IR 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
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
Procedure
Type
Designation
Description or Title
Revision or
Date
2515/194
Calculations
BNP-E-4.008
Response Time
Drawings
F-03001
230KV & 24KV Systems Main
One Line Diagram
F-03000
230KV & 24KV Systems Main
One Line Diagram
F-03043
230KV, 24KV, & 4160V
Systems Key One Line
Diagram
Design Change
Packages
Unit 1 Open Phase Detection
System
& 4
U1 MPT Installation
U2 MPT Installation
U1 MPT Trip Defeat
U2 SAT Trip Defeat
U1 Cyber Security Changes
Open Phase Detection System
10CFR50.59 Screen
Miscellaneous
LOT-AOP-
140
Licensed Operator Continuing
Training Simulator Exercise
Guide Sat Phase A Failure
LOI-CLS-LP-
050
230 KV Electrical Distribution
17A
AOI-CLS-LP-
050
230 KV Electrical Distribution
SD-50
230 KV Electrical Distribution
System
1OI-03.4.3
Unit 1 Turbine Building
Auxiliary Operator Daily Check
Sheets
Deleted
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-
2137356
PM Add Request with
Assignment for OPDS
Evaluation
PCHG-DESG
PCS Open Phase Detection
System User Manual
06/30/2014
Brunswick Nuclear Plant Units
and 2, Section 8
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Plant Electric System
Operating Procedure
136
Plant Electric System
Operating Procedure
167
Annunciator Procedure for
Panel UA-13
0AOP-36.1
Loss of Any 4160 Buses or
480V E-Buses
Work Orders
Implement Open Phase Relay
Protection EC on U2 SAT
Implement Open Phase Relay
Protection EC on U2 MPT