ML21076A511

Information Request to Support Upcoming Temporary Instruction 2515/194 Inspection; Inspection Report 05000461/2021013

ML21076A511
Person / Time
Site:	Clinton
Issue date:	03/17/2021
From:	Ijaz Hafeez Engineering Branch 3
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2021013
Download: ML21076A511 (6)

See also: IR 05000461/2021013

Text

March 17, 2021

Mr. David Rhoades

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATIONINFORMATION REQUEST TO SUPPORT

UPCOMING TEMPORARY INSTRUCTION 2515/194 INSPECTION; INSPECTION

REPORT 05000461/2021013

Dear Mr. Rhoades:

This letter is to request information to support our inspection of the Industry Initiative Associated

with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (U.S. Nuclear

Regulatory Commission (NRC)Bulletin 2012-01) beginning May 24, 2021, at your Clinton

Power Station. This inspection will be performed in accordance with the NRC Temporary

Instruction 2515/194.

In order to minimize the impact that the inspection has on the site and to ensure a productive

inspection, we have enclosed a list of documents requested for the inspection. Please provide

this information prior to April 24, 2021. It is important that all of these documents are up to date

and complete in order to minimize the number of additional documents requested during the

preparation and/or the onsite portions of the inspections. Insofar as possible, this information

should be provided electronically to the lead inspector.

The lead inspector for this inspection is Mr. I. Hafeez. We understand that our licensing contact

for this inspection is Mr. N. Santos of your organization. If there are any questions about the

inspection or the material requested in the enclosure, please contact the lead inspector at

630-829-9843 or via e-mail at Ijaz.Hafeez@nrc.gov.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

D. Rhoades -2-

This letter and its enclosure 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/

Ijaz Hafeez, Reactor Engineer

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Document Request for Temporary

Instruction 2515/194 Inspection

cc: Distribution via LISTSERV

D. Rhoades -3-

Letter to David Rhoades from Ijaz Hafeez dated March 17, 2021.

SUBJECT: CLINTON POWER STATION INFORMATION REQUEST TO SUPPORT

UPCOMING TEMPORARY INSTRUCTION 2515/194 INSPECTION; INSPECTION

REPORT 05000461/2021013

DISTRIBUTION:

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Mark Haire

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John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

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ADAMS Accession Number: ML21076A511

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME IHafeez:mb

via e-mail

DATE 03/17/2021

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION

Inspection Report: 05000461/2021013

Inspection Dates: May 24, 2021, through May 28, 2021

Inspection Procedures: 2515/194-TI-2515-Phase 5

Inspector: Ijaz Hafeez

630-829-9843

Ijaz.Hafeez@nrc.gov

Please provide the following documentation (Items 1-9) to the lead inspector prior to the onsite

inspection date, preferably no later than April 24, 2021. Whenever practical, please provide

copies electronically. Please provide an index of the requested documents which includes a

brief description of the document and the numerical heading associated with the request (i.e.,

where it can be found in the list of documents requested).

1. Copies of any calculations, analyses, and/or test reports performed to support the

implementation of your open phase condition (OPC) solution. If, in your implementation,

OPCs are not detected and alarmed in the control room please include documentation

that: (a) demonstrates the OPC will not prevent functioning of important-to-safety

structures, systems, and components; and (b) detection of an OPC will occur within a

short period of time (e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

2. Copies of any modification packages, including Title 10 of the Code of Federal

Regulations, Part 50.59 evaluations if performed, used for or planned for the

implementation of your OPC solution.

3. Copies of periodic maintenance, surveillance, setpoint calibration, and/or test

procedures implemented or planned, for your OPC solution.

4. Copies of your licensing basis changes to Updated Final Safety Analysis Report and/or

Technical Specifications, as applicable, which discuss the design features and analyses

related to the effects of, and protection for, any OPC design vulnerability.

5. Copies of any procurement specifications and acceptance testing documents related to

the installation of your OPC solution.

6. Copies of any site training the team will need to accomplish to gain access to areas with,

or planned, major electrical equipment used in your OPC solution (i.e., switchyard).

7. Provide documentation showing that with an OPC occurrence and no accident condition

signal present, either:

a. An OPC does not adversely affect the function of important-to-safety structures,

systems, and components; or

Enclosure

DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION

b. TS LCOs are maintained, or the TS actions are met without entry into TS

LCO 3.0.3, and

i. Important-to-safety equipment is not damaged by the OPC; and

ii. Shutdown safety is not compromised.

8. With OPC occurrence and an accident condition signal present:

a. Provide documentation showing that automatic detection and actuation will

transfer loads required to mitigate postulated accidents to an alternate source

and ensure that safety functions are preserved, as required by the current

licensing bases; or

b. Provide documentation showing that all design basis accident acceptance criteria

are met with the OPC, given other plant design features. Accident assumptions

must include licensing provisions associated with single failures. Typically,

licensing bases will not permit consideration of the OPC as the single failure

since this failure is a non-safety system.

9. For those licensees that opted to demonstrate that operator manual actions will be

sufficient to mitigate the impact of an OPC, in accordance with VII, Revision 3,

Attachment 1 and NEI 19-02, Guidance for Assessing Open Phase Condition

Implementation Using Risk Insights, instead of automatic protective actions discussed

in Section 03.02.b of TI 2515/194, Revision 2, provide the following:

a. Copies of any PRA evaluations for your plant response to an OPC including your

Human Reliability Analysis (HRA) and sensitivity analyses; and

b. Procedure(s) and operator actions required to respond to an OPC alarm and

potential equipment trip.

Please provide the following documentation to the team when they arrive onsite. Whenever

practical, please provide copies electronically, except for drawings. Drawings should be

provided as paper copies of sufficient size (ANSI C or D) such that all details are legible.

1. A brief presentation describing your electric power system design and typical electrical

transmission and distribution system alignments; OPC design schemes installed to

detect, alarm and actuate; bus transfer schemes; and maintenance and surveillance

requirements. This presentation should be a general overview of your system. Please

schedule the overview shortly after the entrance meeting.

2. Plant layout and equipment drawings for areas that identify: (a) the physical plant

locations of major electrical equipment used in your open phase condition solution; and

(b) the locations of detection and indication equipment used in the OPC sensing circuits.

3. If OPC actuation circuits are required, provide documentation that demonstrates

continued coordination with the other protective devices in both the offsite electrical

system (within Clinton Power Station area of responsibility) and the onsite electrical

systems.

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DOCUMENT REQUEST FOR TEMPORARY INSTRUCTION 2515/194 INSPECTION

4. Access to locations in which OPC equipment is installed or planned (i.e., switchyard,

etc.).

5. Copies of documentation or testing that demonstrates your OPC solution minimizes

spurious actuation or mis operation in the range of voltage imbalance normally expected

in the transmission system that could cause undesired separation from an operable

off-site power source.

3