RA-18-0227, Commitment Schedule to Implement NEI Initiative on Open Phase Condition
| ML18344A047 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/04/2018 |
| From: | Burchfield J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NEI 99-04, RA-18-0227, SECY-00-0045 | |
| Download: ML18344A047 (4) | |
Text
l(.,DUKE ..
~ ENERGY J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 o:
- 864.873.3478
- f. 864.873.5791 Ed.Burchfield@duke-energy.com RA-18-0227 NEI 99-04 SECY-00-0045 December 4, 2018 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55
Subject:
Commitment Schedule to Implement NEI Initiative on Open Phase Condition
References:
- 1. U.S. Nuclear Regulatory Commission Letter, Design Vulnerability in Electric Power System, NRC Bulletin 2012-01, dated July 27, 2012 (ML12074A115),
- 2. Duke Energy Letter to U.S. Nuclear Regulatory Commission Related to Response to Request for Additional Information for Bulletin 2012-01, dated February 3, 2014 (ML14035A453),
- 3. Nuclear Energy Institute Letter to U.S. Nuclear Regulatory Commission, Industry Initiative on Open Phase Condition, Revision 1, dated March 16, 2015 (ML15075A454), .
- 4. Nuclear Energy Institute Letter to U.S. Nuclear Regulatory Commission, Industry Initiative on Open Phase Condition, Revision 2, dated September 20, 2018 (ML18268A114).
In response to NRC Bulletin 2012-01 (Reference 1), the Nuclear Energy Institute (NEI) organized an industry initiative to address the identified design vulnerability, The industry Open Phase Condition (OPC) initiative (Reference 3) identified several actions that licensees should complete by December 31, 2018. The purpose of this letter is to notify the NRC of changes to the implementation schedule for the OPC Initiative actions for Oconee Nuclear Station (ONS).
Specifically, ONS is deferring implementation from December 31, 2018, to August 31, 2019.
On February 3, 2014 (Reference 2), Duke Energy Carolinas, LLC (Duke Energy) stated its intention to follow the NEI industry initiative document and the generic schedule provided in the document. Duke Energy noted that a provision in the NEI industry initiative provides for deviation to the schedule to accommodate outage schedules and technology availability stating that it will be documented through the NEI industry initiative exemption process.
U.S. Nuclear Regulatory Commission December 4, 2018 Page2 Duke Energy has documented the need for this. schedule change through the NEI Industry Initiative exemption process. This extension is necessary to allow adequate time to complete installations after the Open Phase Detection (OPD) Systems are delivered without incurring additional risk to the station, *particularly since these installations will interface with existing safety-related components. This change includes system installations for Unit Start-Up Transformers CT1, CT2, CT3, the Keowee Main Step-Up Transformer, and the CT-5 Lee/Central Switch Yard Power Path Transformer.
ONS selected the OPD Sys.tern that was developed by the Electric Power Research Institute, Power System Sentinel Technologies, LLC. The ONS OPD systems are analog safety-related devices that include an external Uninterruptible Power Supply (UPS). Due to schedule delays associated with the equipment vendors, final equipment deliveries have been re-scheduled for the first quarter of 2019. This new delivery schedule will not allow ONS to complete installation activities, including plant tie-ins, by the December 31, 2018, deadline of the NEI OPC Initiative, Revision 2. OPC implementation activities are also impacted by a Keowee Hydro Unit (KHU) outage scheduled for January and February 2019.. During the KHU outage, OPC tie-ins to transformers would not be allowed by ONS Technical Specifications since these sources are required to remain in service during this stator upgrade outage.
There is no change to Duke Energy's implementation of the NEI OPC initiative other than the schedule deferral based on the reasons described above. Trip functions will be installed and enabled within 24 months after system monitoring/detection installations as allowed by.Revision 2 of the NEI OPC Initiative (Reference 4). A summary of the regulatory commitment described in this letter may be found in the Attachment to this letter.
If you have any questions regarding this submittal, please contact Chris Wasik, Regulatory Affairs Manager, at (864) 873-5789.
Sincerely,
~C1~t J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station
Attachment:
Summary of Regulatory Commitments
U. S. Nuclear Regulatory Commission December 4, 2018 Page 3 cc w/attachment:
Ms. Catherine Haney, Admir,iistrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Ms. Audrey Klett, Project Manager (by electronic mail only)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8G9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. Eddy Crowe NR.C Senior Resident Inspector Oconee Nuclear Station Ms. Lynne Garner, Manager, (by electronic mail oniy: garnerld@dhec.sc.gov)
Infectious and Radioactive Waste Management, Bureau of Land and Waste Management Dep~rtment of Health & Environmental Control 2600 Bull Street Columbia, SC 29201
Attachment December 4, 2018 Page 1
SUMMARY
OF REGULATORY COMMITMENTS The following commitment table identifies those actions committed to by Duke Energy Carolinas, LLC (Duke Energy) in this submitta). other actions discussed in the submittal represent intended or planned actions by Duke Energy. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Duke Energy will implement the NEI Open Phase Condition initiative at Oconee Nuclear Station as described in the "Schedule for Operating August 31, 2019 Plants - Dec. 31, 2018" section of the Attachment to the NEI letter dated September 20, 2018.
Text
l(.,DUKE ..
~ ENERGY J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 o:
- 864.873.3478
- f. 864.873.5791 Ed.Burchfield@duke-energy.com RA-18-0227 NEI 99-04 SECY-00-0045 December 4, 2018 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55
Subject:
Commitment Schedule to Implement NEI Initiative on Open Phase Condition
References:
- 1. U.S. Nuclear Regulatory Commission Letter, Design Vulnerability in Electric Power System, NRC Bulletin 2012-01, dated July 27, 2012 (ML12074A115),
- 2. Duke Energy Letter to U.S. Nuclear Regulatory Commission Related to Response to Request for Additional Information for Bulletin 2012-01, dated February 3, 2014 (ML14035A453),
- 3. Nuclear Energy Institute Letter to U.S. Nuclear Regulatory Commission, Industry Initiative on Open Phase Condition, Revision 1, dated March 16, 2015 (ML15075A454), .
- 4. Nuclear Energy Institute Letter to U.S. Nuclear Regulatory Commission, Industry Initiative on Open Phase Condition, Revision 2, dated September 20, 2018 (ML18268A114).
In response to NRC Bulletin 2012-01 (Reference 1), the Nuclear Energy Institute (NEI) organized an industry initiative to address the identified design vulnerability, The industry Open Phase Condition (OPC) initiative (Reference 3) identified several actions that licensees should complete by December 31, 2018. The purpose of this letter is to notify the NRC of changes to the implementation schedule for the OPC Initiative actions for Oconee Nuclear Station (ONS).
Specifically, ONS is deferring implementation from December 31, 2018, to August 31, 2019.
On February 3, 2014 (Reference 2), Duke Energy Carolinas, LLC (Duke Energy) stated its intention to follow the NEI industry initiative document and the generic schedule provided in the document. Duke Energy noted that a provision in the NEI industry initiative provides for deviation to the schedule to accommodate outage schedules and technology availability stating that it will be documented through the NEI industry initiative exemption process.
U.S. Nuclear Regulatory Commission December 4, 2018 Page2 Duke Energy has documented the need for this. schedule change through the NEI Industry Initiative exemption process. This extension is necessary to allow adequate time to complete installations after the Open Phase Detection (OPD) Systems are delivered without incurring additional risk to the station, *particularly since these installations will interface with existing safety-related components. This change includes system installations for Unit Start-Up Transformers CT1, CT2, CT3, the Keowee Main Step-Up Transformer, and the CT-5 Lee/Central Switch Yard Power Path Transformer.
ONS selected the OPD Sys.tern that was developed by the Electric Power Research Institute, Power System Sentinel Technologies, LLC. The ONS OPD systems are analog safety-related devices that include an external Uninterruptible Power Supply (UPS). Due to schedule delays associated with the equipment vendors, final equipment deliveries have been re-scheduled for the first quarter of 2019. This new delivery schedule will not allow ONS to complete installation activities, including plant tie-ins, by the December 31, 2018, deadline of the NEI OPC Initiative, Revision 2. OPC implementation activities are also impacted by a Keowee Hydro Unit (KHU) outage scheduled for January and February 2019.. During the KHU outage, OPC tie-ins to transformers would not be allowed by ONS Technical Specifications since these sources are required to remain in service during this stator upgrade outage.
There is no change to Duke Energy's implementation of the NEI OPC initiative other than the schedule deferral based on the reasons described above. Trip functions will be installed and enabled within 24 months after system monitoring/detection installations as allowed by.Revision 2 of the NEI OPC Initiative (Reference 4). A summary of the regulatory commitment described in this letter may be found in the Attachment to this letter.
If you have any questions regarding this submittal, please contact Chris Wasik, Regulatory Affairs Manager, at (864) 873-5789.
Sincerely,
~C1~t J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station
Attachment:
Summary of Regulatory Commitments
U. S. Nuclear Regulatory Commission December 4, 2018 Page 3 cc w/attachment:
Ms. Catherine Haney, Admir,iistrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Ms. Audrey Klett, Project Manager (by electronic mail only)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8G9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. Eddy Crowe NR.C Senior Resident Inspector Oconee Nuclear Station Ms. Lynne Garner, Manager, (by electronic mail oniy: garnerld@dhec.sc.gov)
Infectious and Radioactive Waste Management, Bureau of Land and Waste Management Dep~rtment of Health & Environmental Control 2600 Bull Street Columbia, SC 29201
Attachment December 4, 2018 Page 1
SUMMARY
OF REGULATORY COMMITMENTS The following commitment table identifies those actions committed to by Duke Energy Carolinas, LLC (Duke Energy) in this submitta). other actions discussed in the submittal represent intended or planned actions by Duke Energy. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Duke Energy will implement the NEI Open Phase Condition initiative at Oconee Nuclear Station as described in the "Schedule for Operating August 31, 2019 Plants - Dec. 31, 2018" section of the Attachment to the NEI letter dated September 20, 2018.