ML22068A182

NRR E-mail Capture - Beaver Valley Power Station, Units 1 & 2 - Request for Additional Information for License Amendment Request to Revise Technical Specification 3.3.5

ML22068A182
Person / Time
Site:	Beaver Valley
Issue date:	03/09/2022
From:	Ballard B Plant Licensing Branch 1
To:	Lashley P Energy Harbor Nuclear Corp
Ballard B
References
L-2021-LLA-0156
Download: ML22068A182 (6)

Text

From: Ballard, Brent Sent: Wednesday, March 9, 2022 1:42 PM To: 'Lashley, Phil H' Cc: 'McCreary, Dave M'; Danna, James

Subject:

Beaver Valley Power Station, Units 1&2 - Request for Additional Information for License Amendment Request to Revise Technical Specification 3.3.5 (EPID L-2021-LLA-0156)

Attachments: Final RAIs for TS 3.3.5 LAR_EPID L-2021-LLA-0156.docx Hi Phil, By letter L-21-068 dated August 29, 2021, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21242A125), Energy Harbor Nuclear Corp (the licensee) submitted a license amendment request (LAR) to Facility Operating License Nos. DPR-66 and NPF-73 for the Beaver Valley Power Station, Unit 1 and Unit 2. The proposed amendment would add notes to technical specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation, required actions C.1 and D.1, and revise Table 3.3.5-1, Loss of Power Diesel Generator Start and Bus Separation Instrumentation.

The NRC staff has reviewed the information provided by the licensee and has determined that additional information is required to be submitted to the NRC to complete the review of the LAR. The requests for additional information (RAIs) are attached to this email. Draft RAIs were provided to the licensee and a clarification call was held on March 9, 2022. Following the clarification call, no changes were made to the draft RAIs. This email and attachment will be made publicly available in ADAMS and a response is due in 30 days (by April 8, 2022) as per agreement at the clarification call.

If you have any questions regarding this matter, please contact me at 301-415-0680 or by email.

Thank you, Brent Brent Ballard Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-0680

Hearing Identifier: NRR_DRMA Email Number: 1550 Mail Envelope Properties (BY5PR09MB4627BB411C0400023760F047E00A9)

Subject:

Beaver Valley Power Station, Units 1&2 - Request for Additional Information for License Amendment Request to Revise Technical Specification 3.3.5 (EPID L-2021-LLA-0156)

Sent Date: 3/9/2022 1:41:59 PM Received Date: 3/9/2022 1:41:00 PM From: Ballard, Brent Created By: Brent.Ballard@nrc.gov Recipients:

"'McCreary, Dave M'" <dmccreary@energyharbor.com>

Tracking Status: None "Danna, James" <James.Danna@nrc.gov>

Tracking Status: None

"'Lashley, Phil H'" <phlashley@energyharbor.com>

Tracking Status: None Post Office: BY5PR09MB4627.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1553 3/9/2022 1:41:00 PM Final RAIs for TS 3.3.5 LAR_EPID L-2021-LLA-0156.docx 43381 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION BEAVER VALLEY POWER STATION- UNITS 1 & 2 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.5, LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START AND BUS SEPARATION DOCKET NUMBERS 50-334 AND 50-412 EPID No. L-2021-LLA-0156 By letter dated August 29, 2021, (Agency wide Document Access Management System (ADAMS) Accession No. ML21242A125), Energy Harbor Nuclear Corporation (the licensee),

requested an amendment to Facility Operating License Nos. DPR-66 and NPF-73 for the Beaver Valley Power Station (Beaver Valley), Unit Nos. 1 and 2. The proposed amendment would revise the Technical Specification (TS) 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation. In response to the audit plan issued by the Nuclear Regulatory Commission (NRC) on December 15, 2021 (ADAMS Accession No. ML21347A883), the licensee posted calculations relating to the license amendment request (LAR) on a secure web portal on January 4, 2022.

The NRC staff has reviewed the information provided by the licensee on the secure web portal and has determined that following additional information is required to be submitted to the NRC to complete the review of the LAR.

Regulatory Basis Title 10 of the Code of Federal Regulations (CFR) section 50.36, Technical Specifications, requires, in part, that the TS shall be included by applicants for a license authorizing operation of a production or utilization facility. 10 CFR 50.36(c) requires that TS include items in five specific categories related to station operation. These categories are (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation (LCOs)

(3) Surveillance requirements, (4) Design features, and (5) Administrative controls. 10 CFR 50.36(c)(2) requires that LCOs be established.

The licensing basis for LOP DG Start and Bus Separation Instrumentation is captured in the Beaver Valley Updated Final Safety Analysis for both Unit 1 and 2, and the corresponding Technical Specifications.

RAI EEB-1 The NRC staff reviewed the calculations provided by the licensee during the audit and has determined that the following information is needed to support the safety evaluation of the LAR:

a) Summary/Excerpts from Calculation No. 8700-E-345, Rev. 1 for BVPS-1, i.e.,

Background/Objective thru Recommendations [Pages 1 thru 15 of the calculation]

b) Summary/Excerpts from Calculation No. 10080-E-346, Rev. 1 for BVPS-2, i.e.,

Background/Objective thru Recommendations [Pages 1 thru 16 of the calculation]

c) Summary/Excerpts from Calculation No. 8700-E-271, Rev. 3, Addendum 4 for BVPS-1, i.e., Background/Objective thru Conclusions [Pages 6 thru 13 of the calculation]

d) Summary/Excerpts from Calculation No. 10080-E-271, Rev. 1, Addendum 6 for BVPS-2, i.e., Background/Objective thru Conclusions [Pages 5 thru 12 of the calculation]

e) Summary/Excerpts from Calculation No. 10080-E-271, Rev. 1, Addendum 7 for BVPS-2, i.e., Background/Objective thru Conclusions [Pages 4 and 5 of the calculation]

RAI EEB - 2 In the following calculations requested in RAI EEB-1 above, certain overcurrent relay replacements and settings changes have been proposed/recommended:

• Calculation No. 8700-E-345, Rev. 1 for BVPS-1

• Calculation No. 10080-E-346, Rev. 1 for BVPS-2 Please clarify whether the overcurrent relay replacements and settings changes, as proposed /

recommended in the above calculations, have already been implemented. If not, please provide status and timeline for implementation.

RAI EEB - 3 In Calculation No. 8700-E-271, Rev. 3, Addendum 4, for Unit 1 (requested in RAI EEB-1), the following Conclusions are made:

When the SSSTs are unloaded, the secondary-side voltages shall be regulated to within 128.5+/- 1.5 volts.

For accident conditions, the degraded voltage relay time delay shall be greater than 2.5 seconds. This provides adequate time for bus voltages to recover following fast bus transfers and is longer than the voltage transients associated with block starting safety-injection equipment. To minimize the potential for inadvertent relay actuation and to preserve operating margin, the time delay should be as long as permissible. (Refer to Calculation 8700-E-345.)

The dropout voltage of the loss of voltage relays for the safety-related 4160-volt buses shall be less than 80.1 percent of the nominal bus voltage. This ensures that the relays do not drop out when starting large motors, such as the reactor coolant pump motors.

To minimize the potential for inadvertent relay actuation and to preserve operating margin, the dropout setting should be as low as permissible. (Refer to calculation 8700-E-345.) To be within the bounds of the analysis, SSST taps should be raised such that secondary-side voltages are at least 127 volts before starting the A reactor coolant pump. Also, the reset voltages for the loss of voltage relays shall not exceed 90 percent of the nominal bus voltage.

Similarly, in the Calculation No. 10080-E-271, Rev. 1, Addendum 6, for Unit 2 (requested in RAI EEB-1), the following Acceptance Criteria is stated:

Voltage Regulation Band for the SSSTs The SSST voltage regulation scheme is being modified such that the transformer taps are maintained in elevated positions when the transformers are unloaded. This ensures the degraded voltage relays reset following fast bus transfers - without crediting the load tap changers. This addendum establishes an acceptable voltage regulation band for the SSSTs. The minimum voltage is selected such that the degraded voltage relays reset following fast bus transfers. For the degraded voltage relays to reset, voltages at the safety related 4160-volt and 480-volt buses shall recover above 94.14 percent of the Maximum Allowable Dropout Voltage for the Loss of Voltage Relays This addendum determines maximum allowable dropout voltage for the loss of voltage relays. The maximum dropout voltage shall be less than the minimum voltage observed at the safety-related 4160-volt buses during reactor coolant pump starts.

Based on Conclusions/Acceptance Criteria in the above Calculations, the staff has interpreted that by manipulating the SSST [station service transformer] (138 kV-4.36 kV-4.36 kV) taps, the minimum voltage at the safety-related 4160 V buses during the A reactor coolant pump start(s) can be maintained above the maximum allowable dropout voltage for Loss of Voltage Relays (during non-accident conditions).

According to LAR, as a precaution to avoid spurious operation of Loss of Voltage Relays, the licensee has proposed to add a TS Note to TS 3.3.5 Required Actions C.1 and D.1 to facilitate temporary bypassing of the loss of voltage functions 1 and 2 (up to one hour) while starting a reactor coolant pump. The staff interprets that although according to Calculations, adequate voltage at the safety-related buses can be provided by manipulating the SSST [station service transformer] taps, the TS Note would provide additional measure/option to the licensee in case it is not able to provide adequate voltage at the safety-related buses by manipulating the SSST taps during A reactor coolant pump start(s). Please explain the reasons for the Note proposed to be inserted in TS 3.3.5 Required Actions C.1 and D.1 for allowing Functions 1 and 2 to be bypassed up to one hour.

RAI EICB - 4 In the LAR, the licensee requested to revise the loss of voltage (LOV) nominal trip setpoints (NTSs) and allowable values (AVs) of FUNCTION 1, 4160 V Emergency Bus DG start and FUNCTION 2, 4160 V Emergency Bus, Bus Separation. In Section 3.1 of the LAR, Loss of Voltage Relay Settings, the licensee provided the proposed changes of channel statistical allowance (CSA), NTS, and AV values.

Provide the following information regarding the proposed LOV setpoint and allowable values for Function 1 and 2.

a) Summary/excerpts from Calculation No. 8700-DEC-0212 Rev. 2 for Unit 1, 4.1 kV Emergency Bus Undervoltage functions (Trip Feed, Emergency Diesel Generator Start) [Pages 1 - 8 of the calculation].

b) Summary/excerpts from Calculation No.10080-DEC-0215 Rev. 2 for Unit 2, 4.1 kV Emergency Bus Undervoltage functions (Trip Feed, Emergency Diesel Generator Start) [Pages 1 - 8 of the calculation].

NRC staff will review the calculations that determined the proposed LOV, NTSs, AVs, and the uncertainties associated with these settings for Functions 1 and 2, that are shown in the Calculations 10080-DEC-0215 Rev. 2 and 8700-DEC-0212 Rev. 2.

RAI EICB-5 In the LAR, the licensee proposes to add Function 5, 4160 V Emergency Bus, Bus Separation, and Function 6, 480 V Emergency Bus, Bus Separation. The AV voltages remain the same as Functions 3 and 4, only the time delay differs. In Section 3.2, Degraded Voltage Time Delay with Safety Injection Signal,, the licensee provided the proposed values of the CSA, NTS, and AV values of the Degraded Voltage Relay (DVR) time delays for Functions 5 and 6.

Please provide the following information:

1. Summary/Excerpts of the Calculation E-529 Rev. 1, for BVPS-1 and BVPS-2, LOV Degraded Voltage (with safety injection signal) [Pages 1 - 7 of the calculation].

2. The relevant calculation information that determined the new DVR time delay setpoints, and the uncertainties associated with these settings for Functions 5 and 6 that are as shown in the Calculations E-529 Rev. 1.