IR 05000440/2023010
| ML23178A230 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/29/2023 |
| From: | Jamie Benjamin NRC/RGN-III/DORS/EB1 |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| IR 2023010 | |
| Download: ML23178A230 (1) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - COMPREHENSIVE ENGINEERING TEAM INSPECTION REPORT 05000440/2023010
Dear Rod Penfield:
On May 25, 2023, 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.
Four findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Perry Nuclear Power Plant.
June 29, 2023 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, Jamie C. Benjamin, Acting Branch Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58
Enclosure:
As stated
Inspection Report
Docket Number:
05000440
License Number:
Report Number:
Enterprise Identifier:
I-2023-010-0039
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
April 24, 2023 to May 12, 2023
Inspectors:
K. Barclay, Senior Reactor Inspector
J. Corujo-Sandin, Senior Reactor Inspector
I. Hafeez, Senior Reactor Inspector
S. Liska, Reactor Inspector, Observer
D. Melendez-Colon, Reactor Inspector
J. Park, Reactor Inspector
R. Waters, Contractor
J. Zudans, Contractor
Approved By:
Jamie C. Benjamin, Acting Branch Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Comprehensive Engineering Team 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
Failure to Account for Instrument Uncertainties Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-01 Open/Closed None (NPP)71111.21M The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for instrument uncertainty in the surveillance procedures acceptance criteria for High Pressure Core Spray required pump flow and differential pressure.
Failure to Have Administrative Controls for the Upper Containment Pool Temperature Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-02 Open/Closed None (NPP)71111.21M The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the Station Blackout (SBO) analysis assumptions into procedures. Specifically, the licensee failed to establish administrative controls to ensure Upper Containment Pool temperature remained within the assumptions of the SBO analysis as delineated in NUMARC-8700 and ensured the final temperature of the Suppression Pool at the end of the 4-hour coping period of an SBO event would not exceed the design temperature of 185 degrees Fahrenheit (°F).
Required Fuses to Implement a Credited Electrical Cross-Tie During a Station Blackout Event Were Missing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-03 Open/Closed None (NPP)71111.21M The team identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to prescribe instructions and procedures appropriate for implementing the credited Division 3 to Division 2 480 Volt cross-tie required to power the Suppression Pool Makeup system, which is needed to mitigate the Station Blackout (SBO) event. Specifically, (1) procedure ONI-SPI C-7 directs operators to look for fuses in a location where the fuses were never stored/placed; and (2) Maintenance Plan 46399 was never updated to reflect the fuses and/or location to be inventoried to ensure the equipment required to implement the credited cross-tie could be performed in accordance with the SBO analysis.
Failure to Assure Seismic Qualification of Division 3 Battery Charger 1E22S0006 Was Maintained Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-04 Open/Closed None (NPP)71111.21M The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to check the seismic design adequacy and operability requirements for the Division 3 Battery Charger 1E22S0006 were maintained. Specifically, upon discovering a bolt and wingnut hardware was not installed for the circuit control cards, the licensee failed to verify whether the discovered condition would have satisfied the seismic design qualification of the battery charger during a postulated design bases seismic event.
Failure to Submit a Licensee Event Report (LER) for Condition That Could Have Prevented the Fulfillment of Safety Function Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2023010-05 Open/Closed Not Applicable 71111.21M The inspectors identified a Severity Level IV (SL-IV) Non-Cited Violation (NCV) of 10 CFR 50.73(a)(2)(v), for the licensees failure to report, within 60 days of discovery, a condition that could have prevented the fulfillment of the safety function. Specifically, the licensee failed to notify the NRC upon discovery of a condition that could have prevented the Division 3 Battery Charger 1E22S0006 from fulfilling its intended safety function.
Additional Tracking Items
None.
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/reading-rm/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. 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.
REACTOR SAFETY
===71111.21M - Comprehensive Engineering Team Inspection The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Structures, Systems, and Components (SSCs) (IP Section 03.01)===
For each component sample, the inspectors reviewed the licensing and design bases including:
- (1) the Updated Safety Analysis Report (USAR);
- (2) the Technical Specifications (TS); and
- (3) the Operational Requirements Manual (ORM). The inspectors reviewed a sample of operating procedures (including normal, abnormal and emergency procedures),overall system/component health (including condition reports and operability evaluations, if any) and associated maintenance effectiveness (e.g., Maintenance Rule, procedures). The inspectors performed visual inspections of the accessible components to identify potential hazards and/or signs of degradation. Additional component specific design attributes reviewed by the inspectors are listed below.
- (1) Unit 1: High Pressure Core Spray (HPCS) Pump (1E22C0001)
1. Translation of vendor specifications
2. Environmental qualification
3. Protection against external events: Seismic
4. Mechanical design calculations and considerations:
a.
Flow capacity & balance b.
Minimum flow c.
Runout flow d.
Required submergence (net positive suction head (NPSH) and vortexing)e.
Suction strainer blockage f.
Condensate Storage Tank (CST) vent and/or instrument line freeze protection g.
Pump cooling h.
Room heat up calculations i.
Room cooling
5. Test/inspection procedures, acceptance criteria, and recent results:
a.
Pump comprehensive In-Service Testing (IST) surveillances b.
Flow balance/capacity tests c.
Pump quarterly IST surveillances d.
TS instrument surveillances e.
Full of water verification at suction piping
6. Electrical design calculations and considerations:
a.
Pump motor voltage drop b.
Pump motor degraded voltage c.
Pump motor brake horsepower d.
Protective devices e.
Cable ampacity f.
Minimum voltage g.
Control logic
1. Translation of vendor specifications
2. Environmental qualification
3. Protection against external events: Seismic
4. Mechanical design calculations and considerations:
a.
Room heat up calculations and environmental considerations b.
Lube oil cooler c.
Jacket water cooler d.
Fuel oil volume consumption e.
Fuel oil available volume/level f.
Fuel oil transfer design (e.g., flow capacity, NPSH)g.
Starting air design, including Station Blackout (SBO) recovery capability h.
Engine lubrication i.
Room heat up calculations j.
Room cooling
5. Test/inspection procedures, acceptance criteria, and recent results:
a.
Engine b.
TS surveillances c.
Lube oil cooler d.
Jacket water cooler e.
Fuel oil volume f.
Fuel oil quality g.
Starting air
6. Electrical design calculations and considerations:
a.
Dynamic calculation (Volts, Hertz, Amps, & loading sequence)b.
Output breaker control logic c.
DG relay coordination d.
Protective relay setpoint e.
Generator grounding scheme f.
Capability to start under degraded voltage conditions
- (3) Unit 1: HPCS Room Cooler (1M39B0003)
1. Translation of vendor specifications
2. Environmental Qualification
3. Design calculations and considerations:
a.
Minimum cooling water flowrate b.
Maximum cooling water temperature c.
Tube plugging limit d.
Fan motor minimum voltage e.
Fan motor cable ampacity f.
Control logic g.
Control circuit voltage h.
Fan motor protective device i.
Heat transfer capacity
4. Test/inspection procedures, acceptance criteria, and recent results:
a.
Flowrates b.
Inspection or thermal performance test
- (4) Unit 1: Emergency Service Water (ESW) Pump (P45-C002)
1. Translation of vendor specifications
2. Environmental qualification
3. Protection against external events:
a.
Flooding, including sump pump b.
Seismic plus pump column seismic analysis
4. Mechanical design calculations and considerations:
a.
Flow capacity & balance b.
Minimum flow c.
Runout flow d.
Required submergence (NPSH, vortexing)e.
Level setpoints and instrument uncertainty f.
Sump/pool level setpoints and instrument uncertainty g.
Hydraulic transients (water hammer)h.
Gas intrusion & accumulation i.
Pump cooling
5. Test/inspection procedures, acceptance criteria, and recent results:
a.
Pump comprehensive IST surveillances b.
Flow balance/capacity tests c.
Pump quarterly IST surveillances d.
TS instrument surveillances
6. Electrical design calculations and considerations:
a.
Alarms b.
Pump motor brake horsepower c.
Protective devices d.
Minimum voltage e.
Control logic
1. Protection against external events: Seismic
2. Mechanical design:
a.
Debris loading impact to flow capacity/balance b.
Mesh size vs downstream component openings c.
Manual backwash capability
3. Test/inspection procedures, acceptance criteria, and recent results:
a.
Protective devices b.
Alarms c.
Minimum voltage d.
Control logic
- (6) Unit 1: 480 VAC 1E Motor Control Center (MCC) EF-1-E1/E2 (PY-1R24S0029 and PY-1R24S0030)
1. Environmental qualification
2. Protection against external events: Seismic
3. Electrical design calculations and considerations:
a.
Bus capacity b.
Degraded voltage protection c.
Overcurrent protection d.
Cable ampacity e.
Protective devices and trip set points
- (7) Unit 1: Division 3 Battery Charger EF-D1-C (1E22S0006)
1. Protection against external events: Seismic
2. Test/inspection procedures, acceptance criteria, and recent results
3. Electrical design calculations and considerations:
a.
Sizing b.
Current limiting setting c.
Duty cycle d.
Contribution to short circuit fault current e.
Sizing of protective fuses/breakers/relays f.
Configuration of electrical distribution g.
Cable ampacity h.
Protective relays/breakers
- (8) Unit 1: 125 VDC Bus ED-1-C (PY-1R42S0037)
1. Protection against external events: Seismic
2. Test/inspection procedures, acceptance criteria, and recent results:
a.
Relay/Meter calibration
3. Electrical design calculations and considerations:
a.
Short circuit calculations b.
Coordination calculations c.
Bus capacity d.
Overcurrent protection e.
Loss of voltage f.
Cable ampacity g.
Protective devices and trip set points
Modifications (IP Section 03.02) (6 Samples)
- (1) Calculation P45-084, Addendum No. A-01 - Determine Allowable Silt and Zebra Mussel Accumulations in ESW and SW Intake SSCS
- (2) Calculation M39-015, Revision 4 - High Pressure Core Spray Pump Room Cooler Performance Test Results
- (3) Calculation E22-043, PIN-05 - High Pressure Core Spray System Thermal Hydraulic Analysis
- (5) ECP-12-0037: Installation of 18 Inch Tall Flood Curb at Door IB 103
- (6) Engineering Design Change Request (EDCR) 92-0202, Revision 0 - Station Blackout Cross-Tie Between EF1E (Div.3) and EF1C07 (Div. 2)10 CFR 50.59 Evaluations/Screening (IP Section 03.03) (11 Samples)
- (2) SCR 18-00926, Revision 0 - Calculation P45-057A/B/C Emergency Service Water Thermal Hydraulic Model
- (3) SCR 18-02362, Revision 1 - Other SCN-005 to ISS-2300 Insulation of Plant Systems
- (4) SCR 18-03530, Revision 9 - Procedure SOI-M32 Emergency Service Water Pump House Ventilation System
- (5) SCR 20-00488, Revision 0 - Calculation SBO-007 1/A-01 Loss of Heat Tracing - CST/HPCS Instrument Line
- (6) SCR 20-00581, Revision 0 - USAR CN 20-051 0 Emergency Service Water Operating Data Updates Based on EER 601268759
- (7) SCR 21-00871, Revision 0 - Calculation AOV-1 0, A-04 Perry Nuclear Power Plant Air Operated Valve Functional Evaluation
- (8) SCR 22-00075, Revision 0 - Calculation B13-027 0 ASME Code NB-3200 Analysis of HPCS Piping Location
- (9) SCR 22-00582, Revision 0 - Calculation M39-015 4 High Pressure Core Spray Pump Room Cooler Performance Test Results
- (10) SCR 17-01209, Revision 1 - ECP 17-0132: Replacement of Division 3 Diesel Generator Stator Analog Temperature Monitor 1E22R0716 with an Equivalent Digital Device
Operating Experience Samples (IP Section 03.04) (2 Samples)
- (1) CR-2023-01057 - FME: Division 1 Right Bank #6 Thermocouple Outer Sheath Found Missing During Replacement
- (2) Licensee Event Report (LER) 2011-004-00 & 2011-004-01 - Flooding Calculation Deficiency Results in Unanalyzed Condition
INSPECTION RESULTS
Failure to Account for Instrument Uncertainties Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-01 Open/Closed None (NPP)71111.21M The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, when the licensee failed to account for instrument uncertainty in the surveillance procedures acceptance criteria for High Pressure Core Spray required pump flow and differential pressure.
Description:
When using an instrument to measure a quantity, the recorded value will always have an amount of uncertainty. These uncertainties need to be accounted for to ensure that when a quality related test is performed the results collected validate the associated SSCs remain within licensing and design bases values. During their review, the inspectors noted the High Pressure Core Spray (HPCS) pumps performance surveillance test failed to account for said instrument uncertainties.
For the HPCS system, the Technical Specifications (TS) Surveillance Requirement (SR)3.5.1.4 requires, in part, verification that the HPCS pump develops a specified flow rate (greater than or equal to 6110 gpm) with sufficient pump total head to overcome the total system resistance which includes a specified reactor-to-containment wetwell (differential pressure greater than or equal to 128 psid).
The TS SR is met via procedure SVI-E22-T2001, "HPCS Pump and Valve Operability Test,"
Revision 37. Section 5.1.3.19, Section 5.1.4.20, and Section 5.1.5.19 of this procedure establishes the acceptance criteria as a HPCS pump flow rate between 6110 to 6140 gpm and differential pressure between 481.5 to 548.7 psid. These values are meant to ensured conformance with Design and Inservice Testing requirements.
The inspectors noted the design acceptance criteria was obtained from Calculation E22-029, SVI-E22-T2001, HPCS Pump Performance Test Acceptance Criteria, Revision 7, which determined a minimum required value of 468 psid at 6110 gpm. Calculation E22-029 credited NEDC-32972P, BWR Owners Group Report Safety Analysis Evaluations Relative to Measurement Uncertainties for the BWR/6 Improved Standard Technical Specifications, for not including instrument measurement uncertainties in calculating the HPCS pump acceptance criteria. During the review of Calculation E22-029, the inspectors questioned the use of this guidance in the methodology for not separately including the instrument uncertainty. Although, NEDC-32972P is a BWR Owners Group Report, it has not been endorsed by the NRC.
As a result of the inspectors questioning, the licensee calculated the measurement uncertainty for the pressure differential was 23.90 psid. Therefore, the HPCS pump acceptance criteria accounting for all the instrument measurement uncertainties was actually 491.90 psid at 6110 gpm.
Based on the above, the inspectors were concerned the failure to account for said uncertainties could result in a situation where a surveillance test was declared satisfactory when in reality the HPCS pump could be within the unacceptable results range once uncertainties were considered. Since HPCS is a safety related and TS structure, system, or component (SSC), a failed TS Surveillance would result in the SSC becoming inoperable and the associated LCO action statement must be entered.
Corrective Actions: The licensee performed a review of previous test results and noted the last surveillance showed a result of 505.3 psid. The licensee also noted a review of data collected since 2006 showed the lowest result obtained in that period was 495.2 psid.
Therefore, demonstrating the HPCS pump would have passed its required acceptance criteria even when accounting for the newly calculated uncertainties (i.e., greater than or equal to 491.90 psid). As a result, HPCS remained operable and able to perform its function.
In addition, the licensee was recommending: 1) A review of extent of condition, 2) Determine and document the applicability of NEDC-32972P and 3) If required, revise the applicable calculations to include instrument measurement uncertainties.
A preliminary extent of condition by the licensee recognized the Low Pressure Core Spray (LPCS) system was affected by a similar lack of accounting for uncertainties. The licensee calculated an updated acceptance criteria and validated recent test results showed the LPCS pump would have been able to pass using the revised values.
Corrective Action References: CR-2023-03915, NRC Identified Measurement Uncertainties Potentially Not Fully Evaluated in SVI Acceptance Criteria Calculation CR-2023-03932, NRC Identified Measurement Uncertainties Potentially Not Fully Evaluated in SVI Acceptance Criteria Calculation for LPCS
Performance Assessment:
Performance Deficiency: The licensees surveillance procedure SVI-E22-T2001, HPCS Pump and Valve Operability Test, acceptance criteria for required flow and differential pressure failed to account for instrument uncertainty. This was contrary to Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, implementing the acceptance criteria as written, without accounting for the associated instruments' uncertainty, could result in a satisfactory test result, when in actuality the SSCs had failed the surveillance test. This would have resulted in the licensee failing to declare the associated equipment inoperable, entering the required TS Limiting Condition of Operation (LCO) action and potentially place the plant in an unanalyzed configuration.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the finding screened to Green (very low safety significance) because it did not result in the loss of operability or functionality. A review of surveillance test results since 2006, performed by the licensee, determined the HPCS pump would have passed even if using the updated acceptance criteria (which now accounted for all flow and pressure measurement uncertainties).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Technical Specifications Surveillance Requirement 3.5.1.4 requires, in part, the HPCS pump develops a specified flow rate (greater than or equal to 6110 gpm) with sufficient pump total head to overcome the total system resistance, which includes a specified reactor-to-containment wetwell differential pressure. The specified reactor-to-containment wetwell differential pressure was greater than or equal to 128 psid.
Procedure SVI-E22-T2001, "HPCS Pump and Valve Operability Test," Revision 37, was the implementing procedure to comply with applicable HPCS flow and differential pressure design and licensing documents. Section 5.1.3.19, Section 5.1.4.20 and Section 5.1.5.19 of this procedure established the pumps acceptance criteria for flow rate (between 6110 to 6140 gpm) and differential pressure (between 481.5 to 548.7 psid).
Contrary to the above, as of May 12, 2023, the licensee failed to assure all the testing required to demonstrate the HPCS system would perform satisfactorily in service was identified and performed in accordance with written test procedures which incorporated the requirements and acceptance limits contained in applicable design documents.
Specifically, procedure SVI-E22-T2001 failed to account for instrument uncertainties when establishing the acceptance criteria used to ensure successful completion of these tests would ensure the associated SSCs would perform satisfactorily in service, remain operable and within the acceptable limits as determined by applicable design documents (e.g., the TS SR).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Have Administrative Controls for the Upper Containment Pool Temperature Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-02 Open/Closed None (NPP)71111.21M The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the Station Blackout (SBO) analysis assumptions into procedures. Specifically, the licensee failed to establish administrative controls to ensure Upper Containment Pool temperature remained within the assumptions of the SBO analysis as delineated in NUMARC-8700 and ensured the final temperature of the Suppression Pool at the end of the 4-hour coping period of an SBO event would not exceed the design temperature of 185 degrees Fahrenheit (°F).
Description:
On June 1, 2000, the U.S. Nuclear Regulatory Commission issued Amendment No. 112 to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant (PNPP), Unit 1(ML003724441). Amendment No. 112 revised the Technical Specifications and increased the 100 percent authorized rated thermal power level of 3579 megawatts thermal to 3758 megawatts thermal. This represented a power level increase of five percent for PNPP.
Analysis DRF-A22-00084-45, Station Blackout, reevaluated the capability of PNPP following a station blackout event in support of the implementation of the 105 percent power uprate (PU). The licensee reevaluated its existing Station Blackout (SBO) analysis using the guidelines of Nuclear Management and Resources Council (NUMARC)-8700 under the power uprate conditions. NUMARC-8700, Section 2.2.1, Assumptions, states, in part, Immediately prior to the postulated station blackout event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level. The analysis was performed assuming a 4-hour coping duration.
The licensee reevaluated the SBO analysis assuming the Upper Containment Pool temperature at the Technical Specification maximum value of 110 degrees Fahrenheit (°F).
The analysis showed that, at the end of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the Suppression Pool temperature was 186.1 °F. The Suppression Pool temperature of 186.1°F exceeded the Suppression Pool design limit of 185°F. The licensee revised certain input parameters and reperformed the analysis for a second time. The licensee assumed an initial Suppression Pool temperature at the Technical Specification maximum value of 95°F, the Condensate Storage Tank normal temperature maximum value of 125°F, and a value of 95°F for the Upper Containment Pool temperature. This temperature value of 95°F for the Upper Containment Pool was based on historical operating temperature data. Using these new values, the analysis showed that, at the end of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the Suppression Pool temperature was 184.6°F. The licensee determined the peak calculated Suppression Pool temperature remained below the 185°F temperature design limit assumed in the original SBO analysis submittal and therefore, PNPP continued to meet the requirements of Title 10 CFR 50.63, Loss of All Alternating Current Power, after PU.
The inspectors noted the maximum allowed Technical Specification value for the Upper Containment Pool temperature was 110°F. Technical Specification Surveillance Requirement 3.6.2.4.2 states, Verify upper containment pool water temperature is less than or equal to 110°F. Procedure PRI-TSR, Technical Specification Rounds, Revision 48, provides the forms necessary for performance of plant rounds to satisfy Perry Improved Technical Specification Surveillance Requirements. Attachment 5 of procedure PRI-TSR, Item No.
15, Upper Containment Pool Temperature Limits Verification, states the requirement for the temperature of the Upper Containment Pool as less than or equal to 110°F during Modes 1, 2, or 3. In addition, procedure SOI-G41(FPCC), Fuel Pool Cooling and Cleanup System, Revision 43, monitors Upper Containment Pool temperature using instruments CNTMT FUEL STRG POOL TEMP, 1G41-R121 and SEPARATOR STRG POOL TEMP, 1G41-R106.
Section 5.1, Normal Operation, of procedure SOI-G41 states the range for both parameters is less than or equal to 110°F. The inspectors confirmed both procedures are covered by the licensees Quality Assurance Program Manual.
The inspectors noted procedures PRI-TSR and SOI-G41(FPCC) did not contain administrative controls nor instructed operator actions if the Upper Containment Pool temperature exceeds 95°F. In the event of an SBO with the Upper Containment Pool temperature exceeding 95°F, and all other parameters at the assumed values in the SBO analysis, the final temperature of the Suppression Pool at the end of the 4-hour coping period could exceed the design temperature of 185°F and invalidate the SBO analysis. The inspectors reviewed Upper Containment Pool historical operating temperature data for the past five years and did not identify any temperature values above 95°F.
Corrective Actions: The licensees recommended corrective actions included recommending a note be placed in a procedure or in the operator round that the Upper Containment Pool should be maintained less than 95°F per the SBO analysis.
Corrective Action References: Condition Report (CR) 2023-03938, 2023 CETI Inspection - NRC Identified Station Blackout Suppression Pool Analysis Input Temperature.
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to establish administrative controls to ensure Upper Containment Pool temperature remained within the assumptions of the SBO analysis was a performance deficiency. Specifically, procedure SOI-G41(FPCC), Fuel Pool Cooling and Cleanup System, Section 5.0, Normal Operations/Data, and Procedure PRI-TSR, Technical Specification Rounds, Item No. 15, state the allowable value/range for the temperature of the Upper Containment Pool as less than or equal to 110°F. The current SBO analysis (post power uprate) assumes an Upper Containment Pool temperature of 95°F.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to translate the assumptions in the SBO analysis to procedures, following the PU license amendment, to ensure Upper Containment Pool temperature remained within the assumptions of the analysis did not ensure the availability, reliability, and capability of the Suppression Pool to cope with an SBO event to prevent undesirable consequences (i.e., core damage).
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as having very low safety significance (Green) because the inspectors answered No to the risk screening questions listed in IMC 0609, Appendix A, Exhibit 2, Section A. Specifically, the inspectors reviewed Upper Containment Pool historical operating temperature data for the past five years and did not identify any Upper Containment Pool temperature values above 95°F. Therefore, Upper Containment Pool temperature remained within the assumptions of the SBO analysis and PRA functionality was not lost.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which Appendix B applies are correctly translated into specifications, drawings, procedures, and instructions.
Perry Nuclear Power Plant Updated Safety Analysis Report (USAR), Table 1.8-1, Conformance to NRC Regulatory Guides, states, in part, PNPP conforms to Regulatory Guide (RG) 1.155, Station Blackout, Revision 0.
Regulatory Guide 1.155, states, in part, Nuclear Management and Resource Council (NUMARC) developed guidelines and procedures for assessing station blackout coping capability and duration for light-water reactors (NUMARC-8700, November 1987). Section C, Regulatory Position, of RG 1.155, states, in part, NUMARC-8700 provides guidance acceptable to the staff for meeting the requirements of § 50.63 of 10 CFR Part 50.
NUMARC-8700, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light-Water Reactors, Section 2.2.1, Assumptions, states, in part, Immediately prior to the postulated station blackout event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level.
Analysis DRF-A22-00084-45, Station Blackout, reevaluated the capability of Perry Nuclear Power Plant following a station blackout event in support of the implementation of a 105 percent power uprate. The analysis assumed a value of 95°F for the Upper Containment Pool temperature. Using this value, the analysis showed that, at the end of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the Suppression Pool temperature was 184.6°F, meeting the Suppression Pool design limit of 185°F.
Procedure PRI-TSR, Technical Specification Rounds, Revision 48, provides the forms necessary for performance of plant rounds to satisfy Perry Improved Technical Specification Surveillance Requirements. Attachment 5 of procedure PRI-TSR, Item No. 15, Upper Containment Pool Temperature Limits Verification, states the requirement for the temperature of the Upper Containment Pool as less than or equal to 110°F during Modes 1, 2, or 3.
Procedure SOI-G41(FPCC), Fuel Pool Cooling and Cleanup System, Revision 43, monitors Upper Containment Pool temperature using instruments CNTMT FUEL STRG POOL TEMP, 1G41-R121 and SEPARATOR STRG POOL TEMP, 1G41-R106. Section 5.1, Normal Operation, of procedure SOI-G41 states the range for both parameters is less than or equal to 110°F.
Contrary to the above, as of May 12, 2023, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which Title 10 CFR Part 50, Appendix B applies are correctly translated into specifications, drawings, procedures, and instructions. Specifically, procedures PRI-TSR, Technical Specification Rounds, and SOI-G41(FPCC), Fuel Pool Cooling and Cleanup System, which are the procedures used to monitor and control the Upper Containment Pool temperature, do not include administrative controls to ensure the Upper Containment Pool temperature remained within the normal operating ranges assumed in the SBO analysis.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Required Fuses to Implement a Credited Electrical Cross-Tie During a Station Blackout Event Were Missing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-03 Open/Closed None (NPP)71111.21M The team identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to prescribe instructions and procedures appropriate for implementing the credited Division 3 to Division 2 480 Volt cross-tie required to power the Suppression Pool Makeup system, which is needed to mitigate the Station Blackout (SBO) event. Specifically,
- (1) procedure ONI-SPI C-7 directs operators to look for fuses in a location where the fuses were never stored/placed; and
- (2) Maintenance Plan 46399 was never updated to reflect the fuses and/or location to be inventoried to ensure the equipment required to implement the credited cross-tie could be performed in accordance with the SBO analysis.
Description:
As part of the SBO event mitigation strategy, the licensee credits the ability to crosstie MCC EF1E (Division 3) to MCC EF1C07 (Division 2). This cross-tie allows the licensee to use the Division 3 Diesel Generator (which normally powers the High Pressure Core Spray system) to provide power to the Suppression Pool Makeup system. During an SBO, the licensee credits the Suppression Pool Makeup system to transfer water from the Upper Containment Pool over to the Suppression Pool. This ensures the Suppression Pool temperature stays within the analyzed limits. The cross-tie is implemented using procedure ONI-SPI C-7, Division 3 to Division 2 480 Volt Cross-tie, Revision 5. The procedure directs operators to obtain two sets of three 600 VAC/60 Amp fuses from the Storage Area 7 File Cabinet at Control Complex (CC) 599. The ONI-SPI C-7 subsequently directs the operator to install the fuses (steps 2.1 and 4.3) in order to establish the cross-tie.
As part of the 2023 Comprehensive Engineering Team Inspection, licensee staff and the inspectors performed a walkdown of procedure ONI-SPI C-7. However, when the Storage Area 7 File Cabinet at CC 599 was checked, no fuses were found. Subsequently, the fuses were found in the bottom of electrical cubicles EF1C07-UU and EF1E-1-B. These were the previous storage locations for the fuses. On March 23, 2017, the licensee changed the intended storage location for the cross-tie fuses. A procedure revision to ONI-SPI C-7 was issued (from Revision 3 to Revision 4). However, the licensee believes the fuses were never physically moved to the new desired location (i.e., Storage Area 7 File Cabinet CC 599).
The inspectors inquired as to how the pre-staging of equipment was controlled. The licensee stated the inventory of the pre-staged equipment was controlled via procedure PAP-0524, Emergency Operating Procedures, which states that tool inventory shall be done quarterly.
While the procedure uses the term tool, the licensees practice is to verify the contents of a location including items that are not tools. The licensee was crediting Maintenance Plan 46399 for performing the required quarterly inventory of the cross-tie fuses, as well as other Emergency Operating Procedures (EOPs) required equipment and storage locations.
However, it was subsequently discovered the Maintenance Plan 46399 was never updated to reflect the cross-tie fuses and/or the new location to be inventoried (i.e., Storage Area 7 File Cabinet at CC 599).
The inspectors confirmed both ONI-SPI C-7 and Maintenance Plan 46399 were covered by the licensees Quality Assurance Program Manual.
Corrective Actions: The licensee located the fuses in their previous storage locations (electrical cubicles EF1C07-UU and EF1E-1-B). A continuity check was performed to ensure the fuses were in a good working condition. Subsequently, new fuses were obtained and tested from the sites main storage warehouse then placed in their required storage location as required by procedure ONI-SPI C-7. The licensee is evaluating actions to update Maintenance Plan 46399. The licensee also discovered procedure ONI-SPI C-6, which provides for establishing a similar cross-tie between Division 3 to Division 1, had the same deficiency (i.e., fuses were stored in the respective electrical cubicles instead of the required file cabinet). However, this cross-tie was not credited for mitigating the SBO event.
Corrective Action References: Corrective Action References:
CR 2023-03570, 2023 CETI Inspection: NRC Identified ONI-SPI C7 Fuses Not in Specified Storage Location; 04/27/2023 CR 2023-03776, 2023 CETI Inspection: NRC Identified EOP-2 Tool Inventory Maintenance Plan Needs Clarification; 05/04/2023
Performance Assessment:
Performance Deficiency: The licensee failed to prescribe appropriate instructions and procedures to ensure the Division 3 to Division 2 480 Volt cross-tie, required to power the Suppression Pool Makeup system, which is needed to mitigate the SBO event, could be implemented as required. Specifically, two examples of procedure deficiencies were identified. First, procedure ONI-SPI C-7, "Division 3 to Division 2 480 Volt cross-tie" directed operators to obtain a set of required fuses from a location which never housed said fuses.
Second, Maintenance Plan 46399,which ensures an inventory of the required fuses is performed, was not updated to reflect the equipment or location to be inventoried. This was contrary to 10 CFR Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to pre-stage the required fuses could impede or delay establishing a flow path from the Upper Containment Pool to the Suppression Pool via the Suppression Pool Makeup system. The result of the delay would allow Suppression Pool temperatures to rise, potentially exceeding the previously evaluated limits established in the SBO analysis.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, based on the equipment available and working in consultation with the regional Senior Reactor Analyst (SRA) the inspectors were able to determine the degraded condition did not result in a loss of PRA function. As a result, the SRA and inspectors were able to answer "no" to the IMC 0609 Exhibit 2, "Mitigating Systems Screening Questions" discussed in Section A and the Exhibit 3, "Barrier Integrity Screening Questions" discussed in Section C.
Therefore, this finding was assessed as having a very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.
ONI-SPI C-7, Division 3 to Division 2 480 Volt Cross-tie, Revision 5, was the procedure for establishing the electrical cross-tie required to power MCC EF1C07. Power to this MCC is required to initiate the Suppression Pool Makeup system, which is credited to mitigate the SBO event. To perform the cross-tie two sets of three 600 VAC/60 Amp fuses are required.
Under section Necessary Equipment the Storage Area 7 File Cabinet at CC 599 is the location designated for storage of this fuses.
Maintenance Plan 46399 was the instruction credited to perform the inventory of the required Division 3 to Division 2 480 Volt Cross-tie fuses. Item 2 of the maintenance plan lists the locations to be inventory.
Contrary to the above, since March 23, 2017, the licensee failed to prescribe instructions and procedures appropriate for implementing the credited Division 3 to Division 2 480 Volt cross-tie required to power the Suppression Pool Makeup system, which is needed to mitigate the SBO event. This is evidenced by the following examples:
1) Specifically, ONI-SPI C-7 directs operators to look for fuses in a location where the fuses were never stored/placed.
2) Specifically, Maintenance Plan 46399 was never updated to reflect the fuses and/or location to be inventoried to ensure the equipment required to implement the Division 3 to Division 2 480 Volt Cross-tie could be performed in accordance with the SBO analysis.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Assure Seismic Qualification of Division 3 Battery Charger 1E22S0006 Was Maintained Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2023010-04 Open/Closed None (NPP)71111.21M The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to check the seismic design adequacy and operability requirements for the Division 3 Battery Charger 1E22S0006 were maintained. Specifically, upon discovering a bolt and wingnut hardware was not installed for the circuit control cards, the licensee failed to verify whether the discovered condition would have satisfied the seismic design qualification of the battery charger during a postulated design bases seismic event.
Description:
Perry Nuclear Power Plants (PNPP) Updated Safety Analysis Report (USAR), Revision 22, Section 8.3.2.1.3, High Pressure Core Spray - Division 3 - Engineered Safety Features DC System, establishes the Division 3 Battery Charger as Class 1E. The USAR Table 3.2-1, Equipment Classification, also establishes the 125V battery chargers, which include Division 3 Battery Charger 1E22S0006, as Seismic Category I. Additionally, Technical Specification 3.8.4, DC Sources - Operating, requires the Division 3 electrical power subsystem shall be operable.
On August 11, 2017, the licensee generated condition report (CR) CR-2017-08373, Potential Seismic Bolt Missing from Charger. The CR identified a condition of Battery Charger 1E22S0006 in which a bolt and wingnut hardware was discovered to be not installed to secure its circuit control cards in place. This condition was discovered during its 10-year preventative maintenance to replace the circuit control cards. During review of the corrective actions, the inspectors noted the licensee recommended an action to determine whether the bolt and wingnut hardware was needed to maintain the battery chargers seismic qualification. The licensee, as part of their investigation for this CR, attempted to contact the vendor and performed review of the seismic qualification report; however, the necessity of bolt and wingnut hardware for seismic capability still could not be determined. Nevertheless, the review of the condition resulted in no reportability concerns, and no past operability review was requested.
The inspectors questioned the basis for concluding there were no reportability or past operability concerns. The original seismic qualification of the battery charger was performed via shaker table testing utilizing seismic inputs that enveloped the sites design basis seismic criteria (discussed in USAR Section 3.7, Seismic Design). The seismic qualification report neither explicitly discussed the necessity of the subject bolt and wingnut hardware, nor did it specifically call them out in the drawings that were included in the test report. The licensees work instruction for performing preventative maintenance to replace the control cards also did not explicitly discuss installation of the subject bolt and wingnut hardware.
The inspectors reviewed the vendor manuals for information on the circuit control cards. Additionally, walkdowns were performed to better understand the mounting configuration for the control cards. One of the two control card assemblies in the battery charger was in question. The assembly consisted of a mounting bracket, two control cards, and a bolt/wingnut combination. The mounting bracket was equipped with a guide piece on each side of the bracket for the control cards to slide in along the bracket, so that they could be fit into the connector slots. Once the control cards are fit into the connector slots, the bolt and wingnut hardware would then be inserted across the bracket and fastened to secure the control cards in place. Therefore, the absence of the bolt and wingnut hardware effectively eliminated the securing mechanism for the control cards in their respective mounting bracket. With the connector slots being the only mechanism holding the control cards in place without the bolt and wingnut hardware securing them, the inspectors challenged whether this condition wouldve been bounded by the testing configuration in their original seismic qualification test report.
Following discussions with the licensee, the inspectors concluded significant doubts existed in the battery chargers ability to perform its required safety functions had it been called upon to function during a design basis seismic event. The licensee was not able to determine the duration of this deficient condition prior to discovery. However, the inspectors noted the corrective actions from CR-2017-08373 included installing the bolt and wingnut hardware to secure the control cards. During walkdown of the battery charger, the inspectors verified the required bolt and wingnut hardware was in place. Therefore, this condition did not represent a current operability concern.
A violation regarding the failure to provide the required licensee event report to the NRC was dispositioned as a separate item in this report.
Corrective Actions: Based on a review of available documentation and conversations with the inspectors, the licensee concluded the missing bolt and wingnut hardware was required to maintain the battery chargers seismic qualification and consequently its operability requirements. The licensee staff and inspectors performed a walkdown of Battery Charger 1E22S0006 and verified the required bolt and wingnut hardware was installed in place.
Corrective Action References: CR-2023-03970, CETI Inspection: NRC Identified 50.72 Notification not conducted for CR-2017-08373
Performance Assessment:
Performance Deficiency: The licensee's failure to check the of seismic design adequacy and operability requirements for the Division 3 Battery Charger 1E22S0006 were maintained was contrary to Title 10 CFR 50, Appendix B, Criterion III, and a performance deficiency.
Specifically, upon discovering the bolt and wingnut hardware was not installed for the circuit control cards, the licensee failed to verify whether the discovered condition would have satisfied the seismic design qualification of the battery charger during a postulated design bases seismic event.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the discovery of a degraded condition associated with the missing seismic bolt and wingnut hardware for the circuit control cards created significant doubts on the battery charger's ability to perform its required safety function during postulated design basis seismic events.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. A detailed risk evaluation was performed to assess the significance of the finding. The finding was assumed to result in the loss of seismic capacity of the division 3 normal battery charger during and following a seismic event. The condition was assumed to exist for an exposure period of one year. A Region III senior reactor analyst (SRA) used the Standardized Plant Analysis Risk (SPAR) model version 8.80 for Perry Nuclear Power Plant, Unit 1 and SAPHIRE version 8.2.8 to analyze the finding. Flex equipment failure rates were estimated by using the latest failure rates from PWROG-18042-NP, FLEX Equipment Data Collection and
Analysis.
The change in core damage frequency for the exposure period was estimated to be 3E-8/yr. Therefore, the finding screened as having very low safety significance (Green).
Risk contributions for internal events were not evaluated because a seismic event would be needed to disconnect the division 3 battery charger control board and thereby cause failure of the associated battery charger. The risk associated with the failure of the division 3 battery charger control board comes from additional sequences which include common cause failure of the division 3 battery chargers. These sequences are not dominant sequences in the seismic model. The seismic model has a basic event for the division 3 battery chargers which assumes a seismic magnitude great enough to cause their failure, this basic event dominates the common cause failure of the division 3 battery chargers. In this detailed risk evaluation, the dominant core damage sequence involves a seismic event (> 1.0g), which results in the loss of the reactor building.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, the design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
USAR Table 3.2-1, Equipment Classification, Principal Component XXXIII.1, establishes the 125V battery chargers, which include the Division 3 Battery Charger 1E22S0006, as Seismic Category I.
USAR Section 3.7.1, Seismic Input, establishes in part, that Seismic Category I structures, systems and components are necessary to assure:
- (1) the integrity of the reactor coolant pressure boundary,
- (2) the capability to shut down the reactor and maintain it in a safe shutdown condition or
- (3) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable exposure guidelines.
Contrary to the above, on August 11, 2017, the license failed to verify the adequacy of the design of Battery Charger 1E22S0006. Specifically, upon discovering the bolt and wingnut hardware was not installed for the circuit control cards, the licensee failed to verify whether the discovered condition would have satisfied the seismic design qualification of the battery charger, a safety related and seismic Category I equipment.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Submit a Licensee Event Report (LER) for Condition That Could Have Prevented the Fulfillment of Safety Function Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2023010-05 Open/Closed Not Applicable 71111.21M The inspectors identified a Severity Level IV (SL-IV) Non-Cited Violation (NCV) of 10 CFR 50.73(a)(2)(v), for the licensees failure to report, within 60 days of discovery, a condition that could have prevented the fulfillment of the safety function. Specifically, the licensee failed to notify the NRC upon discovery of a condition that could have prevented the Division 3 Battery Charger 1E22S0006 from fulfilling its intended safety function.
Description:
Technical Specification 3.8.4, DC Sources - Operating, requires the Division 3 electrical power subsystem shall be operable. During review of the licensees condition report (CR)2017-08373, Potential Seismic Bolt Missing from Charger, the inspectors identified a condition that could have prevented the fulfillment of safety function of the Division 3 Battery Charger. Specifically, the CR identified a condition of Battery Charger 1E22S0006 in which a bolt and wingnut hardware was discovered to be not installed to secure its circuit control cards in place. Following discovery of the missing hardware, the inspectors noted an adequate reportability review was not conducted, nor a past operability evaluation was requested to determine whether the battery charger would have been operable. Following review of the vendor manuals and walkdowns to better understand the control card mounting configuration within the battery charger, and follow-up discussions with the licensee, it was concluded significant doubts existed in the battery chargers ability to perform its required safety function when called upon during the design basis seismic events.
Licensee Procedure NOP-OP-1015, Event Notifications, established the requirements for the identification and development of notifications. Section 4.2.3 of the procedure stated, Any event or condition requiring an evaluation in order to determine reportability must be evaluated on a schedule commensurate with its safety significance per the guidance of NRC Regulatory Issue Summary (RIS) 2005-20. Whenever a reasonable expectation no longer exists that the equipment in question is operable, or significant doubts begin to arise, appropriate actions, including event notifications, should be taken. In light of the discovered condition, and in conjunction with the licensee procedural requirements, it was concluded it constituted a condition that should have been reported under the provision of 10 CFR 50.73(a)(2)(v).
A separate violation regarding the failure to verify the adequacy of the seismic design of Battery Charger 1E22S0006 was dispositioned as a separate item in this report.
Corrective Actions: Based on a review of available documentation and conversations with the inspectors, the licensee concluded the missing bolt and wingnut hardware was required to maintain the battery chargers seismic qualification and consequently its operability requirements. The licensee entered this issue into their Corrective Actions Program and performed a review of NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73,"
Revision 3. The licensee subsequently determined there were no reporting requirements associated with this condition since the event occurred more than 3 years ago.
Corrective Action References: CR-2023-03970, CETI Inspection: NRC Identified 50.72 Notification not conducted for CR-2017-08373
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency.
Specifically, the performance deficiency is considered minor since it dealt with a reporting requirements. A separate, but related, finding of very low safety significance (Green) associated with the failure to assure the Battery charger's seismic qualification was maintained has been documented in this report.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: Based on the examples provided in Section 6.9 of the Enforcement Policy, dated January 13, 2023, Inaccurate and Incomplete Information or Failure to Make a Required Report, the issue of concern was determined to be a Severity Level IV violation. Specifically, example 6.9.d.9 lists a failure to make a required report per 10 CFR Part 50.73, as an example of a Severity Level IV violation Violation: 10 CFR 50.73(a)(2)(v) requires, in part, that an event or condition that could have prevented fulfillment of safety function be reported to the NRC within 60 days from the time of discovery.
Contrary to the above, the licensee failed to submit a LER within 60 days of August 11, 2017, after discovering a condition that could have prevented Division 3 Battery Charger from fulfilling its safety function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 25, 2023, the inspectors presented the Comprehensive Engineering Team Inspection results to Rod Penfield and other members of the licensee staff.
On May 12, 2023, the inspectors presented the Interim Exit Meeting inspection results to Chris Elliott and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
P45G071A
T: Evaluation of Emergency Service Water Piping and
Supports for Package 1 P45G071A
1E22G008A
Analysis of Piping for HPCS Diesel Exhaust
and A-01
1P45H0010
Qualification of Emergency Service Water Pipe Support
1P45H0010
B13-027
ASME Code NB-3200 Analysis of HPCS Piping Location
DRF-A22-00084-
Station Blackout
10/12/1999
E22-029
SVI-E22-T2001 HPCS Pump Performance Test
Acceptance Criteria
E22-042
Division 3 EDG Jacket Water Heat Exchanger Performance
Test
E22-043
HPCS System Hydraulic Analysis
04/13/2006
E22-C10
HPCS Pump Discharge Indicated Flow
ECA-018
Environmental Conditions Analysis
ECA-064
HPCS PRC Load for Steady State Room Temperatures
EQ-151
Determine Effects on Safety Equipment for Accident
Temperature Increase
GEN-022
JL-083
Flooding Analysis of CCB, IB, and FHB - Floor Elevation
574-10
and P-01
M39-014
HPCS Pump Room Cooler Air Flow Rate and Performance
Evaluation at Design Conditions
06/11/2012
M39-015
HPCS Pump Room Cooler Performance Test Results
M39-016
ECCS Pump Room Coolers Design Airflows
M39-017
Minimum Reynolds Number to Verify Turbulence for
1M39B0003 Operating Ranges
P45-030
Perry Unit #1 P45 System Operating Temperatures
P45-031
SW-ECC Emergency Temperatures
P45-038
Evaluation for Cavitation in Butterfly/Globe Valves
P45-051
Composite Bias Uncertainty of HPCS PRC ESW Flow
Calculations
P45-056
ESW Pump Performance Acceptance Criteria for SVI-P45
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
T2001
P45-057C
ESW System Thermal Hydraulic Model (Loop C)
P45-075
Minimum Branch Flow Rates for P45 Surveillance
Acceptance Criteria
P45-078
Emergency Service Water Pump "C" as Built Head
Capacity Curve
01/31/2006
P45-081
Evaluation of Net Positive Suction Head (NPSH) and
Submergence Requirements for the Emergency Service
Water (ESW) Pumps
09/28/2004
P45-44
Keep Fill Check Valve Leak Rate Standpipe Draindown
Level
P924
Penetration Analysis for P-108, P-310, P-311, and P-409
PRDC-0002
Unit 1 Div 1, 2, 3 125 VDC System Coordination
PRDC-0012
Evaluation of DC Loads for a 4 Hours Design Basis Station
Blackout (SBO) and Also for a 24 Hours Beyond Design
Basis Events
and 3 P-01
PRDC-0016
Division 3, 125 VDC System Load Evaluation, Voltage
Drop, Battery / Battery Charger Sizing Calculation
3, 3 P-01, 3
A-01, and 3
PY-1R45A0005
Final Report on ASME Section III Analysis of Class 3
Nuclear Safety Related Shop Fabricated Tanks for the
Perry Nuclear Power Plant
2/16/1977
R45-003
Diesel Fuel Oil Pumps
R45-007
Standby and HPCS DG Fuel Oil Day Tank Volume Level
R45-012
HPCS and Div. I & II Fuel Oil Day Tank Setpoint Volumes
R45-C04
Div. 1, 2&3 DG Fuel Oil Day Tank ITS Volume Calculation
R48-10
Standby and HPCS DG Intake Air
SQ-0147
Seismic Qualification for 1P45C0002 (ESW Pump)
CR 1996-02889
HPCS DG Left Bank Admission Valve
09/05/1996
CR 2003-05065
Track Activities to Completion That are Required to Close
04/15/2005
CR 2003-05354
Emergency Service Water Pump Couplings
2/04/2004
CR 2017-08373
Potential Seismic Bolt Missing from Charger
08/11/2017
Corrective Action
Documents
CR 2017-08373
Potential Seismic Bolt Missing from Charger
08/11/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2017-08930
NRC ID DBAI Inspection: Calculation SBO-007
Conservatism and Degraded CST Instrumentation LIne
Insulation
08/29/2017
CR 2017-09006
NRC ID DBAI Inspection: The SBO Analysis Requires 150k
Gallons of Water from the CST Which Affects ONI-R10
Requirements
08/31/2017
CR 2017-09033
NRC ID DBAI Inspection: ESW Discharge Strainer
Differential Pressure Alarms are the Same Value as Design
Maximum Value
08/31/2017
CR 2019-00742
Deficient 50.59 Screen for Temporary Insulation Removal
Spec Change Notice
2/22/2019
CR 2019-06875
2019 NRC 50.59 Inspection: Inappropriate 10CFR 50.59
Exemption Applied for RAD
08/15/2019
CR 2020-04310
ED1C Bus Volts are Drifting on Normal Charger 1E22-S006
05/16/2020
CR 2020-05484
Prompt Operability Determination Form (NOP-OP-1009-01)
07/06/2020
CR 2021-05948
Division 3 Emergency Service Water Flow is Degrading
08/11/2021
CR 2021-07711
Diesel Fuel Storage Tank Cleaning
10/14/2021
CR 2022-03956
Division 3 Emergency Service Water Flow Lower After
Maintenance
05/09/2022
CR 2022-04902
Division 3 ESW Degradation
06/16/2022
CR 2022-07882
Division 1 Diesel Right Bank Cylinder 6 Low Exhaust
Temperature
10/18/2022
CR 2023-10157
FME: Division 1 Right Bank #6 Thermocouple Outer Sheath
Found Missing During Replacement
2/15/2023
CR G202-2002-
00329
Determine Operability of ESW with an ESWPH Ventilation
Subsystem out of Service
01/31/2002
CR 2023-03504
NRC ID: 2023 CETI Inspection: NRC Identified Material
Cart Not Secured
04/25/2023
CR 2023-03570
23 CETI Inspection: NRC Identified ONI-SPI C-7 Fuses
Not in Specified Storage Location
04/27/2023
CR 2023-03672
23 CETI Inspection: NRC Identified Equivalent
Instrument May Not Have Been Used
05/01/2023
Corrective Action
Documents
Resulting from
Inspection
CR 2023-03714
23 CETI Inspection: NRC Identified Deficiencies in DC
Fault Analysis
05/02/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2023-03776
NRC ID: 2023 CETI Inspection: EOP Tool Inventory
Maintenance Plan Needs Clarification.
05/04/2023
CR 2023-03889
23 CETI Inspection: NRC Identified HPCS Dissimilar
Weld Not Evaluated for License Renewal
05/08/2023
CR 2023-03915
23 CETI Inspection - NRC Identified Measurement
Uncertainties Potentially Not Fully Evaluated in SVI
Acceptance Criteria Calculation
05/09/2023
CR 2023-03918
23 CETI Inspection - NRC Identified Cable Tie Mount
Detached on Inside of Division 3 Control Panel
05/09/2023
CR 2023-03932
23 CETI Inspection - NRC Identified Measurement
Uncertainties Potentially Not Fully Evaluated in SVI
Acceptance Criteria Calculation for LPCS
05/10/2023
CR 2023-03938
23 CETI Inspection - NRC Identified Station Blackout
Suppression Pool Analysis Input Temperature
05/10/2023
CR 2023-03961
23 CETI Inspection - NRC Identified the Pyrocrete
Installed on the Div 3 HPCS Fuel Oil Day Tank Was Not
Considered in the Structural Qualification
05/11/2023
CR 2023-03964
23-CETI Inspection: NRC Identified Additional
Deficiencies in DC Fault Analysis
05/11/2023
CR 2023-03970
CETI Inspection: NRC Identified 50.72 Notification Not
Conducted for CR-2017-08373
05/11/2023
2-0576-001-020
Division # ED Tube Plugging
206-0018-00000
Class 1E 4.16KV Bus EH13
206-0020-00000
Electrical Main One Line Diagram 480V
206-0029-0000
Electrical Class 1E 480V Bus EF1E
NN
206-0050-00000
Electrical Class 1E DC System - Division 3
Z
208-0065-00003
High Pressure Core Spray System Pump Relay Logic
S
208-0066-00001
High Pressure Core Spray Power Supply System Pump
C001
208-0066-00116
High Pressure Core Spray 125V DC Battery Charger
1E22-S006 (EFD-1-C)
E
208-0131-00003
Pump Room Cooling System HPCS Pump Room Cooler
S
Drawings
208-0176-00003
Emergency Service Water System HPCS Emergency
U
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Service Water Pump C002
208-0176-00006
HPCS Emergency Service Water Pump Discharge Valve
F140
Z
208-0176-00020
Emergency Service Water System HPCS Discharge
Strainer MOV 1P45--F160
T
208-0215-00022
Division III 125V D.C. System Metering & Relaying
G
2-0126-00001
Emergency Service Water Pump (1P45C002)
A
2-0212-00000
Service Water System
VVV
2-0356-00000
Division 3 Diesel Fuel Oil System
V
2-0358-00000
Division 3 Diesel Starting Air System
G
2-0359-00000
Division 3 Diesel Lube Oil System
E
2-0360-00000
Division 3 Diesel Jacket Water Cooling System
G
2-0701-00000
HPCS System
2-0791-00000
Emergency Service Water System
BBB
2-0793-00000
Emergency Service Water Operating Data
P
B-208-066
High Pressure Core Spray Power Supply System Pump
C001 Manual Override Control
M
B-208-176
Emergency Service Water System HPCS Discharge
Strainer
P
DCP 98-0052
Single Feedwater MOV Improvements Modification
EC 04-0146
ESW C Pump Lift Setting
EC 04-0263
Emergency Service Water Pump (ESW) Upgrade
ECP 12-0037
Installation of 18" Tall Steel Flood Curb at Door IB-103
EDCR 92-0202
Station Blackout Cross-Tie Between EF IE (DIV. 3) and EF
lC07 (DIV. 2)
P45-084
Determine Allowable Silt and Zebra Mussel Accumulation in
Engineering
Changes
P45-084
Determine Allowable Silt and Zebra Mussel Accumulation in
ESW and SW Intake SSC's, Addendum A-01
05-03199
CFR 50.59 SCXREEN - P45-084 and Other P45 Calcs
08/12/2005
05-06409
CFR 50.59 SCREEN - Calculation P-45-078
01/31/2006
Engineering
Evaluations
06-02235
10CFR 50.59 SVI-E22-T2001 HPCS Pump Test
Acceptance Criteria
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2-01602
Installation of 18 Tall Steel Flood Curb at Door IB-103
16-01392
CFR 50.59 SCREEN - Replacement of Valves
1E12F0084A/C
2/28/2019
17-01209
10CFR 50.59 Screen ECP-17-0132
18-00926
CFR 50.59 SCREEN - Calculation P-45-057 A/B/C
04/05/2020
18-02362
CFR 50.59 SCREEN - Insulation of Plant Systems
08/24/2018
18-03530
Emergency Service Water Pump House Ventilation System
20-00488
10CFR 50.59 Screen SBO-007
20-00581
CFR 50.59 SCREEN - Emergency Service Water
Operating Data Updates Based on EER601268759
05/11/2020
21-00871
SCR 21-00871 00 Calculation AOV-1 0, A-04 Perry Nuclear
Power Plant Air Operated Valve Functional Evaluation
06/03/2021
2-00075
50.59 Screening for ASME Code NB-3200 Analysis of
HPCS Piping Location
2-00582
10CFR 50.59 Screen M39-015
HPCS Room Air Handling Unit Vendor Manual
HPCS Pump Vendor Manual
Seismic Qualification Reevaluation Class 1E Equipment for
HPCS Batteries, Rack and Charger
03/01/1985
2-316
C&D Technologies KCR Lead-Calcium Specification Sheet
0512/CD
and
20/CD
1P45-C002 ROCA
7-4-2022
1P45-C002 Five Point Curve Validation
07/06/2022
200864310
SVI-R42T5227 Unit 1, Div 3, Annual Battery Inspections
08/31/2022
200864316
SVI-R42T5225 Unit 1, Div 1, Annual Battery Inspections
07/21/2022
200864319
SVI-R42T5226 Unit 1, Div 2, Annual Battery Inspections
08/23/2022
43368-1
Seismic Simulation Test Report for Battery Charger and
Battery Rack
09/12/1976
600503777
Engineering Evaluation Request
11/14/2008
Miscellaneous
ATL-2018-1291-
SOI-M32
05/18/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ATA-40
DI-224
HPCS Pump Room Cooler Design Input
07/26/2012
DSP-504-4549-00
Design Specification for Nuclear Safety Related Shop
Fabricated Tanks
VII
DSP-R44-R48-
E22-3-4549-00
Design Specification for Standby and High Pressure Core
Spray Diesel Generator Starting Air, Intake and Exhaust
Systems Piping and Pipe Supports
EMARP-0011
Emergency Service Water System Monitoring Program
G239-061 D1-D7
Division 3 Battery Charger Vendor Manual: C & D
Technologies, Inc. Model ARR130HK50
2/01/1976
IB 6.1.2.7-1C
BBC Brown Boveri, Inc.; Installation/Maintenance
Instructions; I-T-E Low Voltage Power Circuit Breakers;
Type K-225 thru 2000 and K-600S thru 2000S
C
LER 2011-004
Flooding Calculation Deficiency Results in Unanalyzed
Condition
and 1
Maintenance Rule
System Basis
Document
System S99
MRN#5
C&D Technologies, Inc. Supplemental Data for KCR-7
Battery Cell
None
GE Safety Analysis Report for Perry PERFORM - Safety
System Parameter Relaxations
03/01/2002
GE Safety Analysis Evaluations Relative to Measurement
Uncertainties for the BWR/6 Improved Standard Technical
Specifications
2/01/2001
NORM-ER-3302
FENOC: I&C Relays
NORM-ER-3311
FENOC: I&C Loop Components
Guidelines and Technical Bases for NUMARC Initiatives
Addressing Station Blackout at Light Water Reactors
11/20/1987
OE-2017-0561
Operating Experience Evaluation: IN 1706, Battery and
Battery Charger Short-Circuit Current Contributions to a
Fault on the Direct Current Distribution System
05/31/2019
OE-2017-0561-1-
FA002
Review of NUREG/CR-7229, "Testing to Evaluate Battery
and Battery Charger Short-Circuit Contributions to a Fault
11/28/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
on the DC Distribution System."
OTCOMBINEDP45
Emergency Service Water (ESW) System
PHS-IST
Inservice Testing IST - Perry
2/02/2022
Procurement
Package - 1-19201
Pump Partial Assembly, ESW C
1, 2, and 3
PRS-3202
Emergency Service Water Partial Pump Assemble
Procurement Specification
Pump IST Bases
Pump IST Basis Report - 1P45-C002 ESW Pump C
Various
PY-1Z99
Perry Nuclear Pwr Plt Maintenance Plan Administrative
Inventory EOP Files, Ladders
05/04/2023
RS02098
C&D Technologies Standby Battery Rack Assembly
Instructions
0114/CD
SHR-E22A
System Health Report 2022-22 - System - E22B - High
Pressure Core Spray Components
2/28/2023
SHR-E22B
System Health Report 2022-2 - System - E22B - High
Pressure Core Spray Diesel Components
2/28/2023
SHR-R42
Perry System Health Report: R42 - DC Systems
07/28/2022
SOI-P45/P49
Emergency Service Water and Screen Wash Systems
SSC-001
Appendix R Evaluation: Safe Shutdown Capabilities Report
TAF 081854
Maintenance Rule Walkdown Confirmation of Personnel
Qualifications
05/28/2020
TD-6694
Time-Current Characteristic Curves For K-Line and K-Don
Circuit Breakers; ABB Power T&D Company Inc.
Distribution Systems Division
US-GN-RS-002
EnerSys PowerSafe GN Specification
2/01/2012
US-GNRACK-IM
EnerSys; Instructions for Assembling Class 1E Racks
04/01/2004
Valve IST Bases
Valve IST Basis Report - 1P45-F140 ESW Discharge Pump
Valve
Various
ARI-H13-P601-
0016
Div 3 Diesel Gen & HPCS
ARI-H13-P601-
0016-G4
HPCS ESW Disch Strainer Start Diff Press HI
Procedures
ELI-R42
Perry Operations Manual: Electrical Lineup Instruction: DC
Systems: Batteries Chargers Switchboards
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RPV Control
I
Primary Containment Control
G
SPMU Initiation
HPCS Injection
FTI-F0036
Post-Maintenance Test Manual
GEI-0029
Testing of Molded Case Circuit Breakers and Overload
Heater Relays
GEI-0046
Perry Operations Manual: Generic Electrical Instruction:
Division 3 125VDC Relays
GEI-0057-B
Division 3 Normal Battery Charger Maintenance,
Calibration, and Functional Testing
GMI-0040
Disassembly and Reassembly of Division 3 Emergency
Service Water Pump
GMI-0145
Sluice Gate Maintenance
NOBP-CC-7007
Part Interchangeability Evaluation
NOBP-ER-3003-02
System Walkdown Check List
NOBP-ER-3902
Component Template Development ER Workbench
Module 2
NOBP-OP-1113
Control of Time Sensitive Operator Actions
NOBP-SS-3202
Delegation of Authority
NOP-CC-1002
Drawing Control
NOP-CC-2003
Engineering Changes
NOP-CC-2004
Design Interface Reviews and Evaluations
and 12
NOP-CC-3002
Calculations
NOP-CC-7002
Procurement Engineering
NOP-ER-3203
Snubber Program
NOP-ER-3204
Inservice Testing Program
NOP-LP-2601
Procedure/Work Instruction Use and Adherence
NOP-LP-4003
Evaluation of Changes, Tests and Experiments
NOP-OP-1013
Control of Time Critical Operator Actions
NOP-OP-1015
Event Notifications
NORM-ER-3103
Low & Medium Voltage Switchgear and Motor Control
Centers
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OAI-0201
Operations General Instructions and Operating Practices
ONI-R10
Loss of AC Power
ONI-R10-2
Station Blackout (SBO)
F
ONI-R42-3
Loss of DC Bus ED-1-C
ONI-SPI C-7
Division 3 to Division 2 480 Volt Cross-Tie
ONI-SPI D-2
Nonessential DC Loads
ONI-SPI D-3
Cross-Tying Unit 1 and Unit 2 Batteries
ONI-SPI D-6
Containment Closure
PAP-1115
Snubber Visual Inservice Examination and Testing Program
PAP-1705
Diesel Generator Reports and Records
PDB-R0001
Operational Requirements Manual
PMI-0095
Division 3 Diesel Generator Electrical Maintenance
PRI-TSR
Technical Specification Rounds
PTI-P45-P0003
ESW System Loop C Flow and Differential Pressure Test
PTI-P54-P0041
Semiannual Fire Door Inspection
PYBP-POS-0029
Time Critical Operator Action Validation
PYRM-SITE-0007
Drawing Categories
SOI-E22A
HPCS System
SOI-E22B
Division 3 Diesel Generator
SOI-G41 (FPCC)
Fuel Pool Cooling and Cleanup System
SOI-M32
Emergency Service Water Pump House Ventilation System
and 9
SOI-M43
DG Building Ventilation System
SOI-P45/P49
Emergency Service Water and Screen Wash Systems
SOI-R42 (Div. 3)
Div 3 Distribution, Bus ED-1-C and ED-2-C: Batteries,
Chargers, and Switchgear
SOI-R44/E22B
Division 3 Diesel Generator Starting Air System
SOI-R45/E22B
Division 3 Diesel Generator Fuel Oil System
SOI-R46/E22B
Division 3 Diesel Generator Jacket Water System
SOI-R47/E22B
Division 3 Diesel Generator Lube Oil System
SVI-P45-T2003
HPCS ESW Pump and Valve Operability Test
SVI-R42-T5225
Unit 1, Div 1, Annual Battery Inspections (1R42-S002)
SVI-R42-T5227
Unit 1, Div 3, Annual Battery Inspections (1E22-S005)
TAI-0513
Monitoring the Effectiveness of Maintenance Structure
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Monitoring Program
200116472
Replace HVSD & Control Circuit Boards for Battery
Charger EFD-1-C
07/06/2006
200412355
HPCS-Diesel GEN CT & PT Cubicle Panel; Test Molded
Case Circuit Breakers
05/18/2012
200516722
Replace HVSD & Control Circuit Boards, Battery Charger
EFD-1-C
09/14/2017
200727509
Potentiometer Thread Locker Sealant Application and
Control Card Bracket Screw; Division 3 Battery Charger
09/18/2017
200727542
Battery Charger EFD-2-C; Remove Bracket Screw and
Wing Nut
09/12/2017
200730816
Unit 1 Division 3 Charger (EFD-1-C) Load Test
08/12/2019
200739647
PTI-M39P0002 HPCS Pump Room Cooler Performance
Testing
2/15/2021
200770452
PY-S99 Miscellaneous and Structures
07/16/2020
200792978
ESW System Loop C Flow and Differential Pressure Test
10/07/2021
200798895
Unit 1 Division 3 Charger (EFD-1-C) Load Test
08/06/2021
200807328
HPCS ESW Pump and Valve Operability Test
SVI-P45-T2003
07/05/2022
200807329
HPCS ESW Pump and Valve Operability Test
SVI-P45-T2003
10/04/2022
200807330
HPCS ESW Pump and Valve Operability Test
SVI-P45-T2003
01/03/2023
200807424
1P45-C002 Pump Inspect/Tighten Packing
01/04/2023
200807704
SVI-E22T1319 HPCS D/G Start and Load
10/04/2022
200807708
SVI-E22T1319 HPCS D/G Start and Load
01/31/2023
200807710
SVI-E22T1319 HPCS D/G Start and Load
04/13/2023
200813753
Semiannual Fire Door Inspection
07/26/2022
200823783
(6M) Semiannual Fire Door Inspection
2/10/2023
Work Orders
200882815
1P45-C002 Pump Rebaseline
07/04/2022