HNP-98-061, Application for Amend to License NPF-63,revising TS 3/4.3.2, ESFAS Instrumentation, to Allow Two Hour Surveillance Interval to Facilitate Testing of 6.9 Kv Emergency Bus Undervoltage Relays
| ML18016A399 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/24/1998 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18016A400 | List: |
| References | |
| HNP-98-061, HNP-98-61, NUDOCS 9804290197 | |
| Download: ML18016A399 (11) | |
Text
CATEGORY l~~
REGULA> RY INFORMATION DISTRIBUTIOMHYSTEM (RIDS)
ACCESSION NBR:9804290197 DOC.DATE: 98/04/24 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AQTH.NQE q
'UTHOR AFFILIATION ROBINSON;S.=R.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET ¹ 05000400
SUBJECT:
Application for amend to license NPF-63,revising TS 3/4.3.2, "ESFAS Instrumentation,"
to allow two hour surveillance interval to facilitate testing of 6. 9 kV emergency bus undervoltage relays.
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Carolina Power & Light Company PO Box 165 New Hill NC 27562 William R. Robinson Vice President Harris Nuclear Plant APR 24 1998 SERIAL:
HNP-98-061 10CFR50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEARPOWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR EXIGENTLICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.3.2
Dear Sir or Madam:
In accordance with the Code ofFederal Regulations, Title 10, Part 50.90, Carolina Power S Light Company (CPS') requests a revision to the Technical Specifications (TS) for the Harris Nuclear'lant (HNP). The proposed amendment revises TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation" to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval to facilitate testing of the 6.9 kV Emergency Bus Undervoltage relays. The proposed change is necessary to prevent a potential shutdown per the requirements ofTS 3.0.3.
Enclosure 1 provides a description ofthe proposed changes and the basis for the changes. Enclosure 2 details, in accordance with 10 CFR 50.91(a), the basis for the COL's determination that the proposed changes do not involve a significant hazards consideration.
Enclosure 3 provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment is required for approval of this amendment request. provides page change instructions for incorporating the proposed revisions. Enclosure 5 provides the proposed Technical Specification pages.
In accordance with 10 CFR 50.91(b), CPE~L is providing the State ofNorth Carolina with a copy of the proposed license amendment.
10 CFR 50.91(a)(6)(vi) requires that a licensee explain the nature of the exigency and why the exigency could not have not have been avoided. To adequately perform a TS required surveillance test, the Harris Nuclear Plant must enter TS 3.0.3 which could lead to an unnecessary plant shutdown. The surveillance interval for this test is at least once per 31 days. There is insufficient time between test performance to process a license amendment through normal means. Therefore, CP&Lrequests the NRC review and approve the proposed change as an exigent submittal.
r~ JQ~
5413 Shearon Harris Road New Hill NC Tel 919 362-2502 Fax 919 362-2095
Please refer any questions regarding this submittal to Mr. J. H. Eads at (919) 362-2646.
Sincerely, W. R. Robinson MSE/mse
Enclosures:
- 1. Basis for Change Request 2.
10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages W. R. Robinson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best ofhis information, knowledge and belief, and the sources of his information are employees, contractors, and agents ofCarolina Power 0 Light Company.
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Notary (Seal)
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Mr. J. B. Brady, NRC Sr. Resident Inspector Mr. Mel Fry, Acting Director, N.C. DEHNR Mr. S. C. Flanders, NRC Project Manager Mr. L. A. Reyes, NRC Regional Administrator
ENCLOSURE 1 TO SERIAL: HNP-98-061 SHEARON HARRIS NUCLEARPOWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR EXIGENTLICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.3.2 BASIS FOR CHANGE RE UEST
~Back round The Harris Nuclear Plant (HNP) 6.9kV electrical emergency buses, 1A-SA and 1B-SB, are equipped with three primaiy and three secondary undervoltage relays to monitor the voltage condition of these buses. Loss of voltage on either bus, sensed by these undervoltage relays, causes shedding of all loads on the applicable bus, automatic starting ofthe associated emergency diesel generator (EDG),
and automatic starting of the Turbine-Driven AuxiliaryFeedwater Pump (TDAFWP). When the EDG has attained rated speed and voltage, the EDG circuit breaker to the 6.9 kVemergency bus is closed and the safety-related loads are connected to the bus automatically by the emergency load sequencer.
Undervoltage of a safety bus could be indicative of a loss-of-offsite power. A loss-of-offsite power willbe accompanied by a loss ofreactor coolant pumping power and the subsequent need for some method of decay heat removal. Loss ofpower to either emergency bus willstart the TDAFWP to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip.
HNP Technical Specifications (TS) require primary and secondary undervoltage relays to be operable per Table 3.3-3 Item 6.e. (Loss-of-Offsite Power Start Motor-Driven Pumps and Turbine-Driven Pump) and Item 9.a.
and 9.b (Loss-of-Offsite Power, Undervoltage-Primary and Undervoltage-Secondary).
Table 3.3-3 Item 6.e. references Item 9 for initiating functions and requirements. Additionally, Table 4.3-2 Item 6.e. references Table 4.3-2 Item 9. for surveillance requirements associated with Loss-of-Offsite Power (LOSP) requirements, The surveillance requirement for LOSP Trip Actuating Device Operational Test (TADOT)is in TS Table 4.3-2 Item 9.a. and 9.b. The current HNP TS surveillance interval for LOSP TADOT is once per 31 days (M).
On January 10, 1996, the NRC issued Generic Letter (GL) 96-01. The NRC requested licensees to review Engineering Safety Features circuitry, Reactor Protection circuitry, and EDG actuation and load shedding circuitry to verify all portions ofthe circuitry were being tested. In response to GL 96-01, HNP identified in LER 96-002 that surveillance testing had not been performed to verify proper operation ofthe 6.9 kVemergency bus degraded grid voltage relays (secondary undervoltage relays) during monthly TADOTtesting. HNP revised the surveillance test procedure to adequately test the secondary under voltage relays. However, to properly test the secondary undervoltage relays, the primary undervoltage relays are rendered inoperable.
HNP wrote a TS Interpretation that determined the intent of the TS could be met by declaring the associated emergency bus inoperable ifthe corresponding primary and secondary undervoltage relays were inoperable. This is similar to NUREG 1431, Revision 1 TS 3.3.5 which requires declaring the associated EDG inoperable ifthe Action and associated Completion times are not met for LOSP EDG start instrumentation. Upon futher review, HNP has determined that this interpretation is not in literal compliance with TS.
Page E1-1
There is no TS Action for 3 channels of primary undervoltage relays being inoperable. Therefore, a TS 3.0.3 entry is required in order to perform the TS surveillance requirement. GL 87-09 and NUREG-1431, Revision 1 state in TS LCO Bases forTS 3.0.3 that "Itis not intended to be used as an operational convenience that permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable". The proposed change willpermit performance of the associated surveillance requirement without entry into TS 3.0.3.
Pro osed Chan e
Harris Nuclear Plant (HNP) proposes revising TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation" to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval to facilitate testing of the 6.9 kV Emergency Bus Undervoltage relays. Specifically, HNP proposes modifyingTechnical Specification Table 3.3.3 Items 9.a. and 9.b. to change the Action from 15 to 15a. In addition, TS Table 3.3-3 is revised to add Action 15a to allow removal of 6.9 kV Emergency Bus Undervoltage relays for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the redundant train Emergency 6.9kV Bus and associated undervoltage primary and secondary relays are operable.
Basis In order to perform required surveillance testing without entering into Technical Specification (TS) 3.0.3, HNP proposes revising TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation" to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval to facilitate testing of the 6.9 kVEmergency Bus Undervoltage relays. During the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that surveillance testing is being performed on the Emergency Bus Undervoltage relays, the redundant train emergency bus willbe available to perform necessary safety functions. Additionally, the redundant emergency bus undervoltage relays willbe operable to detect a loss-of-offsite power and automatically start the redundant Emergency Diesel Generator (EDG), redundant Motor-Driven Auxiliary Feedwater Pump (MDAFWP), and the Turbine-Driven AuxiliaryFeedwater Pump (TDAFWP)ifrequired. As an additional compensatory feature, the secondary or degraded voltage relays willbe available to provide automatic loss-of-offsite power protection on the associated bus during testing. Manual initiation of the associated Emergency Diesel Generator (EDG), Motor-Driven AuxiliaryFeedwater Pump (MDAFWP), and the Turbine-Driven AuxiliaryFeedwater Pump (TDAFWP) willalso be available to the operators in the Main Control Room.
The TDAFWP can be started on an undervoltage signal from either emergency bus. Although the automatic start from an undervoltage condition willbe degraded while testing one of the emergency
- buses, the redundant bus that is not being tested will be able to sense a loss-of-offsite power condition and consequently automatically start the TDAFWP. The emergency bus that is being tested can also automatically start the TDAFWP. This is due to a testing feature that willautomatically enable the secondary undervoltage relays should a loss-of-offsite condition occur. The secondary relays are redundant to the primary relays in that they perform the same functions. However, the secondary relays are not instantaneous.
The secondary relays actuate when bus voltage is degraded for designated period of time that depends on whether or not Safety Injection has been actuated.
The design for the HNP loss-of-offsite power circuitry is different compared to the Standard Westinghouse Technical Specifications. The relays that start the EDGs on loss-of-offsite power are the same relays that start the TDAFWP on loss-of-offsite power. NUREG 1431, Revision 1
(Standard Westinghouse Technical Specifications) has a separate LimitingCondition for Operation (LCO) requirement for the EDG start on loss-of-offsite power that is different from the LCO requirement for TDAFWP loss-of-offsite power start. Therefore, HNP is unable to adopt the Page El-2
Standard Westinghouse Technical Specification for this circuitry. Additionally, the HNP undervoltage relay testing design is unique to the nuclear industry in that the primary and secondary relays cannot be tested separately. Therefore, HNP requires a plant unique provision in the applicable LCO that allows removal ofloss-of-offsite power undervoltage relays for testing to ensure each set ofundervoltage relays have been adequately tested. The HNP Primary and Secondary Loss-of-Offsite Power undervoltage relays have demonstrated high reliability based on successful completion of previous TADOTtesting.
==
Conclusion:==
HNP concludes the proposed change is acceptable based on the following:"
Sufficient redundancy willbe provided during TADOTtesting on Primary and Secondary Loss-of-Offsite Power undervoltage relays. During TADOT testing of Primary and Secondary Loss-of-Offsite Power undervoltage relays, the redundant emergency bus, that is unaffected by testing, and the associated redundant Primary and Secondary Loss-of-Offsite Power undervoltage relays willbe operable. Should a Loss-of-Offsite Power condition occur, the redundant emergency bus willautomatically sense the undervoltage condition and start the redundant EDG and start the TDAFWP. Additionally, the Secondary or Degraded undervoltage relays will be available to provide loss-of-offsite power protection on the affected emergency bus. The EDG and the TDAFWP have manual start capability in the Main Control Room as a backup to the available automatic features.
2, HNP Primary and Secondary Loss-of-Offsite Power undervoltage relays have demonstrated high reliabilitybased on successful completion ofprevious TADOTtesting.
HNP Primary and Secondary Loss-of-Offsite Power undervoltage relays share the EDG start and the TDAFWP start functions. This design is unique compared to other Westinghouse plants. Additionally, HNP does not have the design capability to separately perform TADOT testing ofPrimary and Secondary Loss-of-Offsite Power undervoltage relays.
4.
The interval that Primary and Secondary Loss-of-Offsite Power undervoltage relays are unavailable due to testing is limited to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
HNP TS require performance ofTADOTtesting on primary and secondary undervoltage circuitry for 6.9kV emergency buses. Currently there is no provision with the HNP design to adequately perform this testing without entry into TS 3.0.3. Therefore, it is concluded that a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval for Primary and Secondary Loss-of-Offsite Power undervoltage relays is necessary and acceptable.
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ENCLOSURE 2 TO SERIAL: HNP-98-061 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR EXIGENTLICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.3.2 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. Aproposed amendment to an operating license for a facilityinvolves no significant hazards consideration ifoperation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Carolina Power A Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination.
The bases for this determination are as follows:
Pro osed Chan e
Harris Nuclear Plant (HNP) proposes revising TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation" to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval to facilitate testing of the 6.9 kV Emergency Bus Undervoltage relays. Specifically, HNP proposes modifyingTechnical Specification Table 3.3.3 Items 9.a. and 9.b. to change the Action from 15 to 15a. In addition, TS Table 3.3-3 is revised to add Action 15a to allow removal of 6.9 kV Emergency Bus Undervoltage relays for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the redundant train Emergency 6.9kV Bus and associated undervoltage primary and secondary relays are operable.
Basis This change does not involve a significant hazards consideration for the followingreasons:
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Loss-of-Offsite Power Emergency Bus undervoltage relays are not accident initiating components as described in the Final Safety Analysis Report. The proposed change allows a surveillance test interval to facilitate required testing per the Harris Nuclear Plant Technical Specifications (TS). Redundancy of emergency buses, availability of alternate automatic loss-of-offsite power protection, and the capability of manual initiation of affected components combined with the short duration allowed for testing, compensate for the new allowed surveillance interval.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Page E2-1
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Loss-of-Offsite Power Emergency Bus undervoltage relays are not accident initiating components as described in the Final Safety Analysis Report (FSAR). The proposed change only affects testing of the Loss-of-Offsite Power Emergency Bus undervoltage relays while not affecting other structures, systems, or components.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment does not involve a significant reduction in the margin of safety.
The proposed change to testing ofLoss-of-Offsite Power Emergency Bus undervoltage relays does not affect any of the parameters that relate to the margin of safety as described in the Bases ofthe TS or the FSAR. Accordingly, NRC Acceptance Limits are not affected by this change.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
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ENCLOSURE 3 TO SERIAL: HNP-98-061 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR EXIGENTLICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.3.2 ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.
A proposed amendment to an operating license for a facilityrequires no environmental assessment ifoperation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts ofany effiuents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure.
Carolina Power 8c LightCompany has reviewed this request and determined that the proposed amendment meets the eligibilitycriteria 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 needs to be prepared in connection with the issuance of the amendment.
The basis for this determination follows:
Pro osed Chan e
Harris Nuclear Plant (HNP) proposes revising TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation" to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance interval to facilitate testing of the 6.9 kV Emergency Bus Undervoltage relays. Specifically, HNP proposes modifyingTechnical Specification Table 3.3.3 Items 9.a. and 9.b. to change the Action from 15 to 15a. In addition, TS Table 3.3-3 is revised to add Action 15a to allow removal of 6.9 kV Emergency Bus Undervoltage relays for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the redundant train Emergency 6.9kV Bus and associated undervoltage primary and secondary relays are operable.
Basis The change meets the eligibilitycriteria forcategorical exclusion set forth in 10 CFR 51.22(c)(9) for the followingreasons:
1.
As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.
2.
The proposed amendment does not result in a significant change in the types or increase in the amounts of any effiuents that may be released offsite.
The change does not introduce any new effiuents or increase the quantities of existing effluents. As such, the change cannot affect the types or amounts of any effluents that may be released offsite.
The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.
The proposed change does not result in any physical plant changes or new sur veillance which would require additional personnel entry into radiation controlled areas.
Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
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ENCLOSURE 4 TO SERIAL: HNP-98-061 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKET NO. 50400/LICENSE NO. NPF-63 REQUEST FOR EXIGENTLICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.3.2 PAGE CHANGE INSTRUCTIONS Removed Pa e 3/4 3-25 3/4 3-26
~dP 3/4 3-25 3/4 3-26 Page E4-1