ML15218A155
| ML15218A155 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/14/1997 |
| From: | Labarge D NRC (Affiliation Not Assigned) |
| To: | Mccollum W DUKE POWER CO. |
| References | |
| TAC-M86027, TAC-M86028, TAC-M86029, NUDOCS 9711200343 | |
| Download: ML15218A155 (7) | |
Text
November 14, 1997 Mr. W. R. McCollum Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - PROPOSED AMENDMENTS TO THE ELECTRICAL TECHNICAL SPECIFICATIONS - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. M86027, M86028, AND M86029)
Dear Mr. McCollum:
By letter dated September 3, 1997, Duke Energy Corporation requested amendments to the Technical Specifications for the Oconee Nuclear Station, Units 1, 2, and 3. The amendments would completely replace the present electrical technical specifications. To complete its review, the staff requests additional information as described in the enclosure.
Sincerely, ORIGINAL SIGNED BY:
David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Request For Additional Information cc w/encl: See next page Distribution:
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 14, 1997 Mr. W. R. McCollum Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - PROPOSED AMENDMENTS TO THE ELECTRICAL TECHNICAL SPECIFICATIONS - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. M86027, M86028, AND M86029)
Dear Mr. McCollum:
By letter dated September 3, 1997, Duke Energy Corporation requested amendments to the Technical Specifications for the Oconee Nuclear Station, Units 1, 2, and 3. The amendments would completely replace the present electrical technical specifications. To complete its review, the staff requests additional information as described in the enclosure.
Sincerely, David E. LaBarge, Senior Project Manager Project Directorate !!-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Request For Additional Information cc w/encl: See next page
Oconee Nuclear Station cc:
Mr. Paul R. Newton Mr. J. E. Burchfield Legal Department (PBO5E)
Compliance Manager Duke Energy Corporation Duke Energy Corporation 422 South Church Street Oconee Nuclear Site Charlotte, North Carolina 28242 P. 0. Box 1439 Seneca, South Carolina 29679 J. Michael McGarry, III, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW.
Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice Mr. Robert B. Borsum P. 0. Box 629 Framatome Technologies Raleigh, North Carolina 27602 Suite 525 1700 Rockville Pike Mr. G. A. Copp Rockville, Maryland 20852-1631 Licensing - ECO5O Duke Energy Corporation Manager, LIS 526 South Church Street NUS Corporation Charlotte, North Carolina 28242-0001 2650 McCormick Drive, 3rd Floor Clearwater, Florida 34619-1035 Mr. Richard M. Fry, Director Division of Radiation Protection Senior Resident Inspector North Carolina Department of U. S. Nuclear Regulatory Environment, Health, and Commission Natural Resources 7812B Rochester Highway 3825 Barrett Drive Senca South Carolina 2 Raeigh, North Carolina 27609-7 721 Regional Administrator, Region II U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621
Request for Additional Information Electrical Technical Specifications Amendments Oconee Nuclear Station, Units 1, 2 and 3 Duke Energy Corporation Proposed Technical Specification (TS) Section 3.7.1 does not provide an explicit completion time requirement to restore the overhead emergency power path to operable status if this path is inoperable due to reasons other than an inoperable startup transformer, no designated startup transformer, an inoperable Keowee hydro unit, or an inoperable Keowee main step-up transformer. For this case, provide a discussion that explains why a restoration completion time requirement is viewed to be unnecessary or revise the section to include such a requirement.
- 2.
Item Number 6 on Page 10 of the technical justification indicates that Action C.2.1 specifies the restoration of the startup transformer in Condition A.
However, Action C.2.1 specifies the restoration of the emergency power path in Condition C. Provide information that resolves this inconsistency.
- 3. Condition L of proposed TS Section 3.7.1 addresses the N and SL circuit breakers.
The Standard Technical Specifications (STSs) guidelines require that the conditions be related to the limiting conditions of operation. However, no specific limiting condition of operation is provided for Condition L. Revise the submittal to include a specific limiting condition of operation for the N and SL circuit breakers.
- 4.
Proposed Surveillance Requirement 3.7.1.18 does not require verification of redundant breaker trip coils on a staggered test basis even though it permits such staggeeU esLiL.
ProViUe a discussion that includes the technical bases for not requiring staggered testing of these trip coils or revise the surveillance requirement to require staggered testing of the trip coils.
- 5. The current TSs permit one complete single string or single component (i.e.,
125 Vdc battery, charger, distribution center) of the Keowee 125 Vdc power system to be inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For the same condition, the proposed TS Section 3.7.1 permits 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In a letter dated October 3, 1995, the response to a previous question regarding this increased allowed outage time (AOT) indicated that the Keowee unit availability is not expected to decrease significantly because of this change. The response also indicated that during this 72-hour period, both Keowee units would be physically available due to the direct current (dc) buses being cross-tied and fed from a single battery. Considering this response, provide a discussion that contains the bases for the expectation that the Keowee unit availability will not decrease significantly because of the change in AOT. In addition, discuss why common cause implications resulting in inoperability of both units are not viewed to be significant when the dc buses are cross-tied as described.
Enclosure
-2
- 6.
Note 2 for Condition J of the proposed TS Section 3.7.1 changes the previously proposed allowed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the operable Keowee hydro unit to be made inoperable to restore both Keowee units. As a result, this change permits both Keowee units to be inoperable for a longer period of time during an extended outage of a Keowee unit. In Item Number 38 of the technical justification, it is noted that the longer period of time is due to a planned modification after both units are dewatered. It is also noted in this justification that a review of the penstock modification indicates that the removal of the bulkhead will take more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Expand your discussion provided in the technical justification to include additional detailed information as to why the longer period of time is necessary. In addition, include in the response a discussion that addresses why this planned Keowee penstock modification is not viewed as an unreviewed safety question.
- 7. Section 3.7.5, "Emergency Power Switching Logic (EPSL) Keowee Emergency Start Function," of the proposed TSs changes the current AOT TS for the Keowee emergency start circuitry from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Provide a discussion that includes the detailed technical bases as to why this change will not result in longer periods of inoperability for the emergency power paths.
- 8. Proposed TS Section 3.7.6, "Emergency Power Switching Logic (EPSL) Degraded Grid Voltage Protection," does not include provisions for placing an inoperable voltage sensing relay in a bypassed or trip state. The STSs include these provisions for degraded grid voltage protection circuitry. Provide a discussion that includes the technical bases for not incorporating these provisions in the proposed electrical TSs.
- 9. During the September 22, 1997, Duke Energy Corporation-NRC management meeting relating to the emergency power system, it was noted that 13 of the 14 Regulatory Guide 1.9 testing surveillances were determined to be applicable to Keowee. Identify the 13 applicable Regulatory Guide 1.9 testing surveillances and the attendant specific surveillance requirement contained in the proposed TSs. For each of the 13 applicable surveillances, identify the specific testing acceptance criteria and provide the technical bases used to establish the specific criteria.
- 10. The proposed TSs submittal does not include voltage and frequency surveillance testing acceptance criteria for the Keowee or Lee emergency power sources. The STSs include specific voltage and frequency surveillance testing acceptance criteria for the emergency power sources. The proposed TSs submittal should be revised to include specific surveillance testing acceptance criteria for the Keowee and Lee emergency power sources.
- 11. The current Oconee TSs contain requirements for the main feeder bus monitor panel circuitry. The proposed TSs do not contain any requirements for this circuitry. In the Duke Energy Corporation report dated July 2, 1997, addressing the June 20, 1997, events involving loss of power to the Unit 1 main feeder buses, it is
-3 noted that the main feeder bus monitor panel logic timer actuated an emergency start of both Keowee units and the emergency power switching logic. This information suggests that the main feeder bus monitor panel circuitry actuated the emergency power switching logic, which caused additional equipment to actuate and restore power to the main feeder buses. Provide a discussion that describes in detail the expected response of the electrical power system if the main feeder bus monitor panel signal is not provided for loss of power to the main feeder buses. For this case, include in the discussion a description of how electrical power is restored and what is being credited for main feeder bus power restoration.
- 12. During the past 3 years, modifications, changes, and other activities relating to the electrical power systems have occurred at the Oconee Station. In view of this, verify that the TSs review information previously provided with letters dated November 29, 1993, December 6, 1993, October 3, 1995, and February 27, 1997, continues to be accurate and valid. Identify and provide a discussion addressing any of this information which no longer is accurate and valid.
- 13. The proposed TSs do not address the loss of power relay circuitry associated with the emergency power buses. Provide a discussion that contains the technical bases for why this loss of power circuitry need not be addressed by a specific TS.
- 14. Item Numbers 19 (page 19) and 32 (page 26) of the technical justification address inoperability of two or more required 125 Vdc I&C power sources and inoperability of two 230 kV switchyard 125 Vdc power sources, respectively. For each of these cases, the justification notes that the required action is entry into Technical Specification 3.0, which requires that the associated Oconee unit be in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This required action is consistent with the current TSs. However, the proposed TSs allow 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> to place the associated Oconee unit in a cold shutUown condition instead of the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> per Technical Specification 3.0. For each of these cases, provide a discussion that includes the detailed technical bases for allowing the additional time to place the associated unit in a cold shutdown condition.
- 15. The previously proposed TS section for battery parameters included as a condition more than two battery cells jumpered in one battery. The proposed TS Section 3.7.10, "Battery Cell Parameter," has been revise to be consistent with the STSs and, therefore, does not explicitly address jumpering of battery cells. However, jumpering of up to two battery cells in a single battery is not precluded. Provide a discussion to justify how the licensing basis requirements are continued to be maintained with two battery calls jumpered in a single battery.
- 16. The IEEE Standard 450-1975 battery discharge test is not included in the licensing bases for the Oconee Station. However, the maintenance program includes battery performance discharge testing to assist in predictive maintenance and to indicate the need for battery replacement. A difference in the practice recommended in the
-4 standard and that in the Oconee maintenance program involves actions to be taken based on test results. The Oconee procedures require an operability evaluation if battery capacity test results are below 80 percent versus the standard which recommends replacement if battery capacity test results are 80 percent or less.
Regarding this difference, provide a discussion that includes the technical bases used to establish that the battery may be operable if battery capacity test results are below 80 percent.