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Draft James A. FitzPatrick Nuclear Power Plant - Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source
	ML19277D552
Person / Time
Site:	FitzPatrick
Issue date:	10/04/2019
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
	Lee S
References
	Download: ML19277D552 (59)
	v • d • e

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.91(a)(5)

October 4, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. NPF-59 NRC Docket No. 50-333

SUBJECT:

Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-59 for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed changes are being requested on an emergency basis pursuant to 10 CFR 50.91(a)(5).

The proposed change modifies the completion time for JAF TS 3.8.1, "AC Sources-Operating," Action A.3 from 7 days to 21 days.

TS 3.8.1 was entered at 0715 on October 3, 2019 due to a rapidly degrading trend in total dissolved combustible gas concentration (TDCG) in the 71T-3 Reserve Station Service Transformer (RSST) that is one of the station's qualified offsite circuits. The total time to allow for troubleshooting and repairs and, if necessary, transition to and complete a transformer replacement is twenty-one (21) days, including post-maintenance testing. This results in the requested Completion Time ending at 0714 on October 24, 2019. Without approval of the extension, JAF will need to shutdown on October 10, 2019.

At this time, the most likely cause of the degrading trend is an overheating condition due to a high resistance mechanical connection internal to the transformer. A bounding schedule for a transformer replacement has been developed should discovery determine the extent of repairs warrant a complete replacement. The replacement transformer has limited functionality as compared to the existing transformer. It is desired to make every effort to repair the existing transformer prior to making the decision to replace the transformer.

This submittal was developed using the guidance provided in NUREG 0800 Standard Review Plan Branch Technical Position 8-8. Deviations from this guidance are documented in section 4.0 Technical Evaluation.

Emergency License Amendment Request One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source October 4, 2019 Page 2 Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program. provides the evaluation of the proposed changes and justification for the need for the emergency LAR per 10 CFR 50.91(a)(6). Attachment 2 provides a copy of the marked-up TS pages that reflect the proposed changes.

Exelon requests approval of this emergency LAR by October 9, 2019 to support the currently planned repairs and restoration of the offsite source to Operable status.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Christian Williams at (610) 765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of October 2019.

Respectfully, David T. Gudger Acting Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. List of Affected Surveillance Requirements

4. Assessment of Equipment affected by Surveillance Suspension

5. Summary of Normal and Enhanced Compensatory Measures cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A.L. Peterson, NYSERDA

Emergency License Amendment Request One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source October 4, 2019 Page 3 bcc: Senior Vice President - Mid-Atlantic Operations w/o attachments Site Vice President - JAF Vice President, Licensing and Regulated Plant Manager - JAF Director, Operations - JAF Director, Site Engineering - JAF Director, Site Training - JAF Manager, Regulatory Assurance - JAF w/ attachments Senior Manager, Licensing, KSA Manager, Fuels, KSA C. Williams, KSA Commitment Coordinator - KSA Correspondence Control Desk - KSA

ATTACHMENT 1 Emergency License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 EVALUATION OF PROPOSED CHANGES

Subject:

Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Action A.3 Completion Time for an Inoperable Offsite Source 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 1 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes are being requested on an emergency basis pursuant to 10 CFR 50.91(a)(5). The reason that this License Amendment Request (LAR) is being submitted on an emergency basis and the justification why this situation could not be avoided is further discussed in Section 2 below.

The proposed change provides for a one-time modification of the completion time for JAF TS 3.8.1, AC Sources-Operating, Action A.3 from 7 days to 21 days. This one-time extension is requested to facilitate repair and, if necessary, replacement of the 71T-3 transformer. The change also includes a request for a one-time suspension of the affected surveillances associated with protected equipment.

Exelon requests approval of this emergency LAR by October 9, 2019 to support the currently planned repairs and restoration of the offsite source to Operable status.

2.0 DETAILED DESCRIPTION The JAF Reserve Station Service Transformers 71T-2 and 71T-3 are the preferred independent offsite power sources to the redundant emergency buses 10600 and 10500 respectively. Each Reserve Station Service Transformer (RSST) is fed from the cross-tied 115 KV power lines Lighthouse Hill Line #3 and Nine Mile Point Line #4. Each of these offsite 115KV sources are capable of providing power to either division 1 or 2 busses through the respective RSST. The RSSTs are classified as non-safety related equipment.

While connected to the emergency buses, each of these offsite AC sources must be capable of maintaining rated frequency and voltage and accepting required loads during an accident.

Loss or degradation of normal AC power at the 4 KV level results in an automatic fast transfer or automatic residual transfer to the offsite AC power sources through the RSSTs 71T-2 and 71T-3. These transformers contain an On-Load Tap Changer to maintain the 4KV Bus voltages under various analyzed scenarios.

Upon loss of offsite power or failure of an RSST, the emergency bus undervoltage signal will start the Emergency Diesel Generators (EDGs) and the redundant EDG subsystems would automatically energize their respective emergency buses. Each of the EDGs have a continuous rating of 2600 kW and each of the diesel engines have a continuous brake horsepower rating of 3600 hp. Each diesel generator unit has an independent fuel oil system capable of providing fuel for seven (7) days of continuous operations.

The proposed change addresses a condition related to one of JAFs two offsite AC power sources. On 9/27/2019, it was identified that one of the Reserve Station Service Transformers, 71T-3, was exhibiting elevated Total Dissolved Combustible Gas levels.

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 2 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes Both the installed Kelman Gas Analyzer and laboratory analysis of transformer oil samples confirmed the elevated TDCG levels were rising. Between September 27 and October 2, this trend rapidly degraded requiring the transformer to be removed from service and subsequently entry into JAF TS LCO 3.8.1 Required Action A.3. The required Completion Time to restore the offsite circuit to OPERABLE is 7 days.

Implementation of this one-time TS change will support the expected duration of 21 days to replace the failed RSST 71T-3.

Description of Events The 71T-3 Reserve Station Service Transformer is used for outage and accident scenarios to supply power to safety related loads. This can feed the 10100,10300, and 10500 bus. If this transformer were to fail, while loaded the A and C EDGs would start on loss of offsite power.

On 09/27/2019, the 71T-3 Reserve Station Service Transformers Kelman Gas Analyzer indicated abnormal gas parameters. This is captured in the site Corrective Action Program under condition report (IR) 04282868. Subsequent to feedback received from the vendor, external temperatures on 71T-3 were obtained using an FLIR camera for comparison to the external temperatures on the opposite transformer, 71T-2. No obvious difference in temperatures were noted between the two transformers and no apparent thermal abnormalities existed.

An oil sample was taken on 9/27/2019 and analyzed on 9/28/2019 which confirmed an elevated TDCG level of 615 ppm, which is within the IEEE C57.104 Standards for Condition 1 TDCG parameters of less than or equal to 720 ppm. For comparison, TDCG in June of 2019 was 46 ppm. Over several hours during the evening of 10/2/2019 and into the morning of 10/3/2019, TDCG rate of change increased rapidly and reached a peak of 2900 ppm. Based on the increased rate of change of the TDCG concentration, the transformer was required to be removed from service as OPERABILITY could no longer be assured. Operators entered LCO 3.8.1 at 0715 on 10/3/2019.

Reason the Amendment is Requested on an Emergency Basis JAF entered TS LCO 3.8.1 Action Statement A.3 at 0715 in October 3, 2019 due to a rapidly degrading trend which called into question the OPERABILTY of one of the credited offsite circuits. The completion time of 7 days requires that JAF shut down at 0714 on October 10, 2019. The Station does not have a ready spare to complete a replacement and thus initial restoration efforts are focused on fixing the installed transformer. In the event that these efforts are unsuccessful, restoration of the offsite circuit will require replacing the 71T-3 RSST.

This change is needed sooner than can be issued under exigent circumstances and this license amendment request is considered timely considering the unplanned and rapidly degrading nature of the event.

Reason Emergency Situation Has Occurred

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 3 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes The rapidly degrading TDCG concentration resulted in the INOPERABILITY of the 71T-3 RTTS which required entry in the LCO. The station began developing a repair and replacement plan as well as an Exigent TS Amendment as soon as the initial trend was identified however the trend rapidly degraded driving entry into the LCO prior to finalizing preparations for replacement.

JAF does not have a ready replacement of the 71T-3 RSST and in order to replace the 71T-3 RSST corrective maintenance is required on the available transformer. Based on the vintage of the spare transformer some important replacement components were not yet available and thus, the work to replace the transformer could not begin.

Reason the Situation Could Not Have Been Avoided This transformer has been in service since 2012. There has been no indication during testing or maintenance to indicate that a degrading gas trend would occur. Gas trending has been identified as a leading performance monitoring predictor of transformer failure.

Current TS:

Technical Specification (TS) Limiting Condition for Operation (LCO) 3.8.1 requires two (2) qualified circuits between the offsite transmission network and the plant Class 1E electrical power distribution system and two (2) emergency diesel generator (EDG) subsystems. Action Statement A.3 requires that if an offsite source is lost, it shall be returned to service within seven (7) days AND 21 days from discovery of failure to meet LCO.

Proposed TS Changes:

Exelon is requesting a one-time extension of the A.3 Required Action to restore the offsite source from seven (7) days AND 21 days from discovery of failure to meet LCO to fourteen (21) days AND 21 days from failure to meet LCO. This will be reflected as a footnote to TS LCO 3.8.1 A.3 Required Action.

The proposed footnote will read as follows:

For the Division 1 offsite circuit only, the Completion Time that the subsystem can be inoperable as specified by Required Action A.3 may be extended beyond 7 days to 21 days to support repair and restoration of 71T-3 RSST. This extension is allowed only when Compensatory Measures described in attachment 5 of License Amendment Requested Dated October 4, 2019 and reviewed and approved by the NRC are in place. Upon completion of the repair and restoration, this footnote is no longer applicable and will expire at 0714 on October 24, 2019 In addition, affected Surveillance Requirements (SRs) associated with other in-service but protected equipment are requested to be suspended until completion of the required repairs. The specific surveillances as well as an assessment of the

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 4 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes equipment is documented in attachments 3 and 4. The affected SRs will be annotated by a footnote as follows:

Following return to service of the 71T-3 Reserve Station Service Transformer, the past due Surveillances will be completed before the end of the next available Divisional window.

3.0 TECHNICAL EVALUATION

The AC Sources for the plant Class 1E AC Electrical Power Distribution System consist of the Main Generator (normal), 115 kV transmission network (reserve), 345 kV transmission network (backfeed, which is only available with the main generator offline and the links removed), and emergency diesel generators (EDGs) A, B, C, and D (onsite). As required by JAFNPP design criteria, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safeguards systems.

The offsite power source consists of two qualified circuits between the transmission network and the plant class 1E distribution system. 71T-3, Reserve Station Service Transformer T3 is a non-safety-related element of one of these circuits which allows connection of either incoming 115 kV transmission line with the safety-related 10500 4 kV emergency bus. The 10500 bus is one of two emergency buses, either of which will power all equipment required for safe shutdown of the plant or mitigation of an accident up to and including the design basis loss of coolant accident. The lines connecting the RSSTs to the 115kV transmission lines are arranged so that a failure of either line does not result in the loss of the other line. If the offsite sources were providing power to the emergency busses and were to fail, the EDG subsystems would automatically energize their respective buses. A qualified offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the 115-kV transmission network source to the plant Class 1E emergency bus or buses.

Upon loss of offsite power or failure of an RSST, the emergency bus undervoltage signal will start the Emergency Diesel Generators (EDGs) and the redundant EDG subsystems would automatically energize their respective emergency buses. Installation of the replacement transformer meets Technical Specification 3.3.8.1 Loss of Power (LOP)

Instrumentation and does not affect the ability of the EDG to supply the emergency buses.

With 71T-3 out of service for maintenance, redundancy of the emergency power system is reduced, and compliance with the intent of General Design Criteria requiring demonstration of the ability to maintain certain safety functions solely with offsite power and accommodating a single failure of safety-related equipment is not assured.

The limiting analyzed Loss of Coolant Accident for JAF is a double-ended guillotine break of a Reactor Water Recirculation system suction line with a passive failure of a Station Battery (Design Basis Accident Loss of Coolant Accident, DBA LOCA). For a DBA LOCA with only offsite power available through the remaining transformer, 71T-2, Reserve Station Service Transformer T2, the LOCA analysis is dependent on the full complement of equipment served by the 10600 bus. Therefore, the intent of GDCs which include both

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 5 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes a power source dependence (offsite or onsite) and accommodation of single failure are not satisfied. This configuration exists any time that condition A or B of LCO 3.8.1 is in effect. With these conditions, a single failure of the other offsite circuit or the other EDG subsystem results in an inability to satisfy the GDC requirement that certain functions be maintained by the offsite power source acting alone or the onsite power source acting alone. The requirements for electric power sources within these criteria are independent of the requirement for single-failure. Although the GDC intent are not met, there is significant redundancy in the plant design. With 71T-3 out of service, the 10500 bus may be supplied by the pair of 93EDG-A and 93EDG-C and the 10600 bus may be supplied by either the pair of 93EDG-B and 93EDG-D or by either offsite 115kV source through 71T-2.

For an event other than a LOCA, there is additional redundancy since only a single Residual Heat Removal (RHR) pump is required for Reactor Pressure Vessel (RPV) injection after the vessel is depressurized and a single RHR Service Water pump required to transfer decay heat to the Ultimate Heat Sink as a limiting case with a substantial reduction in loading of the emergency buses and manual, rather than automatic sequencing of loads. In this case any of the four EDGs may supply the loads necessary for RPV injection and decay heat removal along with associated supporting system loads (cooling for safety related pumps and Standby Gas Treatment system operation to control Secondary Containment parameters). Prior to RPV depressurization, the Reactor Core Isolation Cooling (RCIC) system or the High Pressure Core Injection system may be used for RPV water level control, and RHR for decay heat removal as heat from the fuel is transferred to the suppression pool by the HPCI or RCIC exhaust and operation of Main Steam Safety Relief Valves (SRVs).

With the plant in power operation, electrical loads are normally supplied from the Main Generator through 71T-4, Normal Station Service Transformer T4. In the event of plant shutdown with 71T-3 out of service, loads will be manually or automatically transferred to 71T-2, and if the transfer fails, select loads will be placed on the EDGs. A similar sequence occurs for a LOCA, except in this instance, the EDGs automatically start on the LOCA signal in anticipation of being loaded if the bus transfer to the reserve transformers fails. With the plant is out of service and 71T-3 de-energized, only half of the normal buses are energized (the 10100 and 10300 buses are powered from 71T-3 and will also be out of service). While no manual or automatic transfer to offsite power is required since available electrical buses will already be shifted to an offsite supply through 71T-2, the emergency power system will be in an abnormal lineup. In this case, the 10500 bus must either be supplied by the associated EDGs or maintained de-energized. If energized by the EDGs, safety-related 10500 bus loads would require operation to ensure reliable engine operation. This abnormal operating condition may be precluded by maintaining the plant on-line with power supplied through 71T-4 during the period that 71T-3 is maintained.

Plant response to a Station Blackout (SBO) is not significantly affected by removal of 71T-3 from service. JAF does not credit any offsite power source or the EDGs for maintaining plant safety during its four-hour coping time. The only effect is the number of potential sources of AC power available at the end of the coping period. With 71T-3 out of service, 71T-2 is required to restore AC power from either of the 115 kV lines serving the

Emergency License Amendment Request Attachment 1 Emergency License Amendment Request - One Time Extension to the TS 3.8.1 Page 6 of 15 Action A.3 Completion Time for an Inoperable Offsite Source Evaluation of Proposed Changes station. There is no impact on any of the four EDGs that may be available to restore power to required safe shutdown loads. If the SBO was caused by a fault in 71T-2, restoration of an EDG is required to restore power to the station. The EDGs and their supporting equipment will be protected during the extended completion time, further assuring their availability to mitigate this event.

A completion time of 14 days to restore 71T-3 to service following maintenance is analogous to the currently permitted completion time for restoration of one pair of EDGs (TS 3.8.1 Required Action B.4) with the exceptions that the reserve transformer is not a safety-related component and power from the transformer is passed through an additional bus (10300) prior to reaching the emergency bus and thus marginally less resilient.

Compliance with NUREG 0800 Standard Review Plant, Branch Technical Position:

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," specifically discusses the DID aspects for onsite power sources from a deterministic perspective for proposed Allowed Outage Time (AOT) or Completion Time extensions. No changes are being proposed to the current AOTs for the onsite DGs. The following is a list of critical BTP 8-8 guidance and an explanation of how JAF complies with the guidance criteria, with the plant configuration described above:

a) The supplemental source must have the capacity to bring a unit to safe shutdown (cold shutdown) in case of a loss of offsite power (LOOP) concurrent with a single failure during plant operation (Mode 1).