JAFP-18-0055, Commitment Schedule to Implement NEI Initiative on Open Phase Condition

Commitment Schedule to Implement NEI Initiative on Open Phase Condition

ML18213A016
Person / Time
Site:	FitzPatrick
Issue date:	08/01/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-18-0055, NEI 99-04, SECY-00-0045
Download: ML18213A016 (3)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com NEI 99-04 SECY-00-0045 JAFP-18-0055 August 1, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333

Subject:

Commitment Schedule to Implement NEI Initiative on Open Phase Condition

References:

1. U.S. Nuclear Regulatory Commission Letter, Design Vulnerability in Electric Power System, NRC Bulletin 2012-01, dated July 12, 2012 (ML12074A115}

2. Entergy Letter to U.S. Nuclear Regulatory Commission Relating to Response to Request for Additional Information for Bulletin 2012-01, dated February 3, 2014 (ML14034A362, JAFP-14-0011}

3. Nuclear Energy Institute Letter to U.S. Nuclear Regulatory Commission, Industry Initiative on Open Phase Condition, Revision 1, dated March 16, 2015 (ML15075A454}

In response to NRC Bulletin 2012-01, Reference 1, the Nuclear Entergy Institute (NEI) organized an industry initiative to address the identified design vulnerability. The industry Open Phase Condition (OPC) initiative, Reference 3, identified several actions that licensees should complete by December 31, 2018. The purpose of this letter is to notify the NRC of changes to the implementation schedule for the OPC Initiative actions for James A. FitzPatrick Nuclear Power Plant (JAF). Specifically, JAF plans to defer the implementation from December 31, 2018, until December 31, 2020.

On February 3, 2014 (Reference 2), JAF discussed the progress toward implementing the OPC initiative actions in a response to an NRC request for additional information. JAF was on track for implementing an Entergy designed Open Phase Detection solution until plant closure was announced by Entergy in November 2015; at which time the project was cancelled. With the sale and transfer of the facility operating license from Entergy to Exelon on April 1, 2017, the plans changed to continue operating the plant and the OPC project was reinstituted.

The Exelon solution for Open Phase Detection for JAF is a different approach than the Entergy solution for JAF and requires additional time to prepare the engineering change package, procure the materials, implement the change, and execute the monitoring period before

U.S. Nuclear Regulatory Commission Open Phase Condition Commitment Revision Docket No. 50-333 August 1, 2018 Page2 completing implementation. Based on the plan to implement this solution, JAF expects to meet the OPC initiative actions by December 31, 2020.

In response to INPO Event Report (IER) L2-12-14, actions to support JAF's ability to monitor for a 115 kV Open Phase condition were established. This implementation schedule change does not change how those compensatory measures ensure that applicable systems, structures, and components are capable of performing their safety functions.

There is no change to JAF's implementation of the OPC initiative other than a schedule deferral based on the reasons described above. A summary of the regulatory commitment described in this letter may be found in the Attachment to this letter.

If you have any questions regarding this submittal, please contact Christian Williams at (610) 765-5729.

Respectfully, James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Summary of Regulatory Commitments cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRA - James A. FitzPatrick Nuclear Power Plant A.L. Peterson, NYSERDA B. Frymire, NYSPSC

Attachment Open Phase Condition Commitment Revision Docket No. 50-333 Page 1 of 1

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE*TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No) (Yes/No)

FitzPatrick will implement the NEI 12/31/2020 Yes No Open Phase Condition Initiative actions as described in the "Schedule for Operating Plants - Dec. 31, 2018" section of the Attachment to the NEI letter dated March 16, 2015 (ML15075A454), by December 31, 2020.