IR 05000382/2019011
| ML20007E701 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/07/2020 |
| From: | Nick Taylor NRC/RGN-IV/DRS/EB-2 |
| To: | Vazquez S Entergy Operations |
| Taylor N | |
| References | |
| IR 2019011 | |
| Download: ML20007E701 (10) | |
Text
January 7, 2020
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - TEMPORARY INSTRUCTION 2515/194 (INSPECTION REPORT 05000382/2019011)
Dear Mr. Vazquez:
On December 11, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3, and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety
Docket No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier: I-2019-011-0028
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA
Inspection Dates:
December 10, 2019, to December 11, 2019
Inspector:
S. Graves, Senior Reactor Inspector
Approved By:
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting Temporary Instruction 2515/194 at Waterford Steam Electric Station, Unit 3, 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.
List of Findings and Violations
No findings or violations of more than minor significance 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)
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.
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)
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 Waterford Steam Electric Station, Unit 3.
During normal operations, auxiliary power for plant electrical loading is supplied by the units main generator through a unit auxiliary transformer for each redundant train. For unit startup and off-normal conditions, Waterford Steam Electric Station, Unit 3, has two Startup Transformers ST-EMT-A and ST-EMT-B, which are connected to the 230-kV switching yard and are normally operated in a standby condition. The startup transformers provide the preferred source of offsite power to the stations safety-related 4-kV power system. Both transformers have solidly grounded wye wound primary windings, which the licensee identified as susceptible to an open phase condition. Startup Transformer ST-EMT-A serves as the standby source for train A, Startup Transformer ST-EMT-B serves as the standby source for train B. The system is designed to fast transfer loads to a startup transformer following a turbine generator or reactor trip without a loss of auxiliary load. Each units engineered safety features buses are capable of being supplied from either the associated unit auxiliary transformer during normal operation or the associated startup transformer from offsite power.
Waterford Steam Electric Station, Unit 3, installed redundant open phase detection systems on each startup transformer and at the end of this inspection the PCS2000 system was operating normally with all functions enabled.
INSPECTION RESULTS
Observation: Temporary Instruction 2515/194-03.01 - Voluntary Industry Initiative (Part 1)2515/194 Based on discussions with licensee staff, review of design, installation and testing documentation, tour of the control room and discussions with operators, and walkdowns of installed equipment, the inspector had reasonable assurance that the licensee has appropriately implemented the voluntary industry initiative.
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 and has been tuned 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 Final Safety Analysis Report and the Technical Specification Bases documents 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 ST-EMT-A and ST-EMT-B 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 startup transformer. The 4.16-kV engineered safeguards buses are normally energized from the main generator through each train's unit auxiliary transformer and the non-engineered safeguards buses. 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.
- (4) The inspector held discussions with licensee staff and identified that the vendor guidance, including periodic tests, setpoint verification, and equipment maintenance and inspections had been integrated into plant procedures and processes. The licensee had performed a pre-inspection self-assessment, documented in Condition Report LO-WLO-2019-00029 which documented, in part, the licensee's actions to determine if any of the open phase detection components needed to be included in the Maintenance Rule program and integrate previous operating experience from other Entergy inspections into the Waterford Steam Electric Station, Unit 3, program. The licensee was in the process of developing additional procedures and processes to inspect and maintain the PCS2000 equipment in addition to that recommended by the vendor, and to meet North American Electric Reliability Corporation standards.
EXIT MEETINGS AND DEBRIEFS
The inspector verified no proprietary information was retained or documented in this report.
- On December 11, 2019, the inspector presented the Temporary Instruction 2515/194 results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2515/194
Calculations
ECE15-002
Coordination of Open Phase Detection Time Delay Trip
Setting
Corrective Action
Documents
AR 264850264850Create a new RQ under PMID-5234 and PMID-5235 to
replace batteries for components installed in the Open Phase
Detection System for ST-A and ST-B. Battery replacements
must occur at or before 10 years.
2/16/2016
CR-WF3-2019-
06595, CR-WF3-
2019-06597, CR-
Corrective Action
Documents
Resulting from
Inspection
CR-WF3-2019-
08921
Drawings
5817-14365
SUT-A Start Up Transformer OPD Systems 1 & 2
Communication Block Diagram
5817-14375,
Sheet 1
SUT-A Start Up Transformer OPD Systems 1 & 2 Plant
Contacts Schematic Diagram
5817-14376,
Sheet 1
SUT-B Start Up Transformer OPD Systems 1 & 2 Plant
Contacts Schematic Diagram
B424, Sheet 2244 Startup Transf 3A Diff Relay and Open Phase Detection
B424, Sheet 2245 Startup Transf 3A Lockout Relay
B424, Sheet 3089 ST EMT-A Open Phase Detection Control Wiring Diagram
B424, Sheet 3090 ST EMT-B Open Phase Detection Control Wiring Diagram
G285
Main One Line Diagram
G347
Transformer Yard Conduit & Grounding
Engineering
Changes
Design Change to Detect Open Phase Condition on Primary
Side of Startup Transformers A and B (Byron Event)
IER-L2-12-14, CR-WF-2012-932, SIPD 1630
000
Startup Transformer A - Design Change to Detect Open
Phase Condition (CHILD EC OF 52305)
Activation of Trip Circuit on The PCS2000 Open Phase
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Detection System for Startup Transformers A and B (Byron
Event) IER-L2-12-14, CR-WF3-2012-932 (PARENT)
Miscellaneous
Factory Acceptance Test - Waterford SUT A
9/2/2015
Factory Acceptance Test - Waterford SUT B
9/3/2015
LBDCR #16-066
LBDCR updates FSAR Section 8.2.1.6.4 and TS
Bases 3/4.8.1 to include descriptions of the Open Phase
Detection system trip capability for Startup Transformers ST
EMTA and ST EMTB as a result of EC62977.
CHILD EC62977
EC80850
Enable Open Phase Detection Trip Function - CHILD for ST
EMTA
PCS2000 Open
Phase Detection
System SAT
Waterford SUTB Site Acceptance Test
Post Modification
Test Plan for EC 2306 ECN61227
Startup Transformer A - Design Change to Detect Open
Phase Condition (CHILD EC OF 52305)
Post Modification
Test Plan for EC 2307 ECN61228
Startup Transformer B - Design Change to Detect Open
Phase Condition (CHILD EC OF 52305)
Procedure
Improvement
Request to
ME-004-071
Add A New Section to ME-004-071 for the Open Phase
Detection System (OPD)
N/A
Topic Notes EC No. 62976, Rev.
No. 0
Enable Open Phase Detection Trip Function - PARENT EC
WF3-EE-17-
00001
SUT-A & SUT-B Open Phase Detection Monitoring Period
Report November 2015 - May 2016
WF3-EE-17-
00002
SUT-A & SUT-B Open Phase Detection Monitoring Period
Report May 2016 - May 2017
Procedures
OP-600-035
MT, UAT, SUT Local Panel (Section 4.3, SUT A(B) Open
Phase Detection)
017
Self-Assessments LO-WLO-2019-
Self-Assessment NRC Inspection TI 2515/194
8/15/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
00029
Work Orders
00397144
Perform Modification EC52306 on ST EMTA Open Phase
2/11/2015
00441413
RF21-Complete Install of Open Phase Detect Sys for ST
EMTA
3/11/2019
00441419
RF21-Complete Install of Open Phase Detect Sys for ST
EMTB
4/2/2019
00524970
ST IC3089-A1, Retrieve OPD Computer Data
5/17/2019
00524972
ST IC3090-B1, Retrieve OPD Computer Data
5/17/2019