ML12236A304
| ML12236A304 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/26/2012 |
| From: | Thadani M Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Thadani M | |
| References | |
| TAC ME6877 | |
| Download: ML12236A304 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 26, 2012 Vice President, Operations Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT REVISING THE UPDATED FINAL SAFETY ANALYSIS REPORT TO REFLECT AUTHORIZATION OF USE OF ON LOAD TAP CHANGERS WITH THE NEW RESERVE STATION SERVICE TRANSFORMERS (TAC NO.
ME68??)
Dear Sir or Madam:
The U. S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 302 to Renewed Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant (JAF). The amendment consists of changes to the JAF Updated Final Safety Analysis Report (UFSAR) in response to your application dated August 16, 2011, as supplemented by letters dated March 30, June 13, August 1,and August 16, 2012.
The amendment revises the JAF's current licensing basis, in the UFSAR, to support installation of new reserve station service transformers (RSST) with on-load tap changers (OL TC). The new RSSTs with OL TCs will compensate for the wider range of offsite power voltage variations so that acceptable voltages at the safety-related equipment will be better maintained. The OL TCs are SUb-components of two new RSSTs that will be installed at JAF during the refueling outage scheduled for September 20012.
Entergy Nuclear Operations, Inc, the licensee for JAF, requested approval to replace existing RSSTs, which are provided with manual no-load tap changers, with new RSSTs provided with OL TCs to facilitate operations in the automatic mode The Commission's staff evaluated the licensee's request, and based on its evaluation, the NRC staff concludes that, with the revised design basis, the offsite power will remain capable of shutting down and maintaining the reactor in a safe condition after an anticipated operational occurrence or a postulated design-basis accident. Thus, the revised licensing basis will continue to meet the Commission's regulations in Appendix A of Title 10 of Code of Federal Regulations, Part 50.
Vice President, Operations A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.
Sincerely, Mohan C. Thadani, Senior Project Manager Plant licensing Branch 1-1
. Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosures:
- 1. Amendment No. 302 to DPR-59
- 2. Safety Evaluation cc w/encls: Distribution via listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY NUCLEAR FITZPATRICK. LLC AND ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 302 Renewed Facility Operating License No. DPR-59
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated August 16, 2011, as supplemented on March 30, June 13, August 1,and August 16, 2012 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, by Amendment No. 302 the renewed operating license is amended by changes to the Updated Final Safety Evaluation as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No.
DPR-59 is hereby amended to read as follows:
Accordingly, the license is amended to authorize changes to the Updated Final Safety Analysis Report to reflect the changes approving the use of on load tap changers
- 2 Accordingly, the license is amended to authorize changes to the Updated Final Safety Analysis Report to reflect the changes approving the use of on load tap changers (OL TCs) with the new reserve station service transformers, as discussed in the licensee's application dated August 16, 2011, as supplemented by letters dated March 30, June 13, April 1, August 16, and September 14, 2012. The OL TCs will compensate for the wider range of offsite power voltage variations so that acceptable voltages at the safety-related equipment will be maintained.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 90 days. The licensee shall submit the changes authorized by the Amendment with the next update of the UFSAR in accordance with 10 CFR 50.71(e).
FOR THE NUCLEAR REGULATORY COMMISSION A~~d-'
George Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License Date of Issuance: September 26, 2012
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 302 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59 ENTERGY NUCLEAR OPERATIONS, INC.
JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By letter dated August 16,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML112280282), as supplemented by letters dated March 30, June 13, August 1, August 16, and September 14, 2012 (ADAMS Accession Nos. ML12090A613, ML 112166A326, ML12214A462, ML12230A126, and ML12261A056 respectively), Entergy Nuclear Operations, Inc., the licensee the James A. FitzPatrick Nuclear Power Plant (JAF),
submitted a license amendment request (LAR). The supplements dated March 30, June 13, August 1, August 16, and September 14, 2012 provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register.
The licensee requested approval for the use of on load tap changers (OL TCs) with the new reserve station service transformers (RSSTs) at JAF. The new RSSTs provided with OLTCs will replace existing RSSTs with manual no-load tap changers, and will facilitate operation in the automatic mode. The amendment would revise the JAF licensing basiS by incorporating the appropriate changes to the Updated Final Safety Analysis Report (UFSAR) to allow the use of OL TCs with the new RSSTs. The OL TCs will compensate for the wider range of offsite power voltage variations so that acceptable voltages at the safety-related equipment will be maintained.
2.0 REGULATORY REQUIREMENTS The regulatory requirements which the staff applied in the review of the application include:
J.
10 CFR 50.59(c)(1) A licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedures as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:
- 2 (i) A change to the technical specifications incorporated in the license is not required, and (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c}(2) of this section.
(2) A licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment jf the change, test, or experiment would:
(i) Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated);
(ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report (as updated);
(iii) Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated);
(iv) Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);
(v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated);
(vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated);
(vii) Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.
(3) In implementing this paragraph, the FSAR (as updated) is considered to include FSAR changes resulting from evaluations performed pursuant to this section and analyses performed pursuant to Sec. 50.90 since submittal of the last update of the final safety analysis report pursuant to Sec. 50.71 of this part.
(4) The provisions in this section do not apply to changes to the facility or procedures when the applicable regulations establish more specific criteria for accomplishing such changes.
The licensee determined that the operation of the new RSST provided with OL TCs in the automatic mode requires prior NRC approval because such operation creates the possibility for
- 3 a malfunction of a structure, system or component important to safety with a different result than previously evaluated in the UFSAR. Accordingly, pursuant to the regulation 10 CFR 50.59(c)(2)(vi), the licensee has submitted its request for approval of the proposed changes to the UFSAR.
- 2.
General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR 50, requires that An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that: (1) Specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences; and, (2) The core is cooled, and containment integrity and other vital functions are maintained, in the event of postulated accidents.
The on-site electric power supplies, including the batteries, and the on-site electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.
Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights-of-way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all on-site alternating current power supplies and the other off-site electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.
Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the on-site electric power supplies.
The Atomic Energy Commission's (the NRC's predecessor) Safety Evaluation for JAF states that the design and design criteria for JAF are consistent with GDC 17.
3.0 TECHNICAL EVALUATION
The JAF's electrical distribution system provides three sources of power to the safety-related busses. During normal operation in MODE 1, the safety-related busses are supplied power
-4 from the Normal Station Service Transformer (NSST). The NSST steps down the voltage from the main generator output and supplies to 4.16 kilo-Volt (kV) switchgear busses 10300 and 10400 which in turn supply 4.16 kV power to the safety-related busses 10500 (Division A) and 10600 (Division 8). During this time, the RSSTs are in an energized and unloaded condition. In the event of a generator trip or a plant shutdown, loads are transferred to two qualified offsite circuits which supply power from the 115 kV system through two RSST (T3 and T2) to the safety-related busses (1 0500 and 10600) via circuit breakers in the 10300 and 10400 switchgear.
The purpose of the two qualified off-site circuits is to supply power to the plant vital loads, including the emergency core cooling systems (ECCS), in the event of unit trip, startup and shutdown conditions. This is accomplished by using the RSSTs to reduce the 115 kV transmission voltage to 4.16 kV distribution system voltage. Each qualified offsite circuit consists of a 115 kV transmission line, a RSST, and the circuit breakers and disconnects necessary to complete the circuit to a 4.16 kV safety-related bus. There are two 115 kV transmission lines which provide offsite power to JAF - one from the Lighthouse Hill Hydroelectric Station, and other from the Nine Mile Point Nuclear Station.
In the case of loss of offsite voltage or degraded voltage, the 4 kV undervoltage protection scheme transfers the power source to the safety-related buses from offsite circuits to the emergency diesel generators (EDGs).
3.1 Proposed Change In the LAR, the licensee stated that in case of a design basis loss-of-coolant accident (LOCA),
the 115 kV transmission lines must provide adequate voltage (after the generator trip) to allow the RSSTs to power the plant loads, including ECCS loads, without transferring to EDGs. The post-contingency voltages at 115 kV switchyard (primary side of RSSTs) are monitored frequently by the 115 kV system operator, using a predictive model to confirm that (after a postulated generator trip), the 115 kV voltage will not decrease sufficiently to cause any safety related bus (10500 bus or 10600 bus) to separate from the offsite power source, due to the operation of degraded voltage relays (DVRs). The post-contingency voltage at 115 kV switchyard voltages is used by the licensee to calculate minimum voltages at safety-related buses. The licensee has a post-contingency voltage requirement of 112.5 kV at the 115 kV switch yard, in order to have adequate voltages at the safety-related buses without operating the DVRs. If the postulated contingency voltage drops below this level, the 115 kV system operator notifies the JAF control room, and takes necessary mitigating actions (within 30 minutes) to attempt to raise the postulated contingency voltage. In case the system operator cannot make sufficient adjustments to raise the postulated contingency voltage, JAF follows the requirements of Technical Specification (TS) LCO (Limiting Conditions for Operation) 3.8.1, "AC Sources Operating."
The licensee has proposed to replace existing RSSTs (presently provided with manual no-load tap changers) with the new RSSTs provided with OL TCs for operation in the automatic mode.
The OL TCs will be located on the low voltage 4.16 kV "Y" winding of the RSSTs, provided with 8 steps above and 8 steps below (each step 1.25%), for a total voltage range of +/-1 0 percent. The OL TCs would make adjustments such that 4.16 kV system voltages would be maintained above the DVR setpoint over a broader range of 115 kV system conditions. The change would help in reducing the number of postulated unplanned entries into the LCO. The licensee also submitted
- 5 marked-up pages of the UFSAR which were impacted by the proposed changes. The automatic operation of an OL TC is controlled by a set of primary and backup controllers. In the LAR, the licensee stated that the use of the OL TC in automatic mode creates the possibility for a malfunction of the OL TC mechanism or the primary controller, resulting in raising or lowering the voltage (to an unsafe level) provided to the 4.16 kV safety-related buses. Since, this failure mechanism can result in a malfunction of a structure, system or component important to safety with a different result than any previously evaluated in the UFSAR, the use of OL TCs in the automatic mode requires NRC approval in accordance with 10 CFR 50.59.
3.2 Evaluation of the Changes The staff reviewed the LAR to determine whether the proposed new replacement RSSTs provided with OLTCs with operation in the automatic mode, would have any adverse impact on the operation of safety-related equipment. The staff reviewed the proposed change for any adverse impact on emergency bus voltages when fed from the RSSTs with OL TCs.
Since, the minimum voltages rather than the maximum voltages are of main concern for the operation of the safety-related loads, the impact of the OL TCs on the minimum acceptable voltages is evaluated, as below.
The requirement of minimum degraded voltage on the emergency buses is provided in TS Table 3.3.8.1-1 (Loss of Power Instrumentation). The minimum allowable voltage setting is 2:109.8 V [volt]. Based on voltage transformer ratio of 35 (4200 V/120 V), the minimum allowable voltage at the emergency buses is 2:3843 V (92.38% of 4160 V).
The staff requested the licensee whether it would have a new agreement with the 115 kV transmission operator for any new range of 115 kV switchyard voltage operation after the new RSSTs with OL TCs are installed, which could have an impact on the existing voltage analysis at the safety-related buses. The licensee, in response to a staff's request for additional information, in letter dated March 30, 2012, stated that the Transmission Owner (National Grid) maintains the 115 kV system operating voltages between 109.25 kVand 120.75 kV (115 kV
+/-5%). The current permissible post-LOCA 115 kV contingency voltage that can occur following a generator trip without actuating the DVR scheme with the existing RSST's installed is 112.5 kV. Based on the analysiS performed by the licensee, the minimum post-LOCA contingency voltage requirement with the proposed replacement of RSSTs following a generator trip, without actuating the DVR scheme, and with the OLTC in automatic operation will be 106.8 kV. In its letter dated June 13, 2012, Enclosure 5, the licensee showed how the RSST OL TCs primary and backup controller settings would enable it to keep the 4160 V emergency bus voltage above the required minimum allowable voltage, and also limit the maximum voltages at the emergency buses for continuous operation of safety-related loads. The NRC staff reviewed the licensee's analyses and finds that the RSST OL TCs in automatic operation would not adversely impact the voltages at safety-related buses.
In its letter dated March 30, 2012, the licensee also stated that the Transmission Owner has procedural controls in place that monitor the minimum 115 kV system post-LOCA contingency voltage for JAF. In the event of the minimum post-LOCA voltage alarm, notification is made to the JAF Control Room, at which time the 115 kV system would be declared inoperable, and the Transmission Owner takes actions to raise the 115 kV system voltage at JAF. Within 30 minutes from the initial alarm, another load flow is performed by the Transmission Owner and
- 6 the JAF Control Room is notified if the minimum post LOCA contingency voltage alarm has cleared or if the Transmission Owner was not successful in raising the 115 kV system voltage above the minimum post LOCA contingency voltage. If the post LOCA contingency alarm has cleared, the 115 kV system would be declared operable; otherwise the 115kV system would remain inoperable.
In letter dated September 14, 2012, the licensee further clarified that the current mutual agreement between the Transmission Owner and Entergy FitzPatrick requires a minimum voltage of 112.5 kV in order to support post trip accident loads. After replacement of the RSSTs with on-load tap changers, the post-contingency switchyard voltages will be revised to reflect the the minimum voltage as 109.25 kV with both RSST tap changers in Auto mode, and 111.1 kV with either tap changer in Manual mode. These values are consistent with the analysis results provided in the proposed revised UFSAR pages. The licensee submitted revised UFSAR Page 8.6.9, and Figure(s) 8.6-1a and 8.6-1b based on RSST tap changers in Auto mode and Manual mode. The NRC staff finds the proposed changes as acceptable since the voltages at emergency buses will not be adversely impacted by the proposed changes, and because the minimum voltages as provided in UFSAR Page 8.6.9, and Figure(s) 8.6-1a and 8.6-1b bound the minimum degraded voltage (3843 V) on the emergency buses as provided in TS Table 3.3.8.1-1 (Loss of Power Instrumentation). The licensee requirement to declare the 115 kV system inoperable will be minimized, since the minimum switchyard voltages required under accident conditions will be lowered from 112.5 kV to 109.25 kV with RSST tap changes in Auto mode and 112.5 kV to 111.1 kV with RSSTs tap changers in Manual Mode. Therefore, the staff finds the proposed changes to UFSAR Page 8.6.9, and Figure(s) 8.6-1a and 8.6-1b as acceptable.
In the LAR, the licensee described the various potential failure modes and the resulting impacts of OL TC automatic operation, and the actions which will be taken by the licensee corresponding to each failure mode. The OL TC mechanism is equipped with system monitoring functions that generate alarms in case of malfunctions and block the raisellower switch while bringing the OL TC back to the most recent step position. The licensee stated that in the event an OL TC needs to be placed in manual control, the tap setting will be placed in a predetermined position based on 115 kV switchyard voltage. In letter dated September 14,2012, the licensee provided voltage profiles at emergency buses in UFSAR Figure 8.6-1 b with OL TCs in manual mode under light load, LOCA, and normal load conditions. Based on its review, the NRC staff finds that the licensee has adequately analyzed the potential failure modes of OL TC operation, and the proposed actions corresponding to each failure mode are acceptable.
In letter dated September 14, 2012, the licensee provided regulatory commitment to have a revised voltage agreement by December 10,2012, with the transmission owner per NUC-001
[Standard for Nuclear Plant Interface Coordinatioh], regarding the use of the RSST OL TC (Le.,
minimum 115 kV switchyard voltage of 111.1 kV in Manual mode, and 109.25 kV in Auto mode) based on the analysis results provided in UFSAR. Until December 10, 2012, the analysis corresponding to the new RSSTs will continue to be enveloped by the existing voltage agreement (Le., minimum 115 kV switchyard voltage of 112.5 kV). The NRC staff finds this acceptable, since the current agreement for the 115 kV switchyard voltage range is conservative.
Based on the above evaluation, the NRC staff concludes that, with the implementation of the proposed revisions, the offsite power will remain capable of shutting down and maintaining the
- 7 reactor in a safe condition after an anticipated operational occurrence or a postulated design-basis accident, and the revised licensing basis will continue to meet GDC 17.
Therefore the incorporation of the proposed changes to the JAF current licensing basis in the UFSAR to allow the use of OLTCs. with the new (replacement) RSSTs is acceptable.
4.0 REGULATORY COMMITMENT The changes to the voltage agreement with the Transmission Owner per NUC-001 will be completed by December 10, 2012 (within Sixty (60) days after the engineering change has been completed). This action will be tracked by Entergy as a one time commitment. The commitment states that, "Post installation and use of the RSST OL TC in manual and automatic mode, revise agreement per NUC-001 with transmission owner based on conservative analysis results documented in UFSAR."
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 1 0 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (76 FR 70768). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.
Principal Contributor: V. Goel Date: September 26, 2012
Vice President, Operations
- 2 A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.
Sincerely, IRA!
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosures:
- 1. Amendment No. 302 to DPR-59
- 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:
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