IR 05000250/2019013

NRC Temporary Instruction 2515/194 Inspection Report 05000250/2019013 and 05000251/2019013

ML19296B727
Person / Time
Site:	Turkey Point
Issue date:	10/22/2019
From:	Steven Rose NRC/RGN-II
To:	Moul D Florida Power & Light Co
Archer L
References
IR 2019013
Download: ML19296B727 (10)

Text

ber 22, 2019

SUBJECT:

TURKEY POINT NUCLEAR GENERATING STATION, UNITS 3 AND 4 - NRC TEMPORARY INSTRUCTION 2515/194 INSPECTION REPORT 05000250/2019013 AND 05000251/2019013

Dear Mr. Moul:

On September 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Nuclear Generating Station, Units 3 and 4 and discussed the results of this inspection with Mr. B. Stamp, Site Director, and other members of your staff.

The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation 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, Requests for Withholding.

Sincerely,

/RA/

Steven D. Rose, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket No.: 50-250 and 50-251 License No.: DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2019013 and 05000251/2019013

Inspection Report

Docket Number: 50-250 and 50-251 License Number: DPR-31 and DPR-41 Report Number: 05000250/2019013 and 05000251/2019013 Enterprise Identifier: I-2019-013-0009 Licensee: Florida Power & Light Company (FPL)

Facility: Turkey Point Nuclear Generating Station, Units 3 and 4 Location: 9760 SW 344th Street Homestead, FL 33035 Inspection Dates: September 23, 2019 to September 26, 2019 Inspectors: G. Crespo, Sr. Construction Inspector Approved By: Steven D. Rose, 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 Turkey Point Nuclear Generating Station, Units 3 and 4, 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.

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 Commission guidance. The inspector discussed the licensees open phase condition 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. These reviews were also made to determine if the licensee had completed the installation and testing of equipment, installed and tested alarming circuits both local and in the control room, and analyzed potential impacts associated with the design implementation on the current licensing basis. The inspectors reviewed the status of indication lamps in the front of the individual system cabinets to verify the status of the system tripping functions. These tripping functions of the system had not been activated or wired to date pending resolution of decision if to activate the function.

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 open phase conditions.

Temporary Instruction 2515/194-03.01 - VII (Part 1)

Turkey Point Nuclear Generating Station, Units 3 and 4 selected General Electric Energy Connections - ALSTOM, as the open phase detection system. At the end of this inspection, the system remained in the monitoring mode of operation to facilitate continued data gathering of grid perturbations for evaluation of alarm and trip setpoints. The equipment was installed on the start-up transformers SUT-3X03 and SUT-4X03. The licensee is scheduled to transition the open phase detection system to full implementation including trip functions, if so decided, by December

INSPECTION RESULTS

Based on discussions with the licensee staff, review of available design, testing, grid data monitoring results documentation, and walkdowns of installed equipment, the inspectors had reasonable assurance the licensee appropriately implemented the VII.

The inspectors determined:

Assessment 2515/194 Detection, Alarms, and General Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) Open phase conditions will be detected and alarmed in the control room on the X common annunciator panel.

(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 prepared to discuss the design features and analyses related to the effects of, and protection for, and open phase condition (OPC) design vulnerability.

Assessment 2515/194 Protective Actions Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) Two transformers were susceptible to an open phase condition and the licensee had installed detection and mitigating equipment for both.

(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 General Electric-ALSTOM systems on the start-up transformers 3X03 and 4X03. The trip function, if and when enabled, will provide an additional input to the associated transformer output breakers. The credited plant response is unaffected and will be the same regardless of the conditions that generated the trip of the transformer output breakers.

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 design was operating in the monitoring mode with already established setpoints and gathering data to ensure the open phase condition design and protective schemes would minimize mis-operation, or spurious actions in the range of voltage unbalance normally expected in the transmission system. The licensee developed engineering calculations applied to the open phase detection and protection (OPDP) system to protect important-to-safety equipment during an open phase condition. These calculations are included in MPR calculations 1110-0042-CALC-001, Rev. 0, Turkey Point Setpoint #8 Calculation, and 1110-0044-RPT-001, Rev. 0, Basis of Alarm Only Setpoints and Time Delays at Turkey Point 3 & 4, that provide ranges of setpoints to ensure both security against false trips and detection of open phase conditions.

(2) A draft of the proposed changes to the Unit 3 and Unit 4 UFSARs were available for the inspectors review and included information related to open phase conditions that describe the functions of the OPDP system. These changes included for Units 3 and 4, to trip the 4.16 kV breakers upon detecting an OPC on the high side of the SUTs 3X03 and 4X03 respectively if the SUT is loaded and to provide an OPC alarm in the control room upon detecting the OPC on the high side of the SUT for loaded and unloaded SUT.

Assessment 2515/194 Protective Actions Criteria Exceptions; TI 2515/194-03.01 - VII (Part 1)

(1) The licensees open phase condition design solution uses General Electric-ALSTOM systems to detect, alarm, and provide a trip signal input to the associated SUT transformer load side main breakers. Upon open phase trip signal, the existing undervoltage relays would operate as designed to initiate starting of the emergency diesel generator to restore power to the bus.

The trip function input to the transformer load side breakers remained deactivated and disconnected during the onsite system implementation inspection and that design function was not able to be demonstrated. The implementation of the trip function was being tracked in the design change package EC 287154 for Unit 3 and EC 287155 for Unit 4, future revision for both that provides for the final electrical terminations required to enable the open phase protection (OPP) system SUT load breaker trip function. Once enabled, the OPP system will have the ability to isolate an affected SUT with a OPC detected on the high side of the SUTs.

Due to the configuration of the Turkey Point Nuclear Generating Stations electrical distribution system, a loss of phase on one transformer would affect one of two utility feeds to the emergency busses in the affected unit and a back-up feed to the emergency buss on the other unit. The normal feed and diesel generator feed would still be available on all emergency buses required to mitigate postulated accidents, ensuring that safety functions are preserved as required by the current licensing bases.

(2) Periodic tests, calibrations, setpoint verifications or inspections (as applicable) have been established for system operations at present. The surveillance requirements have been maintained for the plant Technical Specifications (TSs) in compliance with the provisions of 10 CFR 50.36.

The licensee has included an action request AR 2259267 that covered both Unit 3 and 4 to develop a preventive maintenance program for the installed OPDP equipment. Existing plant equipment will continue to be maintained according to the licensees current preventative maintenance program.

The inspectors identified the following observation:

Observations 2515/194 1. The trip function capabilities for both OPDP systems on Units 3 & 4 have not been enabled by the positioning of the OPDP cabinet trip output knife switches (FT1-1 and FT1-2) and by missing final connections to the SUT output breaker trip signal wiring not run into the 3A, 3B, 4A and 4B 4.16kV switchgear specific breaker compartments. The associated conduits and wires were roughed in suspended directly above the switchgear compartments.

2. Preventive Maintenance Program for the OPDP systems have not been implemented but it has been recorded to be developed under an Action Request AR 02259267 program with an assigned due date of 12/12/2019.

EXIT MEETINGS AND DEBRIEFS

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

• On September 26, 2019, the inspector presented the NRC inspection results to Mr. B.

Stamp, Site Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Calculations 1110-0043- Turkey Point Units 3 & 4 Startup Transformer Open Phase 0

Summary-001 Setpoint Summary

5614-E-315- Open Phase Cabinet 3C400 Start-up Transformer Unit 3 1

SH124A-EC287154

5614-E-315- Open Phase Cabinet 4C400 Start-up Transformer Unit 4 1

SH124A-EC287155

1110-0027-CALC- PTN Units 3 & 4 Main Transformer Mode 1 Open Phase 0

2 Vulnerability Study. (Developed by MPR)

1110-0026-CALC- Turkey Point Main Transformer Open Phase Scoping Study 0

2 (Developed by MPR)

1110-0026-RPT- PTN Main Transformer Open Phase Vulnerability Evaluation 0

001 (Developed by MPR)

1110-0044-RPT- Basis of Alarm-Only Setpoints and Time Delays at Turkey 0

001 Point Units 3 and 4 (Developed by MPR)

1110-0041-RPT- Methodology for Trip Enabled Setpoints 3

001

1110-0044-RPT- Basis of Alarm Only Setpoints and Time Delays at Turkey 0

001 Point Units 3 & 4.

1110-0043- Turkey Point Units 3 & 4 Startup Transformer Open Phase 0

SUMMARY-001 Setpoint Summary

Action Request A/R 02283385 U3 Open Phase Cabinet Indicated OPD when FLAGAME 10/03/2018

Documents Line Remove

A/R 02295123 Unit 3 Open Phase System Trouble While Enabling Alarm 12/18/2018

A/R 02310755 Unit 4 Class B Alarm Locked In On 4C400 (Open Phase 04/16/2019

Detection)

A/R 02315855 Unit 4 Class C Alarm ON Open Phase Detection Cabinet. 05/28/2019

Drawings 5610-E-1 Main Single Line - Unit 3 sheet 1 47

5610-E-1 Main Single Line - Unit 4 sheet 2 19

5610-T-E-1591 Operating Diagram Electrical Distribution 82

5613-E-25 (Unit 3) Reactor Auxiliaries Spent Fuel Pit Pump 3P212A 5

Breaker 30309

Inspection Type Designation Description or Title Revision or

Procedure Date

5613-M-3033 (Unit 3) Spent Fuel Pool Cooling System 26

5614-E-25 (Unit 4) Reactor Auxiliaries Spent Fuel Pit Pump 4P212A 3

Breaker 40309

5614-M-3033 (Unit 4) Spent Fuel Pool Cooling System 31

Design Change FCR #016 ECR Unit 3 OPDP Cabinet 3C400 Final Relay Design Setting to 3

Packages 287154 be installed in Micom Relays 1, 2, & 3.

EC287154 U3 Switchyard Open Phase Protection - Phase III 4

EC287155 U4 Switchyard Open Phase Protection - Phase III 4

Miscellaneous 5613-E-315- Open Phase Cabinet 3C400 Start-Up Transformer Unit 3 1

SH124B-EC287154

5614-E-315- Open Phase Cabinet 4C400 Start-Up Transformer Unit 4 1

SH124B-EC287155

EC287154 NRC Functional Requirements Relative to Open Phase --

H.2 Detection and Protection

EC287154 UFSAR Change Request Turkey Point Unit 3, UFSAR 16

H.5 Chapter 8.2-3

EC287155 UFSAR Change Request Turkey Point Unit 4, UFSAR 16

H.5 Chapter 8.2-3

EC287154 10 CFR 50.59 Screening Form 4

Procedures 3-NOP-092.02 Open Phase Detection and Protection 0

4-NOP-092.02 Open Phase Detection and Protection 0

EN-AA-100-10001 Open Phase Detection and Protection (OPDP) Data 1

Extraction and Analysis

Work Orders 40491799 50 EC287154 U3 - FCR-016- Install New Design Settings at 11/12/2018

3C400

40491799 51 EC287154 U3 - Install New COSI Firmware & Parameters 12/10/2018

at 3C400

40491800 52 EC287155 U4 - FCR-013- Install New Design Settings at 11/20/2018

4C400

40491800 53 EC287155 U4 - Install New COSI Firmware & Parameters 12/21/2018

at 4C400