following statement to be added to the license of Hatch, Unit 2; (i) Degraded Voltage Protection SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events by completion of the Unit 2, 2019 spring Outage U2 R25 In view of the extended schedule for implementation of the modifications, by letter dated April 22, 2013 (ADAMS Accession No. ML13085A260), the NRC staff requested additional information with respect to consequences of degraded voltage conditions and compensatory actions that are in place for protection of safety significant equipment. By letter dated June 21, 2013, SNC provided responses to the NRC staff's questions as detailed below:

In the event of an ESF actuation signal during degraded voltage conditions (voltage between the alarm setpoint of 3825 V and trip setpoint of 3280 V), the NRC staff requested details on equipment that may:

(a) Not have adequate voltage to operate, (b) Trip due to automatic protection such as overload relay actuations, (c) Trip but will require manual action to reset the protective device, and (d) Degrade and may not be able to perform its required function.

In response to question (a), the licensee stated that the DVR is an inverse time relay with a pickup of 88.34% of 4160V (3675V). The TS value of 3280V (78.8% of 4160V) represents a calibration point for the inverse time curve. The licensee evaluated the operability of equipment based on plant bus voltages corresponding to a minimum grid voltage of 101.3% during normal operation and anticipated operational occurrences (AOO). The response also indicated that safety-related equipment will have adequate voltage to operate and respond properly during AOOs, such as a turbine trip or generator load rejection combined with a grid voltage at (99.3%

approximately two percent below 101.3%).

In response to questions (b) and (c) related to equipment that may trip due to protective action of relays or fuses, the licensee indicated that the existing contingency plans and operator actions are expected to ensure that the required equipment can be restored to support plant shutdown.

In response to question (d), the licensee indicated that based on engineering evaluations and administrative controls, it does not expect safety-related equipment to degrade such that it will not be able to perform its required functions.

The NRC staff requested information on the performance and reliability of the offsite power system during the last five years. The licensee sampled the data for offsite power system voltages from January 1, 2008 to April 25, 2013. The licensee stated that in all cases, the voltage remained above the degraded grid voltage alarm setting of approximately 95% of 230kV during normal operation. The 230kV bus voltage was maintained within the desired range most of the time. Two points out of277601 data points showed voltage levels less than,the desired 101.3% of 230kV.

The NRC staff requested details on the grid contingencies that were evaluated to' ensure the switchyard voltages remain above the voltages required for safe shutdown of the plant. .In response, the licensee stated that the HNP switch yard is normally maintained between 101.3%

and 104.9% of 230kV. The plant has procedural controls, voltage monitoring alarms, and protocols have been established with the grid operator to improve voltage and minimize the potential of a degraded voltage event. The grid operator actions include:

1. Performance of voltage projections for the peak summer loading season for various contingencies. The steady state loadflow analysis considers projections which include loss of local generation, maximum system loading and power to support loads on the Florida Interchange. The adequacy of offsite power system is considered for plant conditions that include limiting configurations such as one unit in an accident condition with the other unit in controlled shutdown, one unit in accident condition and a

transmission line outage and one unit in accident condition with loss of a critical element such as a 230/SOOkV autobank transformer.

2. Real time contingency analysis that simulate the current system loading conditions with actual generation and transmission system configuration and postulated contingencies.

The analysis is performed at approximately 10 minute intervals and attempts are made to restore or correct any conditions that are projected to result in inadequate bus voltage for the HNP Units. The plant is provided adequate notice if projected conditions cannot be corrected within a few minutes.

• In addition, the grid operators and plant operators have continuous monitoring and alarm features to alert them if 230kV switchyard voltage conditions are actually degrading. The plant has alarms at the safety busses to alert operators about degraded bus voltages. The procedural actions include starting of an onsite power source on each unit if degraded bus voltages last more than 30 minutes and plant shutdown within an hour if adequate offsite power system voltages cannot be restored.

• The NRC staff requested information on the project milestones that impact the implementation of proposed modifications. The licensee stated that planning and procurement of new SATs will be completed by spring of 2016. However, due to extensive modifications to the plant busses and switchgear, the installation of all the equipment cannot be completed until spring of 2020.

The NRC staff reviewed the licensee's reasoning for the ability to monitor and predict offsite power system performance and the contingency actions in place to assure that voltage at the safety busses do not degrade voltage below an acceptable level.

The NRC staff finds the licensee's conclusions of the offsite power system under postulated worst-case grid operating conditions to support safe plant operation, to be acceptable for continued operation with existing measures until the 2020 refueling outage for Unit 1.

Considering the potential impact on safety systems during unanticipated degraded grid

• conditions, implementation of modifications to eliminate the manual actions and provide automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events is a critical feature for improving defense in depth provisions at HNP Units 1 and 2.

3.3

SUMMARY

The licensee stated that the consequences of a degraded grid condition concurrent with an accident condition at any one of the units that requires safe shut down of both units can be managed with manual actions. The plant operators and grid operators continuously monitor the grid system of both HNP units. The equipment that may operate due to the inherent delay associated with manual actions will be protected by overcurrent relays and can.be restored in reasonable time.

Based on the extent of planned modifications and above the evaluation, the NRC staff determined that the time requested for implementation of plant modifications to bring Hatch, Units 1 and 2, into compliance with the regulatory requirements of GDC 17 and 10 CFR 50.55a(h)(2) is acceptable. The_proposed amendment to the HNP license is acceptable for

tracking the completion of the plant modification. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 HUMAN FACTORS

4.1 REGULATORY EVALUATION

The regulatory requirements and guidance which the Nuclear Regulatory Commission (NRC) staff considered in its review of the LAR are as follows:

a. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel;"

2.2 . NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition:" Chapter 13 addresses "Conduct of Operation," the specific sub-chapter considered in this review was 13.5.2.1, "Operating and Emergency Operating Procedures", Rev. 2;

b. Chapter 18, Rev. 2, provides review guidance for "Human Factors Engineering";

c. NUREG-1764,"Guidance for the Review of Changes to Human Actions" Rev. 1;

d. NUREG-0700, "Human-System Interface Design Review Guidelines" Revision 2

e. NUREG-0711, "Human Factors Engineering Program Review Model," Revision 2;

f. IN 97-78, "Crediting Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times~"

4.2 TECHNICAL EVALUATION

4.2.1 Description of Operator Action(s)

Manual actions, both on-site and off-site, and cues for these actions include the following:

• . Grid operators are alerted by periodic contingency analysis (every 10 minutes) if the next contingency (N-1) condition will result in a post-contingency 230 kV grid voltage less than the minimum required. If corrections cannot be made within a few minutes, the grid operators notify the HNP control room.

• HNP operators have continuous monitoring and alarm features to alert them if voltage conditions are actually degrading. Each of the Class 1 E (three per unit) busses has a Degraded Grid Voltage Alarm to notify the control room operators of a sustained Class 1 E bus under-voltage condition.

• Upon notification of a potential for degraded grid operations or through receipt of main control annunciation indicating degraded grid conditions, plant operators would initiate abnormal operating procedure 34AB-S 11-001-0, "Operation with Degraded System Voltage."

o If bus voltage remains less than 3850 Volts (V) for grea.ter than one hour, Technical Specifications (TSs) require operators to isolate the plant from the grid and reduce power or shut down.

4.2.2 Human-System Interface Design Human-System Interface (HSI) design, including the design of the Safety Parameter Display System (SPDS) will not be affected by the license amendment. Annunciators, alarms, controls, and displays are unchanged and the operators are trained in their use.

4.2.3 Procedu.re Design No changes are required to the Emergency Operating Procedures (EOPs). Because the proposed interim actions are not new actions, the existing abnormal operating procedure (Procedure 34AB-S 11-001-0, "Operation with Degraded System Voltage") does not require any changes. The staff finds the existing procedure acceptable based on its use during operator continuing training. The long-term successful use of the procedure in training confirms its effectiveness.

4.2.4 Training Program and Simulator Design The operators who control the grid at the Power Coordination Center (PCC) and the Georgia Control Center (GCC) are provided annual training on communication protocol and expectations of procedures BP0-02, "Nuclear Plant Procedure" and NUC-001, "Nuclear Plant Interface Coordination for Southern Nuclear Operating Company, Version 2." HNP operators routinely train in the simulator on degraded grid conditions. This training is part of the initial licensed operator and the licensed operator requalification training programs. In the licensed operator requalification training program, degraded grid conditions are incorporated into simulator scenarios and are trained on within the two year requalification cycle. Based on the fact that the proposed actions have a long history of successful implementation, and are included in operator continuing training, the staff concludes that additional training is not necessary. Based on the above, the staff finds that the training already provided is acceptable.

4.3

SUMMARY

Based on the statements provided by SNC, i.e., that appropriate administrative controls will be applied to procedures and training, and that both Units have substantial in-house operating experience, the staff concludes that both the Technical Specification required actions and the compensatory actions discussed in the LAR are acceptable from a human performance

. perspective.

5.0 STATE CONSULTATION

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

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the 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 considerations, and there has been no public comment on the finding (78 FR 54289, September 3; 2013). 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: S. Matharu G. Lapinsky Date: December 16, 2014

December 16, 2014 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

Post Office Box 1295, Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS FOR DEGRADED VOLTAGE PROTECTION MODIFICATION SCHEDULE (TAC NOS. MF0412 AND MF0413)

Dear Mr. Pierce:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 271 to Renewed Facility Operating License DPR-57 and Amendment No. 215 to Renewed Facility Operating License NPF-5 for the Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2, respectively.

The amendments revise the Renewed Operating Licenses in response to your application dated December 21, 2012, as supplemented June 21, 2013, to incorporate a degraded voltage protection modification schedule into the Hatch licenses.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RAJ Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment No. 271 to DPR-57

2. Amendment No. 215 to NPF-5

3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDoriDpr Resource RidsNrrPMHatch Resource LPL2-1 R/F RidsNrrDorllpl2-1 Resource RidsRgn2MaiiCenter Resource RidsAcnw_MaiiCTR Resource RidsNrrDeEeeb Resource ADAMS A ccess1on No. ML14328A323 . dblY memo date d

• SE transm1tte OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/AHPB/BC NRR/EEEB/BC NAME RMartin SFigueroa SWeerakkody JZimmerman DATE 12/10/14 12/10/14 12/05/14

• 11/28/14

• OFFICE OGC NRR/LPL2-1/BC NRR/LPL2-1/PM NAME Jlindell RPascarelli RMartin DATE 12/10/14 12/16/14 12/16/14 I I OFFICIAL RECORD COPY