IR 05000334/2020010

Reissued Temporary Instruction 2515/194 Inspection Report 05000334/2020010 and 05000412/2020010

ML20077J473
Person / Time
Site:	Beaver Valley
Issue date:	03/16/2020
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Penfield R Energy Harbor Nuclear Corp
Dentel G
References
IR 2020010
Download: ML20077J473 (9)

Text

March 16, 2020

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - REISSUED TEMPORARY INSTRUCTION 2515/194 INSPECTION REPORT 05000334/2020010 AND 05000412/2020010

Dear Mr. Penfield:

The U.S. Nuclear Regulatory Commission (NRC) identified one factual error in NRC Temporary Instruction 2515/194 Inspection Report 05000334/2020010 and 05000412/2020010, dated February 24, 2020 (ADAMS Accession No. ML20058D181). In the Protective Actions Criteria, the number of PSSTech systems added to each system station service transformer was stated incorrectly, and has been changed from two to one. As a result, the NRC has reissued the report in its entirety to correct the error.

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 Reactor Safety Docket Nos. 05000334 and 05000412 License Nos. DPR-66 and NPF-73

Enclosure:

Inspection Report 05000334/2020010 and 05000412/2020010

Inspection Report

Docket Numbers: 05000334 and 05000412 License Numbers: DPR-66 and NPF-73 Report Numbers: 05000334/2020010 and 05000412/2020010 Enterprise Identifier: I-2020-010-0010 Licensee: Energy Harbor Nuclear Corp.

Facility: Beaver Valley Power Station Location: Shippingport, PA Inspection Dates: January 27, 2020 to January 31, 2020 Inspectors: L. Dumont, Reactor Inspector C. Hobbs, Reactor Inspector Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting Temporary Instruction 2515/194 at Beaver Valley Power Station,

Units 1 and 2 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

The inspection was conducted using Temporary Instruction 2515/194 (ADAMS Accession No. ML17137A416), effective November 1, 2017. The inspectors reviewed the licensees implementation of the Nuclear Energy Institutes voluntary industry initiative in compliance with Commission guidance. The inspectors discussed Beaver Valleys open phase condition system design and ongoing implementation plans with plant staff. The inspectors reviewed licensee and vendor documentation, and performed system walkdowns to verify that the installed equipment was supported by the design documentation. Beaver Valley had recently completed physical installation and the equipment was being operated in a monitoring mode with the trip functions disabled.

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, (ADAMS Accession No. ML15075A454) dated March 16, 2015. 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) The licensee selected the open phase detection system designed and manufactured by Power System Sentinel Technologies, LLC, as the design vendor for the open phase condition system at Beaver Valley Power Station. The open phase protection system is designed to protect the offsite power sources from a loss of phase condition.

The offsite electrical distribution system is functionally the same for both Beaver Valley Unit 1 and Unit 2. Two general design criteria (GDC-17) offsite power sources are credited for each unit. At each unit offsite power is provided by two independent system station service transformers (SSSTs), each powered from a different bus of the 138 kV switchyard to supply reliable power to two safety-related 4kV buses for each Beaver Valley unit. The 138 kV connections between the switchyard buses and the SSSTs are made with overhead lines having separate towers for each line. At the time of the inspection the active trip feature of the open phase detection systems installed at Beaver Valley was not enabled for either unit.

INSPECTION RESULTS

Temporary Instruction 2515/194-03.01 - Voluntary Industry Initiative 2515/194 Detection, Alarms, and General Criteria 1. 03.01(a)(1) OPC are detected and alarmed in the control room for Unit 1 and 2.

2. 03.01(a)(2) Detection circuits are sensitive enough to identify an OPC for credited loading conditions (i.e., high and low loading).

3. 03.01(a)(3) 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. In the design of the OPC system, multiple features have been added to prevent spurious trips of the system. The licensee 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 during installation of the open phase detection system.

Protective Actions Criteria 1. 03.01(b)(1) Two SSSTs at both Unit 1 and Unit 2 were identified as susceptible to an open phase condition and the licensee has implemented design changes on all four transformers to mitigate the effects.

2. 03.01(b)(2) With an open phase condition present and no accident condition signal, the open phase design would not adversely affect the function of important-to-safety systems, structures, or components. The licensees OPC design solution added one PSSTech system on each SSST, TR-1A, TR-1B, TR-2A, and TR-2B. The credited plant response was unaffected and would be the same regardless of the conditions that generated the lockout of the transformer.

Detection, Alarms, and General Criteria Exceptions 2515/194 03.01(a)(5) The Beaver Valley Unit 1 UFSAR has been updated to discuss the design features of the open phase condition detection system. However, the Unit 2 UFSAR was not updated at the time of the inspection. This has been noted in CR-2020-00263 and as part of the self-assessment conducted prior to the start of the inspection under SA-BN-2020-1796. The licensee provided to the inspectors the proposed changes to the licensing basis that discussed the system requirements related to the effects of, and protection for, any open phase condition design vulnerability.

Protective Actions Exceptions 2515/194 03.01(b)(3) Inspectors determined that with an open phase condition and an accident condition signal present, the open phase detection system would not adversely affect the function of the load shedding and sequencing system to provide a means of disconnecting and sequencing of loads on the safety related buses. The open phase protection trip circuit was installed; however, this trip function will remain disabled until cessation of plant operations. The licensee issued a letter, dated November 19, 2018, to inform the NRC that based on the previously announced near-term plant shut downs, Beaver Valleys OPC detection equipment will remain in the monitor mode up until the respective shut down dates for each site. As such, the OPC equipment on both units were not placed in the trip mode of operation.

03.01(b)(4) The licensee had not established documentation for periodic tests, calibrations, setpoint verifications, or inspection procedures associated with the PSS Tech equipment.

This action was being tracked in their corrective action program (CR-2020-00586) and was identified as part of the self-assessment conducted prior to the start of the inspection under SA-BN-2020-1796.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 30, 2020, the inspectors presented the Temporary Instruction 2515/194 inspection results to Mark Manoleras and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Corrective Action CR-2020-00263

Documents CR-2020-00585

CR-2020-00586

Corrective Action CR-2020-00708

Documents CR-2020-00732

Resulting from

Inspection

Drawings RE-0001C Beaver Valley Power Station Unit 2 Equipment One Line 15

Diagram

RE-0001C Beaver Valley Power Station Unit 1 Equipment One Line 32

Diagram

Engineering ECP 15-0060-000 Unit 2 Open Phase Detection System Reference Documents 5/31/2018

Changes ECP-15-0059- Unit 1 Open Phase Detection System Reference Documents 11/30/2015

000

ECP-18-0156- Unit 1 Main Transformer Leads Protection Replacement 4/18/2019

000

Miscellaneous Open Phase Protection (OPP) System Factory Acceptance 5/18/2016

Test (FAT) Plan for FENOC

Open Phase Protection (OPP) System Site Acceptance Test 8/3/2016

Procedure for Single Channel System

Open Phase Protection (OPP) System Procedure for OPP 12/5/2018

System Online Commissioning

PSSTech OPD System Enhanced Test Execution, Results 0

and Conclusions

Shiftly readings of SSST Secondary Phase Voltages 1/26/2020

and

1/27/2020

Daily SSST 1A High line Drop Inspection 1/26/2020

and

1/27/2020

PSSTech Open Phase Protection (OPP) System Preventive 0.0.1

Maintenance Guide

Inspection Type Designation Description or Title Revision or

Procedure Date

L-18-219 First Energy Solutions letter to NRC announcing intent to 11/19/2018

leave OPC systems in monitoring mode until plant closures

in 2021.

Procedures 1OM-36.4.AFY SS Service Transformer 1B Open Phase Alarm 1

1OM-36.4.AFZ SS Service Transformer 1A Open Phase Alarm 0

1OM-54.3.OUT1 Beaver Valley Unit 1 Outside Log Readings 71

2OM-36.4.AFK SS Service Transformer 2A Open Phase Alarm 0

2OM-36.4.AFK SS Serv Tfmr Open Phase Alarm 1

2OM-36.4.AFL SS Service Transformer 2B Open Phase Alarm 1

Self-Assessments SA-BN-2020- BVPS self assessment for TI-194 Open Phase Condition 1/24/2020

1796 inspection

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