NRC-2014-0131, Comment (10) by Kenneth Fredrickson and Scott Bauer, on Behalf of Stars Alliance LLC, on Draft Branch Technical Position 8-9, Open Phase Conditions in Electric Power System.
| ML14206A744 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/23/2014 |
| From: | Bauer S, Fredrickson K STARS Alliance, Wolf Creek |
| To: | Cindy Bladey, Carol Gallagher Rules, Announcements, and Directives Branch |
| References | |
| 79FR3258 00010, NRC-2014-0131, STARS-14009 | |
| Download: ML14206A744 (4) | |
Text
Gallagher, Carol From: Fredrickson Kenneth L <kefredr@WCNOC.com>
Sent: Wednesday, July 23, 2014 3:18 PM To: Gallagher, Carol Cc: Scott Bauer
Subject:
STARS Comments for Docket ID NRC-2014-0131, draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System" Attachments: STARS 14009 Final Signed.pdf
- Carol, Per our discussion I am forwarding you STARS Comments for Docket ID NRC-2014-0131, draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System." I realize that this did not meet the submittal date of July 21, 2014, so there is no guarantee our comments will be considered, and appreciate your willingness to post STARS comments for me.
Thank you, Kenneth Fredrickson Wolf Creek Generating Station kefredr@wcnoc.com Phone: 620-364-8831, Ext. 4505 m
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STARS Alliance Alliance Members:
Callaway Energy Center www.starsalliance.com Comanche Peak Nuclear Power Plant 1626 N. Litchfield Rd., Suite 230 Diablo Canyon Power Plant Goodyear, AZ 85395 Palo Verde Nuclear Generating Station T: 623-209-7549 Wolf Creek Generating Station STARS-14009 July 23, 2014 Ms. Cindy Bladey Office of Administration Mail Stop: 3WFN-06-44M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
STARS Alliance LLC Comments on new Draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System," and draft Revision 5 to Section 8.1, "Electric Power- Introduction," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Docket ID NRC-2014-0131
References:
- 1. FederalRegister Notice, 79 FR 32580, dated June 5, 2014; Docket ID NRC-2014-0131
- 2. Letter from Nuclear Energy Institute (NEI) to Ms. Cindy Bladey, USNRC, "Comments on new Draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System" and draft Revision 5 to Section 8.1, "Electric Power- Introduction," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (Docket ID NRC-2014-0131) (Federal Register Notice 79FR32580)," dated July 21, 2014
Dear Ms. Bladey:
As noted in Reference 1, the Nuclear Regulatory Commission (NRC) published Draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System," and draft Revision S to Section 8.1, "Electric Power- Introduction," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Docket ID NRC-2014-0131, soliciting public comments. STARS appreciates the opportunity to comment on this draft BTP.
Draft BTP 8-9 contains proposed guidance for the staff's safety review of licensing actions related to electric power system design capability for coping with open phase electrical conditions in the offsite power sources. It is understood, and this understanding is important to the STARS licensees, that the
STARS-14009 NRC staff does not intend to impose or apply the positions described in the draft BTP 8-9 or Standard Review Plan to existing licenses and regulatory approvals. contains STARS Alliance LLC comments on the Draft Branch Technical Position (BTP) 8-9, "Open Phase Conditions in Electric Power System," Docket ID NRC-2014-0131.
In addition to the attached comments, STARS also endorses the comments submitted by the Nuclear Energy Institute (NEI) on July 21, 2014 (Reference 2).
If you have any questions, please contact me at 623-239-4359, or scott.bauer(@starsalliance.com.
Sincerely, Scott A. Bauer Regulatory Affairs Functional Area Manager, STARS LLC Attachment 2
STARS-14009 Comments on Draft Branch Technical Position 8-9 "Open Phase Conditions in Electric Power System" (Docket ID NRC-2014-0131)
By STARS Alliance LLC BTP Comment Recommendation Basis for Comments or Resolution 1 Section A, Background The BTP is inappropriately referred to as Explicitly state that the BTP There are defined processes for the NRC to establish new (last paragraph) criteria document. Additionally, the Interim does not establish any new requirements.
NRC OPC Enforcement Policy implies criteria for existing plants.
Section B(1), Nuclear applicability to current plant licensing bases. The stated purpose is to provide guidance for NRC licensing action Power Plants with The treatment of open phase condition is reviews. To the contrary, the long term actions in the enforcement Active Safety Features beyond current plant design and licensing policy refer to NUREG 0800 as a criteria document.
basis. As such, it would not be appropriate to Section B(11)(V)(3), first impose new requirements without performing a Section B also has statements that read "...the following criteria page 5 unnumbered backfit analysis in accordance with 10 CFR should be satisfied." and "Ifthe non-Class 1E... schemes are paragraph 50.109. installed.. .the following equivalent... requirements... should be met as a minimum."
2 Section A,Background The single failure consideration of passive Consider postulated open The second sentence reads, in part, "A design basis event (2 nd from last components within non-Class 1E systems is phase conditions as an event concurrent with this open phase condition could have..." The Paragraph) beyond current requirements. by itself. single failure consideration of passive components outside Class 1E systems is beyond current requirements.
3 Section A, The implication that a design basis accident Safe shutdown capability, not It is acknowledged that an open phase condition in an offsite Background; must be assumed concurrent with an open accident mitigation, must be power circuit must be detectable to help assure a viable source.
phase condition is incorrect. assured for an open phase This is especially true for a standby circuit. However, as described Section B(1)(III), event, by both industry and the NRC to date, an open phase condition is Circuit Classification; an event, not a deterministic single failure. This is an event that affects power quality.
Section B(11)(V)(2),
Protective Actions (w/ Requiring the postulation of an open phase condition inthe offsite Accident Signal) power circuit concurrent with a DBA contradicts GDC-17. Per GDC-1 7 single failure only applies to the Class 1E onsite sources and associated distribution systems. GDC-17 only requires one offsite power circuit to be immediately available. Adding a requirement to postulate a deterministic failure of the sole immediate source contradicts GDC-17.
4 Section B 1(VI) A separate LCO and condition is not Consider modifying the section LCO and conditions already exist for Offsite Power.
Surveillances and necessary. to reflect this.
Limiting Conditions for Operation 3