ML13031A626

Joseph M. Farley Nuclear Plant, Units 1 and 2, Supplemental Information Needed for Acceptance of Requested Licensing Action Concerning Degraded Voltage Compensatory Measures (TAC Nos. MF0468 and MF0469) (NL-12-2142)

ML13031A626
Person / Time
Site:	Farley
Issue date:	03/22/2013
From:	Brown E A, Martin R E Plant Licensing Branch II
To:	Pierce C R Southern Nuclear Operating Co
Brown E A
References
NL-12-2142, TAC MF0468, TAC MF0469
Download: ML13031A626 (5)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 March 22, 2013 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc. P. O. Box 1295, Bin -Birmingham, AL JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED ACTION CONCERNING DEGRADED VOLTAGE MEASURES (TAC NOS. MF0468 AND MF0469)

Dear Mr. Pierce:

By letter dated December 21, 2012, [Agencywide Document Access and Management System (ADAMS) No. ML 12356A470] the Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request for Joseph M. Farley Nuclear Plant, Units 1 and 2. The proposed amendment requests the addition of condition to the licensee related to the completion date for SNC to complete modifications to redesign the current degraded voltage scheme to eliminate the use of administrative controls. This application was made to support ongoing compensatory measures as a result of NRC staff inspection results in NRC Inspection Report 50-348(364)/2011-10 (ADAMS Accession No. ML 113530575). The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant. Consistent with Section 50.90 of Title 10 of the Code ofFederal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations. The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment/relief request in terms of regulatory requirements and the protection of public health and safety and the environment.

C. Pierce -2 Given the rare circumstances surrounding this submittal, the NRC staff has identified that in addition to the schedule request, SNC needs to submit, for NRC approval, those compensatory measures that the licensee intends to keep in place until completion of the proposed modifications at the end of the spring 2018 outage. Therefore, the NRC staff requests that SNC supplement the application to address the information requested in the enclosure by 60 days from the issuance of this letter. This will enable the NRC staff to begin its detailed technical review. Should the application be subsequently accepted for review, SNC will be advised of any further information needed to support the staff's detailed technical review by separate correspondence. The information requested and the associated timeframe in this letter were discussed with Mr. Doug McKinney of your staff on March 7,2013. If you have any questions, please contact me by phone at (301) 415-2315 or email at Eva. Brown@nrc.gov. Sincerely, IRA! Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

As stated cc w/encl: Distribution via Listserv SUPPLEMENTAL INFORMATION NEEDED DEGRADED VOLTAGE SCHEDULE SOUTHERN NUCLEAR OPERATING JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND DOCKET NOS. 50-348 AND In the letter dated December 21, 2012 (the submittal [Agencywide Document Access and Management System (ADAMS) No. ML 12356A470], Southern Nuclear Operating Company (SNC, the licensee) indicates that an administrative limit has been established at a voltage level between the degraded grid voltage alarm allowable value (A V) and the automatic degraded grid voltage actuation upper AV. In the voltage range between the administrative limit and the degraded grid voltage actuation trip setpoint, a few engineered safety feature (ESF) components may not have automatic protection from inadequate voltage. The submittal further states that 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. In the event of ESF actuation during degraded voltage conditions, provide details on: a) Equipment/components that may not have adequate voltage to operate; b) Equipment that may trip due to automatic protection such as overload relay actuations; c) Equipment that may trip but will require manual action to reset the protective device; and, d) Equipment that may degrade and may not be able to perform its required function. Explain the grid contingencies that were considered to ensure the switchyard voltages remain above the voltages required for safe shutdown of the plant. Provide technical basis including supporting data or analysis to show that the degraded voltage relay alarm settings would provide enough time to take operator actions in order to protect all Class 1 E equipment from the consequences of a sustained degraded voltage condition. The implementation schedule proposes Technical Specification amendment request after completion of Design. In order to expedite the schedule, explain why a concurrent amendment request is not considered to resolve any staff questions associated with proposed setpoints. Enclosure

-2 The submittal indicates that two outages are necessary to complete the modifications on each unit based on SNC's philosophy that limits electrical modifications to one electrical train per outage. In view of the high consequences of degraded voltage conditions concurrent with an ESF actuation (impact on redundant trains of ESF equipment). explain why the modification cannot be implemented in one outage with non-intrusive work performed online. APHB Identify the compensatory actions that will be relied upon to support the operation of equipment identified in Question 1 above. Include in the details of the consequences on accident analyses as a result of any delay equipment restoration by the proposed manual How long have the existing manual actions that respond to degraded voltage conditions been in place? If not since initial licensing. what were the circumstances that led to allocation of this function to operators rather than automatic systems? Discuss the alarms. annunciators. etc ... that are provided to notify personnel manual action(s) to respond to degraded voltage conditions is/are Discuss the alarms. annunciators, etc ... that are provided to notify personnel that the manual action(s) to respond to degraded voltage conditions is/are no longer required. Describe the administrative controls in place to ensure that. when the action(s) is/are no longer required, and the plant configuration is restored in the correct configuration for the plant status. a. Describe any manual actions in the normal and the emergency operating procedures in addition to those discussed in Q2 that are needed to prevent or mitigate degraded voltage conditions. If the Emergency Operating Procedures are involved. describe any verification and validation that was done to confirm that the existing manual actions are feasible. reliable. and effective. e.g .. initial start-up testing. V&V performed as part of the Detailed Control Room Design Review. post-mod or post-maintenance testing, or cyclical testing done as part of a Time-Critical Action Program. Regarding the V&V or testing discussed in Q7.b. above. did the validation include a representative sample of operators. and was it done with Technical Specification (TS) minimum staffing and nominal staffing? Discuss the time required to perform manual actions versus time available. Describe any controls or displays (including annunciators and alarms) needed to respond to degraded voltage conditions until implementation of the proposed modifications.

C. Pierce -2 Given the rare circumstances surrounding this submittal, the NRC staff has identified that in addition to the schedule request, SNC needs to submit, for NRC approval, those compensatory measures that the licensee intends to keep in place until completion of the proposed modifications at the end of the spring 2018 outage. Therefore, the NRC staff requests that SNC supplement the application to address the information requested in the enclosure by 60 days from the issuance of this letter. This will enable the NRC staff to begin its detailed technical review. Should the application be subsequently accepted for review, SNC will be advised of any further information needed to support the staff's detailed technical review by separate correspondence. The information requested and the associated timeframe in this Jetter were discussed with Mr. Doug McKinney of your staff on March 7, 2013. If you have any questions, please contact me by phone at (301) 415-2315 or email at Eva. Brown@nrc.gov. Sincerely, IRA! Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

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