ML18309A227

October 17, 2018, Summary of Public Meeting Between the U.S. Nuclear Regulatory Commission and Nuclear Energy Institute and Industry Representatives-Industry Actions on Open Phase Conditions (NRC Bulletin 2012-01)

ML18309A227
Person / Time
Issue date:	11/09/2018
From:	Leslie Perkins NRC/NRR/DLP/PLPB
To:	Dennis Morey NRC/NRR/DLP/PLPB
Perkins L, 415-2375
References
2012-01
Download: ML18309A227 (5)

Text

November 9, 2018 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM: Leslie Perkins, Project Manager /RA/

Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation

SUMMARY

OF OCTOBER 17, 2018, PUBLIC MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NUCLEAR ENERGY INSTITUTE AND INDUSTRY REPRESENTATIVES-INDUSTRY ACTIONS ON OPEN PHASE CONDITIONS (NRC BULLETIN 2012-01)

On October 17, 2018, a Category 2 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of the Nuclear Energy Institute (NEI) and nuclear power plant industry. The purpose of the meeting was to discuss industrys responses to NRC staff questions on the open phase condition (OPC) voluntary industry initiative (VII) in three topics of interest: (1) OPC protective actions, (2) updated final safety analysis report (UFSAR) changes, and (3) Technical Specifications (TS) surveillance & limiting conditions for operation (LCO) requirements. This was a follow-up to a September 19, 2018 public meeting (meeting summary available at Agency-wide Documents Access and Management System (ADAMS) Accession No. ML18268A346) where the NRC discussed questions for the industry of its implementation of the OPC VII. No regulatory decisions were made during this meeting.

The meeting began with introductions and opening remarks followed by a member of the technical specification tasks force (TSTF) providing their response to the staffs questions concerning surveillance & LCO TS requirements (ADAMS Accession No. ML18289A980).

Industry representatives also presented information to address the staffs questions on the above three topic areas (ADAMS Accession No. ML18289A992). During the discussion, industry provided responses and clarification to staffs questions on how the NEI VII is being implemented. For example, if the open phase isolation system (OPIS) is non-functional and unable to isolate an OPC, plant procedures would be followed and manual actions will be taken by the operators, including implementing compensatory measures until the OPIS is restored.

With respect to updating TSs, industry stated that the existing LCO 3.8.1, LCO 3.8.2, and SR 3.8.1.1 for offsite sources require offsite circuits to be operable and an OPC not to be present.

Additionally, industry determined that the OPIS does not satisfy any of the 10 CFR 50.36 criteria and should not be included in TSs. The industry described that the review of whether TS requirements would be applicable was conducted in 2015 and provided to the NRC staff

D. Morey (ADAMS Accession No. ML18262A377). The NRC staff asked industry whether a comparison of protective relay settings for loss of offsite power and degraded voltage conditions was performed. The industry responded by stating that the OPIS is not similar to the protective relay settings associated with the degraded voltage conditions because the OPIS is installed as a non-safety related system that supports the performance of the safety function of the offsite power source by monitoring and separating an inoperable offsite source. Further, industry provided examples of other support systems for offsite power sources that do not require TSs.

Regarding UFSAR updates, industry presented examples that described the level of details for UFSAR updates in accordance with 10 CFR 50.71(e).

During the discussion, staff asked several clarifying questions on each topic of interest. At the end of meeting, NRC staff informed industry that it would use the information discussed in the public meetings, information provided by industry as part of its efforts to address OPC vulnerabilities, the staffs preliminary risk assessment on the impact of OPC (ADAMS Accession No. ML17234A631), and the functional criteria described in the November 25, 2014, NRC letter to NEI (ADAMS Accession No. ML15075A454) to determine whether the licensees are adequately addressing potential OPC vulnerabilities.

The industry anticipates sending a letter to formally respond to the NRC questions and address feedback provided by NRC staff during the meeting. The staff will consider this information in evaluating actions to close Bulletin 2012-01.

CONTACT: Leslie Perkins, DLP/PLPB (301) 415-2375

Enclosures:

List of Attendees NEI Slide Presentation TSTF Slide Presentation Meeting Notice

ML18309A227 Mtg. Summary; ML1829A980 NEI Slide Presentation; ML18289A992 TSTF Slide Presentation; ML18277A137, Mtg. Notice; ML18309A226, Package OFFICE NRR/DLP/PLPB PM NRR/DE/EEOB NRR/DLP/PLPB/D NRR/DLP/PLPB/PM NAME LPerkins JQuichocho DMorey (JRowley for) LPerkins DATE 11/07/2018 11/07 /2018 11/9/2018 11/9/2018 List of Attendees Names Organization Mitch Mathews Exelon Kazimierz Leja Exelon Robert Carritte MPR Associates Brian Mann EXCEL Services Corporation Stephen Geier Nuclear Energy Institute (NEI)

Frances Pimentel NEI Maggie Staizes NEI Greg Krueger NEI ED Miller U.S. Nuclear Regulatory Commission (NRC)

Ed Miller NRC Roy Mathew NRC Margaret Chernoff NRC Sarah Elkhiamy NRC Jessie Guichocho NRC Jeremy Bowen NRC Leslie Perkins NRC G.S. Matharu NRC W. Orders NRC H. Kodali NRC Peter Snyder NRC Glenn Dentel NRC David Decker NRC Guillermo Crespo NRC Hassan Movafegh Talen Energy - affiliated with Susquehanna plants Mike Wiwel PSEG Nuclear Jeffrey Krov Pacific Gas and Electric Company David Hantman Pacific Gas and Electric Company Gary Miller Dominion Energy Greg Miller Dominion Energy Kelvin Ali Sargent & Lundy James Reynolds Sargent & Lundy Joe Krvavac Sargent & Lundy Boyd Shingleton Duke Energy Wesley Kijowski Duke Energy Elizabeth Hare DTE Energy Susan Richards DC Cook Thomas Braudt Certrec Gregory Norris Entergy Services Mike Mustafa Entergy Services Mark Rice Entergy Northwest Tamatha Womack Tennessee Valley Authority (TVA)

Preston Cooper TVA Christopher Riedl TVA Jana Bergman Curtiss-Wright Enclosure

Names Organization Gregg Reimers Public Bob Hirmanpour Southern Nuclear Brian Cates Southern Nuclear Cheryl Gayheart Southern Nuclear Bonnie Goodwin Southern Nuclear Saed Almajdoubah Wolf Creek Nuclear Operating Corporation Larry Parker Stars Alliance Ayodele Ishola-Salawu NextEra Energy Nuclear Fleet