Text

Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request
	ML15324A297
Person / Time
Site:	Farley
Issue date:	11/20/2015
From:	Pierce C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-0722
	Download: ML15324A297 (36)
	v • d • e

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

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40 Inverness Center Parkway Post Office Box 1295 Birmingham , AL 35242 Tel 205.992.7872 SOUTHE RN Fax 205.992.7601 NUCLEA R A SOUTHERN COMPANY NOV 2 0 2015 Docket Nos.: 50-348 NL-15-0722 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specifications (TS). This amendment request proposes to revise TS 3.3.5, "Loss of Power Diesel Generator Start Instrumentation," as described in the Enclosures to this letter.

Revision of the TS 3.3.5 degraded grid voltage relay actuation requirements is needed to enable compliance with the license condition stated in Appendix C of FNP Unit 1 Renewed Operating License NPF-2, and in Appendix C of FNP Unit 2 Renewed Operating License NPF-8. This license condition requires SNC to implement modifications that will eliminate use of manual actions as part of the FNP degraded voltage protection scheme, and is to be complete before restart from the Fall 2017 refueling outage for Unit 2 (2R25) and before restart from the Spring 2018 refueling outage for Unit 1 (1 R28). provides the basis for the proposed changes, Enclosure 2 provides the marked-up TS 3.3.5 pages (along with unaffected pages included for context) and provides the clean-typed TS 3.3.5 pages. Also provided for information in are marked-up pages (along with unaffected pages included for context) showing associated changes planned for the TS 3.3.5 Bases.

SNC requests approval of the proposed license amendment by November 30, 2016, with implementation within 90 days.

In accordance with the requirements of § 50.91, a copy of this request is provided to the designated Alabama official.

U. S. Nuclear Regulatory Commission NL-15-0722 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, c.flP~

C. R. Pierce Regulatory Affairs Director Sworn to and subscribed before me this~ day of n~ , 2015.

~~or:~

~otary Public My commission expires: /o- $ *.) ~ t7 CRP/DWDI<>

Enclosures:

1. Basis for Proposed Changes

2. FNP Units 1 and 2 Technical Specification 3.3.5 Marked-Up Pages

3. FNP Units 1 and 2 Technical Specification 3.3.5 Clean Typed Pages

4. FNP Units 1 and 2 Technical Specification 3.3.5 Bases Marked-Up Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RType: Farley=CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Enclosure 1 Basis for Proposed Changes

Enclosure 1 Basis for Proposed Changes Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Precedent 4.4 Conclusion 5.0 Environmental Consideration 6.0 References E1-1

Enclosure 1 Basis for Proposed Changes 1.0 Summary Description This proposed license amendment request (LAR) by Southern Nuclear Operating Company (SNC) is made, pursuant to the requirements of 10 CFR 50.90, for a change to the Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, Technical Specifications (TS). This amendment request proposes to revise the setpoint requirements in TS 3.3.5, "Loss of Power Diesel Generator Start Instrumentation,"

for the 4.16 kV Emergency Bus Degraded Grid Voltage Actuation and Alarm functions as follows (and as shown in the marked-up and clean typed pages of Enclosures 2 & 3):

A) In the LCO 3.3.5 and APPLICABILITY sections of TS 3.3.5, add "and Table 3.3.5-2" after each reference to Table 3.3.5-1.

B) Under APPLICABILITY, add the following NOTES:

1. "For Unit 1, use Table 3.3.5-1 until Mode 4 entry following the spring 2018 outage (1 R28); thereafter use Table 3.3.5-2."

2. "For Unit 2, use Table 3.3.5-1 until Mode 4 entry following the fall 2017 outage (2R25); thereafter use Table 3.3.5-2."

C) Following Table 3.3.5-1, "Loss of Power Diesel Generator Start Instrumentation," add a new page with Table 3.3.5-2. Table 3.3.5-2 differs from Table 3.3.5-1 as follows:

1. Function 1, "4.16 kV Emergency Bus Loss of Voltage DG Start and Function 2, "4.16 kV Emergency Bus Degraded Grid Voltage Actuation," has the Trip Setpoint column replaced by a new Delay Time column,

2. Function 2 has the singular Allowable Value (AV) voltage range specified for all buses replaced with new AV lower limits specified for each 4.16 kV bus (1 F, 1G, 2F & 2G), and

3. Function 3, "4.16 kV Emergency Bus Degraded Grid Voltage Alarm," is deleted.

2.0 Detailed Description Revision of the TS Table 3.3.5-1 setpoint requirements is needed to fulfill a license condition contained in FNP Unit 1 Renewed Operating License NPF-2 and in FNP Unit 2 Renewed Operating License NPF-8, which was added to Appendix C of each license by Amendments No. 194 and No. 190, respectively.

These amendments were requested by SNC by letter dated December 21, 2012 (Ref. 5), as supplemented by letter dated May 21, 2013 (Ref. 6).

The pertinent license condition states that "SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events." Completion of this license condition is required before restart from the spring 2018 outage for Unit 1 (U1 R28) and before restart from the fall2017 outage for Unit 2 (U2R25). The changes proposed by this LAR are to enable compliance with these License Conditions.

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Enclosure 1 Basis for Proposed Changes It is proposed that a new Table 3.3.5-2 be added to TS which will contain the revised loss of power diesel generator start instrumentation specifications which are entailed in eliminating manual actions from the FNP degraded voltage protection scheme. Reference to Table 3.3.5-2 will be added to LCO 3.3.5 and the APPLICABILITY statement, followed by NOTES to accommodate the differing implementation dates for Unit 1 and Unit 2, as follows:

1. For Unit 1, use Table 3.3.5-1 until Mode 4 entry following the spring 2018 outage (1 R28); thereafter use Table 3.3.5-2.

2. For Unit 2, use Table 3.3.5-1 until Mode 4 entry following the fall2017 outage (2R25); thereafter use Table 3.3.5-2.

The proposed Table 3.3.5-2 differs from Table 3.3.5-1 as follows:

a) Function 1, "4.16 kV Emergency Bus Loss of Voltage DG Starf' and Function 2, "4.16 kV Emergency Bus Degraded Grid Voltage Actuation,"

has the Trip Setpoint column replaced by a new Delay Time column, b) Function 2 has the singular Allowable Value (AV) voltage range specified for all buses replaced with new AV lower limits specified for each 4.16 kV bus (1 F, 1G, 2F & 2G), and c) Function 3, "4.16 kV Emergency Bus Degraded Grid Voltage Alarm," is deleted.

These changes are shown in the marked-up and clean typed TS 3.3.5 pages provided in Enclosures 2 & 3. In addition, Enclosure 4 provides, for information only, mark-ups of anticipated corresponding changes to the TS 3.3.5 Bases to accommodate the overlapping period of applicability of Tables 3.3.5-1 and 3.3.5-2, and of the overlapping period of service of the existing type of DVRs and of the new type DVRs which will replace them on a bus-by-bus basis.

The new degraded voltage relay (DVR) actuation voltage AV limits listed individually in Table 3.3.5-2 Function 2 for the four 4.16 kV emergency buses (Buses 1F, 1G, 2F & 2G) are increased from the existing AV range specified in Table 3.3.5-1 so as to provide for fully automatic degraded voltage protection on each bus, eliminating the need for administrative controls (i.e. manual actions), as are used in the existing FNP degraded voltage protection scheme.

To enable implementation of the higher AV limits in Table 3.3.5-2, the induction disc type relays currently used for the DVR function will be replaced with new solid-state relays. Replacement of the induction disc relays with solid-state relays was evaluated and determined not to constitute a digital upgrade per procedurally established criteria. Because the new solid-state relays provide for discrete setting of actuation delay time rather than actuating according to an inverse-time characteristic curve like the existing induction disc relays, a Delay Time column is added to Table 3.3.5-2.

Installation of the new DVRs is planned to be performed one bus at a time over two successive refueling outages for each unit, beginning with Bus 2G in spring 2016 (2R24) and Bus 1G in fall 2016 (1 R27). The new DVRs will initially be set to actuate per the existing TS Table 3.3.5-1 Function 2 requirements. Approval of E1-3

Enclosure 1 Basis for Proposed Changes this LAR adding Table 3.3.5-2 is expected to occur prior to the second round of OVA replacement, which is to be performed on Bus 2F in fall 2017 (2A25) and on Bus 1F in spring 2018 (1 A28). During the outages when the new DVRs are installed on each "P' bus, the "G" bus DVRs will be re-set per Table 3.3.5-2.

Thus, for the operating cycles beginning with 2R24 and 1R27, each unit will operate with both induction disc and solid-state type relays in service, with both relay types set to actuate per the existing TS Table 3.3.5-1 requirements. For the period between 2A25 and 1 A28, the new Table 3.3.5-2 requirements will be in effect for Unit 2 while Table 3.3.5-1 will still apply for Unit 1. From spring 2018 (1 A28) onward, Table 3.3.5-1 will no longer have any applicability. At a convenient subsequent opportunity an administrative LAR will be made to delete Table 3.3.5-1, at which time Table 3.3.5-2 will be re-numbered as a new Table 3.3.5-1 and the references to Table 3.3.5-2 in TS 3.3.5 will be deleted, along with the NOTES under the APPLICABILITY statement. Appropriate changes to amend discussion of Table 3.3.5-1 and delete discussion of Table 3.3.5-2 will then be made to the TS 3.3.5 Bases as well.

Background:

The existing FNP degraded voltage protection scheme, which relies on administrative controls (i.e. manual actions) to assure adequate voltage to safety-related equipment during design basis events by avoiding or minimizing the occurrence of degraded voltage conditions, was accepted by the Nuclear Regulatory Commission (NRC) in a November 21, 1995 Safety Evaluation Report (SEA) (Ref. 1). This SEA relied in part on a commitment by SNC to include limiting conditions for operations and surveillance requirements for the degraded grid voltage alarm relays in the planned conversion to Improved Technical Specifications (ITS). In fulfillment of this commitment, Function 3, "4.16 kV Emergency Bus Degraded Grid Voltage Alarm" was added to Table 3.3.5-1 when the ITS was issued on November 30, 1999 (Ref. 2).

During the Component Design Basis Inspection (CDBI) performed at FNP in 2011, the NRC inspection team identified an Unresolved Item (URI) regarding the use of administrative controls at FNP in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events. The December 19, 2011 CDBI report (Ref. 3) designated this issue as URI 050000348, 364/2011010-10, "Administrative Controls in lieu of Automatic Actions for Degraded Voltage Protection," and noted the similarity of this issue to the degraded voltage protection issue then under appeal for Hatch Nuclear Plant (HNP). In addition, on December 29, 2011, the NRC distributed Regulatory Issue Summary (RIS) 2011-12 (Ref. 4) to clarify the staff's technical position on existing regulatory requirements and the voltage studies necessary to properly determine OVA settings.

Consistent with the position expressed by the NRC staff in the COB I report and in RIS 2011-12, the appeal process in the HNP degraded voltage case was resolved with a definitive determination that reliance on manual actions as part of E1-4

Enclosure 1 Basis for Proposed Changes the degraded voltage protection scheme did not meet regulatory requirements, and that previous acceptance of this protection scheme by the NRC staff did not constitute an exemption from the regulations. In consequence, SNC elected to resolve the 2011 CDBI degraded voltage URI at FNP by submitting a LAR on December 21, 2012 (Ref. 5) which provided a schedule for implementing plant modifications to eliminate manual actions for degraded voltage protection at FNP; this LAR, supplemented by additional information in a letter dated May 21, 2013 (Ref. 6), resulted in the License Amendments cited above, which were issued May 13, 2014 (Ref. 7).

3.0 Technical Evaluation Successful operation of the required functions of the Engineered Safety Features (ESF) systems is dependent upon the availability of adequate power sources for energizing the various components such as pump motors, motor operated valves, and associated control components. Offsite power is the preferred source of power for the 4160V emergency buses which power the required components.

The Loss of Power (LOP) protection instrumentation monitors voltage on the F and G 4160V buses of each FNP unit. Each electrical train has independent LOP instrumentation and relay actuation logic for detecting degraded grid or loss of voltage conditions, and initiating an LOP emergency diesel generator (EDG) start signal.

There are currently three LOP protection instrumentation actuation levels. An alarm sounds at a set point of not less than 3850V on detection of degraded grid voltage. At not less than 3675V a LOP signal is generated for sustained degraded grid voltage. At not less than 3255V a LOP signal is generated for near instantaneous loss of voltage conditions. Actuation of the degraded grid or loss of voltage relays will automatically disconnect the 4160V emergency buses from the offsite power source.

An administrative limit is established at a voltage level between the degraded grid voltage alarm allowable value and the automatic degraded grid voltage actuation upper allowable value. In the voltage range between the administrative limit and the degraded grid voltage actuation trip setpoint, a few ESF components may not have automatic protection from inadequate voltage. The manual actions provide the primary means of protecting these few ESF components from a sustained, slightly low voltage condition and all components from unnecessary automatic disconnection from the preferred offsite power source.

FNP's current degraded voltage protection scheme requires upgrades because it currently relies upon administrative controls to assure adequate voltage is supplied to safety-related equipment during design basis events. The automatic portion of the degraded voltage protection scheme employs setpoints which are too low to assure operability of all safety-related electrical equipment in case of a sustained degraded grid voltage condition, instead relying on administrative controls (i.e. manual actions) to assure adequate voltage is supplied to safety-related equipment during accident conditions.

While the FNP electrical distribution system is capable of providing sufficient E1-5

Enclosure 1 Basis for Proposed Changes margin between the minimum expected bus voltage and the voltage level required by the safety-related equipment, achieving fully automatic degraded voltage protection will require installation of new type DVRs as well as higher actuation setpoints. The design of the existing DVRs does not allow resolution of this issue through set point adjustment alone.

The DVRs are intended to protect plant equipment from an undervoltage condition when the 4.16 kV emergency buses are powered from the off-site grid.

The DVRs monitor voltage on Buses 1F, 1G, 2F & 2G (three relays per bus) and actuate when the voltage falls below a pre-determined value and remains below this value for a specified amount of time. Actuation of any two out of three relays on the same bus results in an automatic trip of the applicable 4.16 kV preferred power supply breakers, disconnecting the undervoltage (degraded) bus from its offsite preferred power source; that bus is then transferred to receive power from its alternate power supply, an EDG.

The DVR actuation voltage and delay time settings should minimize nuisance tripping during normal operating conditions but still ensure that the voltage requirements of the safety-related loads are met without exceeding the maximum time delay assumed in the safety analyses. As the 1995 SER acknowledged, however, the existing actuation voltage range AV and setpoint specified for the FNP DVRs (Function 2 in TS Table 3.3.5-1) is such that a sustained degraded voltage condition could occur in which grid voltage is too low to assure proper operation of safety-related equipment, yet not low enough to cause the DVRs to automatically separate the emergency buses from grid power and transfer to the EDGs.

This gap is addressed in the existing protection scheme by means of the Degraded Grid Voltage Alarm (Table 3.3.5-1, Function 3), which is intended to alert plant operators to degraded grid voltage conditions and prompt their coordination with the offsite power system operators on actions to restore grid voltage. At present, these manual actions are the means relied on to protect safety-related equipment from inadequate voltages in the range where automatic protection is not provided by the DVRs. With implementation of plant modifications (including installation of the new type 27N DVRs) which enable use of higher DVR actuation voltage setpoints in accordance with the newTS Table 3.3.5-2 Function 2 AVs, reliance on manual actions for degraded voltage protection will be eliminated. The Degraded Grid Voltage Alarm function, though it will remain in service, will in consequence be returned to its previous role as a non-TS alarm, with Function 3 deleted from TS 3.3.5, restoring consistency with the standard TS.

Calculations were performed to determine the acceptable voltage operating range at the 4.16 kV emergency buses. Offsite power system voltage at FNP is not intentionally lowered below 101.6% of 230 kV, and system voltages for worst-case single contingencies are expected to remain at or above 101.0%.

Therefore, the minimum expected voltage (MEV) was calculated as the 4.16 kV bus voltage which would occur during a loss of coolant accident (LOCA) steady-state loading condition concurrent with a 230kV switchyard voltage of 101.0%.

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Enclosure 1 Basis for Proposed Changes Based on this MEV, the minimum required voltage (MRV) was determined as the greater of: a) the minimum acceptable steady-state voltage for normal operation of Class 1E loads, using maximum expected non-accident bus loading, b) the minimum pre-start voltage providing acceptable Class 1E motor starting (e.g.

during LOCA group motor starting, using maximum expected accident loading, or c) the minimum steady-state voltage providing acceptable Class 1E motor starting and operation for individual motors, using maximum expected accident loading.

The MRV value for each emergency bus was used in calculating the DVR actuation voltage AVs specified in TS Table 3.3.5-2. Since the safety-related function of the DVRs is to actuate when the voltage falls below a pre-determined value and remains below this value for a specified amount of time, the voltage AVs are given in Table 3.3.5-2 as one-sided limits in "'2!:." (greater-than-or-equal-to) form while the Delay Times are given as one-sided limits in "~" (less-than-or-equal-to) form.

4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration The proposed Amendment would revise the relay setpoint requirements for the 4.16 kV Emergency Bus Degraded Grid Voltage Actuation function in the Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specifications (TS). TS 3.3.5, "Loss of Power Diesel Generator Start Instrumentation" would be revised so as to fulfill a License Condition requirement to eliminate use of manual actions from the degraded voltage protection scheme. Also, with the 4.16 kV Emergency Bus Degraded Grid Voltage Alarm function thereby being made unnecessary as part of the protection scheme, the Alarm function would be deleted from TS 3.3.5 by the proposed Amendment *as well.

Southern Nuclear Operating Company (SNC) has evaluated the proposed changes to TS 3.3.5 using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

As required by 10 CFR 50.91 (a), the SNC analysis supporting a determination of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed license amendment request changes the TS 3.3.5 requirements for loss of power diesel generator start instrumentation to enable elimination of manual actions for protection of safety-related equipment from degraded voltage conditions during design basis events.

Elimination of these manual actions is required to fulfill an existing License Condition on each unit.

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Enclosure 1 Basis for Proposed Changes The proposed change increases the Allowable Value (AV) for the 4.16 kV Emergency Bus Degraded Grid Voltage Actuation function. Installation of new, higher precision Degraded Voltage Relays (DVRs) makes possible an increase in the DVR actuation setpoint (encompassed by the AV) to a level which provides fully automatic protection of s~fety-related equipment while minimizing the chance of unwanted disconnection from the preferred offsite power source, which is itself an analyzed condition.

Based on the above, the proposed change does not involve a significant

increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed license amendment request changes the TS 3.3.5 requirements for loss of power diesel generator start instrumentation to enable elimination of manual actions for protection of safety-related equipment from degraded voltage conditions during design basis events.

Elimination of these manual actions is required to fulfill an existing License Condition on each unit.

The proposed changes to TS 3.3.5 do not change the methods of normal plant operation nor the methods of response to transient conditions, save that the range of automatic action provided by the DVRs is expanded.

This change will eliminate the need for manual action from the degraded voltage protection scheme, as required by a License Condition for each unit, to achieve compliance with 10 CFR 50.55a(h)(2) and 10 CFR Part 50, Appendix A, General Design Criterion 17 - Electric Power Systems.

Accordingly, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No Margin of safety is provided by the performance capability of plant equipment in preventing or mitigating challenges to fission product barriers under postulated operational transient and accident conditions.

Since the proposed license amendment request changes the TS 3.3.5 requirements for loss of power diesel generator start instrumentation to enable elimination* of manual actions for protection of safety-related equipment from degraded voltage conditions during design basis events, it will tend to increase the margin of safety by better protecting the safety-E1-8

Enclosure 1 Basis for Proposed Changes related plant equipment.

Based on the above, the proposed change does not involve a significant reduction in a margin of safety.

SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.2 Applicable Regulatory Requirements/Criteria This license amendment request is submitted to ensure compliance with applicable provisions of 10 CFR 50.55a(h)(2) and 10 CFR Part 50, Appendix A, General Design Criterion 17 - Electric Power Systems.

The existing degraded voltage protection scheme for FNP, which relied partially on manual action, was established in accordance with the NRC Safety Evaluation Report (SER) issued November 21, 1995 (Ref. 1). This SER allowed for a voltage "deadband" between the minimum required voltage at the 4160V buses (the calculated voltage value at which the required safety related loads have been evaluated to start and run in response to an automatic safety injection actuation) and the DVR setpoint.

In connection with the 1995 SER, limiting conditions for operation and surveillance requirements for the degraded grid voltage alarm relays were made part of the Technical Specifications (Function 3 in Table 3.3.5-1), along with the loss of voltage and degraded grid voltage relays (Functions 1 and 2, respectively, in Table 3.3.5-1). NRC subsequently concluded that reliance on manual actions as part of the degraded voltage protection scheme did not meet regulatory requirements, and that previous acceptance of this protection scheme by the NRC staff did not constitute exemption from the regulations.

By letter dated December 21, 2012, (Ref. 5) SNC proposed a schedule to implement degraded voltage modifications to address this issue, and by letter dated May 13, 2014 (Ref. 7), NRC accepted the proposed schedule. License Conditions were added to the FNP Unit 1 and Unit 2 Facility Operating Licenses requiring that "SNC shall implement the Degraded Voltage modifications to eliminate the manual actions in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events."

Completion of the License Conditions is required by the Unit 1 2018 Spring Outage (1 R28) and the Unit 2 2017 Fall Outage (2R25).

4.3 Precedent This license amendment request is made pursuant to existing License Conditions applicable to FNP Units 1 and 2, which were issued May 13, 2014 (Ref. 7).

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Enclosure 1 Basis for Proposed Changes Similar License Conditions, which will likewise require similar TS changes to expand the DVR action range, are in place for Edwin I. Hatch Nuclear Plant, Units 1 and 2 (the Hatch license amendment request has not yet been submitted).

4.4 Conclusion In conclusion, based on the considerations discussed above: (1} there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manl"!er; (2) such activities will be conducted in compliance with the Commission's 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.

5.0 Environmental Consideration Southern Nuclear has evaluated the proposed amendment to change the FNP Technical Specifications and determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b}, an environmental assessment of the proposed amendment is not required.

6.0 References

1. November 21, 1995 -letter from Pierce H. Skinner, USNRC, to D.N. Morey, SNC, "NRC Inspection Report Nos. 50-348/95-18 and 50-364/95-18, Notice of Violation, and Safety Evaluation Report

2. November 30, 1999 -letter from L. Mark Padovan, USNRC, to D.N. Morey, SNC, "Joseph M. Farley Nuclear Plant, Units 1 and 2 - Issuance of Amendments Re: Conversion to Improved Standard Technical Specifications (TAC Nos.

MA 1364 and MA 1365)"

3. December 19, 2011 -letter from Rebecca Nease, USNRC, to T.A. Lynch, SNC, "Joseph M. Farley Nuclear Plant- NRC Component Design Bases Inspection - Inspection Report 05000348/2011010 and 050003564/201101 0"

4. December 29, 2011 -NRC Regulatory Issue Summary (RIS) 2011-12, Rev. 1, "Adequacy of Station Electric Distribution System Voltages"

5. December 21,2012 -letter NL-12-2142, from M.J. Ajluni, SNC, to USNRC, "Joseph M. Farley Nuclear Plant - Units 1 and 2, Facility Operating License Amendment Request for Degraded Voltage Protection Modification Schedule" E1-10

Enclosure 1 Basis for Proposed Changes

6. May 21, 2013 -letter NL-13-0933, from C.R. Pierce, SNC, to USNRC, "Joseph M. Farley Nuclear Plant Response to Request for Additional Information Concerning Degraded Voltage Compensatory Measures"

7. May 13, 2014 -letter from Shawn A. Williams, USNRC, to C.R. Pierce, SNC, "Joseph M. Farley Nuclear Plant, Units 1 and 2, Issuance of Amendments to Incorporate the Schedule for Degraded Grid Voltage Modification (TAG Nos.

MF0468 and MF0469)"

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Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Enclosure 2 FNP Units 1 and 2 Technical Specification 3.3.5 Marked-Up Pages (unaffected pages are also provided for context)

LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 The LOP instrumentation for each Function in Table 3.3.5- shaDbe OPERABLE.

APPLICABILITY: According to Table 3.3.5-1.

- - - - - - - Insert A ACTIONS

~ OTE----------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION nME A. NOTE A. 1 NOTE Only applicable to The inoperable channel Functions 1 and 2. may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveiUance One or more functions testing of other channels.

with one channel per train inoperable.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. NOTE B.1 Restore aUbut one 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to channel per train to Functions 1 and 2. OPERABLE s1atus.

One or more Functions with two or more channels per train inoperable.

C. Required Action and C.1 Enter applicable Immediately associated Completion Condition(s) and Required Time of Condition A or Action(s) for the B not mel associated DG made inoperable by LOP DG start instrumentation.

Farley Units 1 and 2 3.3.5-1 Amendment No. 146-(Unit 1)

Amendment No. '8T- (Unit 2)

='io change on rbis page; proYided for re-ference only. LOP DG Start Instrumentation 3.3.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION T IME D. NOTE D.1 Verify voHage on Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to associated bus is~ 3850 Function 3. volts.

One Alarm Function channel inoperable on one or more trains.

E.. Required Action and E..1 Restore bus voltage to ~ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated Completion 3850 volts.

Time of Condition 0 not mel F. Required Action and F. 1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition E AND not mel F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEJLLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 ------------INOTE.~-------------

1. T ADOT shall exclude actuation of the final trip actuation relay for LOP Functions 1 and 2.

2. Setpoint verification not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program Fartey Units 1 and 2 3.3.5-2 Amendment No. 185 (Unit 1)

Amendment No. 180 (Unit 2}

~o change on this page; proYided for reference only. LOP DG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEIUANCE FREQUENCY SR 3.3.5.2 --------------NOTE-------------

CHANNEL CALIBRATION shall exclude actuation of the final trip actuation relay for Functions 1 and 2 Perfonn CHANNEL CAUBRATION . In accordance with the Surveillance Frequency Control Program SR 3.3.5.3 ---------------No~--------------

Response -time testing shall include actuation of the final trip actuation relay.

Verify ESF RESPONSE TIME within limit In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.3.5-3 Amendment No. 185 (Unit 1)

Amendment No. 180 (Unit 2)

r\o change ou this page; prolided fo r reference only. LOP DG Start Instrumentation 3.3.5 Tabte 3.3.5-1 (page 1 of 1)

Loss of Power Diesel Generator Start Instrumentation FUNCTION APPLICABLE REQUIRED SURVEILLANCE ALLOWABLE TRIP MODES OR CHANNELS REQULREMENTS VALUE SETPOIMT OTHER PER TRAIN SPECIFIED CONDITIONS

1. 4.16 kV Emergency Bus 1.2,3,4, (a) 3 SR3.3.5.1 ~ 3222 V ~ 3255 V Loss of Voltage DG Start SR3,3.5.2 and SR3.3.5.3 $ 3418 v

2. 4.16 kV Emergency Bus 1,2,3,4, (a} 3 SR3.3.5.1 ~ 3638 V ~ 3675 V Degraded Grid Voltage SR3.3.5.2 and Attualion SR3.3.5.3 S 3749 V

3. 4.16 kV Emergency Bus 1,2,3,4 1 SR3.3.5.1 DegrBQed Grid Voltage SR3.3.5.2 ~ 3835 V ~ 38SO V Alarm (a} When associated DG Is required to be OPERABLE by LCO 3.8.2, nAC Sourtes- Shutdown."

Farley Units 1 and 2 3.3.5-4 Amendment No. 146 {Unit 1)

Amendment No. 137 (Unit 2)

Insert A - add to page 3.3.5-1

NOTES

1. For Unit 1, use Table 3.3.5-*t until Mode 4 entry following the spring 2018 outage (1R28);

thereafter use Table 3.3.5-2.

2. For Unit 2, use Table 3.3.5-1 until Mode 4 entry following the fall 2017 outage (2R25);

thereafter use Table 3.3.5-2.

Insert 8 - add on new page 3.3.5-5 Table 3.3.5-2 (page 1 of 1)

Loss of Power Diesel Generator Start Instrumentation FUNCTION APPLICABLE REQUIRED SURVEILLANCE AllOWABLE DELAY MODES OR CHANNELS REQUIREMENTS VALUE TIME OTHER. PER TRAIN SPECIFIED CONDITIONS

1. 4.16 kV Emergency Bus 1,2.3.4, (a) 3 SR3.3.5.1 _3222V NA Loss of Voltage DG Start SR3.3.5.2 and SR3.3.5.3 s 3418 v

2. 4.16 kV Emergency Bus 1,2,3,4, {a) 3 SR3.3.5.1 Bus 1F: .:: 3761 V .::, 11.4 sec Degraded Grid Voltage SR3.3.52 Bus 1G* :::. 3752 V :S 11.4 sec Actuation SR3.3.5.3 Bus 2F: ;:: 3757 V !: 9.9 sec Bus 2G: :: 3778 V ~ 9.9 sec (a) When associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources- Shutdown."

Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Enclosure 3 FNP Units 1 and 2 Technical Specification 3.3.5 Clean Typed Pages J

LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (OG) Start lnstrumentation LCO 3.3.5 The LOP instrumentation for each Function in Table 3.3.5-1 and Tabfe 3.3.5-2 shall be OPERABLE.

APPUCABIUTY: Accor<fing to Table 3.3.5-1 and Table 3.3.5-2.

NOTE~------------------------

1. For Unit 1, use Table 3.3.5-1 until Mode 4 entry following the spring 2018 outage (1R28);

thereafter use Table 3.3.5-2.

2. For Unit 2, use Table 3.3.5-1 until Mode 4 entry folrowing the fall 2017 outage {2R25);

thereafter use Table 3.3.5-2 ACTIONS

NOTE-- -------------------------------------

Separate Condition entry is aUowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. NOTE A. 1 NOTE Only applicable to The inoperable channel Functions 1 and 2 may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance One or more functions testing of other channels.

with one channel per train inoperable.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. NOTE 6.1 Restore all but one 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to channelper~nto Functions 1 and 2 OPERABLE status.

One or more Functions with two or more channels per tra[n inoperable.

Farley Units 1 and 2 3.3.5-1 Amendment No. {Unit 1)

Amendment No. {Unit 2)

LOP DG Start Instrumentation

. 3.3.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Reqlrired Action and C.1 Enter appficable Immediately associated Completion Con<fition(s} and Required Time of Comfrtion A or Action(s) for the B not mel associated DG made inoperable by LOP DG start instrumentation.

D. NOTE D.1 Verify voltage on Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to associated bus is ~ 3850 Function 3. volts.

One Alarm Function channel inoperable on one or more trains.

E. Required Action and E.1 Restore bus voltage to~ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated Completion 3850 volts.

Time of ComfJtion D not met.

F. Required Action and F.1 Be in MODE3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associa~ Completion Time of Comfltion E AND not mel F2 Be in MODE5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Farley Uni1s 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2}

LOP DG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 ------------INOTES--------------

1. TADOT shall exdude actuation of the fmal trip actuation relay for L9 P Functions 1 and 2

2. Setpoint verification not required.

Perform TADOT. In accordance wi1h the Surveillance Frequency Control Program SR 3.3.5.2 -------------NOTE-------------

CHANNEL CAUBRATJON shall exdilde actuation of the final tip actuation relay for Functions 1 and 2 Perform CHANNEL CALIBRATION. In accordance wi1h the Surveillance Frequency Control Program SR 3.3.5.3 --------------Notc~------------

Response time testing shall indude actuation of the final trip actuation relay.

Verify ESF RESPONSE TIME within limit In accordance wi1h the SurveiJiance Frequency Control Program Farley Uni1s 1 and 2 3.3.5-3 Amendment No. (Unit 1}

Amendment No. (Unit 2}

!\o change on this page; prolided for reference only. LOP DG Start Instrumentation 3.3.5 Table 3.3.5-1 (page 1 of 1)

Loss of Power Diesel Generator Start Instrumentation FUNCTION APPLICABLE REQUIRED SURVEILLANCE ALLOWABL E TRIP MODES OR CHANNELS REQUIREMENTS VALUE SETPOINT OTHER PER TRAIN SPECIFIED CONDffiONS

1. 4.16kV EmergencyBus 1,2,3,4, (a ) 3 SR3.3.5.1 2: 3222 v 2: 3255 \1 Loss of Voltage DG Start SR3.3.52 and SR3.3.5.3 s; 3418 v 2.. 4.16 kV Emergency Bus 1,2,3,4, (8) 3 SR3.3.5.1 2: 3638 v 2: 3675 v Dew'aded Grid Voftage SR3.3.52 and Actuation SR3.3.5.3 s; 3749 v

3. 4.16 kV Emergency Bus 1,2,3,4 1 SR3.3.5.1 Degraged Grid Voltage SR3.3.52 ;:: 3835 \1 2: 3850 V Alann (a) When associated DG is required to be OPERABLE by LCO 3.82, "AC Sources - Shutdown. w Fartey Units 1 and 2 3.3.5-4 Amendment No. 146 (Unit 1)

Amendment No. 137 (Unit 2)

LOP DG Start Instrumentation 3.3.5 Table 33 .~2 (page 1 of 1}

Loss of Power Diesel Generator Start Instrumentation FUNC ION APPLICABLE REQUIRED SURVEILLANCE ALLOWABLE DELAY MODES OR CHANNELS REQUIREMENTS VALUE T IME OTHER PER TRAIN SPECIFIED CONDITIONS

1. 4. 16 kV Emergency Bus 1.2,3,4, (a ) 3 SR3"3.5. t <!: 3222 V NA Loss of Voetage DG Start SR3.3 .5.2 and SR3.3.5.3 ~ 34 1 8V 2.. 4. 16 kV Emergency Bus 1,2,3 .4, (a ) 3 SR3.3.5. BUS 1F: ~ 3761 V :S 11.4 see Oeilraded Grid Volt:a.~e SR3.3..5.2 BUs 1G: :!! 3752 V :S 11.4 see Ac1uation SR3.3..5.3 Bus 2F: ~ 3757 V ~9.9sec eus 2G: :!! 3778 v S9.9sec (a) When associated DG is required to be OPERABLE by LCO 3.8.2 , *Ac Sources - Shutdown.*

Farley Uni1s 1 and 2 3.3.5-5 Amendment No. (Unit 1)

Amendment No. (Unit2)

Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Enclosure 4 FNP Units 1 and 2 Technical Specification 3.3.5 Bases Marked-Up Pages (unaffected pages are also provided for context)

LOP DG Start Instrumentation B3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation BASES BACKGROUND Successful operation of the required safety functions of the Engineered Safety Features (ESF) systems is dependent upon the availability of adequate power sources for energizing the various components such as pump motors, motor operated valves, and the associated control components. Offsite power is the preferred source of power for the 4.16 kV emergency buses which power the required ESF components. The LOP protection instrumentation monitors voltage on the F and G 4.1 6 kV buses. Each electrical train has independent LOP instrumentation and relay actuation logic for detecting degraded grid or loss of voltage conditions. and initiating an LOP emergency diesel generator (EDG) start signaL There are three LOP protection instrumentation actuation levels.

The first level of protection consists of a single independent channel providing a degraded grid voltage alarm. This alann is set at~

3850V. This setpoint is based on detection of a degrading voltage condition where the bus voltage is below the minimum expected based on studies of the expected operation of the offsite power system. The alarm has a time delay to reduce the possibility of ~

for each 4 .16 kV nuisance alarms for expected voltage transients. delav emergency bus as tabulated in Technical The second level is set at~ 3675¥. This level generates an LOP Specification 3.3.5.

signal for sustained degraded grid voltage conditions. The ut ttel se time setting prevents an unnecessary LOP by ensuring th e existence of a sustained voltage inadequacy before actuation.

The third level is set at~ 3255V. This level generates an LOP signal for near instantaneous loss of voltage conditions. The inverse time setting provides quick detection of a significant voltage inadequacy while preventing an unnecessary LOP for momentary power system disturbances.

The second and third levels provide LOP actuation signals. Each level consists of three undervoltage relays o.e., channels}-witft-iflvef9e tiffle eflBFBelefistiea arranged in a two-out-of-three logic.

Actuation of either protection level will automatically disconnect the 4.16 kV emergency buses from th e offsite power source. The loss of voltage sensors start the EDGs, and following the bus load shed, the Emergency Sequencer automatically reloads the bus.

(continued)

Farley Units 1 and 2 B 3.3.5-1 Revision ~

LOP DG Start Instrumentation B 3.3.5 BASES BACKGROUND The LOP instrumentation is also discussed in FSAR, Section 8.3 (continued) (Ref.1).

Alarmffrip Setpoints and AJJowable Values The actual nominal Alarm/Trip Setpoint entered into the device is normally still more conservative than that required by the AIJowable Value. If the measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE..

Setpolnts adjuste-d in accordance with the Allowable VaJue ensure that the consequences of accidents will be- acceptable, providing the unit is operated from within the LCOs at the onset of the accident and that the equipment functions as designed.

AUowable Values and/or Alarm/Trip Setpoints are spe-cified for each Function in the LCO. Nominal Alarm or Trip Setpoints are also specified in the tJFift Bf'eeifie setpoint calculations. The nominal setpoints are selected to ensure that the setpoint measured by the surveillance procedure does not exceed the Anowable Value if the device is performing as required. If the measured setpoint doe-s not exceed the Allowable Value, the device is considered OPERABLE.

Operation with an Alarm or Trip Setpoint less conservative than the nominal value, but within the Allowable Value-, is acceptable provided that operation and testing is consistent with the assumptions of the tJflit Bf3eeitie setpoint calculation.

Each Allowable Value and/or Alarm/Trip Setpoint spe-cified is more conservative than the analytical limit specifie-d in the voltage analyses to account for instrument uncertainties appropriate to the trip function.

These uncertainties are d"efined in the tJAit ~eeitie setpoint calculation (Ret 3).

APPLICABLE The LOP DG start instrumentation is required for the ESF Systems to SAFETY ANALYSES function in any accident with a loss of offsite- power. Its design basis is that of the ESF Actuation System (ESFAS).

Safety analyses credit the loading of the- OG based on concurrent loss of offsite power and a loss of coolant accident (LOCA). The (continued)

Fartey Units 1 and 2 B 3 .3.5-2 Revision e

LOP DG Start lnstrumentafion 83.3.5 BASES APPLICABLE actual DG start has historically been associated with the ESFAS SAFETY ANALYSES actuation. The DG loading is included in the delay time associated (continued) with each safety system component requiring DG supplied power following a loss of offstte power.

Mon.itorin g by the offs fte power system grid operators *and the first

..------------. level LOP instrumentation (alarm) provide the primary protection for a For the 4.16 kV degraded grid event The degraded grid voltage alarm provides emergency buses to notification to control room operators that an abnormally lowvoltage which Technical condition exists on a 4.16 kV emergency bus. Forslow acting Specification Table transientconartions, the alarm setpointallo¥JS forthe initiation of 3.3.5-1 is applicable, an manual actions by the offsite power system operatorto restore

'-----.......------' normal bus voHageandprotectrequiredESFLOCAioadsfromthe low voltage condition wtthoutinitiating an unnecessary automatic disconnectfrom the preferred offstte power source.

~ administratrve limit is esta.blished at a voltage level between the degraded grid voHage alarm allowable value (3835V) and the automaticdegradedgrldvoltageactuationupperallowable value (3749V). Calculations verify that no ESF components require a 4.16kV bus voltage higherthan the administrative limitto perform theirsafety functions . In the voltage range between the For the 4.16 kV administrative lfmitandthe degraded grid voltage actuation trip emergen cy busesto

setpoinf, a few ESF components may not have automatic protection which Te'chnical from inadequatevoHage. The manual actions provide the primary Specification Table means of protecting these few ESF components from a sustained, 3.3 .5-2 is applicable, slightly low voltage condttion and all components from unnecessary an analyticallimtt is [ ' !utomatrc disconnection from the preferred offsite power source.

established for each bus at a voltage level The required channels of LOP DG start instrumentation. rn below the automatic conjunction with the ESF systems powered from the DGs, provide degraded grid voltage unit protectton in th*e event of any of the analyzed accidents actuation allowable discussed in FSAR, Section 15 (Ref. 2 ), in which a loss of offsfte value shown in Table power is assumed.

3.3.5-2 . Calculations verify that no ESF The delay times assumed in the safety analysis forthe ESF components require a equipmentboundfhe12secondDGstartdelay andincludethe 4.16 kV bus voltage appropriate sequencing delay, if applicable. The response times for higher than the ESFAS actuatedequipmentin LC03.32. "EngineeredSafety analyticallimitto Feature Actuation System (ESFAS) Instrumentation," include the perform their safety appropriate DG loading and sequencing delay.

functions .

The LOP DG start instrumentation channerssatistyCriterion3 of10 CFR 50.36{c}(2)(ii).

Farley Units 1 and2 8 3.3 .5-3 Revision ~

LOP DG Start Instrumentation B 3.3.5 BASES LCO The LCOfor LOP DG start instrumentation requires that three channels pertrain of both the loss ofvoHage and degraded grid voltage actuation Functions shaUbe OPERABLE in MODES 1, 2, 3, and4 when the LOP DG start fnstrumentationsupports safety systems associated wHhthe ESFAS. In MODES 5 and 6, the three channel.s mustbeOPERABLE whenevertheassoci.atedDG is requtredto be OPERABLE to ensure that the automaticstartofthe DG is availablewhen needed. Loss of the LOP DG Start Instrumentation Function could result in the delay of safety systems fnttiatfon when requjrecL This could lead to unacceptable consequences during accfdenfs. During the loss of offsite powerthe DG powers-the motor driven auxiliary feedNater pumps. Failure of these pumps to start would leave only one turbine driven pump, as wetr as an fncreased potential for a loss of decay heat removal through the secondary system.

ln addftion, the LCO requires one channel of the degraded grid alarm fundi on pertrain of 4.16 kV emergency buses to be OPERABLE fn MODES 1, 2, 3, and4. The required alarm channels include the Digitaf VoltmeterRelay Contacfs (L0-21V) on buses FandG andthe assocfatedalarmannunciaforsWE2, VE2 (Untt1 ) andYE2, ZE2 (Unit 2 ). The alarm channels provide assurance thatmanuar actions are taken to restore bus voltage and protectthe required ESF LOCA loads from a degraded grid voltage condition.

APPLICABILilY The LOP OG Start Instrumentation Functions are required in MODES 1, 2, 3 , and4 becauseESFFunctions are designed to provide protection in these MODES. Actuation in MODE 5 or 6 fs For the 4.16 kV required wheneverthe required DG must be OPERABLE so that it emergency buses to can performitsfundfon on an LOPordegradedpowertothe vital which Technical bus Specifi~ation ~able [\;

3.3.5-1Js applicable ,the ..:r.A& degradedgrid afarmfundion isrequiredOPERABLEfn MODES 1, 2, 3 , and4 to supportthe voltagerequirementsoftheESF loads required OPERABLE to mffigate a design basrs LOCA In MODES 5 For the 4.16 kV and 6. the degraded grid aJarmfundion is not required OPERABLE emergency buses to as no design basis LOCAis assumed to occur in these MODES and which Technical most of the ESF loads required to mitigate a design basis LOCA are not required OPERABLE.

Specification Table 3.3.5-2 is applicable , the --.

degraded grid alarm is not a function included in the Technical Soecifications.

Farley Units 1 and 2 B 3.3.5-4 Revfsion-4-2

No chsng~s on this paga; includ~d for information onl~*-

LOP DG Start Instrumentation 93.3.5 BASES ACTIONS In the event a channel's Alarm or Trip Setpaintisfound nonconservafive with respedto the Allowable~ orthe channel is found inoperable,then the function thatchannel provides must be declared inoperable and the LCO Condition enteredforthe p,articular protection function affectec1 Because the required channels are specified on a per train basis, the Concfrtion may be entered separately for each train as appropriate.

A Note has been added in the ACTIONS to clarify the application of Completfon Time rules. The Conditions of this Specification may be entered independently for each Function listed in the LCO. The Completfon Time(s) of the inoperable channet(s) of a Function will be tracked separately for each Function startingfromthetimethe Condition was enteredforthatFunction.

Concfrtion A appfiesto the LOP DG start Functions (Functions 1 and

2) with one loss of voltage or degraded grid voltagechannel pertrain inoperable.

If one channel is inoperable, Required Action A.1 requires that channel to be placed in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Wrth a channelfn trip, the remaining LOP DG start instrumentation channels will provide&.

one-out-ot-two logic to initiate a trip of the incoming offsite power.

ANotefs added to Condition e,indicatfngthatitis only applicable to Functions*1 and 2.

A Note is added to allow bypassing an inoperablechannelforupto 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sforsurveutancetesting of other channels. This allowance is made wherebypassingthechannel does not cause an actuation and where at leasttwo other channels are monitoringthatparameter.

The specified Completion Time and time allowed for bypassing one channel are reasonable considering the Function remainsfuiTy OPERABLE on each train and the row probability of an event occurring during these intervals.

Concfrtion B appfies to LOP Functions 1 and 2 when two or more loss of voltage or degraded voltage channels on a single train are inoperable.

{continued)

Farley Units 1 and 2 B 3.3.5-5 Revision42

LOP DG Start Instrumentation No change5 on this page; prowided for information only.

B 3.3.5 BASES ACTIONS 8 .1 (continued)

A Note is added to Condition B indicating that it is only appficable to Functions 1 and 2.

Required Action 8 .1 requires restoring all but one channel on a train to OPERABLE status. With a single inoperable channel remaining on a train, Condition A is applicable. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time should allow ample time to repair most failures and takes into account the low probability of an event requiring an LOP start occurring during this intervaL Condition C applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for ConaJtion A or B are not mel In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources- Operating; or LCO 3.82, nAC Sources- Shutdown: for the DG made inoperable by failure of the LOP DG start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.

Condition D appfies when the required degraded grid voltage alarm function is inoperable on one or both trains of emergency buses. The affected bus voltage associated with each inoperable alarm function must be verified ~ 3850 volts every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Frequent bus voltage verifications in lieu of an OPERABLE alarm effectively accomplish the same function as the alarm and allow operation to continue without the requiTed alarm(s). A Note is added to Condition D indicating that it is only applicable to Function 3.

Condition E is appticable when the Required Action and associated Completion Tune of Condition D is not mel If the voltage being verified per Required Action 0 .1 is< 3850 volts, action must be taken to restore the voltage to ~ 3850 volts within one hour. The Completion Tune of one hour is reasonable to ensure prompt action is taken to restore adequate voltage to th e affected emergency bus(es).

{continued)

Farley Units 1 and 2 83.3.5-6 Revision 0

No changes on this page; prov1ded for infonnation only LOP DG Start Instrumentation B 3.3.5 BASES ACTIONS F.1 and F.2 (continued)

Condition F becomes applicable when the Required Action and associated Completion Time of Condition E is not met. If the emergency bus voltage cannot be restored to ~ 3850 volts within the Completion Tun e of Condition E, action must be taken to place the unit in a MODE where the LCO requirement for the Alarm function is not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The aDowed Completion TLmes are reasonable, based on operating experience, to reach the required unit conditions from tun power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT. The test checks trip devices that provide actuation signals directly, bypassing the analog process control equipment The TADOT surveillance is modified bytwo Notes. The first Note excludes the actuation of the final trip actuation relay for LOP Functions 1 and 2 from til is TADOT. The actuation of this relay would cause the DG start and separation of the emerg.ency buses from the grid. The actual DG start and connection to the emergency bus is verified by other surveillance testing (SR 3.3.5.3) accomplished during shutdown conditions. The second Note provides an exception to the verification of the LOP function setpoints during performance of this monthly TADOT. The TAOOT includes verification of1he undervoltage device operation upon removal of the input voltage and does not require the setpoint be verified or adjusted. The LOP function setpoints are verified during the CHANNEL CALl BRATION.

In addition, the TADOT includes verification of the operation of the two-out-of-three logic associated with LOP Functions 1 and 2. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Any change in the components being tested by this SR will require reevaluation of STI Evaluation Number 558904 in accordance with the Surveillance Frequency Control Program.

(continued)

Farley Units 1 and 2 B 3.3.5-7 Revision 59

No changes on this page* provided for mfonnahon only. LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE SR 3.3.5.2 REQUIREMENTS SR 3.3.5.2 is the performance of a CHANNEL CALI~RATION.

The setpoints, as well as the response to a loss of voltage and a degraded grid voltage test, shall include a sing[e point verification that the trip occurs within the required time delay (refer to appropriate relay setting sheet calibration requirements).

The CHANNEL CAUBRATION is a check of the major instrument components in the loop, including the sensor (relay or digital voltmeter).

The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The CHANNEL CALIBRATION is modified by a Note. The Note excludes the actuation of the final trip actuation relay for LOP functions 1 and 2 from this CHANNEL CALIBRATION. The actuation of this relay would cause the DG start and separation of the emergency buses from the grid. The actual DG start and connection to the emergency bus is verified by other surveiJiance testing (SR 3.3.5.3) accomplished during shutdown conditions.

The Surveillance Frequency is controned under the Surveillance Frequency Control Program.

SR3.3.5.3 This SR ensures the individual channel response times are less than or equal to the maximum values assumed in the safety analysis. The response time testing acceptance criteria are included in FSAR Table*

7.3-16. This surveillance is perfonned in accordance with the guidance provided in the ESF RESPONSE TIME surveillance requirement in LCO 3.3.2, ESFAS.

This surveillance is modified by a Note. The Note states that this surveiHance shall include verification of the actuation of the final trip actuation relay associated with LOP Functions 1 and 2 Far1ey Units 1 and 2 B 3.3.5-8 Revision 59

LOP DG Start Instrumentation B3.3.5 BASES REFERENCES 1 . FSAR, Section 8.3.

2. FSAR, Chapter15.

3 . SN C Calculations E-35.1A, E-352A, af:KI SE-94-0470-006.

4. FSAR, Section 7.3.

and SJ-SNC529029-001 Farley Units 1 and2 93.3.5 -9 Revision -5S

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

c\

40 Inverness Center Parkway Post Office Box 1295 Birmingham , AL 35242 Tel 205.992.7872 SOUTHE RN Fax 205.992.7601 NUCLEA R A SOUTHERN COMPANY NOV 2 0 2015 Docket Nos.: 50-348 NL-15-0722 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specifications (TS). This amendment request proposes to revise TS 3.3.5, "Loss of Power Diesel Generator Start Instrumentation," as described in the Enclosures to this letter.

Revision of the TS 3.3.5 degraded grid voltage relay actuation requirements is needed to enable compliance with the license condition stated in Appendix C of FNP Unit 1 Renewed Operating License NPF-2, and in Appendix C of FNP Unit 2 Renewed Operating License NPF-8. This license condition requires SNC to implement modifications that will eliminate use of manual actions as part of the FNP degraded voltage protection scheme, and is to be complete before restart from the Fall 2017 refueling outage for Unit 2 (2R25) and before restart from the Spring 2018 refueling outage for Unit 1 (1 R28). provides the basis for the proposed changes, Enclosure 2 provides the marked-up TS 3.3.5 pages (along with unaffected pages included for context) and provides the clean-typed TS 3.3.5 pages. Also provided for information in are marked-up pages (along with unaffected pages included for context) showing associated changes planned for the TS 3.3.5 Bases.

SNC requests approval of the proposed license amendment by November 30, 2016, with implementation within 90 days.

In accordance with the requirements of § 50.91, a copy of this request is provided to the designated Alabama official.

U. S. Nuclear Regulatory Commission NL-15-0722 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, c.flP~

C. R. Pierce Regulatory Affairs Director Sworn to and subscribed before me this~ day of n~ , 2015.

~~or:~

~otary Public My commission expires: /o- $ *.) ~ t7 CRP/DWDI<>

Enclosures:

1. Basis for Proposed Changes

2. FNP Units 1 and 2 Technical Specification 3.3.5 Marked-Up Pages

3. FNP Units 1 and 2 Technical Specification 3.3.5 Clean Typed Pages

4. FNP Units 1 and 2 Technical Specification 3.3.5 Bases Marked-Up Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RType: Farley=CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant, Units 1 and 2 Technical Specification 3.3.5 Loss of Power Diesel Generator Start Instrumentation License Amendment Request Enclosure 1 Basis for Proposed Changes

Enclosure 1 Basis for Proposed Changes Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Precedent 4.4 Conclusion 5.0 Environmental Consideration 6.0 References E1-1

Enclosure 1 Basis for Proposed Changes 1.0 Summary Description This proposed license amendment request (LAR) by Southern Nuclear Operating Company (SNC) is made, pursuant to the requirements of 10 CFR 50.90, for a change to the Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, Technical Specifications (TS). This amendment request proposes to revise the setpoint requirements in TS 3.3.5, "Loss of Power Diesel Generator Start Instrumentation,"

for the 4.16 kV Emergency Bus Degraded Grid Voltage Actuation and Alarm functions as follows (and as shown in the marked-up and clean typed pages of Enclosures 2 & 3):

A) In the LCO 3.3.5 and APPLICABILITY sections of TS 3.3.5, add "and Table 3.3.5-2" after each reference to Table 3.3.5-1.

B) Under APPLICABILITY, add the following NOTES:

1. "For Unit 1, use Table 3.3.5-1 until Mode 4 entry following the spring 2018 outage (1 R28); thereafter use Table 3.3.5-2."

2. "For Unit 2, use Table 3.3.5-1 until Mode 4 entry following the fall 2017 outage (2R25); thereafter use Table 3.3.5-2."

C) Following Table 3.3.5-1, "Loss of Power Diesel Generator Start Instrumentation," add a new page with Table 3.3.5-2. Table 3.3.5-2 differs from Table 3.3.5-1 as follows: