TI 2515/194

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See also TI 2515/192 for more OPC

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Issue Date: 08/18/20 1 2515/194 Rev 2

NRC INSPECTION MANUAL EEOB

TEMPORARY INSTRUCTION 2515/194 REVISION 2

INSPECTION OF THE LICENSEES’ IMPLEMENTATION OF INDUSTRY INITIATIVE

ASSOCIATED WITH THE OPEN PHASE CONDITION DESIGN VULNERABILITIES IN

ELECTRIC POWER SYSTEMS (NRC BULLETIN 2012-01)

Effective Date: 08/18/2020

CORNERSTONE: Initiating Events, Mitigating Systems

APPLICABILITY: This Temporary Instruction (TI) applies to the holders of operating licenses

for operating nuclear power reactors who have implemented actions to

protect against open phase conditions (OPCs). This TI is to be performed

at all current operating plants with the exception of Seabrook Station, Unit

1, plants seeking NRC approval in accordance with 10 CFR 50.90, and

sites that have informed the NRC of their intent to decommission prior to

01/30/2021.

2515/194-01 OBJECTIVE

01.01 To verify that licensees have appropriately implemented the Nuclear Energy Institute

(NEI) voluntary industry initiative (VII), Revision 3, including updating their licensing

basis to reflect the need to protect against OPCs.

2515/194-02 BACKGROUND

Event at Byron Nuclear Plant

On January 30, 2012, Byron Station, Unit 2 experienced an automatic reactor trip from full

power because the reactor protection scheme detected an undervoltage condition on the 6.9

kilovolt (kV) buses that power reactor coolant pumps (RCPs) B and C (undervoltage on two of

four RCPs initiate a reactor trip).

Byron Station is a two-unit pressurized water reactor plant. The electrical distribution system for

each unit consists of four non-safety 6.9-kV buses, two non-safety 4 kV buses, and two

engineered safety features (ESF) 4-kV station buses. During normal plant operation, the safety

(or ESF buses) and non-safety buses (or non-ESF) are powered from the Unit Auxiliary

Transformers (UATs). On the day of the event, two non-ESF 6.9-kV station buses that power

two of the RCPs and the two 4-kV (ESF and non-ESF) buses were supplied by station auxiliary

transformers (SATs) connected to the 345-kV offsite power switchyard (Figure 1 below). The

other two 6.9-kV and 4-kV buses were powered from the UATs. The undervoltage condition on

the SAT powered buses was caused by a broken inverted porcelain insulator stack of the phase

C conductor for the 345-kV power circuit that supplies both SATs. The insulator failure caused

the associated phase C conductor to break off from the power line disconnect switch resulting in

a high impedance ground fault through the fallen phase C conductor and a sustained open

phase condition (OPC) on the high voltage side of the SAT. The open circuit created an

Issue Date: 08/18/20 2 2515/194 Rev 2

unbalanced voltage condition on the two 6.9-kV non-ESF RCP buses and the two 4.16-kV (ESF

and non-ESF) buses. After the reactor trip and subsequent generator trip, the two 6.9 kV

buses, which were aligned to the UATs, automatically transferred to the SATs, as designed. As

a result of the open circuit on C phase, the load current in phases A and B increased and

caused the remaining two operating RCPs to trip on phase overcurrent. In the absence of any

operating RCPs, control room operators performed a natural-circulation cooldown of the plant.

The SATs continued to power the 4.16 kV ESF buses A and B because of a design vulnerability

that did not isolate the safety related buses from the degraded offsite power system. Some ESF

loads that were energized relied on equipment protective devices to prevent damage from an

unbalanced overcurrent condition. The phase overcurrent condition caused by the OPC

actuated relays to trip several ESF loads.

Approximately 8 minutes after the reactor trip, the control room operators diagnosed the loss of

the phase C condition and manually tripped circuit breakers to separate the unit buses from the

offsite power source. When the operators opened the SAT feeder breakers to the redundant

4.16-kV ESF buses, the loss of voltage relays started the emergency diesel generators (EDGs)

and restored power to the ESF buses. If the condition had been allowed to persist for an

additional few minutes, damage to the RCP seals could have occurred through a loss of RCP

seal cooling water. This in turn, could have resulted in a loss of coolant from the RCP seals in

the containment building.

Figure 1. Simplified Schematic of Electrical busses associated with one train (Unit 2)

Issue Date: 08/18/20 3 2515/194 Rev 2

A second event also occurred at Byron Station Unit 1 on February 28, 2012. This event was

also initiated by a failed inverted porcelain insulator that resulted in an open phase as well as a

phase-to-ground fault on the line side of the circuit. In this event, the fault current was high

enough to actuate protective relaying on the 345-kV system. The 4.16-kV ESFs buses

experienced a loss of voltage (LOV) caused by the opening of 345-kV system breakers, which

resulted in a separation of the SATs from the 4.16-kV buses. The two EDGs started and

energized the 4.16-kV ESF buses, as designed.

Operating Experience

A review of other operating experience identified design vulnerabilities associated with single

phase open circuit conditions at South Texas Project (South Texas), Unit 2 (Licensee Event

Report (LER) 50 499/2001 001, Agencywide Documents Access and Management System

(ADAMS) Accession No. ML011010017); Beaver Valley Power Station, Unit 1 (LER 50

334/2007 002, ADAMS Accession No. ML080280592); and a single event that affected Nine

Mile Point, Unit 1 (LER 50 220/2005 04, ADAMS Accession No. ML060620519) and the

neighboring James A. Fitzpatrick Power Plant (LER 50 333/2005 06, ADAMS Accession

No. ML060610079).

These events involved offsite power circuits that were rendered inoperable because of an open

circuit in one phase. In each instance (except South Texas, Unit 2), the condition went

undetected for several weeks because offsite power was not aligned to the ESF buses and

therefore unloaded during normal operation and the surveillance tests, which recorded

phase-to-phase voltage, did not identify the loss of the single phase. At South Texas, Unit 2,

offsite power was normally aligned to the ESF and non-safety plant buses, and the operator

manually tripped the reactor when the OPC tripped the three circulating water pumps.

Operating experience has identified several international events and the International Atomic

Energy Agency (IAEA) has published a report titled “Impact of Open Phase Conditions on

Electrical Power Systems of Nuclear Power Plants,” detailing the significance and

consequences of such events (Reference: https://www.iaea.org/publications/11026/impact-ofopen-phase-conditions-on-electrical-power-systems-of-nuclear-power-plants.)

Industry Initiative to Resolve OPC Design Vulnerability Issue

In response to the Byron event, the industry’s chief nuclear officers approved a formal initiative

to address OPCs. This initiative was communicated to NRC by the NEI in letter dated

October 9, 2013 (ADAMS Accession No. ML13333A147) and acknowledged in the NRC letter

dated December 19, 2013 (ADAMS Accession No. ML13340329). This letter further indicated

that this approved initiative commits each licensee to develop a proactive plan and schedule for

addressing the potential design vulnerabilities associated with OPCs. Subsequently, on

March 16, 2015, NEI informed the NRC (ADAMS Accession No. ML15075A454) that, to provide

adequate time for OPC implementation, the completion schedule would be revised to

December 31, 2018. The industry’s chief nuclear officers approved this schedule change in

Revision 1 of its document. Subsequently, on September 20, 2018, NEI informed the NRC

(ADAMS Accession No. ML18268A114) that to provide adequate time for implementation of the

necessary modifications to the plants and to accommodate an adequate monitoring time

afterwards, the completion schedule would be revised to December 31, 2019, with a minimum

of 24 months for the completion of the associated monitoring period. The industry’s chief

nuclear officers approved this schedule change in Revision 2 of its document. In letter dated

December 14, 2018, the NRC acknowledged the NEI letter (ADAMS Accession No.

ML18331A156).

Issue Date: 08/18/20 4 2515/194 Rev 2

On June 6, 2019, NEI submitted Revision 3 to the industry initiative (ADAMS Accession No.

ML19163A176), and subsequently submitted the accompanying guidance document, NEI 19-02

“Guidance for Assessing Open Phase Condition Implementation Using Risk Insights,” (ADAMS

Accession No. ML19172A086) on June 20, 2019. Revision 3 of the industry initiative includes

an option for not enabling the Open Phase Isolation System (OPIS) automatic functions based

on assessing the change in risk between operating with automatic functions versus reliance on

operator manual action to isolate a power supply affected by an OPC. The industry’s chief

nuclear officers approved the changes in Revision 3 of its NEI document. In a letter dated July

17, 2019, the NRC acknowledged the NEI letter (ADAMS Accession No. ML19193A192). The

industry initiative described in the June 6, 2019 NEI letter is the VII referred elsewhere in this TI.

Failure Modes and Consequences of OPC

An OPC may result in challenging plant safety. Operating experience in different countries has

shown that the currently installed instrumentation and protective schemes have not been

adequate to detect this condition and take appropriate action. An OPC that affects the safety

function, if not detected and disconnected promptly, represents a design vulnerability for many

nuclear power plants (NPPs). It may lead to a condition where neither the offsite power system

nor the onsite power system is able to support the safety functions, and could propagate to

station blackout. The January 2012 operating event at Byron Station, Unit 2, revealed a

significant design vulnerability where an OPC in the plant’s offsite power supply caused a loss

of certain safety functions powered by the site’s alternating current (ac) electric power system.

The loss of these safety functions occurred because the ESF electric power system's protection

scheme was unable to detect and isolate the loss of a single phase between the transmission

network and the onsite power distribution system. The resulting degraded and unbalanced

voltage conditions on redundant ESF buses led to the tripping of equipment required for normal

plant operations and safe shutdown. The inability of the protection scheme to detect an OPC

and automatically transfer power from the affected electric power system allowed the degraded

offsite power system to remain connected to ESF buses, and prevented other onsite ac sources

(e.g., Emergency Diesel Generators (EDGs)) from starting and powering these buses. As a

result, certain important to safety equipment required for safe operations remained powered by

the degraded ac source. The ability of this equipment to perform the required safety functions

was questionable as the internal protective features installed to prevent damage from

overheating would have either actuated and locked-out the vulnerable components or,

depending on the setpoint, allowed continued operation and thereby risk damage from

overheating. Furthermore, equipment required for safe shutdown was also at risk of being

unavailable for an extended period of time even after the restoration of an operable power

source, since operator actions would be required to manually reset tripped protective devices.

In response to the Byron event, the U.S. and international nuclear industry evaluated the

consequences of an OPC and an unbalanced voltage condition in a three-phase power system.

Continued operation for an extended duration with unbalanced voltage conditions can damage

equipment as a result of overheating and vibration, or result in the inadvertent trip of electrical

equipment and cause a plant transient. Redundant equipment important to safety which is

supplied from a common power source may be damaged when exposed to the unbalanced

voltage conditions. The operators may not always be able to respond promptly to prevent

multiple equipment damage due to a lack of information available from existing measurements,

indications, and automatic actions. The type of fault or transformer winding configuration and

grounding techniques can result in low voltage unbalance conditions (e.g., during light load or

Issue Date: 08/18/20 5 2515/194 Rev 2

no-load conditions), and the degraded conditions can go undetected for a long period of time

and may not be revealed until the transformer load is increased.

The effect of OPC on the operating equipment, typically induction motors, depends on a number

of factors. An OPC in fully loaded power supply system can result in high current flow in at least

one of the three phases of rotating motors. This higher than normal current may actuate the

protective scheme, which disconnects the loads from the degraded source. However, the

magnitude of the current is dependent on the type of transformer and system configuration to

the associated feeder circuits and in some cases the current flow may not actuate protective

relaying and result in excessive heating of the motor windings. Unbalanced voltages applied to

a three–phase induction motor result in unbalanced currents in the stator windings and

introduce a negative sequence voltage. The negative sequence voltage produces a flux rotating

in the opposite direction of the rotation of the rotor, producing additional currents and heating.

The unbalanced conditions result in overheating of the motor. If the protective scheme actuates

and disconnects the load important to safety from the degraded power source, the safe

shutdown capability of the plant may be compromised as the affected component may not be

available until manual actions are taken to identify the cause of the trip, reset the protective

relaying and close the appropriate breaker.

If the circuit with an OPC is in standby mode or lightly loaded, then the low magnitude of current

flow in the degraded circuit may not result in sufficient unbalance to actuate any protective

device. The OPC may therefore not get detected until a change in plant state or a bus transfer

to the offsite standby source results in increasing the load current in the circuit. Once the circuit

has increased demand, then the running motors may trip due to overcurrent protection actuation

or sustain winding damage due to heating effects.

The operating experience as well as results from analytical studies has confirmed that voltages

can be present on all three phases downstream of the OPC due to the interaction of magnetic

fields in transformers and three phase loads. In some cases, all three phases on the low

voltage winding may have balanced voltages in all phases under no load or lightly loaded

conditions. With this regard, the voltage can be regenerated through the systems, but depends

upon:

• Transformer winding, core configuration, and rated power

• System grounding arrangements

• Transformer loading, size and type of loads (e.g. motor or static)

• Properties of cables and overhead lines (capacitance, inductance)

• Location of the open phase.

NRC Actions

Based on the Byron Station operating event, the Nuclear Regulatory Commission (NRC) staff

issued Information Notice 2012-03, “Design Vulnerability in Electric Power System,” dated

March 1, 2012 (ADAMS Accession No. ML120480170). On July 27, 2012, the staff issued

Bulletin (BL) 2012-01, “Design Vulnerability in Electric Power System” (ADAMS Accession

No. ML12074A115). Specifically, the NRC asked licensees to provide information by

October 25, 2012, on (1) the protection scheme to detect and automatically respond to a

single-phase open circuit condition or high impedance ground fault condition on GDC 17 power

circuits, and (2) the operating configuration of ESF buses at power.

Issue Date: 08/18/20 6 2515/194 Rev 2

The Electrical Engineering Branch staff reviewed the information that NRC licensees provided

and documented the details of this review in NRC BL 2012-01, in the summary report dated

February 26, 2013 (ADAMS Accession No. ML13052A711).

In SECY-16-0068, dated May 31, 2016 (ADAMS Accession No. ML15219A327), the staff

requested Commission approval of an Interim Enforcement Policy (IEP), applicable to all

operating reactors, to allow the NRC to exercise enforcement discretion for certain instances of

noncompliance with the requirements specified in the technical specifications (TS) for electrical

power systems (typically TS Section 3.8) and action statement(s) associated with “AC

Sources—Operating” and “AC Sources—Shutdown,” and with GDC 17. This IEP could be

applicable to certain instances of nonconformance with the principal design criteria specified in

the UFSAR.

On March 9, 2017, the Commission issued (ADAMS Accession No. ML17068A297) Staff

Requirements Memorandum (SRM) SECY 16-0068, “Interim Enforcement Policy for

Open-Phase Conditions in Electric Power Systems for Operating Reactors.” The Commission

disapproved the staff’s request to establish an IEP for the purpose of exercising enforcement

discretion for purported noncompliance with NRC requirements and nonconformance with

design criteria during the pendency of licensee implementation of actions to address an OPC.

The SRM stated the following:

“Going forward, the staff should verify that licensees have appropriately implemented the

voluntary industry initiative. If the staff determines that a licensee does not adequately

address potential OPCs, including updating the licensing basis to reflect the need to protect

against OPCs, the staff should consider the appropriate regulatory mechanism to impose the

necessary requirements to protect against OPCs using the current guidance on such matters

from the Office of the General Counsel.

The staff should provide the Commission with a notation vote paper if this situation arises for

any licensee or licensees, with options, including the staff's recommended path forward. In

addition, if disagreements arise between the staff and the industry during implementation of

the voluntary industry initiative, and the related issues have policy implications, the staff

should promptly raise such issues to the Commission for resolution.

Once satisfactory implementation of the technical resolution has been verified for each

licensee, the associated NRC Bulletin should be closed. The staff should update the Reactor

Oversight Process to provide periodic oversight of industry's implementation of the OPC

initiative.”

The staff has written this TI for inspectors to verify whether licensees have appropriately

implemented the technical resolution of OPC design vulnerability as discussed in their industry

initiative document at each operating reactor unit. A TI inspection was chosen as verification of

implementation would closely resemble a plant modification inspection.

Four nuclear power plants (River Bend, Palo Verde, Byron, and St. Lucie) were selected as an

initial set of plants with four distinct designs (OPC detection and protection schemes) to assess

the adequacy of the designs using TI 2515/194, Revision 0. The results of the inspections are

documented in inspection reports 05000458/2018010 (ADAMS Accession No. ML18085B197);

05000528/2018010, 05000529/2018010, and 05000530/2018010 (ADAMS Accession No.

ML18103A157); 05000454/2018011 and 05000455/2018011 (ADAMS Accession No.

ML18138A136); and 05000335/2018002) and 05000389/2018002 (ADAMS Accession No.

Issue Date: 08/18/20 7 2515/194 Rev 2

ML18208A328). The inspection team consisted of inspectors from each region and a member

of the Electrical Engineering Operating Reactors Branch (EEOB) staff from headquarters. The

regional inspectors completed Section 03.01 of TI 2515/194, Rev. 0 and the EEOB staff

gathered information in accordance with Section 03.02 of TI 2515/194, Rev. 0. The EEOB staff

generated an assessment of the inspection results from implementation of the TI dated October

31, 2017 (Rev. 0) to document whether licensees identified OPC vulnerabilities using one of the

four OPC designs and implemented the OPIS consistent with the NEI OPC VII. A summary of

the staff’s preliminary assessments and the areas needing additional clarity were discussed with

the industry representatives in two public meetings conducted on September 19, 2018, and

October 17, 2018 (ADAMS Accession Nos.: ML18268A342 and ML18309A227, respectively).

The NRC staff informed the industry that it would use inspection results, the information

discussed in the public meetings, information provided by industry as part of its efforts to

address OPC vulnerabilities, the staff’s 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 consistent with Commission

direction in SRM- SECY 16-0068.

The staff is issuing this revision (Rev. 1) to the TI for NRC inspectors to verify that the plants

that choose operator manual action in lieu of automatic protective action are appropriately

implementing the VII and adequately addressing the OPC design vulnerability issue. The staff

is also deleting Section 03.02, “Information Gathering for VII Assessment (Part 2),” guidance

from the TI since the information was obtained during the initial inspections and no longer

required to be performed by this TI.

2515/194-03 INSPECTION REQUIREMENTS AND INSPECTION GUIDANCE

General Guidance.

Preparation: Prior to arrival on site, request that key documents be available for on-site

inspection (e.g., NEI 19-02 evaluation, calculations, analyses, drawings, procurement

specifications, test reports, modification packages including 10 CFR 50.59 evaluations,

maintenance, surveillance, test, and alarm response procedures). Arrange with the licensee to

have appropriate design, maintenance, probabilistic risk assessment (PRA), and operations

staff on-site to support the inspection. Request a brief licensee presentation after entrance

meeting describing their electric power system design; normal plant operating alignments; OPC

design schemes installed to detect, alarm and actuate (if applicable); bus transfer schemes;

maintenance and surveillance requirements; operator walkthrough verifications of the OPC

alarm response procedure(s); consequences of extended duration of unbalanced voltage

conditions affecting electric equipment if OPC is not automatically isolated; and any licensing

basis changes to Updated Final Safety Analysis Report (UFSAR) and Technical Specifications

(TS).

Conduct: It is expected that this TI will be performed to verify that licensees have appropriately

implemented the VII and adequately addressed potential OPCs. Deviations and exceptions to

the VII implementation should be documented in the inspection report with enough details for

EEOB staff to review and closeout Bulletin 2012-01. For sites that are implementing the riskinformed evaluation method to demonstrate that operator manual actions will be sufficient to

mitigate the impact of an OPC, in lieu of TI Section 03.01.b (automatic protective actions), TI

Section 03.01.c will be performed. This inspection activity will be performed after the licensees

Issue Date: 08/18/20 8 2515/194 Rev 2

have completed their evaluations and analyses, issued plant procedure(s), and completed

training for taking manual actions consistent with plant’s design and licensing bases. Any

identified deviations from the VII and TI guidance will be documented in the inspection report as

exceptions. These exceptions will be considered by EEOB staff during the final review and

closeout of the Bulletin. Any performance issues identified during the inspection of the VII that

are considered to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612 will be reviewed by a panel to determine whether they represent a finding to be

documented. These issues may be initially treated as unresolved items (URIs), prior to final

disposition.

As directed by the Commission in SRM SECY-16-0068, should disagreements arise between

the NRC staff and the industry during implementation of the voluntary initiative, and the related

issues have policy implications, the NRC staff will promptly raise such issues to the Commission

for resolution.

03.01 Voluntary Industry Initiative.

Determine whether the licensee appropriately implemented the VII dated June 6, 2019 (ADAMS

Accession No. ML19163A176), by verifying the following:

a. Detection, Alarms and General Criteria.

1. Either:

OPCs are detected and alarmed in the control room.

OR

(a) The licensee has demonstrated that OPCs do not prevent the functioning of

important-to-safety SSCs

AND

(b) OPC detection will occur within a reasonably short period of time (e.g., 24

hours)

AND

(c) The licensee has established appropriate documentation regarding OPC

detection and correction.

2. Either:

Detection circuits are sensitive enough to identify an OPC for credited loading

conditions (i.e., high and low loading).

OR

If automatic detection may not be possible in very low or no loading conditions

when offsite power transformers are in standby mode; automatic detection must

happen as soon as loads are transferred to this standby source. Additionally, if

automatic detection is not reliable, monitoring requirements should be

established on a per shift basis to look for evidence of an OPC.

3. OPC design/protective schemes minimize misoperation or spurious action in the

range of voltage unbalance normally expected in the transmission system that

could cause separation from an operable off-site power source. Licensees have

Issue Date: 08/18/20 9 2515/194 Rev 2

demonstrated that the actuation circuit design does not result in lower overall

plant operation reliability.

4. New non-Class-1E circuits are not used to replace existing Class-1E circuits.

5. The UFSAR has been updated to discuss the design features and analyses

related to the effects of any OPC design vulnerability.

6. Identify whether OPIS detection and alarm components are maintained in

accordance with station procedures or maintenance program and that periodic

tests, calibrations, setpoint verifications or inspections (as applicable) have been

established.

b. Protective Actions.

1. If the licensee determines there is no single credible failure that could cause an

OPC, then verify that the licensee has developed and issued a full engineering

evaluation to document the basis for OPC as a non-credited event. The Bruce

Power and Forsmark operating experience must be considered as part of this

analysis.

2. With OPC occurrence and no accident condition signal present, either:

An OPC1 does not adversely affect the function of important-to-safety SSCs

OR

(a) TS LCOs are maintained or the TS actions are met without entry into TS LCO 3.0.3 (or equivalent).1&2

AND

(b) Important-to-safety equipment is not damaged by the OPC1&3

.

AND

(c) Shutdown safety is not compromised3&4

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

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.

1 For operating modes where power is supplied from the main generator through unit auxiliary

transformers, the evaluation must assume that the main generator is lost and loads must be transferred to

the alternate source(s).

2 Applies to TS equipment affected by the OPC and not just the TS related to off-site power system.

Situations where alternate sources are removed from service if allowed by the TS must be considered.

3 Operator action may be credited in the evaluation if existing regulations and guidelines are met for the

use of manual actions in the place of automatic actions.

4 Power supplied to spent fuel pool cooling systems must also be considered. The limiting conditions will

be those where power is supplied from a single source or an alternate source is used that does not have

open phase protection (like a main power transformer back-feed source).

Issue Date: 08/18/20 10 2515/194 Rev 2

OR

The licensee has shown 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 in a non-safety system.

4. Periodic tests, calibrations, setpoint verifications or inspections (as applicable)

have been established for any new protective features. The surveillance

requirements have been added to the plant TSs if necessary, to meet the

provisions of 10 CFR 50.36.

5. The UFSAR has been updated to discuss the design features and analyses

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

6. Identify whether OPIS protection components are maintained in accordance with

station procedures or maintenance program.

c. Use of Risk-Informed Evaluation Method

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 b above, the inspectors should review, verify, and document, as appropriate,

the following:

1. Review licensee’s evaluation of NEI 19-02 and Attachment 1 of VII, Revision 3

stated above. Verify that the plant configuration matches the changes made to

the PRA model used to evaluate an OPC, and that the logic of the PRA model

changes is sound. Consult with regional Senior Reactor Analyst (SRA) if

inspectors have any questions or concerns regarding the PRA model.

2. Review the procedure(s) and operator actions required to respond to an OPC

alarm and potential equipment trip, with an operator walkthrough and simulator

demonstration if possible (during the walkthrough, verify that the procedure which

validates that the OPC alarm is legitimate would identify the proper indication to

validate the OPCs at all possible locations).

3. Verify that the observations made while carrying out step 2 above match the

Human Reliability Analysis (HRA). Consult with regional SRAs as necessary. To

achieve this objective:

a. Verify that the execution time for each human action as described in the

alarm response procedure(s) and the time available to complete each action

are reasonable.

b. Verify that the environmental and plant operating conditions allow access

where needed, procedures have been revised to account for identifying and

Issue Date: 08/18/20 11 2515/194 Rev 2

isolating an OPC, training has been conducted on these revised procedures,

and any equipment needed to complete these actions is available and ready

for use.

4. Review the assumptions listed in the NEI 19-02 (Appendix A) evaluation and the

sensitivity analyses listed in Section 5 of the evaluation. Verify the assumptions,

focusing additional attention on any assumption that causes the sensitivity

analysis to exceed the risk threshold defined in the NEI 19-02 evaluation.

5. Review the following to ensure the assumptions, procedures, operator actions,

and licensee’s analyses specified above are consistent with the plant-specific

design and licensing bases and/or the as-built, as-operated plant as appropriate:

a. Review the initiating events considered in the analysis.

b. Review and verify the boundary conditions specified in VII, Rev.3, Att. 1.

c. If certain loads are assumed to be impacted by an OPC (i.e.,

tripped/locked out or damaged) review the operating procedure(s) for any

steps taken to recover the affected equipment (or use of alternate

equipment).

d. If recovery is assumed as part of the basis in the PRA analysis for

impacted electric equipment, verify that the restoration of equipment is

based on analyses that demonstrate that automatic trips for isolating any

operating equipment during an OPC event did not result in equipment

damage. The review of the analyses supporting recovery may include,

but not be limited to:

1) System load flow calculations, protective coordination, and failure

mode and consequence analyses.

2) Verifying that the licensee appropriately analyzed the capability of

safe shutdown equipment to perform the required functions.

3) Review of the licensee’s evaluations to verify that ESF/PRAcredited loads (such as large motors, motor-operated valves,

inverters, etc.) would not be damaged during the time delay

between detection of an OPC by the control room operators and

completion of the operator actions.

4) Review of the maximum unbalance seen on ESF buses

(considering ESF/PRA-credited loads during normal, anticipated

operational occurrences, and design basis accidents) at all

voltage levels and verifying how the existing relays are used to

protect the equipment from unbalanced power quality issues and

potential consequences.

5) Review of the time to recover the tripped equipment and/or

replace fuses and damaged equipment given an OPC.

Issue Date: 08/18/20 12 2515/194 Rev 2

6) Review of the time for restoring large motors while factoring the

manufacturer recommendations or site/industry guidance for

restarting stalled or degraded electric equipment.

2515/194-04 REPORTING AND DOCUMENTATION REQUIREMENTS

Document the completion of this TI in the integrated quarterly report or in a standalone

inspection report. Document the VII inspection results and any deviations from the VII in

sufficient details to facilitate NRR staff ‘s final review and closeout of the Bulletin.

2515/194-05 COMPLETION SCHEDULE

This TI is to be completed by July 29, 2022.

2515/194-06 EXPIRATION

The TI will expire on December 30, 2023.

2515/194-07 CONTACT

Any technical questions regarding this TI shall be directed to the Branch Chief of

NRR/DEX/EEOB. Any Reactor Oversight Process-related questions shall be addressed to

Christopher Cauffman, at (301) 415-8416. Questions can also be sent electronically to

Christopher.Cauffman@nrc.gov.

2515/194-08 STATISTICAL DATA REPORTING

Charge all direct inspection and information collection efforts to TI 2515/194 using IPE code TI.

Charge all preparation and documentation time to activity code TPD (CAC 000989).

2515/194-09 RESOURCE ESTIMATE

Estimated time to complete TI (Rev.0) is 50-60 hours per site for direct inspection and 24-32

hours for preparation and documentation. In addition, estimated time to complete risk-informed

evaluation method of this revised TI is 40-60 hours per site for direct inspection and 24-36 hours

for preparation and documentation.

2515/194-10 TRAINING

It is expected that this inspection will be performed by the regional electrical engineering

specialist or contractors who are knowledgeable in electrical power system design and analyses

for nuclear power reactors. However, a brief training session on the risk-informed evaluation

method outlined in NEI-19-02 and VII, Rev.3, Attachment 1, was provided by NRR/DRA/APOB

and NRR/DEX/EEOB staff on March 6, 2020.

Issue Date: 08/18/20 13 2515/194 Rev 2

2515/194-11 REFERENCES

IP 71152, “Problem Identification and Resolution”

IP 71111.17T, “Evaluations of Changes, Tests and Experiments”

IP 71111.18, “Plant Modifications”

IP 71111.21M, “Design Bases Assurance Inspection (Teams)”

END

Issue Date: 04/15/20 Att1-1 2515/194, Rev 1

Attachment 1 – Revision History for TI 2515/194

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of Training

Required and Completion

Date

Comment Resolution and

Closed Feedback Form

Accession Number

(Pre-Decisional,

Non-Public Information)

ML17220A253

DRAFT

CN 17-XXX

Draft version of the TI was made public to

share with industry during a public meeting

held on August 15, 2017.

N/A ML17158B437

ML17137A416

10/31/2017

CN 17-024

Initial issuance. Researched commitments for

the last four years and found none. This

Temporary Instruction (TI) applies to the

holders of operating licenses for operating

nuclear power reactors who have

implemented actions to protect against open

phase conditions (OPCs). This TI is to be

performed at all current operating plants with

the exception of Seabrook Station, Unit 1,

plants seeking NRC approval in accordance

with 10 CFR 50.90, and sites that have

informed the NRC of their intent to

decommission prior to 01/30/2020.

CA Note: Initiation of Temporary Instruction

2515/194 To Inspect Implementation of

Industry Initiative Associated with Open

Phase Condition Design Vulnerabilities in

Electric Power Systems ML17240A034

It is expected that this

inspection will be

performed by the regional

electrical engineering

specialist or contractors

who are knowledgeable

in electrical power system

design and analyses for

nuclear power reactors.

However, a specialized

brief training on the OPCs

will be provided by

NRR/DE/EEOB staff prior

to 10/31/17.

ML17158B437

Issue Date: 04/15/20 Att1-2 2515/194, Rev 1

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of Training

Required and Completion

Date

Comment Resolution and

Closed Feedback Form

Accession Number

(Pre-Decisional,

Non-Public Information)

ML20085H763 Draft version of the TI was made public to

share with industry during a public meeting

held on April 6, 2020

N/A N/A

ML19339D067

04/15/20

CN 20-021

Revision 1 - Expanded scope to include all

plants. Incorporated guidance for inspecting

manual action (i.e. risk-informed) approach

consistent with VII, Revision 3.

Removed data-gathering instructions (section

03.02) and Table 1 since the HQ staff

completed this one-time activity for VII

verification effort.

Initial training for this TI was

conducted on September

and October 2017.

It is expected that this

inspection activity will be

performed by the regional

electrical engineering

specialist or contractors

who are knowledgeable in

electrical power system

design and analyses for

nuclear power reactors with

assistance from SRA, if

required to perform risk

evaluations. However, a

brief training session on the

risk-informed evaluation

method outlined in NEI-19-

02 and VII, Rev.3,

Attachment 1, was provided

by NRR/DRA/APOB and

NRR/DEX/EEOB staff on

3/6/20.

ML19339D066