IR 05000440/2024011

Fire Protection Team Inspection Report 05000440/2024011

ML24169A393
Person / Time
Site:	Perry
Issue date:	06/17/2024
From:	Jasmine Gilliam NRC/RGN-III/DORS/EB2
To:	Penfield R Vistra Operations Company
References
IR 2024011
Download: ML24169A393 (1)

Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - FIRE PROTECTION TEAM INSPECTION REPORT 05000440/2024011

Dear Rod Penfield:

On May 9, 2024, 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.

One finding of very-low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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 17, 2024 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, Jasmine A. Gilliam, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440

License Number: NPF-58

Report Number: 05000440/2024011

Licensee: Vistra Operations Company, LLC

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Inspection Dates: April 22, 2024 to May 09, 2024

Inspectors: M. Abuhamdan, Reactor Inspector M. Domke, Senior Reactor Inspector A. Shaikh, Senior Reactor Inspector

Approved By: Jasmine A. Gilliam, Chief Engineering Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection 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 Maintain Fire Protection Suppression System Functional Test Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.

Systems NCV 05000440/2024011-01 05 Open/Closed The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4.1, Procedures, for the licensees failure to maintain fire protection system functional test procedure. Specifically, the licensee failed to maintain Procedures PTI-P54-P0036 and PTI-P54-P0036A, Diesel and Motor Driven Fire Pump Flow Data and Control Panel Functional Test, by failing to include appropriate acceptance criteria that accounted for piping degradation since installation in the procedure to demonstrate fire protection system functionality.

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

===71111.21N.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1)

• Diesel/Electric Fire Pumps and Suppression System Hydraulics (2)

• Fire Zone 1RB-1C (3)

• Remote/Alternate Shutdown Panel

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

(1)

• Combustible Control Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (3 Samples)

(1)

• 601360567 Downgrade Penetration 2VRB-7001 (2)

• P54-024 Update Combustible-Loading Calculation for Fire Area DG-1 (3)

• 22-1047-001 Fire Protection Declassification

INSPECTION RESULTS

Failure to Maintain Fire Protection Suppression System Functional Test Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.0 Systems NCV 05000440/2024011-01 5 Open/Closed The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4.1, Procedures, for the licensees failure to maintain fire protection system functional test procedure. Specifically, the licensee failed to maintain Procedures PTI-P54-P0036 and PTI-P54-P0036A, Diesel and Motor Driven Fire Pump Flow Data and Control Panel Functional Test, by failing to include appropriate acceptance criteria that accounted for piping degradation since installation in the procedure to demonstrate fire protection system functionality.

Description:

During review of the work orders for last performed fire pump and fire water flow tests, the inspectors identified that the acceptance criteria in the procedure associated with the fire pump test relied on historic data and assumptions. Specifically, Procedures PTI-P54-P0036 and PTI-P54-P0036A, Diesel and Motor Driven Fire Pump Flow Data and Control Panel Functional Test, which were performed to ensure the functionality of the fire protection system pumps contained acceptance criteria in procedure Section 5.6 that assumed original plant conditions. Section 5.6, Acceptance Criteria, states, in part, that acceptance of functionality is by verification that the fire pumps are capable of supplying fire water to meet the largest plant system demands indicated by performance above the design demand curve.

Footnote 7 on the plotted performance curve states that the design demand curve data points are obtained from Calculation P54-124, Fire Protection Suppression System Water Supply Calculation. In order to obtain a suppression demand data point (pump flow at specific required discharge pressure) for a particular fire area, the total frictional losses incurred along sections of piping delivering the fire water from the discharge of the fire pump up to the suppression load sprinkler heads must be calculated and subtracted from the pumps discharge pressure. The methodology for calculating total frictional losses over the length of piping is described in National Fire Protection Association (NFPA) 13, Standard of Installation of Sprinkler Systems and uses an equation (Williams-Hazen) that contains a piping roughness factor also known as the coefficient of friction or C-factor. The inspectors determined that in calculation P54-124, the licensee had assumed the coefficient of friction values (C-factors) as described in NFPA 13 for all the suppression system demand points and these C-factors assume nominal pipe with some degradation equivalent to a few years of service. However, the inspectors noted that although the C-factor would further degrade over time, the licensee had not changed or adjusted the C-factors over nearly 40 years of operation since installation from the values specified in the installation standard NFPA 13 and used in the calculation P54-124. The inspectors questioned the validity of the licensees assumption that no further degradation has occurred over nearly 40 years since installation. If the C-factor assumed further degradation of piping since installation then the calculated frictional losses would increase along the piping from the pumps discharge up to the suppression load point and hence, the suppression demand points for each fire area would increase since the pump would now have to overcome those frictional pressure losses from its discharge up to the suppression load point. Therefore, the plotted pump curves as determined from procedures PTI-P54-0036 and PTI-P54-0036A could inadvertently lie below the re-calculated suppression demand points and potentially adversely impact the functionality of the fire pumps to deliver required flow and pressure to the most limiting suppression loads on site. Based on the information currently plotted in the most recently performed fire pump functionality tests, the inspectors could not reasonably determine the effect that increased piping degradation C-factors would have on the margins between the re-calculated demand points and the fire pumps performance.

Corrective Actions: The licensee entered the inspectors concern into its corrective action program (CAP) and intends to implement corrective actions that included performing a detailed fire protection suppression system hydraulic calculation to determine system margins and limits. The licensee also intends to revise procedures PTI-P54-P0036 and PTI-P54-0036A to include appropriate acceptance criteria as determined from the re-performance of its fire protection suppression system water supply calculation.

Corrective Action References: CR 2024-04200 - 2024 NRC Fire Protection Inspection - Inadequate Acceptance Criteria for Fire Protection Flow Testing

Performance Assessment:

Performance Deficiency: The Inspectors determined that the licensees failure to maintain fire suppression system functional test procedures PTI-P54-P0036(A) by not including appropriate acceptance criteria that accounted for piping degradation since installation was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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. The inspectors determined the performance deficiency was more than minor, and therefore, a finding, because it was associated with the Procedure Quality 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 maintain procedures PTI-P54-P0036 by not including appropriate acceptance criteria that accounted for piping degradation since installation, resulted in a deficient procedure that could have resulted in the acceptance of degraded fire pump performance and subsequently, adversely impacted the functionality of the fire protection suppression system.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors screened the finding using IMC 0609, Appendix F, 1, Part 1: Fire Protection SDP Phase 1 Worksheet, dated May 02, 2018. The inspectors answered YES to Step 1.3 - Does the fire finding have a low degradation rating?

Therefore, the inspectors determined that the finding screened 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: Technical Specification Section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 8 addresses Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures, and Calibrations, and Subsection b.2 addresses boiling-water reactor specific procedures for surveillances tests, inspections, and calibrations. Item

(h) under Subsection b.2 addresses Fire Protection System Functional Tests. The licensee established Procedures PTI-P54-P0036 and PTI-P54-P0036A, Diesel and Motor Driven Fire Pump Flow Data and Control Panel Functional Test, to address functionality of the fire protection system pumps and incorporated acceptance criteria in the procedure reflective of the material condition of the piping during installation. Specifically, Procedures PTI-P54-P0036(A), Section 5.6, Acceptance Criteria, states, in part, that acceptance of functionality is by verification that the fire pumps are capable of supplying fire water to meet the largest plant system demands indicated by performance above the design demand curve. Footnote 7 on the plotted performance curve states that the design demand curve data points are obtained from Calculation P54-124, which assumed coefficient of friction values for new piping installation in accordance with National Fire Protection Association (NFPA)13, Standard for the Installation of Sprinkler Systems, requirements.

Contrary to the above, since January 1986 and July 2004, the licensee failed to maintain a written procedure covering Fire Protection System Functional Tests by not including appropriate acceptance criteria that accounted for piping degradation since installation. Specifically, the site failed to maintain Procedures PTI-P54-P0036 and PTI-P54-P0036A with appropriate acceptance criteria obtained from Calculation P54-124 because the calculation did not take into consideration aging degradation over the sites years of operation. Therefore, Procedures PTI-P54-P0036 and PTI-P54-P0036A could not reasonably verify functionality of the fire protection system pumps to deliver the required flow and pressure to the most limiting fire suppression loads at the site.

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 9, 2024, the inspectors presented the fire protection team inspection results to Rod Penfield, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Calculations P54-024 Calculation of Combustible Loading and Allowable Limits Rev. 07

for Fire Loading

P54-124 Fire Protection Suppression System Water Supply 06/27/2017

Calculation

P54-211 Unit 2 Fire Hazards Analysis for Impact on Unit 1 0

SSC-001 Appendix R Evaluation: Safe Shutdown Capabilities Rev. 5

Report

Corrective Action CR-2019-04451 ERO Drill 5/15/19 - EPI-A06 (Technical Support Center 05/16/2019

Documents Activation) Procedural Requirements for TSC

Administrative Assistant Position were Not Followed

CR-2020-01070 2020 Pre-DBAI Assessment: Improper Removal of Time 02/11/2020

Critical Operator Action Classification

CR-2020-01071 2020 Pre-DBAI Assessment: TCOA Document 02/11/2020

PYBP-POS-0029s Business Practice Classification is a

Vulnerability

CR-2020-05789 Required Procedure Change to ONI-R10-2 for Time 07/18/2020

Critical Operator Actions

CR-2020-07400 Need to Update EOP-01 for the DBA LOCA Actions for 09/23/2020

Feed Water Leakage Control and MSIV Leakage Control

to Make Them STEPS Vice NOTES on the EOP-01 Flow

Chart

CR-2020-08556 2020 DBAI Inspection - NRC Question on 12/04/2020

PVBP-POS-0029 TCOA Requirements for Suppression

Pool Cooling

CR-2021-04774 Housekeeping Issues Identified during Fire Protection 05/31/2021

Audit

CR-2021-04781 MS-C-21-05-31: Excessive Corrosion Present on Piping 06/18/2021

in Vicinity of the 0P54F3552 Valve

CR-2023-05803 NEIL Inspection Walkdown Identified Issues 07/25/2023

CR-2023-05822 NEIL Inspection Walkdown Identified IB 620 Issue 07/25/2023

CR-2023-05826 NEIL Inspection Walkdown Warehouse Identified Issues 07/26/2023

CR-2024-03458 Fire Penetrations PIB3102 & EIB3014 Found Damaged 04/19/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action 2024-04200 2024 NRC FPTI - Inadequate Acceptance Criteria for Fire 05/09/2024

Documents Protection Flow Testing

Resulting from

Inspection

Drawings 101-0035-00000 Intermediate Building Floor Plan Elevation K

665'-0" 682'-6" 707"-6"

E-023-004 Perry Nuclear Power Plant Unit 2 Fire Protection E

Evaluation Auxiliary and Reactor Building Plan Elevation

574'-10"

Engineering 14-0690-000 Drawing Update Notices (DUNs) for ECP 14-0690 - Perry 10/26/2015

Changes License Renewal Unit 2 Fire Hazards Analysis Doc Only

Design Change

15-0028 Drawing Update Notices (DUNs) for 10/20/2015

ECP 15-0028 FHAR Replacement of IB-304 Roll-Up

Door and Installation of lB-226 Fire Door

2-1047-001 Fire Penetration Declassification 0

Engineering 601360567 Downgrade Penetration 2VRB-7001 on Drawing 05/24/2022

Evaluations 199-0001

Miscellaneous Current Fire Protection Daily Status Report 02/15/2024

Impairments/Permits

Report

Procedures FPI-1RB Pre-Fire Plan Instruction/ Reactor Building Rev. 05

FPI-A-C01 Fire Protection Program Control Processes (Hot Work Rev.16

Permits, Transient Combustible Permits, Impairment

Permits, and Fire Watches)

IOI-0011 Shutdown from Outside Control Room Rev. 41

NOP-LP-2001 Corrective Action Program Rev. 50

ONI-P54 Fire Rev. 28

PAP-1910 Fire Protection Program/ Plant Administrative Procedure Rev. 45

PAP-1910 Fire Protection Program Rev. 45

PTI-P54-P0056 Penetration Seal Visual Inspection 11

PTI-P54-P0068 RX Recirculation Pumps CO2 Systems 7

Detection/Operability Test

SOI-C61 Remote Shutdown System 11

Inspection Type Designation Description or Title Revision or

Procedure Date

SSC-001 Safe Shutdown Capability Report 5

Work Orders 200689395 SVI-C61 T1200 1 (24M) Remote Shutdown Control 07/27/2018

Test -RCIC and RHR

200700360 SVI-C61 T1202 1 (24M) Remote Shutdown Control 11/16/2018

Test -Division 2 RHR, ECC, and ESW

200743154 SVI-C61 T1201 1 RSD Test RHRA, ESWA, ECCA (24M) 03/26/2020

Remote Shutdown Panel 1C61-P001 Control Operability

Test RHR A, ESW A and ECC A

200761516 SVI-C61 T1200 RSD Control Test - RCIC/RHR (24) 07/20/2020

Remote Shutdown Control Test - RCIC and RHR

200763437 SVI-C61 T1202 1 (24M) Remote Shutdown Control 10/28/2020

Test - Division 2 RHR, ECC, and ESW

200806338 SVI-C61 T1202 1RSD D2 RHR, ECC, ESW (24M) 10/27/2022

Remote Shutdown Control Test - Division 2 RHR, ECC,

and ESW

200813232 Motor Driven Fire Pump Flow Data and Control Panel 08/02/2021

Functional Test

200819610 SVI-C61 T1201 (24M) RSD RHR A, ESW A, ECC A 04/21/2022

(24M) Remote Shutdown Panel 1C61-P001 Control

Operability Test RHR A, ESW A, and ECC A

200837626 Diesel Fire Pump Flow Data and Control Panel Functional 11/09/2021

Test

200837761 SVI-C61T1200 RSD RCIC/RHR (24M) Remote Shutdown 07/21/2022

Control Test -RCIC and RHR

200864356 Motor Driven Fire Pump Flow Data and Control Panel 05/05/2023

Functional Test

200872498 Diesel Fire Pump Flow Data and Control Panel Functional 05/05/2023

Test

9