IR 05000440/2004010

IR 05000440-04-010(DRS); 08/09/2004 - 08/27/2004; Perry Nuclear Power Plant, Unit 1; Combined Biennial Engineering Inspections of Routine Evaluations of Changes, Tests, or Experiments and Routine Permanent Plant Modifications Concurrent wit

ML042820605
Person / Time
Site:	Perry
Issue date:	10/08/2004
From:	Julio Lara NRC/RGN-III/DRS/EEB
To:	Myers L FirstEnergy Nuclear Operating Co
References
IR-04-010
Download: ML042820605 (33)

Text

ber 8, 2004

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1 NRC COMBINED BIENNIAL ENGINEERING INSPECTIONS INSPECTION REPORT 05000440/2004010(DRS)

Dear Mr. Myers:

On August 27, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed combined biennial engineering inspections at your Perry Nuclear Power Plant, Unit 1. The enclosed report documents the inspection findings, which were discussed on August 27, 2004, with you and other members of your staff.

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

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

The combined inspections focused on the: (1) evaluations of changes, tests or experiments; (2) permanent plant modifications; and (3) safety system design and performance capability (SSDPC) of selected systems. Specifically, the SSDPC portion of the inspection focused on the design and performance capability of the emergency diesel generators and the high pressure core spray system to ensure that they were capable of performing their required safety-related functions.

Based on the results of this inspection, no findings of significance were identified. However, a licensee-identified violation which was determined to be of very low safety significance is listed in Section 4OA7 of this report.

L. Meyers -2-In accordance with 10 CFR Part 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Julio F. Lara, Chief Electrical Engineering Branch Division of Reactor Safety Docket No. 50-440 License No. NPF-58 Enclosure: Inspection Report 05000440/2004010(DRS)

w/Attachment: SUPPLEMENTAL INFORMATION See Attached Distribution

SUMMARY OF FINDINGS

IR 05000440/2004010(DRS); 08/09/2004 - 08/27/2004; Perry Nuclear Power Plant, Unit 1;

Combined Biennial Engineering Inspections of Routine Evaluations of Changes, Tests, or Experiments and Routine Permanent Plant Modifications concurrent with the Safety System Design and Performance Capability (SSDPC) Inspection.

This report covers announced combined biennial engineering inspections of evaluation of changes, tests, or experiments and permanent plant modifications concurrent with the SSDPC inspection. The inspection was conducted by five Region III inspectors and two mechanical engineering contractors. The inspection focused on the design and performance capability of the emergency diesel generators and the high pressure core spray system to ensure that they were capable of performing their required safety-related functions.

A. Inspector-Identified and Self-Revealed Findings

Cornerstone: Initiating Events

No findings of significance were identified.

Cornerstone: Mitigating Systems

No findings of significance were identified.

Cornerstone: Barrier Integrity

No findings of significance were identified.

Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the licensees corrective action tracking number is listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The plant operated at or near full power throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R02 Evaluations of Changes, Tests, or Experiments

.1 Review of 50.59 Evaluations and Screenings

a. Inspection Scope

The inspectors reviewed five evaluations performed pursuant to 10 CFR Part 50.59.

The evaluations related to permanent plant modifications, setpoint changes, procedure changes, conditions adverse to quality, and changes to the updated final safety analysis report. The inspectors confirmed that the evaluations were thorough and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 10 screenings where the licensee had determined that a 10 CFR Part 50.59 evaluation was not necessary. In regard to the changes reviewed where no 10 CFR Part 50.59 evaluation was performed, the inspectors verified that the changes did not meet the threshold to require a 10 CFR Part 50.59 evaluation. These evaluations and screenings were chosen based on risk significance of samples from the different cornerstones.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

.1 Review of Recent Modifications

a. Inspection Scope

The inspectors reviewed five permanent plant modifications that had been installed within the last two years. The modifications were chosen based upon their affecting systems that had high probabilistic risk analysis (PRA) significance in the licensees Individual Plant Evaluation (IPE) or high maintenance rule safety significance. The inspectors reviewed the modifications to verify that the completed design changes were in accordance with the specified design requirements and the licensing bases and to confirm that the changes did not affect any systems safety function. Design and post-modification testing aspects were verified to ensure the functionality of the modification, its associated system, and any support systems. The inspectors also verified that the modifications performed did not place the plant in an increased risk configuration.

b. Findings

No findings of significance were identified.

1R21 Safety System Design and Performance Capability

Introduction:

Inspection of safety system design and performance capability (SSDPC)verifies the initial design and subsequent modifications and provides monitoring of the capability of the selected systems to perform design basis functions. As plants age, the design bases may be lost and important design features may be altered or disabled.

The plants risk assessment model was based on the capability of the as-built safety system to perform the intended safety functions successfully. This inspectable area verifies aspects of the mitigating systems cornerstone for which there are no indicators to measure performance.

The objective of the SSDPC inspection was to assess the adequacy of calculations, analyses, other engineering documents, and operational and testing practices that were used to support the performance of the selected systems during normal, abnormal, and accident conditions.

The systems and components selected were the emergency diesel generators (EDGs)and the high pressure core spray (HPCS) system. These systems were selected for review based upon:

• having a high probabilistic risk analysis ranking;

• having had recent significant issues;

• not having received recent NRC review; and

• being interacting systems.

The criteria used to determine the acceptability of the systems performance was found in documents such as:

• applicable technical specifications (TS);

• applicable updated safety analysis report (USAR) sections; and

• the systems' design documents.

The following system and component attributes were reviewed in detail:

System Requirements Process Medium - water, air, electrical signal; Energy Source - electrical power, steam, air; Control Systems - initiation, control, and shutdown actions; Operator Actions - initiation, monitoring, control, and shutdown; and Heat Removal - cooling water and ventilation.

System Condition and Capability Installed Configuration - elevation and flow path operation; Operation - system alignments and operator actions; Design - calculations and procedures; and Testing - level, flow rate, pressure, temperature, voltage, and current.

Component Level Equipment/Environmental Qualification - temperature and radiation; and Equipment Protection - fire, flood, missile, high energy line breaks (HELBs), freezing, heating, ventilation, and air conditioning.

.1 System Requirements

a. Inspection Scope

The inspectors reviewed the USAR, TS, system descriptions, drawings and available design basis information to determine the performance requirements of the EDGs and the HPCS system. The reviewed system attributes included process medium, energy sources, control systems, operator actions and heat removal. The rationale for reviewing each of the attributes was:

Process Medium: This attribute required review to ensure that the selected systems flow paths would be available and unimpeded during and following design basis events.

To achieve this function, the inspectors verified that the systems would be aligned and maintained in an operable condition as described in the plants USAR, TS and design bases.

Energy Sources: This attribute required review to ensure that the selected systems motive and/or electrical source would be available and/or adequate and unimpeded during and following design basis events, that appropriate valves and system control functions would have sufficient power to change state when required. To achieve this function, the inspectors verified that the interactions between the systems and their support systems were appropriate such that all components would operate properly when required.

Controls: This attribute required review to ensure that the automatic controls for operating the systems and associated systems were properly established and maintained. Additionally, review of alarms and indicators was necessary to ensure that operator actions would be accomplished in accordance with design requirements.

Operations: This attribute was reviewed because the operators perform a number of actions during normal, abnormal and emergency operating conditions that have the potential to affect the selected systems operation. In addition, the emergency operating procedures (EOPs) require the operators to manually realign the systems flow paths during and following design basis events. Therefore, operator actions play an important role in the ability of the selected systems to achieve their safety-related functions.

Heat Removal: This attribute was reviewed to ensure that there was adequate and sufficient heat removal capability for the selected systems.

b. Findings

No findings of significance were identified.

.2 System Condition and Capability

a. Inspection Scope

The inspectors reviewed design basis documents and plant drawings, abnormal and emergency operating procedures, requirements, and commitments identified in the USAR and TS. The inspectors compared the information in these documents to applicable electrical, instrumentation and control, and mechanical calculations, setpoint changes and plant modifications. The inspectors also reviewed operational procedures to verify that instructions to operators were consistent with design assumptions.

The inspectors reviewed information to verify that the actual system condition and tested capability was consistent with the identified design bases. Specifically, the inspectors reviewed the installed configuration, the system operation, the detailed design, and the system testing, as described below.

Installed Configuration: The inspectors confirmed that the installed configuration of the EDG and HPCS systems met the design basis by performing detailed system walkdowns. The walkdowns focused on the installation and configuration of piping, components, and instruments; the placement of protective barriers and systems; the susceptibility to flooding, fire, or other environmental concerns; physical separation; provisions for seismic and other pressure transient concerns; and the conformance of the currently installed configuration of the systems with the design and licensing bases.

Operation: The inspectors performed procedure walk-throughs of selected manual operator actions to confirm that the operators had the knowledge and tools necessary to accomplish actions credited in the design basis.

Design: The inspectors reviewed the mechanical, electrical and instrumentation design of the EDG and HPCS systems to verify that the systems and subsystems would function as required under accident conditions. The review included a review of the design basis, design changes, design assumptions, calculations, boundary conditions, and models as well as a review of selected modification packages. Instrumentation was reviewed to verify appropriateness of applications and set-points based on the required equipment function. Additionally, the inspectors performed limited analyses in several areas to verify the appropriateness of the design values.

Testing: The inspectors reviewed records of selected periodic testing and calibration procedures and results to verify that the design requirements of calculations, drawings, and procedures were incorporated in the system and were adequately demonstrated by test results. Test results were also reviewed to ensure automatic initiations occurred within required times and that testing was consistent with design basis information.

b. Findings

No findings of significance were identified.

.3 Components

a. Inspection Scope

The inspectors examined the EDG and HPCS systems associated pumps, motor operated valves, heat exchangers and instrumentation to ensure that component level attributes were satisfied.

Equipment/Environmental Qualification: This attribute verifies that the equipment was qualified to operate under the environment in which it was expected to be subjected to under normal and accident conditions. The inspectors reviewed design information, specifications, and documentation to ensure that the EDG and HPCS systems were qualified to operate within the temperatures and radiation fields specified in the environmental qualification documentation.

Equipment Protection: This attribute verifies that the EDG and HPCS systems were adequately protected from natural phenomenon and other hazards, such as HELBs, floods or missiles. The inspectors reviewed design information, specifications, and documentation to ensure that the systems were adequately protected from those hazards identified in the USAR, which could impact the systems ability to perform their safety function.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Condition Reports

a. Inspection Scope

The inspectors reviewed a sample of problems associated with the EDG and HPCS systems that were identified and entered into the corrective action program by the licensee. The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, condition reports written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspection team are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. Myers and other members of licensee management at the conclusion of the inspection on August 27, 2004. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

No interim exits were conducted.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a Non-Cited Violation.

.1 Calculation Post-It-Notes

The licensees program for the control of calculations was described in Nuclear Operating Administrative Procedure NOP-CC-3002, "Calculations," Revision 1. The procedure allowed the use of a Post-It-Note (PIN), which was defined in Sections 3.15 and 4.3, as a request or reminder that some minor change should be incorporated into the next revision of the calculation. The PIN was to make administrative only changes to a calculation and was not to have an impact upon the technical content or results/conclusions of the calculation. The use of a PIN was a FENOC-wide practice and required no independent reviewer and/or management approval to issue.

The inspection team identified numerous examples where the PIN process was inappropriately used to flag/indicate changes to calculations. These examples were not administrative only changes, but involved technical issues potentially impacting the calculations technical content or results/conclusions. The licensee also identified the PIN as a problem area in their self-assessment titled Interim Report FENOC-SA-04-01, Assessment of Engineering Programs Effectiveness Perry, Beaver Valley, and Davis-Besse Plants, dated August 5, 2004, but the extent of the inappropriate use of the PIN was not initially recognized.

Condition Report 04-04405, Engineering Focused Self-Assessment FENOC-SA-04-01, Review Engineering Programs, dated August 26, 2004, identified the PIN process as not being correctly implemented and had the potential for changing plant design without appropriate reviews. The CR was initially categorized as a condition report not adverse to quality. However, as a result of subsequent discussions with the inspection team, the licensee revised the CRs category. In CR 04-04405, CA Numbers 1 and 2 dated August 29, 2004, the licensee revised the corrective action category to a condition adverse to quality and issued Memorandum DES/04-0041 dated August 26, 2004, which stated that the use of PINs per NOP-CC-3002, Section 4.3 shall only be used if authorized, reviewed, and approved by a PNED DES Unit Supervisor or above. This memorandum was issued to all PNED personnel and design consultants. In CA Number 2, the licensee initiated a review of all PINs for compliance with NOP-CC-3002.

Title 10 CFR Part 50, Appendix B, Criterion 3, Design Control, states, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews. As described in CR 04-04405 and CR 04-03848, Inappropriate Use of Post-It-Note (PIN) for Calculations, dated July 24, 2004, the licensee identified examples where the PIN process was inappropriately used and potentially impacted the calculations technical content or results/conclusions. As a result, the licensee failed to provide adequate design control measures for verifying or checking the adequacy of design, such as by the performance of design reviews to ensure that the plants design basis was maintained.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Carpenter, Design Engineering

P. Chatterjee, Design Engineering

V. Higoki, Regulatory Affairs

T. Hilston, Design Engineering

C. Kuester, Design Engineering

T. Lentz, Engineering Director

J. Maloney, Design Engineering

J. Morehouse, Plant Systems Engineering

L. Myers, Chief Operating Officer

W. OMalley, Maintenance Director

H. Reppert, Design Engineering

K. Russell, Regulatory Affairs

R. Stadel, Procurement Engineering

A. Watkins, Design Engineering

J. Zarea, Design Engineering

Ohio Department of Public Safety

J. Wills, Radiation Analyst

Nuclear Regulatory Commission

R. Powell, Senior Resident Inspector

J. Ellegood, Resident Inspector

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Closed

None.

Discussed

None.

Attachment