PLA-6308, Electrical Power Systems Technical Specification 3.8.1 - Supplement PLA-6308
| ML073470232 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/05/2007 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6308 | |
| Download: ML073470232 (9) | |
Text
Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 DEC 0 5 2007 btmckinney@pplweb.com 0 16 P '. 4
- ~ TM U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED LICENSE AMENDMENT NUMBER 262 FOR UNIT 2 OPERATING LICENSE NO. NPF-22 ELECTRICAL POWER SYSTEMS TECHNICAL SPECIFICATION 3.8.1 - SUPPLEMENT PLA-6308 Docket No. 50-388
References:
"ProposedLicense Amendment Number 262for Unit 2 OperatingLicense No. NPF-22 ElectricalPowerSystems Technical Specification 3.8.1,"
dated March 3, 2007.
"Requestfor Additional Information (RAI)-Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2) - ElectricalPowerSystems Technical Specification (TS) 3.8.1 (TAC No. MD4766), 'dated November 14, 2007.
"Response to NRC Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operabilityof Offsite Power,"dated March 28, 2006.
"SupplementalInformation Related to NRC Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operabilityof Offsite Power,"
datedJanuary30, 2007.
"SusquehannaSteam electric Station, Units 1 and 2 - "Response to Generic Letter 2006-02, GridReliability and the Impact on Plant Risk and the Operabilityof Offsite Power," (TAC Nos. MDI040 and MDl04), "dated November 14, 2007.
Pursuant to 10 CFR 50.90, PPL Susquehanna LLC (PPL) requested in Reference 1 approval of an amendment to Susquehanna Steam Electric Station (SSES) Unit 2 Technical Specification (TS) 3.8.1 "Electrical Power Systems - AC Sources Operating."
The proposed change reflects a new ACTIONS Note 3 that is intended to allow a Unit 1 4160 V subsystem to be de-energized and removed from service to perform bus maintenance.
'40,C) 1
Document Control Desk PLA-6308 The purpose of this letter is to provide the PPL responses to the Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI) contained in Reference 2. contains the PPL responses to the NRC RAI's. These responses were discussed during a teleconference between PPL and NRC on November 8, 2007. contains three (3) new regulatory commitments as a result of this supplement.
PPL has reviewed the "No Significant Hazards Considerations" and the "Environmental Consideration" submitted with Reference 1 relative to these responses. We have determined that there are no changes required to either of these documents.
If you have any questions, please contact Mr. Duane L Filchner at (610) 774-7819.
I declare, under penalty of perjury, that the foregoing is true and correct.
Executed on: / ')":' B. T. McKinney : PPL Response to Request for Additional Information : List of Regulatory Commitments Copy: NRC Region I Mr. R. V. Guzman, NRC Sr. Project Manager Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector
Attachment 1 to PLA-6308 PPL Response to Request for Additional Information
Attachment 1 to PLA-6308 Page 1 of 4 The NRC staff requested PPL, in Reference 2, to provide assurance that the following items will be met:
NRC Item a:
No maintenance or testing that affects the reliability of the remaining trains will be scheduled during the SSES Unit 1 bus maintenance. If any testing and maintenance activities must be performed during this time, an evaluation will be performed in accordance with Title 10 to the Code of FederalRegulations (10 CFR)
Section 50.65(a)(4).
PPL Response:
No maintenance or testing that affects the reliability of the remaining OPERABLE Unit 1 and Unit 2 4160 V subsystems will be scheduled while Unit 2 TS 3.8.1 Note 3 is in effect. If any testing or maintenance activities must be performed during this time, an evaluation will be performed in accordance with Title 10 to the Code of Federal Regulations (10 CFR) Section 50.65(a)(4). Attachment 2 identifies this response as Commitment 1.
NRC Item b:
The scheduling of SSES Unit 1 4160 volt (V) bus preplanned maintenance will be avoided during seasons when the probability of severe weather or grid stress conditions is high or forecasted to be high.
PPL Response:
Unit 1 4160 V preplanned bus maintenance is only scheduled during a Unit 1 outage. As such, the timing of the outage determines when this preplanned bus maintenance occurs.
Unit outages are normally scheduled during the spring of the year when the probability of severe weather or grid stress conditions is not high or forecasted to be high. Reference 3, Question 5(c) provided a response by PJM, the Transmission Operator (TO), regarding the scheduling of maintenance activities during periods of high grid stress or severe weather. (See the excerpt below)
PLA 6031 Question 5(c)
Stress on the grid is manifested in a number of ways. Stress can mean the loading levels on individualfacilities, overall demand levels, the degree offacilities out of servicefor maintenance, occurrence of severe weather, etc. Each aspect creates a level of stress on the grid and challenges the system operators.
Regarding the seasonal variability of the stress causers, each has a seasonal component. Forexample, peak load levels occur at the peak seasons of the summer
Attachment 1 to PLA-6308 Page 2 of 4 and winter seasons. While the specific days cannot be predicted, it is known roughly when they will occur. Consequently, maintenanceduring these times of the year is avoided.
Note that Reference 5 is the NRC's determination that PPL's prior responses to Generic Letter 2006-02 (based on References 3 and 4) are complete and that compliance is being maintained with NRC regulatory requirements.
NRC Item c:
The system load dispatcher will be contacted once per day to ensure no significant grid perturbations are expected during the bus maintenance. Also, the system load dispatcher should inform the plant operator if conditions change during the bus maintenance (e.g., unacceptable voltages could result due to a trip of the nuclear unit).
PPL Response:
Current plant procedures are followed on a day-to-day basis and have been demonstrated to be effective. Following these procedures and utilizing effective communication protocols ensures consistent performance in managing risk and when required, reducing risk by restoring equipment or re-scheduling work due to emergent issues.
The response to Reference 4, Question 6 established thatý the on-shift control room operations staff and/or the work management staff make decisions as required to notify the Transmission Operator (TO) or system load dispatcher when maintenance activities extend beyond the original work schedule. (See the excerpt below).
PLA 6152 Question 6 The on-shift Control Room operations staff and/orithe Work Management staff make decisions as requiredto notify the TO for reschedulingof grid-risk-sensitive maintenance activities based on plant work activities. Likewise, for maintenance activities at the nuclearpower plant that extend beyond the originalwork schedule, the Control Room operatorscommunicate with the GO through the GeneratorPower Dispatcherand/or the TransmissionPower System Dispatcher as conditions warrant.
SSES proceduresprovide direction to report equipment malfunctions and status changes affecting or potentially affecting station operation to the Generation Power Dispatcherand/or TransmissionPower System Dispatcher.
These proceduresarefollowed on a day-to-day basis and have been demonstrated to be effective at controllingrisk to generationfrom a plant and Transmission Operator(TO) perspective. Following the appropriateprocedure and effective communicationprotocols ensures consistentperformance in managing risk and
Attachment 1 to PLA-6308 Page 3 of 4 when required,reducing risk by restoringout-of-service equipment and re-schedulingwork due to emergent issues as they occur.
Plant activities and scheduled transmissionoutages are coordinatedbetween SSES and the TO to minimize risk before grid-risk-sensitivemaintenance activities are conducted.
NRC Item d:
Component testing or maintenance of safety systems and important non-safety equipment including offsite power systems (auxiliary and startup transformers) that increase the likelihood of a plant transient or loss of offsite power will be avoided. In addition, no discretionary switchyard maintenance will be allowed.
PPL Response:
In-plant grid-risk-sensitive maintenance activities are rescheduled as required based on information received from the TO for conditions that increase the likelihood of a plant transient or loss of offsite power (LOOP). For grid-risk-sensitive maintenance activities that cannot be rescheduled, i.e. non-discretionary, plant risk is assessed and the appropriate contingencies are put in place. This is consistent with the PPL response to Reference 3, Question 6(c). (See the excerpt below).
PLA 6031 Question 6(c)
...PPL SSES reschedules in-plant grid-risk-sensitivemaintenance activities as requiredbased on information receivedfrom the TO. Forgrid-risk-sensitive maintenance activities that cannot be rescheduled;plant risk is assessed and the appropriatecontingencies areput in place. PJM alerts, warnings, and actions issued to PJMmembers, as listed in Response to Question 1(b), are also considered when performing risk assessment.
Decisions are made by the on-shift Control Room 9perationsstaff and/or the Work Management staff to notify the TO for reschedulingof grid-risk-sensitive maintenance activities as requiredbased on plant 'work activities.
NRC Item e:
TS requirements of verification that the required systems, subsystems, trains, components, and devices that depend on the remaining 4160 V buses are operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices (e.g., the Unit 1 4160 V bus breakers will not lockout any of the remaining emergency 4160 V supplies).
Attachment 1 to PLA-6308 Page 4 of 4 PPL Response:
During application of Note 3, PPL commits to verify that the required systems, subsystems, trains, components, and devices that depend on the remaining 4160 V buses are OPERABLE. Attachment 2 identifies this response as Commitment 2.
Commitment 1, established in response to NRC Question 1, identifies that subsequent testing or maintenance activities on these systems will not be scheduled while Note 3 is in effect. If any testing or maintenance activities must be performed during this time, an evaluation will be performed in accordance with Title 10 to the Code of Federal Regulations (10 CFR) Section 50.65(a)(4).
NRC Item f:
Safety-related steam driven pumps will be controlled as "protected equipment," and will not be taken out of service for planned maintenance while a SSES Unit 1 4160 V bus is out of service for extended maintenance.
PPL Response:
During application of Note 3, Unit 1 is in an outage and no safety-related steam driven pumps (HPCI and RCIC) are available. However, for the operating Unit 2, PPL commits to control the Unit 2 safety-related HPCI and RCIC pumps as "protected equipment" and not take them out of service for planned maintenance while a Unit 1 4160 V bus is out of service for extended maintenance. Attachment 2 identifies this response as Commitment 3.
NRC Item g:
Any component testing or maintenance that increases the' likelihood of a plant transient would be avoided; plant operation should be stable during SSES Unit 1 4160 V maintenance.
PPL Response:
The response to this item has been previously addressed by PPL responses to NRC Items a and d above.
Attachment 2 to PLA-6308 List of Regulatory Commitments
Attachment 2 to PLA-6308 Page 1 of 1 List of Regulatory Commitments The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions, are provided for information purposes, and are not considered to be regulatory commitments.
TYPE SCHEDULED COMMITMENT One-time Continuing COMPLETION Compliance DATE 1.) No maintenance or testing that affects the reliability of the remaining OPERABLE Unit 1 and Unit 2 4160 V subsystems will be scheduled while Unit 2 TS 3.8.1 Note 3 is in effect. If any testing or maintenance X Prior to scheduled activities must be performed during this Unit 1 4160 V bus time, an evaluation will be performed in maintenance during accordance with Title 10 to the Code of the Ul 15RIO.
FederalRegulations (10 CFR) Section 50.65(a)(4).
2.) During the application of Unit 2 TS 3.8.1 During scheduled Note 3, verify that the required systems, Unit 1 4160 V bus subsystems, trains, components, and devices X maintenance.
that depend on the remaining 4160 V buses are OPERABLE.
3.) During the application of Unit 2 TS During scheduled 3.8.1 Note 3, the Unit 2 safety-related HPCI Unit 1 4160 V bus and RCIC pumps will be controlled as X maintenance.
protected equipment" and will not be taken out of service for planned maintenance while a Unit 1 4160 V bus is out of service for extended maintenance.