NL-19-1266, Supplement to License Amendment Request for Technical Specifications 3.3.8.1 and 3.8.1 Regarding Degraded Voltage Protection
| ML19290H599 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/17/2019 |
| From: | Gayheart C Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-19-1266 | |
| Download: ML19290H599 (13) | |
Text
~ Southern Nuclear OCT 1 7 2019 Docket Nos.: 50-321 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Cheryl A. Gayheart Regulatory Affa*rs 01rector Edwin I. Hatch Nuclear Plant-Units 1 and 2 3"'5 Colonnade P.trl..\\\\J~
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205 992 5}16 cnga' heaa c;outhc:rnco com NL-19-1266 Supplement to License Amendment Request for Technical Specifications 3.3.8.1 and 3.8.1 Regarding Degraded Voltage Protection Ladies and Gentlemen:
By letter dated April 30, 2019 (NRC Agencywide Documents Access and Management System Accession No. ML19123A101), and as supplemented by letter dated August 28, 2019 (ML192408751}, Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) related to degraded voltage protection. Among the changes proposed in the LAR were the deletion of Unit 1 and Unit 2 Technical Specification (TS) Surveillance Requirement (SR) 3.3.8.1.1 and the renumbering of TS SRs 3.3.8.1.2 - 3.3.8.1.4 accordingly.
Upon further consideration, SNC would like to modify the request to instead state "Deleted" for Unit 1 and Unit 2 SR 3.3.8.1.1, and avoid renumbering SRs 3.3.8.1.2 - 3.3.8.1.4. SNC considers this request to be an administrative modification to the corresponding SR changes proposed in the April 30, 2019 LAR. As such, the technical justification provided in the April 30, 2019 LAR and the August 28, 2019 supplement are unaffected.
Enclosures 1 and 2 provide revised TS markup and clean-typed pages, respectively, and provides revised TS bases pages for information only. The revised pages provided in Enclosures 1, 2, and 3 correspond to pages in the original LAR affected by the RAI response and supplant the respective pages in the original LAR enclosures.
The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original LAR are unaffected by this request.
This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.
U.S. Nuclear Regulatory Commission NL-19-1266 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the
\\.:!..._day of October 2019.
Respectfully submitted, C. A. G y e
- Director, e
latory Affairs Southern Nuclear Operating Company CAG/RMJ
Enclosures:
- 1. Revised TS Marked-up Pages
- 2. Revised TS Clean-typed Pages
- 3. Revised TS Bases Pages (Information only) cc:
Regional Administrator, Region II NRR Project Manager-Hatch Senior Resident Inspector-Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004
Edwin I. Hatch Nuclear Plant-Units 1 and 2 Supplement to License Amendment Request for Technical Specifications 3.3.8.1 and 3.8.1 Regarding Degraded Voltage Protection Revised TS Marked-up Pages
LOP Instrumentation 3.3.8.1
- -------------------------------------N 0 TE S-----------------------------------------------------------
- 1.
Table 3.3.8.1-1 to determine 't'JAioh SR.s apply for eaoh LOP Funotlon.
- 2.
When a 4.16 kV Emergency Bus Undervoltage channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability (for Funotions 1 and 2) and annunoiatlon oapabili~ (for Funotion a).
SR3.3~
f Deleted.
- ~
SR 3.3.8.1.2 SR 3.3.8.1.3 SR 3.3.8.1.4 HATCH UNIT 1 SURVEILLANCE Perform CHANNEL CHECK.
Perform CHANNEL FUNCTIONAL TEST.
Perform CHANNEL CALIBRATION.
Perform LOGIC SYSTEM FUNCTIONAL TEST.
3.3-71 FREQUENCY In aooordanoe v1ith the Surveillanoe Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 290
LOP Instrumentation 3.3.8.1
*.------------------------------------NOTES-------------------------------------------------------------
- 1.
Table 3.3.8.1 -1 to deterR'Iine whish SRs apply for cash LOP F ~:~nstion.
- 2.
When a 4.16 kV Emergency Bus Undervoltage channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability (for F ~:~notions 1 and 2) and annunoiation oapability (for Funotion 3).
SURVEILLANCE SR 3.3.8~
Perform CHANNEL CHECK.
~ Deleted. *~
SR 3.3.8.1.2 Perform CHANNEL FUNCTIONAL TEST.
SR 3.3.8.1.3 Perform CHANNEL CALIBRATION.
SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST.
HATCH UNIT 2 3.3-71 FREQUENCY In aosordanoe with the SuNeillanse Frequenoy Control PrograR'I In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. ~
Edwin I. Hatch Nuclear Plant-Units 1 and 2 Supplement to License Amendment Request for Technical Specifications 3.3.8.1 and 3.8.1 Regarding Degraded Voltage Protection Revised TS Clean Typed Pages
SURVEILLANCE REQUIREMENTS LOP Instrumentation 3.3.8.1
N 0 TE S-----------------------------------------------------------
- 1.
These SRs apply to each Function in Table 3.3.8.1-1.
- 2.
When a 4.16 kV Emergency Bus Undervoltage channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability.
SURVEILLANCE SR 3.3.8.1.1 Deleted.
SR 3.3.8.1.2 Perform CHANNEL FUNCTIONAL TEST.
SR 3.3.8.1.3 Perform CHANNEL CALIBRATION.
SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST.
HATCH UNIT 1 3.3-71 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.
SURVEILLANCE REQUIREMENTS LOP Instrumentation 3.3.8.1
N 0 TE S-------------------------------------------------------------
- 1.
These SRs apply to each Function in Table 3.3.8.1-1.
- 2.
When a 4.16 kV Emergency Bus Undervoltage channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability.
SURVEILLANCE SR 3.3.8.1.1 Deleted.
SR 3.3.8.1.2 Perform CHANNEL FUNCTIONAL TEST.
SR 3.3.8.1.3 Perform CHANNEL CALIBRATION.
SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST.
HATCH UNIT2 3.3-71 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.
Edwin I. Hatch Nuclear Plant-Units 1 and 2 Supplement to License Amendment Request for Technical Specifications 3.3.8.1 and 3.8.1 Regarding Degraded Voltage Protection Revised TS Bases Pages (Information only)
BASES LOP Instrumentation B 3.3.8.1 ACTIONS 8.1 (continued)
SURVEILLANCE REQUIREMENTS HATCH UNIT 1 With one or more Function a channels per bus inoperable, annunciation capability may not be available to alert the operator of a degraded voltage oondition on the Unit 1 4.16 kV emergency buses.
Sinoe the intended function is to alert personnel to a lo*Nering voltage condition and tl=le voltage reading is available for each bus on the oontrol room front panels, the Required 1\\ction is verification of the voltage to be above the annunciator setpoint (nominal) hourly.
If any Required Action and associated Completion Time are not met, the associated Function does not maintain initiation capability for the associated emergency bus. Therefore, the associated DG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable DG(s). ~
As noted at the beginning of the SRs, the SRs fof~
instrumentation Function are located in the SRs oolumn of~
Table 3.3.8.1-1. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability-tfof Functions 1 and 2) and annunciation capabili~ (for Function a).
Functions 1 and 2 maintain initiation capability provided that, for 2 of the 3 emergency buses, the following can be initiated by the Function:
DG start, disconnect from the offsite power source, DG output breaker closure, load shed, and activation of the ECCS pump power permissive. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.
~
SR 3.3.8.1.1 ~ ~
Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation or a failure of annunsiation has not ocourred. A CHANNEL CHECK is defined for Function a to be a oomparison of the annunciator status to the bus 'IOitage and an annunciator test confirming tl:le annuneiator is capable of lighting and sounding.
(continued)
B 3.3-202 REVISION 101
(
BASES SURVEILLANCE REQUIREMENTS HATCH UNIT 1 SR 3.3.8.1.1 (sontinued)
LOP Instrumentation B 3.3.8.1 A CHANNEL CHECK will detest gross ohannel failure or annunoiator failure; thus, it is key to verifying the instrumentation oontinues to operate properly betv.*een eaoh CHANNEL CI\\LIBRI\\TION.
If a ol=lannel is outside the matol=l oriteria, it may be an indioation that the instrument has drifted outside its limit.
The Suf\\!eillanoe Frequency is oontrolled under the SuiVeillance Frequenoy Control Progrom. The CHI\\N~~El CHECK supplements less formal, but more frequent, shooks of ohannels during normal operational use of the displays associated with channels required by the LCO.
SR 3.3.8.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.8.1.3 A CHANNEL CALl BRA TION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALl BRA TION leaves the channel adjusted to account for instrument drifts between successive calibrations, consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.
(continued)
B 3.3-203 REVISION 101
BASES LOP Instrumentation B 3.3.8.1 ACTIONS B4 (continued)
SURVEILLANCE REQUIREMENTS HATCH UNIT2 With one or more Function a channels per required bus inopemble, annunciation capability may not be available to alert the operator of a de!iJraded volta!iJe condition on the required Unit 1 4.16 kV emergency buses.
Since the intended funotion is to alert personnel to a lowerin!iJ volta!iJe oondition and the voltage readin!iJ is a¥ailable for each bus on the control room front panels, the Required Aotion is ¥erification of the
~o*olta!iJe to be above the annunoiator setpoint (nominal) hourly.
~G.1 If any Required Action and associated Completion Time are not met, the associated Function does not maintain initiation capability for the associated emergency bus. Therefore, the associated DG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable DG(s).
As noted at the beginning of the SRs, the SRs each LOP ~
instrumentation Function are located in the SRs column of~
Table 3.3.8.1-1. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions.may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains initiation capability-tfef Funotions 1 and 2) and annunciation oapability (for Funotion a).
Functions 1 and 2 maintain initiation capability provided that, for 2 of the 3 emergency buses, the following can be initiated by the Function:
DG start, disconnect from the offsite power source, DG output breaker closure, load shed, and activation of the ECCS pump power permissive. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.
~
SR 3.3.8.1.1 I --------------
Performance of the CHANNEL CHECK ensures that a !iJross failure of instr1:1mentation or a fail1:1re of annunciation has not occurred. A CHANNEL CHECK is defined for Funotion a to be a comparison of the annunciator status to the bus volta!iJe and an annunciator test confirmin!iJ the ann1:1neiator is oapable of li!iJhtin!iJ and sot:Jndin!iJ. A CHANNEL CHECK will detest !iJFOss channel failure or an ann1:1noiator failure; thus, it is key to *:erifying the instrumentation continues to (continued)
B 3.3-202 REVISION 113
BASES SURVEILLANCE REQUIREMENTS HATCH UNIT2 SR 3.3.8.1.1 (contiffileG)
LOP Instrumentation B 3.3.8.1 operate properly between each CHANf>~El CALIBRATION.
If a ohannol is outside the matoh criteria, it may be an indication that the instrument has drifted outside its limit.
The Sur\\'eillance Frequency is controlled under the SuF\\'eillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, cheeks of channels during normal operational use of the displays associated with channels required by the LCO.
SR 3.3.8.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.
CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations, consistent with the plant specific setpoint methodology.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel.
(continued)
B 3.3-203 REVISION 113