L-19-191, Open Phase Condition Industry Initiative

Open Phase Condition Industry Initiative

ML19302F579
Person / Time
Site:	Davis Besse
Issue date:	10/29/2019
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-19-191
Download: ML19302F579 (2)

Text

FENOC 5501 North State Route 2 Oak Harbor, Ohio 43449 Mark B. Bezilla 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 October 29, 2019 L-19-191 ATIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Open Phase Condition Industry Initiative On March 22, 2016, the Nuclear Energy Institute (NEI) issued a Regulatory Summary Document, "Industry Position on Open Phase Conditions (OPC) in Electronic Power System which Lead to Loss of Safety Functions of both Offsite and Onsite Power Systems (NRC Bulletin 2012-01)" (Accession No. ML16091A099), that addressed the industry's open phase condition (OPC) detection initiative. The document summarized the industry position on the issue, which included the allowance for units with near term permanent shut down plans to provide the Nuclear Regulatory Commission (NRC) staff with alternatives to the industry initiative, if appropriate based on risk considerations.

FirstEnergy Solutions (FES) notified the NRC staff, in a letter dated April 25, 2018 (Accession No. ML18115A007), of its intention to permanently cease power operations at the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1, by May 31, 2020.

FES notified the NRC staff, in a letter dated November 19, 2018 (Accession No. ML18323A346), that the OPC detection equipment will remain in the monitor mode up until the respective shut down date, noting that the OPC equipment would not be placed in the trip mode of operation.

In a letter dated July 26, 2019 (Accession No. ML19207A097), FES formally withdrew its "Certification of Permanent Cessation of Power Operations" for DBNPS. During the transition period to early shutdown, the OPC equipment was not placed in an automatic trip mode. FirstEnergy Nuclear Operating Company (FENOC) requires additional time to implement the OPC detection initiative actions. The purpose of this letter is to notify the NRC staff of changes to the implementation schedule for the OPC detection initiative for DBNPS. Specifically, DBNPS plans to implement the initiative no later than December 31, 2020.

Davis-Besse Nuclear Power Station, Unit No. 1 L-19-191 Page 2 FENOC requires additional time to complete the risk analysis in accordance with NEI 19-02, Rev 0, "Guidance for Assessing Open Phase Condition Implementation Using Risk Insights," dated May 2019, to complete associated procedure changes, and to complete training from the risk analysis insights before implementing. Also, FENOC requires the additional time to ensure a full 24 months of monitoring time on at least one of the DBNPS systems. Based on conditions noted above, FENOC expects to meet the OPC detection initiative actions by December 31, 2020.

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager - FENOC Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.

Sincerely, atlJ~

Mark B. Bez11;/_ A// /

1 ti cc: NRC Region Ill Administrator NRC Resident Inspector - Davis-Besse NRC Project Manager- Davis-Besse Utility Radiological Safety Board