IR 05000324/2019012

NRC Temporary Instruction 2515/194 Inspection Associated with NRC Bulletin 2012-01, IR 05000325/2019012 & 05000324/2019012

ML19324D085
Person / Time
Site:	Brunswick
Issue date:	11/20/2019
From:	Steven Rose NRC/RGN-II/DCP/CPB2
To:	Krakuszeski J Duke Energy Progress
Bradley Davis RGN-II/DRP
References
IR 2019012
Download: ML19324D085 (9)

Text

November 20, 2019 Mr. John Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Road, SE (M/C BNP001)

Southport, NC 28461 SUBJECT: Brunswick Steam Electric Plant - NRC Temporary Instruction 2515/194 Inspection of the Licensee's Implementation of industry initiative associated with the open phase condition design vulnerabilities in Electric Power Systems (NRC Bulletin 2012-01) Inspection Reports 05000325/2019012 & 05000324/2019012

Dear Mr. Krakuszeski:

On October 10, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Steam Electric Plant and discussed the results of this inspection with Jay Ratliff and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspector did not identify any findings or violations of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, and Requests for Withholding.

Sincerely,

/RA Guillermo Crespo for/

Steven D. Rose, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket No.: 05000325/05000324 License No.: DPR-71/62

Enclosure:

Inspection Reports 05000325/2019012 &

05000324/2019012 w/ Attachment: TI 2515/194 Inspection Documentation Request

Inspection Report

Docket Numbers: 05000325 / 05000324 License Numbers: DPR-71 and DRP-62 Report Numbers: c and 05000324/2019012 Enterprise Identifier: I-2019-012-0017 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: Southport, NC Inspection Dates: October 7 to October 10, 2019 Inspector: C. Stancil, Sr. Fuel Facility Inspector Approved By: Steve Rose, Chief Construction Inspection Branch 2 Division of Construction Oversight Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting Temporary Instruction 2515/194, Inspection of the Licensees Implementation of Industry Initiative Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (NRC Bulletin 2012-01), at Brunswick Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings were identified.

Additional Tracking Items None.

INSPECTION SCOPE

This inspection was conducted using Temporary Instruction 2515/194 (ADAMS Accession No. ML17137A416), dated October 31, 2017. The inspector reviewed the licensees implementation of Nuclear Energy Institute (NEI) voluntary industry initiative (VII) in compliance with regulatory requirements and current licensing bases. The inspector discussed the licensees open phase protection (OPP) system design and ongoing implementation plans with plant staff. The inspector reviewed licensee documentation, vendor documentation, and performed system walkdowns to verify that the installed equipment was supported by the design documentation. The inspector verified that the licensee had completed the installation and testing of equipment, installed and tested alarm circuits both local and in the control rooms, and analyzed potential impacts associated with the design implementation on the current licensing basis.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL Temporary Instruction 2515/194 - Inspection of the Licensees Implementation of Industry Initiative Associated With the Open Phase Condition Design Vulnerabilities In Electric Power

Systems (NRC Bulletin 2012-01) (1 Sample)

The objective of Temporary Instruction 2515/194 is to verify that licensees have appropriately implemented the NEI VII (ADAMS Accession No. ML15075A454), dated March 16, 2015, including updating their licensing basis to reflect the need to protect against open phase conditions (OPC).

Temporary Instruction 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

Brunswick Steam Electric Plant selected the OPP system designed and manufactured by PCS2000 Solutions. Each OPP system for Brunswick included two Schweitzer microprocessor transformer protection relays installed on the high-voltage sides of the 230/4.16 KV start-up auxiliary transformers (SAT) and the 230/24 KV main power transformers (MPT) for both units to detect and initiate an alarm locally and in the main control room for OPCs. The SAT was the immediately available (preferred) offsite power source and the unit auxiliary transformer back-feed (through the MPT) was the delayed alternate offsite power source. The capability to separate emergency busses from the offsite sources (trip of associated high side switchyard breakers) was installed and tested on all transformers. At the end of the inspection, the system was in the passive monitoring mode for all SATs and MPTs with the intent to remove trip functions based on risk analysis.

INSPECTION RESULTS

Based on discussions with the licensee staff, review of available documentation, and walkdowns of installed equipment, the inspector had reasonable assurance the licensee is appropriately implementing the voluntary industry initiative.

The inspectors identified:

Assessment 2515/194 Detection, Alarms, and General Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) OPCs could be detected and alarmed in the main control room with minimal nuisance alarms experienced to date, and therefore, no reduction in overall plant operation reliability.

The detection circuits were sensitive enough to identify an OPC for all credited loading conditions.

(2) No Class-1E circuits were replaced with non-Class 1E circuits in the design.

(3) The updated final safety analysis report (UFSAR) was updated to discuss the design features and analyses related to the effects of, and protection for, any OPC design vulnerability, reflecting the fact that the trip function was not currently enabled.

Assessment 2515/194 Protective Actions Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) Both units 230 kV SATs and MPTs (back-feed), and associated circuitry were susceptible to an OPC. The licensees OPC design solution added the OPP system manufactured by PCS2000 Solutions to include non-safety related detection and alarm of OPCs and separation (trip) of the SATs and MPTs from offsite source OPCs.

(2) With an OPC present and with or without an accident condition signal, the OPP design would not adversely affect the function of important-to-safety systems, structures, or components. With automatic actuation enabled, loads required to mitigate postulated accidents would transfer to an alternate source to ensure that safety functions were preserved. The credited plant response was unaffected.

(3) Periodic tests, calibrations, and setpoint verifications have not been established for the new protective features. However, Preventive Maintenance Add Request (PMAD) 2137356 was previously initiated to transition switchyard preventive maintenance to the site and includes an assignment to evaluate and determine appropriate periodic testing of OPD systems.

No findings or exceptions were identified.

Observations 2515/194 The OPP trip circuit, although installed, remained disabled during the onsite system implementation inspection. The OPP system was in the passive monitoring mode for all SATs and MPTs with the intent to remove trip functions based on risk analysis. The trip circuit will be permanently removed under engineering changes (EC) 415902 and

EXIT MEETINGS AND DEBRIEFS

On October 10, 2019, the inspector presented the NRC inspection results to Mr. Jay Ratliff and other members of the licensee staff. The inspector verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Calculations BNP-E-4.008 Open Phase Condition 0

Response Time

Drawings F-03001 230KV & 24KV Systems Main 37

One Line Diagram

F-03000 230KV & 24KV Systems Main 40

One Line Diagram

F-03043 230KV, 24KV, & 4160V 41

Systems Key One Line

Diagram

Design Change EC 298348 Unit 1 Open Phase Detection 3&4

Packages System

EC 300946 U1 MPT Installation 3

EC 299563 U2 MPT Installation 3

EC 415902 U1 MPT Trip Defeat 0

EC 415916 U2 SAT Trip Defeat 0

EC 413372 U1 Cyber Security Changes 0

AR 2206699 Open Phase Detection System 0

10CFR50.59 Screen

Miscellaneous LOT-AOP- Licensed Operator Continuing 9

140 Training Simulator Exercise

Guide Sat Phase A Failure

LOI-CLS-LP- 230 KV Electrical Distribution 17A

050

AOI-CLS-LP- 230 KV Electrical Distribution 6

050

SD-50 230 KV Electrical Distribution 24

System

1OI-03.4.3 Unit 1 Turbine Building Deleted

Auxiliary Operator Daily Check

Sheets

PMR-747065 PM Request for SEL Protective

Relay and Clock Batteries

PMR-755683 Preventive Maintenance

Request for U1 MPT

PMR-755687 Preventive Maintenance

Request for U1 SAT

PMAD- PM Add Request with

2137356 Assignment for OPDS

Evaluation

PCHG-DESG PCS Open Phase Detection 06/30/2014

System User Manual

UFSAR Brunswick Nuclear Plant Units 25

and 2, Section 8

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures 1OP-50 Plant Electric System 136

Operating Procedure

2OP-50 Plant Electric System 167

Operating Procedure

1APP-UA-13 Annunciator Procedure for 57

Panel UA-13

0AOP-36.1 Loss of Any 4160 Buses or 79

480V E-Buses

Work Orders WO Implement Open Phase Relay

13413042 Protection EC on U2 SAT

WO Implement Open Phase Relay

13413044 Protection EC on U2 MPT

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