IR 05000440/2018003

NRC Integrated Inspection Report 05000440/2018003

ML18313A054
Person / Time
Site:	Perry
Issue date:	11/08/2018
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2018003
Download: ML18313A054 (20)

Text

ber 8, 2018

SUBJECT:

PERRY NUCLEAR POWER PLANTNRC INTEGRATED INSPECTION REPORT 05000440/2018003

Dear Mr. Hamilton:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline inspection at your Perry Nuclear Power Plant. On October 9, 2018, the NRC inspectors 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.

Based on the results of this inspection, no findings or violations were identified.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Billy Dickson, Chief Branch 2 Division of Reactor Projects Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2018003

REGION III==

Docket No: 50-440 License No: NPF-58 Report No: 05000440/2018003 Enterprise Identifier: I-2018-003-0019 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant Location: North Perry, Ohio Dates: July 1 through September 30, 2018 Inspectors: J. Steffes, Senior Resident Inspector J. Nance, Resident Inspector N. Peterka, Acting Resident Inspector R. Ng, Project Engineer T. Briley, Fermi Senior Resident Inspector M. Holmberg, Senior Reactor Inspector J. Park, Reactor Inspector Approved by: B. Dickson, Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting an integrated quarterly inspection at Perry Nuclear Power Plant, Unit 1, 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. Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations No findings or violations were identified.

Additional Tracking Items Type Issue Number Title Report Status Section URI 05000440/2018003-01 Application of ASME Code IP 71152 Open Case N-513-3 for the Emergency Service Water Piping Degradations URI 05000440/2016008-01 Coincidence Logic to IP 71153 Closed Preclude Spurious Trips of the Offsite Power Source

TABLE OF CONTENTS

PLANT STATUS

INSPECTION SCOPES

............................................................................................................

REACTOR SAFETY

.................................................................................................................

OTHER ACTIVITIES - BASELINE

...........................................................................................

INSPECTION RESULTS

..............................................................................................................

EXIT MEETINGS AND DEBRIEFS

............................................................................................ 14

DOCUMENTS REVIEWED

......................................................................................................... 14

PLANT STATUS

The plant began the inspection period at rated thermal power. On August 25, 2018, reactor

power was lowered to 60 percent to perform a rod sequence exchange. The unit was returned

to rated thermal power on August 26, 2018. On September 15, 2018, reactor power was

lowered to 79 percent to perform a load line adjustment. The unit was returned to rated thermal

power on September 15, 2018. The unit remained at, or near, rated thermal power for the

remainder of the inspection period with the exception that on several occasions, power was

reduced to maintain condensate demineralizer outlet temperature and/or high condenser

circulating water outlet temperatures at or below their respective upper limits due to

environmental conditions. The power reductions varied between 1 and 14 percent of rated

thermal power and lasted from a few hours to several days.

On March 28, 2018, FirstEnergy Solutions (FES)/ FirstEnergy Nuclear Operating Company

(FENOC) verbally notified the NRC that they intended to shut down all four of their operating

nuclear power units. Perry Nuclear Power Plant, Unit 1, is scheduled to be shut down

May 31, 2021. On March 31, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and

FENOC filed for bankruptcy. The NRC continues to maintain focus on public health and safety

and the protection of the environment. This will include a continuous evaluation by inspectors to

determine whether the licensees financial condition is impacting safe operation of the plant.

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 performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Division 1 diesel generator on August 15, 2018;

(2) Motor control center, switchgear, and miscellaneous electrical equipment area heating,

ventilation and air conditioning system train A on September 27, 2018; and

(3) Annulus exhaust gas treatment system train A on September 28, 2018.

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the

emergency closed cooling system on July 2 through 11, 2018.

71111.05AQFire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Service building 604 and 620 foot elevations on July 19 through 20, 2018;

(2) Auxiliary building 599 foot elevation, fire zone 1AB-2 on September 20, 2018;

(3) Intermediate building 620 foot elevation fire zones 0IB-3; FHB 620-3 on

August 18, 2018;

(4) Control complex and diesel building fire zones 1DG-1c and 1CC-3c on

August 15, 2018; and

(5) Emergency service water (ESW) pump house on August 8 through 9, 2018.

71111.06Flood Protection Measures

Internal Flooding (2 Samples)

(1) The inspectors evaluated internal flooding mitigation protections in the control complex

on August 17 through 29, 2018; and

(2) The inspectors evaluated internal flooding mitigation protections in the intermediate

building on August 28 through 30, 2018.

Cables (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Review of safety-related cables in manholes 1, 2, 3 and 4 on August 6 and 7, 2018.

71111.07Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated B residual heat removal (RHR) heat exchanger performance on

September 10 through 13, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated an operations crew-evaluated scenario in the plant

training simulator on September 17, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operations crew performance during plant

manipulations for rod sequence exchange on August 25, 2018.

71111.12Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Average power range monitor system on August 21, 2018.

71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Work week risk assessment to include diving activities, reactor core isolation cooling

(RCIC) system inoperability due to surveillance, severe weather and increase in A

essential service water system leakage on July 25 through 27, 2018;

(2) Emergent work on the B ESW pump due to an oil leak August 15 through 16; and

(3) Emergent work on the Division 1 diesel generator on September 26 through 30, 2018.

71111.15Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) 'B' ESW motor oil leak operability determination on August 6 and 7, 2018;

(2) High pressure core spray ESW piping and elbow wall thinning downstream of the HPCS

diesel heat exchanger ESW outlet valve on July 10 through 11, 2018;

(3) Low pressure core spray, RHR A and containment isolation valves operability

determination due to failed fuse in Division 1 loss of coolant accident actuation circuitry;

and

(4) RCIC suppression pool suction isolation valve failed to open during surveillance.

71111.18Plant Modifications (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary flooding barriers on August 22, 2018.

71111.19Post Maintenance Testing (3 Samples)

The inspectors evaluated the following post maintenance tests:

(1) High pressure core spray operability test following system maintenance on

September 13, 2018;

(2) A ESW operational test following a piping through wall leak repair on

September 5, 2018; and

(3) B standby liquid control pump and valve operability test following pump internal and

coupling inspections on August 3, 2018.

71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) SVI-C11-T1006: Control rod maximum scram insertion time testing on August 25, 2018;

(2) C RHR pump and valve operability test on August 1 through 2, 2018; and

(3) Remote shutdown control test - RCIC and RHR routine surveillance testing on

July 25 through 26, 2018.

In-Service (1 Sample)

(1) RCIC pump and valve surveillance testing on July 24, 2018.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) MS08: Heat Removal Systems - 1 Sample (July 1, 2017-June 30, 2018);

(2) MS09: Residual Heat Removal Systems - 1 Sample (July 1, 2017-June 30, 2018); and

(3) MS10: Cooling Water Support Systems - 1 Sample (July 1, 2017-June 30, 2018).

71152Problem Identification and Resolution

Semiannual Trend Review (1 Sample)

The inspectors reviewed the licensees corrective action program for trends that might be

indicative of a more significant safety issue.

Annual Follow-Up of Selected Issues (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Condition Report (CR) 2018-05504, Emergency Service Water (ESW) A Through-Wall

Pipe Leak at RHR A HX Outlet Piping, Aux 574 E, was initiated by the licensee to

document an approximately 0.1 gallon-per-minute through-wall leakage on the 20 ESW

piping. The inspectors selected this CR for annual review because this was the third

through-wall leakage that occurred in their ESW piping system over the past 12 months.

The licensee invoked the requirements of ASME Code Case N-513-3, Evaluation

Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,

Section XI, Division 1, to evaluate and temporarily accept the flaw without

repair/replacement for a limited period;

(2) CR 2018-06205, Emergency Service Water Pipe Exceeded Minimum Wall Thickness -

Localized Wall Thinning, was initiated by the licensee. This condition report

documented that, from the inspection of five additional locations as required by

Section 5(a) of Code Case N-513-3 due to the condition described in (1) above, a

localized wall thinning was identified on the 8 ESW pipe elbow, which was found not

meeting the minimum wall thickness requirement;

(3) CR 2018-05153, Division 2 DG Fuel Oil Storage Tank Level Indicator 1R45-R0191B

Appears to be Failing, and CR 2018-06869, Water Found in Access Space for Div 2

Diesel Generator Level Transmitter, were selected for annual review because the

instrument provides control room indication of Division 2 diesel generator fuel oil storage

tank level which is checked weekly to ensure the amount of fuel oil stored meets the

required amount for the diesel generator to perform its safety-related function.

As appropriate, the inspectors verified the following attributes during their review of the

licensees corrective actions for the above CRs and other related CRs:

• Complete and accurate identification of the problem in a timely manner

commensurate with its safety significance and ease of discovery;

• Consideration of the extent of condition, generic implications, common cause, and

previous occurrences;

• Evaluation and disposition of operability/functionality/reportability issues;

• Classification and prioritization of the resolution of the problem commensurate with

safety significance;

• Identification of the root and contributing causes of the problem;

• Identification of corrective actions, which were appropriately focused to correct the

problem;

• Completion of corrective actions in a timely manner commensurate with the safety

significance of the issue;

• Effectiveness of corrective actions taken to preclude repetition; and

• Evaluate applicability for operating experience and communicate applicable lessons

learned to appropriate organizations.

The inspectors discussed the corrective actions and associated evaluations with

licensee personnel.

71153Follow-Up of Events and Notice of Enforcement Discretion

The inspectors also reviewed the status of URI 05000440/2016008-01. This did not constitute

an inspection sample.

INSPECTION RESULTS

No findings or violations were identified.

71152Problem Identification and Resolution

Observation IP 71152 - Semi

Annual Trend

Review

During the inspection period the licensee noted an adverse trend in housekeeping. The

licensee documented the observed trend in CR 2018-03308, PA-PY-18-02: Housekeeping

Elevation Letter, and CR 2018-03269, Commitment and Accountability to the Perry

Housekeeping Program Needs to be Strengthened Across the Site. The licensee developed

actions associated with the housekeeping trend to include, but not limited to, site wide

communications, paired observations, and supervisor training. The inspectors monitored

licensee progress to address the issue.

After a couple of months and further evaluation, the licensee determined that the continued

issues with housekeeping was due to a lack of understanding and compliance with the site

configuration management process. The inspectors assessed that the licensees evaluation

and identification that configuration management contributed to the housekeeping issues was

appropriate as they had independently identified a trend in procedure use and adherence.

The NRC identified examples associated with procedure use and adherence include, but were

not limited to:

• On July 24, 2018, the licensee failed to follow the Precaution and Limitation section in

surveillance procedure SVI-E51-T2001, RCIC Pump and Valve Operability Test,

after the required response was not obtained for the stroke of the RCIC suppression

pool suction valve until questioned by the inspectors. (CR 2018-06615 and CR 2018-

06788);

• On July 25, 2018, during a pre-job brief, the licensee stated that they intended to

perform all sections of surveillance SVI-C61-T1200, Remote Shutdown Control

Test - RCIC and RHR, in parallel. The inspectors questioned the staff, and the

licensee explained that the notes contained within the procedure were interpreted such

that all sections could be performed in parallel. The notes being referenced stated

that, Sections 5.1.2 through 5.1.8 may be performed in any order. Steps within each

individual section must be performed in order, unless otherwise specified, and Steps

5.1.2.2 through 5.1.2.6 may be performed in any order or in parallel.

Additional examples identified by the licensee or were self-revealed and documented in the

corrective action program include, but were not limited to:

• On May 12, 2018, a non-licensed operator did not exit the radiologically controlled

area when required by radiation work permit and received an electronic dosimetry

dose alarm (CR 2018-04447);

• On September 12, 2018, a contract worker did not exit the radiologically controlled

area when required by the radiation work permit and received an electronic dosimetry

dose alarm (CR 2018-08066 and CR 2018-08068);

• On August 2, 2018, an employee opened a protected area portal without security

present contrary to site procedures (CR 2018-06886).

Although the issues reviewed by the inspectors individually did not result in any significant

consequences or violations, the examples represent a larger trend in individual contributor

behaviors which requires further scrutiny. The licensee documented the inspectors concerns

and licensee observations in CR 2018-08694. A causal evaluation was ongoing at the end of

the inspection period.

Observation IP 71152 - Annual

Sample Review

Division 2 Diesel Generator Fuel Oil Storage Tank Level Indicator Failing

The inspectors performed a selected review of the licensees correction action program

documents; specifically, CR 2018-05153, Division 2 DG Fuel Oil Storage Tank Level

Indicator 1R45-R0191B Appears to be Failing, and CR 2018-06869, Water Found in

Access Space for Div 2 Diesel Generator Level Transmitter. The inspectors performed

walkdowns and assessed the adequacy of the corrective actions taken in response to the

failed level transmitter for the Division 2 diesel generator fuel oil storage tank.

This level transmitter provides remote indication of the fuel oil level in the main control

room. Annunciator alarms are provided when levels are less than 17 percent and

80percent. Tank level can also be monitored by direct measurement with a dip stick. This

method of measurement has been proceduralized, equipment was staged and can be used to

satisfy Technical Specification requirement of verifying fuel oil level.

Although there is no preventative maintenance associated with the level transmitter other

than a calibration of the channel every nine years, the inspectors noted that the level

instrumentation is not safety related and is not needed for the emergency operation

procedures.

The inspectors reviewed the maintenance history of the transmitter and did not identify any

recent failures. The licensee removed the water, replaced the failed transmitter, and sealant

was applied to the seams of the cover to prevent future water intrusion. Given the safety

significance of the issue, the inspectors determined that the licensees actions were

appropriate.

Unresolved Item Application of ASME Code Case N-513-3 for the IP 71152 -

(Open) Emergency Service Water (ESW) Piping Annual Sample

Degradations05000440/2018003-01 Review

Description:

The inspectors identified an Unresolved Item concerning the Title 10 of the Code of Federal

Regulations (10 CFR), Part 50, Appendix B, and ASME Code requirements for the ESW

piping systems with regards to the licensees application of ASME Code Case N-513-3,

Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3

Piping,Section XI, Division 1.

Updated Safety Analysis Report (USAR) Section 9.2.1 describes that the function of ESW

system is to provide a reliable source of water to safety-related components required for

normal and emergency reactor operation. USAR Table 3.2-1, Equipment Classification,

delineates that the ESW piping system is safety-related and designed in accordance with the

requirements of ASME Section III, Subsection ND (Class 3). The regulation in 10 CFR 50.55a(g) requires, in part, that Class 3 components and their supports meet the requirements

of ASME Section XI of the ASME Boiler and Pressure Vessel (BPV) Code or equivalent

quality standards. The ASME also publishes Code Cases, which provide alternatives to

existing Code requirements. The NRC Regulatory Guide (RG) 1.147 identifies that Code

Case N-513-3 provides acceptable alternatives to applicable parts of Section XI, provided it

is used with any identified conditions or limitations.

Code Case N-513-3, Section 2(d) requires that a flaw evaluation shall be performed to

determine the conditions for flaw acceptance. Section 3 provides accepted methods for

conducting the required analysis. In addition, Section 3 requires, in part, that nonplanar

flaws shall be evaluated in accordance with the requirements in 3.2. Additionally, Section 5

requires that an augmented volumetric examination or physical measurement to assess

degradation of the affected system shall be performed as follows: (a) From an engineering

evaluation, the most susceptible locations shall be identified. A sample size of at least five of

the most susceptible and accessible locations, or, if fewer than five, all susceptible and

accessible locations shall be examined within 30 days of detecting the flaw. (b) When a flaw

is detected, an additional sample of the same size as defined in 5(a) shall be examined. (c)

This process shall be repeated within 15 days for each successive sample, until no significant

flaw is detected or until 100 percent of susceptible and accessible locations have been

examined.

On June 13, 2018, a through-wall leakage on the 20 ESW piping was identified in

CR 2018-05504. As a result, the licensee invoked the Code Case to evaluate this flaw and

permit the degraded ESW piping system to remain in service for a limited period without

repair/replacement. The licensees evaluation involved characterization of this flaw as

nonplanar, and subsequently, the methodology as described in Section 3.2 of the Code Case

was utilized for this nonplanar flaw. Additionally, the licensee identified the five most

susceptible and accessible locations in the ESW system and performed examination in

accordance with Section 5(a).

From the examination of the five additional locations, another localized wall degradation was

identified on the 8 ESW pipe elbow on July 10, 2018. The licensee initiated CR 2018-06205

to document this condition. The licensee characterized this degradation also as a nonplanar

flaw, and this degradation represented approximately 80 percent wall loss from its nominal

thickness. During the review of the licensee evaluation of this degraded pipe elbow, the

inspectors identified that the methodology as described in Section 3.2 of the Code Case had

not been utilized. Instead, the licensee elected to use an alternate methodology to evaluate

and disposition for its acceptability. Furthermore, the inspectors identified that the licensee

essentially redefined the term flaw in the Code Case to reflect the ASME Section XI,

IWA-9000 definition of the term defect. The ASME Section XI, IWA-9000 defines a flaw

as an imperfection or unintentional discontinuity that is detectable by nondestructive

examination. It also defines a defect as a flaw (imperfection or unintentional discontinuity)

of such size, shape, orientation, location, or properties as to be rejectable. With respect to

the Code Case, the licensee essentially restricted the criteria for examination scope

expansion only to the flaws that were rejectable; therefore, the licensee had not expanded the

scope to perform examination of additional locations in accordance with Section 5(b).

In essence, two items are to be further evaluated and addressed: (1) whether the use of

methodology not described in the Code Case Section 3.2 was appropriate for evaluation of

the nonplanar flaw on the 8 ESW pipe elbow, and (2) whether the stopping of scope

expansion for examination as required by the Code Case Section 5(b) was appropriate based

on the licensees redefining of the term flaw.

In response to the inspectors concern, the licensee initiated CR 2018-08483, NRC ID: Code

Case N-513-3 Interpretation, September 26, 2018. The licensee also plans to perform

examination of five additional locations in November of 2018.

This represents an item where the inspectors identified Code interpretation issues that

resulted in a disagreement with the licensee. This will require additional review to determine

whether a violation exists. Therefore, this issue is considered an unresolved item pending

completion of inspector review and evaluation and discussion with the Office of Nuclear

Reactor Regulation.

Licensee Action: The licensee plans to perform examination of five additional locations in

November of 2018.

Corrective Action Reference: CR 2018-08483

71153Follow-Up of Events and Notice of Enforcement Discretion

Unresolved Item Coincidence Logic to Preclude Spurious Trips of the IP 71153 -

(Closed) Offsite Power Source Follow-Up of

05000440/2016008-01 Events and

Notice of

Enforcement

Discretion

Description:

On March 28, 2016, Region Ill staff completed a reactive inspection at PNPP (ADAMS

Accession No. ML16147A437). During the inspection, the Special Inspection Team identified

a concern involving the adequacy of the Perry Nuclear Power Plant (PNPP) under voltage

(UV) relay protection design and licensing bases, which was documented in the NRC SIT

Report as Unresolved Item (URI)05000440/2016008-01, Coincidence Logic to Preclude

Spurious Trips of the Offsite Power Source. The reactive inspection was conducted, in part,

to evaluate the circumstances where a blown fuse in the UV-sensing circuitry resulted in the

loss of the offsite power to a safety bus and precluded the EDG from successfully performing

its safety function.

On February 11, 2016, while the plant was shut down, a fuse failure in a bus voltage detection

scheme resulted in the actuation of associated under voltage relays and a trip of the safety

related EH11 bus. With the under voltage condition locked in, the Division 1 safety-related

equipment remained unavailable when the Division 1 EDG started and powered up the EH11

bus. As a consequence of the under voltage scheme, the ESW pump for the EDG was not

available to provide cooling water and the EDG was manually shut down by operators to

prevent damage to the diesel engine.

During initial licensing, the NRC staff outlined that the purpose of the UV relays is to protect

Class 1E safety related buses from sustained degraded voltage (DV) or loss of offsite power

conditions and explicitly delineated the specific design requirements to satisfy license

condition for PNP

P. This guidance was subsequently documented in NUREG-0800, Branch

Technical Position (BTP) PSB 1, Adequacy of Station Electric Distribution System Voltages,

Revision 0, dated July 1981 (ADAMS Accession No. ML052350520). The BTP PSB 1

references events at Millstone Power Station and Arkansas Nuclear One that led to the NRC

staff establishing the position. The conformance of PNPP with BTP PSB-1 is documented in

Item a.2 of PNPP USAR Section 8.3.1.1.2.9, Electric Circuit Protection System Network,

(ADAMS Accession No. ML17305A203) which states, in part:

Two levels of undervoltage protection, Degraded Voltage and Loss of Power, are provided

on each Class 1E 4160V bus to conform to the requirements of the NRC Branch Technical

Position PSB 1.

The licensees installed design utilizes a single voltage sensor that is shared between two

relays in the under voltage trip logic. As a consequence of a shared voltage sensor between

both under voltage relays, the overall under voltage protection did not constitute a coincidence

logic as stated in BTP PSB-1. A single malfunction in the voltage sensing circuit resulted in a

trip of the offsite power source and precluded the onsite power source from performing its

safety related functions. As evidence by the February 11, 2016, event, a secondary potential

transformer fuse failure caused the EH11 bus to separate from offsite power (even though

there were no deficiencies in offsite power voltage) and resulted in shutdown of the Division 1

EDG bus due to ESW being unavailable. The inspectors believe that this design is deficient in

that there is no coincident logic to ensure that spurious trips are precluded as delineated in

BTP PSB-1 Section B.1.c.

By memorandum dated August 5, 2016 (ADAMS Accession No. ML16218A474), the NRC

Region III, Division of Reactor Projects, requested assistance from the NRC Office of Nuclear

Reactor Regulation (NRR) to conduct a technical assessment of the licensing basis of the

Perry Nuclear Power Plant, Unit No. 1 (PNPP) undervoltage relay protection scheme, and

to determine whether the methodology used in the PNPP offsite/station electric power

system design meets NRC requirements. By memorandum dated December 20, 2016

(ADAMS Accession No. ML16355A444), RIII revised its request to supersede that provided

on August 5, 2016. Specifically, in Task Interface Agreement (TIA) 2016-01, dated

December 20, 2016, RIII focused its question on compliance with the current licensing basis,

as opposed to compliance with NRC requirements. To assist in determining whether PNPP

offsite/station electric power system design was in compliance with the licensee current

licensing basis the staff review information contained in NRC issued Safety Evaluation

Report (SER) and in the supplemental Safety Evaluation Reports (SSER).

The NRC Office of Nuclear Reactor Regulation response to the TIA concluded that the plant

was in compliance with its current licensing basis (ADAMS Accession No. ML17023A191).

The staff noted that a review of the SSER and correspondence related to Confirmatory Item

No. 34 on the undervoltage protection scheme indicated that the NRC staff reviewers (that

reviewed and approved the original license in 1982/83) had information regarding the final

design and had accepted this final design. Additionally, NRR noted that the current design

was reflective of the accepted final design. Therefore, NRR did not have a basis to determine

that the plants design is not in accordance with its licensing basis.

The NRR staff also noted in its response that a design vulnerability exists, which could defeat

coincident logic. Specifically, the staff noted that a failure of any of the PTs would also result in

separation of the offsite power source from the safety bus. The NRR staff concluded that

modifications to the UV/DV protection system to prevent separation of the offsite power

source from the safety buses were prudent to preclude another event similar to the one that

occurred on February 11, 2016.

The licensee also identified this design vulnerability in the UV relay protection system in a

letter dated June 7, 2016 (ADAMS Accession No. ML16166A197). In this letter, the licensee

committed to modify the design of the UV/DV circuits for all three divisions to prevent a failed

fuse from satisfying the coincident logic and causing a separation of the offsite power source

from the safety bus when no UV/DV condition exists.

Specifically, the licensee has committed to installing a modification to the UV/DV protection

scheme for the division one, two and three 4.16kV safety buses that will prevent a failed fuse

from satisfying the coincident logic and causing a separation of the offsite power source from

the safety bus when no UV/DV condition exists. The design change will be implemented

during the upcoming refueling outage and completed over the next operating cycle.

NRC Inspection Manual Chapter 0611, Power Reactor Inspection Reports, defines a

performance deficiency as an issue that is the result of a licensee not meeting a requirement

or self-imposed standard where the cause was reasonably within the licensees ability to

foresee and correct, and therefore should have been prevented. The NRC has concluded

that the installed 4160-volt UV/DV detection system meets the current licensing bases, and

therefore it was not reasonable to foresee, correct, and prevent the issue since it would have

required FENOC to question the NRCs original approval of the PNPP licensing basis and

therefore is not subject to enforcement action in accordance with the NRCs Enforcement

Policy. This documents the closure of URI 05000440 /2016008-01.

Corrective Action Reference: CR 2016-04016

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public

disclosure. No proprietary information was documented in this report.

• On October 9, 2018, the inspectors presented the quarterly integrated inspection results to

Mr.

D. Hamilton, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.04Equipment Alignment

- SOI-M15; Annulus Exhaust Gas Treatment System; Revision 12

- SOI-M23/M24; MCC, Switchgear, and Miscellaneous Electrical Equipment Area HVAC

System; Revision 15

- VLI-P42; Emergency Closed Cooling; Revision 20

- VLI-R44; Division 1 and 2 Diesel Generator Starting Air System Valve Lineup Instruction;

Revision 6

- VLI-R45; Division 1 and 2 Diesel Generator Fuel Oil System (Unit 1) Valve Lineup Instruction;

Revision 5

- VLI-R46; Division 1 and 2 Diesel Generator Jacket Water Systems (Unit 1) Valve Lineup

Instruction; Revision 4

- VLI-R47; Division 1 and 2 Diesel Generator Lube Oil Valve Lineup Instruction; Revision 7

- VLI-R48; Division 1 and 2 Diesel Generator Exhaust, Intake and Crankcase Systems Valve

Lineup Instruction; Revision 6

71111.05AQFire Protection Annual/Quarterly

- FPI-0CC; Control Complex; Revision 10

- FPI-0EW; Emergency Service Water Pumphouse; Revision 6

- FPI-0IB; Intermediate Building; Revision 9

- FPI-1AB; Auxiliary Building Unit 1, Revision 4

- FPI-SB; Service Building; Revision 3

- FPI-1DG; Diesel Generator Building; Revision 8

71111.06Flood Protection Measures

- Drawing 302-0653-00000; Fuel Pool Filter Demineralizer System; Revision U

- Drawing 302-0654-00000; Fuel Pool Cooling and Clean-up System; Revision U

- Drawing 302-0738-00000; LRW - Tanks and Pumps for Handling Backwash Slurries from

Fuel Pool Filter/Demineralizer; Revision DD

- CR 2018-07685; Unexpected Fuel Pool Closed Cooling Surge Tank Level Lowering;

08/28/2018

- Drawing 302-0741-00000; Liquid Radwaste Sumps System - Laundry, Chemical and

Common Floor and Equipment Drain Sumps; Revision AA

- Drawing 911-0628-00000; Intermediate Building Drains; Revision F

- Calculation JL-083; Flooding Analysis of CCB, IB, and FHB - Floor Elevation 574-10;

Revision 3

- WO 200711677; Inspect and Dewater Safety-Related Manholes 1, 2, 3, and 4; 08/06/2018

71111.07Heat Sink Performance

- Calculation E12-089; Required ESW Flow for the RHR HXs; Revision 3

- Calculation E12-102; RHR System Heat Exchanger B Loop Performance Test Evaluation;

Revision 4

- Calculation E12-102; RHR System Heat Exchanger B Loop Performance Test Evaluation;

Revision 4; Addendum 1

- CR 2018-08003; Small Margin Remaining in RHR Heat Exchanger Loop B; 09/10/2018

- Drawing 302-0643-00000; Residual Heat Removal System; Revision CCC

- Drawing 302-0792-00000; Residual Heat Removal System; Revision PP

- PTI-E12-P0003; RHR HX B and D Performance Testing; Revision 12

- WO 200624207; PTI-E12-P0003; 05/31/2018

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

- OTLC-3058201809-PY-SGC1; Cycle 9 2018 Evaluated Scenario C1; 08/25/2018

- NOBP-TR-1151; 4.0 Crew Critique; Revision 6

- Evolution Specific Reactivity Plan; August 2018 Sequence Exchange; 07/30/2018

71111.12Maintenance Effectiveness

- CR 2018-06854; LPRM - Gain Adjust Factor Outside of Technical Specification Acceptance

Criteria Following Calibration; 08/01/2018

- Maintenance Rule System Basis Document C51 - Neutron Monitoring; Revision 0

- SVI-C51-T0027-A; APRM A Channel Functional for 1C51-K605A; Revision 13

- SVI-C51-T0030-A; APRM A Channel Calibration for 1C51-K605A; Revision 13

- SVI-C51-T0250-A; APRM A Response Time for 1C51-K605A; Revision 9

71111.13Maintenance Risk Assessments and Emergent Work Control

- CR 2018-05504; ESW Through-Wall Leak at RHR A Heat Exchanger Outlet Piping Auxiliary

Building 574 Foot Elevation; 06/13/2018

- CR 2018-06921; Emergency Service Water Pump B Oil Leakage; 08/04/2018

- CR 2018-07276; As-Found Condition of ESW Pump B for Oil Leak Condition; 08/16/2018

- CR 2018-07410; As-Found Condition for ESW B Breathers; 08/21/2018

- CR 2018-08510; Division 1 Diesel Generator Trip While Paralleling to the Grid; 09/26/2018

- CR 2018-08511; Abnormal Plant Response Following Electrical Transient; 09/26/2018

- CR 2018-08541; NRC ID: Bent Tubing Discovered on Division 1 Diesel Generator;

09/27/2018

- CR 2018-08546; Division 1 Diesel Generator Air Gaps Found Greater than Allowable

Variance; 09/27/2018

- Drawing 208-0206-00053; 4.16KV Standby Diesel Brk. EH1102 Protective Relaying; Revision

CC

- NOP-OP-1007; Risk Management; Revision 27

- NOP-WM-1001; Order Planning Process; Revision 29

- PAP-1924; Risk-Informed Safety Assessment and Risk Management; Revision 9

- PMI-0096-A; Division 1 Standby Diesel Generator Electrical Maintenance; Revision 5

- WO 200585392; Diesel Generator 1 Perform Generator Inspection; 12/18/2017

- WO 200701673; Megger Division 1 Diesel Generator per PMI-0096-A; 12/11/2017

- WO 200761606; Perform Simple Troubleshooting Plan of ESW B Motor Oil Leakage;

08/16/2018

71111.15Operability Determinations and Functionality Assessments

- ARI-H13-P601-0020-A6; Residual Heat Removal A Out of Service; Revision 21

- ARI-H13-P601-0021-D6; Low Pressure Core Spray Out of Service; Revision 15

- CR 2018-05504; ESW Through-Wall Leak at RHR A Heat Exchanger Outlet Piping Auxiliary

Building 574 Foot Elevation; 06/13/2018

- CR 2018-05997; Received Unexpected RHR A Out of Service Alarm; 06/30/2018

- CR 2018-06205; Emergency Service Water Pipe Exceeded Minimum Wall Thickness -

Localized Wall Thinning; 07/10/2018

- CR 2018-06615; RCIC Suppression Pool Suction Valve did not Stroke on the First Attempt;

07/24/2018

- CR 2018-06788; NRC ID: SVI-E51-T2001 Valve Stroke Timing of the Suppression Pool

Suction Valve 1E51F0031 - Precaution and Limitation 15 not Initially Followed; 07/24/2018

- CR 2018-06921; Emergency Service Water Pump B Motor Oil Leakage; 08/04/2018

- CR 2018-07276; As-Found Condition of ESW Pump B For Oil Leak Condition; 08/16/2018

- CR 2018-07277; Stripped Cover Bolt Motor Upper Reservoir Cover of the Emergency Service

Water Pump; 08/08/2018

- NOP-OP-1009; Operability Determinations and Functionality Assessments; Revision 8

71111.18Plant Modifications

- Advance Change Notice 13-0802-006; Door Barrier; Revision 0

- CR 2013-05625; Calculation for Minor Stream Cannot be Located; 04/11/2013

- CR 2013-07852; Closure Items Not Addressed in CR 2013-05625 Investigation Problem

Statement; 05/20/2013

- CR 2015-08036; Prompt Functionality Assessment Needed for Site Flooding Issues;

06/08/2015

- ECP 0212-001; Site Flooding Sand Bags Temporary Modification; Revision 0

- ECP 0212-002; Site Flooding Sand Bags Temporary Modification - Removal Package;

Revision 1

- ECP 0212-003; Modification Compensatory Measures for Flooding Prompt Functionality

Assessment; Revision 0

- ONI-ZZZ-1; Tornado or High Winds; Revision 30

71111.19Post Maintenance Testing

- WO 200594426; High Pressure Core Spray Condensate Storage Tank Suction Valve Static

Motor Operated Valve Test; 08/15/2018

- WO 200718804; SVI-C41T2001B Standby Liquid Control B Pump and Valve Operability Test;

08/02/2018

- WO 200757942; ECP 18-0158-001 Repair Leak - ESW Piping; 08/22/2018

- SOI-P45/P49; Emergency Service Water and Screen Wash Systems; Revision 32

71111.22Surveillance Testing

- CR 2018-06590; Issues Encountered during the Performance of SVI-E51-T2001; 07/24/2018

- SVI-C11-T1006; Control Rod Maximum Scram Insertion Time; Revision 23

- SVI-E12-T2003; RHR C Pump and Valve Operability Test; Revision 31

- WO 200689395; SVI-C61T1200 (24M) Remote Shutdown Control Test - RCIC and RHR;

07/25/2018

- WO 200718796; SVI-E51T2001 RCIC Pump and Valve Operability Test; 07/24/2018

71151Performance Indicator Verification

- NOBP-LP-4012; NRC Performance Indicators; Revision 6

- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)

and Unreliability Index (URI) for Heat Removal System (RCIC); July 2017 through June 2018

- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)

and Unreliability Index (URI) for Residual Heat Removal (RHR); July 2017 through June 2018

- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)

and Unreliability Index (URI) for Emergency Service Water (ESW); July 2017 through

June 2018

71152Problem Identification and Resolution

- ARI H13-P877-0001-A3; Fuel Storage Tank Level Low (7 Day Level); Revision 14

- ARI H13-P877-0001-A3; Fuel Storage Tank Level Low (1 Day Level); Revision 14

- CR 2003-03033; Through Wall Leak in ESW A Piping Between Valves 1P45F0550A and

1P45F0068A; 05/07/2003

- CR 2011-00861; Division 2 Fuel Storage Tank Level; 08/21/2011

- CR 2011-90473; Division 2 Diesel Generator Fuel Oil Storage Tank Level did not Pass

Channel Check; 03/05/2011

- CR 2017-08106; ESW B Piping Through Wall Leak to ECC HX B; 08/04/2017

- CR 2017-08581; P45 Piping Thru Wall Pin Hole Leak; 08/18/2017

- CR 2018-01035; PA-PY-18-01: Engineering Has Not Developed an Effective Failure

Assessment and Monitoring Plan for Safety Related Piping Systems; 02/05/2018

- CR 2018-03269; Commitment and Accountability to the Perry Housekeeping Program Needs

to be Strengthened Across the Site; 04/10/2018

- CR 2018-03308; PA-PY-18-02: Housekeeping Elevation Letter; 04/11/2018

- CR 2018-04447; Dose Alarm Received during Fuel Pool Filter Demineralizer Evolution;

05/12/2018

- CR 2018-05153; Division 2 DG Fuel Oil Storage Tank Level Indicator 1R45-R0191B Appears

to be Failing; 06/02/2018

- CR 2018-05504; Emergency Service Water (ESW) A Through-Wall Pipe Leak at RHR A HX

Outlet Piping, Aux 574 E; 06/13/2018

- CR 2018-06205; Emergency Service Water Pipe Exceeded Minimum Wall Thickness -

Localized Wall Thinning; 05/01/2018

- CR 2018-06615; RCIC Suppression Pool Suction Valve did not Stroke on the First Attempt;

07/24/2018

- CR 2018-06788; NRC ID: SVI-E51-T2001 Valve Stroke Timing of the Suppression Pool

Suction Valve 1E51F0031 - Precaution and Limitation 15 Not Initially Followed; 07/24/2018

- CR 2018-06869; Water Found in Access Space for Division 2 Diesel Generator Level

Transmitter; 08/02/2018

- CR 2018-06886; Employee Opened a Protected Area Portal without Security Present;

08/02/2018

- CR 2018-08066; Dose Alarm Received by Supplemental Personnel; 09/12/2018

- CR 2018-08068; MG Dose Alarm Received by Individual; 09/12/2018

- CR 2018-08483; NRC ID: Code Case N-513-3 Interpretation; 09/26/2018

- CR 2018-08694; Affinity Analysis of Recent Perry Site Incidents Related to Human

Performance and Leadership Engagement of Workforce Fundamental Behaviors; 10/03/2018

- DSP-P45; ASME Design Specification for ESW System; Revision 5

- NOP-ER-2005; Flow Accelerated Corrosion Management Program; Revision 6

- NOP-ER-2006; Service Water Reliability Management Program; Revision 4

- SOI-R45; Division 1 and 2 Diesel Generator Fuel Oil System; Revision 17

- WO 200758330; EC-71 Cycle 17 Final Package; 07/07/2018

18