ML19240A829
| ML19240A829 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/28/2019 |
| From: | Christopher Even NRC/RGN-II |
| To: | Kharrl C Southern Nuclear Operating Co |
| Reeder D | |
| References | |
| IR 2019012 | |
| Download: ML19240A829 (12) | |
Text
August 28, 2019 Mr. Charles Kharrl Site Vice President Southern Nuclear Operating Co., Inc.
7388 North State Highway 95 Columbia, AL 36319
SUBJECT:
JOSEPH M. FARLEY NUCLEAR POWER 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) STAND-ALONE INSPECTION REPORT 05000348/2019012 & 05000364/2019012
Dear Mr. Kharrl:
On June 27, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Power Plant and discussed the results of this inspection with Mr. D. Komm, Plant Manger, and other members of your staff. Based upon additional information after the initial exit date, a re-exit was completed July 22, 2019 with Mr. Gene Surber, Licensing Manager. The results of this inspection are documented in the enclosed report.
The NRC inspectors 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/
Christopher Even, Acting Chief Construction Inspection Branch 2 Division of Construction Oversight Docket Nos.: 05000348 / 05000364 License No.: NPF-2 / NPF-8
Enclosure:
Inspection Report 05000348/2019012 & 05000364/2019012 w/
Attachment:
TI 2515/194 Inspection Documentation Request cc w/ encl: Distribution via Listserv
C. Kharrl 2
SUBJECT:
JOSEPH M. FARLEY NUCLEAR POWER PLANT - NRC TEMPORARY INSTRUCTION 2515/194 INSPECTION REPORT 05000348/2019012 &
05000364/2019012 DISTRIBUTION:
M. Kowal, RII S. Price, RII OE Mail RIDSNRRDIRS PUBLIC ADAMS Accession Number: ML19240A829 OFFICE RII/DCO RII/DCO RII/DCO NAME GCrespo CStancil CEven DATE 8/27/2019 7/30/2019 8/27/2019 OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000348 / 05000364 License Number: NPF-2 and NPF-8 Report Numbers: 05000348/2019012 and 05000364/2019012 Enterprise Identifier: I-2019-012-0014 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley Nuclear Plant, Units 1 and 2 Location: Columbia, AL Inspection Dates: June 24 to June 27, 2019 Inspectors: G. Crespo, Sr. Construction Inspector C. Stancil, Sr. Resident Inspector Approved By: Christopher Even, Acting Chief Construction Inspection Branch 2 Division of Construction Oversight Enclosure
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 Joseph M. Farley 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 were identified.
Additional Tracking Items None.
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INSPECTION SCOPE This inspection was conducted using Temporary Instruction 2515/194 (ADAMS Accession No. ML17137A416), dated October 31, 2017. The inspectors 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 OPC system design and ongoing implementation plans with plant staff. The inspectors reviewed licensee documentation, vendor documentation, and performed system walkdowns to verify that the installed equipment was supported by the design documentation.
The inspectors verified that the licensee had completed the installation and testing of equipment, installed and tested alarming 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 OPCs.
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)
Temporary Instruction 2515/194-03.01 - VII (Part 1)
Joseph M. Farley Nuclear Power Plant selected the open phase detection system designed and manufactured by Power System Sentinel Technologies, LLC. At the end of this inspection, the system was not in the monitoring mode. The OPC system was awaiting repairs and evaluation of operation settings by the manufacturer/installer prior to placing the system back into monitoring mode annunciating in the Main Control Rooms. The equipment was installed on the start-up transformers (SAT-1A, SAT-1B, SAT-2A and SAT-2B). The licensees schedule to transition the open phase detection system to full implementation (tripping functions enabled) has not yet been defined.
INSPECTION RESULTS - OBSERVATIONS Based on discussions with the licensee staff, review of available documentation, and walkdowns of installed equipment, the inspectors 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) 3
(1) OPCs could be detected in some of the system cabinets but additional adjustments were needed to reliably detect the OPC and avoid repeated nuisance alarms. Nuisance alarms resulted in the annunciator signals being blocked by operators for long periods of time. The transformer panel alarm modules must be unblocked (removed from the off position) to allow open phase indications to be alarmed on the main control room annunciator panels.
(2) Detection circuits will be sensitive enough to identify an open phase condition for all credited loading conditions for installed equipment.
(3) No Class-1E circuits were being replaced with non-Class 1E circuits in the design.
(4) The updated final safety analysis report (UFSAR) has been updated to discuss the design features and analyses related to the effects of, and protection for, any OPC design vulnerability for the monitoring function. However, the proposed trip function had not been enabled, but draft UFSAR changes had been prepared.
Assessment 2515/194 Protective Actions Criteria; TI 2515/194-03.01 - VII (Part 1)
(1) Four transformers were susceptible to an open phase condition and the licensee had installed detection and mitigating equipment on all four.
(2) With an open phase condition present and with or without an accident condition signal, the open phase design would not adversely affect the function of important-to-safety systems, structures, or components. The licensees open phase condition design solution added two Power System Sentinel Technologies, LLC system channels on each start-up transformer SAT-1A, SAT-1B, SAT-2A and SAT-2B. The trip function, when enabled, will provide an additional input to the associated transformer lockout relays. The credited plant response is unaffected and will be the same regardless of the conditions that generated the lockout of the transformer.
No findings were identified.
The inspectors identified the following exceptions to the Temporary Instruction criteria resulting from the operating status of the design modifications:
Assessment 2515/194 Detection, Alarms, and General Criteria Exceptions; TI 2515/194-03.01 - VII (Part 1)
(1) The licensees OPC protection system could operate in the monitoring mode with calculated setpoints while gathering data to ensure the OPC design and protective schemes would minimize mis-operations, or spurious actions in the range of voltage imbalance normally expected in the transmission system. However, any monitoring alarms transmitted to the main control room were blocked at the transformer summary alarm panels located in the transformer yard due to numerous and repeated alarm signals coming from the Open Phase Detection panels.
(2) The inspectors identified several exceptions that were presented to the licensees staff concerning existing conditions/alarms in the open phase protection (OPP) systems for all four 4
SAT transformers. These conditions prevented the open phase protection system from annunciating in the main control room for both Unit 1 & Unit 2. In addition, there were no routine operator rounds nor administrative compensatory measures required for the OPP panels. These concerns were placed into the licensees corrective action program with the following condition reports:
- 1. CR 10623313: SAT 1A - OPP Channel 1 had a 50nDT neutral overcurrent alarm.
Neutral current indicated 137.2 amps. Channel 2 indicated 0.8 amp for the same cable.
- 2. CR 10623322: SAT 1B - OPP Injection Abnormal current persisted after the March 2019 adjustment by PSSTech under previous CR 10508305.
- 3. CR 10623525: Two qualified system operators performing rounds were not familiar with OPP administrative tracking item (ATI) to perform daily OPP alarm checks, while local transformer alarm modules were in the off position (cutout, main control room notification blocked). ATI was updated per CR 10623717 below.
- 4. CR 10623755: Units 1 & 2 Operator rounds were not updated to include routine checks for open phase detection system. The licensees original plan was pending the implementation of the OPP trip functions. This CR requests operator checks of the OPP prior to the trip function being enabled.
- 5. CR 10623717: Unit 1 ATI #216 was in place for monitoring transformer conditions associated with cutout alarm window D8, SU 1A Low Oil Level, but did not have an action to check the OPP panels. The ATI was updated to add the OPP checks.
Assessment 2515/194 Protective Actions Criteria Exceptions; TI 2515/194-03.01 - VII (Part 1)
(1) The licensees open phase condition design solution uses Power System Sentinel Technologies, LLC to detect, alarm, and provide an input to the associated Start-up Auxiliary Transformer (SAT) lockout relays. Upon transformer lockout, the existing undervoltage relays would operate as designed to initiate starting of the emergency diesel generator to restore power to the bus. These open phase protection systems were installed under design change packages DCP SNC679759 for SAT-1A, DCP SNC679760 for SAT-1B, DCP SNC679761 for SAT-2A, and DCP SNC679762 for SAT-2B.
The trip function input to the transformer lockout relays remained deactivated during the onsite system implementation inspection and was not able to be demonstrated to perform the designed function. The OPP trip circuit was installed; however, this trip function will remain disabled until sliding links are closed under design change packages DCP SNC900664 for SAT-1A and SAT-1B, and DCP SNC900665 for SAT-2A and SAT-2B.
Due to the configuration of the Farley Nuclear Power Plants electrical distribution system, a loss of phase on one transformer would only affect one train of equipment, and loads required 5
to mitigate postulated accidents would be available on the non-affected train, ensuring that safety functions are preserved as required by the current licensing bases.
(2) As of this inspection, periodic tests, calibrations, setpoint verifications or inspections (as applicable) had not been established for any new protective features. There are no changes to the surveillance requirements for the plant Technical Specifications (TSs) in compliance with the provisions of 10 CFR 50.36.
No findings were identified.
The inspectors identified the following observations:
Observation 2515/194 Inspectors identified conditions that do not deal directly with the protection functions of the OPP system include:
- 1. CR 10623319: SAT 1A OPP Channel 2 had high Temp Alarm. The air conditioning unit associated with this OPP cabinet was not operating.
- 2. CR 10623325: Unit 2 Low Voltage Switchyard alarm panel deficiencies, which included door hinge failing, door latch missing hardware, and 2A SAT label missing its respective alarm module grouping.
- 3. CR 10623348: The SAT 2B neutral conductor wire was not properly restrained, and therefore, sagging between the cooling fans and the transformer, potentially touching the transformer cooling fins and radiator fan.
- 4. CR 10623516/10623521: Procedure FNP-1(2)-ARP-5.0 required a revision for alarm windows C8 and D8 to add information/actions erroneously provided for windows C12 and D12. OPP field wiring is appropriately installed for windows C8 and D8 as evidenced by alarm testing witnessed by the inspectors.
EXIT MEETINGS AND DEBRIEFS On July 22, 2019, the inspector presented the NRC inspection results to Mr. D. Komm, Plant Manager, and other members of the licensee staff. Based upon additional in-office review after the initial exit date, a re-exit was completed via telephone on July 22, 2019 with Mr. Gene Surber, Licensing Manager. The inspectors verified no proprietary information was retained or documented in this report.
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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 2515/194 Calculations SNC 900664J004 Farley Unit 1 Farley Nuclear Power Plant Open Phase 01 Detection System PSSTech Setpoints and System Results Calculation (MPR-2380-0024-CALC-004 Farley Nuclear Power Plant Open Phase Detection System Results Calculation)
Condition Report CR 10623313 SAT 1A - OPP Channel 1 has a 50nDT neutral overcurrent 6/25/2019 alarm. (NRC identified)
CR 10623322 SAT-1B - OPP Injection Abnormal (NRC identified) 6/25/2019 CR 10623525 SO Performing operator rounds was not familiar with the 6/25/2019 Admin Tracking Item (ATI) associated with OPP nor the required checks per ATI. (NRC identified)
CR 10623755 Unit 1 and Unit 2 Operator rounds are not updated to include 6/26/2019 checks of open phase panels. There is currently no formal tracking mechanism in place to ensure they are updated.
(NRC identified)
CR 10623717 Unit 1 ATI Administrative Tracking Item 216 was in place for 6/26/2019 tracking and monitoring for OPP panels for Alarm (D8) SU 1A Low Oil Level did not have action to check OPP panel.
ATI updated to add OPP. (NRC identified)
CR 10623319 SAT 1A - OPP Channel 2 has high Temp Alarm. (NRC 6/25/2019 identified)
CR 10623325 Unit 2 Low Voltage Switchyard alarm panel deficiencies, 6/25/2019 which included door hinge failing, door latch missing hardware, and 2A SAT label missing from the top of alarm column. (NRC identified)
CR 10623348 SAT-2B Neutral cable is sagging. (NRC identified) 6/25/2019 CR 10623516 Procedure FNP-1(2)-ARP-5.0 needs change for window C8 6/25/2019
/10623521 and D8 for information provided for windows C12 and D12.
The panels in the field have OPP in windows C8 and D8.
(NRC identified > 1 year since licensee identified with no action) 7
Inspection Type Designation Description or Title Revision or Procedure Date Drawings D-172784 Farley Unit 1 - ELEM. DIAG. - Generator and Transformer 4.0 Auxiliary Relays D-172852 Farley Unit 1 - Elementary Diagram - Start-UP Auxiliary 12.0 Transformer 1A & 1B Controls D-172962 Farley Unit 1 - Wiring Diagram - Local Annunciator Cabinet 4.0 Unit & Start-Up Auxiliary Transformer.
D-202784 Farley Unit 2 - ELEM. DIAG. Generator and Transformer 9.0 Auxiliary Relay.
D-202852 Farley Unit 2 - Elementary Diagram - Start-UP Auxiliary 9.0 Transformer 2A & 2B Controls D-356870 Farley Unit 1 - Connection Diagram Open Phase Protection 1.0 (OPP) Panel N1R11NO501 D-356877 Farley Unit 2 - Connection Diagram Open Phase Protection 1.0 (OPP) Panel N2R11NO501 U-736629 Farley Unit 1 - OPEN PHASE PROTECTION (OPP) 2.0 SYSTEM, ELECTRICAL DRAWINGS, CHANNEL 1 &
CHANNEL 2 (18 pages)
U-736630 Farley Unit 1 - OPEN PHASE PROTECTION (OPP) 2.0 SYSTEM, Panel Physical & Layout (8 pages)
U-736670 OPEN PHASE PROTECTION (OPP) SYSTEM, NON- 1.0 CLASS 1E OPP PROTECTION SETTINGS, STARTUP AUXILIARY TRANSFORMER FARLEY 1A,2A,1B AND 2B D-172700 Farley Unit 1 - Main Single Line Diagram Generator & 4160 21.0 Volt Transformer D-177000 Farley Unit 1 - Single Line - Electrical Auxiliary System 33.0 (Normal - 4160V & 600V)
D-177001 Farley Unit 1 - Single Line - Electrical Auxiliary System 23.0 (Emergency - 4160V & 600V)
D-202700 Farley Unit 2 - Main Single Line Diagram Generator & 4160 21.0 Volt Transformer D-207000 Farley Unit 2 - Single Line - Electrical Auxiliary System 26.0 (Normal - 4160V & 600V)
D-207001 Farley Unit 2 - Single Line - Electrical Auxiliary System 22.0 (Emergency - 4160V & 600V) 8
Inspection Type Designation Description or Title Revision or Procedure Date D-356872 Farley Unit 2 - Block Diagram of OPP System Startup XFMR 1.0 2A (N2R11N0501) Sheet 1 of 2 D-356872 Farley Unit 2 - Block Diagram of OPP System Startup XFMR 1.0 2B (N2R11N0501) Sheet 2 of 2 D-513698 Farley Unit 1 - Block Diagram of OPP System Startup XFMR 1.0 1B (N1R11N0502) Sheet 2 of 2 D-513698 Farley Unit 1 - Block Diagram of OPP System Startup XFMR 1.0 1A (N1R11N0502) Sheet 1 of 2 D-207009 Farley Unit 2 - Single Line Protection and Metering 600V 1.0 Load Center 2C D-207007 Farley Unit 2 - Single Line Protection and Metering 600V 1.0 Load Center 2A D-177009 Farley Unit 1 - Single Line Protection and Metering 600V 1.0 Load Center 1C Design Change SNC900664 (Trip Installation and functionally test Phase 1 of the OPP System 2 Packages Function) panels for SAT-1A and SAT-1B SNC900665 (Trip Installation and functionally test Phase 1 of the OPP System 2 Function) panels for SAT-2A and SAT-2B SNC679759 Installation, Testing, and Commissioning of the OPP system 2.0 for the Startup Auxiliary Transformer 1A Miscellaneous FNP-FSAR Section 8.2.1.3 Offsite Power Supply to Plant (page 8.2-3) 29 FNP-FSAR Section 8.2.1.3 Offsite Power Supply to Plant (page 8.2-3), 28, (proposed) with trip function enabled October/2018 Tech Spec Table 3.3.5-2 Loss of Power Diesel Generator Start Amend 206 Instrumentation Unit 1 Amend 202 Unit 2 SNC900665E205 Open Phase Protection (OPP) System, Non-Class 1E OPP 2 Protection Settings, Startup Auxiliary Transformer Farley 1A, 2A, 1B, and 2B Procedures FNP-1-ARP-1.12 Main Control Board Annunciator Panel M 71 9
Inspection Type Designation Description or Title Revision or Procedure Date FNP-1-ARP-5.0 Annunciator Response Procedure / Unit/Start-up 13 Transformer Miscellaneous Alarm Panel FNP-1-SOP-36.1 Startup, Unit Auxiliary, and Main Transformers Preparation 38.4 for Operation FNP-2-ARP-1.12 Main Control Board Annunciator Panel M 50.1 FNP-2-ARP-5.0 Unit Aux/Start-up Transformers Miscellaneous Alarm Panel 10.1 Work Orders 20139791 01 EL, EC 407016, SUT-A, SUT OPEN PHASE FAULT DET & 08/31/2017 PROTECTION 10