ML21187A223

Temporary Instruction 2515/194 Inspection Documentation Request

ML21187A223
Person / Time
Site:	Calvert Cliffs
Issue date:	07/29/2021
From:	Amar Patel Division of Reactor Safety I
To:	Exelon Generation Co
Patel A
References
Download: ML21187A223 (4)

Text

ML21187A223 Calvert Cliffs TI 2515/194 Inspection Documentation Request Please provide the following documentation (Items 1 - 14) to the lead inspector prior to the onsite inspection date, preferably no later than June 28, 2021. Whenever practical, please provide copies electronically. Lead inspector contact information is below:

Amar Patel - Senior Reactor Inspector NRC Region 1 / Division of Reactor Safety / Engineering Branch 2 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406 Email: amar.patel@nrc.gov Phone: 610-337-5220 Note: This inspection will consist of TI-194 Section 03.01, parts (a), (b), and (c).

1. Copies of any modification packages, including 10 CFR 50.59 evaluations if performed, for the implementation of your OPC solution.

• Please indicate if new non-Class-1E circuits were used to replace existing Class-1E circuits.

2. 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.

3. Engineering analysis which demonstrates OPC detection circuits are sensitive enough to identify an OPC for credited loading conditions (i.e., high and low transformer loading).

4. Engineering analysis which demonstrates OPC design/protective schemes minimize misoperation or spurious action in the range of voltage unbalance normally expected in the transmission system that could cause separation from an operable off-site power source.

5. Identify whether OPIS detection and alarm components are maintained in accordance with station procedures or the maintenance program, and that periodic tests, calibrations, setpoint verifications or inspections (as applicable) have been established.

6. Copies of Alarm Response Procedures, Abnormal Operating Procedures, or Standard Operating procedures that demonstrate operator response to detection of an Open Phase Condition.

7. Copies of Operator Training Lesson plans for Operator response to an Open Phase Condition and documentation of the frequency the training is given to Licensed and Non-Licensed Operators.

8. Copies of recent Operator Logs that show:

• How often Voltages and/or Currents are logged under normal operating conditions on all 3 phases of the Tech Spec credited Unit offsite power sources.

• How often Voltages and/or Currents are logged under normal operating conditions on all 3 phases of the Unit credited 4kV safety related buses.

• How often Voltages and/or Currents are logged under abnormal operating conditions on the offsite power source(s) and the 4kV safety related buses. Abnormal conditions include conditions of reduced reliability, such as only one credited offsite power source is available or a credited Emergency Diesel Generator is not available.

• How often switchyard walkdowns are performed under normal and reduced reliability conditions.

• How often operator logs are taken on Open Phase Condition equipment in the plant.

9. Engineering analysis that demonstrates that with an OPC occurrence, and no accident condition signal present:

• Important-to-safety equipment is not damaged by the OPC.

• Shutdown safety is not compromised.

10. Engineering analysis that demonstrates that with an OPC occurrence, and an accident condition signal present:

• 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.

11. Most recent copy of NEI 19-02 evaluation, and any PRA evaluations for your plant response to an open phase condition.

• Include Event Trees and Fault Trees developed/used as part of your analysis

12. Most recent copy of any HRA evaluations for your proposed or existing operator actions in procedures used to identify and mitigate open phase conditions.

• Include timing information for any operator actions.

• Please discuss any sensitivity analyses performed, and the results. Also, discuss any assumptions made which bound the sensitivity analysis.

13. If recovery is assumed as part of the basis in the PRA analysis for impacted electric equipment, then please provide the following:

• System load flow calculations, protective coordination, failure mode and consequence analyses associated with restoration of equipment to perform the required functions.

• Provide evaluations associated PRA credited loads which demonstrates that the PRA credited loads would not be damaged during the time delay between detection of an OPC by the control room operators, and completion of the operator actions.

• Provide an analysis/calculation of the maximum unbalance seen on ESF buses at all voltage levels and provide documents associated with existing relays that are used to protect the equipment from unbalanced power quality issues and potential consequences.

• Provide time analysis associated with the recovery of the tripped equipment and provide recovery actions/procedures (fuse replacement, restoring large motors, restarting stalled or degraded electrical equipment).

14. Copy of OPC self-assessment performed prior to inspection, if performed.

Please provide the following documentation to the inspector when onsite:

15. 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.

• Following the presentation, please upload the power point slides to the Sharefile site or certrec, whichever your site uses.

16. Plant layout and equipment drawings for areas that identify:

• The physical plant locations of major electrical equipment used in your open phase condition solution.

• The locations of detection and indication equipment used in the open phase condition sensing circuits.

• Note: Whenever practical, please provide electronic and paper copies. Drawings should be size ANSI C or D, such that all details are legible.

17. Access to locations in which open phase condition equipment is installed (plant and switchyard).

18. An operator walkthrough of your OPC response procedures. Include any control room time critical operator actions (use of the simulator may be the preferred method).

This document 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 31500011. 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.

This document 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.