ML21020A039
| ML21020A039 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/20/2021 |
| From: | Alan Dahbur Division of Reactor Safety III |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| IR 2021010 | |
| Download: ML21020A039 (6) | |
See also: IR 05000440/2021010
Text
January 20, 2021
Mr. Rod Penfield
Site Vice President
Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant
10 Center Road,
Perry, OH 44081
SUBJECT: PERRY NUCLEAR POWER PLANTINFORMATION REQUEST TO SUPPORT
UPCOMING TEMPORARY INSTRUCTION 2515/194 INSPECTION; INSPECTION
REPORT 05000440/2021010
Dear Mr. Penfield:
This letter is to request information to support our inspection of the Industry Initiative Associated
with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (U.S. Nuclear
Regulatory Commission (NRC)Bulletin 2012-01) beginning April 26, 2021, at your Perry
Nuclear Power Plant. This inspection will be performed in accordance with the NRC Temporary
Instruction 2515/194.
In order to minimize the impact that the inspection has on the site and to ensure a productive
inspection, we have enclosed a list of documents requested for the inspection. Please provide
this information prior to March 26, 2021. It is important that all of these documents are up to
date and complete in order to minimize the number of additional documents requested during
the preparation and/or the onsite portions of the inspections. Insofar as possible, this
information should be provided electronically to the lead inspector.
The lead inspector for this inspection is Mr. A. Dahbur. We understand that our licensing
contact for this inspection is Mr. G. Dujanovic of your organization. If there are any questions
about the inspection or the material requested in the enclosure, please contact the lead
inspector at 630-829-9810 or via e-mail at Alan.Dahbur@nrc.gov.
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget, Control
Number 3150-0011. The NRC may not conduct or 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 Office of Management and Budget Control
Number.
R. Penfield
-2-
This letter and its enclosure 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/
Alan Dahbur, Senior Reactor Engineer
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Document Request for Temporary
Instruction 2515/194 Inspection
cc: Distribution via LISTSERV
R. Penfield
-3-
Letter to Rod Penfield from Alan Dahbur dated January 20, 2021.
SUBJECT: PERRY NUCLEAR POWER PLANTINFORMATION REQUEST TO SUPPORT
UPCOMING TEMPORARY INSTRUCTION 2515/194 INSPECTION; INSPECTION
REPORT 05000440/2021010
DISTRIBUTION:
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Kenneth OBrien
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ADAMS Accession Number: ML21020A039
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
ADahbur:mb via
DATE
01/20/2021
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION
Enclosure
Inspection Report: 05000440/2021010
Inspection Dates:
April 26, 2021, through April 30, 2021
Inspection Procedures:
2515/194-TI-2515-Phase 5
Inspector:
630-829-9810
Alan.Dahbur@nrc.gov
Please provide the following documentation (Items 1-9) to the lead inspector prior to the onsite
inspection date, preferably no later than March 26, 2021. 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).
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
structures, systems, and components; 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 Title 10 of the Code of Federal
Regulations, Part 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 and/or
Technical Specifications, as applicable, which discuss the design features and analyses
related to the effects of, and protection for, any open phase condition design
vulnerability.
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 team 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 structures,
systems, and components; or
DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION
2
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.
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.
9.
For those licensees that opted to demonstrate that operator manual actions will
be sufficient to mitigate the impact of an OPC, in accordance with VII,
Revision 3, Attachment 1 and NEI 19-02, Guidance for Assessing Open Phase
Condition Implementation Using Risk Insights, instead of automatic protective
actions discussed in Section 03.02.b of TI 2515/194, Revision 2, provide the
following:
a. Copies of any PRA evaluations for your plant response to an open phase
condition including your Human Reliability Analysis (HRA) and sensitivity
analyses; and
b. Procedure(s) and operator actions required to respond to an OPC alarm and
potential equipment trip.
Please provide the following documentation to the team when they arrive 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.
1. 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.
2. 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; and
(b) the locations of detection and indication equipment used in the OPC sensing circuits.
3. If OPC actuation circuits are required, provide documentation that demonstrates
continued coordination with the other protective devices in both the offsite electrical
system (within Perry Nuclear Plant area of responsibility) and the onsite electrical
systems.
DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION
3
4. Access to locations in which open phase condition equipment is installed or planned
(i.e., switchyard, etc.).
5. Copies of documentation or testing that demonstrates your OPC solution minimizes
spurious actuation or mis operation in the range of voltage imbalance normally expected
in the transmission system that could cause undesired separation from an operable
off-site power source.