IR 05000333/2021012
| ML21124A028 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/04/2021 |
| From: | Glenn Dentel NRC Region 1 |
| To: | Rhoades D Exelon Generation Co |
| Shared Package | |
| ML21125A125 | List: |
| References | |
| IR 2021012 | |
| Download: ML21124A028 (9) | |
Text
May 4, 2021
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - TEMPORARY INSTRUCTION 2515/194 INSPECTION REPORT 05000333/2021012
Dear Mr. Rhoades:
On April 20, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Mr.
Pat Navin, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, X
/RA/
Signed by: Glenn T. Dentel
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number:
05000333
License Number:
Report Number:
Enterprise Identifier: I-2021-012-0005
Licensee:
Exelon Nuclear
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
April 12, 2021 to April 20, 2021
Inspectors:
C. Hobbs, Reactor Inspector
D. Werkheiser, Senior Reactor Analyst
Approved By:
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction 2515/194 Inspection at James A.
FitzPatrick Nuclear Power 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 or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
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)
The inspectors reviewed the licensees implementation of the Nuclear Energy Institute Voluntary Industry Initiative on Open Phase Condition, (ADAMS Accession No. ML19163A176)dated June 6, 2019. This included reviewing how the licensee updated their licensing basis to reflect the need to protect against open phase conditions.
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)
- (1) Exelon selected the Open Phase Condition (OPC) detection system designed and manufactured by Schweitzer Engineering Laboratories (SEL) for use at James A.
FitzPatrick Nuclear Power Plant. The offsite power distribution system at FitzPatrick is described below.
FitzPatrick has two 115 kV independent offsite power sources, Line 3 and Line 4.
Line 3 is supplied from the Lighthouse Hill substation, while Line 4 is supplied from the South Oswego substation through the Nine Mile Point Unit 1 switchyard. 115 kV power is then supplied to circuit breakers 10022 and 10012, which then supply power to Reserve Station Service Transformers T-2, and T-3. Power is then supplied to the non-safety related 4 kV buses 10400 and 10300. The safety related 4 kV emergency buses are 10600 and 10500, which are supplied power from 10400 and 10300 from circuit breakers 10404 and 10304. OPC detection is provided in 4 locations: at the 115 kV circuit breakers 10022 and 10012, and at the Reserve Station Service Transformers, T-2 and T-3.
In lieu of automatic OPC protective actions, FitzPatrick implemented an alarm only strategy, which relies on proper operator actions to diagnose and respond to an Open Phase Condition. At the end of this inspection, the SEL relays for OPC were monitoring the associated power sources and would provide main control room annunciation if a loss of one or two phases of power was detected, or if an OPC relay was non-functional. In addition, actuation of an OPC relay will also be indicated on alarms in the plant process computer.
INSPECTION RESULTS
Observation: Temporary Instruction 2515/194 - Section 03.01(a) and
- (c) Results 2515/194 Based on discussions with Exelon staff, review of design and testing documentation, and walkdowns of installed equipment, the inspectors had reasonable assurance that FitzPatrick Nuclear Station is implementing the guidance specified in the NEI Voluntary Industry Initiative on Open Phase Condition. The inspectors verified the following criteria:
Detection, Alarms and General Criteria
1. [03.01(a)(1)] OPCs are detected and alarmed in the control room.
2. [03.01(a)(2)] In scenarios where automatic detection may not be possible due to very
low or no load conditions, or when transformers are in a standby mode, detection will occur as soon as loads are transferred to the standby source. Additionally, where detection is not reliable, Exelon has established monitoring requirements on a per shift basis, to look for evidence of an OPC.
3. [03.01(a)(3)] The OPC design and protective schemes minimize misoperation or
spurious action in the range of voltage unbalance normally expected in the transmission system that could cause separation from an operable off-site power source. Additionally, Exelon has demonstrated that the actuation circuit design does not result in lower overall plant operation reliability.
4. [03.01(a)(4)] No Class-1E circuits were replaced with non-Class-1E circuits in this
design.
5. [03.01(a)(5)] The Updated Final Safety Analysis Report was updated to discuss the
design features and analyses related to the effects of any OPC design vulnerability.
6. [03.01(a)(6)] - Open Phase Isolation System (OPIS) detection and alarm components
are maintained in accordance with station procedures or maintenance program, and periodic tests, calibrations, setpoint verifications, or inspections (as applicable) have been established.
Use of Risk-Informed Evaluation Method
1. [03.01(c)(1)] The plant configuration matched the Probabilistic Risk Assessment
(PRA) model to address an OPC, and the logic of the PRA model is sound.
2. [03.01(c)(2)] The procedures which validate that an OPC alarm would identify the
proper indication to validate the OPC at all possible locations.
3. [03.01(c)(3)] Observations associated with procedures and operator actions required
to respond to an OPC alarm and potential equipment trip match the Human Reliability Analysis (HRA).
4. [03.01(c)(4)] Sensitivity analyses used in the FitzPatrick PRA analysis for using
Operator Manual Actions (OMAs) in leu of OPC automatic protective relay actuation, did not exceed the thresholds defined in the NEI 19-02 guidance document for delta Core Damage Frequency (CDF) or delta Large Early Release Frequency (LERF).
5. [03.01(c)(5)] Assumptions, procedures, and operator actions specified in the
FitzPatrick NEI 19-02 analysis are consistent with the plant-specific design and licensing basis, including:
- (a) Initiating events considered in the analysis.
- (b) Boundary conditions specified in Attachment 1 of the NEI Voluntary Industry Initiative, Revision 3.
- (c) Operating procedures for steps taken to recover equipment assumed tripped, locked out, or damaged due to an OPC.
- (d) Where recovery was assumed in the PRA analysis for tripped electric equipment, restoration of the equipment was based on analyses that demonstrate that automatic isolation trips did not result in equipment damage.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 20, 2021, the inspectors presented the Temporary Instruction 2515/194 inspection results to Mr. Pat Navin, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2515/194
Calculations
JAF-CALC-17-
00093
Offsite Power Open Phase EMTP Analysis
Revision 1
JAF-CALC-19-
00010
James A. FitzPatrick Open Phase Backfeed Analysis
Revision 0
Corrective Action
Documents
4190109,
298887
Corrective Action
Documents
Resulting from
Inspection
4416808,
4416820,
4416854,
4416942
Reserve Station Service Transformer Outline
Revision 1
Window Arrangement and Engraving Legends for
Annunciator Panel 09-8-5
Revision 14
Elementary Wiring Diagram - Interposing Relay System,
Sheet 16
Revision 6
Outline & Equipment Arrangement 71OPD-1 Relay Panel
Revision 1
Outline & Equipment Arrangement 71OPD-2 Relay Panel
Revision 1
Elementary Writing Diagram - 115kV RSST 71T-2 Open
Phase Detection
Revision 1
Elementary Writing Diagram - 115kV RSST 71T-3 Open
Phase Detection
Revision 1
Main One Line Diagram, Station Service Transformers,
Sheet 2
Revision 19
Main One Line Diagram, 115 kV Switchyard, Sheet 4
Revision 12
Engineering
Changes
Open Phase Detection on Offsite Feed to RSSTs 71T-2 and
71T-3 (SEL-487 Relays)
Revision 1
Open Phase Detection on Offsite Feed to 71BRK-10012 and
71BRK-10022 (SEL-421-Relays)
Revision 1
Engineering
Evaluations
James A. FitzPatrick Nuclear Power Plant Open Phase
Condition Evaluation
Revision 0
Miscellaneous
UFSAR change number FSAR-20-002
dated 4/9/20
Presentation
Open Phase NEI 19-02 Audit, James A. FitzPatrick
dated
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4/12/21
Procedures
115 kV Grid Loss, Instability, or Degradation
Revision 14
Bus 10300 Reserve Supply Breaker 10312 Trip
Revision 3
Bus 10400 Reserve Supply Breaker 10412 Trip
Revision 4
115 kV Line 3/Line 4 or RSS XSFMR T-2/T-3 Open Phase
Revision 3
115 kV System
Revision 28