View source for JAFP-14-0011, Response to Request for Additional Information for Bulletin 2012-01

{{Adams
| number = ML14034A362
| issue date = 02/03/2014
| title = Response to Request for Additional Information for Bulletin 2012-01
| author name = Coyle L
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000333
| license number = DPR-059
| contact person = 
| case reference number = BL-12-001, JAFP-14-0011
| document type = Letter type:JAFP
| page count = 5
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Lawrence M. Coyle Site Vice President - JAF JAFP-14-0011 February 3, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Response to Request for Additional Information for Bulletin 2012-01 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

==Reference:==
: 1. NRC letter, Design Vulnerability in Electric Power System, NRC Bulletin 2012-01, dated July 12, 2012 (ML12074A115)
: 2. Entergy letter, Response to IE Bulletin 2012-01, Design Vulnerability in Electric Power System, JAFP-12-0095, dated October 25, 2012
: 3. NRC letter, Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System, dated December 20, 2013 (ML13351A314)

==Dear Sir or Madam:==

On July 27, 2012, the NRC issued Bulletin 2012-01 [Reference 1], requesting that each licensee submit a written response in accordance with 10 CFR 50.54(f) within 90 days of the bulletin to provide requested information. James A. FitzPatrick Nuclear Power Plant (JAF) submitted a response [Reference 2] dated October 25, 2012. The NRC made a request for additional information [Reference 3] dated December 20, 2013. This letter provides Entergy Operations' response in the Attachment.

JAFP-14-0011 Page 2 of 2 This letter contains no new regulatory commitments.
If you have any questions regarding this submittal, please contact Mr. Chris M. Adner, Regulatory Assurance Manager, at (315) 349-6766.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 3, 2014.
Sincerely, g~~~hUnr:,
Lawrence M. Coyle Site Vice President LMC/CMA/mh

==Attachment:==
JAF Response to Request for Additional Information cc:   Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector Mr. Mohan Thadani, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. Francis J. Murray Jr., President NYSERDA

JAFP-14-0011 Attachment JAF Response to Request for Additional Information (2 Pages)

JAFP-14-0011 Attachment JAF Response to Request for Additional Information NRC letter (ADAMS ML13351A314) dated December 20, 2013 requests the following:
Question 1 - Summary of All Interim Corrective Actions 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-1E vital buses until permanent corrective actions are completed.
Response 1 Lessons learned from the events at Byron station were reviewed and various interim corrective actions evaluated for safety and efficiency at the James A. FitzPatrick (JAF) Plant. Based upon the plants 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 All of JAFs interim corrective actions can be tracked via CR-JAF-2012-01016 o   Periodic walk-downs are on-going of the switchyard to identify OPC vulnerabilities, as per Operations Procedure OP-44 115 kV System and AOP-72 115kV Grid Loss, Instability or Degradation.
o   Operating instructions and training curriculum ensure operators can diagnose and respond to an OPC.
o   Corona Camera scans are conducted every six (6) months. This task focuses on various high voltage components and connections.
o   Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
o   Bi-annual infrared inspections (Infrared Thermography) of yard equipment are being completed as part of routine inspections.
o   Operations procedures were revised to include recognition of equipment problems caused by OPC.
o   Electrical Maintenance is performing inspections every month with instrument readings for the switchyards (115 kV and 345 kV) and large transformers (71-T1A, 1B, T2, T3, and T4). This includes 115 kV and 345 kV visual insulation inspections for conditions adverse to quality.
o   Operators take the following readings once per shift:
Load on NMP Reserve Station Transformer T101S Out MW (NMP #1 G367)
Load on NMP Reserve Station Transformer T101N Out MW (NMP #1 G371)
NMP 1 Steady State load (NMP #1 G367 + G371) 115 KV Line #4 (Manual / Auto) 71T-2 H Winding Phase Currents (A,B,C) 71T-3 H Winding Phase Currents (A,B,C) 71T-4 H Winding Phase Currents (A,B,C)
Page 1 of 2

JAFP-14-0011 Attachment JAF Response to Request for Additional Information Question 2 - Status and Schedule for Completion of Plant Design Changes Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power.
Response 2 Status o JAF and Entergy are investigating options being researched by several vendors (PCS2000, 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 JAF and Entergy 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.
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 be tested, and will be fully analyzed before installation.
o Vulnerability studies of the OPC faults have been started for JAF.
o JAF has selected a vendor for the technical solution. A proposal for implementation of the solution has been received and is under review.
Schedule o JAF has 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, manufacturers 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.
o JAF is targeting the Reactor Outage RO22 (October 2016) for completion of the required modification.
Page 2 of 2}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Lawrence M. Coyle Site Vice President - JAF JAFP-14-0011 February 3, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Response to Request for Additional Information for Bulletin 2012-01 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

==Reference:==
: 1. NRC letter, Design Vulnerability in Electric Power System, NRC Bulletin 2012-01, dated July 12, 2012 (ML12074A115)
: 2. Entergy letter, Response to IE Bulletin 2012-01, Design Vulnerability in Electric Power System, JAFP-12-0095, dated October 25, 2012
: 3. NRC letter, Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System, dated December 20, 2013 (ML13351A314)

==Dear Sir or Madam:==

On July 27, 2012, the NRC issued Bulletin 2012-01 [Reference 1], requesting that each licensee submit a written response in accordance with 10 CFR 50.54(f) within 90 days of the bulletin to provide requested information. James A. FitzPatrick Nuclear Power Plant (JAF) submitted a response [Reference 2] dated October 25, 2012. The NRC made a request for additional information [Reference 3] dated December 20, 2013. This letter provides Entergy Operations' response in the Attachment.

JAFP-14-0011 Page 2 of 2 This letter contains no new regulatory commitments.
If you have any questions regarding this submittal, please contact Mr. Chris M. Adner, Regulatory Assurance Manager, at (315) 349-6766.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 3, 2014.
Sincerely, g~~~hUnr:,
Lawrence M. Coyle Site Vice President LMC/CMA/mh

==Attachment:==
JAF Response to Request for Additional Information cc:   Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector Mr. Mohan Thadani, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. Francis J. Murray Jr., President NYSERDA

JAFP-14-0011 Attachment JAF Response to Request for Additional Information (2 Pages)

JAFP-14-0011 Attachment JAF Response to Request for Additional Information NRC letter (ADAMS ML13351A314) dated December 20, 2013 requests the following:
Question 1 - Summary of All Interim Corrective Actions 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-1E vital buses until permanent corrective actions are completed.
Response 1 Lessons learned from the events at Byron station were reviewed and various interim corrective actions evaluated for safety and efficiency at the James A. FitzPatrick (JAF) Plant. Based upon the plants 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 All of JAFs interim corrective actions can be tracked via CR-JAF-2012-01016 o   Periodic walk-downs are on-going of the switchyard to identify OPC vulnerabilities, as per Operations Procedure OP-44 115 kV System and AOP-72 115kV Grid Loss, Instability or Degradation.
o   Operating instructions and training curriculum ensure operators can diagnose and respond to an OPC.
o   Corona Camera scans are conducted every six (6) months. This task focuses on various high voltage components and connections.
o   Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
o   Bi-annual infrared inspections (Infrared Thermography) of yard equipment are being completed as part of routine inspections.
o   Operations procedures were revised to include recognition of equipment problems caused by OPC.
o   Electrical Maintenance is performing inspections every month with instrument readings for the switchyards (115 kV and 345 kV) and large transformers (71-T1A, 1B, T2, T3, and T4). This includes 115 kV and 345 kV visual insulation inspections for conditions adverse to quality.
o   Operators take the following readings once per shift:
Load on NMP Reserve Station Transformer T101S Out MW (NMP #1 G367)
Load on NMP Reserve Station Transformer T101N Out MW (NMP #1 G371)
NMP 1 Steady State load (NMP #1 G367 + G371) 115 KV Line #4 (Manual / Auto) 71T-2 H Winding Phase Currents (A,B,C) 71T-3 H Winding Phase Currents (A,B,C) 71T-4 H Winding Phase Currents (A,B,C)
Page 1 of 2

JAFP-14-0011 Attachment JAF Response to Request for Additional Information Question 2 - Status and Schedule for Completion of Plant Design Changes Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power.
Response 2 Status o JAF and Entergy are investigating options being researched by several vendors (PCS2000, 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 JAF and Entergy 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.
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 be tested, and will be fully analyzed before installation.
o Vulnerability studies of the OPC faults have been started for JAF.
o JAF has selected a vendor for the technical solution. A proposal for implementation of the solution has been received and is under review.
Schedule o JAF has 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, manufacturers 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.
o JAF is targeting the Reactor Outage RO22 (October 2016) for completion of the required modification.
Page 2 of 2}}