ML20009E834

Notification of Temporary Instruction Inspection (Ti) 2515/194 (NRC Inspection Report 05000275/2020011 and 05000323/2020011) and Request for Information

ML20009E834
Person / Time
Site:	Diablo Canyon
Issue date:	01/08/2020
From:	Sam Graves NRC/RGN-IV/DRS/EB-2
To:	Welsch J Pacific Gas & Electric Co
Taylor N
References
IR 2020011
Download: ML20009E834 (5)

See also: IR 05000275/2020011

Text

January 8, 2020

Mr. James M. Welsch

Senior Vice President, Generation

and Chief Nuclear Officer

Pacific Gas and Electric Company

P.O. Box 56

Mail Code 104/6

Avila Beach, CA 93424

SUBJECT: DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - NOTIFICATION

OF TEMPORARY INSTRUCTION INSPECTION (TI) 2515/194 (NRC

INSPECTION REPORT 05000275/2020011 AND 05000323/2020011)

AND REQUEST FOR INFORMATION

Dear Mr. Welsch:

On March 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) will perform an

inspection in accordance with Temporary Instruction (TI) 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), Revision 0, at

Diablo Canyon Power Plant, Units 1 and 2. This inspection verifies that Diablo Canyon Power

Plant has appropriately implemented the Nuclear Energy Institute voluntary industry initiative

including updating licensing basis to reflect the need to protect against open phase conditions.

The lead inspector for this inspection is Sam Graves. We understand that our regulatory

contact for this inspection is Jeff Skov. If there are any questions about the inspection or the

material requested, please contact the lead inspector at 817-200-1102 or by e-mail

at Samuel.Graves@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct nor sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.

J. Welsch 2

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/

Samuel T. Graves, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 05000275 and 05000323

License Nos. DPR-80 and DPR-82

Enclosure:

TI 2515/194 Inspection Documentation Request

cc w/encl: Electronic Distribution

ML20009E834

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: STG Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:EB2

NAME SGraves

SIGNATURE /RA/

DATE 1/08/2020

TI 2515/194 Inspection Documentation Request

Please provide the following documentation (Items 1 - 8) to the lead inspector prior to the onsite

inspection date, preferably no later than March 2, 2020. Whenever practical, please provide

copies electronically. Please provide an index of the requested documents which includes a

brief description of the document and the numerical heading associated with the request

(i.e., where it can be found in the list of documents requested).

Sam Graves, Senior Inspector

RIV/DRS/EB2

1600 E. Lamar Blvd.

Arlington, TX 76011

817-200-1102

samuel.graves@nrc.gov

1. Copies of any calculations, analyses, and/or test reports performed to support the

implementation of your open phase condition (OPC) solution. If, in your implementation,

OPCs are not detected and alarmed in the control room please include documentation that:

a. Demonstrates the OPC will not prevent functioning of important-to-safety SSCs; AND

b. Detection of an OPC will occur within a short period of time (e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

2. Copies of any modification packages, including 10 CFR 50.59 evaluations if performed,

used for or planned for the implementation of your OPC solution.

3. Copies of periodic maintenance, surveillance, setpoint calibration, and/or test procedures

implemented or planned, for your OPC solution.

4. Copies of your licensing basis changes to Updated Final Safety Analysis Report (UFSAR)

and/or Technical Specifications (TS), or equivalent, as applicable, which discuss the design

features and analyses related to the effects of, and protection for, any open phase condition

design vulnerability. If these documents have not been updated, provide documentation of

your plans to do so.

5. Copies of any procurement specifications and acceptance testing documents related to the

installation of your OPC solution.

6. Copies of any site training the inspector will need to accomplish to gain access to areas

with, or planned, major electrical equipment used in your OPC solution (i.e. switchyard).

7. Provide documentation showing that with an OPC occurrence and no accident condition

signal present, either:

a. An OPC does not adversely affect the function of important-to-safety SSCs, OR

b. TS LCOs are maintained, or the TS actions are met without entry into TS LCO 3.0.3

AND

i. Important-to-safety equipment is not damaged by the OPC, AND

ii. Shutdown safety is not compromised

Enclosure

8. With OPC occurrence and an accident condition signal present:

a. Provide documentation showing that automatic detection and actuation will transfer

loads required to mitigate postulated accidents to an alternate source and ensure

that safety functions are preserved, as required by the current licensing bases, OR

b. Provide documentation showing that all design basis accident acceptance criteria are

met with the OPC, given other plant design features. Accident assumptions must

include licensing provisions associated with single failures. Typically, licensing

bases will not permit consideration of the OPC as the single failure since this failure

is a non-safety system.

Please provide the following documentation to the inspector when onsite. Whenever practical,

please provide copies electronically, except for drawings. Drawings should be provided as

paper copies of sufficient size (ANSI C or D) such that all details are legible.

9. A brief presentation describing your electric power system design and typical electrical

transmission and distribution system alignments; OPC design schemes installed to detect,

alarm and actuate; bus transfer schemes; and maintenance and surveillance requirements.

This presentation should be a general overview of your system. Please schedule the

overview shortly after the entrance meeting.

10. Plant layout and equipment drawings for areas that identify: (a) the physical plant locations

of major electrical equipment used in your open phase condition solution; (b) the locations of

detection and indication equipment used in the open phase condition sensing circuits.

11. If OPC actuation circuits are required, provide documentation that demonstrates continued

coordination with the other protective devices in both the offsite electrical system (within

Diablo Canyons area of responsibility) and the onsite electrical systems.

12. Access to locations in which open phase condition equipment is installed or planned

(i.e. switchyard, etc.)

13. Copies of documentation or testing that demonstrates your OPC solution minimizes spurious

actuation or misoperation in the range of voltage imbalance normally expected in the

transmission system that could cause undesired separation from an operable off-site power

source.

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