IR 05000483/2018011

NRC Inspection of Temporary Instruction 2515/194, Inspection Report 05000483/2018011

ML18289A652
Person / Time
Site:	Callaway
Issue date:	10/16/2018
From:	Greg Werner NRC/RGN-IV/DRS/EB-2
To:	Diya F Ameren Missouri
Werner G
References
IR 2018011
Download: ML18289A652 (13)

Text

ber 16, 2018

SUBJECT:

CALLAWAY PLANT, UNIT 1 - NRC INSPECTION OF TEMPORARY INSTRUCTION 2515/194, INSPECTION REPORT 05000483/2018011

Dear Mr. Diya:

On September 13, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On September 18, 2018, the inspector discussed the results of this inspection with Mr. Roger Wink, Regulatory Affairs Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspector did not identify any findings or violations 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 Gregory Pick Acting for/

Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-483 License Nos. NPF-30 Enclosure:

Inspection Report 05000483/2018011 w/ Attachment: TI 2515/194 Inspection Documentation Request

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s): 05000483 License Number(s): NPF-30 Report Number(s): 05000483/2018011 Enterprise Identifier: I-2018-011-0050 Licensee: Union Electric Company Facility: Callaway Plant Location: Steedman, Missouri Inspection Dates: September 10, 2018, to September 13, 2018 Inspectors: B. Correll, Reactor Inspector Approved By: Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety 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 Callaway Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the Nuclear Regulatory Commission 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 voluntary industry initiative in compliance with Commission guidance. The inspector discussed the licensees open phase condition system design and ongoing implementation plans with plant staff. The inspector reviewed licensee and vendor documentation, and performed system walk downs to verify that the installed equipment was supported by the design documentation. The inspector verified that the licensee had completed the installation and testing of equipment (with the exception of the tripping functions),

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.

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)

The objective of Temporary Instruction 2515/194 is to verify that licensees have appropriately implemented the Nuclear Energy Institute voluntary industry initiative (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 - Voluntary Industry Initiative (Part 1)

Callaway Plant selected a hybrid design using safety-related negative sequence relays and the open phase detection system designed and manufactured by Power System Sentinel Technologies, LLC. At the end of this inspection the system was still in the monitoring mode of operation to facilitate continued data gathering of grid perturbations for evaluation of alarm and trip setpoints. The open phase condition equipment was installed on the safety-related 4160 Vac buses (NB01 and NB02), and the Power System Sentinel Technologies, LLC equipment installed on Safeguards Transformer A (XMDV24). The licensee is scheduled to transition the negative sequence relays to full implementation (tripping functions enabled) by December 31, 2018. The licensee was preparing associated documentation for this transition, however they were not available for review at the time of inspection.

INSPECTION RESULTS

- OBSERVATIONS/ASSESSMENT Based on discussions with the licensee staff, review of available design, testing, grid data trending results documentation, and walk downs of installed equipment, the inspector had reasonable assurance the licensee appropriately implemented the voluntary industry initiative.

The inspector determined that:

Detection, Alarms, and General Criteria TI 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

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

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

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

Protective Actions Criteria TI 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

(1) One transformer was susceptible to an open phase condition and the licensee was implementing design changes to mitigate the effects.

(2) With an open phase condition present and no 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 safety-related negative sequence relays on the safety-related 4160 Vac buses, and a Power System Sentinel Technologies system on the Safeguards B transformer for alarm only. This addition added a new tripping condition (open phase) to safety-related bus incoming supply breakers. The credited plant response was unaffected and would be the same regardless of the conditions that generated the isolation of the transformer.

No findings were identified.

The inspector identified the following exceptions to the Temporary Instruction criteria resulting from the incomplete design modifications:

Detection, Alarms and General Criteria Exceptions TI 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

(1) The licensees design was operating in the monitoring mode with established setpoints enabled to gather data to ensure the open phase condition design and protective schemes would minimize misoperation, or spurious actions in the range of voltage unbalance normally expected in the transmission system. Because actual demonstration of this criterion requires the system to be in operation with final trip setpoints established, the inspector was not able to fully verify this criterion. After discussions with licensee staff, design document and test results reviews, the inspector had reasonable assurance that the actuation circuit design would not result in lower overall plant reliability. The inspector did not identify any issues of concern.

(2) The Final Safety Analysis Report (FSAR) had not been updated to include information related to open phase conditions at the conclusion of the onsite inspection. The licensee provided the inspector 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. The licensee continued to modify and update the proposed changes during the onsite portion of the inspection. The inspector verified the proposed change process is being tracked under License Document Change Notice, LDCN 17-0012 for the completion of the FSAR updates.

The inspector did not identify any issues of concern.

Protective Actions Criteria Exceptions TI 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

(1) The licensees open phase condition design solution uses safety-related negative sequence relays on the 4160 Vac safety buses in a 2-out-of-2 coincidence logic for protection. A voltage unbalance of sufficient magnitude will actuate both negative sequence relays. The relays are designed to trip open the normal and alternate supply breakers to the associated safety bus, causing a loss of voltage to the bus.

The existing undervoltage relays will operate as designed to initiate starting of the emergency diesel generator to restore power to the bus.

The tripping function of the incoming breakers remained disabled during the onsite portion of the inspection and was not able to be demonstrated to perform the designed function. This action was being tracked in the modification package MP 15-0008.

Through review of design documents and discussions with licensee staff, the inspector had reasonable assurance that with an open phase condition present and with and without an accident condition signal, the open phase design would isolate the affected bus and cause an automatic restoration of power from the emergency diesel generators. Due to the configuration of Callaway 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. The inspector did not identify any issues of significance.

(2) At the time of this inspection, the licensee had not finalized documentation for periodic tests, calibrations, setpoint verifications, or inspection procedures associated with the Power System Sentinel Technologies, LLC at the time of this inspection. This action was being tracked in the modification package MP 15-0008. The inspector held discussions with licensee staff and identified that plans were in place to establish contracts with the vendor to provide maintenance and support activities for the Power System Sentinel Technologies, LLC equipment.

The licensee established maintenance activities for the safety-related portion of the open phase condition design, and the inspector verified the activities were appropriate.

Existing plant equipment will continue to be maintained according to the licensees current preventative maintenance program. The inspector did not identify any issues of concern.

EXIT MEETINGS AND DEBRIEFS

On September 18, 2018, the inspector conducted a telephonic exit to present the Temporary Instruction 2515/194 inspection results to Mr. R. Wink, Regulatory Affairs Manager, and other members of the licensee staff. The inspector verified no proprietary information was retained.

DOCUMENTS REVIEWED

Inspection Procedure TI 2515/194

Condition Reports

201707350 201707586 201802205 201802672

Drawings

Number Title Revision

8618-X-94076 Metering and Relaying 345-13.8KV Safeguard 8

Transformers POSN-V22 and V24

8618-X-94091 345-13.8KV SFGD XFMR-B AC Portion 11

8618-X-94726 Annunciator -1 Sheet -2 Drop -51 Thru 96, 98, & 100 18

8618-X-94760 Alarms and Metering to Plant Unit-1 ANN., BOP 22

Computer and Site Related Panel

8618-X-95741 345-13.8KV SFGD XFMR-B DC Portion 11

E-21001 Main Single Line Diagram 25

E-21023 Relay Setting Tabulations and Coordination Curves 27

System NB

E-21NB01 Lower Medium Voltage System Class 1E 4.16KV 11

Single Line Meter and Relay Diagram

E-21NB02 Lower Medium Voltage System Class 1E 4.16KV 17

Single Line Meter and Relay Diagram

E-23NB01 Lower Medium Voltage System Class 1E 4.16KV 9

Three Line Meter and Relay Diagram

E-23NB03 Lower Medium Voltage System Class 1E 4.16KV 18

Three Line Meter and Relay Diagram

E-23NB04 Lower Medium Voltage System Class 1E 4.16KV 8

Three Line Meter and Relay Diagram

E-23NB06 Lower Medium Voltage System Class 1E 4.16KV 10

Three Line Meter and Relay Diagram

E-23NB12 Class 1E Bus NB01 Feeder Brkr 152NB0112 12

E-23NB13 Class 1E Bus NB01 Feeder Brkr 152NB0109 11

E-23NB14 Class 1E Bus NB02 Feeder Brkr 152NB0209 13

E-23NB15 Class 1E Bus NB02 Feeder Brkr 152NB0212 12

Engineering Studies

Number Title Revision

MP 15-0008 Engineering Disposition - Modification Open Phase 007

Condition Protection

NB-05 System NB Protective Relay Setpoints 004, Addendum

ZZ-561 Open Phase Fault Study for the Callaway Energy 000

Center

Miscellaneous

Documents Revision

Number Title or Date

DCN: IEGR-DD-1672 Open Phase Protection (OPP) System Non-Class 1E 0.0.1

OPP Protection Settings, Ameren-Callaway SFGD-B

DCN: ITST-TP-1704 Open Phase Protection (OPP) System Site 0.0.2

Acceptance Test (SAT) Plan Single Channel Analog

System for the Callaway Nuclear Plant

TSTF Evaluation of Inclusion of Open Phase Condition October 8, 2015

Equipment Requirements in the Technical

Specifications

LOCT/NLOCT Large Transformers January 25,

T61.0810 8/T61.0740 2018

Cycle 18-1

Modification

Number Title Revision

MP 15-0008 Open Phase Condition Protection 000

Procedures

Number Title Revision

MPE-ZZ-QY055 Inspection, Test and Calibration of Protective 000

Negative Sequence Overvoltage Relays, ABB

Type 60Q

MPE-ZZ-QY109 Operational Test Sequence of 4.16KV Bus NB01 011

Main Air Circuit Breaker 152NB0109

MPE-ZZ-QY112 Operational Test Sequence of 4.16KV Bus NB01 011

Main Air Circuit Breaker 152NB0112

MPE-ZZ-QY126 Operational Test Sequence of 4.16KV Bus NB02 013

Main Air Circuit Breaker 152NB0209

MPE-ZZ-QY129 Operational Test Sequence of 4.16KV Bus NB02 011

Main Air Circuit Breaker 152NB0212

Procedures

Number Title Revision

OTA-RK-00016, NB02 Bus Undervoltage 000

Addendum 21B

OTA-RK-00016, NB02 Undervoltage Relay 1/4 001

Addendum 21D

OTA-RK-00016, NB02 Bus Degraded Voltage or Phase Imbalance 003

Addendum 22E

OTA-ZZ-00SA1, Safeguards Transformer B Open Phase Trouble 002

Addendum 77

OTO-NB-00002 Loss of Power to NB02 031

Vendor Document

Number Title Revision

IB 7.4.1.7-3 ABB Phase Unbalance Relay Issue C

TI 2515/194 Inspection Documentation Request

Please provide the following documentation (Items 1 - 8) to the lead inspector prior to the onsite

inspection date, preferably no later than August 27, 2018. Whenever practical, please provide

copies electronically (IMS/CERTREC is preferred). 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).

Brian Correll, Lead Inspector

RIV/DRS/EB2

1600 E. Lamar Blvd.

Arlington, TX 76011

817-200-1565

brian.correll@nrc.gov

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 SSCs; 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 10 CFR 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 (UFSAR)

and/or Technical Specifications (TS), as applicable, which discuss the design features and

analyses related to the effects of, and protection for, any open phase condition design

vulnerability. If these documents have not been updated, provide documentation of your

plans to do so.

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 SSCs, OR

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.

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.

9. 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.

10. 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; (b) the locations of

detection and indication equipment used in the open phase condition sensing circuits.

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

coordination with the other protective devices in both the offsite electrical system (within

Callaway Plant area of responsibility) and the onsite electrical systems.

2. Access to locations in which open phase condition equipment is installed or planned (i.e.

switchyard, etc.)

Copies of documentation or testing that demonstrates your OPC solution minimizes spurious

actuation or misoperation in the range of voltage imbalance normally expected in the

transmission system that could cause undesired separation from an operable off-site power

source.

This document 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 31500011. 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.

This document 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.

ML18289A652

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: BKC Yes No Publicly Available Sensitive

OFFICE RI: EB2 C:EB2 C:PBB C:EB2

NAME BCorrell GWerner NTaylor GWerner

SIGNATURE /RA/ /RA/ /RA/ /RA/GAP for

DATE 09/21/2018 10/10/2018 10/13/2018 10/16/2018