View source for W3F1-2014-0008, Response to Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System

{{Adams
| number = ML14035A454
| issue date = 02/03/2014
| title = Response to Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System
| author name = Chisum M
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person = 
| case reference number = BL-12-001, W3F1-2014-0008
| document type = Letter type:W
| page count = 6
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6698 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 W3F1-2014-0008 February 3, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Response to Request For Additional Information Regarding Response To Bulletin 2012-01, Design Vulnerability In Electric PowerSystem.
Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38

==REFERENCES:==
: 1. NRC issued Bulletin 2012-01, Design Vulnerability in Electric Power System, dated July 27, 2012 (ADAMS Accession No. ML12074A115).
: 2. Entergy letter W3F1 -2012-0091, 90-Day Response to NRC Bulletin 2012-01, Design Vulnerability in Electric Power System, dated October 25, 2012, (ADAMS Accession No. ML12299A392).
: 3. Nuclear Energy Institute (NEI) letter, Industry Initiative on Open Phase Condition, dated October 9, 2013, (ADAMS Accession No. ML13333A147)
: 4. NRC letter, Request For Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System, dated December 20, 2013 (ADAMS Accession No. ML13351A314)

==Dear Sir or Madam:==
,
On July 27, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2012-01, "Design Vulnerability in Electric Power System" (Reference 1), to all holders of operating licenses and combined licenses for nuclear power reactors, requiring a response within 90 days.
In letter dated October 25, 2012 (Reference 2), Entergy Operations Inc. (Entergy) provided the 90-day response to NRC Bulletin 2012-01 for Waterford 3.
In letter dated October 9, 2013 (Reference 3), the Nuclear Energy Institute (NEI} submitted an industry initiative document to support the resolution of the open phase issue described in NRC issued Bulletin 2012-01. This initiative was approved by the NEI Nuclear Strategic Issues Advisory Committee.

W3F1 -2014-0008 Page 2 In letter dated December 20, 2013 (Reference 4), the NRC staff requested additional information from licensees, with responses signed under oath or affirmation, due by February 3, 2014. Entergy's Waterford 3 response to the Request for Additional Information is attached.
There are no new regulatory commitments contained in this submittal.
If you require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504.739.6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 3, 2014.
Sincerely, MRC/JDW

==Attachment:==
Response to Request for Additional Information

W3F1 -2014-0008 Page 3 cc:    Mr. Marc L. Dapas Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector for Waterford 3 Marlone.Davis@nrc.gov (SRI)
Chris.Speer@nrc.gov (RI)
NRC Program Manager for Waterford 3 Alan.Wang@nrc.gov

Attachment to W3F1-2014-0008 Response to Request for Additional Information

Attachment to W3F1-2014-0008 Page 1 of 2 Response to Request for Additional Information NRC letter (ADAMS ML13351A314) dated December 20, 2013 requests the following:
        "In order for the NRC staff to complete its review of responses to the bulletin, the following additional information is requested:
: 1. Provide a summary of all interim corrective actions that have been taken since the January 30, 2012, event at Byron Station, Unit 2, to ensure that plant operators can promptly diagnose and respond to open phase conditions on the offsite power circuits for Class-i E vital buses until permanent corrective actions are completed.
: 2. Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power."
Response 1 - Summary of All Interim Corrective Actions Lessons learned from the events at Byron station were reviewed and various interim corrective actions evaluated for safety and efficiency at Waterford Steam Electric Station, Unit 3 (Waterford 3).
Based the plant's offsite power configuration, electrical design details, and on lessons learned, the following actions were taken to ensure plant operators can promptly diagnose and respond to open phase conditions (OPC):
Interim Corrective Actions o   Training was performed to make Operations personnel aware of the electrical system response on an open phase at the high side of the Startup Transformers with or without a ground fault.
o   Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
These inspections were updated to include a visual inspection of the switchyard overhead lines connecting to the Startup Transformers to identify OPC vulnerabilities.
o   Operations procedures were revised to include recognition of equipment problems caused by OPC.
Response 2 - Status and Schedule for Completion of Plant Design Chanaes Status o   All holders of operating licenses and combined licenses for nuclear power reactors are investigating options being researched by several vendors (PSC2000, EPRI, Schweitzer, etc.) to detect OPC faults. 'There is currently no generic, off-the-shelf technology that has been proven to detect all the required open phase fault conditions for all plant and transformer designs.
o   All holders of operating licenses and combined licenses for nuclear power reactors are fully engaged in the development of the NEI OPC Guidance Document, as well as development of enhancements to software tools being used to analyze OPC faults.

Attachment to W3F1-2014-0008 Page 2 of 2 o  With the goal of ensuring accurate detection without compromising nuclear safety or increasing plant risk, this new OPC technology is being thoroughly evaluated, will provide reasonable assurance of precluding false operation of automatic features..
o  Vulnerability studies of the OPC faults have been started for Waterford 3.
Schedule o  The Entergy nuclear fleet plants have committed to the generic schedule provided in the Industry OPC Initiative.
o  It is our intention to meet the milestones of this schedule; however, deviations may be required to accommodate outage schedules, software and hardware availability, manufacturer's delivery capabilities, licensing delays, etc.
o  Any deviation from the Industry OPC Initiative schedule will be documented through the deviation/exemption process addressed in the NEI OPC Guidance Document.}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6698 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 W3F1-2014-0008 February 3, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Response to Request For Additional Information Regarding Response To Bulletin 2012-01, Design Vulnerability In Electric PowerSystem.
Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38

==REFERENCES:==
: 1. NRC issued Bulletin 2012-01, Design Vulnerability in Electric Power System, dated July 27, 2012 (ADAMS Accession No. ML12074A115).
: 2. Entergy letter W3F1 -2012-0091, 90-Day Response to NRC Bulletin 2012-01, Design Vulnerability in Electric Power System, dated October 25, 2012, (ADAMS Accession No. ML12299A392).
: 3. Nuclear Energy Institute (NEI) letter, Industry Initiative on Open Phase Condition, dated October 9, 2013, (ADAMS Accession No. ML13333A147)
: 4. NRC letter, Request For Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System, dated December 20, 2013 (ADAMS Accession No. ML13351A314)

==Dear Sir or Madam:==
,
On July 27, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2012-01, "Design Vulnerability in Electric Power System" (Reference 1), to all holders of operating licenses and combined licenses for nuclear power reactors, requiring a response within 90 days.
In letter dated October 25, 2012 (Reference 2), Entergy Operations Inc. (Entergy) provided the 90-day response to NRC Bulletin 2012-01 for Waterford 3.
In letter dated October 9, 2013 (Reference 3), the Nuclear Energy Institute (NEI} submitted an industry initiative document to support the resolution of the open phase issue described in NRC issued Bulletin 2012-01. This initiative was approved by the NEI Nuclear Strategic Issues Advisory Committee.

W3F1 -2014-0008 Page 2 In letter dated December 20, 2013 (Reference 4), the NRC staff requested additional information from licensees, with responses signed under oath or affirmation, due by February 3, 2014. Entergy's Waterford 3 response to the Request for Additional Information is attached.
There are no new regulatory commitments contained in this submittal.
If you require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at 504.739.6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 3, 2014.
Sincerely, MRC/JDW

==Attachment:==
Response to Request for Additional Information

W3F1 -2014-0008 Page 3 cc:    Mr. Marc L. Dapas Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector for Waterford 3 Marlone.Davis@nrc.gov (SRI)
Chris.Speer@nrc.gov (RI)
NRC Program Manager for Waterford 3 Alan.Wang@nrc.gov

Attachment to W3F1-2014-0008 Response to Request for Additional Information

Attachment to W3F1-2014-0008 Page 1 of 2 Response to Request for Additional Information NRC letter (ADAMS ML13351A314) dated December 20, 2013 requests the following:
        "In order for the NRC staff to complete its review of responses to the bulletin, the following additional information is requested:
: 1. Provide a summary of all interim corrective actions that have been taken since the January 30, 2012, event at Byron Station, Unit 2, to ensure that plant operators can promptly diagnose and respond to open phase conditions on the offsite power circuits for Class-i E vital buses until permanent corrective actions are completed.
: 2. Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power."
Response 1 - Summary of All Interim Corrective Actions Lessons learned from the events at Byron station were reviewed and various interim corrective actions evaluated for safety and efficiency at Waterford Steam Electric Station, Unit 3 (Waterford 3).
Based the plant's offsite power configuration, electrical design details, and on lessons learned, the following actions were taken to ensure plant operators can promptly diagnose and respond to open phase conditions (OPC):
Interim Corrective Actions o   Training was performed to make Operations personnel aware of the electrical system response on an open phase at the high side of the Startup Transformers with or without a ground fault.
o   Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
These inspections were updated to include a visual inspection of the switchyard overhead lines connecting to the Startup Transformers to identify OPC vulnerabilities.
o   Operations procedures were revised to include recognition of equipment problems caused by OPC.
Response 2 - Status and Schedule for Completion of Plant Design Chanaes Status o   All holders of operating licenses and combined licenses for nuclear power reactors are investigating options being researched by several vendors (PSC2000, EPRI, Schweitzer, etc.) to detect OPC faults. 'There is currently no generic, off-the-shelf technology that has been proven to detect all the required open phase fault conditions for all plant and transformer designs.
o   All holders of operating licenses and combined licenses for nuclear power reactors are fully engaged in the development of the NEI OPC Guidance Document, as well as development of enhancements to software tools being used to analyze OPC faults.

Attachment to W3F1-2014-0008 Page 2 of 2 o  With the goal of ensuring accurate detection without compromising nuclear safety or increasing plant risk, this new OPC technology is being thoroughly evaluated, will provide reasonable assurance of precluding false operation of automatic features..
o  Vulnerability studies of the OPC faults have been started for Waterford 3.
Schedule o  The Entergy nuclear fleet plants have committed to the generic schedule provided in the Industry OPC Initiative.
o  It is our intention to meet the milestones of this schedule; however, deviations may be required to accommodate outage schedules, software and hardware availability, manufacturer's delivery capabilities, licensing delays, etc.
o  Any deviation from the Industry OPC Initiative schedule will be documented through the deviation/exemption process addressed in the NEI OPC Guidance Document.}}