IR 05000313/2019013

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Temporary Instruction 2515/194 Report 05000313/2019013 and 05000368/2019013
ML19178A249
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 06/26/2019
From: Nick Taylor
Division of Nuclear Materials Safety IV
To: Richard Anderson
Entergy Operations
Taylor N
References
IR 2019013
Download: ML19178A249 (11)


Text

une 26, 2019

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - TEMPORARY INSTRUCTION 2515/194 REPORT 05000313/2019013 AND 05000368/2019013

Dear Mr. Anderson:

On June 6, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Units 1 and 2 and discussed the results of this inspection with Mr. Terry Evans, Coord-Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspector 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/

Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Enclosure:

Inspection Report 05000313/2019013 and 05000368/2019013

Inspection Report

Docket Numbers: 05000313 and 05000368 License Numbers: DPR-51 and NPF-6 Report Numbers: 05000313/2019013 and 05000368/2019013 Enterprise Identifier: I-2019-013-0000 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Russellville, AR Inspection Dates: June 3, 2019, to June 6, 2019 Inspector: S. Graves, Senior Reactor Inspector Approved By: Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction 2515/194 inspection at Arkansas Nuclear One, Units 1 and 2 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.

Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations No findings were identified.

Additional Tracking Items None.

INSPECTION SCOPE

Inspections were conducted using the appropriate portions of the Temporary Instruction (TI)inspection in effect at the beginning of the inspection unless otherwise noted. Samples were declared complete when the TI requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspector reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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)

This inspection was conducted using Temporary Instruction 2515/194 (ADAMS Accession No. ML17137A416), effective November 1, 2017, 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. The inspector reviewed the licensees implementation of Nuclear Energy Institutes voluntary industry initiative in compliance with Commission guidance. The inspector reviewed and discussed the licensees open phase condition system design, installation, testing and maintenance plans with plant staff, and performed system walkdowns to verify that the installed equipment was supported by the design documentation.

Temporary Instruction 2515/194-03.01 - Voluntary Industry Initiative (Part 1)

Entergy Operations Inc. selected the open phase detection system designed and manufactured by PCS2000 Solutions, LLC, as the design vendor for the open phase condition system at Arkansas Nuclear One.

During normal operations, auxiliary power for plant electrical loading is supplied by each units main generator through an associated Unit Auxiliary Transformer. Arkansas Nuclear One has three standby transformers, Startup Transformers 1, 2, and 3, which are credited General Design Criteria, GDC-17, offsite power sources. During normal operation, Startup Transformers 1 and 3 are connected to 22-kV tertiary windings of the switchyard bus tie autotransformer bank. Startup Transformer 2 is connected to the switchyard 161-kV ring bus.

Each Startup Transformer provides a source of power for startup, shutdown, and post-shutdown loads. Startup Transformer 1 serves as a standby source for the plant auxiliaries of Unit 1, Startup Transformer 3 serves as a standby source for the plant auxiliaries of Unit 2. Startup Transformer 2 is common to both units. The system is designed to transfer loads to a Startup Transformer following a turbine generator or reactor trip without a loss of auxiliary load. Each units engineered safety features busses are capable of being supplied from either the unit auxiliary transformer during normal operation, the associated units Startup Transformer, or Startup Transformer 2.

Arkansas Nuclear One installed redundant open phase detection systems on each Startup Transformer and at the end of this inspection the PCS2000 system was operating with all functions enabled for each Startup Transformer.

INSPECTION RESULTS

Observation 2515/194 Based on discussions with licensee staff, review of design, installation and testing documentation, and walkdowns of installed equipment, the inspector had reasonable assurance the licensee is appropriately implementing the voluntary industry initiative.

The inspector determined by design document review, walkdowns, staff discussions, and observation that:

Detection, Alarms, and General Criteria

(1) Open phase conditions will be detected and alarmed in the control rooms.
(2) Detection circuits are sensitive enough to identify an open phase condition for all credited loading conditions.
(3) The PCS2000 system is designed to minimize misoperation or spurious action in the range of voltage unbalance normally expected in the transmission system that could cause separation from an operable offsite power source. The licensee had demonstrated that the actuation circuit design did not result in lower overall plant operation reliability.
(4) No Class-1E circuits were replaced with non-Class 1E circuits in the design.
(5) The licensee had updated the Unit 1 and Unit 2 Final Safety Analysis Reports to discuss the design features and analyses related to the effects of, and protection for, any open phase condition vulnerabilities.

Protective Actions Criteria

(1) Startup Transformers 1, 2, and 3 were identified as susceptible to an open phase condition and the licensee had implemented design changes to mitigate the effects.
(2) With an open phase condition present and no accident condition signal present, the PCS2000 system would not adversely affect the function of important-to-safety systems, structures, or components. The licensees open phase condition design solution added a set of additional tripping inputs in parallel with existing transformer isolation controls. This addition added a new tripping condition (open phase) to the previously analyzed electrical faults which result in isolation of the transformers. The credited plant response was unaffected and would be the same independent of the conditions that generated the isolation of the transformer.
(3) With an open phase condition present and accident condition signal present, the PCS2000 system would not adversely affect the transfer of 4.16-kV engineered safeguards buses to the onsite emergency diesel generators as required by the current licensing bases; only a new tripping condition (open phase) was added to the electrical faults which result in isolation of the alternate offsite source of power.

The 4.16-kV engineered safeguards buses are normally energized from the main generator through the unit auxiliary transformer and the non-engineered safeguards busses. Upon loss of the normal power source, the engineered safeguards loads are automatically transferred to the selected Startup Transformer. Isolation of the Startup Transformer due to an open phase condition results in the engineered safeguards loads being automatically transferred and energized from the respective emergency diesel generator in the same manner as required by the current licensing bases.

Protective Actions Criteria Exception At the time of this inspection, the licensee had not finalized development for all periodic tests, calibrations, setpoint verifications, or inspection procedures for open phase protection system equipment. The licensee had developed and implemented work instructions and procedures for the uninterruptible power supplies used to power the open phase protection equipment, had established preventive maintenance identification for the system components, and had established plans for repair or replacement of degraded components. The inspector held discussions with licensee staff and identified that the vendor guidance, including periodic tests, setpoint verification, and equipment maintenance and inspections would be integrated into plant procedures and processes. The licensee had performed a pre-inspection self-assessment, documented in Condition Report LO-ALO-2019-00029 which documented, in part, the licensees pending actions to determine if any of the open phase detection components needed to be included in the Maintenance Rule program and, if so, ensure actions are in place to include the components in the program.

EXIT MEETINGS AND DEBRIEFS

On June 6, 2019, the inspector presented the Temporary Instruction 2515/194 results to Mr. T. Evans, Coord-Site Vice President, and other members of the licensee staff. The inspector verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Calculations CALC-14-E- EMTP Station Open Phase 0

2001-01 LOCA Analysis

CALC-15-D- EMTP Transmission Line Open 0

3001-01 Phase Analysis

CALC-15-D- EMTP Station Open Phase 0

3001-02 Analysis

CALC-17-E- Coordination of Open Phase 0

3001-01 Detection Time Delay Trip

Setting

CALC-84-E- General Criteria for Safety 10

0103-01 Buses

CALC-ANOC- ANO SU1 & SU3 Open Phase 0

EE-18-00001 Detection Monitoring Period

Report June - December 2017

CALC-ANOC- SU2 Open Phase Detection 0

EE-18-00003 Monitoring Period Report

October 2018

Corrective LO-ALO- Track the Pre-NRC Inspection 2/21/2019

Action 2019-00029 Focused Self-Assessment for

Documents Open Phase Condition Design

Vulnerabilities

Corrective CR-ANO-1- 6/04/2019

Action 2019-01375

Documents

Resulting from

Inspection

Drawings E-1 Station Single Line Diagram 62

E-112 Schematic Diagram StartUp 7

XFMR Aux Systems Local

Annunciator Reflash Modules

E-2001 Station Single Line Diagram 39

E-2094 Schematic Diagram Startup 20

Transformer #3 Lockout Relay

E-2112 Schematic Diagram Start-Up 12

Transformer Auxiliary System

E-2812 Transformer Area Grounding & 8

Underground Ductbank Layout

Inspection Type Designation Description or Title Revision or

Procedure Date

E-2814 Transformer Area Grounding & 8

Underground Ductbank Layout

E-2816 Transformer Area Isophase 13

and Non-Segregated Busses

and Overhead Lines

E-2819 Transformer Yard Deluge 3

System Conduit Layout

E-613 Underground Conduit and 16

Grounding Transformer Yard

Area

E-614 Transformer Yard Area 14

Isophase Bus, Structures and

Overhead Lines

E-94 Schematic Diagram Startup 21

Transformers No 1 & No 2

Lockout Relays

Engineering EC-48770 Provide Open Phase Detection 0

Changes and Protection for Startup

Transformer No. 2

EC-73661 Enable Open Phase Detection 0

Trip Circuits (Parent EC)

EC-73663 Enable Open Phase Detection 12/21/2017

Trip and Alarm Circuits Startup

Transformer 1

(CHILD EC TO EC 73661)

EC-73664 Enable Open Phase Detection 12/21/2017

Trip and Alarm Circuits Startup

Transformer 2

(CHILD EC TO EC 73661)

EC-73665 Enable Open Phase Detection 12/21/2017

Trip and Alarm Circuits Startup

Transformer 3

(CHILD EC TO EC 73661)

ECT-48708- Post Modification Testing of 4/20/2017

Trip and Alarm Functions for

SU3 Open Phase Detection

Inspection Type Designation Description or Title Revision or

Procedure Date

(OPD)

ECT-48770- Post Modification Testing of 9/24/2017

Trip and Alarm Functions for

SU2 Open Phase Detection

(OPD)

ECT-48771- Post Modification Testing of 11/17/2017

Trip and Alarm Functions for

SU1 Open Phase Detection

(OPD)

Miscellaneous Arkansas Nuclear One, Unit 1 Amendment

Safety Analysis Report 29

Arkansas Nuclear One, Unit 2 Amendment

Safety Analysis Report 28

PCS2000 Open Phase 8/08/2016

Detection System Factory

Acceptance Testing for Start

Up Transformers 1, 2, and 3

PCS2000 Open Phase 11/11/2016

Detection System ANO SU1

Site Acceptance Test

PCS2000 Open Phase 9/24/2017

Detection System ANO SU2

Site Acceptance Test

PCS2000 Open Phase 4/20/2017

Detection System ANO SU3

Site Acceptance Test

Process Applicability 11/12/2018

Determination for EC 73661,

Enable Open Phase Detection

Trip Circuits (Parent EC)

Licensing Clarification of Offsite Power 3/15/2017

Basis Operability Requirements

Document TSTF-556-T

Change

LBDC 17-015

Licensing Clarification of Offsite Power 3/10/2017

Basis Operability Requirements

Document TSTF-556-T

Change

LBDC 17-016

Procedures 1107.001 Electrical System Operations 123

Inspection Type Designation Description or Title Revision or

Procedure Date

203.012B Annunciator K02 Corrective 048

Action

2107.001 Electrical System Operations 129

203.012A Annunciator 2K01 Corrective 049

Action

203.054 Abnormal Grid 002

Work Orders 00499121-01 D-71 Battery Charger for SU1

Open Phase Detection,

Perform Monthly Battery

Charger Checks for Voltage

and Current Output, Check and

Reset Alarms and Perform

Alarm Indication Lamp Tests

00506901-01 D-71 Start-up (SU) #1 Open 11/07/2018

Phase Detection 125 VDC

Battery Bank Monthly

Monitoring and Inspection

00506913-01 2D-70 Battery Bank for SU3 10/29/2018

Open Phase Detection Monthly

Monitoring and Inspection

2816135-01 2D-70 Battery Bank for SU3 12/03/2018

Open Phase Detection Monthly

Monitoring and Inspection

2843065 D-71 Battery Charger Monthly 4/24/2019

PM

ML19178A249

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

By: STG Yes No Publicly Available Sensitive

OFFICE SRI:EB2 C:EB2 C:PBD C:EB2

NAME SGraves NTaylor JDixon NTaylor

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 6/25/2019 6/25/2019 6/26/2019 6/26/2019