May 17, 2018

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555

SUBJECT: BYRON STATION, UNITS 1 AND 2—NRC INSPECTION OF

TEMPORARY INSTRUCTION 2515/194, INSPECTION OF THE LICENSEE’S
IMPLEMENTATION OF INDUSTRY INITIATIVE ASSOCIATED WITH THE OPEN
PHASE CONDITION DESIGN VULNERABILITIES IN ELECTRIC POWER
SYSTEMS (NRC BULLETIN 2012-01)—INSPECTION REPORT
05000454/2018011; 05000455/2018011

Dear Mr. Hanson:

On April 5, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Byron Station, Units 1 and 2. On April 5, 2018, the inspectors discussed the results of this
inspection Mr. T. Chalmers and other members of your staff. The results of this inspection are
documented in the enclosed report.

The NRC inspectors 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 Title 10 of the Code of Federal Regulations, Part 2.390, “Public
Inspections, Exemptions, Requests for Withholding.”

Sincerely,

/RA/

Robert C. Daley, Chief

Engineering Branch 3
Division of Reactor Safety

Docket Nos. 50–454; 50–455

License Nos. NPF–37; NPF–66

Enclosure:
IR 05000454/2018011; 05000455/2018011
Letter to Bryan C. Hanson from Robert C. Daley dated May 17, 2018

SUBJECT: BYRON STATION, UNITS 1 AND 2—NRC INSPECTION OF

TEMPORARY INSTRUCTION 2515/194, INSPECTION OF THE LICENSEE’S
IMPLEMENTATION OF INDUSTRY INITIATIVE ASSOCIATED WITH THE OPEN
PHASE CONDITION DESIGN VULNERABILITIES IN ELECTRIC POWER
SYSTEMS (NRC BULLETIN 2012-01)—INSPECTION REPORT
05000454/2018011; 05000455/2018011

DISTRIBUTION:
Jeremy Bowen
RidsNrrDorlLpl3
RidsNrrPMByron Resource
RidsNrrDirsIrib Resource
Steven West
Darrell Roberts
Richard Skokowski
Allan Barker
DRPIII
DRSIII
[email protected]
[email protected]

ADAMS Accession Number ML: 18138A136

OFFICE RIII RIII RIII RIII
NAME ADahbur:cl RDaley
DATE 05/17/18 05/17/18
OFFICIAL RECORD COPY
 U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Numbers: 50–454; 50–455

License Numbers: NPF–37; NPF–66

Report Numbers: 05000454/2018011; 05000455/2018011

Enterprise Identifier: I–2018–011–0015

Licensee: Exelon Generation Company, LLC

Facility: Byron Station, Units 1 and 2

Location: Byron, IL

Dates: April 2, 2018, through April 5, 2018

Inspectors: A. Dahbur, Senior Reactor Inspector (Lead)

I. Hafeez, Reactor Inspector

Accompanying J. Quichocho, Chief, NRR/DE/EEOB

Personnel: H. Kodali, Electrical Engineer, NRR/DE/EEOB
S. Elkhiamy, Reactor Inspector, (Region I, Observer)

Approved by: R. Daley, Chief

Branch 3
Division of Reactor Safety

Enclosure
 SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensee’s 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 Byron Station, Units 1 and 2, in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRC’s 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

None

Additional Tracking Items

None

2
INSPECTION SCOPE

Inspections were conducted using the appropriate portions of the temporary instruction (TI)
in effect at the beginning of the inspection unless otherwise noted. Currently approved
TIs with their attached revision histories are located on the public website at
https://www.nrc.gov/reading-rm/doc-collections/insp-manual/temp-instructions/. Samples were
declared complete when the TI requirements most appropriate to the inspection activity were
met consistent with Inspection Manual Chapter 2515, “Light-Water Reactor Inspection Program
—Operations Phase.” The inspectors 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)

The inspectors conducted interviews and discussions with the licensee, reviewed available
design, testing, grid data trending results documentation, and conducted walkdowns of installed
equipment. The team verified that the licensee had completed the installation and testing of
equipment (including 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.

The inspectors performed Section 03.01 of the Temporary Instruction in order to determination
whether the licensee appropriately implemented the voluntary industry initiative, dated
March 16, 2015 (ADAMS Accession No. ML15075A454).

The team performed Section 03.02 of the Temporary Instruction to gather information to
determine whether the modifications implemented by the licensee of each unique open phase
condition system design adequately address potential open phase conditions. The information
gathered for this section is tabulated in attachment “Table 1—Information Gathered for
TI 2515/194,” to this report.

INSPECTION RESULTS

Observation TI 2515/194
Byron Station selected Schweitzer Engineering Laboratories (SEL) 451-5 microprocessor
based relays for the open phase detection system. The relay schemes monitor and compare
the positive, negative and zero sequence current input from existing Current Transformers on
the high side of System Auxiliary Transformers (SATs) 142-1, 142-2, 242-1 and 242-2 to detect
loss of phase or low load conditions. The relay algorithm/scheme and associated setpoint
calculations were developed by the licensee to detect the loss of phase on the preferred offsite
source for the engineered safety feature buses and initiate actions to separate that source from
the onsite distribution system. The relay schemes also used a time delay to ride out a short
duration transient but allow sufficient time to detect a valid phase failure condition. The
licensee completed the monitoring mode of operation of open phase system and enabled the
tripping function for full implementation in November 2014.

3
Based on interviews and discussions with the licensee, review of available design, testing, grid
data trending results documentation, and walkdowns of installed equipment, the team had
reasonable assurance the licensee appropriately implemented the voluntary industry initiative.

No findings were identified.

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

a. Detection, Alarms and General Criteria

(1) The inspectors determined by walkdowns and observation that open phase
conditions will be detected and alarmed in the control room for each unit.

(2) Based on review of the licensee calculation for the relay setting limits used in the
Open Phase Condition algorithms, the inspectors determined that detection circuits
were sensitive enough to identify an open phase condition for all credited loading
conditions.

(3) Licensee analysis showed that the short time delay used in the open phase
condition design/protective scheme will minimize misoperation or spurious trip in the
range of voltage unbalance normally expected in the transmission system. The
analysis also showed that time delay coordinated with switchyard faults. In addition,
since 2014 in when the open phase condition scheme was activated/in-service, the
system did not cause any trip.

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

(5) The licensee revised Byron Updated Final Safety Analysis Report,
Section 8.3.1.1.2.1 “Offsite Power Sources (SATs),” and added the loss of phase
protection. The change was incorporated into Updated Final Safety Analysis
Report, Revision 16. The revision did not discuss the design features and analysis
in detail. However, the licensee concluded that the level of detail provided for the
open phase condition protection was consistent with the level of detail provided for
the other conditions that could trip the SAT feed breakers to the engineered safety
feature buses.

b. Protective Actions Criteria

(1) The licensee determined they were susceptible to an open phase condition, and
implemented design changes to mitigate the effects.

(2) The inspectors determined that with an open phase condition present and no
accident condition signal, the SEL 451-5 protection relay system would not
adversely affect the function of important-to-safety systems, structures and
components. The licensee’s open phase condition design solution added a set of
additional tripping inputs in parallel to the existing transformer isolation controls.
This addition added a new tripping condition (open phase) to the electrical faults
which result in tripping the SAT lockout relays after short time delay. The credited
plant response would be the same regardless of the conditions that generated the
isolation of the transformer. In addition, the licensee’s analysis verified that the

4
 open phase condition Relays can detect and isolate an open phase condition
prior to any motor damage or loss of Technical Specifications function for
important-to-safety equipment.

(3) The inspectors determined that with an open phase condition present and an
accident condition signal present, the SEL 451-5 protection relay system would
result in tripping the SAT lockout relays after a short time delay. The SAT lockout
relays will then trip the SAT primary and secondary side breakers. This will result in
the bus loss of voltage relays dropping out and transferring the safety-related
busses to their respective emergency diesel generators.

(4) The inspectors verified that periodic test, calibrations, setpoint verifications were
established for the newly added SEL 451-5 protection relays system. No
surveillance requirements for the SEL 451-5 were added to the plant Technical
Specifications.

EXIT MEETINGS AND DEBRIEFS

On April 5, 2018, the inspectors presented the Temporary Instruction 2515/194 inspection
results to Mr. T. Chalmers, Plant Manager, and other members of the licensee staff.

The inspectors verified no proprietary information was retained, however some material used by
the team to document compliance was characterized as proprietary by the vendor.

DOCUMENTS REVIEWED

Inspection Procedure Temporary Instruction 2515/194

Drawings:

- 6E-0-4000B; One Line Current Relay & Instrument Diagram Of 345KV Bus-4,5,6 &7;
Revision P
- 6E-0-4106B; Schematic Diagram Current & Potential Circuits For Sys. Aux. TR. 242 & 345KV
Bus 13 (Units 1 &2); Revision F
- 6E-0-4106C; Schematic Diagram System 1 &2 Protective Relays D.C. Circuits Sys. Aux.
TR 242 345KV Bus 13; Revision D
- 6E-0-4106D; 3-Line Current & Potential Schematic Diagram 345KV Bus 13 SAT-242 Revenue
Metering; Revision C
- 6E-1-4002B; Single Line Diagram System Auxiliary Transformer and 6.9KV Switchgear;
Revision M
- 6E-1-4016C; Relaying & Metering Diagram System Auxiliary Transformers 142-1 & 142-2;
Revision N
- 6E-2-4016C; Relaying & Metering Diagram System Auxiliary Transformers 242-1 & 242-2;
Revision N
- 6E-1-4030AN002; Schematic Diagram Annunciator Window Engraving 1UL-AN023 &
24 AT 1PM01J; Revision Y
- 6E-1-4030AP01; Schematic Diagram System Auxiliary Transformer 142-1 Tripping Relays
- 6E-1-4030AP02; Schematic Diagram System Auxiliary Transformer 142-2 Tripping Relays

5
Procedures:

- 2BOSR 8.1.1-1; Normal and Reserve Offsite AC Power Availability Weekly Surveillance;
Revision 11
- BAR 1-20-A4; SAT 142-2 Lockout Relay Trip Alarm; Revision 5
- BAR 1-20-E7; Sat 142-1 Low Load/Trouble Alarm; Revision 4
- BAR 2-20-E5; SAT 242-1 Loss of Phase Alarm; Revision 4
- 1BOL AP1; Unit 1 SAT Low Load or Trouble Condition Loss of Phase Monitoring; Revision 2
- BOP AP-52; Restoring Unit System Aux Transformer 142-1 and 142-2 During Power
Operation; Revision 23

Calculation:

- BYR13-177; Unit 1 and Unit 2 Loss of Phase Detection Relay Settings; Revision 01
- BYR13-221; Open Phase Detection LOCA Analysis; Revision 00
- BYR13-176; Loss of Phase Detection EMTP Analysis; Revision 01
- EC 389896; SAT Loss of Phase Relay Installation; Revision 04
- 6G-12-008; 50.59 Evaluation for Loss of Phase Detection Scheme Phase Unbalance Relay
Installation; Revision 2
- EC 623307; Open Phase Evaluations on Secondary Side of Auxiliary Transformer

Condition Reports Issued during Inspection:

- AR 04122056; SAT Loss of Phase Relay Minimum Load Requirement; 04/02/2018

- AR 04122523; Identified Error in 50.59; 04/03/2018
- AR 04122945; Schematic Drawing Errors; 04/04/2018

Work Orders:
- 01564945; Install Modification per EC 389896 – SAT 142-1
- 01565039; Install Modification per EC 389896 – SAT 142-2
- 01565043; Install Modification per EC 389896 – SAT 242-1
- 01565047; Install Modification per EC 389896 – SAT 242-2

6
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

Open Phase Condition

A Detection and Alarm Scheme Describe Observations/Comments
1 Are all credited offsite power Yes The two credited offsite power sources are the
sources specified in Updated No power feeds from the switchyard to the Unit 1
Final Safety Analysis System Auxiliary Transformers (SATs) 142-1 and
Report (UFSAR), Chapters 8.1, 142-2 and to the Unit 2 SATs 242-1 and 242-2.
8.2, and 8.3, and plant For each unit there is a common feed from the
Technical Specifications (TSs) switchyard and then there is a ‘T’ connection near
considered in the design of the SATs, where the common feed splits into two
Open Phase Condition (OPC) sections to connect to the two SATs. Byron
detection and protection Station does not use a backfeed configuration.
schemes? Engineering Change (EC) 389896 installed OPC
relays to protect the Unit 1 SATs, and EC 389897
installed OPC relays to connect the Unit 2 SATs.
The Schweitzer Engineering Laboratories (SEL)
451 relay was selected to be used as OPC relay.
2 Are OPC detection scheme(s) Yes The ESF buses are normally aligned to the SATs
installed to monitor the No from their respective unit (e.g., 4.16 kV ESF
qualified offsite power paths to Bus 141 is fed by SAT 142-1 and 4.16 kV ESF
the engineered safety Bus 142 is fed by SAT 142-2). The ESF buses
feature (ESF) buses during all also can be aligned to the reserve feed from the
modes of operation? opposite unit’s SATs via the crosstie breakers.
OPC protection is provided for both the Unit 1
and Unit 2 SATs per ECs 389896 and 389897.

The EC 623307 evaluated the potential need for

OPC detection on the secondary sides of the
SATs that connect the SATs to the 4.16 kV and
6.9 kV buses. The EC concluded that due to the
connections being non-segregated phase buses,
an open phase circuit failure is not credible.
Therefore OPC detection is not required for the
secondary side connections of the SATs to the
4.16 kV ESF buses.
3 a. What is the scope of OPCs a. The scope of the OPCs considered include:
considered by the licensee?
The two credited offsite power sources are the
power feeds from the switchyard to the Unit 1
SATs 142-1 and 142-2 and to the Unit 2
SATs 242-1 and 242-2. For each unit there is
a common feed from the switchyard and then
there is a ‘T’ connection near the SATs, where
the common feed splits into two sections to
connect to the two SATs.

Attachment
TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

b. Did the licensee exclude Yes b. Consistent with the industry initiative and as
certain OPCs (e.g., high No discussed in Calculations BYR13-176 and
voltage or low voltage side BYR13-177, the Byron Station OPC analysis
of power transformers), included consideration of the following types of
operating and loading OPCs on the two credited offsite power
configurations in their sources:
analyses? If so, identify the
technical justifications for • Single or Double Open Phase and Ground
any exclusion. on SAT Primary
• Single Ungrounded or Double
Grounded/Ungrounded on SAT Primary
• Double Ungrounded Open Phase on SAT
Primary

These OPCs were evaluated for all expected

operating and loading configurations.

The only exception is when the SAT is initially

energized. A minimum load of 2.27 A primary
current (about 1400 kVA) needs to be applied
to satisfy minimum loading requirements. A
low load/trouble alarm window is provided to
alert the operators to this condition. After the
SATs are energized and loaded, this minimum
loading requirement is met during all normal
and accident loading conditions.

The EC 623307 evaluated the potential need

for OPC detection on the secondary sides of
the SATs that connect the SATs to the 4.16 kV
and 6.9 kV buses. The EC concluded that due
to the connections being non-segregated
phase buses, an open phase circuit failure is
not credible. Therefore OPC detection is not
required for the secondary side connections of
the SATs to the 4.16 kV ESF buses.

The 4.16 kV ESF switchgear buses include

switchgear breakers and cable feeds to 4.16
kV loads and 480V ESF switchgear buses.
Each 480V ESF switchgear houses a
stepdown transformer (4.16 kV to 480V) and a
480V bus including load center breakers that
have cable feeds to 480V load center loads
and 480V motor control centers (MCCs). The
480V MCCs includes compartments with
molded case circuit breakers and cable feeds
to small 480V MCC loads. The cables are
routed within plant trays or conduits.

2
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

A separate OPC detection system that monitors

the circuits at the ESF 4.16 kV, 480V switchgear,
and 480V MCCs is not required, since an OPC on
an ESF circuit would be considered a single
failure, and the redundant train would be
available to provide the required safe shutdown
functions. Additionally, detecting OPCs on the
low voltage side is not part of the industry
initiative.
4 Are the detection schemes Yes The OPC relays are capable of detecting OPCs
capable to identify OPCs under No under all operating electrical system
all operating electrical system configurations and plant loading conditions.
configurations and plant The only exception is when the SAT is initially
loading conditions? energized. A minimum load of 2.27 A primary
current (about 1400 kVA) needs to be applied to
satisfy minimum loading requirements. A low
load/trouble alarm window is provided to alert the
operators to this condition. After the SATs are
energized and loaded, this minimum loading
requirement is met during all normal and accident
loading conditions.
5 a. If the licensee determined Yes a. The licensee determined that OPC detection is
that OPC detection and No needed at the Byron Station and that alarm,
alarm scheme was not and protection is required. The OPC relays
needed, did the licensee were installed per ECs 389896 and 389897.
provide adequate
calculational bases or test
data?

b. Are all OPCs detected and Yes b. the OPC relays installed by these EC’s will
alarmed in the Main Control No detect OPCs and alarm in the MCR.
Room (MCR) with the
existing relays?
6 a. Are the detection and alarm Yes a. For each SAT, an OPC relay is used to detect
circuits independent of No OPCs and to generate alarm and actuation
actuation (protection) signals. The relay does have independent
circuits? output circuits for alarms and for actuation.

b. If the detection, alarm and Yes b. There are no interfaces with Class 1E systems.
actuation circuits are No The current sensing inputs for the Byron OPC
non-Class 1E, was there any relays are connected to the SAT 345 kV
interface with Class 1E bushing current transformers (CTs), which are
systems? nonsafety-related (NSR). In the same manner
as other SAT protective relays, the trip outputs
from the Byron OPC relays are connected to
the SAT lockout relays, which are NSR. The
OPC relay, or any other SAT protective relay,
would trip the SAT lockout relay, which would
then trip SAT high side (345 kV) and low side

3
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

(4.16 kV and 6.9 kV) breakers to isolate the

SATs. The alarm outputs from the Byron OPC
relays are connected to NSR alarm windows in
the MCR.
7 a. Did the manufacturer Yes a. Per Calculation BYR13-176, the Byron OPC
provide any information/data No relays use phase and sequence currents on
for the capability of installed the high side (345 kV) of the SATs to detect
relays to detect conditions, OPCs. The SEL-451-5 relays are used for the
such as unbalanced voltage OPC relays. According to the vendor, this
and current, negative relay has a minimum relay input current
sequence current, hardware detection limit of 0.02 A secondary
subharmonic current or other current (Reference Section 2.1 of Calculation
parameters used to detect BYR13-177) and is able to detect a minimum
OPC in the offsite power change in current of 0.01 A secondary current
system? (Reference Section 2.5 of Calculation
BYR13-177). The OPC relay does not use
unbalanced voltages or subharmonic currents
as inputs to detect an OPC. Also, the relay
uses filtered inputs for the current input signals,
so subharmonics would not affect the OPC
relays (Reference: BYR 13-176, Section 1.0).

b. What are the analyses and Yes b. The Electric Magnetic Transit Program (EMTP)
criteria used by the licensee to No was used to model the Byron electrical system
identify the power system and to simulate various types of OPCs (single
unbalance due to OPCs; and and double open phases, with and without a
loading and operating ground) under different loading conditions.
configurations considered for
all loading conditions which  For single or double open phase and ground,
involve plant trip followed by zero sequence current is used to detect an
bus transfer condition? OPC.
 For single ungrounded or double
grounded/ungrounded open phase, phase
currents are used to detect an OPC, and
zero and negative currents are used as
security elements to differentiate a true OPC
from a fault.
 For double ungrounded open phases, phase
currents are used to detect an OPC, and
zero sequence current is used as a security
element to differentiate a true OPC from a
fault.

4
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

c. If certain conditions cannot c. The analysis accounted for minimum relay

be detected, did the licensee sensitivity. The analysis identified that there
document the technical is a minimum current, equivalent to about
basis for its acceptability? 1400 kVA or 2.27 A, that is required for the
OPC relay to detect an ungrounded OPC.
This minimum loading requirement is met
during all normal and accident loading
conditions (Reference: BYR 13-177,
Section 8.8).

d. Did the licensee perform d. Functional testing of the OPC relays was
functional testing to validate performed per Work Orders #01564945,
limitations specified by the 01565039, 01565043, and 01565047 for
manufacturer of the relays? SATs 142-1, 142-2, 242-1, and 242-2,
respectively.
8 a. Do OPC detection circuit Yes a. As discussed in Section 6 of
design features minimize No Calculation BYR13-176, security elements
spurious detections due to (zero and negative sequence current limits)
voltage perturbations were added to allow the relay to distinguish
observed during events between a true OPC and a fault downstream of
which are normally expected the SATs. This ensures that for a fault on a
in the transmission system? bus or a load fed by the SAT, the OPC relays
will not actuate and trip the SATs. Instead, the
protective devices closest to the fault will
isolate the faulted load or bus, and the SAT will
remain available to supply power to the
remaining loads.

b. Identify whether the licensee b. In addition, as discussed in Section 7.4

considered alarm/trip of Calculation BYR13-176, a 30 cycle
settings coordination with (0.5 second) time delay is provided to allow
other electric power system the OPC relay to coordinate with switchyard
relays including transmission transmission relays for Zone 2 protection, so
system protection features that the OPC relay will not spuriously actuate
setup to avoid false for a switchyard fault.
indications or unnecessary
alarms.
9 Identify how the alarm features Transmittal of Design Information #BYR-16-005
provided in the MCR including identified the maintenance testing requirements
setpoints are maintained, for the OPC relays per North American Reliability
calibrated, and controlled. Corporation (NERC) Standard PRC-005-2. Note
that PRC-005-6 has superseded PRC-005-2;
however, the requirements applicable to the OPC
relays are the same in both revisions of PRC-005.
The Preventative Maintenance Identity
Documents 00190772-03, 00190773-03,
00190774-03, and 00190775-03 are in place
to track the periodic testing of the OPC relays.
The Preventive maintenance are scheduled to
be performed on a 9 year frequency with a

5
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

25 percent grace period, which is bounded by the

12 year frequency specified in PRC-005-6 and is
acceptable. The setpoints are maintained by
SEL 451 relay “software control program.”
10 Does the OPC detection Yes The relay uses filtered inputs for the current input
scheme consider No signals, so subharmonics would not affect the
subharmonics in the supply OPC relays. Thus, subharmonics were not
power or offsite power system? considered during the design of the OPC relays.
No issues with subharmonics were identified
during the testing and monitoring of the OPC
relays. A 125 volts direct current (VDC) bus is
used to provide control power for each OPC, so
the power source would not be susceptible to
subharmonics. After the OPC relays were
installed, the relays were monitored for a period
of time in the alarm-only configuration, and proper
operation of the relays was verified. Therefore,
spurious operation due to subharmonics is not a
concern.
11 Are OPC detection and alarm Yes Action Tracking Item (ATI) #01570501-53
circuit components scoped into No documents the Maintenance Rule scoping review
the licensee’s maintenance performed by Engineering for the OPC relays.
rule program? According to this ATI, the functions that the OPC
relays are protecting are already scoped into the
Maintenance Rule. A spurious relay actuation
would result in a spurious SAT trip, which would
be a functional failure of the SAT per
Maintenance Rule Function MP-08, “Transform
Switchyard Voltage to 4 KV and 6.9 KV for Plant
Use.” This would ensure that an OPC relay
failure that causes a spurious SAT trip is resolved
in a timely manner. Consistent with other SAT
protective relays, the OPC relays are not
individually listed in the Maintenance Rule
Program.

An OPC relay trouble condition (loss of power,

software issues (S-alarm), hardware trouble
(H-alarm) and Minload )that results in the relay
not being functional would be identified as an
“Unresolved Maintenance Issue,” per
Requirement R5 of NERC Standard PRC-005-6.
This would ensure that a failed OPC relay is
either repaired or replaced in a timely manner.
This is consistent with other SAT protective
relays.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

Open Phase Condition

B Protection scheme Describe Observations/Comments
1 Record location of the sensing The Byron OPC relays monitor current on the
of the protection scheme high side (345 kV) of the SATs. The Byron OPC
(e.g., high voltage or low relay current sensing inputs are connected to the
voltage side of the transformer, current transformers (CTs) that are part of the
ESF bus, etc.). 345 kV bushings on the SATs.
2 a. Record the classification of a. Classification: Safety / Non-Safety (circle one)
the protection scheme,
safety or non-safety.

b. Did the licensee consider Yes b. Yes. The OPC protection scheme is classified
the interface requirements No as NSR and the OPC relay configuration and
for non-safety with circuitry does not interface with safety-related
safety-related circuits? (SR) circuits.

As stated in Section 4.1.4.2 of the Design

Considerations Summary (DCS) for ECs
389896 and 389397, “The new ‘Loss of Phase
Detection Cabinet’ 1(2)PA55J and all of the
components being installed within this cabinet
are considered NSR.” In Section 4.1.4.2 of the
DCS, it states that the design change is
classified as SR since the cabinet attachment
to the wall is SR since the wall is SR. The
anchors must be procured safety related. The
floor anchor installation for the panel support
frame is a SR activity and must be performed
according to all SR procedures, practices and
quality control hold points.

The current sensing inputs for the Byron OPC

relays are connected to the SAT 345 kV
bushing CTs, which are NSR. In the same
manner as other SAT protective relays, the trip
outputs from the Byron OPC relays are
connected to the SAT lockout relays, which are
NSR. The OPC relay, or any other SAT
protective relay, would trip the SAT lockout
relay, which would then trip SAT high side
(345 kV) and low side (4.16 kV and 6.9 kV)
breakers to isolate the SATs. The alarm
outputs from the Byron OPC relays are
connected to NSR alarm windows in the MCR.
Based on the above discussion, the licensee
considered interface requirements for
non-safety with SR circuits.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

3 a. Record the type of the a. Type: Digital / Non-Digital (circle one)

protection scheme, digital or
non-digital.

b. Are cyber security Yes b. The OPC (SEL-451) relays installed per EC
requirements specified for No 389896 (U1) and EC 389897 (U2) were
digital detection scheme? N/A screened and determined to be Critical Digital
Assets (CDAs) in scope of 10 CFR 73.54.

During the design process, protection from

accidental and malicious attempts to
manipulate relay programming were
established

A Disaster Recovery Plan has been developed

and is stored in the Records Management
System to ensure timely restoration of the
SEL-451 relays in the event of failure.
4 Did the licensee consider any Yes The SEL-451 is highly reliable relay. The relay is
design features to prevent No continuously running self-diagnostic routines. In
protective functional failures for the unlikely event that an internal relay failure is
OPC protection system? detected, a trouble alarm is annunciated in the
MCR and the relay tripping function is blocked to
prevent the possibility of a spurious relay trip.
See references below and also Section 4.1.5 of
(DCS for ECs 389896 and 389897. Additionally,
Operating Experience (OPEX) reviews that were
performed for ECs 389896 and 389897 only
identified one OPEX (OE24398 at Comanche
Peak U1) where two SEL-551 relay failures
occurred approximately 1 month apart due to a
manufacturing defect in the voltage regulator
integrated circuit. The SEL has since upgraded
the power supply voltage regulators, which are
not susceptible to the same failure mechanism.
This issue was resolved prior to the SEL-451-5
relays for Byron Station being manufactured. The
remaining 10 OPEX items that were identified
were due to incorrect relay settings or
programming and not due to internal relay
failures, or the OPEXs identified cases where an
OPC occurred and OPC protection had not been
provided. (Reference Section 4.1.16 of the DCS
for ECs 389896 and 389897)
5 Identify the number of The credited offsite power sources are the Units 1
channels provided per offsite and 2 SATs. Each Byron Unit has two SATs.
power source and if there is One OPC relay is provided for each SAT. The
independence between Units 1 OPC relays are completely independent
channels and sensors. from the Unit 2 OPC relays and do not share any
sensor (i.e., CT) inputs.

8
TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

For each unit, the two SATs (i.e., Unit 1

SATs 142-1 and 142-2) share a common
connection to the switchyard. There is a “T”
connection near the SATs that connects each
SAT to the common feed to the switchyard. It is
possible that an open phase upstream of the “T”
connection could cause circulating currents in the
two SATs if the SAT loading is uneven between
the two SATs. Therefore, it is necessary for each
OPC relay to be connected to the CTs from both
SATs to be able to detect OPCs on the common
feed to the switchyard with uneven SAT loading
conditions. Reference the following discussion
from Section 6.1.2.1 of Calculation BYR13-176:

“At Byron, each unit has two identical

SATs operated off a common feed from
the switchyard. An open phase can –
and did (at Byron) – occur on the
common point prior to the “T”
connection. Uneven transformer loading
will cause a circulating current to exist in
both SAT H windings even if an open
phase exists upstream of the “T”
connection. The circulating current
exists in the SAT neutrals and the
opened phase, which means that an
Ia<MINDETC condition at the individual
transformers does not exist. For this
reason, it is necessary to not only
monitor the six SAT phase currents
(three for each SAT), but also the phase
currents flowing into the “T” connection
from the switchyard. Following
Kirchhoff’s current law, this current can
be calculated by simply taking the
vectoral sum (IVsum in the diagram below)
of SAT phase currents, so additional
CTs are not required.

The logic string will be altered so that it checks for

current unbalance in the common feed as well as
current unbalance in the individual SAT feed. This
logic will be able to detect an open phase at the
common SAT feed.”

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

6 a. What is the safety a. Non-safety related. The Byron OPC relays are
classification of power provided control power from the 125 VDC NSR
supply for the protection distribution panel that is of the same electrical
scheme? division as the division used to provide control
power for the other SAT protective relays and
lockout relays:

 SAT 142-1 OPC Relay 851PST11 NSR

Div 11 Panel 1DC05EB
 SAT 142-2 OPC Relay 851PST12 NSR
Div 12 Panel 1DC06EB
 SAT 242-1 OPC Relay 851PST21 NSR
Div 21 Panel 2DC05EB
 SAT 242-2 OPC Relay 851PST22 NSR
Div 22 Panel 2DC06EB

The 125 VDC ESF battery of the same

electrical division provides power for the
associated NSR panel via two 1E/Non-1E
isolation fuses. For example, 125 VDC ESF
Battery 111 provides power to NSR Div. 11
Panel 1DC05EB. The SR stationary battery
calculations were updated due to the addition
of NSR panels.

b. Was a loss of power to the Yes b. Loss of direct current control power to the OPC
protection scheme No relay will not cause a spurious trip of the relay.
considered? Loss of direct current control power will result
in a relay low load/trouble alarm window being
actuated in the MCR, and the OPC relay will
not be functional and will not be able to trip on
an action OPC. (Reference: Section 4.1.5 of
the DCS for ECs 389896 and 389897)
7 Identify if the licensee No OPC and Relay Failure:
considered the consequences
of a failure or malfunction of a The OPC relays are continually running
channel. self-diagnostics. The inputs to the relay trouble
alarm are loss of power, software trouble
(S-alarm), hardware trouble (H-alarm) and
Minload. If a relay trouble condition were to be
detected, the relay tripping capability would be
automatically blocked, and a relay low
load/trouble alarm window would be annunciated
in the MCR.

One OPC relay is provided per SAT. For each

unit, the two SATs share a common connection to
the switchyard. While the two OPC relays per
unit are not redundant, there is some overlap in
protection for an OPC. Both OPC relays would

10
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

detect an OPC on the common line between the

Switchyard bus and upstream of the ‘T’
connection, where the line splits into two sections
to connect to each SAT. For an OPC on the line
section downstream of the ‘T’ connection, only
the OPC relay for the affect SAT would detect the
OPC. The other OPC relay would not be able to
detect the OPC.

OPC and Relay Failure:

Therefore, if an OPC relay had a trouble condition

and an OPC were to then occur, either the other
OPC relay would detect the OPC and trip the
SATs for an OPC on the common line or the
operators would respond per station procedures
to manually trip the SATs for the line section
downstream of the ‘T’ connection. (Reference
the DCS for ECs 389896 and 389897 and
Procedures BARs 1-20-E7, 1-20-E8, 2-20-E11,
and 2-20-E12.)

A spurious actuation of an OPC relay would result

in the SATs de-energizing and causing a loss of
offsite power (LOOP). The diesel generators
(DGs) would re-energize the 4.16 kV ESF buses
and the remaining Non-ESF buses would autobus
transfer to the Unite Auxiliary Transformers
(UATs). The unit is expected to keep operating
under these conditions. Spurious actuation of an
OPC relay would not cause a turbine/generator or
reactor trip.
8 Did the design consider the Yes As described in GDC 17, “Electric Power
single failure criteria as No Systems,” the single failure criteria as it applies to
outlined in the General Design the offsite power supplies is at the system level.
Criterias (GDCs) or the Specifically, that a single failure will only affect
principle design criteria one supply, and will not propagate to the
specified in the updated final alternate supply. This is based on the physical
safety analysis report? configuration of the transmission lines, right of
ways, and the transmission circuit supplying the
SATs, and means to rapidly locate and isolate
system faults.

11
 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

The NSR OPC relays are only connected to the

NSR SAT lockout relays. There are no interfaces
with the ESF buses or the ESF DGs. Therefore,
if an OPC were to occur with a single failure of a
4.16 kV ESF bus, the OPC relays would trip the
SAT lockout relays. The SAT lockout relays
would trip the SAT high and low side breakers
(including the SAT feed breakers to the 4.16 kV
ESF buses).

Both DGs would auto start on bus undervoltage.

The DG for the non-faulted bus would re-energize
its bus and sequence on the required loads. The
DG for the faulted bus would run unloaded and
not attempt to re-energize its bus due to the bus
being locked out. This is consistent with the
single failure criteria for the SR portion of the
Auxiliary Power System.

Therefore, Byron Station's installation and

activation of an automatic loss of phase
detection and actuation system addresses
the identified gap in the inclusion of adequate
provisions to ensure a failure of the offsite
circuit as a result of an open phase condition will
not preclude the onsite electrical power system
from being able to perform its specified safety
functions. Specifically, in accordance with
GDC 17, the onsite power systems will retain
sufficient capacity and capability to assure that
(1) specified acceptable fuel design limits and
design conditions of the reactor coolant
pressure boundary are not exceeded as a result
of anticipated operational occurrences and
(2) the core is cooled and containment integrity
and other vital functions will be maintained in
the event of postulated accidents given an OPC
on the offsite electric power system and a single
failure in the onsite power system.
9 a. Did the licensee identify the Yes a. Calculation BYR13-176 Sections 3.11, 6.5 and
industry standards and No 7.1 and Attachment A evaluated the Byron
criteria to verify power area transmission system and accounted for
quality issues caused by normal unbalanced voltages and currents in
OPCs that affect redundant the grid. The bounding transmission system
ESF buses? sequence voltages are summarized in
Section 7.1.1 of Calculation BYR13-176 and
were used as inputs for the EMTP analysis for
OPCs.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

As discussed in Calculation BYR13-176, the

OPC relays measure phase currents on the
high side (345 kV) of the SATs. The OPC
relays use the phase current inputs to
calculate sequence currents, and then the
phase and sequence currents are used to
detect an OPC. Sequence voltages are not
used by the OPC relays.

In the event of an OPC, the OPC relays will

rapidly detect the OPC condition and trip the
SATs after a 30 cycle (0.5 second) time delay.
(Reference Section 7.4 of Calculation
BYR13-176.) The associated 4.16kV ESF bus
will experience an undervoltage condition.
This will start the emergency DG, load shed
the bus, and then load the bus with the
required ESF loads. The feed to the
associated 6.9kV bus will be automatically
transferred from the SAT to the UAT, if it is
available. That is, the actuation of the OPC
relays will produce the same results as the
actuation of other SAT protection devices.

Calculation BYR13-221 evaluated the effects

of negative sequence current on motor heating
during an OPC and determined that the
motors would not be damaged during the time
that it would take the OPC relays to isolate the
buses from the SATs. Due to the short
duration of an OPC condition, additional
evaluation of power quality issues caused by
an OPC is not required.
b. What industry standards
were used to develop the b. Industry standards were listed in Section 4,
acceptance criteria for OPC “References” of Calculation BYR13-176, Loss
trip setpoint or analytical of Phase Detection EMTP Analysis and in
limit? Calculation BYR13-221, Open Phase Detection
Loss of Coolant Accident (LOCA) Analysis.
10 What are the analytical limits or The logic strings and bounding values for the
criteria used for setpoints of OPC relays are summarized in Section 8 of
the actuation/protection Calculation BYR13-176. There are three logic
scheme to provide adequate strings used to detect OPCs as discussed in
protection for motors and Section 8.1 of Calculation BYR13-176:
sensitive equipment?
 Logic String 1 (Single or Double Grounded
Open Phase Detection)
 Logic String 2 (Single Ungrounded or Double
Grounded/Ungrounded Open Phase Detection)

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TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

 Logic String 3 (Double Ungrounded Open

Phase Detection)

The bounding values for the settings used in the

logic strings are summarized in Section 8.2 of
Calculation BYR13-176. These bounding values
were selected based on the results of the EMTP
analysis to provide a range of values that will be
able to promptly detect an OPC and trip the SATs
after a 30 cycle (0.5 second) time delay, while
also not tripping for other fault conditions.

Calculation BYR13-177 used the bounding values

from Calculation BYR13-176 as inputs and
applied CT and relay accuracy to determine the
actual setpoints used for the settings in the OPC
logic.

Calculation BYR13-221 performed an analysis to

verify that the ESF loads would not be damaged
during the time delay between when an OPC
occurs and when the SAT is tripped. As
discussed in Section 1.3 of Calculation
BYR13-221, this analysis evaluated the following
four items for the ESF buses:

 The impact of the single phase block start of

ESF loads on the bus protection scheme
(overcurrent and undervoltage).
 The impact of the single phase block start of
ESF loads on the motor protection scheme
(overcurrent).
 The heating (i22t) impact of single phase block
start of ESF loads on the running and starting
motors and motor operated valves (MOVs).
 The impact of isolating ESF loads from the
SATs during the starting sequence and then
restarting the ESF loads on the emergency
source.

As discussed in Section 6.2.3 of Calculation

BYR13-221 for motor heating, the induction
motors’ i22t capability is >= 40 pu. However, a
thermal limit of 20 pu was used during the OPC to
account for a second start (hot start) of the motor
after the emergency DG restores normal voltage
to the bus.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

As discussed in Section 8 of Calculation

BYR13-221, the analysis determined that no bus
or motor protective devices would trip during the
OPC, and the analysis also determined that the
motor thermal duties would be less than the
thermal limit of 20 pu for i22t heating. Therefore,
this ensures that all loads are protected from the
effects of an OPC.
11 What are the design features As discussed in Section 6 of Calculation
provided to preclude spurious BYR13-176, security elements (zero and negative
trips of the offsite power source sequence current limits) were added to allow the
(e.g. coincidence logic)? relay to distinguish between a true OPC and a
downstream fault. This ensures that for a fault on
a bus or a load fed by the SAT, the OPC relays
will not actuate and trip the SATs. Instead, the
protective devices closest to the fault will isolate
the faulted load or bus, and the SAT will remain
available to supply power to the remaining loads.

In addition, as discussed in Section 7.4 of

Calculation BYR13-176, a 30 cycle (0.5 second)
time delay is provided to allow the OPC relay to
coordinate with switchyard transmission relays for
Zone 2 protection, so that the OPC relay will not
spuriously actuate for a switchyard fault.
12 a. What analyses have been a. Calculation BYR13-221 performed an open
performed by the licensee phase detection LOCA analysis. This
which demonstrates that the calculation determined that the effects of
OPCs do not adversely negative sequence current during the OPC
affect the function(s) of time delay are acceptable and will not prevent
important-to-safety the ESF loads from functioning as required.
equipment required for safe Section 8.1.3 of Calculation BYR13-221 states,
shutdown during anticipated “Based on the results all motors and MOVs
operational occurrences, have the thermal capability to withstand the
design basis events, and postulated event.”
accidents?
(Note that as stated in Section 2.5.1 of
If an analyses was not Calculation BYR13-221, the Calculation used
performed, what justification an OPC time delay of 0.6023 seconds, which
was provided? included the 0.5 second time delay for the
OPC relay and additional times for operation
of the SAT lockout relay and the 345 kV circuit
breakers.)

b. Are bus transfer schemes Yes b. Bus transfer schemes do not apply. The ESF
and associated time delays No buses are always connected to the SATs.
considered?

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

13 Are OPC protection/actuation Yes The ATI #01570501-53 documents the

circuit components scoped, as No Maintenance Rule scoping review performed by
appropriate, into the licensee’s Engineering for the OPC relays. According to this
Maintenance Rule Program? ATI, the functions that the OPC relays are
protecting are already scoped into the
Maintenance Rule. A spurious relay actuation
would result in a spurious SAT trip, which would
be a functional failure of the SAT per
Maintenance Rule Function MP-08, “Transform
Switchyard Voltage to 4 KV and 6.9 KV for Plant
Use.” This would ensure that an OPC relay
failure that causes a spurious SAT trip is resolved
in a timely manner. Consistent with other SAT
protective relays, the OPC relays are not
individually listed in the Maintenance Rule
Program.

An OPC relay trouble condition that results in the

relay not being functional would be identified as
an “Unresolved Maintenance Issue” per
Requirement R5 of NERC Standard PRC-005-6.
This would ensure that a failed OPC relay is
either repaired or replaced in a timely manner.
This is consistent with other SAT protective
relays.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

C Describe Observations/Comments
UFSAR Updates to Reflect the Yes Byron Station has revised the UFSAR to add the
Need to Protect Against OPCs: No OPC relays to UFSAR Section 8.3.1.1.2.1 per
Using items 1 to 6 below as Document Revision Package 14-094 for Unit 1
examples, identify whether the EC 389896 and per Document Revision
licensee has updated the Package 14-090 for EC 389897. The level of
UFSAR (and supporting detail provided in the UFSAR for the OPC relays
documents such as is consistent with the level of detail provided in
calculations of record, design the UFSAR for the other SAT protective relays.
change modifications, etc.) to
ensure plant-specific licensing
basis/requirements include
discussions of the design
features and analyses related
to the effects of, and protection
for, any OPC design
vulnerability:
1 The plant-specific analysis and The plant-specific analysis is documented in
documentation that established Calculations BYR13-176, BYR13-177, and
the resolution of the OPC BYR13-221. The failure mode analysis is
design vulnerability, including documented in ECs 389896 and 389897.
the failure mode analysis
performed.  The plant-specific analysis is documented in
Calculations BYR13-176, “Loss of Phase
Detection EMTP Analysis” BYR13-177, “Unit 1
and 2 Loss of Phase Detection Relay Settings “,
and BYR13-221, “Open Phase Detection LOCA
Analysis”.

 The failure modes and effects analysis is

documented in ECs 389896 and 389897. The
components evaluated are—SEL-451 relays,
CTs on the high side of the SATs, new test
switches, existing watt-hour meters and
overcurrent relays. The classification used; No,
low, medium and high impact is based on the
impact of a single system or component failure.
A no impact event will allow the new relay
system to sustain failure without materially
impacting the relay system reliability. In a low
impact event, the system will still function to
isolate the 4.16 kV and 6.9 kV buses on a
phase balance, and will not induce a spurious
LOOP. A medium impact event is where
protection to the electrical system is lost from a
phase imbalance event. In a high impact event
a unit LOOP is created.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

Summary:

The SEL-451 Relays will have high impact on

spurious actuation of the relay, and failure of
current inputs, CTs for high side of SAT’s will
have high impact CT short to ground, open circuit
in the CT windings, high impact on failure of the
CTs, high impact on failure of overcurrent relay.

 The Calculation BYR 13-176 is to provide the

logic and setting limits for an algorithm that will
be able to detect a single or double open phase
in the high voltage (345 kV) connection between
SATs and the interconnection with the ring bus.
This calculation examines the OPC event
scenario during which the 345 kV line does not
to ground on the transmission side, so there
may not be enough fault current to be detected
and cleared by the switchyard protection
scheme; and the energized 345 kV line does not
short to ground on the transmission side, so
there may be no fault current to be detected and
cleared by the switchyard protection scheme.

 Calculation BYR13-177 implements the results

of Calculation BYR13-176 for the above OPC
phase event scenarios.

 Calculation BYR13-221 evaluate the impact an

open phase event concurrent with a LOCA for
Byron and Braidwood stations has on essential
(ESF) buses, motors, and MOVs.
2 Description of OPC automatic The description of the OPC automatic detection
detection scheme, including scheme is documented in Calculations
how offsite power system BYR13-176 and BYR13-177.
OPCs are detected from
sensing to alarm devices (loss The OPC relays will detect an OPC on the 345kV
of one or two phases of the side of the SATs to isolate the SATs and to alarm
three phases of the offsite the condition so that the appropriate operator
power circuit both with and action can be taken. The OPC relays will detect
without a high-impedance both one or two open phases with or without a
ground fault condition on the ground. The OPC relays are connected to
high-voltage side of all credited existing CTs on the high side (345kV) of the
qualified offsite power sources SATs. The OPC relays measure phase currents
under all loading and operating and calculate positive, negative, and zero
configurations; and loss of one sequence currents to detect an OPC.
or two phases of three phases
of switchyard breakers that One OPC relay is installed for each SAT.
feed offsite power circuits to However, there are two SATs per unit connected
transformers without ground.) to a common switchyard bus. Therefore, a trip of

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

one OPC relay will result in both SATs for the unit
being isolated. Alarms are provided in the MCR
for loss of phase trip and OPC relay low
load/trouble conditions.
3 Detection circuit design Detection circuit design features to minimize
features to minimize spurious spurious indications for an operable offsite
indications for an operable power source are documented in Calculations
offsite power source in the BYR13-176 and BYR13-177 and in ECs 389896
range of voltage perturbations, and 389897.
such as switching surges,
transformer inrush currents, The potential effects of normally expected
load or generation variations, transmission system conditions on the OPC
and lightning strikes, normally relays are summarized as follows:
expected in the transmission
system.  Range of voltage perturbations, such as
switching surges:

The OPC relays use phase and sequence

currents as inputs to detect an OPC. The OPC
relays do not use voltage as an input to detect
an OPC. Therefore, voltage perturbations will
not cause a spurious actuation of an OPC relay.

 Transformer inrush currents:

The OPC relay trip outputs are manually

blocked by opening test switches to prevent
spurious OPC relay trips during energization of
the SATs. After a minimum load of 2.27 Amps
primary current (about 1400 kVA) has been
applied to the SATs and min load alarm has
reset, the test switches are closed to enable the
tripping capability for the OPC relays.

Inrush currents for the Main Power

Transformers (MPTs) are not a concern since
the Main Generator energizes the MPTs prior to
closing the MPT switchyard breakers. Also,
Byron does not backfeed the MPTs from the
Switchyard.

 Load or generation variations:

As discussed in Section 6.6.4 of Calculation

BYR13-176, the EMTP analysis evaluated SAT
loading conditions from no load to maximum
load. Also, as discussed in Section 2.3.2 and in
Attachment B (Page B227) of Calculation
BYR13-176, the EMTP analysis evaluated
generation voltage variation from 0.95 pu to

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

1.05 pu. Additionally, according to Section 7.5

of Calculation BYR13-176, the EMTP analysis
evaluated the impact of whether or not the
Byron Main Generators were operating on the
minimum load requirement for the OPC Logic
Strings 2 and 3 to function correctly.

 Lightning strikes:

The OPC relays have a 0.5 second time delay

which would bound the expected transient from
a lightning strike and prevent spurious trip of an
OPC relay.
4 Alarm features provided in the The normal ESF bus alignment is discussed in
MCR. Discuss the ESF bus UFSAR Section 8.3. The credited offsite power
alignment during normal plant circuits are always loaded during normal
operation and the operating operation. The alarm features provided in the
procedures in place to address MCR for OPCs are documented in ECs 389896
OPCs. If the plant auxiliaries and 389897.
are supplied from the main
generator and the offsite power
circuit to the ESF bus is
configured as a standby power
source, then OPCs should be
alarmed in the MCR for
operators to take corrective
action within a reasonable
time.
5 Describe the automatic The automatic protection scheme for OPCs is
protection scheme provided for documented in Calculations BYR13-176 and
OPCs including applicable BYR13-177 and in ECs 389896 and 389897.
industry standards used for The standards are listed in Section 4 of
designing the scheme. Design Calculation BYR13-176.
features to minimize spurious
actuations for an operable Protection Scheme:
offsite power source in the
range of voltage perturbations, Upon detection of an OPC, the OPC relays will
such as switching surges, actuate the SAT lockout relays, similar to other
transformer inrush currents, SAT protective relays. The SAT lockout relays
load or generation variations, will isolate the SAT by tripping the 345kV feed
and lightning strikes, normally breakers to the SAT and the SAT secondary side
expected in the transmission 4.16kV and 6.9kV feed breakers. The associated
system should be described. 4.16kV ESF bus will experience an undervoltage
condition. This will start the EDG, load shed the
bus, and then load the bus with the required ESF
loads. The feed to the associated 6.9kV bus will
be automatically transferred from the SAT to the
UAT, if it is available. That is, the actuation of the

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TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

OPC relays will produce the same results as the

actuation of other SAT protection devices.

The OPC relay logic strings for detecting an OPC

without a ground require a minimum load to
operate correctly. A MINLOAD interlock is
provided in the relay logic. If the SAT load is
below the MINLOAD value, the relay trip logic is
blocked and a low load alarm will annunciate in
the Main Control Room. In addition, the relay will
alarm in the Main Control Room in the event of an
internal relay failure, and the tripping capability of
the relay will be automatically blocked.

A spurious trip of the OPC relay could result in a

LOOP. The potential effects of normally
expected transmission system conditions on the
OPC relays are summarized as follows:

 Range of voltage perturbations, such as

switching surges:

The OPC relays use phase and sequence

currents as inputs to detect an OPC. The OPC
relays do not use voltage as an input to detect
an OPC. Therefore, voltage perturbations will
not cause a spurious actuation of an OPC relay.

 Transformer inrush currents:

The OPC relay trip outputs are manually

blocked by opening test switches to prevent
spurious OPC relay trips during energization of
the SATs. After a minimum load of 2.27 Amps
primary current (about 1400 kVA) has been
applied to the SATs and min load alarm has
reset, the test switches are closed to enable the
tripping capability for the OPC relays.

Inrush currents for the MPTs are not a concern

since the Main Generator energizes the MPTs
prior to closing the MPT switchyard breakers.
Also, Byron does not backfeed the MPTs from
the Switchyard.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

 Load or generation variations:

As discussed in Section 6.6.4 of Calculation

BYR13-176, the EMTP analysis evaluated SAT
loading conditions from no load to maximum
load. Also, as discussed in Section 2.3.2 and in
Attachment B (Page B227) of Calculation
BYR13-176, the EMTP analysis evaluated
generation voltage variation from 0.95 pu to
1.05 pu. Additionally, according to Section 7.5
of Calculation BYR13-176, the EMTP analysis
evaluated the impact of whether or not the
Byron Main Generators were operating on the
minimum load requirement for the OPC Logic
Strings 2 and 3 to function correctly.

 Lightning strikes:

The OPC relays have a 0.5 second time delay

which would bound the expected transient from
a lightning strike and prevent spurious trip of an
OPC relay.
6 Brief discussion of the The analysis for an accident condition with a
licensee’s analyses performed concurrent OPC is documented in Calculation
for accident condition BYR13-221. The analysis assumes a design
concurrent OPCs which basis LOCA concurrent with the OPC. A design
demonstrate that the actuation basis LOCA bounds other design basis accidents
scheme will transfer ESF loads and a reactor trip without an accident with respect
required to mitigate postulated to electrical loading.
accidents to an alternate
source consistent with accident The analysis verified that the ESF loads would
analyses assumptions to not trip their overcurrent protective devices and
ensure that safety functions that the ESF buses would not trip any
are preserved, as required by undervoltage or overcurrent protective devices
the licensing bases. during the OPC time delay of 0.5 seconds. The
analysis also verified that the ESF loads would
not be damaged from excessive heating due to
negative sequence currents. This assures that
the required ESF loads would be capable of
starting and running as required when the DGs
restore normal voltage to the ESF buses.

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 TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

D Describe Observations/Comments
1 a. The TS Surveillance Yes a. Byron Station is using NSR protective relays
Requirements and Limiting No connected to the SAT high side (345 kV)
Condition of Operation for bushing to detect and protect against OPCs.
Equipment Used for OPCs Upon detection of an OPC, the OPC relays trip
Mitigation: Are TSs the NSR SAT lockout relays. Each OPC relay
Surveillance Requirements is another offsite source protective relay. The
and Limiting Condition of OPC relays do not have any safety-related
Operation for equipment inputs from ESF bus voltage or current, and the
used for the mitigation of OPC relay outputs do not trip any ESF bus
OPC identified and breakers or start any safety-related DGs.
implemented consistent with Therefore, the OPC relays are being treated in
the operability requirements the same manner as other offsite power source
specified in the plant TSs? protective relays, and the OPC relays do not
require addition to the TSs.

b. If the licensee determined Yes b. Steps have been added to the Normal and
that TSs are unaffected No Reserve Offsite Power Availability Weekly
because OPC is being Surveillances 1BOSR 8.1.1-1 and
addressed by 2BOSR 8.1.1-1 to verify that the SAT OPC
licensee-controlled relays are functioning normally. If an OPC
programs, is the technical relay is identified not to be functioning
justification adequate? normally, then the procedures direct the
operator to take the appropriate compensatory
actions to monitor ESF bus voltage and to
open the affected SAT feed breaker if
necessary.

E Describe Observations/Comments
Provide a brief summary of the Open The 50.59 evaluation concludes that no
Phase Condition plant modification U.S. Nuclear Regulatory Commission review is
performed under Title 10 of the Code of required.
Federal Regulations, Part 50.59
The OPC relays will detect an OPC on the 345kV
side of the SATs to isolate the SATs and to alarm
the condition so that the appropriate operator
action can be taken. The OPC relays will detect
both one or two open phases with or without a
ground. The OPC relays are connected to
existing CTs on the high side (345kV) of the
SATs. The OPC relays measure phase currents
and calculate positive, negative, and zero
sequence currents to detect an OPC.

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TABLE 1—INFORMATION GATHERED FOR TEMPORARY INSTRUCTION 2515/194

One OPC relay is installed for each SAT.

However, there are two SATs per unit connected
to a common switchyard bus. Therefore, a trip of
one OPC relay will result in both SATs for the unit
being isolated. Alarms are provided in the MCR
for loss of phase trip and OPC relay low
load/trouble conditions.

Upon detection of an OPC, the OPC relays will

actuate the SAT lockout relays, similar to other
SAT protective relays. The SAT lockout relays
will isolate the SAT by tripping the 345kV feed
breakers to the SAT and the SAT secondary side
4.16kV and 6.9kV feed breakers. The associated
4.16kV ESF bus will experience an undervoltage
condition. This will start the EDG, load shed the
bus, and then load the bus with the required ESF
loads. The feed to the associated 6.9kV bus will
be automatically transferred from the SAT to the
UAT, if it is available. That is, the actuation of the
OPC relays will produce the same results as the
actuation of other SAT protection devices.

The OPC relay logic strings for detecting an OPC

without a ground require a minimum load to
operate correctly. A MINLOAD interlock is
provided in the relay logic. If the SAT load is
below the MINLOAD value, the relay trip logic is
blocked and a low load alarm will annunciate in
the MCR. In addition, the relay will alarm in the
MCR in the event of an internal relay failure, and
the tripping capability of the relay will be
automatically blocked.

A spurious trip of the OPC relay could result in a

LOOP. However, the SEL-451-5
microprocessor-based relays are very reliable
and are widely used in the industry. A review in
industry operating experience identified instances
of improper settings or testing of similar relay
models, but no failures of these devices.
The 50.59 Evaluation determined that due to the
balancing of the positive effects (isolating a
degraded power source) and the potential
negative effects (inappropriate isolation of a
functioning power source), the proposed activity
does not result in a more than a minimal increase
in the frequency of occurrence of an accident
previously evaluated in the UFSAR or result in a
more than minimal increase in the frequency of a
malfunction of an structures, systems, and
components.

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