IR 05000369/2019011

NRC Temporary Instruction 2515/194 Open Phase Condition Inspection Report 05000369/2019011 and 05000370/2019011

ML19330D480
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/26/2019
From:	Steven Rose NRC/RGN-II
To:	Teresa Ray Duke Energy Carolinas
Reeder D
References
IR 2019011
Download: ML19330D480 (9)

Text

ber 26, 2019

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC TEMPORARY INSTRUCTION 2515/194 OPEN PHASE CONDITION INSPECTION REPORT 05000369/2019011 AND 05000370/2019011

Dear Mr. Ray:

On October 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at McGuire Nuclear Station and discussed the results of this inspection with Mr. Ed Pigott and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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,

/RA/

Steven D. Rose, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket Nos. 05000369 and 05000370 License Nos. NPF-9 and NPF-17

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000369 and 05000370 License Numbers: NPF-9 and NPF-17 Report Numbers: 05000369/2019011 and 05000370/2019011 Enterprise Identifier: I-2019-011-0046 Licensee: Duke Energy Carolinas, LLC Facility: McGuire Nuclear Station Location: Huntersville, NC Inspection Dates: October 28, 2019 to October 31, 2019 Inspectors: L. Castelli, 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 the 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 McGuire Nuclear 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

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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)

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 inspectors discussed the licensees open phase condition (OPC) system design and ongoing implementation plans with plant staff. The inspectors reviewed licensee documentation, vendor documentation, and performed system walkdowns to determine if 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 locally and in the control room, and analyzed potential impacts associated with the design implementation on the current licensing basis.

The objective of TI 2515/194 was to verify that licensees had 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)

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

McGuire Nuclear Station selected the open phase detection system designed and manufactured by Power System Sentinel Technologies, LLC. At the end of this inspection the system remained in the monitoring mode of operation to facilitate continued data gathering of the system for evaluation of alarm and trip setpoints. The equipment was installed on the main step-up transformers (MSU) 1A, 1B, 2A, and 2B. McGuire Nuclear Station currently has no set scheduled date to transition the open phase detection system to full implementation (tripping functions enabled) and is assessing implementation of NEI VII Revision 3. Revision 3 to the NEI OPC initiative incorporated an option for plants to perform a risk evaluation under certain boundary conditions to support manual response to an OPC.

INSPECTION RESULTS

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

(1) OPCs will be detected and alarmed in the control room on the common annunciator panel.

(2) Detection circuits will be sensitive enough to identify an OPC 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.

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

(1) Four transformers were susceptible to an OPC as identified in this VII when the main generator was offline. The licensee installed detection and mitigating equipment for these affected transformers.

(2) With an OPC 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 OPC design solution added Power System Sentinel Technologies LLC systems on the main step-up transformers MSU 1A, 1B, 2A, and 2B. The tripping function, if enabled, will provide an additional input to the associated transformer lockout relays. The credited plant response is not negatively affected and will be the same regardless of the conditions that generated the lockout of the transformer.

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

The inspectors identified the following minor exceptions to the Temporary Instruction criteria resulting from the operating status of the design modifications:

(1) The licensees design was operating in the monitoring mode with already established setpoints and gathering data to verify the OPC design and protective schemes would minimize mis-operation, or spurious actions in the range of voltage unbalance normally experienced in the transmission system.

(2) A draft of the UFSAR was available for the inspectors review that included information related to OPCs. The licensee provided the inspectors with proposed changes to the licensing basis that discussed the system requirements related to the effects of, and protection for, any OPC design vulnerability.

The inspectors verified the proposed change process was being tracked under initiating document EC 0000400267, Install Open Phase Detection to Meet NEI/NRC Commitments U1, Rev. 013 & EC 0000400268, Install Open Phase Detection to Meet NEI/NRC Commitments U2, Rev. 012. The inspectors also determined that the Technical Specification was not affected by this VII as evaluated under EC 0000400267.

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

The inspectors identified the following minor exceptions to the Temporary Instruction criteria resulting from the operating status of the design modifications:

The licensees OPC design solution uses Power System Sentinel Technologies, LLC to detect, alarm, and provide an input to the associated MSU zone lockout relays. Upon an initiation of the zone lockout relays, the zone that is affected by a power loss is tripped and isolated.

The tripping function input to the transformer lockout relays remained deactivated during the onsite system implementation inspection.

Due to the configuration of the McGuire Nuclear Station electrical distribution system, a loss of phase on one transformer would only affect one train of equipment, and loads required 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.

Periodic tests, calibrations, setpoint verifications or inspections (as applicable) have been established for any new protective features. The surveillance requirements have been maintained for the plant Technical Specifications (TSs) in compliance with the provisions of 10 CFR 50.36. Existing plant equipment will continue to be maintained according to the licensees current preventative maintenance program.

EXIT MEETINGS AND DEBRIEFS

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

• On October 31, 2019, the inspectors presented the NRC Temporary Instruction 2515/194 inspection results to Mr. Ed Pigott and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Drawings EC 400267 MNS-1 Open Phase Protection System: 1A Block Diagram 013

EC 400267 MNS-1 Open Phase Protection System: 1B Block Diagram 013

EC 400268 MNS-2 Open Phase Protection System: 2A Block Diagram 012

EC 400268 MNS-2 Open Phase Protection System: 2B Block Diagram 012

MC-1700-02.00 One line Diagram 24KV Relays & Meters 1A, 1ATA, 1ATE 027

MC-1700-03.00 One line Diagram 24KV Relays & Meters 1B, 1ATB, 1ATE 019

MC-2700-02.00 One line Diagram 24KV Relays & Meters 021

MC-2700-03.00 One line Diagram 24KV Relays & Meters 017

Engineering EC 0000400267 INSTALL OPEN PHASE DETECTION TO MEET NEI/NRC 013

Changes COMMITMENTS U1

EC 0000400268 INSTALL OPEN PHASE DETECTION TO MEET NEI/NRC 012

COMMITMENTS U2

Engineering AR 02277571 Open Phase Detection Unit 1 07/15/2019

Evaluations

AR 02287571 Open Phase Detection Unit 2 08/12/2019

Miscellaneous AR 02058175 New procedure for equipment installed under EC 400267 08/31/2016

AR 02277752 UFSAR Change Package 19-12 Open Phase EC 40267 06/18/2019

AR 02282731 UFSAR Change Package 19-13 Open Phase EC 40268 07/18/2019

MCM 1332.05- PSSTECH OPEN PHASE PROTECTION (OPP) SYSTEM 0B

0099.001 OPERATION AND MAINTENANCE MANUALS

MCM 1332.05- PSSTECH OPEN PHASE PROTECTION (OPP) SYSTEM 0D

0099.004 CONFIGURATION -MCGUIRE UNIT 1

MCM 2332.05- PSSTECH OPEN PHASE PROTECTION (OPP) SYSTEM 0B

0099.004 CONFIGURATION -MCGUIRE UNIT 2

Procedures AD-OP-AL-0109 Operator Rounds 000

OP/1/A/6800/004 1A Busline Block Tagout 025

OP/1/A/6800/005 1B Busline Block Tagout 028

OP/2/A/6800/004 2A Busline Block Tagout 027

Inspection Type Designation Description or Title Revision or

Procedure Date

OP/2/A/6800/005 2B Busline Block Tagout 028

Work Orders 20084450 61 EC 400267 Functional Test 08/14/2017

20107662 31 EC 400268 Functional Test 01/23/2019

20182757 47 EC 400268 Functional Test 10/16/2018

20199133 05 EC 400267 Functional Test 09/26/2016

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