IR 05000440/2020001
| ML20136A054 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/14/2020 |
| From: | Billy Dickson NRC/RGN-III |
| To: | Payne F Energy Harbor Nuclear Corp |
| References | |
| IR 2020001 | |
| Download: ML20136A054 (13) | |
Text
May 14, 2020
SUBJECT:
PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2020001
Dear Mr. Payne:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects
Docket No. 05000440 License No. NPF-58
Enclosure:
As stated
Inspection Report
Docket Number:
05000440
License Number:
Report Number:
Enterprise Identifier: I-2020-001-0050
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
L. Alvarado Guilloty, Reactor Engineer
T. McGowan, Reactor Engineer
J. Nance, Reactor Engineer
J. Steffes, Senior Resident Inspector
Approved By:
Billy C. Dickson, Jr., Chief
Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Perry Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000440/2019004-01 Degraded Turbine Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency 71111.18 Closed LER 05000440/2018-002-00 LER 2018-002-00 for Perry Nuclear Power Plant, Failed Fuse Leads to Loss of Safety Function.
71153 Closed
PLANT STATUS
The plant began the inspection period at rated thermal power. On January 4, 2020, operators lowered reactor power to 57 percent to perform power suppression testing. Following successful suppression testing, operators increased reactor power. The licensee achieved full power operations on January 7, 2020. On March 13, 2020, operators lowered reactor power to 53 percent to perform rod pattern adjustment as well as planned surveillances. Following completion of these activities, the operators commenced power ascension activities. Full power operations resumed on March 16, 2020. The plant remained at or near full power for the rest of the inspection period.
On February 27, 2020, the licensees parent company successfully completed its Chapter 11 restructuring process and emerged from bankruptcy as Energy Harbor Nuclear Corp. The NRC Region III inspectors used flexibility in the baseline inspection program to assess the potential impact of the financial conditions on licensee performance. Through February 27, 2020, the inspectors applied additional focus to the following areas:
- (1) impact on regulatory required plant staffing,
- (2) corrective maintenance backlog,
- (3) changes to the planned maintenance schedule,
- (4) corrective action program implementation, and
- (5) reduction in outage scope, including risk-significant modifications. No concerns were identified.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme cold weather for two systems on February 3 and 4, 2020.
Verified temporary heating staged for potential extreme weather IAW Attachment 1 in ONI-R36-2, Rev. 10.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Division 3 diesel generator while the Reactor Core Isolation Cooling (RCIC) system was unavailable for maintenance on January 30, 2020.
- (2) Control room heating, ventilation, air conditioning, and emergency recirculation "B" system following division 2 emergency diesel generator run on March 31, 2020.
- (3) Low pressure core spray on March 25, 2020.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the licensee's direct current (DC) distribution systems to include: normal and reserve battery chargers, batteries and battery racks, DC load centers, DC motor control centers and DC distribution panels system on February 26 to March 2, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Control Complex 654 foot elevation on January 6, 2020.
- (2) Nuclear closed cooling pumps and heat exchanger 599 foot elevation fire zone 0CC-2A on January 7, 2020.
- (3) Unit 1 containment on January 8, 2020.
- (4) Intermediate building 574 and 585 foot elevations fire zone 0IB-1 on January 9, 2020.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during downpower and rod control manipulations for power suppression testing on January 4, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;
- (1) Plant risk evaluation during unavailability of the RCIC system for planned maintenance from January 21-23, 2020.
- (3) Emergent work on the RCIC trip throttle valve due to test failure January 28-29, 2020.
- (4) Risk assessment associated with emergent work activities to isolate and locate a underground water leak near the pump house on February 12, 2020.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Fire protection system functionality determination with fire protection water being supplied to non-safety pump seals on February 20-21, 2020.
- (2) Main turbine valve surveillance failure on March 26-27, 2020.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Installation of a manual lockout switch for main turbine mechanical and electrical overspeed trips on March 18-30, 2020.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) RCIC trip throttle valve test following corrective maintenance on January 26, 2020.
- (2) RCIC systems pump and valve operability test following extended maintenance window on January 26, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) RCIC system pump and valve surveillance on January 31,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January-December 2019)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) Unit 1 (January-December 2019)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) Unit 1 (January-December 2019)
===71153 - Followup of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02)===
The inspectors evaluated the following licensee event reports (LERs):
- (1) Licensee Event Report 05000440/2018-002-00, Failed Fuse Leads to Loss of Safety Function (ADAMS Accession No. ML18236A294)
The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensee's ability to have forseen and corrected and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified.
INSPECTION RESULTS
Unresolved Item (Closed)
Degraded Turbine Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency URI 05000440/2019004-01 71111.18
Description:
On July 27, 2019, a turbine trip and reactor scram occurred during performance of weekly Main Turbine overspeed testing. The turbine trip occurred during performance of the mechanical overspeed portion of the testing procedure. The inspectors determined that troubleshooting efforts identified a ground associated with the reset limit switch on the turbine overspeed system. The inspectors reviewed the prompt functionality assessment (PFA)contained in CR 2019-06321, Turbine Trip during Weekly Turbine Overspeed Test and noted that the licensee did not immediately address the reset limit switch ground by fixing the issue but would instead correct the condition following the corrective action process in a timely manner commensurate with its safety significance. The inspectors additionally determined the licensee had contracted with an outside vendor to assess the impacts of changing the turbine overspeed testing frequency on the design/license basis turbine missile hazard likelihood which could in turn change the turbine missile probability. The inspectors determine the vendor used a Monte Carlo methodology to decrease the testing frequency from weekly to semi-annually rather than a methodology by General Electric or Siemens-Westinghouse, as stated in USAR 10.2.3.6.1.1. The inspectors noted that the licensee determined that extending testing from weekly to semi-annually constituted a non-conforming condition with respect to the design basis.
As a result, the inspectors generated an Unresolved Item (URI)05000440/2019004-01, Degraded Turbine Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency, to ascertain the appropriateness of the licensee using the PFA process to change USAR described testing rather than the 10 CFR 50.59 process.
Specifically,
- (1) whether the change in overspeed testing frequency, i.e. non-performance on a weekly basis, constituted a compensatory measure for the degraded condition, and (2)whether the compensatory measure should have been evaluated in accordance with the 10 CFR 50.59 process. The licensee entered the inspectors concerns in CR 2020-01004, NRC Open Unresolved Item - Degraded Overspeed Limit Switch Results in an Extension in USAR Described Test Frequency.
In response to inspector questions the licensee developed a position paper explaining their decision-making. The position paper stated that, the less frequent test interval that is implemented by the PFA is not viewed to be a compensatory action for the degraded condition, as it does not restore or maintain functionality for the turbine overspeed trip test system. The PFA is not intended to accept the degraded condition as-is, or to change the facility or its procedures. As such, the less frequent turbine trip test interval that is implemented by the PFA was concluded to not require further review under 10 CFR 50.59.
The inspectors consulted subject matter experts in the Office of Nuclear Reactor Regulation (NRR) and ultimately agreed that the change in testing frequency was not subject to 10 CFR 50.59 requirements but disagreed with the licensees reasoning. The inspectors concluded that regardless of whether the change in frequency was in response to a degraded condition, the change in frequency itself was a separate stand-alone non-conforming condition for which evaluation shouldve been performed. However, NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Evaluations, Section 4.1.2 contained guidance for changes made to maintenance procedures. Surveillances are considered maintenance activities and changes to surveillances are made in accordance with applicable 10 CFR Part 50, Appendix B assuming those changes do not alter plant configurations.
The inspectors determined that in this case the licensee implemented the temporary change to the turbine overspeed test interval using the PFA process rather than changing the test procedure for the turbine overspeed protection test and that those changes did not inadvertently alter the design, performance requirements, operation or control of the turbine overspeed mechanism and therefore was not subject to 10 CFR 50.59 requirements. Based on this review, no performance deficiencies and associated violations of NRC regulations were identified, and URI 05000440/2019004-01 is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 31, 2020, the inspectors presented the integrated inspection results to Mr. F. Payne, Site Vice President and other members of the licensee staff.
- On April 22, 2020, the inspectors presented the integrated inspection results to Mr. F. Payne, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
IOI-0015
Seasonal Variations
ONI-R36-2
Extreme Cold Weather
ONI-ZZZ-1
Act of Nature - Severe Weather
Corrective Action
Documents
CR 2020-01139
Evaluation of Part 21 for Batteries
2/12/2020
Drawings
206-0050-00000
One Line Diagram - Class 1E DC System Division 3
Z
206-0051-00000
One Line Diagram Class 1E DC System
DDD
206-0052-00000
One Line Diagram Non-Class 1E DC System Bus D1A and
D1B
DDD
Miscellaneous
SOI-E22B
Division 3 Diesel Generator
Procedures
ARI-H13-P601-
0016
Division 3 Diesel Generator and High Pressure Core Spray
ARI-H13-P877-
0002
Division 2 Power
ARI-H13-P887-
0001
Division 1 Power
SOI-E22A
High Pressure Core Spray System
SOI-R42 (DIV 1)
Div 1 DC Distribution, Buses ED-1-A and ED-2-A, Batteries,
Chargers, and Switchgear
SOI-R42 (DIV 2)
Div 2 DC Distribution, Buses ED-1-B and ED-2-B, Batteries,
Chargers, and Switchgear
SOI-R42 (DIV 3)
Div 3 DC Distribution, Buses ED-1-C and ED-2-C: Batteries,
Chargers, and Switchgear
VLI-E21
Low Pressure Core Spray System
VLI-E22A
Valve Lineup Instruction for HPCS
VLI-M25/26
Control Room HVAC and Emergency Recirculation System
Work Orders
200548141
Replace K1 Relay for 125 Volt DC Division 1 Battery
Charger
01/26/2020
Procedures
FPI-0CC
Conference Room, Corridor, Kitchen and Storage Room 654
Foot Elevation
FPI-0CC
Unit 2 Control Room 654 Foot Elevation
FPI-0CC
Unit 1 Control Room 654 Foot Elevation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
FPI-0CC
NCC Pump/Heat Exchangers 599 Foot Elevation East
FPI-0IB
Intermediate Building 574 Foot Elevation and Pipe Chase
585 Foot Elevation
FPI-1RB
Unit 1 Containment to Drywell Space
Work Orders
200717072
Portable Fire Extinguishers Maintenance Inspection
05/19/2019
71111.11Q Miscellaneous
Evolution Specific
Reactivity Plan
Perry Nuclear Power Plant January 2020 Power
Suppression Test
Corrective Action
Documents
20-00486
Unexpected Mechanical Component Contact Identified
during RCIC Pump Dissassembly
01/22/2020
20-00599
Delays Encountered While Performing PTI-E51-P0003 RCIC
Terry Turbine Overspeed Trip Test Due to Erratic Governor
Controls
01/25/2020
20-00611
Issue Identified with the RCIC Turbine Mechanical
Overspeed Trip while Performing Overspeed Trip Testing
01/26/2020
20-00621
Degraded Part Identified During Inspection of Overspeed
Trip Assembly
01/26/2020
20-00660
RCIC Trip Throttle Valve Did Not Trip
01/28/2020
20-00979
ONI-ZZZ-0006 Water Leaking Out of Ground in Front of
Service Water Pump House
2/07/2020
20-01142
Unable to Perform Operations Evolution Order for Shifting
from the Clearwell to Fire Water
2/13/2020
Procedures
NOP-OP-1007
Risk Management
PAP-1924
Risk-Informed Safety Assessment and Risk Management
Work Orders
200518430
Replacement of RCIC EGM Control Box, Overspeed Test
Controller, and Ramp Generator and Signal Converter
200741073
RCIC Terry Turbine Overspeed Trip Test
200754241
Diesel Generator Start and Load Division 1
Calculations
P54-124
Fire Protection Suppression System Water Supply
Calculation
Corrective Action
Documents
20-02235
Unsat Continuity Reading During Performance of SVI-N31-
T1151, Main Turbine Valve Exercise Test
03/15/2020
Engineering
Evaluations
EER 601260168
Fire Protection Engineering Evaluation to Permit the Use of
the Water-Based Fire Protection System in Support of SOI-
P20/21/22
2/17/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
200625795
Main Turbine Valve Exercise Test
03/15/2020
200756819
Motor Driven Fire Pump Flow Data and Control Panel
Functional Test
01/25/2020
Corrective Action
Documents
CR 2020-01004
NRC Open Unresolved Item-Degraded Overspeed Limit
Switch Results in an Extension in USAR Described Test
Frequency
2/10/2020
Engineering
Changes
19-0173-001
Manual Lockout Switch for Main Turbine Mechanical and
Electrical Trips
01/16/2020
Work Orders
200801461
Modification 19-0173-001 to Install a 3-Position Keylock
Switch on the EHC Panel for Use During the Electrical and
Mechanical Turbine Overspeed Tests
03/13/2020
Procedures
GMI-0182
RCIC Trip and Throttle Valve Maintenance and Trip Linkage
Adjustment
Work Orders
200718798
RCIC Pump and Valve Operability Test
01/21/2019
200741073
PTI-E51-P0003 RCIC Turbine Overspeed Trip Test
01/28/2020
200810835
RHR and RCIC Steam Supply Second Drain Shutoff Valve
Packing Replacement
01/21/2020
Corrective Action
Documents
20-00745
RCIC Pump and Valve Surveillance Discrepancies
01/30/2020
Drawings
2-0632-00000
Reactor Core Isolation Cooling
Procedures
SVI-E51-T2001
RCIC Pump and Valve Operability Test
Work Orders
200740485
RCIC Cold Quick Start and Position Indication Verification
Test
01/31/2020
71151
Miscellaneous
SPYA227-
P20012319310
Performance Indicator Summary Report
01/01/2019 -
2/31/2019
Corrective Action
Documents
2018-05997
Received Unexpected RHR A Out of Service Alarm
06/30/2018
Work Orders
200758862
Troubleshoot to Determine the Cause of the Unexpected
RHR A Out of Service and LPCS Out of Service Alarms
0