ML20280A329
| ML20280A329 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/20/2020 |
| From: | Audrey Klett Plant Licensing Branch IV |
| To: | Entergy Operations |
| Lee S, NRR/DORL/LPL4, 4153168 | |
| References | |
| EPID L-2019-LLA-0230 | |
| Download: ML20280A329 (22) | |
Text
October 20, 2020 Site Vice President Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - ISSUANCE OF AMENDMENT NO. 258 REGARDING TECHNICAL SPECIFICATION 3/4.8.1 SURVEILLANCE REQUIREMENTS (EPID L-2019-LLA-0230)
Dear Sir or Madam:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 258 to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). This amendment revises the Technical Specifications (TSs) in response to the application from Entergy Operations, Inc. via letter W3F1-2019-0073 dated October 24, 2019, as supplemented by letter W3F1-2020-0033 dated May 29, 2020.
Specifically, the amendment revises various surveillance requirements (SRs) in Waterford 3 TS 3/4.8.1, A.C. [Alternating Current] Sources - Operating, by correcting the SRs frequency and voltage values to ensure that the emergency diesel generators are capable of supplying power to the required loads.
The NRC staffs safety evaluation of the amendment is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Audrey L. Klett, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosures:
- 1. Amendment No. 258 to NPF-38
- 2. Safety Evaluation cc: Listserv
ENTERGY OPERATIONS, INC.
DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 258 Renewed License No. NPF-38
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (EOI) dated October 24, 2019, as supplemented by letter dated May 29, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations 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 Commissions regulations; 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 Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Renewed Facility Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. NPF-38 is hereby amended to read as follows:
- 2.
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 258, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 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 Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-38 and Technical Specifications Date of Issuance: October 20, 2020 Jennifer L.
Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2020.10.20 14:52:11 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 258 RENEWED FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 Replace the following pages of Renewed Facility Operating License No. NPF-38 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License No. NPF-38 Remove Page Insert Page Technical Specifications Remove Page Insert Page 3/4 8-3 3/4 8-3 3/4 8-4 3/4 8-4 3/4 8-5 3/4 8-5 3/4 8-6 3/4 8-6 3/4 8-6a 3/4 8-6a
the NRC of any action by equity investors or successors in interest to Entergy Louisiana, LLC that may have an effect on the operation of the facility.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
- 1.
Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3716 megawatts thermal (100% power) in accordance with the conditions specified herein.
- 2.
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 258, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
Antitrust Conditions (a)
Entergy Louisiana, LLC shall comply with the antitrust license conditions in Appendix C to this renewed license.
(b)
Entergy Louisiana, LLC is responsible and accountable for the actions of its agents to the extent said agent's actions contravene the antitrust license conditions in Appendix C to this renewed license.
AMENDMENT NO. 258
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS WATERFORD-UNIT3 3/483 AMENDMENTNO.23,74,126,216,249 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be:
a.
Determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments, indicated power availability, and b.
Demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by transferring manually and automatically unit power supply from the normal circuit to the alternate circuit.
4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE*:
a.
In accordance with the Surveillance Frequency Control Program by:
1.
Verifying the fuel level in the diesel oil feed tank, 2.
- Deleted, 3.
Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the diesel oil feed tank, 4.
Verifying the diesel generator starts** from standby condition and achieves:
a)
In 10 seconds, voltage 3920 volts and frequency 58.8 Hz, and b)
Steady state voltage 4160 +420, -240 volts, and frequency 60 +1.2, -0.3 Hz.
The diesel generator shall be started for this test by using one of the following signals:
a)
Manual.
b)
Simulated loss-of-offsite power by itself.
c)
Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.
d)
An ESF actuation test signal by itself.
- All planned starts for the purpose of surveillance in this section may be preceded by a prelube period as recommended by the manufacturer.
- A modified diesel generator start involving idling and gradual acceleration to synchronous speed may be used for this surveillance requirement as recommended by the manufacturer. When modified start procedures are not used, the time, speed, voltage, and frequency tolerances of this surveillance requirement must be met.
, 258
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
WATERFORD-UNIT3 3/484 AMENDMENTNO.4,23,92,126,180,216,249 5.
Verifying the generator is synchronized, loaded to an indicated 4000-4400 Kw* in accordance with the manufacturer's recommendation and operates for at least an additional 60 minutes#, and 6.
Verifying the diesel generator is aligned to provide standby power to the associated emergency buses.
b.
In accordance with the Surveillance Frequency Control Program and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the diesel oil feed tanks.
c.
Deleted d.
In accordance with the Surveillance Frequency Control Program a diesel generator fast start test shall be performed in accordance with TS 4.8.1.1.2a.4.
Performance of the fast start test satisfies the testing requirements specified in TS 4.8.1.1.2a.4.
e.
In accordance with the Surveillance Frequency Control Program by:
1.
Verifying the generator capability to reject a load of greater than or equal to 498 kW while maintaining voltage at 4160 +420, -240 volts and frequency at 60 +4.5, -1.2 Hz.
2.
Verifying the generator capability to reject a load of an indicated 4000-4400 kW without tripping. The generator voltage shall not exceed 5023 volts during and following the load rejection.
- This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band for special testing under direct monitoring of the manufacturer or momentary variation due to changing bus loads shall not invalidate the test.
- This surveillance requirement shall be preceded by and immediately follow without shutdown a successful performance of 4.8.1.1.2a.4 or 4.8.1.1.2d.
, 258
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
WATERFORD-UNIT3 3/485 AMENDMENTNO.4,23,74,88,98,126, 180,216,249 3.
Verifying, during shutdown, on a simulated loss-of-offsite power signal by itself:
a)
Deenergization of the emergency buses and load shedding from the emergency buses.
b)
The diesel generator auto-starts from standby condition and:
i)
Energizes the emergency buses and the permanently connected loads in 10 seconds, ii)
Energizes the auto-connected shutdown loads through the load sequencer, iii)
Operates for 5 minutes while loaded with the shutdown loads, and iv)
The steady-state voltage and frequency of the emergency buses shall be maintained at 4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test.
4.
Verifying on an SIAS actuation test signal (without loss-of-offsite power) the diesel generator auto-starts from standby condition and:
a)
Achieves, in 10 seconds after auto-start and during tests, voltage 3920 volts and frequency 58.8 Hz, b)
Achieves steady state voltage 4160 +420, -240 volts and frequency 60 +1.2, -0.3 Hz, c)
Operates for 5 minutes.
5.
Verifying, during shutdown, on a simulated loss-of-offsite power signal in conjunction with an SIAS actuation test signal:
a)
Denergization of the emergency buses and load shedding from the emergency buses.
, 258
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
WATERFORD-UNIT3 3/486 AMENDMENTNO.4,23,74,98,126,180 b)
The diesel generator auto-starts from standby condition and:
i)
Achieves, in 10 seconds, voltage 3920 volts and frequency 58.8 Hz, ii)
Energizes, in 10 seconds, the emergency buses and the permanently connected loads, iii)
Energizes the auto-connected emergency loads through the load sequencer, iv)
Achieves steady state voltage 4160 +420, -240 volts, v)
Achieves steady state frequency 60 +1.2, -0.3 Hz, and vi)
Operates for greater than or equal to 5 minutes.
c)
Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection actuation signal.
6.
Verifying the diesel generator operates for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
a)
For 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded to an indicated 4700 to 4900 Kw* and b)
For the remaining hours of the test, loaded to an indicated 4000 to 4400 Kw.*
c)
Verify the diesel generator starts and achieves, in 10 seconds, voltage 3920 volts and frequency 58.8 Hz.
d)
Verify the diesel generator achieves steady state voltage 4160 +420, -240 volts, and frequency 60 + 1.2, -0.3 Hz during this test.
e)
Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2.a.4.**
- This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band for special testing under direct monitoring of the manufacturer or momentary variation due to changing bus loads shall not invalidate the test.
- If Surveillance Requirement 4.8.1.1.2.a.4 is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead, the diesel generator may be operated at an indicated 4000-4400 kw* for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until internal operating temperatures have stabilized.
Within 5 minutes of securing the diesel generator, perform Surveillance Requirement 4.8.1.1.2.a.4
, 258
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
WATERFORD-UNIT3 3/486a AMENDMENTNO.23,92,126,180, 211,216,249 7.
During shutdown, verifying that the auto-connected loads and permanently connected loads to each diesel generator do not exceed the 2000-hour rating of 4400 kW.
8.
During shutdown, verifying the diesel generator's capability to:
a)
Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b)
Transfer its loads to the offsite power source, and c)
Be restored to its standby status.
9.
During shutdown, verifying that with the diesel generator operating in a test mode (connected to its bus), a simulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.
10.
Verifying that each fuel transfer pump transfers fuel to its associated diesel oil feed tank by taking suction from the opposite train fuel oil storage tank via the installed cross connect.
11.
During shutdown, verifying that the automatic load sequence timer is OPERABLE with the time of each load block within +/-10% of the sequenced load block time.
12.
Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:
a) turning gear engaged b) emergency stop c) loss of D.C. control power d) governor fuel oil linkage tripped f.
Deleted g.
In accordance with the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence, verify, when started simultaneously, during shutdown, from standby condition, each diesel generator achieves:
1.
In 10 seconds, voltage 3920 volts and frequency 58.8 Hz, and 2.
Steady state voltage 4160 +420, -240 volts, and frequency 60 +1.2, -0.3 Hz.
h.
Deleted
, 258
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 258 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION
1.1 Background
By letter W3F1-2019-0073 dated October 24, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19297H543), as supplemented by letter W3F1-2020-0033 dated May 29, 2020 (ADAMS Accession No. ML20150B638), Entergy Operations, Inc. (the licensee) applied for a license amendment to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). The licensee requested to revise various surveillance requirements (SRs) in Waterford 3 Technical Specification (TS) 3/4.8.1, A.C. [Alternating Current] Sources - Operating, by correcting the SRs frequency and voltage values to ensure that the emergency diesel generators (EDGs) are capable of supplying power to the required loads. The licensee also proposed some editorial changes to the SRs for consistency and clarity. In addition, the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff included an editorial change (i.e., a line above the footnote on TS page 3/4 8-3) per the licensees requested clean pages that did not affect the meaning of the TSs.
By letter dated April 1, 2020, the NRC, the Commission sent the licensee a request for additional information (RAI) (ADAMS Accession No. ML20086M385). By letter W3F1-2020-0033 dated May 29, 2020, the licensee responded to the RAI. The supplemental letter dated May 29, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs proposed no significant hazards consideration determination published in the Federal Register on December 17, 2019 (84 FR 68952).
1.2 Description of the EDGs and Current TS Requirements Section 8.3.1, AC Power Systems, of the Waterford 3 Updated Final Safety Analysis Report (UFSAR) (ADAMS Accession No. ML19268A129) describes the onsite power systems, including the standby power supply, which consists of two EDGs. The licensee stated in its
license amendment request (LAR) dated October 24, 2019, that the EDG system is arranged in two separate divisions that are functionally identical. The safety-related functions of each divisions EDG are to provide sufficient power to (1) control and shutdown systems in the event of an accident condition and loss of preferred power from the offsite power source and (2) enable a controlled shutdown of the plant whenever there is no accident but preferred power is lost in both divisions. Each EDG carries out its purpose of supplying standby electrical power by starting on receipt of either a manual or automatic command signal, accelerating to rated speed, and accepting load as determined by the safety system requirements.
The Waterford 3 UFSAR states that each EDG is rated at 4400 kilowatts (kW) when operating at 4.16 kilovolts and 0.8 power factor. The rated speed of each EDG engine is 600 revolutions per minute, which produces a steady-state generator frequency of 60 hertz (Hz). The EDG ratings are sufficient to supply reliable power to all safety-related loads in the associated division and some procedurally controlled manual loads. Each EDG unit is designed to start automatically upon receipt of an accident or loss-of-voltage signal and attain rated speed and rated voltage within 10 seconds. The EDGs are designed to automatically accept loads in each division that are required to mitigate the consequences of postulated accident conditions. The performance capability of rotating equipment to supply design flow rates of fluid systems is dependent on the steady-state frequency and voltage of the onsite power supply systems.
Waterford 3TS 3/4.8.1 has several SRs that demonstrate operability of the EDGs. These SRs have, in part, frequency and voltage requirements, alignment requirements, and load shedding requirements for the EDGs.
1.3 Licensees Proposed Changes to the TSs In the LAR, the licensee proposed to modify TS 3/4.8.1 SRs 4.8.1.1.2.a.4, 4.8.1.1.2.a.6, 4.8.1.1.2.e.3, 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.5.a, 4.8.1.1.2.e.5.b, 4.8.1.1.2.e.6, and 4.8.1.1.2.g to correct errors in some criteria for frequency and voltage to conform to the plant design basis and ensure that the EDGs are capable of supplying power with the correct frequency and voltage to required loads. The licensee also proposed to make editorial changes to SRs 4.8.1.1.2.d, 4.8.1.1.2.e.1, 4.8.1.1.2.e.2, and 4.8.1.1.2.e.7.
The licensee stated in its LAR that the current SR acceptance criteria for the EDGs allow a +/- 1.2 Hz variation in steady-state frequency. The licensee has concluded that the allowable variation in frequency is non-conservative when a combination of uncertainties (e.g., component degradation, instrumentation, and frequency) are factored into the performance capabilities of the pumps and motors powered by the EDGs, and that the TS should be changed to a minimum steady-state frequency of 59.7 Hz.
The licensee has also concluded that the steady-state under-voltage limit should be increased to 3920 volts (4160 -240 volts), which ensures the degraded voltage relay will reset under the worst equipment drift and inaccuracy condition, as supported by Waterford 3 License Amendment No. 74 dated August 24, 1992 (ADAMS Accession No. ML021770163).
The licensee also proposed editorial changes and a spelling correction for consistency and clarity.
The licensee proposed the following changes to TS 3/4.8.1:
Change #1: Revise SR 4.8.1.1.2.a.4 to state:
- 4. Verifying the diesel starts** from standby condition and achieves:
a)
In [less than or equal to]10 seconds, voltage [greater than or equal to] 3920 volts and frequency 58.8 Hz, and b)
Steady state voltage 4160 +420, -240 volts, and frequency 60 +1.2 Hz, -0.3 Hz.
The diesel generator shall be started for this test by using one of the following signals:
Change #2: Correct spelling in SR 4.8.1.1.2.a.6 The licensee proposed to change the spelling of busses to buses.
Change #3: Move SRs 4.8.1.1.2.d, 4.8.1.1.2.e.1, and 4.8.1.1.2.e.2 The licensee proposed to move SRs 4.8.1.1.2.d, 4.8.1.1.2.e.1, and 4.8.1.1.2.e.2 from TS page 3/4 8-5 to page 3/4 8-4 for editorial reasons. The licensee did not propose any non-editorial changes to the SRs content.
Change #4: Revise SR 4.8.1.1.2.e.3 to state:
- 3.
Verifying, during shutdown, on a simulated loss-of-offsite power signal by itself:
a)
Deenergization of the emergency buses and load shedding from the emergency buses.
b)
The diesel generator auto-starts from standby condition and:
i)
Energizes the emergency buses and the permanently connected loads in 10 seconds, ii)
Energizes the auto-connected shutdown loads through the load sequencer, iii)
Operates for 5 minutes while loaded with the shutdown loads, and iv)
The steady-state voltage and frequency of the emergency buses shall be maintained at 4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test.
Change #5: Revise SR 4.8.1.1.2.e.4 to state:
- 4.
Verifying on an SIAS [safety injection actuation signal] actuation test signal (without loss-of-offsite power) the diesel generator auto-starts from standby condition and:
a)
Achieves, in 10 seconds after auto-start and during tests, voltage 3920 volts and frequency 58.8 Hz, b)
Achieves steady state voltage 4160 +420, -240 volts and frequency 60 +1.2, -0.3 Hz, c)
Operates for 5 minutes.
Change #6: Revise SRs 4.8.1.1.2.e.5 and 4.8.1.1.2.e.5.a to state:
- 5.
Verifying, during shutdown, on a simulated loss-of-offsite power signal in conjunction with an SIAS actuation test signal:
a)
Deenergization of the emergency buses and load shedding from the emergency buses.
Change #7: Revise SR 4.8.1.1.2.e.5.b to state:
b)
The diesel generator auto-starts from standby condition and:
i)
Achieves, in 10 seconds, voltage 3920 volts and frequency 58.8 Hz, ii)
Energizes, in 10 seconds, the emergency buses and the permanently connected loads, iii)
Energizes the auto-connected emergency loads through the load sequencer, iv)
Achieves steady state voltage 4160 +420, -240 volts, v)
Achieves steady state frequency 60 +1.2, -0.3 Hz, and vi)
Operates for greater than or equal to 5 minutes.
Change #8: Revise SR 4.8.1.1.2.e.6 to state:
- 6.
Verifying the diesel generator operates for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
a)
For 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded to an indicated 4700 to 4900 kW* and b)
For the remaining hours of the test, loaded to an indicated 4000 to 4400 kW.*
c)
Verify the diesel generator starts and achieves, in 10 seconds, voltage 3920 volts and frequency 58.8 Hz.
d)
Verify the diesel generator achieves steady state voltage 4160 +420, -240 volts, and frequency 60 + 1.2, -0.3 Hz during this test.
e)
Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8.1.1.2.a.4.**
Change #9: Move SR 4.8.1.1.2.e.7 The licensee proposed moving SR 4.8.1.1.2.e.7 from page 3/4 8-6 to page 3/4 8-6a for editorial reasons. There are no proposed changes to the SRs content.
Change #10: Revise SR 4.8.1.1.2.g to state:
- g.
In accordance with the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence, verify, when started simultaneously, during shutdown, from standby condition, each diesel generator achieves:
- 1.
In 10 seconds, voltage 3920 volts and frequency 58.8 Hz, and
- 2.
Steady state voltage 4160 +420, -240 volts, and frequency 60 +1.2, -0.3 Hz.
2.0 REGULATORY EVALUATION
The NRC staff considered the following regulations, licensing and design bases, and guidance during its review of the proposed changes.
2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, states, in part, that whenever a licensee desires to amend the license..., application for an amendment must be filed with the Commission... fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
The regulation under 10 CFR 50.92(a) states that determinations on whether to grant an applied-for license amendment are guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for operating licenses and construction permits in 10 CFR 50.40(a) and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3) provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The regulation under 10 CFR 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. The categories of items required to be in the TSs are listed in 10 CFR 50.36(c). SRs are defined in 10 CFR 50.36(c)(3) as requirements relating
to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulation under 10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors, requires, in part, that nuclear power plants must be provided with an emergency core cooling system (ECCS) that must be designed so that its calculated cooling performance following postulated loss-of-coolant accidents conforms to the criteria set forth [in the section]. ECCS cooling performance must be calculated in accordance with an acceptable evaluation model and must be calculated for a number of postulated loss-of-coolant accidents of different sizes, locations, and other properties sufficient to provide assurance that the most severe postulated loss-of-coolant accidents are calculated....
Comparisons to applicable experimental data must be made and uncertainties in the analysis method and inputs must be identified and assessed so that the uncertainty in the calculated results can be estimated.
General Design Criterion (GDC) 17, Electric power systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50 requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite transmission network, or the onsite power supplies.
GDC 18, Inspection and testing of electric power systems, requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.
GDC 34, Residual heat removal, states that a system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded. The GDC requires in part that capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) the system safety function can be accomplished, assuming a single failure.
2.2 Licensing and Design Bases The licensee discussed the current licensing basis and evaluation in Section 3.2, Current Licensing Basis and Evaluation, of the LAR. Calculation assumptions for EDG frequency were incorporated into the SRs in TS 3/4.8.1. The licensee performed subsequent evaluations to ensure adequate margin to the design basis required flow to account for the effects of the diesel generator under-frequency condition.
The licensee also discussed Waterford 3 License Amendment No. 74, dated August 24, 1992.
This license amendment included a change to the minimum voltage specification in TS 3.8.1.1
SRs. This change was made to ensure that the degraded voltage relay will reset under the worst equipment drift and inaccuracy conditions.
2.3 Guidance NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 (ADAMS Accession No. ML100351425), contains guidance for reviews of TSs. The NRC staff applies this guidance in its reviews to help it determine whether the proposed changes would clarify the intent of the TSs.
Regulatory Guide 1.9, Revision 4, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants, dated March 2007 (ADAMS Accession No. ML070380553).
Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, dated December 29, 1998 (ADAMS Accession No. ML031110108).
3.0 TECHNICAL EVALUATION
The proposed amendment would revise TS 3/4.8.1 SRs to correct non-conservative errors in the criteria for voltage and frequency. In the LAR, the licensee stated that the acceptance criteria for TS 3/4.8.1 are currently being administratively controlled per Administrative Letter 98-10. The licensee is seeking to revise the allowable minimum steady-state EDG frequency and voltage to 59.7 Hz and 3920 volts, respectively.
Plant safety analyses make specific assumptions regarding the ECCS flow to provide the core cooling function following any event that requires safety injection to mitigate the event. For the events that assume offsite power is lost, the EDGs provide power to the ECCS pumps.
The ECCS flow provided by the ECCS pumps is determined by the pump speed, which in turn is a function of the EDGs frequency and voltage. The primary effect of reduced frequency and voltage on the ECCS safety functions is to decrease the speed of safety-related motors that are powered by the EDGs, which affects, for example, pump performance, motor-operated valve (MOV) stroke times, and cooling fan performance. A higher than normal frequency will result in higher speed of rotating equipment and potential increase in the pressure in the ECCS.
The NRC staff evaluated the licensees application to determine if the proposed changes are consistent with the guidance, regulations, and plant-specific design and licensing basis information. Specifically, the NRC staff reviewed the proposed changes to TS 3/4.8.1 to restrict the steady-state voltage and frequency limits for EDGs operation to ensure that accident mitigation equipment can perform to satisfy the requirements of 10 CFR 50.46.
3.1 EDG Allowable Steady-State Frequency Limit In Section 3.2 of the LAR, the licensee stated that the hydraulic performance of the high-pressure safety injection and low-pressure safety injection (LPSI) systems are determined in calculations, and these calculations determine that the minimum safety analyses delivery assumptions for these systems are met at an EDG under-frequency limit of 59.7 Hz (60 Hz -
0.3 Hz). The licensee also stated that the design basis flow calculation for the emergency feedwater system was revised to account for an EDG under-frequency limit of 59.7 Hz. The licensee also performed an extent of condition action to investigate if the flow calculations for
pumps operated by the EDGs following a loss of offsite power (LOOP) account for the EDG under-frequency limit of 59.7 Hz, and if the under-frequency limit had the potential to result in the system not providing the required flow in a LOOP scenario. The licensees review concluded that all the pumps reviewed had adequate margin to its design basis flow rates to account for an EDG under-frequency limit of 59.7 Hz. The NRC staff finds that a 0.5 percent decrease in pump flow rate due to an EDG under-frequency limit of 59.7 Hz is not significant (Flow Rate 59.7 Hz = Flow Rate 60 Hz x (59.7Hz/60 Hz)). Also, the licensee revised its calculations for the high-pressure safety injection, low-pressure safety injection, and emergency feedwater systems to account for an EDG under-frequency limit of 59.7 Hz, and performed an extent of condition action on the flow rates of other applicable systems, which determined that all of the pumps had adequate margin with an EDG under-frequency limit of 59.7 Hz.
In the RAI dated April 1, 2020, the NRC staff requested the licensee to discuss the impact of the voltage limits and frequency variations proposed in the LAR on other safety-related equipment.
Specifically, the NRC staff requested information on performance capabilities and flow rates of EDG support systems which have pumps that may be subjected to lower engine speeds and electric power driven safety-related equipment, such as MOVs, heaters, fans, or pumps, that were evaluated for conformance with the assumptions in the accident analyses for Waterford 3.
In the supplemental letter to the LAR dated May 29, 2020, the licensee provided responses to the staffs RAI.
The licensee stated in its supplement to the LAR that an EDG under-frequency limit of 59.7 Hz will cause a minimal decrease in the EDG lube oil pump flow rate. However, there is a standby lube oil pump available that will automatically start if the lube oil pressure drops below a set pressure. The NRC staff finds that a 0.5 percent decrease in lube oil pump flow rate due to an EDG under-frequency limit of 59.7 Hz is not significant and will not affect the performance of the EDG lube oil system and that the standby lube oil pump will provide lube oil flow if the lube oil pressure drops.
The licensee also stated in its supplement to the LAR that an EDG under-frequency limit of 59.7 Hz is not an issue due to the jacket water pump rating and that the jacket water temperature control valve located in the jacket water piping loop will open in order to maintain jacket water temperature. The NRC staff finds that a 0.5 percent decrease in the jacket water pump flow rate due to an EDG under-frequency limit of 59.7 Hz is not significant and will not affect the performance of the EDG jacket water system. Further, the temperature control valve will mix hot and cold water to provide the proper jacket water temperature to the water entering the EDG.
The licensee stated in its supplement to the LAR that although the flow rates from the fuel oil transfer pumps are lower at an EDG under-frequency limit of 59.7 Hz, the lower flow rates are within the available margin. The licensees calculation determined that the minimum flow rates from the fuel oil transfer pumps to the diesel oil feed tanks is 47 gallons per minute (gpm). The maximum required flow rate from the diesel oil feed tanks is 15 gpm. The calculation does not account for the EDG under-frequency limit of 59.7 Hz because of the large differential in inlet and outlet flows for the tanks. The NRC staff finds that the 0.5 percent decrease in the fuel oil transfer pump flow rate due to an EDG under-frequency limit of 59.7 Hz is not significant and will not affect the performance of the EDG fuel oil system. The licensees calculation, performed at an EDG frequency of 60 Hz, concludes that the minimum flow rate of fuel oil into the diesel oil feed tanks is over three times the maximum amount flowing from the tanks to the EDGs. This margin is much greater than the lower minimum fuel oil flow rate to the tanks due to the EDG
under-frequency limit of 59.7 Hz (approximately 46.8 gpm) and the maximum tank outflow of 15 gpm.
The licensee also stated in its supplement to the LAR that pump flow is proportional to pump speed (motor frequency), and pump head is proportional to the square of the pump speed. An EDG under-frequency limit of 59.7 Hz from the nominal value of 60 Hz results in a decrease in pump flow of 0.5 percent and a decrease in pump head of 1.0 percent. Pump available net positive suction head (NPSH) will slightly increase due to the decreased pump flow. The licensee stated that these changes in pump flow, pump head and available NPSH are minimal and within existing margins. The NRC staff finds that a 0.5 percent decrease in the pump flow rate and a 1.0 percent decrease in pump head due to an EDG under-frequency limit of 59.7 Hz is not significant and will not affect the performance of the pumps. Also, the margin between the pumps available NPSH and required NPSH will increase at the decreased flow rate.
The licensee also stated in its supplement to the LAR that MOV stroke time is proportional to frequency, and an increase in EDG under-frequency limit of 58.8 Hz to 59.7 Hz will improve MOV performance. Compared to the nominal frequency of 60 Hz, an EDG under-frequency of 59.7 Hz will lower the MOV stroke time by 0.5 percent. This minimal change is within existing margins. The NRC staff finds that lowering the MOV stroke time by 0.5 percent due to an EDG under-frequency limit of 59.7 Hz is not significant and will not affect the performance of the MOVs associated with EDG or its support systems. The proposed allowable frequency range does not result in an increase or decrease in MOV motor torque outside the bounds of the existing frequency range. The tighter frequency band will mean a tighter stroke band, which is conservative, and therefore acceptable.
The licensee further stated in its supplement to the LAR that A review of the under-frequency on the electrical performance of motors, static uninterruptible power supplies (SUPS), battery chargers, transformers, and heaters that are fed by the EDG during a LOCA [loss-of-coolant accident] coincident with a LOOP was performed. The licensee has concluded that, Therefore, the proposed under-frequency value is within the span of frequency where the motors, SUPS, battery chargers, transformers, and heaters can operate. Based on the licensees response, the NRC staff finds that the licensee has adequately addressed the potential impacts of the proposed allowable steady-state frequency on other safety-related electrical systems.
3.2 EDG Allowable Steady-State Voltage Limit The licensee requested to revise the EDGs steady-state voltage range in SR 4.8.1.1.2.e.6 to 4160 +420, -240 volts, in order to maintain the desired EDG operating parameters. The licensee stated in Section 2, Detailed Description, of the LAR regarding the EDG voltage:
The minimum voltage of 3920 volts ensures the degraded voltage relay will reset under the worst equipment drift and inaccuracy condition, as supported by Waterford 3 License Amendment No. 74 (Reference 10).
In the supplemental letter dated May 29, 2020, the licensee stated:
The minimum voltage of 3920 volts [V] envelopes and protects the degraded voltage relay trip setpoint of 3875 volts and its reset value of 3915 volts. The degraded voltage relay trip setpoint is shown in Waterford 3 Technical Specification Table 3.3-4. The 3920V ensures safe operations of all safety
related electrical loads. Additionally, it assures the minimum voltage output of the EDG is adequate before the safety related loads are connected and the degraded voltage relays reset.
The NRC staff concurs with the licensee that increasing the allowable minimum steady-state EDG voltage limit as proposed is conservative because it bounds the degraded voltage relay setpoint and reset value. In addition, the increased voltage value was previously approved in Waterford 3 License Amendment No. 74 and incorporated into SR 4.8.1.1, except for SR 4.8.1.1.2.e.6. The licensees proposed TS change would maintain consistency in SR 4.8.1.1 and is acceptable.
3.3 Editorial Changes of TS SRs In the LAR, the licensee proposed to make some editorial changes to the Waterford 3 TS 3/4 8.1 SRs for consistency and clarity and to correct a spelling error. The SRs specified in Section 1.3 of this safety evaluation (SE) have been rewritten and reformatted to improve clarity.
The proposed changes by the licensee are editorial and are based on the format of NUREG 1432, Revision 4, Standard Technical Specifications - Combustion Engineering Plants, Volume 1 (ADAMS Accession No. ML12102A165). The NRC staff notes that, in SR 4.8.1.1.2.e.1, the licensee kept the current licensing basis values for steady-state frequency limits and the proposed changes to this SR are editorial. SR 4.8.1.1.2.e.1 states that, Verifying the generator capability to reject a load of greater than or equal to 498 kW while maintaining voltage at 4160 +420, -240 volts and frequency at 60 +4.5, -1.2 Hz. The NRC staff did not evaluate the unchanged voltage and frequency values in SR 4.8.1.1.2.e.1 because they are part of the licensing basis and only considered the proposed editorial changes to the SR.
The NRC staff finds that the proposed changes to the SRs mentioned above are editorial in nature and do not impact the intent of the technical requirements established in the existing SRs. Therefore, the NRC staff finds that the proposed editorial changes are acceptable.
3.4 Evaluation of SR Changes in TS 3/4.8.1 The NRC staff reviewed the proposed TS changes discussed in Section 1.3 of this SE. The proposed changes revise the allowable minimum steady-state EDG frequency and voltage values in various SRs to address non-conservatism and inconsistency in the SRs for TS 3/4.8.1. The NRC staff reviewed the potential impact of the EDG frequency and voltage changes on other safety-related equipment and discussed it in Sections 3.1 and 3.2 of this SE. The licensee also proposed editorial changes, and the NRC staff evaluation is discussed in Section 3.3 of this SE. The NRC staff finds the proposed TS changes are acceptable.
3.5 Technical Evaluation Conclusion
The NRC staff reviewed the proposed changes to Waterford 3 TS 3/4.8.1 to revise minimum voltage and frequency acceptance criteria for steady-state operation of the EDGs. The proposed changes increase the minimum allowable steady-state frequency and voltage parameters in TS 3/4.8.1 related SRs. Based on the regulatory and technical evaluations in Sections 2.0 and 3.0 of this SE, the NRC staff finds that the licensee has adequately justified the proposed TS changes in its application, as supplemented.
The NRC staff finds that the proposed TS changes will not adversely impact the capacity and capability of the safety-related electrical equipment required for accident mitigation and plant
shutdown. The NRC staff also concludes that the proposed editorial changes are acceptable.
The NRC staff concludes there is reasonable assurance the requirements of 10 CFR 50.36(c)(3) will continue to be met. The NRC staff finds that the proposed TS changes provides reasonable assurance that the licensee will continue to comply with the intent of 10 CFR Part 50, Appendix A, GDC 17, GDC 18, GDC 34 and 10 CFR 50.46. In conclusion, the NRC staff finds the proposed changes in the LAR, as supplemented, acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the NRC staff notified the State of Louisiana officials on September 25, 2020 of the proposed issuance of the amendment. The State officials had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration published in the Federal Register on December 17, 2019 (84 FR 68952), and there has been no public comment on such finding.
Accordingly, the amendment meets 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 amendment.
6.0 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: Jorge Cintron, NRR Robert Wolfgang, NRR Date: October 20, 2020
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