IR 05000400/2019012

NRC Temporary Instruction 2515/194 Inspection Report 05000400/2019012

ML19175A270
Person / Time
Site:	Harris
Issue date:	06/24/2019
From:	Christopher Even NRC/RGN-II, Division Reactor Projects II, NRC/RGN-II/DRP/RPB4
To:	Hamilton T Duke Energy Carolinas
Geanette D
References
IR 2019012
Download: ML19175A270 (11)

Text

une 24, 2019

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC TEMPORARY INSTRUCTION 2515/194 INSPECTION REPORT 05000400/2019012

Dear Ms. Hamilton:

On May 16, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Shearon Harris Nuclear Power Plant and discussed the results of this inspection with Mr. J Dills and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) 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/

Christopher Even, Chief (Acting)

Construction Inspection Branch 2 Division of Construction Oversight Docket No.: 05000400 License No.: NPF-63

Enclosure:

Inspection Report 05000400/2019012

Inspection Report

Docket Number: 05000400 License Number: NPF-63 Report Number: 05000400/2019012 Enterprise Identifier: I-2019-012-0014 Licensee: Duke Energy Progress, LLC Facility: Shearon Harris Nuclear Power Plant Location: New Hill, NC 27562 Inspection Dates: May 13, 2019 to May 16, 2019 Inspectors: G. Crespo, Sr. Construction Inspector J. Kent, Construction Inspector Approved By: Christopher Even, Chief (Acting)

Construction Inspection Branch 2 Division of Construction Oversight Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting Temporary Instruction 2515/194, Inspection of the Licensees Implementation of Industry Initiative Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (NRC Bulletin 2012-01), at Shearon Harris Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings were identified.

Additional Tracking Items None.

INSPECTION SCOPE

This inspection was conducted using Temporary Instruction 2515/194 (ADAMS Accession No. ML17137A416), dated October 31, 2017. The inspectors reviewed the licensees implementation of Nuclear Energy Institute (NEI) voluntary industry initiative (VII) in compliance with Commission guidance. The inspectors discussed the licensees open phase condition system design and ongoing implementation plans with plant staff. The inspectors reviewed licensee documentation, vendor documentation, and performed system walkdowns to verify that the installed equipment was supported by the design documentation. These reviews were also made to determine if the licensee had completed the installation and testing of equipment, installed and tested alarming circuits both local and in the control room, and analyzed potential impacts associated with the design implementation on the current licensing basis. The inspectors reviewed the positioning of the control switches in the individual system cabinets to verify the status of the system tripping functions. These tripping functions of the system had not been activated, however they were wired and ready to be activated from the control switches in the front of the system cabinets.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL Temporary Instruction 2515/194 - Inspection of the Licensees Implementation of Industry Initiative Associated With the Open Phase Condition Design Vulnerabilities In Electric Power

Systems (NRC Bulletin 2012-01) (1 Sample)

The objective of Temporary Instruction 2515/194 is to verify that licensees have appropriately implemented the NEI VII (ADAMS Accession No. ML15075A454), dated March 16, 2015, including updating their licensing basis to reflect the need to protect against open phase conditions.

Temporary Instruction 2515/194-03.01 - VII (Part 1)

Shearon Harris Nuclear Power Plant selected the open phase detection system designed and manufactured by Power System Sentinel Technologies, LLC. At the end of this inspection, the system remained in the monitoring mode of operation to facilitate continued data gathering of grid perturbations for evaluation of alarm and trip setpoints. The equipment was installed on the start-up transformers (SUT)-1A and SUT-1B. The licensee is scheduled to transition the open phase detection system to full implementation (tripping functions enabled) by December

INSPECTION RESULTS

Based on discussions with the licensee staff, review of available design, testing, grid data trending results documentation, and walkdowns of installed equipment, the inspectors had reasonable assurance the licensee appropriately implemented the VII.

The inspectors determined:

Assessment 2515/194 Detection, Alarms, and General Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) Open phase conditions will be detected and alarmed in the control room on the common annunciator panel.

(2) Detection circuits will be sensitive enough to identify an open phase condition for all credited loading conditions for installed equipment.

(3) No Class-1E circuits were being replaced with non-Class 1E circuits in the design.

(4) The updated final safety analysis report (UFSAR) has been updated to discuss the design features and analyses related to the effects of, and protection for, and open phase condition (OPC) design vulnerability.

Assessment 2515/194 Protective Actions Criteria; TI 2515/194-03.01 - VII (Part 1)

(1) Two transformers were susceptible to an open phase condition and the licensee had installed detection and mitigating equipment for both.

(2) With an open phase condition present and with or without an accident condition signal, the open phase design would not adversely affect the function of important-to-safety systems, structures, or components. The licensees open phase condition design solution added two Power System Sentinel Technologies, LLC systems on the start-up transformer SUT-1A and SUT-1B. The tripping function, when enabled, will provide an additional input to the associated transformer lockout relays. The credited plant response is unaffected and will be the same regardless of the conditions that generated the lockout of the transformer.

The inspectors identified the following exceptions to the Temporary Instruction criteria resulting from the operating status of the design modifications:

Assessment 2515/194 Detection, Alarms, and General Criteria Exceptions; TI 2515/194-03.01 - VII (Part 1)

(1) The licensees design was operating in the monitoring mode with already established setpoints and gathering data to ensure the open phase condition design and protective schemes would minimize mis-operation, or spurious actions in the range of voltage unbalance normally expected in the transmission system. The licensee developed engineering calculations to demonstrate coordination of the OPC detection and tripping setpoints for the actuation circuit that does not result in lower overall plant operation reliability. This calculation was presented in HNP E5-0007, Open Phase Protection System Evaluation.

(2) A draft of the UFSAR was available for the inspectors review that included information related to open phase conditions. The licensee provided the inspectors with proposed changes to the licensing basis that discussed the system requirements related to the effects of, and protection for, any open phase condition design vulnerability.

Assessment 2515/194 Protective Actions Criteria Exceptions; TI 2515/194-03.01 - VII (Part 1)

(1) The licensees open phase condition design solution uses Power System Sentinel Technologies, LLC to detect, alarm, and provide an input to the associated SUT transformer lockout relays. Upon transformer lockout, the existing undervoltage relays would operate as designed to initiate starting of the emergency diesel generator to restore power to the bus.

The tripping function input to the transformer lockout relays remained deactivated during the onsite system implementation inspection and was not able to be demonstrated to perform the designed function. This action was being tracked in the design change package EC 402237, which provides for the final electrical terminations required to enable the open phase protection (OPP) system SUT lockout function. Once enabled, the OPP system will have the ability to isolate an affected SUT with a OPC detected on the high side of the SUTs.

Due to the configuration of Shearon Harris Nuclear Power Plants electrical distribution system, a loss of phase on one transformer would only affect one train of equipment, and loads required to mitigate postulated accidents would be available on the non-affected train, ensuring that safety functions are preserved as required by the current licensing bases.

(2) Periodic tests, calibrations, setpoint verifications or inspections (as applicable) have been established for any new protective features. The surveillance requirements have been maintained for the plant Technical Specifications (TSs) in compliance with the provisions of 10 CFR 50.36.

The licensee has included preventive maintenance activities for the installed equipment as part of Work Orders 20139791-01 and 20139792 -01. Existing plant equipment will continue to be maintained according to the licensees current preventative maintenance program.

The inspectors identified the following observation:

Observation 2515/194 The inspectors identified a condition presented as an observation to the licensees staff concerning the raceway used to route the high side neutral conductor from the H0 terminal post through the OPP system cabinets and finally to ground. This is a solidly grounded system on the transmission lines feeding the two startup transformers SUT-1A and SUT-1B primary side. The neutral ground connection cable is a 1/C 4/0 AWG Copper RSCC 600V 90 DEG C FIREWALL(R) III-J (UL) VW-1 SUN RES OIL RES II FOR CT USE TYPE RHH OR RHW-2 XLPE CSPE FMRC GP-1 P62-5093 as inscribed on the cable. This insulated cable is routed through a ferrous rigid galvanized 2 conduit that is not connected to this cable at either end of the run. The inspectors obtained information on the short circuit available current in the event of a phase to ground short in the primary feeder. The magnitude of the current from a line to ground short would exceed 26,000 amps. Since this is only a single conductor with current flow in only one direction at any time, it may inductively magnetize the conduit and present a choking type restriction to the current flow to ground. This choking type restriction may cause the system to be less sensitive to an open phase condition. An Action Request - 02253069 - 07 was generated to review and document this observation.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On May 16, 2019, the inspector presented the NRC inspection results to Mr. J Dills and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Calculations HNP E5-0007 Open Phase Protection System Setpoint Evaluation 03

Corrective Action A/R 02253069 Evaluate NRC Observation of the installation of the SUT high

Documents Assignment NBR side neutral conductor being installed in ferrous conduit from

the SUT Neutral to the OPPS cabinets

EC 296261 A/R Screen to implement the 1st phase of the NEI initiative to

01977405 mitigate the OPC design vulnerability on the offsite power

system

EC 402237 A/R Provides the final electrical terminations required to enable

2079940 the OPP system SUT lockout function

EC402237 A/R 10 CFR 50.59 Evaluation will physically connect the OPP

2079940 system installed under EC 296261 to the corresponding SUT

lockout relay. Once implemented, the OPP system will be

capable of locking-out a SUT

EC402237 A/R Provides for the final electrical terminations required to

Number: 2090444 enable the OPP system SUT lockout function. Once enabled,

the OPP system will have the ability to isolate an affected

SUT with a OPC detected on the high side of the SUTs

Drawings CAR 2166 B-401 Control Wiring Diagram - Spent Fuel Pool Instrumentation 07

HNP 1364- Open Phase CH 1 Electrical Drawings 00

099317 S01

HNP 1364- Open Phase CH 1 Electrical Drawings 01

099317 S02

HNP 1364- Open Phase CH 1 Electrical Drawings 01

099317 S07

HNP 1364- Open Phase CH 1 Electrical Drawings 00

099317 S13

HNP 1364- Open Phase CH 2 Electrical Drawings 00

099318 S06

HNP 1364- Open Phase CH 2 Electrical Drawings 00

099318 S07

HNP 6-B-401 Control Wiring Diagram A Start-up Transformers Protection 18

1614 Lockout Relay 86/STUA Sh. 1

Inspection Type Designation Description or Title Revision or

Procedure Date

HNP 6-B-401 B Start-up Transformers Protection Lockout Relay 86/STUB 17

1614A Sheet 1

HNP 6-B-401 B Start-up Transformer Open Phase Protection System 01

1617A Control Cabinets

HNP 6-G-0029 Main & 6900 Volt Auxiliary One Line Wiring Diagram 28

HNP CAR 2166 - Start-up Transformer Protective Relaying & 6.9 KV Bus 05

G-040 Transfer Logic Diagram Unit 1

HNP PD5165-BC- AC Power Distribution System Unit 1 15

Engineering EC 0000296261 Installation of PSStech OPP System on Startup Transformer 14

Changes EC 0000402237 SUT Open Phase Fault Detection and Protection 03

Miscellaneous AD-LS-ALL-0005 UFSAR Change Summary Form 04

AD-LS-ALL-0015 EC 402237R3 TS Bases 3 / 4.8 05

Z07 - Open Phase Protection (OPP) System Operating and 0.0.2

IEGR-MN-317 Maintenance Manual

Open Phase Protection (OPP) System - Non-Class 1E OPP 0.0.5

Z08R002 - IEGR- Protection Settings, Harris Start-up Transformer

DD-867

IER 17-5 Simulator Training, Lesson IER-SIM-18.0 01

NCP-E-0002 CONTROL CABLE AND LOW VOLTAGE POWER CABLE 00

Power System Power System Sentinel Technologies OPD Industry Training 02/07/2017

Sentinel

Technologies

OPD

Required Reading Required Reading OPS-JITI-12-25 10/25/2012

OPS-JITI-12-25

Required Reading IER2 12-14, Automatic Scram at Byron NPS 03/13/2014

OPS-JITI-14-09

Required Reading Open Phase Protection System (EC 296261) 07/24/2017

OPS-JITI-17-05

Procedures AOP-039 STARTUP AND UNIT AUXILIARY TRANSFORMER 15

TROUBLE

AOP-039-BD STARTUP AND UNIT AUXILIARY TRANSFORMER 19

TROUBLE

Inspection Type Designation Description or Title Revision or

Procedure Date

APP-ALB-022 MAIN CONTROL BOARD (Annunciator Panel Procedure) 91

APP-ALB-023 AUXILIARY EQUIPMENT PANEL NO. 1 (Annunciator Panel 51

Procedure)

OP-116 FUEL POOL COOLING SYSTEM 43

OP-156.02 AC ELECTRICAL DISTRIBUTION 165

OST-1023 OFF SITE POWER AVAILABILITY VERIFICATION WEEKLY 34

INTERVAL MODES 1, 2, 3, 4, 5, 6

Work Orders 20139791 01 EL, EC 407016, SUT-A, SUT OPEN PHASE FAULT DET & 08/31/2017

PROTECTION

20139792 01 EL, EC 407017, SUT-B, SUT OPEN PHASE FAULT DET & 08/15/2017

PROTECTION

9