IR 05000440/2014007

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IR 05000440-14-007, on 03/03/2014 & 04/04/2014; Perry Nuclear Power Plant. Component Design Bases Inspection (CDBI)
ML14128A310
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 05/07/2014
From: Ann Marie Stone
NRC/RGN-III/DRS/EB2
To: Harkness E
FirstEnergy Nuclear Operating Co
Andrew Dunlop
References
IR-14-007
Download: ML14128A310 (24)
v • d • e


Text

May 7, 2014

SUBJECT:

PERRY NUCLEAR POWER PLANT COMPONENT DESIGN BASES INSPECTION 05000440/2014007

Dear Mr. Harkness:

On April 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a Component Design Bases Inspection (CDBI) inspection at your Perry Nuclear Power Plant. The enclosed report documents the results of this inspection, which were discussed on April 4, 2014, with Mr.

D. Reeves, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No findings were identified during this inspection.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's

"Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2014007 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-440 License No:

NPF-58 Report No:

05000440/2014007 Licensee:

FirstEnergy Nuclear Operating Company (FENOC)

Facility:

Perry Nuclear Power Plant, Unit 1 Location:

Perry, Ohio Dates:

March 3 - 7, 2014; March 17 - 21, 2014, and March 31, through April 4, 2014 Inspectors:

A. Dunlop, Senior Engineering Inspector, Lead

J. Corujo-Sandin, Engineering Inspector, Mechanical

C. Brown, Engineering Inspector, Electrical

C. Moore, Operations Inspector

S. Kobylarz, Electrical Contractor

M. Yeminy, Mechanical Contractor Approved by:

Ann Marie Stone, Chief Engineering Branch 2

Division of Reactor Safety

SUMMARY OF FINDINGS

IR 05000440/2014007, 03/03/2014 - 04/04/2014; Perry Nuclear Power Plant. Component

Design Bases Inspection (CDBI)

The inspection was a 3-week onsite baseline inspection that focused on the design of components. The inspection was conducted by regional engineering inspectors and two consultants. No findings or violations of significance were identified by the inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green,

White, Yellow, Red) and determined using IMC 0609, Significance Determination Process dated June 2, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings No findings of significance were identified.

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Component Design Bases Inspection

Main article: IP 71111.21

.1 Introduction

The objective of the component design bases inspection is to verify that design bases have been correctly implemented for the selected risk significant components and that operating procedures and operator actions are consistent with design and licensing bases. As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The Probabilistic Risk-Assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance.

Specific documents reviewed during the inspection are listed in the Attachment to the report.

.2 Inspection Sample Selection Process

The inspectors used information contained in the licensees PRA and the Perry Standardized Plant Analysis Risk Model to identify a scenario to use as the basis for component selection. The scenario selected was a Loss of Condenser Heat Sink event.

Based on this scenario, a number of risk significant components, including those with Large Early Release Frequency (LERF) implications, were selected for the inspection.

The inspectors also used additional component information such as a margin assessment in the selection process. This design margin assessment considered original design reductions caused by design modification, power uprates, or reductions due to degraded material condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective actions, repeated maintenance activities, Maintenance Rule (a)(1) status, components requiring an operability evaluation, NRC resident inspector input of problem areas/equipment, and system health reports.

Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins. A summary of the reviews performed and the specific inspection findings identified are included in the following sections of the report.

The inspectors also identified procedures and modifications for review that were associated with the selected components. In addition, the inspectors selected operating experience issues associated with the selected components.

This inspection constituted 20 samples as defined in Inspection Procedure 71111.21-05.

.3 Component Design

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report (USAR), Technical Specifications (TS), design basis documents, drawings, calculations and other available design basis information, to determine the performance requirements of the selected components. The inspectors used applicable industry standards, such as the American Society of Mechanical Engineers (ASME) Code, Institute of Electrical and Electronics Engineers (IEEE) Standards and the National Electric Code, to evaluate acceptability of the systems design. The NRC also evaluated licensee actions, if any, taken in response to NRC issued operating experience, such as Bulletins, Generic Letters (GLs),

Regulatory Issue Summaries (RISs), and Information Notices (INs). The review was to verify that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability was consistent with the design bases and was appropriate may include installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation.

For each of the components selected, the inspectors reviewed the maintenance history, preventive maintenance activities, system health reports, operating experience-related information, vendor manuals, electrical and mechanical drawings, and licensee Corrective Action Program documents. Field walkdowns were conducted for all accessible components to assess material condition and to verify that the as-built condition was consistent with the design. Other attributes reviewed are included as part of the scope for each individual component.

The following 16 components, two with LERF implications, were reviewed:

  • Residual Heat Removal (RHR) Pump B (1E12-C0002B): The inspectors reviewed hydraulic calculations to ensure design requirements for flow and pressure were translated as acceptance criteria for pump in-service testing (IST).

The inspectors reviewed IST results to assess potential component degradation and impact on design margins. Surveillance procedures for the RHR pump were reviewed to ensure TS surveillance requirements were met. The inspectors reviewed start/stop pump control logic and the different modes of operation of the RHR pump to ascertain that the pump would operate as designed during accident and most limiting conditions. Pump protection logic and interlocks were reviewed to verify appropriate testing. Maintenance and calibration procedures were reviewed to ensure instrument setpoints were consistent with design basis assumptions. In addition, the licensee actions to NRC Bulletin 88-04, Potential Safety-Related Pump Loss, were reviewed to ensure pump minimum flow requirements were addressed. The inspectors reviewed elementary diagrams to confirm that the pump operation conformed to the design requirements. The one-line diagram and the motor protective relay setting calculation were reviewed to confirm relay calibration testing verified the proper setting and operation for the protective relays. The inspectors also verified adequate control voltage was available for operation of the motor circuit breaker close circuit. Voltage drop calculations were reviewed to determine whether the motors had adequate voltage for starting and running under degraded voltage conditions and the motor circuit cabling had adequate ampacity. The inspectors confirmed the adequacy of the motor size based on worse case design conditions affecting pump break horsepower.

  • RHR Pump B Room Cooler (M39-B001B): The inspectors reviewed the analysis of the room coolers heat removal capability with respect to heat load, fouling factors, air flow rate, and water flow rate to verify the capability of the room cooler to maintain the room temperature at or below the design temperature of the safety-related components located in the room. The inspectors reviewed the modeling of the room cooler into the Aerofin computer program used to assess operation of the cooler at the design conditions. The inspectors also reviewed the coolers test procedures, test frequency, and analyzed the validity of test results with respect to air flow rates and impact on the coolers fan motor. The elementary diagrams were reviewed to confirm that the fan operation conformed to the design requirements. The inspectors reviewed the one-line diagram and the motor overload protection selection calculation to confirm proper selection of the motor circuit and motor overload protection. The inspectors verified adequate control voltage was available for operation of the motor starter contactor. Voltage drop calculations were reviewed to determine whether the motors had adequate voltage for starting and running under degraded voltage conditions and the motor circuit cabling had adequate ampacity. The inspectors confirmed the adequacy of the motor size based on worse case design conditions affecting fan break horsepower.
  • RHR Test Return Valve (1E12-F0024B): The inspectors reviewed motor-operated valve (MOV) calculations and analyses to ensure the valve was capable of functioning under design conditions. These included calculations for required thrust, maximum differential pressure (d/p), and valve weak link analysis. Diagnostic testing and IST surveillance results, including stroke time, seat leakage, and available thrust, were reviewed to verify acceptance criteria were met and performance degradation could be identified. Control logic and elementary diagrams were reviewed to confirm operation of the valve conformed to design requirements and operating procedures. The inspectors reviewed the circuit protection, the thermal overload application, and the environmental qualification of the motor operator to confirm the circuit was adequately protected and the valve was capable of performing its intended safety function. Voltage drop calculations were reviewed to verify the motor and associated control circuits had adequate voltage under degraded voltage conditions. The inspectors also inspected the valve for actuator orientation, proper greasing, and ability to be manually operated.
  • Low Pressure Coolant Injection Valve (1E12-F0042C): The inspectors reviewed MOV calculations and analyses to ensure the valve was capable of functioning under design conditions. These included calculations for required thrust, maximum d/p, and valve weak link analysis. Diagnostic testing and IST surveillance results, including stroke time, seat leakage, and available thrust, were reviewed to verify acceptance criteria were met and performance degradation could be identified. The inspectors reviewed control logic and elementary diagrams to confirm operation of the valve conformed to design requirements and operating procedures. This included the procedures used to override the actuators seal-in circuit such that the valve could be throttled to control reactor vessel level to ensure the valve would continue to be able to perform its design functions in this mode of operation. In addition, the open permissive signals to the valve were reviewed to ensure the settings would protect the RHR piping from being over pressurized. The inspectors also reviewed the circuit protection, the thermal overload application, and the environmental qualification of the Limitorque motor operator to confirm that the circuit was adequately protected and that the valve was capable of performing its intended safety function during a design basis accident. Voltage drop calculations were reviewed to verify the motor and associated control circuits had adequate voltage under degraded voltage conditions. The inspectors reviewed the actuator for proper orientation, greasing and ability to be manually operated; and the procedures to prevent over torqueing in the manual mode.
  • Emergency Service Water (ESW) Pump B (1P45-C0001B): The inspectors reviewed hydraulic calculations pump line up, capacity and IST to ensure that the pump was capable of performing its safety functions during the most limiting design conditions. The inspectors reviewed the pressure loss due to the discharge strainer and licensee actions in response to GL 89-13, Service Water System Problems Affecting Safety-Related Equipment. The inspectors reviewed elementary diagrams to confirm that the pump operation conformed to the design requirements. The one-line diagram and the motor protective relay setting calculation was reviewed to confirm that relay calibration testing verified the proper setting and operation for the protective relays. The inspectors also verified adequate control voltage was available for operation of the motor circuit breaker close circuit. Voltage drop calculations were reviewed to verify the motors had adequate voltage for starting and running under degraded voltage conditions and the motor circuit cabling was adequate. The inspectors confirmed the adequacy of the motor size based on worse case design conditions affecting pump break horsepower.
  • ESW Pump Discharge Strainer (1P45-D0002B): The inspectors reviewed performance data provided in the design procurement specifications and vendor documents for the full-flow automatic backwash strainer to verify performance assumptions in the ESW Train B system flow balance and hydraulic calculation.

Calculations for normal and design basis accident conditions were reviewed to verify sufficient ESW system flow was available and operators were capable of manually backwashing the strainer upon loss of offsite power. The inspectors also reviewed worst case plugging of the strainer and the capability of the system to operate under this condition. The power requirements for the strainer and backwash valves were reviewed to confirm operation of the automatic backwashing strainer conformed to design requirements and operating procedures. The inspectors also reviewed the available pressure instrumentation as well as the capability of operators to determine the pressure drop across the strainer in case of loss of offsite power. In addition, the inspectors verified the high pressure drop alarm was properly set and consistent with the value used in design calculations. Elementary diagrams were reviewed to confirm the pump operation conformed to the design requirements. The inspectors reviewed the one-line diagram and the motor protective relay setting calculation to confirm relay calibration testing verified the proper setting and operation for the protective relays. The inspectors also verified that adequate control voltage was available for operation of the motor circuit breaker close circuit. Voltage drop calculations were reviewed to verify the motors had adequate voltage for starting and running under degraded voltage conditions and the motor circuit cabling was adequate.

The inspectors confirmed the adequacy of the motor size based on worse case design conditions affecting break horsepower.

  • ESW Pump B Discharge Check Valve (1P45-F501B): The inspectors reviewed vendor drawings system isometrics and operating procedures to determine whether system design basis conditions were accounted for in the design of the check valve. The IST procedure and test results were reviewed to verify valve freedom of motion and to ensure that the valve allowed required flow in the open position and limited backflow in the closed position to avoid air voids in the discharge piping.

The review included original design specifications and pre-operational testing of the safety relief valve (SRV) to ensure the component could operate under limiting design basis conditions. Testing was reviewed for compliance with applicable IST requirements and approved license amendments. In addition, the inspectors reviewed elementary diagrams to confirm SRV operation conformed to the design requirements. The inspectors reviewed 125Vdc voltage drop calculations to confirm the SRV solenoid valves received adequate voltage to operate during the most limiting battery conditions and the cabling to the solenoid valve had adequate ampacity. The inspectors also reviewed the preventive maintenance to confirm the solenoid coils were maintained in accordance with the equipment qualification requirements.

  • Emergency Closed Cooling (ECC) Water System Pump B (1P42-C0001B): The inspectors reviewed the basis for the pumps performance test acceptance criteria, pump performance IST procedures and results of the most recent test to verify current performance. Part of the review included the testing of required interlocks during design basis events, adequate flow to the system loads, and adequate net positive suction head (NPSH) for the required mission time. The inspectors reviewed elementary diagrams to confirm pump operation conformed to the design requirements. The one-line diagram and the motor protective relay setting calculation were reviewed to confirm relay calibration testing verified the proper setting and operation for the protective relays. The inspectors also verified adequate control voltage was available for operation of the motor circuit breaker close circuit. The voltage drop calculations were reviewed to verify the motors had adequate voltage for starting and running under degraded voltage conditions and the motor circuit cabling ampacity was adequate. The inspectors confirmed the adequacy of the motor size based on worse case design conditions affecting pump break horsepower.
  • Emergency Closed Cooling Heat Exchanger (1P42-B00011B): The inspectors reviewed recent thermal performance tests and associated calculations to ensure the equipment was capable of removing the required heat under design basis conditions. Previously completed internal inspections results were also reviewed in order to evaluate for potential component degradation or fouling concerns.

The heat exchangers tube plugging limit, tube plugging criteria, and chemistry control procedures were reviewed to ensure the heat exchanger remained within its heat removal requirement.

  • Emergency Closed Cooling Temperature Control Valve (1P42-F0665B):

Inspectors reviewed for potential impacts to the plant based on postulated failures of the component. The established temperature setpoints and associated tolerances were reviewed to ensure they did not impact the design basis assumptions during an accident. Aspects of the seismic mounting for the component were also reviewed. The control logic and elementary diagrams were reviewed to confirm operation of the valve conformed to design requirements and operating procedures. The inspectors reviewed the circuit protection, the thermal overload application, and the environmental qualification of the valve operator to confirm the circuit was adequately protected and the valve was capable of performing its intended safety function during a design basis accident. Voltage drop calculations were reviewed to determine whether the motor and associated control circuits had adequate voltage under degraded voltage conditions.

  • Emergency Closed Cooling Surge Tank B (A001B): The inspectors reviewed the components design and associated testing to ensure it would be capable of meetings its required function under design basis events. Inspectors verified the adequacy of the tanks capacity, assumed initial volume, expected leakage during a design basis event, and associated system leakage testing. The components available instrumentation, available operational guidance (under normal and accident conditions), and recent level setpoints modifications were also reviewed to ensure sufficient NPSH was maintained for the ECC pump. The inspectors discussed with licensee staff, and reviewed calculations, to determine if the seismic qualification would be impacted by the level setpoint modifications.
  • 125Vdc Distribution Panel (ED1B08): The inspectors reviewed the one-line diagram, the short circuit current calculation, and the coordination calculation to confirm the short circuit duty and the proper coordination between the panel fuses and branch circuit cabling with the upstream protective device. The inspectors also reviewed the panel electrical loading and voltage drop calculations, and the branch circuit cabling, to confirm bus and circuit cable ampacity was adequate and branch circuits had adequate voltage.
  • 4160Vac Bus (EH-12): The inspectors reviewed bus loading calculations to verify the 4160Vac system had sufficient capacity to support its required loads under worst case accident loading and grid voltage conditions. The inspectors reviewed the degraded voltage protection design scheme to determine whether it afforded adequate voltage to safety-related devices at all voltage distribution levels. This included review of degraded voltage relay setpoint calculations and voltage calculations for downstream equipment such as MOVs. The inspectors reviewed the overcurrent protection scheme for the 4160Vac buses including drawings and calculations to determine whether loads were adequately protected and immune from spurious tripping. The inspectors also reviewed maintenance frequencies and procedures for the 4160Vac bus, its associated circuit breakers, and the system transformer to determine whether the equipment was being properly maintained. This included reviewing acceptance criteria in procedures for consistency with vendor recommendations and design calculations.
  • 480Vac Motor Control Center (MCC) (EF-1-D): The inspectors reviewed bus and control circuit loading calculations to verify MCC 1D had sufficient capacity to support its required loads under worst case accident loading and grid voltage conditions. The overcurrent protection scheme for the MCC, including drawings and calculations, were reviewed to determine whether loads were adequately protected and immune from spurious tripping. The inspectors reviewed maintenance schedules and procedures for the 480Vac bus and its associated circuit breakers to determine whether the equipment was being properly maintained. This included reviewing acceptance criteria in procedures for consistency with vendor recommendations and design calculations.
  • 480Vac Motor Control Center (EF-1D07): The inspectors reviewed bus and control circuit loading calculations to verify MCC 1D had sufficient capacity to support its required loads under worst case accident loading and grid voltage conditions. The overcurrent protection scheme for the MCC, including drawings and calculations, were reviewed to determine whether loads were adequately protected and immune from spurious tripping. The inspectors reviewed maintenance schedules and procedures for the 480Vac bus and its associated circuit breakers to determine whether the equipment was being properly maintained. This included reviewing acceptance criteria in procedures for consistency with vendor recommendations and design calculations.

b. Findings

No findings of significance were identified.

.2 Operating Experience

a. Inspection Scope

The inspectors reviewed four operating experience issues to ensure that NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection:

  • GL 96-01, Testing of Safety Related Circuits;
  • Industry Operating Experience, Manual Reactor Scram Following Loss of Division 1, 480Vac Safety-Related Busses.

b. Findings

No findings of significance were identified.

.3 Modifications

a. Inspection Scope

The inspectors reviewed two permanent plant modifications related to selected risk significant components to verify that the design bases, licensing bases, and performance capability of the components had not been degraded through modifications. The modifications listed below were reviewed as part of this inspection effort:

  • PERP 000805; Equivalent Replacement of Limitorque S/N 1YFB01142A4 Motor to Limitorque Model R-302-E04-082100A20 Motor; and
  • ECP 02-0045, EQ Zone Temperature Changes as a Result of ESW Piping Temperature Changes.

b. Findings

No findings of significance were identified.

.4 Operating Procedure Accident Scenarios

a. Inspection Scope

The inspectors performed a margin assessment and detailed review of three risk significant, time critical operator actions. These actions were selected from the licensees PRA rankings of human action importance based on risk-achievement worth values. Where possible, margins were determined by the review of the assumed design basis and USAR response times and performance times documented by job performance measures results. For the selected operator actions, the inspectors performed a detailed review and walk through of associated procedures, including observing the performance of the selected actions in the stations simulator and in the plant, with an appropriate plant operator to assess operator knowledge level, adequacy of procedures, and availability of special equipment where required.

The following operator actions were reviewed:

  • Loss of Condenser Heat Sink;
  • Alignment of Condensate Transfer Alternate Injection; and
  • Operators Restore Instrument Air to SRVs following an Isolation.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered Into the Corrective Action Program

a. Inspection Scope

The inspectors reviewed a sample of the selected component problems identified by the licensee and entered into the corrective action program. The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the Corrective Action Program. The specific corrective action documents sampled and reviewed by the inspectors are listed in the Attachment to this report.

The inspectors also selected five issues identified during previous CDBIs to verify the concern was adequately evaluated and corrective actions were identified and implemented to resolve the concern, as necessary. The following issues were reviewed:

  • CR-2011-05510; NRC CDBI SOI-P45/49 Incorrectly States ESW Strainer Backwash Starts at 2.75 psid;

b. Findings

No findings of significance were identified.

4OA6 Meeting(s)

.1

Exit Meeting Summary

On April 4, 2014, the inspectors presented the inspection results to Mr. D. Reeves, and other members of the licensee staff. The licensee acknowledged the issues presented.

Several documents reviewed by the inspectors were considered proprietary information and were either returned to the licensee or handled in accordance with NRC policy on proprietary information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

E. Harkness, Site Vice-President
T. Brown, Performance Improvement Director
J. Ellis, Recovery Director
D. Reeves, Site Engineering Director
J. Veglia, Maintenance Director
R. Briggs, Design Engineering Supervisor
B. Coad, Design Engineering Supervisor
A. Frey, Mechanical/Structural Engineering
D. Lieb, Nuclear Engineering Analysis
D. Lockwood, Regulatory Compliance Engineer
C. Olivier, Operations Manager
D. Stoltz, Electrical/I&C Engineering
T. Watterson, Design Engineering
L. Zerr, Regulatory Compliance Supervisor
E. Zidow, BOP Systems Engineering

Nuclear Regulatory Commission

M. Marshfield, Senior Resident Inspector
J. Nance, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed and

Discussed

None

LIST OF DOCUMENTS REVIEWED

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