PLA-7126, Response to Request for Additional Information Regarding Response to NRC Bulletin 2012-01, Design Vulnerability in Electric Power System, (ML13351A314)

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Response to Request for Additional Information Regarding Response to NRC Bulletin 2012-01, Design Vulnerability in Electric Power System, (ML13351A314)
ML14031A086
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 01/30/2014
From: Franke J
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-12-001, PLA-7126
Download: ML14031A086 (5)
v • d • e


Text

Jon A. Franke PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504 JAN 3 0 2014 jfranke@ pplweb.com U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC

  • 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE TO NRC BULLETIN 2012-01, DESIGN VULNERABILITY IN ELECTRIC POWER SYSTEM Docket No 50-387 PLA-7127 and No. 50-388

References:

1. NRC Bulletin 2012-01, "Design Vulnerability in Electric Power System,"

dated July 27, 2012 (Accession ML12074A115).

2. PPL Letter (PLA-6919), titled "Susquehanna Steam Electric Station, 90-Day Response to NRC Bulletin 2012-01," dated October 24, 2012.
3. NRC Letter, titled "Request for Additional1nformation Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System,"

dated December 20, 2013 (Accession ML13351A314).

The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide a response to the request for additional information contained in Reference 3. The written response was requested by February 3, 2014. The information requested relates to the status of interim and long-term corrective actions at Susquehanna Steam Electric Station (SSES). The NRC Bulletin 2012-01 requested information about each facility's electric power system designs and operating experience, involving design vulnerability to open phase conditions on the offsite power circuits for Class-1E vital buses. The requested additional information is in to this letter.

There are no new regulatory commitments associated with this response.

If you have any questions or require additional information, please contact Mr. Duane L. Filchner (570) 542-6501.

Document Control Desk PLA-7127 I declare under penalty of perjury that the foregoing is true and correct.

6\ I 10 Executed on: _ _ _ __ _(_?a_ cY Sincerely, J. A. Franke Attach nts: Response to Request for Additional Information Copy: NRC Region I Mr. J. Greives, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP

.1 '

Attachment 1 to PLA-7127 Response to Request for Additional Information

Attachment 1 to PLA-7127 Page 1 of2 Response to Request for Additional Information NRC Request for Additional Information (RAJ):

In order for the NRC staff to complete its review of responses to the bulletin, the following additional information is requested.

1. 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.
2. Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power.

PPL's RESPONSE:

1. Summary of all Interim Corrective Actions Since January 30, 2012, PPL Susquehanna, LLC (PPL) has reviewed the open phase condition (OPC) events at Byron station and the lessons learned within the industry. PPL developed and implemented the following interim corrective actions for the Susquehanna Steam Electric Station (SSES) to ensure plant operators can promptly diagnose and respond to an OPC:

Interim Corrective Actions:

  • Walk-downs of the three SSES switchyards are on-going on a weekly basis to visually inspect line terminals and insulators for identification of abnormalities.
  • Operations procedures were revised to include symptoms potentially caused by OPC.
  • Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
  • Infrared inspections of yard equipment are performed as part of routine inspections.
2. "Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power. "

Status:

  • SSES OPC vulnerability studies have been started and are currently still on-going.
  • Currently there is no generic, off-the-shelf technology that has been proven to detect all the required open phase fault conditions for all power plant and transformer designs. As such, SSES in collaboration with other nuclear power operating license holders is investigating options being researched by several vendors (PCS2000, EPRI, Schweitzer, etc.) to detect OPC faults .

Attachment 1 to PLA-7127 Page 2 of2 Response to Request for Additional Information

  • With the goal of ensuring reliability and accuracy, (e.g., detection without compromising nuclear safety or increase plant risk), new OPC detection technology is being thoroughly evaluated and analyzed. This technology will be tested and then monitored in operation.
  • SSES remains actively engaged in various OPC industry initiatives such as the Nuclear Energy Institute (NEI) OPC working groups for the development of an OPC Guidance Document as well as enhancements to software tools being used to analyze OPC faults.

Schedule:

  • SSES will follow the generic schedule that is provided in the NEI 13-12 OPC Industry Guidance Document, issued in December 2013, to support addressing OPC in off-site power sources at nuclear power plants.
  • It is the intention of SSES to meet the milestones of this schedule; however, deviations may be required to accommodate outage schedules, software and hardware availability, manufacturer's delivery capabilities, licensing delays, etc.
  • Deviation from the Industry OPC Initiative schedule will be documented through the deviation/exemption process addressed in the NEI OPC Guidance Document.

Text

Jon A. Franke PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504 JAN 3 0 2014 jfranke@ pplweb.com U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC

  • 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE TO NRC BULLETIN 2012-01, DESIGN VULNERABILITY IN ELECTRIC POWER SYSTEM Docket No 50-387 PLA-7127 and No. 50-388

References:

1. NRC Bulletin 2012-01, "Design Vulnerability in Electric Power System,"

dated July 27, 2012 (Accession ML12074A115).

2. PPL Letter (PLA-6919), titled "Susquehanna Steam Electric Station, 90-Day Response to NRC Bulletin 2012-01," dated October 24, 2012.
3. NRC Letter, titled "Request for Additional1nformation Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System,"

dated December 20, 2013 (Accession ML13351A314).

The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide a response to the request for additional information contained in Reference 3. The written response was requested by February 3, 2014. The information requested relates to the status of interim and long-term corrective actions at Susquehanna Steam Electric Station (SSES). The NRC Bulletin 2012-01 requested information about each facility's electric power system designs and operating experience, involving design vulnerability to open phase conditions on the offsite power circuits for Class-1E vital buses. The requested additional information is in to this letter.

There are no new regulatory commitments associated with this response.

If you have any questions or require additional information, please contact Mr. Duane L. Filchner (570) 542-6501.

Document Control Desk PLA-7127 I declare under penalty of perjury that the foregoing is true and correct.

6\ I 10 Executed on: _ _ _ __ _(_?a_ cY Sincerely, J. A. Franke Attach nts: Response to Request for Additional Information Copy: NRC Region I Mr. J. Greives, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP

.1 '

Attachment 1 to PLA-7127 Response to Request for Additional Information

Attachment 1 to PLA-7127 Page 1 of2 Response to Request for Additional Information NRC Request for Additional Information (RAJ):

In order for the NRC staff to complete its review of responses to the bulletin, the following additional information is requested.

1. 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.
2. Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power.

PPL's RESPONSE:

1. Summary of all Interim Corrective Actions Since January 30, 2012, PPL Susquehanna, LLC (PPL) has reviewed the open phase condition (OPC) events at Byron station and the lessons learned within the industry. PPL developed and implemented the following interim corrective actions for the Susquehanna Steam Electric Station (SSES) to ensure plant operators can promptly diagnose and respond to an OPC:

Interim Corrective Actions:

  • Walk-downs of the three SSES switchyards are on-going on a weekly basis to visually inspect line terminals and insulators for identification of abnormalities.
  • Operations procedures were revised to include symptoms potentially caused by OPC.
  • Transformer yard rounds are performed daily and include general and detailed inspections of the transformers to ensure parameters are within expected limits.
  • Infrared inspections of yard equipment are performed as part of routine inspections.
2. "Provide a status and schedule for completion of plant design changes and modifications to resolve issues with an open phase of electric power. "

Status:

  • SSES OPC vulnerability studies have been started and are currently still on-going.
  • Currently there is no generic, off-the-shelf technology that has been proven to detect all the required open phase fault conditions for all power plant and transformer designs. As such, SSES in collaboration with other nuclear power operating license holders is investigating options being researched by several vendors (PCS2000, EPRI, Schweitzer, etc.) to detect OPC faults .

Attachment 1 to PLA-7127 Page 2 of2 Response to Request for Additional Information

  • With the goal of ensuring reliability and accuracy, (e.g., detection without compromising nuclear safety or increase plant risk), new OPC detection technology is being thoroughly evaluated and analyzed. This technology will be tested and then monitored in operation.
  • SSES remains actively engaged in various OPC industry initiatives such as the Nuclear Energy Institute (NEI) OPC working groups for the development of an OPC Guidance Document as well as enhancements to software tools being used to analyze OPC faults.

Schedule:

  • SSES will follow the generic schedule that is provided in the NEI 13-12 OPC Industry Guidance Document, issued in December 2013, to support addressing OPC in off-site power sources at nuclear power plants.
  • It is the intention of SSES to meet the milestones of this schedule; however, deviations may be required to accommodate outage schedules, software and hardware availability, manufacturer's delivery capabilities, licensing delays, etc.
  • Deviation from the Industry OPC Initiative schedule will be documented through the deviation/exemption process addressed in the NEI OPC Guidance Document.
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